Vous êtes sur la page 1sur 6

PHILIPPINE

CHAMBER OF

TELECOMMUNICATIONS
OPERATORS

|une 20L5

1-

Membersl
Boyon

Telecommunicolions Corp.
(BAYANTET.)

Copitol
Wireless, Inc.

Disiiol Telecommunicofions

lnc.

(DrcrTEr)

HON. DELITAH DETES


HON. CARLO JOSE MARTINEZ
h
L ^
DePutY Commissioners

Eostern Telecommunicotions

Phililippines, Inc.

Telecommunicotions

Compony, lnc.

HON. EDGARDO V. CABARIOS


Director - Regulatory Branch/CCAD

Subject:

PROPOSED TEST PARAMETERS AND


METHODOLOGYFOR INTERNET SPEED

(EXTETCOM)

Globe
Telecom, Inc.,

f-ij!5-

Attention:

(ETPr)

Express

!'lCi-it-[\lTC

iPu'.,____JUJ

(cAPWTRE)

Philippines,

REGLqLATICru
Rec'ei ii,v:

HON. GAMAIIEI A. CORDOBA


Commissioner

Dear Sirs/Madam:

(GroBETEr)

is made to the Commission's latest draft issuance on the

Innove Communicqtions,IncReference

(lNNovE)
phircom
Corporotion
(PHltcoM)

parameters and methodology for testing the internet speed of internet


service providers [SPs), a copy of which is attached as Annex "A."

of

For ease of reference, we shall respond to each item in the draft, point

- pOint.
'

Philippine Associolion
by
Privote Telecom Comoonies
(PAPTETCO)

phirippine Long
Telephone Co.

Disronce

with respect to the oarameters to be measured:

(PrDT)

1.

Philippine Telegroph &


Telephone Corp.

2.

(PT&r)

Pilipino

Telephone Corp.
(PrrTEr)

Smort

Communicotions, Inc.
(SMART)

3.

We agree to the recording of the downstream and upstream


average data rate.
We agree to the recording of latency, provided that it is
limited to an ISP's own network. Outside of its network, an
ISP no longer has any control over factors that affect latency.
We do not agree to the recording of jitter and packet loss. By
industry practice and pertinent regulations, the Commission
has not viewed these factors as essential to testing internet
speed, and ISPs have not advertised data reflectingthese
parameters.

Telecommunicotions
Technologies of lhe Phils. (ilPl)

28u' Floor, The Globe Tower, 32nd Street corner

7t'Avenue, Bonifacio Global City, Taguig

Tel 797 4268 o Fax797.2697

PHILIPPINE
CHAMBER OF

TELECOMMUNICATIONS
OPERATORS

With respect to the method of measurement:


Before we proceed, allow us to state what we understand to be the
premise of this methodology, namely, that it shall have only prospective
application, and shall be conducted only in relation to a particular
subscriber complaint. Since the Commission seeks to hold the ISPs
accountable for "truth in advertising," then what ought to be tested is
only what the subscriber complains of vis-d-yrs an ISP's advertised
statements.
We shall now tackle the proposed methodology in detail.

L.

"The measurement shall be conducted taking into consideration the

broadband/internet service providers' (lSPs) uncontrollable


variables (variables beyond the control of the ISPs)."

We agree with this. Among the uncontrollable factors are those


listed by us in our letter to the Commission dated March 30, 20L5
on the subject.

2.

"For DSL (Digital Subscriber Line), the measurement shall be done at


the station protector that connects to the drop wire."
"For FTTH (Fiber-to-the-Home), the measurement shall be done at
the "lN" port of the optical nehuork unit (ONU)."
"For fixed wireless, the measurement shall be done at the "lN" port
the fixed wireless modem."

of

We agree with the above methods, provided that the measurement


be done at the "lN" port of the ISP. Also, there is a need to define
"fixed wireless." Furthermore, before the actual implementation of
these three testing methods is carried out, the Commission and the
ISP must agree on the conditions for such testing, taking into
consideration the peculiarities of day / time, place, consistency in
the number of test samples to be collected and other relevant
circumstances obtaining at the time of the testing.

3. "For CAW, the measurement

shall be done at the LAN port of the

cable modem."
We leave the cable television operators to comment on this.

4.

"The measurements shall be taken using standard devices, available


c ommer ci ally w ith out chan g e s."

28tt' Floor, The Globe Tower, 32nd Street corner 7th Avenue, Bonifacio Global City,

Taguig

Tel 797 4268

Fax797.2697

PHILIPPINE
CHAMBER OF

TELECOMMUNICATIONS
OPERATORS

We agree, provided that the standard devices abovementioned (to

which the

Commission's testing equipment will

be

interconnected/interfaced) are ISP-issued devices.


"There shall be no applications that are running while the measurements are being conducted."

"The test equipment shall be free from viruses or any form of


melwqre."
We agree.
6.

We shall break down the following method according to their


component sentences.

