NTC TWG Meeting On Broadband Speed Dated 4.23.15

Page
Continuation of Public Consultation on Broadband

Speed
April 23, 2015/2PM |1
REPUBLIC OF THE PHILIPPINES

NATIONAL TELECOMMUNICATIONS COMMISSION
Quezon City
--------------------------------------------
Continuation of Public Consultation on Broadband Speed

-----------------------------------------TRANSCRIPT
OF THE STENOGRAPHIC NOTES TAKEN DURING THE PUBLIC
HEARING ON APRIL 23, 2015 AT 2:00 IN THE AFTERNOON, BEFORE
ALL CONCERNED OFFICIALS AND REPRESENTATIVE OF DIFFERENT
GOVERNMENT AGENCIES AND STAKEHOLDERS
----------------------------------------
ENGR. SUSANA PANES =

Good Afternoon everyone. Pasensya na po, Dir. Cabarios
cannot
attend this Technical Working Group Meeting.
He has an important
commitment.
Malacaang. We can
continue our discussion last time. I think
may kopya na po ang
bawat
discussion with this summary of
isa.
Right
We
now,
can
he
was
continue
in
our
what we did last time. So,
any comment po dito sa pinrepare ni Dir. Cabarios?

ATTY ROY IBAY =
Good Afternoon po, Madame Chair. Before we start on what
we
talked during the last technical meeting, we just
want to clarify, we
have
yesterday from, I would assume from
received
an
CCAD
sending us a revised updated draft. So, we just want to put
e-mail
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April 23, 2015/2PM |2
(cont. Atty.Ibay)
on record, what is the status of that e-mail and the
attachments
supposedly draft stating that it is
now the subject which is quality
of
service
standards for internetconnectivity services. We just want

to ask to put on the record on what is this document that
was
circulated
among
previous technical
the
participants
of
the
meeting.

Actually, I am not aware of that e-mail but I can verify this
one
with our secretary.
ENGR. PIERRE TITO GALLA =

Madam
Chair,
may
Cantara,PECE. I am
speak?
am
Engr.
one of the co-founders
Pierre
of the
democracy.net with me is Carlos Nazareno also from

democracy.net. Now, the e-mail that you are referring to
is a proposed revised draft based on the discussion on
the last meeting. What we did was to take the draft that
was being discussed during the last meeting and then
convert the discussion points that were done last
meeting
then
resubmitted
the
said
proposal.
You
probably noticed from the document that the definitions

were no longer included in the definition of terms. It was
moved towards an Annex. Individual parameters were
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April 23, 2015/2PM |3
moved also to Annexes and so on. And then, we also

included, based on the discussion last meeting and other
(cont. Engr.Galla)
meetings, the definition of best efforts. So in something
that based on the definition made on the previous
meetings that the ISPs want to make clear that a lot of
services that they are providing are best efforts. Means,
the definitions be presented as well.

Okay, so that was submitted for Comment.
ATTY ROY IBAY =
I would like to clarify Madam Chair and will be put on
record that this is their suggestion and not adopted in Toto by
the NTC. And
that this is the input or suggested draft by
democracy.net and
nothing anyway an adoptive draft. So, it
is on record.
Democracy.net does not represent this working draft of the
NTC, instead, as you have seen the previous proposal, right?
There have been a lot of good suggestions from ISPs and a lot of
discussion on
that. And we think that TWG will be best serve
if we can use this as

not to.
ATTY ROY IBAY =
one. But it is up to the NTC whether or
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Okay, may I also clarify that? We just like to proceed from

where
we asked just a recap on what was stated here. We
also look on the

(cont. Atty.Ibay)
Transcript on the Stenographic Records and quoting the
NTC on
Page 19 of the Stenographic Records. We would like to
state that
during the last meeting, paraphrasing on what NTC
said on Page
19 that current meetings that we are doing now or
conducting now
is basically to find out what to measure. So, it
is stated here that this
Minimum Standards if ever should be discuss
earlier if there is still
need
to
Standards. What we read upon is
include
Number
meeting is that we need to empower the
the
Minimum
on
the
past
consumers to make it
more transparent to make them known on
what
they
are
paying for and that they get what they are paying
for. And in relation to what the other agencies like DTI and
the
DOJ are doing that it is the NTC that shall have the
mandate to at
least verify if what the carriers or ISP providers are
really what are
supposed to be advertise. But short of that, no
standards no
regulations because we again reiterate that
internet is a valuewhat was discussed
added service. So, if I adequately cover

previously, we also mentioned that
similar to the broadcasters, we

self-regulation for the ISP Providers.
believed that the worst penalty that the service
would like also to address the

