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REPUBLIC OF THE PHILIPPINES

NATIONAL TELECOMMUNICATIONS COMMISSION


Quezon City
--------------------------------------------

MEETING ON THE MINIMUM BROADBAND SPEED


-----------------------------------------TRANSCRIPT
OF THE STENOGRAPHIC NOTES TAKEN DURING THE MEETING ON
APRIL 16, 2015 AT 2:00 IN THE AFTERNOON, BEFORE ALL
CONCERNED OFFICIALS AND REPRESENTATIVE OF DIFFERENT
GOVERNMENT AGENCIES AND STAKEHOLDERS
----------------------------------------

DIR. EDGARDO CABARIOS=


Good morning everyone. Umpisahanna po natin. First,
thank you for coming over again. We will try to finish
everything by next week because the Commissioner
wishes

to

have

thispromulgated

by

next

week.

Subukannatin kung kaya. Well, last yesterday or the other


yesterday,

we

have

circulated

comment

from

democracy.net tsaka LIRNEasia on the position paper. On


the position paper of the PCTO, we will not yet discuss it
now here. Ang pag-uusapan natin that was agreed last
time ay yung technical aspect lang muna. Doon muna tayo
mag-concentrate.Kasi kung titingnan nyo, magkalayo konti
but that can beresolve later on. As I have, kung walang
consensus at the end of how many tries, the Commissioner

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will have to decide. Yun ang bottomline but hanggat maari


we
(cont.Dir.Cabarios)
should strike consensus. So, yung technical aspect nyan is
first we will discuss here yung parameters na susukatin.
Second is papaano. And third, if we are to set minimum
service performance, ano yun? So, yung tatlong yun
langangating paguusapan so far. All the others will be
reserve at babalikan natin after ma-discuss itong technical
aspects. Yes, Derek Lim?

ATTY. DEREK LIM =


Good afternoon, Sir, good afternoon everybody. Sir, with
all due respect, why next week? Can I ask candidly? Is this
because of the SONA?

DIR. EDGARDO CABARIOS=


Hindi naman. It is just the wish and the hope of the
Commissioner na kung maari daw ay ma-i-promulgate next
week. Yun lang ang wish nya as relate to me yesterday.

ENGR. ERIC DELOS REYES=


Just for the record, Sir. We have not yet received the
Comment that you mentioned. You said that it is already email.

DIR. EDGARDO CABARIOS=


Yes.

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ATTY. ROY IBAY=


I think that paper should be circulated among the
participants of one meeting.

DIR. EDGARDO CABARIOS=


Ang sinabi ko is yung sa April 8 meeting.

ATTY. ROY IBAY=


Yes, just for that.

DIR. EDGARDO CABARIOS=


Wala ka ba nung April 8?

ATTY. ROY IBAY=


Yes.

DIR. EDGARDO CABARIOS=


Okay, I am sorry.

ATTY. ROY IBAY=


Okay, just put on the record.

ATTY. ROY IBAY=


Okay, sabihan natin si Moray.

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ENGR. ERIC DELOS REYES=


Also for clarification, my understanding during the meeting
is that one of our group members offersto assist the NTC in
coming with the specification for the measuring equipment
that the commission will buy. I think that is the record from
the PLDT. Our offer is to assist the NTC in coming up with
the specification. In fact, you mentioned, if I have
remembered correctly, that it has to be something that is
post take?

DIR. EDGARDO CABARIOS=


No, it is general, as general as passive. Not to detailed as
to point one supplier.

ENGR. ERIC DELOS REYES=


So, that is the reason why we are here. Well, I just want
that for record.

DIR. EDGARDO CABARIOS=


Yes, but whatever is the agreed parameter to be measured
and how it is going to be measure, yun na yung magiging
terms of reference doon sa bibilhin na equipment.

ENGR. ERIC DELOS REYES=


Okay, since you have mentioned it. I just want to add some
statements. I just like to inform the commission that the
cost of our

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(cont.Engr.Delos Reyes)
Technical Working Group. We discussed specifically what
we offer to NTC. Just like the PCTO as what they want to
offer NTC coming up with the specifications that will be
used in measuring the performance of the ISPs. Now, there
are basic questions that came out. First is that we want to
know if there is already a mind set, for the NTCs concern,
of what the NTC

if the NTC has already avision or

something that they really want for this purpose.Because


as much as possible we want to know if what we will be
recommend and what we will study also and is in line and
consistent on what the NTCs vision. Number two is we
want to know if there is already an existing test procedure
that the NTC has issued within the commission. We want to
know kung existing ba yan. If we have an existing policy or
maybe may not be consistent in what we have to do.Now,
also, when we are discussing, one question also came out
asking if, baka kasi we are spending so much time to this
then at the end of the date then the NTC will say wala
kaming pera e. So, we want to know if the NTC has a
budget to this. Because we will recommend that we will
have take cost. So, this is the basic question that we would
like to be clarifybefore we proceed further.

