1. What do you mean by “shared Internet resources”?
TekSavvy provides Internet access. Providing Internet access means making use of shared network resources: the Internet is all about aggregating traffic on shared links, and processing it through shared routing resources.
One of the things that makes the Internet awesome is that it puts very few restrictions on what end-users do with their Internet access. That openness, which some people call the “end-to-end principle”, gives everyone the freedom to innovate and interact without having to ask permission. It also gives them full access to use as much or as little as they need of those shared Internet resources. Someone who needs more of the shared upstream link will open more sessions in order to demand more of it. Someone who needs less will open fewer sessions and demand less. The Internet is, quite literally, based on sharing.
2. Why do you need a policy on shared Internet resources?
We have always had to decide how to manage our shared Internet resources. Until recently, though, we didn’t have a formal policy on how to do so. We did employ a range of measures, like time-of-day incentives and a focus on domestic interconnection. But the centerpiece of our unwritten policy was a very simple concept: provision all the upstream bandwidth we need to minimize congestion.
There were two problems with that policy.
First, it’s not sustainable. No matter how much bandwidth we provision, unusual network events like a new Netflix release or a major new download can and, in many cases, will congest it. Put simply, Internet traffic is growing very, very quickly; peak usage events are shooting past average levels by greater and greater degrees; and every user always has the ability to command extra resources by opening multiple parallel sessions. All of that has the potential to degrade end-users’ experiences significantly and increasingly, especially when those experiences involve real-time applications like voice-over-IP or streaming media.
Second, even were it possible to provision enough upstream bandwidth that no network event and no user behaviour could saturate it, it wouldn’t be sustainable, because that approach is expensive in a way that wastes resources. “Throw more bandwidth at it” is an easy policy to implement, but it forces every user to chip in for all of the bandwidth needed to handle the activity of any user.
That is especially hard to sustain when bandwidth is extremely costly. For some years now, TekSavvy has argued that the mandated bandwidth rates we pay to wholesale network access providers have been set far too high. Those wholesale rates are divided into two parts. One is the access part. The other is, in most cases, the size of our point of interconnection with the wholesale carrier, which determines how much capacity gets to the access part – and varies from $10.36 monthly per Mbps (Bell Canada), to $11.81 (Cogeco), to $14 (Rogers), to $20.31 (Videotron).
From 2016 to 2019, the CRTC undertook a comprehensive review of both access rates and bandwidth rates at the point of interconnection. In Telecom Order 2016-396, the CRTC lowered capacity rates on an interim basis to ensure that interim rates were not based on overstated costs, as it was concerned that wholesale providers’ cost studies were not conducted in accordance with costing principles. The CRTC lowered capacity rates to $1.4908 monthly per Mbps (Bell Canada), to $3.2373 (Cogeco), to $3.1968 (Rogers), to $3.9536 (Videotron). They set final capacity and access rates in August 2019 that would be sustainable for competition, but the large carriers have appealed that decision. We’re fighting those appeals, but it is a slow process. In the meantime, the cost of bandwidth remains high (not to mention the impact of covid19), usage continues to go up, and simply throwing more bandwidth at our shared resources may not be sustainable without either hiking prices significantly or managing the capacity we do have in a smarter way.
The SIR Policy is TekSavvy’s attempt to develop a smarter way to do things when the network gets congested during the download day (8 a.m. to 2 a.m.) period. As of August 2020, TekSavvy has not implemented the SIR Policy. That being said, some measures are in place that may affect our customers’ usage, including port blocking for security and traffic management measures imposed by our underlying carriers.
3. Okay, so who is affected by the SIR Policy?
TekSavvy is committed to making sure we always provision enough shared bandwidth to serve end-users under ordinary circumstances. That remains the centerpiece of our SIR Policy. Now, though, the SIR Policy also adds two layers of best-efforts traffic management to congested periods that occur during the 8 a.m. to 2 a.m. period, in order to make sure we keep user experience great and prices low.
First, we will take steps to make sure that on the rare occasions where there is congestion, it least affects the most real-time protocols, like voice-over-IP and streaming media. Instead, less-real-time applications, like peer-to-peer file transfers, will be more likely to be affected. From what we have seen, even less-real-time applications will not be much affected. Few users—if any—should see any perceptible change in their experience, and more users will see a positive improvement in the use of real-time applications in congested circumstances. A little bit of management can go a very long way.
Second, even when congestion does occur, slightly affecting less-real-time applications, it is those who have used the most bandwidth that day whose use of those applications will be the first to be affected by these measures.
We will continue to do our best to make sure that there is no congestion at all. Most of the time, we have been successful. But we are now also acknowledging that, no matter what we do, unusual events or behaviour may cause congestion – and we are working to ensure that, in those circumstances, user experience and user costs are affected as little as possible.
4. When will the SIR Policy be in effect?
The SIR Policy is not yet implemented. As explained above, in October 2016, the CRTC lowered capacity rates on an interim basis to ensure that interim rates were not based on overstated costs, as it was concerned that wholesale providers’ cost studies were not conducted in accordance with costing principles. In January 2017, TekSavvy reduced its pricing for almost all existing customers based on these interim rate reductions. In August 2019, the CRTC set final rates but the big carriers appealed that decision. As long as those appeals are underway, TekSavvy continues to pay inflated rates. TekSavvy is awaiting those wholesale rates to be finalized to determine how to proceed with implementing the SIR Policy.
