TTCS comments on “Towards the Treatment of Over The Top (OTT) services” policy document submitted to Telecom Authority of Trinidad and Tobago

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The Trinidad and Tobago Computer Society (TTCS ; http://cs.tt/) has submitted its comments on the Telecommunications Authority of Trinidad and Tobago (TATT) document “Towards the treatment of Over The Top Services”

The TTCS comments can be viewed at TTCS-comments-on-TATT-Towards-the-treatment-of-OTT-services-public-July20-2015 (PDF ; 369K)

A general comment:

“For the past two decades, TATT has presided over a telecommunications sector which has experienced significant and ongoing growth for all commercial actors. The TATT “light touch” approach is one of the main factors contributing to the success of the sector. The status quo, as facilitated by TATT, should be maintained as the market can and will continue to innovate in the provision of value added services as it has already done for the benefit of clients, consumers, service providers and the country as a whole.

The TTCS fears that any change in the status quo *at the present time* will lead to a stifling of innovation and lead to significantly reduced domestic competition overall.

The treatment of Over The Top (OTT) services is *fundamentally* a Network Neutrality (NN) issue. Once the Telecommunications Authority makes a final decision on where it stands
regarding NN/zero rating of services, its way forward on topics such as OTT becomes much less complex and simple to execute. Over the top services (OTT) can be broad enough to
apply to any service provided over the Internet as a whole, or any future network. If TATT is to consider competition described by providers as “unfair,” then Zero Rated services should also be considered by the Authority in greater detail.

Attempting to make a final decision on OTT without any final decision on NN issues may needlessly complicate the country’s future regulatory landscape, and create precedents
which may limit future regulatory agility and sector innovation and growth. One of the realities of a competitive marketplace is that service providers must innovate constantly or else perish.

The TTCS believes that any regulator should have no vested interest in stifling future sources of innovation in order to preserve revenue streams for service providers. More significantly, any request by service providers that TATT *must* intervene in the regulatory environment in order  to mitigate any loss or potential loss of revenue as a result of technological changes in the sector misunderstands the responsibility of a regulator for the entire sector, and not just one part of it. Increased and differentiated competition and innovation in the telecoms space is to be encouraged, not stifled.

The Trinidad and Tobago Cyber Security Agency Bill, 2015

The Trinidad and Tobago Cyber Security Agency Bill, 2015 was introduced as the same time as the Cybercrime Bill 2015 by the Minister of National Security Brigadier General Carlton Alfonso on May 1 2015.

It seeks to establish a the Trinidad and Tobago Cyber Security Agency (TTCSA) to act as a national point of contact for all cyber security related concerns and other related matters. The functions of the TTCSA are to:

(a) act as the national point of contact for all cyber security related matters;

(b) establish a national computer incident response team to be known as the “Trinidad and Tobago Cyber Security Incident Response Team” (hereinafter referred to as “TT-CSIRT”);

(c) refer matters to the police, where evidence of an offence under the  Cybercrime Act, 2015 comes to its knowledge;

(d) prepare, review and update periodically and in any event at least annually, a national cyber security strategy and prepare such plans as are necessary for the successful implementation of such strategy;

(e) collaborate with the relevant public body in the collection of relevant information which would facilitate the analysis of current and emerging risks, including those risks which could produce an impact on the resilience and availability of data communications networks and on the authenticity, integrity
and confidentiality of the information accessed and transmitted through such
networks;

(f) provide advice on cyber security related matters, including situational awareness information, to the Minister, the Trinidad and Tobago Police Service or such other competent national bodies as are necessary;

(g) enhance cooperation between different actors operating in the field of cybersecurity by holding consultations with, interalia, various industries, universities, public sector bodies and private sector and civil society bodies;

(h) contribute to the awareness raising, and the availability of, current, objective and comprehensive information on cybersecurity by, inter alia, promoting exchanges of current best practices, including methods of alerting users and facilitating cooperation and collaboration between public and private sector initiatives.