ATTY. DEREK LIM =


Sir, good afternoon again.Can we have five minutes to say
something from our industry?

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DIR. EDGARDO CABARIOS=


Yes.

ATTY. DEREK LIM =


First, before we begin, we would like to start reiterating our
basic position that internet access is supposed to be a
value-added service. Therefore, it should be deregulated.
And by participating here, we should not be consideredas
waiving our objection to be intent to regulate the provision
of broadband service. Now, despite of the industrys
objection, the commission is still determined and still intent
to issue. If it is intent in issuing a circular to regulate the
internet,

we

only

have

this

request

that

any

final

Memorandum Circular to be issued must be the result of a


very deliberate carefully, thought out consultativeprocess.
This is a process that is cannot be rush. I understand that
the Commission is tryingto draft a circular that would
replace the existing NTC Memorandum Circular No. 02-072011. So, my question is if that is the intent of NTC, is the
NTC considering that first Circular a failure? We do not
want to replace one failure with another failure. We leave
that haste or we make ways. So, we should not rush this.
That is our basic position. Because if we rush it, that rush
would only hurt the consumer more than it can hurt the
industry. Then, if it hurts the industry then it became cycle,
it would go back in a negative way to the consumer. While

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we respect the attempt of the consumer like democracy.net


that propose parameters for testing, it is our humble

(cont.Atty.Lim)
submission

that

these

formulas

while

they

maybe

appreciated by scientific personmightnot be appreciated by


the normal person.Any Memorandum Circular, if it is to be
effective,not the simple and not that ordinary subscriber
will be available what are. And will also be able to
understand whenis right being violated. And I think that is
true also for the service providers. They have toknow
exactly what the circularobligates them todo beforethey
can beliable.That is part of due process. So, instead of
presenting complicated formulas even scientific persons
might also have difficulty understand it. We proposed that
the industry or the consumer sector suspends thispropose
circular in the mean time. And instead work together with
NTC in jointly developing anact to measure various
effective parameters for internet service performance.
After taking consideration, of course, the various concerns,
the technical concerns that we are calculating this
afternoon.

Hand

in

hand

with

consideration

of

the

development to a possible act, we also want to inquire into


the kind of equipment which the NTC grants to acquire.
Exactly, what is the purpose of that equipment? What is
capable of doing? What it is intent to measure? And how it
is intent to measure it? And what conclusionsare expected
to be drawn after the results of the use of equipment are

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attained? We should be able to take into consideration the


various variable factorsaffecting internet speed which may
or may not be in complete drawn of internet service
provider. After

(cont.Atty.Lim)
considering all the technical considerations then that is
when the legal provision will can be examine after just to
make sure that they do not conflict to the technical
provisions. We will also consider after the technical aspect
studied ifwhat are the various violations and the penalties
of

each

violation?Can

we

consider

also

mitigating,

justifying, exempting circumstances? When is exactly the


ISP beingliable? We are saying all of this because wewant
to have a circular that would really work if we are going to
agree that the circular must be issued. We are as much as
patriots as democracy.net and LIRNE Asia are. We are not
here to obstruct for the sake of obstructive. The fact that
we have a lot of meetings among

ourselves only

evidences how seriously are we in taking this issue. Sir, we


would just like to be heard on this matter. And we hope
that the technical working groupmeetings that we are
going to participated will now be achieve that objective.

