Upload
the-jester-in-exile
View
220
Download
0
Embed Size (px)
Citation preview
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
1/26
Clarity, Transparency, Truthfulness, and Fairness:
Opportunities Towards the Improvement
of NTC MO 07-07-2011
(Minimum Speed of Broadband Communications)
Engr. Pierre Tito Galla, PECE
Democracy.Net.PH
September 16, 2014
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
2/26
Background: 2010 - 2011
Issue of slow internet connection first raised
publicly in December 2010
Public outrage because of announcement by NTC to adoptpolicy of data caps, as supported by service providers*
Stakeholders (telcos, associations, consumers) submitted
position papers for and against the proposed measure
NTC committed to the public: Public hearings on slow internet
Show results of telco audit
* http://www.gmanetwork.com/news/story/209385/scitech/ntc-s-proposed-data-caps-violate-
consumer-rights-lawyer-says 2
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
3/26
Background: 2010 - 2011
As a result of public hearings, NTC released NTC
MO 07-07-2011*
Heavily criticized** Ambiguity of service quality standards
Does not provide clear service quality monitoring processes
Does not provide clear dispute resolution mechanisms
Is especially unhelpful for prepaid subscribers
Is the current regulation governing internet connectivity
subscriber service quality
* http://propinoy.net/2011/07/29/ntc07072011msbc/
** http://propinoy.net/2011/07/29/ampaw-ntcmo07072011-pwe/ 3
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
4/26
Background: Present Day
Grace Mirandilla-Santos, independent ICT
researcher, participated in a study on internet
connectivity service quality* for LIRNE Asia. Participants: select South Asian and Southeast Asian
cities , including Manila
Study findings first presented at PHOpenIX forum
of DOST-ASTI
* http://lirneasia.net/wp-content/uploads/2014/09/BBQoSE-Report_Final.pdf
4
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
5/26
Excerpts from LIRNE Asia Study
Metrics and methodology
6 Parameters: Download, Upload, RTT, Jitter, Packet
Loss and Availability Multiple days: during the week and on weekends
At six times: 0800, 1100, 1500, 1800, 2000, 2300 hrs (3
readings per slot)
Averages of multiple readings for each time slot, takenfrom unannounced, unknown locations
Varying server locations: ISP domain; International
domain; National domain5
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
6/26
Actual vs. Advertised Speed
Download from an international server
0
10
20
30
40
50
60
70
80
90
100
110
120
0800 H 1100 H 1500 H 1800 H 2000 H 2300 H
SMART Bro Starter Plug-it (7.2 Mbps)-Manila,PH*
Globe Tattoo Prepaid Stick (3.6 Mbps)-Manila,PH*
Sun Broadband Plan 799 (3.6Mbps)-Manila,PH
ActualvsAdvertised(%)
Advertised "Up to" Speed
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
7/26
Latency - International
503 ms
438 ms437.6 ms
0
100
200
300
400
500
600
700
0800 H 1100 H 1500 H 1800 H 2000 H 2300 H
Latency
(RTT)
SMART Bro Starter Plug-it (7.2 Mbps)-Manila,PH*
Globe Tattoo Prepaid Stick (3.6 Mbps)-Manila,PH*
Sun Broadband Plan 799 (3.6Mbps)-Manila,PH
Lower the better
300ms
Philippine ISPs Only
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
8/26
Value for Money (kbps per USD)Philippine vs. select SA & SEA ISPs
0
50
100
150
200
250
300
0800 H 1100 H 1500 H 1800 H 2000 H 2300 H
Airtel 3G (4Mbps)-Bangalore,IN
Tata (3.1Mbps)-Chennai,LK
Airtel (4Mbps)-Delhi,IN
Airtel LTE (4Mbps)-Bangalore,IN
Ooredoo Data 99 (7Mbps)-Male,MV
Dhiraagu Data 200 (1Mbps)-Male,MV
Ncell (7.2Mbps)-Kathmandu,NP
PTCL Evo (9.3Mbps)-Karachi,PK
Etisalat (7.2Mbps)-Colombo,LK
Telkomsel Flash Ultima(3.6Mbps)-
Jakarta,ID
SMART Bro Starter Plug-it (7.2
Mbps)-Manila,PH*
Globe Tattoo 4G Flash(7.2 Mbps)-
Manila,PH*
Sun Broadband Plan 799 (3.6Mbps)-
Manila,PH
kbpsperUSD
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
9/26
Excerpts from LIRNE Asia Study
Key findings
21.7% was highest actual vs. advertised speed
achieved. Best performing PH ISP tested offered >256 kbps
download speed only 67% of the time.
All three major ISPs did not meet acceptable levels for
critical QoSE parameters (i.e., actual vs advertised,latency, jitter.)