(i) develop and publish standards for products and services on cyber security;

(j) establish and publish baseline cyber security requirements and standards for
various sectors including operators of critical infrastructures;
(k) conduct research and development in the area of cyber security and identify critical research and development needs, gaps and emerging trends for future research;

(l) promote the development of training and education programmes including the accreditation and certification of cyber security academic programmes;

(m) advise the Minister on research in the area of cyber security as well as on the effective use and adoption of risk preventative technologies;

(n) promote risk assessment activities, interoperable risk management solutions and studies on cyber security management solutions within public and private sector bodies;

(o) collaborate with the relevant public body in the provision of educational guidelines to the national community, as to the appropriate use of the national network infrastructure;

(p) establish internal and joint procedures between the public and private sectors  to manage the incidents and mitigate the threats associated with them;

(q) provide appropriate strategic insights to policy and decision-makers and public bodies in order to strengthen the national network infrastructure;

(r) develop a National Cyber Security Contingency Plan;

(s) coordinate cyber security exercises; and

(t) express independently its own conclusions and orientations and give advice on matters within its scope and objectives.

The Bill lapsed with the end of the Parliamentary session on June 17 2015.

 

 

 

 

Cybercrime Bill 2015

The Cybercrime Bill 2015 and the Trinidad and Tobago Cyber Security Agency Bill 2015 were introduced in the House of Representatives by the Minister of National Security Brigadier General Carlton Alfonso on May 1 2015.

The Cybercrime Bill 2015 seeks “to provide for the creation of offences related to cybercrime and related matters” and if passed would repeal the Computer Misuse Act 2000

The key changes between the Cybercrime Bill 2014 and the Cybercrime Bill 2015 were:

  • the penalties were adjusted for the various cybercrime offences
  • Clause 17 in the 2014 bill re: creating the offence of child pornography through the use of ICT was removed in the Cybercrime 2015 bill

However, the Cybercrime Bill 2015 lapsed with the end of the Parliamentary session on June 17 2015.

 

 

Trinidad & Tobago Computer Society Statement to Telecommunications Authority of Trinidad & Tobago on the proposed acquisition of Columbus International by Cable & Wireless Communications

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Trinidad & Tobago Computer Society (TTCS) Statement to the Telecommunications Authority of Trinidad and Tobago
on the proposed
acquisition of Columbus International by
Cable and Wireless Communications.

This comment is submitted by the Trinidad and Tobago Computer Society (TTCS ; http://cs.tt ) in response to the request for comments on the proposed acquisition of Columbus International Inc.(CII) by Cable and Wireless Communications (CWC)  published by the Telecommunications Authority of Trinidad and Tobago (TATT) on January 5th, 2015. The TTCS has commented on various ICT issues over the past decade as it relates to the interests of end users.

The proposed acquisition can lead to high ownership concentrations in the provision of voice and broadband Internet services throughout the Caribbean as well as in subsea fiber connections. This acquisition may also reduce the probability of healthy competition in mobile telephony services in some jurisdictions. The concerns with the proposed merger between the parties (absent speculation on changes in corporate allegiance) revolves around five main pillars:

  • Potential decrease in market efficiency (competition vs effective duopoly/oligopoly – more benefits to firms rather than consumers);
  • Reduced consumer options for voice and broadband internet services (with an effective CWC/CII and Digicel duopoly);
  • Higher cost of voice and broadband Internet services (concentration of market power among fewer firms);
  • Reduced quality of service in voice and broadband Internet services (common with a concentration of market power among fewer firms);
  • A potential underserving of remote or otherwise ‘less-profitable’ areas by the new corporate entity, and
  • An increase in corporate compliance issues (arising out of the attitude of a merged CWC/CII towards consumers, employees and government regulators, based on experience and past local and regional attempts to “game” the regulators by CWC imposing additional charges and changing service terms).

Ultimately, the TTCS sees the proposed merger as having the potential to reverse two decades of progress in liberalizing the local telecommunication sector and that residential, business and government consumers may lose many of the benefits of competition.

