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VON Europe - Comments to European Commission’s Public Consultation on Specific Aspects of Transparency, Traffic Management and Switching in an Open Internet

VON Europe - Comments to European Commission’s Public Consultation on Specific Aspects of Transparency, Traffic Management and Switching in an Open Internet

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Comments of the Voice on the Net (VON) Coalition Europe on the European Commission's Public Consultation on specific aspects of transparency, traffic management and switching in an Open Internet. ( http://ec.europa.eu/digital-agenda/en/line-public-consultation-specific-aspects-transparency-traffic-management-and-switching-open )
Comments of the Voice on the Net (VON) Coalition Europe on the European Commission's Public Consultation on specific aspects of transparency, traffic management and switching in an Open Internet. ( http://ec.europa.eu/digital-agenda/en/line-public-consultation-specific-aspects-transparency-traffic-management-and-switching-open )

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Published by: Voice on the Net (VON) Coalition Europe on Oct 15, 2012
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04/26/2015

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Comments on
the European Commission’s Public Consultation
on specific aspects of transparency, traffic management andswitching in an Open Internet
October 2012Voice on the Net Coalition EuropeKreupelstraat 331703 Dilbeek (Brussels)
– 
BelgiumRegistration number: 96615638697-36 
 
 
Comments on the European Commission’s
Public Consultation on specific aspects of transparency, traffic management andswitching in an Open Internet
 
Page
1
of 
56
 
Comments on
the European Commission’s Public Consultation
on specific aspects of transparency, traffic management andswitching in an Open Internet
by VON Europe, August 2012
The Voic
e on the Net Coalition Europe (‘
VON
) welcomes the opportunity to comment on European
Commission’s
Public Consultation on specific aspects of transparency, traffic management andswitching in an Open Internet
(hereafter ‘the Consultation’
).
Question 1: I answer as:
 g) Association of Internet content and applications providers
Question 2:(a)
 
Please provide a brief description of your organisation and of your interest in open Internetissues.(b)
 
If your organisation is registered in the Transparency Register, please indicate your RegisterID number.(c)
 
Please provide the postal and e-mail address of your organisation and, if you wish, the nameof a contact person (including telephone number and e-mail address) for any questions onyour contribution.(d)
 
In which Member State(s) are you established and where do you perform your activity?
(a)
 
The Voice on the Net (VON) Coalition Europe was launched in December 2007 by leading Internetcommunications and technology companies, on the cutting edge to create an authoritative voicefor the Internet-enabled communications industry. Its current members are iBasis, Google,Microsoft, Skype, Viber, Vonage, Voxbone and WeePee.The VON Coalition Europe notably focuses on educating and informing policymakers in theEuropean Union and abroad in order to promote responsible government policies that enableinnovation and the many benefits that Internet voice innovations can deliver.(b)
 
Registration number:96615638697-36(c)
 
Postal address: Voice on the Net Coalition Europe, Kreupelstraat 33, 1703 Dilbeek (Brussels)
 –
 Belgium. Contact person: Herman Rucic, VON Europe, by phone (+32 (0)478 966701) or email(hrucic@voneurope.eu).(d)
 
VON Europe is established in Brussels, but its Members are active at an international level.
 
 
Comments on the European Commission’s
Public Consultation on specific aspects of transparency, traffic management andswitching in an Open Internet
 
Page
2
of 
56
 
1.1 Traffic management and differentiationQuestion 3: Please explain briefly which traffic management techniques are usually applied bynetwork operators or ISPs and how they are technically implemented.
VON would first like to point out that it will, in its response to this question, take ‘traffic
managemen
t’ in its broadest sense,
i.e.
as encompassing both legitimate and harmful practices.First, VON would like to put this question in its current context: there is no question that the Internethas experienced tremendous growth in traffic volumes in its history, including in recent years.However, the rate of growth is declining, whilst the increase in capacity is forecasted to be able tohandle the volumes appropriately. At the same time, the costs of upgrading and maintaining bothfixed and mobile networks are falling to such levels that such capacity increases will continue to bemanageable.VON considers that traffic management for the purposes of combating spam, security attacks orpunctual exceptional measures to alleviate congestion are useful and should not be contested assuch, as long as they remain proportional and not harmful.
1
Traffic management has always takenplace in the Internet and VON considers there is no issue for Internet Service Providers (ISPs) to fairlyuse network management to overcome technical challenges and maintain a high quality Internetservice for their customers. However, this freedom to manage the network should not be seen as analternative to sustained network investment to meet large increases of capacity, which hascharacterised the Internet since day 1.
2
 Furthermore, traffic management should not be a license for ISPs to behave in anti-competitive andother harmful ways, such as blocking legitimate content and applications or unreasonably degradingservices. Such practices are often based on commercial motivations and are harmful both to end-users (both users andcontent, applications and services providers)
3
and innovation generally. VON
1
A point also made by the BEREC in its draft QoS Guidelines, p. 6, both as regards congestion and network security andintegrity management. See BEREC. (2012).
Draft BEREC Guidelines for Quality of Service in the Scope of Net Neutrality 
2
The Canadian Radio-television and Telecommunications Commission (CRTC) has very specifically stated in its Review of theInternet traffic management practices of Internet service providers:
“36. The Commission notes that investment in network 
capacity is a fundamental tool for dealing with network congestion and should continue to be the primary solution that ISPsemploy. However, the Commission considers that investment alone does not obviate the need for certain ITMPs, which may be used to address temporary network capacity constraints and changing network conditions, as well as for service
innovation.” 
See CRTC. (2009).
Review of the Internet Traffic Management Practices of Internet Service Providers
3
 
For the sake of clarity, VON refers to the following concepts set forward in the BEREC’s draft Report on assessment of IP
-
interconnection in the context of net neutrality: “
Content and application providers (CAPs) create and aggregate content (e.g. webpages, blogs, movies/photos)
[and]
applications (e.g. search engines, messaging applications)
” (p. 11) and CAUs

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