jfmezei
Premium
join:2007-01-03
Beaconsfield, QC
 ·ELECTRONICBOX
| UBB round 2 at the CRTC
This topic is to hold discussions and filings for the second round of discussions at the CRTC about TN7181 (UBB).
Bell Canada has just sent its responses to the august 20th interrogatory. I will endeavour to generate a single PDF with the answers and post it here shortly. |
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Jazdi
join:2009-07-06
Ottawa, ON | Thx JF  |
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jfmezei
Premium
join:2007-01-03
Beaconsfield, QC
·ELECTRONICBOX
1 edit | reply to jfmezei
Ok, first take at combining some 20 .doc files into one document. This was included in indesign and generated a .PDF. I think one or two images are not there, I will look at the original .DOC documents to see what they are. So I may update this document.
So this is currently serving document version 1. If I update the doc to correct some conversion errors, I'll update this message.
Update: just found out that the ATM graphics didn't make it through, and that the document starts with questions 10 onwards. (I think questions 1 to 10 are later on). Will reorder them. |
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olebiker
join:2008-04-16
Glenburnie, ON | reply to jfmezei
Thank you JF. But every time I start reading I alternate between wanting to puke and wanting to hurt someone. I didn't think my dislike of bell could be any stronger but I was wrong. |
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LOL at rules
@videotron.ca | reply to jfmezei
TY for the update JF.
LOL this filing made me laugh out loud. |
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InvalidError
join:2008-02-03
·TekSavvy Solutions..
 ·Videotron
| reply to olebiker
said by olebiker  :Thank you JF. But every time I start reading I alternate between wanting to puke and wanting to hurt someone. I didn't think my dislike of bell could be any stronger but I was wrong. Really? Guess I'll have to read it and see if they have truly managed to dig themselves lower than they already were in my mind... no idea a-priori how they can do that though. |
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InvalidError
join:2008-02-03
·TekSavvy Solutions..
·Videotron
| reply to jfmezei
Humm...
So, the CRTC asked Bell to file costing figures for public review and questioning yet all the relevant cost data in Bell's response is filed "in confidence" still. Anybody surprised?
The only somewhat interesting part I found at-a-glance is how they try to reconcile their UBB rates with AEI/Primus' suggested UBB rates by dividing max-usage by cost at billing boundaries (cap and 300GB) when the bulk of our beef with UBB is the ridiculously steep rate after 60GB, how quickly it gets us to billing cap and how it makes it impossible for ISPs to dilute the cost... Sympatico sells usage in $5/40GB increments while GAS would be pretty much stuck at $22.50/240GB even if you need less than 40GB extra.
Most of the rest seems to be the same old stuff Bell has repeating all the time since this mess started... not much to see here. |
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jfmezei
Premium
join:2007-01-03
Beaconsfield, QC
·ELECTRONICBOX
2 edits | The process goes as follows:
Bell filed its cost study in july.
CRTC asks questions in august.
The current schedule:
Requests for public disclosure 13 October 2009
Replies for requests for public disclosure 23 October 2009
Service of information, if any to be provided
pursuant to determination with respect to
requests for public disclosure 3 November 2009
Comments 17 November 2009
Reply comments 24 November 2009
The file appears to be the same as before:
»crtc.gc.ca/8740/eng/2009/b2_7181.htm
However, the Bell responses have not been posted. However, the CRTC continues to post comments from the public to this file, so the dile is still active. |
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Cyborg994
join:2005-04-18
Montreal, QC
1 edit | reply to jfmezei
Wow, 53 pages of emptiness...
That really made me laugh : The Companies’ UBB proposal may have already begun to discourage users from looking to independent ISPs to avoid usage charges. (on page 22)
They are not even afraid of admitting that this is the goal...
If you remove all that was filed in confidence, there isn't much left honestly. General feeling is that most of the extra costs in the fillings that Bell uses as a justification for UBB are caused by UBB. That pretty much defeats the point... But no way to be sure as we can't see any actual data.