Our plan was to phase in the SIR Policy gradually. We had intended to first apply the SIR Policy on our highest-cost-bandwidth platforms, Rogers and Videotron, on December 1, 2015, and provided advance notice to all end-users that would be affected by the first phase of the SIR Policy.
We do not expect the SIR Policy to be implemented prior to September 2020. If we do implement it, we expect to do so first on the Rogers and Videotron access platforms.
In subsequent phase, the SIR Policy could apply to service provisioned over our other platforms: Cogeco, Shaw, Bell, and TELUS. We will notify affected end-users well in advance of implementing the policy to these platforms, so that you always know how you are affected.
In the same way, as more detailed implementation is logged, we will document it in greater depth.
5. When the SIR Policy leads to traffic management, what kind of traffic does it affect?
Traffic management will only take place during the ordinary download day of 8 a.m. to 2 a.m. and, within that period, only when a network is congested. In those circumstances, first to be affected will be the use of less-real-time protocols, by those who have made the greatest use of shared network resources that day. We do not expect anyone to be significantly affected: but that is the sequence in which it will occur.
6. How does the SIR Policy affect TekSavvy end-users’ Internet experiences?
We expect that it will improve most end-users’ experiences, allow us to stabilize pricing, and lower the cost of most unlimited packages.
The SIR Policy calls for traffic management only when there is congestion on a network during the 8 a.m. to 2 a.m. period. Even then, the traffic management affects only those who have made the heaviest use of the network over the course of that day. And even then, the traffic management seen by those users is further restricted to the least-real-time traffic that is least sensitive to millisecond timing. None of these measures involves any rate-limiting or speed caps.
For most end-users, those changes will mean better access to shared Internet resources for real-time applications like voice-over-IP and streaming media. A very small subset of our user base will ever experience traffic management – and many of them are not likely to notice it.
7. I’m not really feeling the traffic management piece of your SIR Policy. Can I opt out?
Please know that our traffic management measures are as non-invasive and non-intrusive as we can possibly make them. However, once the SIR Policy is in effect, users with capped packages, and who’d otherwise be subject to emergency traffic management if peak-period congestion happens, can opt out in exchange for a $5 monthly fee. At present, we only contemplate turning on this kind of congestion management on our highest-cost-bandwidth access platforms (Rogers and Videotron), so it only makes sense to opt out if your Internet is provisioned on one of those access platforms. If your service is provisioned over the Rogers or Videotron access platform, you can opt out by calling us at 1-877-779-1575 or through MySavvy (mysavvy.teksavvy.com). We’ll roll out the opt-out functionality across other access platforms, at the same pace as we roll out any required traffic management itself.
Now, recall that one of the reasons we have implemented this formal SIR Policy is to get smarter about how we control shared costs, in order to be fair to our whole user base: hence the charge. For that reason, users with unlimited packages will not have the ability to opt out of traffic management.
8. But then what happened to Zap the Cap?
We phased out the Zap the Cap option that allowed users to turn their capped plans into unlimited plans in exchange for accepting slower-at-peak speeds. Instead, we dropped the price of some of our unlimited plans significantly. Even without implementing it, a smarter SIR Policy let us do that.
9. I thought TekSavvy was all about net neutrality.
We are. Back in 2008, TekSavvy organized a rally on Parliament Hill in support of network neutrality. Our views haven’t changed. We’re simply an intermediary, and we have no business telling our users what to do or snooping on what you actually do. We haul bits to and from end-users, in as neutral a fashion as possible.
But that doesn’t mean we want to charge you higher prices than we need to, nor cause users of real-time applications to experience congestion when they don’t have to. Our SIR Policy formalizes our approach to optimizing those things. TekSavvy’s measures are applied only where necessary, and look only at classes of traffic. We don’t look at content, don’t look at where traffic is coming from, and don’t look at where it’s headed.
10. What are the privacy implications—does this mean TekSavvy is tracking, retaining, or reporting what I do on the Internet?
At TekSavvy, we take privacy very seriously. We have no interest in tracking what you do. We have no interest in looking at any of the content that passes over your network. We certainly have no interest in monitoring your online activities. While we respect all of our legal obligations, we’re an intermediary. That’s all.
We do measure your traffic volume, because we make capped plans available as well as unlimited ones. We do analyze protocols at the aggregate level, because we want to make sure congestion doesn’t cripple real-time applications, and that we don’t waste money buying bandwidth we don’t need. But all of that analysis is done on the fly, and discarded immediately. It’s none of our business.
11. Is there any other traffic management that TekSavvy end-users should know about?
Yes.