In
sense
that
provider
we
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could received is our consumer itself will transfer from
one
provider to another. Because of inadequacy and because the

fact that we really not address, supposedly, service providers as
profess to deliver to the consumers. And so, we would also like to
(cont. Atty.Ibay)
address what we have addressed in the other meeting.
Another,
would
be,
moving
forward
from
our
meetings
previous to this
meetings today is that we would like to address
mainly three issues
to measurable standards, download speeds,
upload speeds and
volume. So, I think those three are all
adequate and sufficient
enough for our consumers to know
whether or not the internet
service that he/she would pay for
would be adequate enough
already
or
not.
So,
anything
forward we feel that aside from what
the technical principles
being discussed now, we also feel that it
would
also
be
good
probably to have a series of technical or field,
validation tests in
order to find out whether or not the suggested
points as contain
here in the official minutes of the NTC being
circulated now is
actually adequate for testing. So, it may be
pointless if
we limit ourselves to discussing them here in this
Conference
Room. And we feel that would be good to go out and
actually
conduct these tests to find out if it really works or if there

other better ways to find out accurately the measures of the
standards that we are proposing without being uncontrollable
variables. That is all, Madam Chair.
are
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Any other comments from the group?

Clarification po. First point, on self-regulation, we are not
agreeable to the idea in principle. Ideally, we were in Kenya
where there are sixty plus Internet Service Providers
because that will be analogous
to as the gentleman
mentioned just like the broadcasters there would be so

much stations to choose from. Where in fact, in our
industry right now, we only have very very few choices to
choose from so currently, the idea of self-regulation is very
lightly not applicable to the Philippines. Second point, on
the idea that speed and volume be sufficient basis for our
subscribers to know whether or not we are getting what is
correct. I agree on this principle, however, measured speed
itself or measures volume is not sufficient unless we
measure it against the standards. Perhaps, we can
measure it against the advertised speed. So the actual
speed versus the advertised speed would be a good
measure probably on some sort of index would be good. Or
that would be different in some standards differently to the
download speeds versus advertised downloads, upload
speed versus advertised upload and so on. So, at least we
will be half sorting indication on the variable planning. So,
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we take that index, X divided by Y is times let say number

of pesos and then you will find out that we were getting
90% or 80 %. It is also part of the proposed metrics of
secondary proposed draft. However, also, reliability should
be something that
(cont. Engr.Galla)
we think be included because not just been it is good if we
are able to get 90% speed all the time that is great.
However, if outages are not included in the metrics, it
would be similar to excising the amount for our customer
experience so if we are able to include service reliability it
would also be good for all of us. And then, finally, on the
parameters that are presented here in the official minutes,
we also include them on the proposed draft. We agree that
some sort of first field measure
should be done so that
it would also be able to see where we are in establishing a

based line, such that if we are agree that this is the
parameters that we will set then maybe we can move
forward and establish a standards mandated. Thank you,
Madam Chair.
Thank you.
MR. CARLOS NAZARENO =
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April 23, 2015/2PM |8
I would also like to add to that. The other party mentioned

the
download, upload but latency and packet loss is also very

important. Because for drop packets, it can render your
real-time
applications
Massive Online
like
video,
live
streaming,
MOOCs,
Video Learning Services so when you drop
packets, the client will tend to resend packets in the server and
it can add to bandwidth.
Sayang
magreresend and then service time-
young
bandwidth
kasi
outs. So there are also
numbers of real time applications will break
(cont. Mr.Nazareno)
when packet loss reaches a certain level. And then also
latency is
very important because some real-time applications
is rely on real
time.

Madam Chair, maybe it will be useful for the bodies to see
the
comparison for this performance metrics versus the
subscribers
experience.

Before we continue our discussion. I think we have a copy
of this
one. This came from Dir. Cabarios. This was part of
the minutes of
what we have discussed last time. It is written
on the paper that the
growth agreed on following aspects. The
following parameters
shall be measured (1) Downstream and
upstream average speed,
(2) Latency, (3) Jitter and (4) Packet
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loss. The location of point A shall be hybrid, i.e., some of the

locations shall be known and other locations shall be determined
by NTC staff who shall conduct
the
measurements.
location of point B shall be (1) within the
The
local area of the
TelCo, (2) outside the LAN of the TelCo but within
the
national network and (3) outside the LAN of the TelCo and
outside the national network. And the last point is the
results,
including the locations of points A and B, shall be
released
within five (5) days after the end of each month. I
think this was
what we have discussed last time. And we
were expecting that we
(cont. Engr.Panes)
will be dealing on this agenda because we are trying to
come with the parameters that we are going to consider in
measuring the
minimum bandwidth. But I would like to ask
now is that are we all
agreeable with this for what we had
discussed last time. Yes, Atty.
Ibay?
ATTY ROY IBAY =

Madam Chair, as I previously mentioned, on the point of
the
TelCos we discussed doon. Actually, we agreed upon what
was
suggested by both TelCos and democracy.net previously.
That is
for item B. This is for the items that we measured.
But we did not
commit in fact we said that we will discuss
among industry. But we
will submit whatever factors or
variables that we have agreed upon
to be measured. So,
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that is the reason why we disclose early what
the factors that
we want to measure only are upload, download
speed
and volume. So, we submit that is our position, we do not

submit to latency, jitter and packet loss. Instead of latency,
jitter and packet loss is volume for the consideration of the NTC.
And
the other methodologies, these are also discussed but I
think we
will limit ourselves to the process by which there will
be no
uncontrollable variables meaning within the network.
I think our engineers here will be more adequate to discuss.