Also Bell still mentions that there is parity between their retail and wholesale prices, and that it is compliant whit what is done by cable. Not once do they mention matching speed and their Usage Insurance, even tho they advertise them heavilly.
Also some documents implies that bell's TOS applies to us as well, which means no servers allowed by example, and even restricts what we cna say or do on IRC ! (I fail to see how this can be part of a wholesale environnement)...
Honestly it's adepressing read, I can't believe our Internet service can fall so low... |
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Guspaz
Guspaz
Premium,MVM
join:2001-11-05
Montreal, QC
·Colbanet
3 edits | reply to jfmezei
Errm, am I missing something, or isn't this the answers that had to be all public?
I thought the whole point of this was, cost study was filed in confidence, so others complained, and the CRTC said you have to file the following information in public to allow debate?
There is a bunch of redacted stuff in here.
EDIT: One question is answered, at least. Uncorrelated usage charges will not have any impact on MLPPP. Bell has clearly defined that they consider uncorrelated usage to be defined as user authenticating to a PPPoE realm other than the one associated to the line. This means that *any* account from the ISP associated to your line will be correlated, and hence OK. So MLPPP will cause no issues.
EDIT2: Somebody needs to jump on the Bell Digital Voice section. Bell says that Bell Digital Voice does *NOT* incur retail UBB charges because it does not travel over the public internet.
GAS is not an internet-related service, and therefore a GAS-based VoIP product would not travel over the public internet. By Bell's own justification, GAS-based VoIP products should not incur UBB charges. |
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freejazz_RdJ
join:2009-03-10
1 edit | Guspaz, you're confusing the two BDV products. They clearly state that the one that uses the ATA in your home will use your bandwidth up.
The first service they refer to is an IP-based, POTS service from the CO. It is basically a DMS-100 I believe where the CO port is fed into a softswitch to give you all the fancy features you get with VoIP. Clearly it doesn't go over your home broadband connection and therefore doesn't use UBB.
EDIT:
First service: "Bell Digital Voice is an access-dependent VoIP service with an enhanced IP-based feature set which is configurable from the Companies’ self-serve portal. No Internet access is required for the voice service itself however Internet access is required to access the portal to configure its enhanced feature set."
Second, ATA based service: "Bell Digital Voice Lite is an access-independent VoIP service that is accessed via the Companies’ public Internet network. As a result, usage associated with Bell Digital Voice Lite VoIP calls is subject to the usage-based billing plans for the Companies’ retail Internet services." |
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freejazz_RdJ
join:2009-03-10
| reply to InvalidError
But did you really expect the cost data to be published?
I'm very mixed on many of the issues, but I still don't understand where people get the idea that any company should have to open it's books for the whole world to see. If Bell is expected to do so, why shouldn't every company?
Publicly breaking down every element of their cost to serve necessarily weakens a company be basically stripping away the veil over their affairs. I support disclosure in confidence because otherwise, other companies could profit by intiating a CRTC proceeding, obtaining detailed cost structure information, and using it to compete against a single element of the service. All a provider needs to know in order to compete is if they can offer an equivalent of GAS for less money than the tariff. |
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TBBPM
join:2009-02-09
1 edit | said by freejazz_RdJ :But did you really expect the cost data to be published? I'm very mixed on many of the issues, but I still don't understand where people get the idea that any company should have to open it's books for the whole world to see. If Bell is expected to do so, why shouldn't every company? Publicly breaking down every element of their cost to serve necessarily weakens a company be basically stripping away the veil over their affairs. I support disclosure in confidence because otherwise, other companies could profit by intiating a CRTC proceeding, obtaining detailed cost structure information, and using it to compete against a single element of the service. All a provider needs to know in order to compete is if they can offer an equivalent of GAS for less money than the tariff. This is a tough one. I completely agree with you that companies should not be forced to publicly release their costs for competitive and business reasons (e.g. customers calling in and telling "I know that this services costs you $X, you want too much profit").