DIR. EDGARDO CABARIOS=


Thank you very much Derek and Eric. First, on budget,
there is a budget approved by the Congress. We have
requested Congress for a budget last year. We have

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submitted our budget request last March 2014.That


equipment is supposed to measureand is supposed to
implement yung MPO that was issued on 2011. But
because there is a proposal to amend that oneao we might
as well wait for this so that the equipment that is going to
purchase ito na

(cont.Dir.Cabarios)
ang i-memeasure nya hindi na iyong nauna and because
the budget as approved this only moved for one year. So,
the bidding process has already started because the
bidding process takes awhile so we have to prepare terms
of reference already. Kasi kapag bumili yan ng mga bid
documents, isasama na yung mga terms of reference, yung
dapat nyang isupply, etc. And that is the reason why kung
pwede ng igawa ito, parameters to be measured, how it is
measured, wag na muna yung setting the standards,
perhaps. Because that would be easykung ilalagay mo sa
measuring. Ang mahirap, of course, is how it is measure
and what parameters are going to measure. So, iyon po
ang ating ididiscuss. After all, this is generic naman,
parameters to be measure and how it is measured. Ganon
lang po muna iyon in the mean time. So, let the output of
this, once we get the consensus ibibigay po sa ating NCR
para sila nap o ang mag-draft nung terms of reference for
the prospective bidders. So, ang ibig sabihin nyan kasi all
the other issues wag po muna and that will be taken after
we have agreed on parameters and how it is measured.

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Iyon po muna but setting the standards uulitin natin, kung


hindi tayo makakuha ng consensus ngayon ihuli na natin
yon. What is important is alam natin ang kungano ang
susukatin natin and how it is going to be measure.

ATTY. DEREK LIM =


Maybe sir, there might not be a need to set the minimum
standard after all. Becauseafter all,what really matters is
empowering the subscriber to know the quality of the
service that is experiencing in the particular area that is
using the internet. And in that aspect, we go by the view of
LIRNE Asia. It is more ofempowering the subscriber by
making and giving him an informed choice.

DIR. EDGARDO CABARIOS=


Kaya nga sabi natin is ihuhuli natin iyon that minimum
standard.

MS. MARY GRACE SANTOS=


Good afternoon everyone. I would like also to express our
appreciation that the TelCos and ISPs are active in
supporting the technical working meeting. Just a few
points, Sir.I think the issue here can be divided into three
aspects. First is the policy. Are we clear of what the NTC is
trying to do? For the LIRNE Asia, it is clear of that mandate
of the NTC is. First and foremost is to ensure that the

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consumers of the telecom and internet services are


protected and the rights are being upheld. Second is the
technical aspect and which I thought thepoint of this
meeting. What to measure, how to measure and who to
measure. The third is the legal aspect. Who is liable and
how do we make those stakeholders liable? If I could just
suggest Sir.Actually, Dir. Egay has been telling us from the
start of the meeting that we focus on the technical

(cont.Ms.Santos)
aspect. What I would agree in Mr. Lim said aboutmaybe we
could just not set a minimum standards. While LIRNE Asia
does agree with that. Itonly agrees upto someparameters
only likeminimum download speeds,uploads speeds. What
we want to do is to measure those true puts and see what
does the TelCos and ISPs deliver. We just want to know
where are we at. So, for particular locations it is for
example, ano ba talaga ang kayang i-deliver ng PLDT and
Globe? But that does not mean that we would stop there.
All other parameters should have their acceptable levels or
standard levels. For example isyour latency. How many
milliseconds would it take for your data to travel for local
server or to an international server? Dapat may set limit
yun kasi may international standards po tayo dyan. For
example, Singapore is recommending their ITA. Thirty MS
lang dapat pag-local server lang not and not above. Tapos
three hundred MS sa international server. So, may mga
nakaset na standards sa ibat ibang country depending of

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course to their setting. For example yung noise which


would affect DOIT. DOIT would agree na very useful yanfor
OFWstrying to communicate to their families.So, meron
dapat tayong sineset for thoseparticular parameters. So, I
just would like to clarify that yung recommendation ng
LIRNE Asia is to net set. It would not make sense to set
minimum download speed at this point. So, maybe we can
just start with knowing what the average or typical speed
is for a particular location.

ENGR. ERIC DELOS REYES=


So, meaning benchmarking?

MS. MARY GRACE SANTOS=


Well, it is tricky to say benchmarking kasi when you are
saying that you are comparing with other countries. But
yes, we will start benchmarking within what we have and
what the service providers are capable of doing. Kasi right
now do we even have a local benchmark for different
parameters? Does the NTC have that?

ATTY. ROY IBAY=


I have a question Dir. Cabarios. For the basic service
usually the drive test being conducted are being performed
by the NTC-NCR for drop calls collocation. We are just
wondering if the equipmenthave been already purchase
methodologiesassuming what have been agreed upon to

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that. Is the budget of NTC for a nationwide testing or just


for the NCR scope area only?

