Wednesday, February 09, 2011

My Opposition Letter to The CRTC regarding UBB

There are several major problems with UBB I will outline them for you below.

1. Independent ISP's already pay for the infastructure congestion is on the bell end and is not caused by the "strain
of independent ISP's" as they only get their agreed upon rate.

2. There is no free ride happening independent ISP's pay for infrastructure upgrades just like everyone else.

3. Accountable metering is needed if we go with UBB: For metered internet to be viable each house will have to get a certified meter installed of which the measurement is validated and government approved. Similar to the requirements of retail scales, gas meters, electricity meters, water meters. In the current model Bell can claim the user used X capacity and the user has no recourse as bell can claim whatever they want. This meter must be readable without requiring logging onto Bell's website (aka must not use bandwidth to check it).

4. Bell is not penalizing the "Bandwidth Hogs" the problem of capacity lies in what is known as "peak hour capacity" that is when everyone is trying to get online. Bell penalizes a 5Mbps plan more by giving them a lower cap vs a 25mbps plan. But the 5mbps users is far less likely to cause congestion because they simply cannot be as demanding as the 25mbps user.

5. UBB is a discouragement for network upgrades and continue investing. If you were Bell and you could just simply penalize your customers for using the service they paid for as a way to make your users demand less would there every be a need to upgrade your infrastructure? Nope. In fact if you knew every customer was capped at 25GB why would you even bother investing any capital at all in improving your network infrastructure? You've essentially frozen all possible future demand.

6. The tariffs don't reasonablely match the cost to produce each GB. Most of us understand there is some markup but Bell's markup model is insane. The price to deliver a GB including network upgrades done annually is less than 3 cents / GB. Yet bell turns around and charges of $2? The cost / GB would be reasonable if UBB was implemented at a rate of 5-10 cents / GB.

7. The tariff's don't reward the non-bandwidth hogs. If we have these tariff's in place what happens when you don't exceed the 25GB of allocated bandwidth? Surely bell will give you a refund or a credit for unused GB? You can carry them over to the next month right? Nope this 25GB just dissapears you don't get it back.

8. Canada already has the highest internet prices in the world. And yet we still can't keep up with our internet? The USA is already offering fiberoptic to the house while charging their customers far less. The argument that Canada needs to charge more to keep it's network running is completely fictitious.

10. Conflict of interest: Bell's own TV service isn't metered in any way. They are using UBB to effectively prevent new errants from entering the market like Netflix.

11. There is something seriously wrong when filling up 6 hard drives then overnight shipping them, and simply throwing them away will cost less than if the same data was delivered over the internet. is a business model that shows just how backwards our internet is.

12. Innovation will leave. Why in the world would companies that are creating new and innovative experiences on the internet stay in Canada when the Canadian public will be completely unable to utilize their services?

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