That is being said, when there are service/network elements elements that, because of public policy, should be offered to the competition at "cost plus", there should be some way to ensure that the costing excersize has been done fairly and not just between Bell and CRTC lawyers.
The best example here would be Unbundled Local Loop, which, unlike GAS, for all intents and purposes, cannot be replicated by competition. Revealing the true cost of maintaining the legacy copper and laying the new one can be made public since it will not jeopardize Bell's competitive position for any retail service. Public process will make sure that we are dealing with the true cost, not loaded with allocations of the Bell's executives salaries, costs of buliding remotes that competition has no access to or adjustments reflecting the increased cost of copper.... |
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freejazz_RdJ
join:2009-03-10
| Absolutely TBBPM. Cost plus for several elements is a necessity. As I've said before to those who use the excuse "But Bell always applies to have unbundled loops removed from mandated wholesale so we won't build a product on it", it won't happen that way. The local loop is the single most costly portion of the network and the hardest to duplicate.
But I still disagree that every figure, even for loops, should be thrown out in public, because some of those elements, mostly surrounding labour and contract costs may be sensitive. But that's open for debate, and I'd be 100% for it if competitors could hire a 3rd party to review them in confidence on their behalf with a prohibition on disclosing the details while being allowed to challenge certain aspects. |
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TBBPM
join:2009-02-09
| said by freejazz_RdJ :But I still disagree that every figure, even for loops, should be thrown out in public, because some of those elements, mostly surrounding labour and contract costs may be sensitive. But that's open for debate, and I'd be 100% for it if competitors could hire a 3rd party to review them in confidence on their behalf with a prohibition on disclosing the details while being allowed to challenge certain aspects. No problem with the third party doing this as long as this is a truly neutral, non-political one. I guess CRTC believes they are exactly such "neutral party". |
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InvalidError
join:2008-02-03
·TekSavvy Solutions..
·Videotron
| reply to freejazz_RdJ
said by freejazz_RdJ :I'm very mixed on many of the issues, but I still don't understand where people get the idea that any company should have to open it's books for the whole world to see. If Bell is expected to do so, why shouldn't every company? Because Bell is a MONOPOLY, there is no significant competition to speak of for the services in question. As such, accurate costing information is necessary to ensure that tariff rates are in line with operating costs rather than orders of magnitude above. In a free market, market forces would push prices down in line with costs... but Bell is in a monopoly position so regulations are required to keep the monopoly's greed in check so it does not become a burden to the population and the country as a whole.
Bell is becoming an economic and social liability, we need Bell to provide numbers that prove that these new rates are warranted.
said by freejazz_RdJ :All a provider needs to know in order to compete is if they can offer an equivalent of GAS for less money than the tariff. The truth of the matter is that individual GAS ISPs cannot afford to set foot beyond COs due to the innumerable road bumps along the way to building their own last mile... and even if they somehow did go that far alone, they would have to imitate the same geographic exclusivity patterns to avoid further diluting each other's local subscriber base.
As soon as you set foot outside the CO, per-subscriber costs skyrocket. |
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An_Onymous
@teksavvy.com
| reply to Guspaz
>This means that *any* account from the ISP associated to your line will be correlated, and hence OK.
So an ISP selling multiple accounts each of 60GB quota to the same line would be legit. Problem solved then.  |
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freejazz_RdJ
join:2009-03-10
| reply to InvalidError
said by InvalidError :Because Bell is a MONOPOLY, there is no significant competition to speak of for the services in question. As such, accurate costing information is necessary to ensure that tariff rates are in line with operating costs rather than orders of magnitude above. In a free market, market forces would push prices down in line with costs... but Bell is in a monopoly position so regulations are required to keep the monopoly's greed in check so it does not become a burden to the population and the country as a whole. [...] As soon as you set foot outside the CO, per-subscriber costs skyrocket. The costing information you get to see shows what elements are included in the service. Forcing a public breakdown has no purpose... the law isn't there to allow wholesale customers to dispute the provider's choices of equipment or architecture or how much they cost, but what costs are included in the service. So there is little point to a the actual cost information, just ensuring that the elements included in the service are all relevant.
