MaynardKrebs
Premium
join:2009-06-17
| reply to jfmezei
Re: UBB round 2 at the CRTC
said by jfmezei  :CRTC has issued a secondary interrogatory to Bell. It is all about uncorelated charges. The types of questions asked seems to indicate to me that they are starting to want to understand what PPPoE is all about. "they are starting to want to understand what PPPoE is all about."
My eyes are rolling like matter around the event horizon of a black hole at the thought of this.
Who are these clowns at the CRTC who think they can rule on something that they have no clue about what it entails and means?
As I previously wrote, anybody who works or the CRTC, either as staff or especially Commissioners, must be required to pass a technical competency exam and score at least 90% BEFORE they are allowed to be employed by the CRTC.
Freakin' patent attorneys are engineers, physicists, & chemists BEFORE they are lawyers - and even then they get the software patent crap wrong all the time (mainly because software patents are BS in the first place). They aren't idiots with sociology undergrad degrees who become lawyers and so-called 'experts' at the CRTC.
What's going on at the CRTC currently is asking a bunch of lawyers to make a ruling on which techniques are appropriate during brain surgery, gene splicing, or searching for the "God particle" at CERN. It doesn't f!cking work. |
|
MaynardKrebs
Premium
join:2009-06-17
| reply to InvalidError
said by InvalidError :said by An_Onymous :
The last CRTC question for the ISP:
>3. Comment on the feasibility and implications of an alternative approach whereby the Bell companies would charge each GAS-ISP, for each speed option, based on its end-users’ total aggregate usage (correlated and uncorrelated), averaged over its end-users.
While that one give the ISP a bit more breathing room to at least average out the usage of their customers, it is still bad for the end users. I'll comment on the feasibility for you: If Bell wanted to have aggregated pseudo-UBB, it could have applied for an AHSSPI review to increase the 1GbE AHSSPI rates from ~$1750/month to $5000/month, which would translate into an effective pseudo-UBB rate hike of ~$0.02/GB (~$0.035/GB total) assuming ~50% overall link utilization with none of the billing mess, uncertainty, caps, etc. This is contemplated in the Questions to ISP's section:
3. Comment on the feasibility and implications of an alternative approach whereby the Bell companies would charge each GAS-ISP, for each speed option, based on its end-users’ total aggregate usage (correlated and uncorrelated), averaged over its end-users. But the first thing the CRTC MUST revisit before they ever consider any form of UBB is the bogus assumption that Bell's network is congested. |
|
InvalidError
join:2008-02-03
 ·TekSavvy Solutions..
 ·Videotron
| said by MaynardKrebs :This is contemplated in the Questions to ISP's section: 3. Comment on the feasibility and implications of an alternative approach whereby the Bell companies would charge each GAS-ISP, for each speed option, based on its end-users’ total aggregate usage (correlated and uncorrelated), averaged over its end-users. If you had actually taken time to read my comment in-context, you would have found out that I was commenting on
3. Comment on the feasibility and implications of an alternative approach whereby the Bell companies would charge each GAS-ISP, for each speed option, based on its end-users’ total aggregate usage (correlated and uncorrelated), averaged over its end-users. As for jacking up the AHSSPI or adding a GAS-UBB fee, the validity of the addition/revision of such fees should depend on Bell proving that it actually needs this much extra cash to keep up with increasing network load. If Bell could prove that the current GAS+AHSSPI cost structure fails to cover all costs intrinsically related to the service with a reasonable (10-15%) profit margin then Bell has just cause to review&vary rates to whatever is needed to remedy the situation.
For now, all we can do is wait for Bell to release its public costs so we can have a look and determine how much of the UBB, if any of it, seems justified. |
|
jfmezei
Premium
join:2007-01-03
Beaconsfield, QC
·ELECTRONICBOX
| reply to MaynardKrebs
The goal of a tribunal is to have the parties explain in plain terms what the issues are so that the commissioners can understand and make the right decision.
In real life, you cannot expect all judges (or commissioners in the CRTC case) to know about all the technologies in use by telecom or broadcasters. For each case, the onus is on the parties to provide a proper explanation.
One of the problems is that when the parties are lawyer driven, lawyers doN't understand and they just revert to their legal arguments (for instance, Bell going for the RJR MacDonald tests because it didn't have potent arguments against the R&V and Stay).
In such cases, the commissioners are left with no real background information on the technology in use and their ruling is made only based on legal arguments.
Remember that commissioners can only rule based on evidence that was submitted to them.
The questions asked for the 2008-19 public hearings were clearly asked in a void. And they worded the "please explain how you throttle" in such a way that allowed the telco/cableco to avoid answering the question. Was that done out of ignorance or on purpose, I don't know.
But this time around, it appears that the commission wants to understand this issue a bit better. They have petitions, federal appeal court and R&V processes, as well as highly heated debate on local tv subsidies and Finckeinstein would know that there are a lot more eyes than usual looking at the unpopular CRTC these days.
And if more and more people learn that the CRTC was merely acting out on the policy statement introduced by the Reform party, then the Reform party might awaken itself and realise they have made an unpopular move. |
|
jfmezei
Premium
join:2007-01-03
Beaconsfield, QC
·ELECTRONICBOX
| reply to jfmezei
Bell has provided answers to the requests for disclosure of information.
The document title is:
091023-GAS UBB_Deficiencies-Attachment.doc
(converting it to .pdf to make it usable by non-Bell people). |
|
jfmezei
Premium
join:2007-01-03
Beaconsfield, QC | Ok, just went though it:
12 pages of: "therefore, the request for disclosure of X should be denied". |
|
Oinktastic
join:2005-08-24
Scarborough
·TekSavvy Solutions..
·3 Web
1 edit | reply to jfmezei
Lol it's like a big middle finger to everyone who made a submission.