DIR. EDGARDO CABARIOS=


For

the

drive

test

we

were

able

to

acquire

one

benchmarking equipment in 2008, if I not mistaken. But


this is of course the time when there were so many
complaints about drop calls, etc. And year 2010, if I may
not mistaken, we have acquired another four. So, we have
one for Mindanao, one for Visayas, one for Luzon and NCR
we have two, I guess, because the traffic is in the NCR. So,
we

(cont.Dir.Cabarios)
performed drive test every month. But the result is release
every quarter. But that is only for measuring the drop calls
at block calls. All the other parameters na sinusukat like
the strength of signal, etc. but this are just for information.
We have set standards for two, drop calls and block calls.
Meron na pong ginagamit nag anon but of course time is in
changed hindi nag anon ang direksyon ngayon and the
problem is in the internet speed. So, iyon po ang kailangan
nating bilhin.That is the reason why Congress is approved.
Isa lang po ang mabibili so far, only for NCR in the mean
time. We are going to convince the Congress again to grant
us para yung mga regions ay bigyan din. That is only
around ten million kasi. The approved budget is around ten
million pesos only. So, medyo may limitasyon din but that

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can be used para ma-imeasure ang dapat nating imeasure.

ATTY. FRANCIS ACERO=


Just for a consumer protection point of view. There is only
reason why we want to put certain minimum standard. It is
for living purposes for the consumers. We need to
understand that when we say certain words to

the

consumers there is created a set ofexpectations already for


them. It might not be, for example for the broadband. For
them, they have already idea of what broadband is. They
come from here, they come from experiences abroad but
they have already an idea. So, when they come back here
and something

(cont.Atty.Acero)
na, Oh, you say broadband pero hindi naman pala
because it is not here. In that way, when they missed to
understand.You do not need to set standard. And for us, we
agreed that we follow the ITUna it should be 256KBPS
minimum for broadband to call it broadband. And for fixed
line or mobile, 56 KBPS. But that is just the more pro-active
just for the consumers to say na, okay, I know what I am
getting when the company tells that I am going to get a
broadband service. I am actually going to have a
broadband service as I know it to be.

ATTY. DEREK LIM =

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Sir, we truly appreciate Ms. Grace and Atty. Kiko have


shared. But when we appreciate the need to study the
international examples.We also hope that these series of
meetings that we are holding should also take due
cognizance of the peculiarities of the Philippine situations
because not everything that works abroad may also work
here,not everything thatapplies there necessary applies
here. So, the MC should take those peculiarities and give
consideration.

DIR. EDGARDO CABARIOS=


Si Eric muna.

ENGR. ERIC DELOS REYES=


Thank you so much, Director. I would just like to comment
on what was mentioned earlier to the question in fact
whether are we clear on the NTC Mandate as far as the
policy is concerned. I think we are agreethat the NTCs
intention is to improve the broadband services here in the
Philippines. What we cannot agree is the regulations
which would believenot consistent to the existing laws.
But you can see, we are convening our technical people
here to contribute that is why impose those questions,
ano ba ang nakikita nila saNTC? Baka may mga nasa isip
nila.Isusuply nalang naming ang mga additional, may

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pera ba yan Meron bang existing policy?Those are the


things. Ang inaano lang namin is,because of the difficulty
that is why we are here, incoming up not necessarily to
the parameters, choosing what parameters would need to
apply. Sabi nga sa meeting kahapon, baka natatandaan
nyo yung sinabi kong metro pop music festival. Yung start
nunare about technical aspect pero hindi sya sumisikat
pero yun ang pinaka-magaling.But they will later on
realize that teka metro pop ito. Ano ba talaga ang
naintindihan ng tao to change the criteria?That is what we
are trying to determine here. Ano ba talaga? It may sound
good, the Jitters and everything. So, may process na dapat
i-consider. But is it useful for the public? Because at the
end the public will chose to appreciate what we are doing.
Yon ang gusto natin that is why we are here.Ano ba ang
gusto nating gawin to assist you?In fact, during our
meeting kami kami mismo

(cont.Engr.Delos Reyes)
nagtatalo na teka ito siguro yung pwede nating matuong
sa NTC. That is why the concern earlier, kailangan ba
nating madaliin itona maraming mag-ooppose, maraming
mali?Or gusto nating moreefficient ang approach pero
tama.Pag inapply natin lahat tayo masaya, consumers,
carriers.I think gusto din naming yun e kasi quality service
will translate to additional costumers and revenues for
us.Kaya nga sinasabi namin na one of the main objections
namingdun sa MC ay may penalty provisions with all those

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variables na-pepenalize kami for some typical. Wherein,


the best ultimate penalty is for us to lose our subscribers.
If they are not happy with us then we fall down. You do not
need to penalize us because we will lose our own
subscribers.