Regarding monopoly, the technically don't have a monopoly, but simply an absence of facilities based competitors. If I have a business with no competition even when I am forced to offer competitors a leg up, for how long should I be punished? Finally, yes, FTTN isn't feasible for competitors at this point, but that isn't all the incumbents fault. They have 400-500K customers out of 2.1 Million, so either consolidation or collaboration could make facility ownership much more viable.
Lastly, for all the claims that FTTN is necessary, most users don't want to pay a premium for FTTN speeds, especially since it seem that the wholesale client base is extremely price sensitive and price is the major differentiator, how many would be willing to pay a premium price? How many more users would take a CO-based service without the constraints of UBB over a capped 16Mbps FTTN service that costs a lot more? |
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Oinktastic
join:2005-08-24
Scarborough
·TekSavvy Solutions..
·3 Web
3 edits | reply to jfmezei
I wish we could see page 14. It's got all the goodies :P
It's rather strange that they have a cost for "Advertising and Promotion" on the GAS service page... can anyone explain that?
I bet they came up with a negative number for the present worth total there, just to spite the wholesalers. |
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globus999
join:2008-05-15
| reply to freejazz_RdJ
said by freejazz_RdJ :The costing information you get to see shows what elements are included in the service. Forcing a public breakdown has no purpose... the law isn't there to allow wholesale customers to dispute the provider's choices of equipment or architecture or how much they cost, but what costs are included in the service. So there is little point to a the actual cost information, just ensuring that the elements included in the service are all relevant. You are splitting hears here, but, if you want a counter-argument, then fine. I disagree. The law is there to ensure a reasonable Cost + Profit. By breaking down the elements of the cost it means nothing because each and one of the elements could be necessary for the service yet have artificially inflated expenditures. Both are necessary. The breakdown and the cost.
said by freejazz_RdJ :Regarding monopoly, the technically don't have a monopoly, but simply an absence of facilities based competitors. If I have a business with no competition even when I am forced to offer competitors a leg up, for how long should I be punished? Punished? Well, if it is NOT your capital that enabled your company to be in a position to have an "absence of facility bases competitors" then, basically, forever. This means, for as long as you are making $$$ out of it. If not, then please fork back ALL the subsidies, unpaid rights of way, tax breaks, etc. your company received since the beginning to implement this infrastructure. You don't like it? Well, then you shouldn't have accepted the money in the first place.
said by freejazz_RdJ : Finally, yes, FTTN isn't feasible for competitors at this point, but that isn't all the incumbents fault. They have 400-500K customers out of 2.1 Million, so either consolidation or collaboration could make facility ownership much more viable. Sure, but why would the competitors have to fork all the money while Bell continues to be subsidized and enjoys a significant head-start? A much fearer solution would be either break Bell into a Public access provider (with a mandate to serve all companies equally) and an ISP. Alternatively, the competitors should be subsidized at the same level as Bell was during decades OR give the competitors free access to Bells' last mile for a long period of time (e.g. 10 years) so that they they be capable of accumulating capital to enable them to build FTTH.
said by freejazz_RdJ :Lastly, for all the claims that FTTN is necessary, most users don't want to pay a premium for FTTN speeds, especially since it seem that the wholesale client base is extremely price sensitive and price is the major differentiator, how many would be willing to pay a premium price? How many more users would take a CO-based service without the constraints of UBB over a capped 16Mbps FTTN service that costs a lot more? Again, you are twisting the numbers here. How about this, everybody would be happy to get uncapped FTTH at a reasonable price, however, this price is not achievable precisely because of Incumbent's actions. It's just like Microsoft and Windows. Nobody can compete against them simply because the entry price barrier is too high. The difference is that Bell's entry barrier was artificially lowered by tax money. Fine. Then, we are in the position to demand from Bell to either roll-out uncapped FTTH or rescind their advantageous and artificial entry barrier and pass it on to the competitors. Fair is far. What's good for Bell is also good for the competition!
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