"The places where the measurement shall be conducted, Point "A",


shall be a combination of known and unknown locations."

We agree only with respect to the known locations. We cannot


subscribe to any test that will reflect on an ISP's performance if the
location is unknown.
"The 'known' Iocations shall be agreed upon by the internet service
providers (lSPs), the consumer groups and the Commission."
We agree.

"The 'unknown' Iocations shall be selected by the staff who shall


perform the measurements. The 'unknown' locations shall be made
known to the ISPs and the consumer groups not later than 2 days from
the conduct of the measurements."

We do not agree. Again, we cannot subscribe to any test that will


reflect on an ISP's performance if the location is unknown and/or
over which an ISP may have no control or presence, as for example,
a deep basement of a building or a place where the signal is coming
from another country. These are just some extreme examples, but
they illustrate the potential mischief that can arise from testing
being done in unknown locations.

7.

We shall also breakdown the following method into its component


parts.
"The server that shall be accessed during the tests, Point'B', shall be
(L) within the local area network (LAN) of the ISP."

28tt Floor, The Globe Tower, 32no Street corner

7ut

Avenue, Bonifacio Global City,

Taguig

Tel 797 4268

Fax797.2697

PHILIPPINE
CHAMBER OF

TELECOMMUNICATIONS
OPERATORS

We agree, provided that "within the network" be further defined. In


this connection, please find attached as Annex "B" our proposed
diagram which we believe to be relevant to this testing method.
". , . (2) outside the LAN of the ISP but within the national network,
the

and (3) outside the LAN of the ISP and located outside
Philippines."

We do not agree. Again, this is because what happens outside of an


ISP's LAN, whether within or without the Philippines is not
completely within said ISP's control. See our Annex "8" earlier
attached.
In this paper, we have limited our comment only on the parameters and
methods for testing. We have not tackled the matter of publication, as
this was not included in the Commission's issuance which is the subject
of this paper. Should the subject of publication later be officially taken
up by the Commission, then, in the interest of due process, we reserve
our right to comment thereon.

Thank you for the opportunity you have given us to comment on the
present matter. We reserve, however, the submission of supplemental
position paper/s on the subject should the need arise.
Very truly yours,

ENGR. EN
Chairman

28t Floor, The Globe Tower,

32nd

Street corner 7t' Avenue, Bonifacio Global City,

Taguig

Tel 797 4268

Fax797 .2697

ANNEy ftlt
PaialTreters to be Measured
r.F fr';iie'"vire aarameters shaii ce aeasurec:

e.
:

lcw;'.st:ea::: ald ;ps,rsa: ave:age :aia rate


-g--

-.,

=. ii:tei

i.

Packet iass

i*eti?og af lvieasuren s:ii


i. lhe measuremeni shai; -:e :cncu:tea taking into consideration the brcadband/internet
service proyiiers' riSPs; uncc::l'ollable var!ables ivai'iabies beyond the control of ifie iSPs).
2. For DSL iDigital Subscriber -i:e;, the measui'ement shaii be cone at the station protector

4.

that ccnnects tc tne droP w!ie.


For FTTH iFiber-to-the-rione'i, tne measut'ement shali be done at the "iN" port of the optical
network unit iCNUi.
For fixei wireless, the rneasi:iemer:t shall be sone at the "lN" port of the fixed wireless

5.
6.

modem.
ior CA.l/, the measurenent shai: be cjone at the LAN port of the cable modem.
Tne .measu;erneits si:all be iakeir using standai'd devices, available commercially without

3.

:hanges.

V.'There s:ail be

ro

appi:ca:i:ns that are renning while the measuremehts are being

;oniucted.

8. -le
3. lie

frcn

or any form of malware.


p;aces wie; the :=as;:::T.enis siai: s: :ctlcuctei, Point "A".' shall be a combinatior:

:est ecuipment si'.ail be ::e=

','ii uses

c; k:gwi^. aic ;;;<ic;t':-. ;::ai:s;s. Iie .'kl:w::" iccations shal! be agreed upon by the
irte:ie: service prov!cers iiS?s;, the ccnsumer groups ancj the Commission. The "unknown"
toca:icns s:'iaii s=te=ei 3y ii:e s:aff who shall perform the rneasurements. The "unknown"
lccaticns sraii. se maoe kr;wl:r ihe iSPs enc the consumergroups not laterthan 2 dals
frorn the concuc of the
=eas';:em=nts.
1C- Tire server that shail be accessec ciuring the tegcs, Point "8", shall be i1) within the local area
network ilAN j of the rsP, i2; cutsicje the ii.N of the lsP but within the national network, and
i3) outslcje the LAN of the lS? anc iocatecj cutsiee the Philippines.

ANNEX

Method of Measurement 10. 1


Point "B" within the LAN of the

ISP
INTERNET

WEB
CACHE

-VIRUS

DOMAIN
NAME
SERVICE
SERVER

BACKEND SITE A

DSL NETWORK

SITE A