Opportunities Towards Improving NTC MO 07-07-2011

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


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


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


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


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


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


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


8/26

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


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


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


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


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


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


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


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


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


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


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


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


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


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


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


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


24/26

Q & A

24


25/26

Appendix.

25


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

Opportunities Towards Improving NTC MO 07-07-2011

Documents

Transcript of Opportunities Towards Improving NTC MO 07-07-2011