Hi Guys: We are still finalizing our official reply comments for the CRTC. I can tell you all that it has been a very long process. Along the way I have also been privy to review the drafts of several other ISPS and CLECs prior to their filing with the commission. I think that the more of you that file comments the better our chances will be of success.
I do have a few points to note however, hopefully they will be of use to you in your submissions. 1. Keep in mind that Gateway Access Service (GAS), the product that Bell sells to us as ISPs is NOT an internet service. It is a service that combines the last mile via DSL with a backhaul facility to bring your traffic to our network as your ISP. The internet is not involved. 2. Keeping number 1 above in mind, the reason why this tariff filing is so bad is that Bell is trying to enforce RETAIL INTERNET SERVICE policies on a service that is NOT RETAIL INTERNET SERVICE. The concepts of usage based billing is one that is being used by Bell in the provision of their Sympatico services for residents, or Bell Business Internet on the business side. In both cases they are internet services, but the service that Bell provides to us as ISPs is not internet, it is last mile connectivity and backhaul. Bottom line, Bell is trying to force their retail internet policies onto wholesale services that are not internet. This must not be allowed. I will be up very late tonight finalizing Telnet's official reply to this proceeding. If anyone is unsure of process or needs some help feel free to shoot me an email or (**Bill evaluates risk of publishing his cell number to a public list and decides that it is worth it**) call me on my cell number at 905-409-5228 up until 10pm or so. Regards, Bill -----Original Message----- From: Dave Donovan [mailto:donovan.da...@gmail.com] Sent: Tuesday, April 14, 2009 4:07 PM To: asterisk Mailing Subject: Re: [on-asterisk] Various regulatory issues that could affect you I got the same prompting from Teksavvy so I decided to put my response together. I've shared it here in case it helps nudge people into posting their thoughts to the comission. Those of you who know me, know that I get a bit long-winded so you won't be surprised that Jim's is much more terse than mine. :-) Whether brief or not, I would encourage members to make their thoughts known to the commission. Their mandate is to "ensure that both the broadcasting and telecommunications systems serve the Canadian public." It's hard for me to see how letting Bell dictate the way overage charges will be charged to end-users can be good for competition or the end user. For what it's worth, here is the full text of my comment to the comission: Tuesday April 14, 2009 Toronto Ontario, Canada As a consumer of DSL services both at home and in Ontario and Quebec as the IT Manager at work, I am very concerned by the anti-competitive and retrogressive nature of Tariff Application 7181 as proposed by Bell Canada. In order to be competitive, ISPs must be able to offer speed-matched services and differentiate their offerings using self-determined price structures. Small DSL providers do not have the brand recognition, capitalization, or variety of offerings that come with incumbency. The ability to set usage terms (such as limits, traffic shaping/prioritization and pricing tiers) is a fundamental part of this ability to differentiate. Weighing the needs of the Bell against those of ISPs, it is clear that Bell must have a mechanism to recover infrastructure costs in a way that is proportionate to consumption. It does not follow, however, that they should offer a subset of speeds and dictate how bandwidth costs are passed on to customers and at what tiers. Furthermore, it seems that the overage charges are not consistent with market prices for wholesale bandwidth and are in fact punitive. I am not opposed, in principle, to charging consumers on a pay-per-usage basis but this pricing scheme should not be set by the ISP. Bell's incumbency makes them the de-facto option for service for many consumers. As a result, they attract a higher than average number of light-weight bandwidth users. The competitive providers typically have better technical support, more flexible offerings and thus appeal to power users. If Bell uses this tariff to push a common pricing structure through to the consumer, it will not foster innovation and competition but, instead, lower the bar across the board to the lowest common denominator; which is, all too often, the incumbent. I would also point out that if the commission were to wade into this area, it would be regulating a moving target. According to Bell Canada's submission, characterizations of Internet usage increase range from "50% per year" to "exponentially". Over the 5 year period cited in the application, this could be anywhere from a factor of 7.6 to a factor in the thousands. As bandwidth availability dramatically increases and cost of provisioning decreases accordingly, how often will the commission revise the tiers and associated charges? Every