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  • MR 2011 77 Comment Scope

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    Mark Goldberg
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    MR_2011_77_Comment_Scope

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    49 views2 pages

    MR 2011 77 Comment Scope

    Uploaded by

    Mark Goldberg

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as PDF or read online from Scribd
    Flag for inappropriate content
    of 2
    Mark Rubenstein ruberslein mark@gmell.com VIAEMAIL February 22,2011 Mr, Robert Morin cretary General Canadian Radio-Television and ‘Telecemmunications Commission Dear Me, Moti: Re: ye and terms ofthe proceeding ‘Thank you very much for allowing interested partes to this Consulation an opportunity to comment on the request (© modi the scope and tems of the proceeding. [have had a chance to review the submissions of a number of different parties. Iam very interested inthis issue and am writing to provide my personal comments on the requests ‘The Public Interest Advocacy Contre (PIAC) and the Consumers’ Association of Canada (CAC) have asked forthe deletion of the references in paragraph 12 and 13 tothe principle thot “ordinary consumers served by Small ISPs should not fund bandwidth used by the heaviest retail Intemet services consumer”, In my view the removal ofthis principle against crosssubsidization is unwarranted and the Commission should not adapt. this recommendation by PIAC and CAC. The public's outrge over the issue of usage based billing UBB") is based in my view less about the particular decision in CRTC 2011-144, and more about the overall perceived high prices and low bandwidth limits that exist in ‘Canada, The principle behind UBB is a sound one forthe purposes of billing faimess 0 “The regulatory goal for wholesale residential high-speed access services has been to create more competitive industry that fosters innovation and provides for teal consumer choice, I is clear to most Canadians that the current marketplace does have not created the optimal level ‘of competition. The Commission than should medi its seope and tems as best 10 be able ‘achieve thie goal. While the outcome of the Consultation aay lead to an altemative method in implementation, the pineiple of UBB should not be abandoned. While the Commission should expand the scope of the proceedings to investigate ways to lower the overall price, it should not allow for usere who conauane dhe meet bandwidth fo be aubeldized by these from the larger ISPs who consume less [do agree with many of the partes who have submited comments that thre ie inadequate competition in the market for residential high-speed internet service. It is unclear though, if the Commission can fashion an appropriate remedy for this problem within the confines of ts regulatory power oF whether it is necesarythat policy and legislative changes be undertaken that fall within the responsbility of Cabinet and Parliament. I do agree with broader conclusion reached by the Canadian Network Operators Consortium Ine, (*CONC") in their Jeter to the Commission. The terms and scope of the consultation proceeding should be expanded 0 address the broader regulatory famework applicable to wholesale high-speed sccess services. This may help answer the larger question about competition in the ‘marketplace or atthe very least identify the limits in what the Commission ean do With respect o procedural changes requested by the various partis, the Commission should undertake whichever procedures best accomplishes any revised scope and tems tothe Notice of Consultation Yours truly, Md Bll. Mark Rubenstein interested parties (via email)

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