Any other comments?
ATTY. ANTHONY FERNANDEZ =

Madam Chair the testing on the testing point. All of these
points
had
been
discussed.
discussed as options but
We
were
simply
after meeting with the group
you were more confident that you
would
available if you will test us within in the full context
be
more
of
our
network where we have control not outside our network.

Again, with due respect to the test points, we were discussing last
time na the controlled points would be
which are created
by the NTC.
control point at NTC but Ms.

suggested that there will be multiple points in
Grace
servers
Initially, there is one

of
LIRNE
across
Asia
the
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country also advised in the NTC offices. I think if it is

within our network then we have control.
Any other comments?
MR. CARLOS NAZARENO =
I think we also have measurements on controlled points or
not
controlled points outside the network. Because that
is the actual
used case that the consumers used. They
connect the servers
overseas which the local ISPs have no
control over but that is what the consumers accessed.

In fact Madam Chair and for the acquisition TelCos, we
proposed if you look at the Annex F and Annex G of the
proposed draft,
what you will able to see there a process by
which a TelCo should
not be penalize or should not be made
accountable for any
variability
network. But from within
that
comes
outside
your
the network, obviously, because
that is the subscribers connection, in fact, it becomes fair. But

again, it is not about the TelCo that we penalized. So, if I am
paying a hundred pesos for X,Y and Z, but
ninety pesos worth, siguro naman it is worth
returning the ten
pesos to you. So that is where we coming from. In
only
getting
Annex F,
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you will find the propulsive of the citizens charter by which

quality of service complaint will be handled and
mediated
by the NTC. And Annex G, it is the service provider who

complaint.
Especially
if
the
service
the
provider
A,
has
the
substandard service of the service provider A is not cause

by this
network but is cause by somebody elses network. I
would
resumed for instance that Cable TV internet provider
have such means to be able to show that it was not their

connectivity to their
cable internet but rather their backend
that was their problem.
Now, if all the citizens charter also
provides that the second TelCos,
meaning
complaint about, should not also be
the
TelCo
being
unaccountable. A, if the
service provider A complaint properly to
(cont. Engr.Galla)
his counterpart TelCo. B, if the service provider B provide a
penetration measures for our service provider A. And C, if
there is
none, then that is the time that the NTC step C. But
we will, of course, make sure that we will respect contractual

relationship
between
processes of Annex F and
TelCos.
Hence,
the
proposed
Annex G. So this is again in line
with allowing for measurement out of the national outside of the

land but within the
network and outside of the land of the
TelCo and within the
nationalize
outside of the land of the
network
and
conversely
Telco and outside of the network. I
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am sure Sir, perhaps, you have
sufficient
time
to
review
these new decks.

ATTY ROY IBAY =
Actually, that was only said yesterday but per year we
actually
met. We understand. We took a look at, actually it is
also the
reaction of their previous draft.
was just assigned
But I guess this
if the NTC put on record that it is not
their job. What we are saying
is that if the NTC will consider
this in Toto as a working draft then
there is really no point
that we are going this TWG because we are
already
submitted a position paper largely on this version. And

moving forward which we would like to say that it is really
their right to submit such a draft. But considering the gains and
heavy
way that we are already achieved in conducting this
TWG, it
(cont. Atty.Ibay)
should be two steps backward if we are going back to this
discussion on standards. It is better if we already, Engr.
Pierre was not here on
discussions with DOJ,
the past two meetings, we have

we have discussion with DTI that is very
productive. That is why
we are working this TWG to be able
to move forward to agree
on
measure in order to comply. We
certain
parameters,
how
to
are already actually gone on
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the discussion on which jurisdiction
across
the
hook
meaning, DTI and DOJ have their jurisdiction to enforce truth and
advertisement. And the NTC has also has its own
jurisdiction
in terms of being measure in accordance, and with
relation
the DTI and DOJ to have measure. So, as we said,
internet
to
should be a value-added service. It should be deregulated but

we support consumer rights, we support that the consumer has
to get what they pay for. And we agreed that
in
accordance with the mandates of the DTI and DOJ that on

whatever it is that service
providers advertised, there has to
be a way to measure whatever it
is that they are supposed to
get. So, because of that, we are able to
move forward but if we
are able again to dwell on the draft which
has been already
previously discussed and there was submitted position

paper then there is nothing for us to say.
We are already
submitted that position.

We would like to point out that I know I was not present but
siguro
naman minutes and everything were able to read.
But that is it,
PAPTELCOs position, TelCos position will be
valuable enough. We have been using that and that NTCs

position, DTI and DOJs inputs, those were all part of the creation
of the draft. So, we do not
consider
this
as
two
steps
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backward because again, the end goal is a
working
document as an MC by which the NTC will raised. What
we
are saying is that we will listen to you and we have meetings, in

fact with such ISPs and DTI and DOJ. And the end result of
that is
we are proposing this draft. I am sure you have no
time to really
read through it because as you said NTC just
based on what you
said. Everything that has been discussed
on the past meetings was

best effort, that the minimum
incorporated their statement like

should be set by the ISPs and
so on. They were not missing.