day that goes by at a fixed tier, Bell's profit margin increases and so does it's competitive advantage ISPs; creating a regulated preferential environment. As disappointed as I am with this single application, it should be noted that it is more disconcerting when taken as a whole with Bell's other efforts to avoid speed matching and force traffic shaping upon their ISPs. Of further concern is Bell's view that it can use the CRTC as a forum of convenience and resort to political interference (section 4 of the tariff application) when due process yields an undesired outcome. I urge the commission to act in the interest of the public and ensure that the regulatory framework promotes diversity of services, pricing and competition. The inherent conflict of interest presented by the dual nature of 'Bell the upstream wholesale provider', and 'Bell the marketplace competitor' must be checked by the regulatory authority of the commission. I ask that the commission deny Bell's application for a tiered pricing as set out in tariff application 7181, and act quickly to seek compliance with it's CRTC Telecom order 2009-111 which would bring speed matching to the wholesale DSL marketplace and freedom of choice to consumers. Sincerely, David Donovan Toronto Ontario, Canada On Tue, Apr 14, 2009 at 2:40 PM, D. Hugh Redelmeier <h...@mimosa.com> wrote: > I'm repeating an old message since I think that it is important and > urgent. I've seen no response to it on this list (the biz list had some). > > Note: this is the last day to comment on URB. It's easy: there is an > awkward web form. Here's how Teksavvy explained using it: > > http://support.crtc.gc.ca/crtcsubmissionmu/forms/Telecom.aspx?lang=e > > Select the word "Tariff" from the drop down list. > > Add the following in Subject Line "File Number # 8740-B2-200904989 - Bell > Canada - TN 7181" and make your thoughts known! > > I think that there are 30 days from March 27 to respond to the petition to > cabinet. > > | Date: Mon, 30 Mar 2009 13:56:30 -0400 > | From: Bill Sandiford <b...@telnetcommunications.com> > | To: 'asterisk Mailing' <asterisk@uc.org>, "'b...@taug.ca'" <b...@taug.ca> > | Subject: [on-asterisk] Various regulatory issues that could affect you > | > | All: > | > | I apologize in advance for the cross-posting between lists, however I > | felt this was of significant enough importance to justify it (hopefully > | Simon and Dave agree with my assessment). I suggest that any discussion > | of this topic take place on the general list > | (asterisk@uc.org<mailto:asterisk@uc.org>). > | > | There is a lot of regulatory proceedings going on right now. These > | proceedings are actually what is taking up the most of my time these > | days. The most important of which are the following > | > | http://www.ic.gc.ca/eic/site/smt-gst.nsf/eng/sf09316.html > | > | We are opposing the Bell and Telus petitions and supporting the > | Allstream petition. > | > | Bell is basically petitioning Governor in Council to overturn CRTC > | decisions that they don't like. There are huge implications to this, > | especially in these few cases. > | > | But more importantly Bell has recently filed a tariff notice for what is > | known as UBB (Usage based billing) > | > | http://www.crtc.gc.ca/8740/eng/2009/b2_7181.htm > | > | UBB will force wholesalers (like Telnet, Teksavvy, and others) to > | enforce 60 GB/month caps on our subscribers and bill for usage above > | 60GB. Bell is asking the CRTC for this to be effective May 31, 2009. > | As you will see from the link above, Telnet (in association with some > | others) have already filed a letter with the CRTC asking that interim > | approval of this tariff not be granted as we plan to intervene and fight > | this tariff. > | > | Have a read of the files in the links. > | > | Regards, > | > | Bill Sandiford > | Telnet Communications > | 905-674-2000 x100 > | b...@telnetcommunications.com<mailto:b...@telnetcommunications.com> > | > | IMPORTANT NOTICE: This message is intended only for the use of the > | individual or entity to which it is addressed, and may contain > | information that is privileged, confidential and exempt from disclosure > | under applicable law. If the reader of this message is not the intended > | recipient, you are hereby notified that any dissemination, distribution > | or copying of this communication is strictly prohibited. If you have > | received this communication in error, please notify the sender > | immediately by email and delete the message. Thank you. > > > --------------------------------------------------------------------- > To unsubscribe, e-mail: asterisk-unsubscr...@uc.org > For additional commands, e-mail: asterisk-h...@uc.org > > --------------------------------------------------------------------- To unsubscribe, e-mail: asterisk-unsubscr...@uc.org For additional commands, e-mail: asterisk-h...@uc.org --------------------------------------------------------------------- To unsubscribe, e-mail: asterisk-unsubscr...@uc.org For additional commands, e-mail: asterisk-h...@uc.org