PH ISPs has lowest value for money among all ISPs
tested (highest average: 22 Kbps per USD)9
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
10/26
Background: Present Day
At the invitation of the Senate, Democracy.Net.PH
submitted proposed improvements to NTC MO 07-
07-2011 Submitted proposal is improved version of MO proposal
submitted to the NTC in 2011 by various public
stakeholders
Improved MO taken up for consideration by TWG ofCommittee on Trade and Industry, for submission for NTCs
consideration as part of Senates power of oversight
10
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
11/26
Rationale of MO Proposal
Proposed Memorandum Order
Anchored on clarity, transparency, truthfulness, and
fairness Proposed order consists of:
Thirteen (13) parts
Thirty-eight (38) rules
Thirty-two (32) subordinate rules Service quality metrics and measurement methodologies
Service quality standards
11
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
12/26
Proposal Principle:
Clarity
The proposed MO emphasizes clarity of rules,
standards, and processes
Definitions of terms, alignment with ITU definitions Service quality standards are metricized and
methodologies to calculate quality metrics are provided
explicitly
Processes for standards implementation, consumercomplaints handling and dispute resolution, service
provider compliance, and NTC enforcement are set out
in detail
12
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
13/26
Proposal Principle:
Transparency
The proposed MO promotes transparency in the
enforcement of standards and processes
Service information is to be made clear on offers to thepublic and on contracts/ service level agreements
Common reference/ source of evidence for actual
service quality is established between NTC, consumer,
and the service provider Periodic service quality reports mechanisms, and on-
demand service quality reports mechanisms, are also
created for common benefit and reference
13
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
14/26
Proposal Principle:
Truthfulness
The proposed MO requires truthfulness from all
stakeholders NTC, consumers, and service
providers alike Truth in advertising is promoted by the proposed MO
Truthfulness of complaints is also promoted by the
proposed MO
Processes ensure that objective, measurable facts will
be the basis for decisions regarding dispute resolution,
service standards adjustments, and compliance
measurement14
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
15/26
Proposal Principle:
Fairness
The proposed MO mandates fairness between
consumers and service providers, to be fairly
enforced by the NTC Service providers are ordered to give subscribers their
rightful due, especially on complaints and required
rebates, whether prepaid or postpaid subscribers
Consumers have the responsibility to act fairly towardsservice providers, especially on complaints and issues
NTC is mandated to provided fair treatment for both
and between consumers and service providers15
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
16/26
Salient Points:
Quality of Service and Offers
In offers to the public, specify minimums, allow
the specification of maximums (up to) of:
broadband/ internet connection data rates data rate reliability
service reliability
overall reliability
Quality of service metrics, calculation methods,
measurement methods, and service quality standards
are provided.
16
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
17/26
Salient Points:
Best Efforts and Fair Use
Service quality standards for best efforts
services are provided.
Fair use policies are provided guidance as to theirpresentation to the public and their implementation.
Data volume capping, should service providers use
such a network management method, is given specific
rules to follow.
17
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
18/26
Salient Points:
Prepaid Service Offers
Prepaid service offers are allowed to have
different services rates, provided there will be no
difference in the implementation of service qualitystandards between prepaid and postpaid services.
Prepaid subscribers are given higher consumer
protection for service delivery, as higher is the
likelihood that their credits are consumed before
any substandard service is detected, disputed, and
resolved.
18
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
19/26
Salient Points:
Disputes, Refunds, and Rebates
A common source of objective evidence will be
used by NTC, service providers, and consumers in
the resolution of disputes. Processes for refunds and rebates are made clear
that it shall not be unreasonably difficult for a
subscriber to collect a rightful refund or rebate
from a service provider.
There will be no discrimination in the processing
of prepaid and postpaid subscriber disputes.19
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
20/26
Salient Points:
Service Standards Adjustments
Service providers are provided mechanisms to
request the adjustment of service standards,
should there be legitimate business reasons,particularly the inability at present to comply with
service quality standards.
Upon compliance with MO requirements, there is
no barrier to reducing service quality standards
for a limited period, after which compliance must
be with the appropriate service quality standards.
20
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
21/26
Salient Points:
Transparency and Compliance
Information for purposes of ensuring the
compliance of service providers is to be gathered
by and acted upon by the NTC. Subject to reasonable processing fees to be
collected by service providers, subscribers are
given the ability to request service quality
information regarding their subscribed service.
21
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
22/26
The Larger Picture
The proposed MO, implemented as is, is a step towards better
service quality of internet connectivity in the Philippines.
Upgraded laws, such as SBN 1091 (the Magna Carta for
Philippine Internet Freedom, filed by Sen. Bam Aquino; SBN53 by Sen. Miriam Defensor-Santiago), including amendments
to RA 7925, will help in the longer term.
Through the support of consumers, service providers,
government stakeholders, and the general public, longer-termimprovements can be made.
That said, a journey of a thousand miles begins with a single
step. We encourage the NTC to adopt the proposed MO.
22
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
23/26
A. Definitions
B. Rules on Offer Information
C. Rules on Measurement and
Metrics
D. Rules on Service Standards
for Standard Broadband
Connectivity Offers
E. Rules on Best Efforts Offers
F. Rules on Data Volume
Capping
G. Rules on Fair Use
Guidelines
H. Rules on Prepaid Service
Offers
I. Rules on Refund or Rebate
J. Rules on Requests for Service
Standards Adjustments
K. Rules for Transparency and
Compliance
L. Rules for Non-Compliance
M. Other Rules
23
MO Proposal Outline
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
24/26
Q & A
24
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
25/26
Appendix.
25
8/11/2019 Opportunities Towards Improving NTC MO 07-07-2011
26/26
END.
Stay updated on the
Magna Carta for Philippine Internet Freedom!
Facebook: facebook.com/groups/Democracy.Net.PH
Twitter: twitter.com/phnetdems (@PHNetDems)
Visit http://democracy.net.ph
26