ATTY ROY IBAY =
I categorically disagree. I just like to maintain that we just
move
forward on what will be discussing. And if that is their
right to
submit a draft, so practically okay with us. But we
submit to the
NTC that we just proceed on what we will be
discussing and that it
is their position to give consideration to
supposedly being
discussed. But we maintain that it did
not.

Can you tell us how?
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Excuse me. Before we continue with our discussion, maybe

first we
will hear from Globe then afterwards I would like to
remind you
that the Commission is hoping that we can to
come up with
parameters that we are going to discussed.
That was the instruction
to Dir. Cabarios, otherwise, the
Commission will be the one to
prepare
necessary in order to come up with the
whatever
proposed
Minimum Broadband Speed. So, we will hear
MC
is
on
from Globe.
MR. MEDEL RAMIREZ =

Good Afternoon, Madam Chair. Actually, we coordinate with
these
past minutes. This is also being agreed among us.
And for Globe,
we follow on what was said by Atty. Roy, as a
PCTO and a
member of Globe.

Yes, but I would like to ask if, yes, according to Atty. Ibay,
he is not favorable of measuring latency, Jitter and packet loss.
Kasi I just
based on what was written here in this paper that
was given to me by Dir. Cabarios. It is my understanding that

during the meeting
we are all agree to take this parameters
as our basis for the
measurement. However, it was noted
that according to Atty. Ibay,
(cont. Engr.Panes)
it is the position of Smart that they are not favorable in
considering
Latency, Jitter and Packet Loss that we will take
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into consideration
that we will put that on writing so that
the Commission can study
this aspect. Yes, Anthony? Would
like to say something?

ATTY ANTHONY FERNANDEZ =
Yes, Madam Chair, just to further solidify the point. We
agreed to
discuss that point but there is no fine agreement. We
just simply agreed
that
we
consider
the
following
for
consideration.
ATTY ROY IBAY =
We discussed in our group what would be acceptable to the
industry and after discussing it came out that we all
consider at least the three: the upload speed, download and
volume.
MS. ALELIE GERMAN =
Good afternoon everyone. Perhaps, the ISPs could help us
to
understand on why there is a vision on Latency, Jitter
and Packet
Loss so that it could put on record also. Thank
you.
MR. REGIN BRIONES =

Latency, Jitter and Packet Loss are very technical metrics.
And if
regulatory
the objective is empowering the public on their
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(cont. Mr.Briones)
consumers, I think this technical parameter
already
metrics are
be has the right impact on the download speed,
upload speed.
That is incorrect, Madam Chair. May I use the projector?
Yes.
Perhaps, for the benefit of the DOJ. As you can see their
differences in how performance metrics affect the subscribers
experiences. So, if you are browsing a text based tsaka wall of
text, typically like
ghost.ph. Download is important, upload
is irrelevant, latency is relevant, Jitter is not, Packet Loss is not.

Browsing download is
important
for media for example, you
are watching You-Tube. Download is
important, upload is
not relevant, latency is very relevant, Jitter is relevant, Packet

Loss is relevant. Redundantly,
only
the
relevant, upload is not, latency is not, Jitter is
download
is
not, packet loss is
not. Transactions like BIR recently, download is not very relevant,

upload speed is not very relevant, latency is very
very
relevant, and Jitter is very relevant as mentioned
by
Carlo
earlier, packet loss is not relevant. Streaming media, if you

are
going to watch, download is very relevant, upload is not
relevant,
latency is very relevant, Jitter is very relevant and
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Packet loss is
very relevant.
VOIP,
Skype
and
other
applications, download and

(cont. Engr.Galla)
upload are not as relevant as Latency, Jitter and Packet
Loss. This is
where you will see all those corrupt pixelized
the conversing in Skype. Even if your speed is really good but

your Latency, Jitter,
Packet loss are high, you do not have
those pixilation. For games,
online
gaming
like
those
is
performed by people in general or speed particularly you have

done with. Upload speed not so
relevant,
Jitter and packet loss are very relevant.
This
cannot just be in volume, you cannot just be
again,
is
Latency,
why
upload
you
speed,
you cannot just be download speed.
MR. REGIN BRIONES =

I think this is refers to the relevance not with direct impact.
Obviously, packet loss has always effect on any media
browsing.
If you will get the document, Jitter and Packet Loss,
generally, is
very important to real-time services. So, VOIP
and games these are
real-time applications. But speaking from
radio just like the fuji
unji UMTS from radio perspective, we
have four classes of
services:
interactive and the background.
training,
conversation,
Voice is categorized as real
time but it is not a packet switch. But all
internet
connections
we get via UMTS and LTE are class as
interactive. So, it is
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not categorized as real time service. Then, that
is
interactive.

