UBB: last day to comment

[D. Hugh Redelmeier]

The deadline for comments is 20:00 2011 May 12 EDT.

<https://services.crtc.gc.ca/pub/instances-proceedings/Default-Defaut.aspx?S=O&PA=A&PT=A&PST=A&Lang=eng>

Scroll way down to 2011-77 (second last).  Use the Submit button.  Or look at other folks' 
submissions.


I'm annoyed by trivia in the submission process:

They forced me to specify Mr, Mrs, or Ms.  What if I were a M?  I
happen to be a Dr. but I cannot specify that, nor can I leave that out
(my preference).

They would not allow me to specify an + in my email address, claiming that 
that isn't valid (it certainly is).

Here's what I just submitted.  It could have been better, but I'm
running out of time:


Comments on File Number 8661-C12-201102350: Review of billing
practices for wholesale
residential high-speed access services

By D. Hugh Redelmeier, Mimosa Systems Inc.

I strongly support the analysis in Vaxination Informatique's
submission.

The broadband last mile is currently a duopoly. The only reason it
isn't a monopoly is that two monopolies converged. I see no way for a
similar third last-mile network to be built by the market.

Free market solutions are generally considered a good thing. But
monopolies are not part of free markets. Monopolies musts be
constrained for the good of the free market. Regulations must be used
to harness them for the good of society and regulations must be used
to prevent monopoly power to be used as a lever to dominate parts of
the market that need not be monopolies.

The last mile is pretty close to a natural monopoly. Everything
outside of that should be severed from the last mile monopoly. This
logic should be applied to the provision of broadband internet service
to Canadian households and businesses. Clearly this was a motivation
for the CRTC requiring the last mile providers make their plant
available to the third-party ISPs.

There should be a simple rationale for this
“unbundling”, and that rational should drive
CRTC regulations.

As Vaxination has clearly laid out, limiting third-party ISPs to
relabelling last-mile provider's retail packages is quite misguided.
It defeats any imaginable purpose of the provision for third-party
access.

The regulatory regime must fairly reward the providers of the last
mile. This reward must be structured to encourage increased efficiency
(for example, reducing costs, increasing reliability, increasing
speed, and increasing access). It must not allow the monopolies to be
leveraged into monopolizing larger markets. It must not incentivize
inefficiency. A tall order.

The proposed tariffs (either retail or now wholesale) for UBB seem to
be orders of magnitude too high.  Logically, they should only be for
the shared part of the last mile.  That is the very cheapest part, or
should be. If it isn't, the last-mile providers would seem to be
intentionally crippling their systems.

One cure would be to give third-party ISPs (or even a fourth party)
access to the Central Offices to build their own backhaul capability.
That is only needed because of the intransigence of the last-mile
providers.

This says nothing about the CATV cable plant. That is more complicated
because more is shared. On the other hand, reasonable regulation of
the telephone last-mile might provide competition to drive cable
last-mile prices to a lower level.

Traffic shaping has some uses. It should be under control of the ISPs,
not the last-mile providers. One reason is that it gives a market
discipline to the practice.

I infer that one purpose of UBB and traffic-shaping is to provide
protection for the last-mile owners' other products: video and voice,
currently, in various packages. This is the sort of thing that the
CRTC should forbid.