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Industry Advocacy
Sandvine actively advocates on a number of key issues that affect the deployment of “intelligent broadband networks” globally, and has participated in formal proceedings on industry issues like network neutrality, online privacy, bill shock and usage-based billing.
- Network Neutrality
- Online Privacy
- Bill Shock
- Usage-based Billing for Wholesale Internet Service Providers (ISPs)
When discussion heats up on regulatory or legislative issues that affect the industry, look for Sandvine’s initial thoughts on The Better Broadband Blog. Sandvine’s Better Broadband Blog provides timely information, analysis and commentary on all topics that relate to making the Internet better; for consumers, content and application developers and, for the broadband and mobile data service providers who aim to provide the best quality of experience.
Network Neutrality: An Unmanaged Network is Not a Neutral Network
The concept of “network neutrality” is being discussed by telecommunications regulators and legislators globally, despite any universally accepted definition of the concept. In Sandvine’s context, network neutrality relates to how service providers can manage the traffic in their networks (e.g. to mitigate congestion, reduce malicious traffic, or deliver the expected quality of experience for time-sensitive applications), and to the types of service plans that operators can offer, which in turn affect the way Sandvine can deliver solutions.
The network neutrality debate has come a long way since it erupted in the United States in 2008. Originally, there was the question of whether a service provider could manage traffic at all. Today, that question has largely gone away as, broadly speaking, the notion of “reasonable network management” is now enshrined as a key part of a neutral network, rather than seen as a challenge to it. It is largely accepted that an unmanaged network is not a neutral network. Left unmanaged, a few applications and users can dominate network resources to the detriment of many.
The latest rules put forward by the Federal Communications Commission in the United States recognize the notion of reasonable network management and the need for reasonable discrimination of network traffic. The rules also recognize the importance of transparency of service terms for users and that service tiers based on subscriber usage levels can be reasonable.
In the European Union (EU), rules established in 2009 (and effective May 2011) require member states’ telecoms regulatory authorities to promote the ability of Internet users "to access and distribute information or run applications and services of their choice". There are also requirements concerning transparency (e.g. any restrictions limiting access to services or applications, connection speeds), quality of service (regulators can set minimum quality levels) and the ability to switch operators (within one working day).
The European Commission (EC) published their report on network neutrality in April 2011, at which time the EC’s Vice-President for the Digital Agenda, Neelie Kroes’, stated:
“Today's report shows a general consensus that traffic management can be useful. For example, it is important to keep video calls running smoothly even if that means an email is delayed by a few seconds. Consumers have the right to choose services, and operators have the right to deliver services, that can meet these expectations.”
Generally, Sandvine believes that the rules set out in both the United States and the EU are reasonable and create business environments in which Sandvine’s solutions can continue to add significant value.
Sandvine’s Filings
- February 23, 2009, Canadian Radio-television Telecommunications Commission, “Review of Internet Traffic Management Practices”
- January 14, 2010, United States Federal Communications Commission, “In the Matter of Preserving the Open Internet”
- September 9, 2010, United Kingdom Office of Communications (Ofcom), “Ofcom’s Discussion Document on Traffic Management and ‘Net Neutrality”
- September 30, 2010, European Commission, “Consultation on the Open Internet and Net Neutrality”
- October 2012: European Commission, “Public Consultation on specific aspects of transparency, traffic management and switching in an Open Internet”
Online Privacy: Privacy is About Use-cases, Not Technologies
Technology is neutral, though its uses may not be. Sandvine’s network policy control solutions incorporate many technologies, including Deep Packet Inspection (DPI). While certain applications (like behavioral targeted advertising) that could incorporate DPI have privacy implications, Sandvine does not offer such solutions and in general, designs its applications to avoid the inspection of user content. For example, Sandvine solutions:
- Identify email but don’t read the note
- Identify a VoIP call but don’t listen in
- Identify a video stream but don’t know the title
DPI is used ubiquitously for a broad range of applications across the Internet – in firewalls, routers, modems, and the network address translation schemes that will enable IPv6.
Privacy-sensitive applications like behavioral targeted advertising can be implemented with a variety of technologies, not just – or even commonly – through the use of DPI. Privacy regulations need to focus on use-cases, not technologies.
Sandvine’s Filings
- May 12, 2009, Office of the Privacy Commissioner of Canada, “A Collection of Essays from Industry Experts on Deep Packet Inspection”
- March 2010, Office of the Privacy Commissioner of Canada, “Public Consultation on the Privacy Implications of Emerging Technologies”
Bill Shock
Sandvine’s focus is to help network operators make the Internet better for subscribers. One way to do that is through increased transparency of subscribers’ network usage to avoid subscriber “bill shock” related to data overage or data roaming charges.
Generally speaking, Sandvine has advocated that network operators implement real-time advice-of-usage and that they consider a number of critical elements when implementing advice-of-usage communication, including:
- Subscriber interactivity
- Communication of the economic impact of charges or choices available to the subscriber
- Non-disruptiveness
- Device awareness
- Subscriber customization
Sandvine’s Filings
Usage-based billing for Canadian wholesale ISPs
Usage-based billing is common in Canada for retail subscribers. The vast majority of Canadians (who subscribe to Internet access through incumbent operators), subscribe to service offerings that include a data usage cap and additional charges for usage beyond that limit. Usage-based billing is also now being applied to wholesale customers of Canada’s incumbent network operators. The CRTC has asked some specific questions about how such plans should be structured in order to maximize the flexibility of the service plans that wholesale ISPs can continue to offer, and to ensure that ordinary consumers don’t fund the bandwidth used by the heaviest retail Internet service consumers.
Sandvine has advocated that incumbent network providers should charge wholesale ISPs for their traffic in aggregate, not an individual retail user basis (as originally contemplated by the CRTC). In other words, for the purposes of usage-based billing, incumbent network operators need to treat each wholesale ISP as a single customer. The usage-based billing rate charged by the incumbent network provider should be based on a “cost-plus profit margin” basis (as with other regulated wholesales services, such as electricity), where the “cost” is the marginal cost of an incumbent operator delivering a gigabyte of traffic. Originally, the CRTC contemplated a wholesale usage-based billing rate that represented a discount from the market usage-based billing rate charged by incumbent ISPs to their retail subscribers.