Yes, that is one of things we took there in the proposed
draft. We
include the definition of the best efforts there for
exactly what you are saying.

MR. REGIN BRIONES =
So, that is why on my point of view, speed can already be
measured
or
there
download, upload
what we offer since it is
is
already
an
enough
measure
speed plus the volume per plan doing on

an interactive class of measure.

Interactive class of service? And you are mentioning UMTS?
LTE? Will this position of PAPTELCO cover the fixed broadband
and all
that? Will it still a plan? So, we will not measure? You
do not
intent
to support the measurement of these
parameters for fixed?
MS. MARIBETH SANTOS =

Yes, we have this in our position.
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Do you submit to the DOJ that, that it is not exactly fair?

Because
as you see, this run is the gallop of subscribers used.
So, I released
my LTE phone to Skype, is that something that
I should able to
do? Or should my contract say please do not
use your Skype while
(cont. Engr.Galla)
you are on the cab. Because I will not know my Jitter is. I
think my
speed is good based on LTE. Assuming that I am
getting what
speed I am getting the advertised speed,. But
it is clear here that it
is not really about the speed. It is about
latency, jitter and packet
loss.
ATTY ROY IBAY =

I think what Engr. Pierre was saying is that you are using a
wireless, LTE? That is precisely I am saying. Fixed line,
wireless
or a mobile, there are so many uncontrollable
variables. He was
saying that let us say that I cannot use
my Skype and the cab, it
depends.
Probably if the cab is here in the area
Where
wherein
there so many people using the internet? That
is
the
cab?
traffic
and
would
affect your internet user experience. Or if you are in the
cab
and the cab is somewhere out in the rural area or something

then that would really affect the usage experience. There
are some
variables that you were saying that may affect your
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user experience. That is why for wireless, for mobile and fixed
internet
there are also certain variables
saying that is
that is why were
why we are discussing now. Maybe we could
also be proper now
to schedule
tests to be able to really
those
certain field
accurately simulate our suggested
metrics. This is probably our suggested metrics. And to be able

to compel and find out which
(cont. Atty.Ibay)
would be accurately in terms of being determined what is
the
actual
considered.
speed and download volume metrics are to be

Considering
what
the
TelCos
are
only
suggesting or pointing out is that this will be done in a controlled

environment.
MR. CARLO NAZARENO =
I would also like to speak as a member of International
Team Developers Association Manila Chamber. I would like to
point out
that gaming is not necessarily all man. Game
development has been bringing billion of dollars in China and

Korea. And the terrible latency we have in the Philippines in the
packet loss has been
hampering
developing products which
us
gain
developers
from
can bring dollars in the Philippines.
It has been very distractive. It
has been hampering us for
fifteen years. So, it is crucial that we get good

minimal pocket loss and this does not only on
latency
gain
and
developing
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industry. This also extends to the creation of start-
ups
which
involve real time video and document sharing, real time

communication apps. I, myself, download with this but the
problem is within the same room. I am on Bayantel and I
am
PLDT, I am a subscriber of both. I build an app which is
multi platform video. The latency was so terrible. There are

about 200-300
milliseconds between two devices in the same
room. And it is
destructive to the Philippine software industry.
ATTY ROY IBAY =

It is easy to quote without any data to backup your
statement, Madam Chair. Because let say that the video industry
has been
driving in fact it is going big and
mount and that
you have data to show that the data you are saying let say you
are saying I am sure
it happens. But to quote to
absolute like tangent and
being
expensive.

Yes, you are right. You are
we
recognize
talking about the IDVTO can
your efforts on that note? But remember the
quality of this connection of IDVTO is not covered by this

memorandum circular. It is covered by the existing
Memorandum Circular the
one that is mentioned na MC
No. 12-19- 2004 which is committed informationally. That is
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what they are getting, that is what they are using, that is the
context they
have with you.
ATTY ROY IBAY =

So, you are saying in connection with the industry? So
maybe you have to specific what subscription are you using. If
probably your
coming from an industry and you really want a
committed rate
then you will subscribe. Why you are saying
bandwidth the
adequate only for a residential and let say for
example for a
(cont. Atty.Ibay)
demand that would probably approximately something for
a small
enterprise. That is what the enterprise packages.

I would like to comment on that. The problem is our
customers are
using home subscriptions. So, that is why
destructive.
ATTY ROY IBAY =
I think the problem is we would like to relay to the
consumers or
really adequate residential consumers.
We do
not want to talk to
people to subscribe to residential plans
and we would like to
ascribe unlimited bandwidth to a service
that should probably
subscribe that are committed internet
bandwidth rate. How can
you say that your carinderia and
you would like to assume that
your
business
will
allow
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bandwidth for a free wifi that a hundred
consumers will be able
to used. May consumers in carinderia not

serve
been
able
to
toward subscribed to residential.

