Reviewing interconnection

Yesterday, the CRTC issued Telecom Notice of Consultation 2011-206Proceeding to review network interconnection matters, which will review the local, wireless, and toll network interconnection regulatory regimes.

The toll interconnection regulatory regime was designed nearly 22 years ago – it was my team that did the original design back in the fall of 1989. We will had to contend with some electromechanical switches and it was long before the first Internet Protocol switches were placed anywhere in the Canadian networks.

As the notice acknowledges:

Currently, there are three distinct regulatory regimes related to the interconnection of telecommunications networks for the purpose of exchanging voice traffic: (i) local network interconnection between local exchange carrier (LEC) networks, (ii) wireless network interconnection between wireless carrier networks and LEC networks, and (iii) toll network interconnection between toll (long distance) networks and LEC networks.

The interconnection arrangements all start with a premise that the primacy exists with the incumbent wireline networks. With wireless substitution and significant migration to alternate local networks including IP, the CRTC is looking to conduct a broad policy review of network interconnection matters. The objective is to determine whether existing interconnection can be simplified and consolidated, which would ultimately enhance competition (to the benefit of consumers), and whether changes are necessary to ensure technological neutrality.

There will be an oral hearing in late October, following interrogatory phases taking place through the summer. The process should wind up with a decision around the time of the 20th anniversary of the landmark long distance competition Decision 92-12. Not sure that any of us involved in that proceeding 20 years ago thought that our interconnection arrangements would still be operating 20 years later!

It is time to go shopping for a new model.

Value based billing

Michael Geist endorsedYouTube propaganda piece by François Caron in his tweet, saying:

The UBB Deception – new YT video explains #UBB and some of the real reasons behind it.

The endorsement isn’t justified. Much of the video, appropriately named The UBB Deception, is filled with deceptive statements. For example, at close to the one minute mark, there is the false statement that says:

In fact, the equipment used to relay these signals doesn’t really care how much data is actually passing through the system.

Whenever a statement starts with “In fact,” my antennae get raised.

That “pseudo-fact” is news to any of us who have networks as simple as a home router, let alone managing a regional or national network. Think about your home WiFi router. If you are home alone, the whole home network is yours, including the internet access pipe. When someone else is home with you, both of you may be able to use the equipment without noticing each other, unless both of you are using a data intensive service such as simultaneously streaming HD video. But, if one of you is just casually looking at web pages while the other is into a heavier use application, the local congestion is not noticeable, despite both computers being connected at WiFi speeds of say, 11 Mbps or more, sharing a 10 Mbps internet access line. Clearly, your home network really does care about how much data passes through the system, not just the connection speeds.

Now multiply the number of users by millions and consider the network not being a local area, but instead, a regional access network and you can see how the “In fact” from video is just plain wrong.

The video continues saying:

which is why corporate internet service providers bill their customers based on the speed of their connections.

The real reason that corporate network connections are often not usage sensitive is because the monthly rates assume a heavier usage load than residential connections. The kinds of connections that are used by most corporate networks are presumed to be engaged nearly all the time. The vast majority of residential customers don’t use their internet access service that way today and so the networks haven’t been engineered for that kind of usage. Most residential users don’t want to pay the kind of rates that are paid by corporate networks.

Around the 0:45 mark on the video, it says that data is not a manufactured product and it’s not a consumable product. Come on now. This is a clever semantical word game. ISPs don’t charge for the data; the charges are for transporting the data the same way Canada Post charges to deliver the package, but not the goods inside.

The video continues to promote a scheme where the only pricing options for customers are based on speed. Low speed connections would cost less and high speed connections would cost more with no options for low volume customers to opt for a higher speed connection with a price break that considers their reduced traffic. As I have written before [such as here and here], this is hardly consumer friendly and serves to banish customers with lower internet access budgets from ever tasting higher speed applications.

