Yesterday, two papers critical of usage based billing were released. Both papers were sponsored by Netflix and neither of them appear to have been filed with the CRTC by the March 28 deadline for the Wholesale Internet Pricing proceeding.
Michael Geist released a paper looking at Usage Based Billing Around the World. The paper includes an estimate of the costs incurred by ILECs on a per gigabyte basis and has views on “what should come next” including a proposal for new guidelines for retail usage based billing: IBUMPS – Internet Billing Usage Management Practices.
If UBB is to remain part of the retail Internet access landscape, the transparency and public disclosures must improve. The CRTC should adopt similar requirements as those found with ITMPs to ensure that consumers are better informed about the benefits and limits of their capped services.
There is also a paper released by Bill St. Arnaud, called Myths and Fallacies about Usage Based Billing.
Hopefully, these papers will be filed as part of the CRTC’s proceeding (2011-77) that is reviewing usage based billing. In this way, the assertions can become part of the evidence examined and tested by the Commission. There are a number of phases remaining in the CRTC proceeding, but one has to wonder about the coincidence of two papers sponsored by the same corporation just happened to be released less than 48 hours after the deadline for submissions.
Netflix is registered as an interested party to the proceeding. I doubt that many of the other parties will object if Netflix files the submissions a few days late in order to ensure that these materials don’t miss the opportunity to be tested in the interrogatory phase of the proceeding.