Excuse me lang po. Atty. Roy, I understand. Anyway, I just
like to
the
remind the group that hopefully we can come up with
parameters. That is why we set for another schedule or
date for this
technical working group so that we can arrive
to the parameters
that
we
technical parameters before the
are
going
to
consider
the
Commission can react to the
MC. So if we may not able to come with
the
parameters
then
maybe the Commission can prepare the

(cont. Engr.Panes)
MC. But we are given a chance to the TelCos to really make
recommendation to the Commission on how we can
measure. That
is why we are considering all your inputs
together with LIRNE
Asia. Sana po we can able to settle on
this points na we have already listed the measure that we are

going to consider. Sana we
can only focus on these items that
we have already enumerated to
this paper so that meron po
tayong output today. Sana po we can
have a good decision.
Thank you.
ATTY ROY IBAY =
Madam Chair, at least two points lang po on the gaming
site. We
actually have several subscribers of ours on slow
internet rate
because
sometimes
they
subscribe
to
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residential or to small base
but they took it up in internet caf
which is unfair also. There are
consumers
residential there are willing to pay sa service
naman
and
na
they
can
defied their connection which is high. So, the higher CIR,

more stable it is. That is why we are saying if you have
the
a
higher requirements subscribe to a higher plan. Because of the

basic residential basically your CIR will be a low number
but not as high as other packages. If you want a higher CIR,
subscriber to a
higher package. Second item is why only for
the reservations only
the speed of download, upload and
volume because that is what we only commit to our subscribers

po. So if in our regulatory
environment that we will measure
on the truth and advertising
(cont. Atty.Ibay)
then let us measure on what we are going. Yung kinomit is
worth
accurate delivery? But again, if other subscribers,
consumers or
those who want to measure other parameters
outside the regulatory bandwidth let us say the uninformed

charge for the
consumer protection like
they rate us
excellent or fair or
something like that po. But in the
indexes and then
whatever. We are not
regulatory environment po,
what we commit is what
we measure. Kasi kung dinidikta na
po samin na parang dapat
ganito sukatin mo ito, parang they
figure upon on how to run the

Packet Loss and latency po, it is our
business already. Yung Jitter,

best interest po na to
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give this figure within acceptable limits kasi
when
there kahit sabihin namin na we are delivering the
you
are
speed
and
the volume, kalaban po naming ang subscriber naming
na
magsasabi na, I do not like you, we will leave. That is more of a

penalty na it is hard to make from us. So, kung sabi ng
subscriber na I am happy with you that is more than reward for
us. Just your
interest to keep this figure on a acceptable
level kasi po mahirap po
kung
san
ka
kasi
ang
pinakakalaban mo is yung customer mo. Yung public perception

pwede mo pang defend yourself. But when
the
says, goodbye I am leaving you, wala na po kaming
subscriber
laban doon.

We took that in college dati na in so far as standards are
concern, as
I presented you this presentation. In Annex B,
you will notice the
speed, how to measure the data and so
on, so forth. In Annex C,
what we propose is exactly what
you are saying but we are not
going to tell you what your
maximum Jitter is is or what is your
maximum
latency
is.
We will provide that index a connectivity quality index. Let us

say for Plan 999 of wi-tribe, you will get a
Connectivity
Quality Index of let say 2.6, so it is good. We are not saying that
you should penalize for it. It is just sounding that the public
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should be better if they know. Let say 3.6 rating which is

and so
very
on and so forth. We are not telling you what is your
minimum should be, that is up to you. What we are saying

is that
the metrics should be measured and it should be
included in such an index so that in consumers, we purchase

the right higher end
plans if we are higher end requirements.
And if you do not, then let
us speak to that. We are saying
that a carinderia who uses those
speed
contain vanity, of course not. I think we
should
will
be
just
able
submit
to
our
position paper to this Commission.

ATTY ROY IBAY =
And looking forward, I think on the approach as you
mentioned earlier that we commend a field or simulation test on
what you
suggested
discussed today or
in
whatever
quality
whatever
we
previously. Because I think it is pointless
if we can go on and
(cont. Atty.Ibay)
discuss until the end of the time if we do not really try to
simulate
test, we cannot achieve on something.

Madam Chair, it is good idea that we have a field test, in
fact, LIRNE Asia was not here but we can able to see a previous
test that
the LIRNE Asia tested for South-East Asia. Maybe we
can ask
LIRNE Asia to submit methodology in such items.
MS. ALELIE GERMAN =
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It is okay to have the field test but do we have the

equipment too?
Perhaps, the TelCos you have but how about
the NTC? How can
we validate that?
ATTY ROY IBAY =

I think for the NTC, my suggestion is, they already have
agreements that they can secure but again, this is
probably
depends on the call of the NTC. We just like to state
that this are the what they are suggesting. That would be the
more or less the contention of the test. So we are able to come
with the more
accurate metrics. And on the benefit of the
DOJ, a lot of these tests
is in fact to that require tools. They
are just programs and we
need just to record the data. So if
the TelCos wanted for instance to
measure for a certain areas,
that will be their tools. But for the
parameters
discussing for the past hour, those are the
that
readily
we
are
available
used metrics on a cable.