The video continues to promote the false statement at the 2:10 mark that the CRTC “is staffed by former and future employees of the corporations”. It is not true, it is a cheap shot and it is an unfair slur against the integrity of the staff and commissioners at the CRTC. I trust the endorsement of the video with a statement that it provides “the real reasons behind” the UBB decisions, was meant to exclude the statement about the CRTC’s people.

I had to wonder what was considered to be the “real reason” behind UBB when I watched the video a few times. And then I saw it. At around the 1:33 mark, the video almost inadvertently provides exactly the motivation behind the fairness principle at the heart of usage sensitive pricing:

It is one of the few services in the world which increases in value the more you use it.

Actually, most flat rate priced services increase in value the more you use the service: local phone service, cable TV, health insurance, extended warranties, maintenance contracts, health clubs. In fact, it is hard to think of a service that doesn’t increase in value the more you use it, whether you pay on a flat rate basis or pay based on usage. You are willing to pay more because you are deriving more value. Would people be happier if the billing principle was called Value Based Billing?

Events ramp up

Mobile World Congress took place last month in Barcelona; CTIA’s annual event opens today in Orlando.

But Canadians don’t have to go far to see what is happening in communications. The Toronto Congress Centre is hosting two major events this year. My regular readers know about The Canadian Telecom Summit, Canada’s leading event for the communications and information technology sector, which is taking place this year on May 31 – June 2 in Toronto. [You really need to be there.]

But, do you also know that this year will see a return of a wireless industry trade show to Canada? The Canadian Wireless Trade Show is coming to Toronto September 15-16. I met with the founders yesterday over breakfast. Jay and Sunny are a couple of wireless industry entrepreneurs who are looking to target the hot mobile devices and accessories market. An increasing number of channels for the service providers are independent dealers; the trade show will provide an opportunity for them to learn about additional ways to satisfy customers and their love of their mobile devices.

The event is timed for right after the Back-to-School period and before the crunch at Christmas.

Compare the selection of accessories at an official carrier store and the kinds of things you see at kiosks and independent stores and you will get an appreciation for the range of toys that can be offered to customers to personalize their devices. Opportunities are available for companies to get involved with The Canadian Wireless Trade Show as sponsors, exhibitors and participants.

It has been nearly a decade since the last major trade show operated in Canadian telecom. It was good to see the enthusiasm that Jay and Sunny are bringing to this venture. I wish them all the best in organizing their inaugural event.

Playing by the rules

There was an important footnote to the CRTC’s revised process for reviewing wholesale high speed internet billing.

In Telecom Notice of Consultation CRTC 2011-77-1, the Commission notes that this proceeding will fall under the new rules of procedure that come into effect for proceedings with a public comment period after April 1. There is a footnote that reads:

The Rules of Procedure set out, among other things, the rules for the filing, content, format and service of interventions and interrogatories, the procedure for filing confidential information and requesting its disclosure, and the conduct of the public hearing. Accordingly, the procedure set out in this notice must be read in conjunction with the Rules of Procedure and its accompanying documents, which can be found on the Commission’s website under “CRTC Rules of Practice and Procedure”.

The filing of comments may be the most important point for individuals participating in a CRTC process for the first time. They should start by reading the CRTC’s page that provides General questions and answers about the new converged Rules of Procedure.

Elevator pitch

The FCC put its 3 goals into a single tweet. It was the ultimate elevator pitch:

3 FCC goals: modernize Universal Service Fund; remove barriers to bband adoption; unleash spectrum for mobile broadband.

Agree with them or not, the FCC was able to clearly set out its priorities. They were described more fully in an address [pdf] from FCC Chair Julius Genachowski.

Industry Minister Tony Clement has talked about delivering Canada’s national digital strategy in the coming months. It is the culmination of an inter-ministerial consultation launched a year ago, together with Heritage and Human Resources. It is certain to be a magnum opus – I wonder if there will be a printed version, or will Canada’s digital strategy will exist only in digital form?

More important than the form will be the substance and the follow-up. Can we focus on clear priorities?

Will the highlights of the digital strategy be able to be expressed as succinctly as the FCC set out its goals?

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