First, on all TekSavvy networks, we block traffic associated with three ports, 25 (outbound), 53 (inbound), and 1900 (inbound), which are typically associated with network attacks. Outbound port 25 traffic, associated with TCP SMTP communications, is vulnerable to concurrent connection attacks and spam abuse, so only connections to TekSavvy’s SMTP server are permitted. Inbound port 53 traffic, associated with UDP DNS server communications, is vulnerable to DNS denial-of-service and related attacks. Inbound port 1900 traffic, associated with Microsoft’s Simple Service Discovery Protocol, is similarly vulnerable to a range of distributed DOS-style attacks. If you have a specific requirement requiring that these ports be maintained open, please contact us.
Second, TekSavvy is being forced by a court order to block access to certain domain names and IP addresses associated with a video streaming service called GoldTV. TekSavvy is appealing that order, but in the meantime we are required to block certain sites. When TekSavvy customers try to access a blocked page, they are redirected to a page with information about the court order and a current list of the blocked sites.
Third, most of our end-users are provisioned over wholesale network access acquired from third-party carriers. In most cases, the CRTC requires third-party carriers disclose in their wholesale access tariffs the technical Internet traffic management practices (ITMPs) they apply to wholesale services. Wholesale-based providers like TekSavvy are, in turn, required to provide their retail customers with information about those technical ITMPs. In keeping with this requirement, we outline the traffic management practices which our third-party carriers apply to the wholesale services we purchase, based on their wholesale access tariffs as of 22 July 2020. Because most third-party carriers have chosen to deliver wholesale network access at the Internet layer, our end-users are necessarily subject to the following traffic management practices of their underlying carrier described below:
- Bell does not indicate in their tariff that they
apply any technical Internet traffic management practices to their wholesale
network access services. - Cogeco does not indicate in their tariff that
they apply any technical Internet traffic management practices. Cogeco
indicated in November 2016 that they stopped applying technical Internet
traffic management in 2010. Since then, they have not notified us of any new
Internet traffic management practices. - Rogers introduced a technical ITMP to its tariff in
May of 2020. The tariff describes the ITMP
vaguely as a temporary constraint of an end-user’s access to shared resources,
regardless of the application used, that would present itself as a restriction
of Internet speeds and is applicable only during times of emergency or high
demand. The tariff goes on to say that
only end-users, including wholesale TPIA end-users such as TekSavvy’s, who disproportionately
consume shared resources may have their service affected by this ITMP. Rogers
later advised, through filings with the CRTC, that it began testing ITMPs
similar to that described above as early April 13, 2020. Rogers has disclosed
that they are deploying a traffic management measure to customers’ upload
traffic on wireline Internet service plans with a maximum upload speed of 10
Mbps or higher should a customer engage in a volume of upload activity over a
sustained period of time such that it negatively impacts, or is likely to
negatively impact, the Internet experience of other customers. The traffic management measure temporarily
reduces a customers’ maximum upload speeds. - Shaw states in their tariff that their retail
and wholesale network access services are equally subject to Internet traffic
management practices to address upstream congestion. This practice is applied
while standard network expansion activities are undertaken to increase
bandwidth availability. In the event of significant network congestion on a
node, Shaw may reduce upstream bandwidth allotted to P2P applications to 80
Kbps per end-user. They further specify that their technical traffic management
practices “are not applied to downstream data transfer, real-time interactive
or time-sensitive Internet applications.” - TELUS does not indicate in their tariff that they apply
any technical Internet traffic management practices to their wholesale network
access services. - Videotron'stariff indicates that its
wholesale network access is, at speeds of 20 Mbps upload speeds or higher
(managed tiers), subject to measures that Videotron has explained are to
prevent users from congesting shared “upload channels”. Every 15
minutes, a system checks the usage rate for each upload channel. If
the usage rate has reached a threshold beyond which congestion is imminent, the
system identifies the 20 Mbps, 30 Mbps, and 50 Mbps upload managed tier modems
on that channel that have uploaded a statistically significant amount of data.
Depending on the severity and duration of the congestion, uploading speed may
be slowed for these modems. When the amount of data uploaded by the modem is
diminished or the transmission of data goes back to a rate that does not cause
congestion, uploading will return to its usual priority. According to
Videotron, these measures are applicable at all times. - Eastlink’s tariff indicates that it has implemented
technical ITMPs to address congestion caused by non real-time and/or latency
insensitive traffic through the use of deep packet inspection equipment. It further explains that these ITMPS are
time-of-day sensitive to accommodate fluctuating network traffic levels and apply
to both retail and TPIA end-users like TekSavvy.
Finally, while carriers are generally required to provide notice of ITMPs, there is an exception for ITMPs that are necessary to protect network integrity against unpredictable and temporary surges in traffic. Those ITMPs are not required to be disclosed to end-users or even to third-party providers like TekSavvy. In either of those circumstances, TekSavvy would be unable to provide its end-users information about those technical ITMPs unless the third-party carrier chose to disclose the ITMPs’ application despite having no requirement to do so.
- During the covid19
pandemic, Shaw made TekSavvy aware that it was applying a temporary ITMP in Lillooet,
British Columbia in response to network congestion to protect the integrity of
its network and to ensure proportional network access for all end users in that
area. - Rogers submitted to the
CRTC that its technical ITMPs outlined above were also applied during a time of
emergency and unpredictable traffic patterns and therefore did not require
disclosure however, TekSavvy and others challenged Rogers’ position.