Before we are going to take into consideration on your
suggestion regarding on what test we are going to conduct, we
will put that on
record and will consider that. Probably, we will
inform the Commission if they are okay with your suggestion.

ATTY ROY IBAY =
Madam Chair, the democracy.net agreed also to our
suggestion in
order to come up with well-informed and
accurate. So, just for they

consideration of the Commission.
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We would like to say here that our position paper is

completely not
adversarial with yours. We understand that
there is a really big
difference between enterprise level users
and consumers. So, hence,
the change of the title that you are
recommending change of the
title is quality of service. And
that, Annex C provides an index on all standards. Annex B is

probably something that we are going to hammer
out
whether or not we agree on the minimum. Well, we
ask
again to the position of the Chair. This is something that we

took together, in Control 11 and Commissioner Cordoba
promised
on an apple
happen or not.
document. That I do not know if it
Based
on
offerings that are in the
the
standards
Annex
what we took together. We do not
for
the
service
B of the new draft, this is
have comparison
for
the
proposed max speed against the current corresponding

technologies that are available today and that
(cont. Engr.Pierre)
the TelCos can use not just the TelCos but ISPs such as
Cable TV
and so on. So, for example, service offerings invested
for minimum
speed that shall be used by the ISP, maximum
speed shall be used
by the ISPs. This is the current practice,
is not it? So, the internet
which is the based line of all the
internet around the world. So
without prior to go through to
take all of the implementations in
the standards. The reasons
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why you have technological minimum
speed
is
service providers typically put them all together to
because
trans
range. What happen is if I can go back to this one, from
the
GSM
2G of 14.4 KPBS down and up, you moved app to its absolute
maximum of edge of 1.9 MBPS and so on and technologically
speaking that is for them to control, that is for the
networks to
manage. So, that is why we made a definition. And
please also
note that the proposed maximum speed is very far from

technological max speed. We recognize that you need to
manage
your networks, the number of subscribers you have.
Because it is
not definitely costly efficient if you are going to
spend too much to
be able to deliver something that is
already too high. So, this us up
to you.
MR. REGIN BRIONES =

In relation lang doon sa what is edge type two EO type one
EO type
two. These are the
standards by edge those for the

Edge revolution type one the max
download is 1.2 MBPS. I do not know if they are
declared
building edge.
speed
of the
implementing it
right now that is why I am asking. Previous night,
we do have
GSM 2G. I do not know what 2.5G is. I think Goble,
Smart, Sun
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have
that.
The
mobile
MBPS. In the
internet
basically
starts
with
13
technological point of view?

It is with edge.
MR. REGIN BRIONES =
Okay. But edge is after the implementation of GSM as well.
Yes it is.? We have to this hard way because there is no
public
declaration of what Telecom Industry is using in the
Philippines.
You have mentioned the technological brand
name but not the
technology. I found out in instance that
the TV we are using here in
the Philippines we are not sure
because there are two kinds, LTE
2x2 and LTE
do not know which one we are using in
4x4. So we
the country. And the
max speed of the 2x2 is 173 megabits per
Second for 4x4 is
326 MBPS per second. What we are proposing for
the
definition is high speed broadband of the Philippines, it is
(cont. Engr.Pierre)
proposed minimum speed of 2 Megabits per Second which
is less
than 1/3 of technological max speed.

Madam Chair, I just want to interject while it is nice to
know that
we are discussing this briefing. Now, we are giving
our focus on
the Memorandum Circular
for fixed internet
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service.
So that we do
past just in the few
not
want our achievements in the
meetings.

Yes, sir, thank you very much.
Any other comments from the group? From PAPTELCO?
So we just clarify that what we are discussing is more for
fixed parameters?
Hindi , it is a new.
The Commission wants a separate?
We actually considered yong discussion in the past na isa
nalang na
document para klaro lahat. That is why the definition
of wireless,
(cont. Engr.Pierre)
mobile internet, mobile broadband all came out is based
on the
implementing rules in the Philippines. We, as
consumers, do not
know technically
implementing but there are
what
you
are
public documents from the
ITU that declare all this. So, we put this
here. You are correct
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when in pointing out that we do not
use
edge revolution
one and two? So, if not then that is not part of spectrum of the
speeds that we are looking for but we know how
we
are
going to fix again the technology.

ATTY ROY IBAY =
Just to clarify. I think what we discussed is that there will be
one
MC that will deal at least on the methodology of
measurement. But
the approach of measuring wireless and
fixed will be different. But
that
will
be
containing
one
document.