MS. MARY GRACE SANTOS=


Sir, from the LIRNE Asias point of view, we would like to
really proposehow discussing the, asAtty. Lim said, the
controllable and uncontrollable variables. That is very
technical, we can discuss that. We can actually start now
at least the technical people are here, the engineers are
here, we also have our own technical and LIRNE Asia has
done measurement for some years. So, we can start
discussing right now here. The service providers can tell us
is this something that you consider a controllable or
uncontrollable? And we talked about our own context.
Because that is important is you are measuring quality
service of mobile broadband. That position is

(cont.Ms.Santos)
very difficult to set standards from one broadband. Other
countries also have that kind of difficulty but then it is
impossibleto

set

standards

because

somebody

set

standards. Again, we have started benchmarking,what


their service providers can deliver and then started
studying and analyzing from quality service from year one,
year two, year three and then they will set the standards

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and what is the acceptable level. Kasi hindi naman pwede


na wala tayong minimum na acceptable level of service.
So, that is our stand. If I could jumpna sir to the propose
parameter based on what LIRNE Asia has measured in the
past.

ATTY. DEREK LIM =


Before Ms. Grace continue, sir will you allow us to
intercheck the point of order? Once we discuss the
technical and legal aspect, perhaps, it will be good for the
proceedings to be transcribed? For the guidance of
everybody that there will be a TSN to avoid for it to have
misunderstanding.

DIR. EDGARDO CABARIOS=


Yes it is being transcribed and meron po tayong staff
Stenographer working for this one and there is a recorder.
Before Atty. Kiko, the mandate of the commission is clear.
We have to balance the interest of both networkservice
providers and the consumers. There are times when the
side of the consumers ay mahina ang boses we

(cont.Dir.Cabarios)
have to stand for them. But kungpareho ng malakas ang
boses nyan, we have to stay in the middle and then when
there is no consensus then we will decide. That is the role
of the commission. Balancing the interest of both.Perhaps,

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we can, paguusapan po muna natin yung parameters and


how it is being going to measure. Yon lang po muna.

ENGR. ERIC DELOS REYES=


Kaya nga po I was asking earlier baka meron that will make
a starting point. If you have something already that we can
start or that we can start for somethingna pwedeng
starting point natin. Baka meron ang Commission that you
can provide us now.Kaya nga I was asking again meron
bang existing measurement policy ang NTC that was
issued? Or what you have in vision for the budgetthat was
release to the Commission. Meron na bang initial na
pagaaral ang NTC on what particular equipment or
parameters? Meron na sila Grace na ideas on the
parameters. I think we can have interaction here. But
coming out with basic ideas I think we need a starting
point. What we are going to do?

ATTY. DEREK LIM =


Sir, we do not know if there are already technical directives
issued by the guidelines of the NTC so that we can put a
starting point.

DIR. EDGARDO CABARIOS=


Well, wala naman po, so far. As I have said, as we
requested for that budget, we are referring to 2011
issuedkasi wala pa poi tong thought of amending the

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2011.Ang nasa isipan ng NTC doonis measuring the


minimum kasi yoon ang nasa 2011. Ngayon, if we are
going to amend, ano po iyong susukatin? Of course,
popular is speed. Anywhere, iyon ang parating lumalabas
comparing that.So, perhaps, yoon ang magiging sentro
nyan and all parameters to be measured susukatin
poiyon.Now, for the information of the consumers, as I
have said, if there is a need later on to set minimum
standard and we agreed to do that then ilalagay po dyan
ang minimum standards, etc. Pero ngayon tingnan po
muna natin kung ano ang susukatin. Hindi po pwedeng
mawala iyonbecause iyon ang gustong malaman ng tao so
dapat nandoon iyon. Whether to measure the average
speed, minimum speed, up and down, nasa satin poi yon.
Let us discuss and agree and then we measure the Jitter,
latency etc. So, ilalabas naman po ang information na ito
later after measuring and getting as many datas as
possible at saka irerelease iyong information.Thank you.
Yes, Grace?

