ICASA published the ADSL Regulations – aka Regulations regarding the provision of Asymmetric Digital Subscriber Line (ADSL) services – on 17 August 2006, but it is not easy to find many Internet Service Providers who adhere strictly to these regulations.
The regulations require Internet Service Providers (ISPs) to publish on their website, on a quarterly basis, Key Performance Indicators (KPIs) of at least packet loss, average latency and jitter for the provisioned ADSL service. The regulations require the quarterly publication of contention ratios associated with the ADSL service, and clearly states that local bandwidth should be uncapped.
It is very difficult to find ISPs with KPI stats published on their websites, and most ADSL service providers cap their users after they reach their monthly usage limit. This is strictly against the law, but since these ISPs are billed for all bandwidth consumed by their subscribers it is not surprising that they don’t adhere to all the ADSL regulations.
According to the Internet Service Provider’s Association of South Africa (ISPA), it is practically impossible for an ISP to provide most of those measurements [KPIs] in the absence of reliable upstream figures from Telkom for IP Connect and other ADSL services.
“ISPA always encourages its members to comply with regulations to the best of their ability, but I think it is unlikely that we’d expect them to comply with any unreasonable requirements, such as publishing performance metrics that it is impossible for them to accurately calculate or measure,” said ISPA’s Ant Brooks.
“It is perhaps worth noting that ISPA’s Code of Conduct requires that our members only offer service levels ‘which are reasonably within their technical and practical abilities’, so we would take a dim view of one of our members providing incorrect or misleading technical information on their website, just for the sake of appearing to comply with the ADSL regulations.”
This view is shared by Internet Solutions (IS) Regulatory Director Siyabonga Madyibi, who says that as far back as 2006 IS has raised concerns with ICASA about certain aspects of the ADSL regulations that were either impossible for ISPs to comply with or totally unworkable.
“Since we do not have access to network elements in Telkom’s ADSL network, we cannot measure statistics like packet loss, latency and jitter. As we have no control over Telkom’s infrastructure, we also cannot provide any commitment to metrics of this nature,” said Madyibi.
“We are entirely dependent on Telkom in this respect. Apart from the above, we also drew ICASA’s attention to the fact that it is entirely unclear how the statistics should be measured. In order to measure jitter across a network it is necessary to have available network probes, such as Cisco’s IP SLA responder. These probes would need to be loaded onto Telkom’s routers in its DSL infrastructure, or collocated in Telkom’s network.”
“In addition, Telkom would need to provide guarantees of the performance of its ADSL infrastructure (including DSLAMs, ATM links, ESRs), since the performance of this infrastructure is beyond the control of ISPs.”
Madyibi added that it is ridiculous to expect IS to publish contention ratios, since it is not possible for the company to calculate what these are. “Firstly, Telkom does not divulge the provisioning of their ADSL infrastructure. Secondly, we do not know the access rates at which our end users connect, so this prevents us from calculating a contention ratio.”
“In order to calculate contention ratios it will be necessary for Telkom to disclose contention ratios on its DSLAM to ESR links, and within the MPLS network used to carry traffic between ADSL users and IPC connections,” Madyibi pointed out.
“As a means to try and resolve this impasse we have repeatedly sought an audience with ICASA with a view to try and have the regulations amended in order to take these issues into consideration. We have numerous correspondence in our records where we raised these issues with ICASA and sought meetings to discuss them,” said Madyibi.
“However it is unfortunate to report that ICASA has not afforded us an opportunity to address them on these issues or responded to our concerns. Some aspects of these regulations therefore remain impossible to implement and for these reasons the information requested is not available on our website.”
Madyibi says that it is their view that such information is unlikely to be available on the websites of many other service providers who provide ADSL for the same reasons as IS. “Without ICASA addressing the issues we raise herein it will remain impossible for traditional ISPs to implement some aspects of these regulations,” Madyibi concluded.
MWEB, which recently stopped their uncapped local bandwidth trial, was asked for comment regarding this issue but failed to respond. ICASA was also asked for comment regarding the ADSL regulations and the problems highlighted by ISPA and Internet Solutions, but did not provide any feedback by the time of publication.