Any other comments? So, if none, we are going to consider
your suggestions for what we have discussed today and we will
just
inform you on what will be the position of the Commission
as
regards with you have all suggested today. So, if there are
no other
comments, can we adjourn the meeting?
MS. ALELIE GERMAN =

Just a clarification. The ISPs are willing to be deregulated
on
volume, download speed and upload speed? But you are
also open
on
parameters?
NTCs
publication
of
your
Jitter
or
other
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ATTY ROY IBAY =

First of all, we said that based on our discussion, the
carriers have
agreed based on what we have advertise or
what we will offer to
our subscribers which will be focus on
upload speed, download
speed and volume. Since those are
the factors or those are the
service parameters intend to offer
to our consumers. And because
we
awareness and their right to what they are
support
consumer
paying for and to
get what they are paying for. Therefore, it is the
NTC should
in partnership I guess with the service providers to be

available and also to the consumers to come with the
methodology
measurement.

Just to clarify. You will support upload speed, download
speed and volume? We are common there to the standards for
the reliability.
ATTY ROY IBAY =
What you are saying is that, that is what we offer to our
subscribers. We would like to be measure on the basis of
upload
speed, download speed, and volume.

Not on the reliability?
ATTY ROY IBAY =
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Just reliability is really question of how controlled or

uncontrolled
the conditions are existing in the area.

But currently, you are already complying with the paper
07-07-2011
which
says 80% reliability.
ATTY ROY IBAY =

On minimum speed. What we are proposing is average
upload or
advertised
minimum speed but
speed.
No,
you
cannot
on our declaration,
advertise
we are compliant
of 07-07-2011. But this is
different. You want to
so you are saying that you
want to be measure based on what
we advertised and offer to
our subscribers then you could
measure your upload, download
avail
with
and volume.

Yes, right. You are 80% reliable on minimum speed?
ATTY ROY IBAY =
Yes.
Then, can we continue using that metric?
ATTY ROY IBAY =

Well, basically, again, we are going back to your draft.
What you
are saying is we are now on this page, we are now
discussing on
what
standards
are
we
agree
with.
So,
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resubmit, upload, download
and volume. I cannot go beyond on
what the industry has already
agreed upon.

When would be a possible time for other stakeholders to
weigh in
on this possible figments on the MC? Kasi parang
unlearned presented yong like industry people like developers

aside from the
consumers.

This technical working group is limited because we are only
dealing on technical parameters. And as what we have
discussed a
while ago, all your inputs are all noted and all
your proposal is also
take into consideration. At this point, I
cannot give the position of
the Commission as regards to your
suggestions. Maybe we can
inform you in a few days on what is
the position of the
Commission. We will just notify you. But
all your comments and inputs

comments from Globe?
MR. MEDEL RAMIREZ =
Nothing, your honor.

From PAPTELCO?
MS. MARIBETH SANTOS =
are
all
considered.
So,
other
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None, your honor.

From DTI?
MR. RONALD CALDERON =
None.
From DOJ and democracy.net?
MS. ALELIE GERMAN=
None.
None.
None.
From Atty. Ibay?
ATTY ROY IBAY =
None.

So, if none, thank you very much.
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Transcribed to the best of my ability.
ELIZABETH G. LAMADRID

NTC TWG Meeting On Broadband Speed Dated 4.23.15

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Continuation of Public Consultation on Broadband

REPUBLIC OF THE PHILIPPINES

Continuation of Public Consultation on Broadband Speed

ENGR. SUSANA PANES =

attend this Technical Working Group Meeting.

continue our discussion last time. I think

may kopya na po ang

discussion with this summary of

what we did last time. So,

any comment po dito sa pinrepare ni Dir. Cabarios?

talked during the last technical meeting, we just

yesterday from, I would assume from

sending us a revised updated draft. So, we just want to put

supposedly draft stating that it is

now the subject which is quality

standards for internetconnectivity services. We just want

ENGR. SUSANA PANES =

with our secretary.

ENGR. PIERRE TITO GALLA =

one of the co-founders

democracy.net with me is Carlos Nazareno also from

probably noticed from the document that the definitions

moved also to Annexes and so on. And then, we also

ENGR. SUSANA PANES =

that this is the input or suggested draft by

nothing anyway an adoptive draft. So, it

that. And we think that TWG will be best serve

if we can use this as

one. But it is up to the NTC whether or

Okay, may I also clarify that? We just like to proceed from

we asked just a recap on what was stated here. We

also look on the

during the last meeting, paraphrasing on what NTC

19 that current meetings that we are doing now or

is basically to find out what to measure. So, it

is stated here that this

Minimum Standards if ever should be discuss

earlier if there is still

Standards. What we read upon is

meeting is that we need to empower the

more transparent to make them known on

least verify if what the carriers or ISP providers are

really what are

supposed to be advertise. But short of that, no

regulations because we again reiterate that

internet is a valuewhat was discussed

added service. So, if I adequately cover

similar to the broadcasters, we

would like also to address the

could received is our consumer itself will transfer from

provider to another. Because of inadequacy and because the

meetings today is that we would like to address

mainly three issues

to measurable standards, download speeds,

upload speeds and

volume. So, I think those three are all

adequate and sufficient

enough for our consumers to know

whether or not the internet

service that he/she would pay for

would be adequate enough

forward we feel that aside from what