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Usage Billing Approach

The usage billing approach was and is still not implemented for the following reasons:

• Usage billing requires extensive modifications to Cogeco’s IT systems. At that time, these modifications were considered too costly and too long to implement with respect to the benefit and the urgency of the situation. Cogeco is however currently in the process of implementing these required IT system modifications and plans to start billing its customers for IP usage above the bandwidth limitations mentioned in Cogeco’s HSIAUP later this year. See response to interrogatory Cogeco(CRTC)4Dec08-10;
• In 2001, the DOCSIS infrastructure was not built to perform usage billing and the cable modem counters were not deemed reliable enough to use as a metric for billing purposes. The development of the Internet Protocol Detail Record (IPDR) was in its infancy. In fact, IPDR was included in the DOCSIS Certification Waves only in May 2005. Lately, CMTS vendors have implemented IPDR in their equipment and IPDR Billing systems are now available on the market. See the IPDR milestone table available on the TM Forum at:
»www.ipdr.org/BestPracticesStanda···ome.html

In any event, the implementation of traffic management equipment enabling Cogeco to monitor and manage its network was necessary. Usage billing was not and still is not considered as a sufficient solution to enable Cogeco to meet its commitment to provide each user with prompt access and fast connection to the World Wide Web, due primarily to the fact that the length time from action to bill would allow subscribers to “abuse” the network for a significant time period without immediate redress for adjacent users. To this end, Cogeco should have the ability to monitor usage and manage bandwidth in a timely fashion in order to protect its network and ensure a fair usage among its customers as well as compliance with applicable terms of use.