MS. MARY GRACE SANTOS=


Sir, I will just continue on what I was saying or discuss
earlier. I think if the technical people are here then we can
start discussing the technical aspects. By agreeing, for
example, on the basic parameters that we want to
measure. As Dir. Egay said that the true

(cont.Ms.Santos)

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puts are basic, download and upload. LIRNE Asia actually


encourage even the upload speed should be measure
because the prevalence now of clouds. Kasi people are
using drop box and so many applications wherein the
upload speed is coming more and more important. So, may
I know the technical people part? Kasi we are always
talking to the lawyers.

DIR. EDGARDO CABARIOS=


Okay. Si Eric is a technical person, si Anthony, si Regin, si
Medel, si James nasa likod.

ENGR. ERIC DELOS REYES=


Kaya dinala namin kasihindi naming ma-compute yong
formula nyo.

MS. MARY GRACE SANTOS=


Maybe we can start?

ATTY. FRANCIS ACERO=


Our measure in modem in simple.We developed a tool that
interrogates a modem.
intersectionbetween

So, at that point that is the

whatever

the

TelCo

can

control,

whatever the users control. So, for the tool, there is a


scriptinside

the

tool

to

interrogatesthe

Interrogates a network types now and

(cont.Atty.Acero)

modem

state.

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then

get

the

upstream

bandwidth

and

downstream

bandwidth from the modem. It will also check the stateof


thenetwork if it can access the proter network to gitsero
network.All thatcreates a local hash down file that the
consumers can complaint to the NTC. At the NTC because
there is a local hash down filesthat is not manipulable. So
integrity is going to be hide.The NTC will have its own and
you guys will going to have your own then you synchronized
it through to the time slump and then you could see from
there what the data rate reliability being percentage in
terms of bandwidth, in terms of latency, in terms of Jitter.
How muchservice reliability? Is it able to connect to all the
networks at large from the modem, 95%? And then
combining the two over-all reliabilityshould reach 80.75%.
That is pretty simple. That is in our position paper. I have
diagram here. The thing we wish to promote here is the
measuring toolbecause it is with the modem.Kasi ilalabas na
nyan isang hash na data lang sya and proprietary, it can
only read by itself. It is that something simple also. It can
also be any platform. And if we can decide later on, for
example if mobile, what needs to be present for you to
launch that measurement? Just to be fair na whenever you
compare your notes or whatever the UI users is usein that
particular point then that he should get for that particular
point. In that, the UI will be pretty simple just test then there
is a hash file then we can go na to NTC.

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ATTY. ROY IBAY=


Actually, we also have initial paper initially submittedby the
PLDT,and it also mentioned that we recommend the
measurement should be in the import of the optical unit of
the modem. I just want to ask Atty. Acero, does this apply to
DSL? Fixed Wireless? Are the condition on the whole shall be
applicable only to the fiber or owned? Like fixed internetor
broadband

platform?

For

DSL,

we

have

different

recommendation.

ATTY. FRANCIS ACERO=


We believed that it is applicable to all. For example, the
problem is at the internal between the internal wiring of the
consumer from the drop of the line to the home.

ATTY. ROY IBAY=


For the DSL, our recommendation is should be done in the
station protector that connects to the top wire.

ATTY. FRANCIS ACERO=


Yes but you moved the modem to that point and then you
measure the modem to that point.But the principle is still
the same.In that way, you will save also in particular
toolsthat the consumer can use. So, then, that would be for
the consumer to do. If the modem there run or connect to

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the modem then test.That is fair and that also eliminates a


problem inside home. At which point, we also

(cont.Atty.Acero)
want to recommend to you na if you can, for your interior
DSL, then we can recommend to your consumers nawhy in
a particular standards. Things like these because again our
experience is when we talked to our members sometimes
we need to go back and then explain.

MS. MARIBETH RAMOS =


I have a question. You said that you will measureif from the
moment, so that is a point A. So, what is the point B?

ATTY. FRANCIS ACERO=


It does not matter because the data is already inside the
modem, youare measuring UX. So, it does not matter kung
saan ang bato nya. What matter is what data the consumer
is getting. So, for example, consumer is watching you and
that.Then, the measurement is throughout the period of
measurement. How much yung true put ng data sa kanya.