They just brainstormed and came up with a ton of different excuses as to why they didn't want to disclose anything. In one section they say they cannot disclose GAS information because it would cause 'the Companies' (Bell) harm.
I hope it's the plan of CAIP and them to counter with that exact same argument: that what Bell is trying to do to smaller ISPs with CAPs, UBB etc would cause them harm.
If it works for Bell, it should work for*... wait, that's not how this game works, is it? It's actually quite one-sided. Silly me. |
|
GNca George
GorillaNET
Premium
join:2008-07-12
Minden, ON
| Unfortunately, Bell makes an excellent point.
Quote: "In Decision 2008-17 the Commission determined in part c) of the Appendix that GAS is a conditional mandated nonessential service. In describing such services, the Commission stated at paragraph 78 of the same Decision that "services in the conditional mandated non-essential services category are those the Commission has determined do not meet the criteria for essential services but must continue to be mandated for reasons as discussed below".
"In any case, given the determinations in Decision 2008-17 that GAS is a conditional mandated non essential service and given the Policy Direction,1 both of which suggest that the rates for GAS should be market- and not cost-based, the disclosure of the costs is not required in order to determine those rates."
"The Companies further note the Commission's well-established rules for former Category II services, which include conditional mandated non-essential services such as GAS, which do not require disclosure of cost information for such services."
"Given the above, there is clearly no justification for disclosure of the requested information and MTS Allstream's and CAIP's associated requests for disclosure should be denied."
The point they are pounding home is that GAS is a conditional mandated non essential service and does NOT have the same disclosure requirements as an essential service.
Looks like the correct approach is to try to push GAS into an "essential service" position requiring full disclosure of costs. If that doesn't happen, Bell appears to be completely within their rights raising a middle-finger salute and effectively saying "bite me!"
George
--
Tough Broadband for a Tough Crowd!
GorillaNET.ca - 10Mbits to your desk, coming soon. |
|
jfmezei
Premium
join:2007-01-03
Beaconsfield, QC | On the other hand, the fact that Bell did comply with the May CRTC request that it produce the cost analysis means that it accepted the need to produce a cost analysis.
The arguments they presented today should have been produced back in May. |
|
mlerner
Premium
join:2000-11-25
Nepean, ON | reply to jfmezei
Right hand and left hand of Bell, doing whatever suits them at the time. Of course the CRTC is not smart enough to pick up on it. |
|
Vomio
join:2008-04-01
·odynet
1 edit | reply to GNca George
"Looks like the correct approach is to try to push GAS into an "essential service" position requiring full disclosure of costs. If that doesn't happen, Bell appears to be completely within their rights raising a middle-finger salute and effectively saying "bite me!""
I think that sums it up quite well George.
I don't think anything is going to get truly resolved until we get to having it declared an "essential service" and to get to that point is going to take political will and pretty obviously bypassing the CRTC.
From a selling point of view I think one could ask almost any MP if they considered internet access an "essential service" and they would say "yes" in pretty much any context. Packaged right saying "no" might be the kiss of death to anyone uttering the words. |
|
Angelo_
The Network Guy
Premium
join:2002-06-18 | reply to jfmezei
shame the ysaid nothing so we still demand the info... |
|
jfmezei
Premium
join:2007-01-03
Beaconsfield, QC
·ELECTRONICBOX
| reply to jfmezei
The CRTC has weighted in on the request for information disclosure.
Looks like they grew a small, muscle  |
|
InvalidError
join:2008-02-03
·TekSavvy Solutions..
·Videotron
| said by jfmezei :The CRTC has weighted in on the request for information disclosure. Looks like they grew a small, muscle A slight slap on the wrist but it does look like we can expect to see some hopefully interesting numbers next week.
It was also refreshing to see the CRTC has pointed out discrepancies between Bell filings and Bell's own website and request explanations about the discrepancies between Bell's service and pricing between filings, Ontario and Quebec.
Looks like someone over there did a little homework for a change! |
|
mlerner
Premium
join:2000-11-25
Nepean, ON | reply to jfmezei
What's this? The CRTC is growing a pair of balls!? Unfortinutely it still does not excuse them from previous incidences i.e. approving UBB without speed increases and not grilling them on this information before. |
|
Farchord
Lost somewhere.
join:2004-08-28
Shawinigan, QC
·TekSavvy Solutions..
| said by mlerner :What's this? The CRTC is growing a pair of balls!? Unfortinutely it still does not excuse them from previous incidences i.e. approving UBB without speed increases and not grilling them on this information before. Well, with a truckload of luck, and by truckload of luck, it's the "chickens grow teeths" kind of luck, they might force Bell to give us faster speeds.... For the time being, til they implement UBB, it should be cool |
|
cpsycho
join:2008-06-03
Orangeville, ON
·Wightman Telecom
·Rogers Hi-Speed
| reply to mlerner
said by mlerner :What's this? The CRTC is growing a pair of balls!? Unfortinutely it still does not excuse them from previous incidences i.e. approving UBB without speed increases and not grilling them on this information before. Maybe it has something to do with your website  |
|
Oinktastic
join:2005-08-24
Scarborough
·TekSavvy Solutions..
·3 Web
| said by cpsycho :Maybe it has something to do with your website His website and what army?
 Do the 9141 of us count? |
|
mlerner
Premium
join:2000-11-25
Nepean, ON
·Rogers Hi-Speed
·TekSavvy Solutions..
·Bell Sympatico
| said by Oinktastic :said by cpsycho :Maybe it has something to do with your website His website and what army? Do the 9141 of us count? Doubtful since they don't usually give in to pressure but perhaps the Google ads got to them. |
|
cpsycho
join:2008-06-03
Orangeville, ON | I forgot about the google ads. Classic, just classic.  |
|