Furthermore, the TTCS notes with concern that TATT has only allowed for a one week comment period on this complex issue. We believe that extending this comment period as well as increased advertising would increase the participation of the general public in this critical decision.

TTCS, ISOC-TT and IEEE-TT Joint Statement on Digicel Trinidad and Tobago’s ban on VOIP Services

The following is a press release of the joint statement from
the Trinidad and Tobago Computer Society,
the Internet Society Trinidad and Tobago Chapter and
the IEEE Trinidad and Tobago Section on
Digicel’s Trinidad and Tobago’s  ban on Voice over IP services.

PDF version of press release:

A longer version of the statement can be viewed at TTCS-ISOC-TT-IEEE-TT-response-to-Digicels-ban-on-VOIP-services or at https://docs.google.com/a/ttcsweb.org/document/d/13pfWE4S6Rr3IwSntEFRdawpxdbnHXrSgpzQ2wcfp3YU/edit


Joint Statement from the
Trinidad and Tobago Computer Society,
Internet Society Trinidad and Tobago Chapter &
IEEE Trinidad and Tobago Section

on Digicel Trinidad and Tobago’s ban on VOIP Services

Summary of Issue

On the 5th July, 2014, Digicel (Trinidad and Tobago) announced  that it will be blocking access to Voice over IP (VoIP) applications it considers to be  ‘unlicensed’ or “unauthorized” on  its “4G” service. The Trinidad and Tobago Computer Society (TTCS),
the Internet Society Trinidad and Tobago Chapter (ISOC-TT) and the IEEE Trinidad and Tobago Section (IEEE-TT) consider this to be a grave error, and wish to make a public statement on this matter,  both from a technical perspective and a social one.

 

Our position

It is the position of the TTCS, ISOC-TT and IEEE-TT that this move is a violation of the concept of “Network Neutrality” as defined by Wu. We are of the firm belief that this move puts us, as Internet users, on a slippery slope, as it may well pave the way for the banning of  other important Internet services for learning, innovation and productivity which use much more bandwidth.

Given that customers are paying for Internet data service, it is not accurate for Digicel to state that VoIP services amount to “illegal bypass activity”. Digicel is effectively asking that both consumers and suppliers pay for the same service.

While we understand the need to ensure the integrity of their service, from a technical perspective, there is no reason to single out VoIP connections as a large consumer of bandwidth that can reduce the Quality of Service enjoyed by other customers as the throughput for a VoIP connection is very small (on the order of 20kbps). Compared to services such as YouTube, Netflix or even browsing media-rich web pages (on the order of hundreds of kbps), throughput required by VoIP applications is negligible. Therefore, the argument that services such as VoIP has a significant impact on other data services is inaccurate (unless the number of  VoIP users is very very much greater than the number of non-VoIP users).

The reasoning given by Digicel TT for the move that “VOIP services (are) putting enormous pressures on bandwidth – and customers’ data usage experience (is) being negatively impacted” is also misleading since it is not technically possible for Digicel to give priority to VoIP traffic on their current data  network. In their current system,  VoIP traffic is treated just as any other data service.

We can only conclude, therefore, that the reason for the proposed ban is to stop the loss of  revenue from traditional circuit switched voice services rather than any move to protect the integrity of its data service to customers.

It is important that Internet service providers are committed to the concept of Network Neutrality in Trinidad and Tobago so as to encourage innovation and avoid the potential of censorship. Digicel should certainly backtrack on this move, in the interest of national development. The  Telecommunications Authority of Trinidad and Tobago (TATT) should engage all stakeholders in a broader discussion with respect to how we should move forward on the issue of Network Neutrality. TATT should also strive towards making a more competitive environment by accelerating the introduction of a 3rd service provider as well as accelerate the long promised implementation of Number Portability to promote the competitiveness in the telecommunications space that would prevent similar anti-consumer, anti-innovation and anti-economic growth policies.