MS. MARIBETH RAMOS =


But you are already measuring something that has a
variable. So, there is a controllable variable, Sir. Kasi you
are measuring one time already so that is not our control
kasi that is outside of our network.

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ATTY. FRANCIS ACERO=


I think we can already include the tool,kung saan din yong
bato. That is not something hard to do and we can set
particular standards. Yung

bato is

to

the particular

networkna hindi kasama sa IX.

MR. MEDEL RAMIREZ =


Good Afternoon. Medel from Globe. Basing on grades
inputs in which there is a Point A and Point B. Thirty
milliseconds for the local and for international three
hundred milliseconds. That is supposed to be specific. But I
do not know how we are going to know which is note to
test and what point of present are you having been done.
So, you never know how that measuring device is going to
collect such a number for you to be able to say that okay,
you are in thelimits of advertise access speed. You never
know what is the end point that you are measuring.
discussion

actually

saythat

there

This

arecontrollable

and

uncontrollable within that span of specific test procedure.


Mypoint there is that we want to be specific.

ATTY. FRANCIS ACERO=


We believe nafor the purposes of testing, the data
connector can actually the modem. You cansee kung saan
yong bato at kung anong IPRS ang inaaccess nya. And for
that IP, you can tell if local

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(cont.Atty.Acero)
or

foreign.

And

we

are

not

entitlingto

imposeestablishingseparate standard for local and foreign


access.

MR. REGIN BRIONES=


Doon sa scenario na yon, what parameters are you
actually out as you mentioned kanina the upstream and
downstream?

ATTY. FRANCIS ACERO=


In that, in terms of the upstream band, we are talking
about
latency. We are talking about speed.

MR. REGIN BRIONES =


I go with what Maam Beth said. Yes, you can actually
output with
that process but the data you will be getting contains a lot
of
variable outside of the network of the data. Yes, I
understand that
is why UX but a lot of those comes from the internet which
is
controllable by us.

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ATTY. FRANCIS ACERO =


Again, the thing is we are not oppose naman to different
standards
and you can create a list kung saan nyo binabato yong
data. So, if in

the pocket did the hash file created there is a

list of IPs that was

visited and then from there you can

create a lot.

MS. MARIBETH RAMOS =


Just a clarification, it is not actually that mind of knowing
what

Point B you are measuring. Because you mentioned

you know the

IP address so you know what you are

measuring. What we are

trying to say is that we are

uncontrollable variables in the internet

because you are

accessing server that is outside of our network. Let

us

say you are accessing a server like NTC, so then you may have
some problem with your carrier but not with us. That is what I am
saying.
ATTY. FRANCIS ACERO =
Again, this is why we hash tag. The data set is not limited
to the

consumer

but

also

the

data

said

that is notcarried by the NTC and the data said that is


carried by

carrier for that particular time. When that

consumer comes to the

NTC, NTCwill have a logand

they can check. So, kung masyadong

malayo sa batong

carrier then it resolves to aninvestigation, case

to

case

basis na sya. It will serve you that the consumer is really


trying to access the esotericsite that is really hard to access. But the
idea

naman

consumerna when they


they access and they press. The

kasi

talaga

is

to

empower

the

come in they have this one button


questionlang is what do

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we measure inside?So that we generate

that

single

number so that the consumer can understand.

MS. MARIBETH RAMOS =


You mentioned that when you measure it there are times
and then

the NTC will test the server if it is really hard to

access. But that is

not actually in the real date and

time because it is measure s by the

subscribers

or

consumer. On our experience kasi, there are servers

(cont.Ms.Ramos)
that maybe okay now, after four hours magdodown sya but
it is not

within our control.

ATTY. FRANCIS ACERO =


Again, the idea is to spread out the data set. The data set
that is

going to be useto adjudicate is just the data

collective from the

consumer. It isalso the data that

the NTC provides kung saan sya

nag-babato

the carrier kung saan din sya nagbabato. At

and
that

from
point,

you overcome the three. Kung msyadong malayo yong


true put and then investigate further. If not, there is no case.

MS. MARY GRACE SANTOS =


Just to add to the discussion. I am not an Engineer, by the
way. My
doing the analysisfor

specialization is public policy but I have been


LIRNE

AsiasMeasurement

of

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broadband and quality service so

may kaunti lang akong

alam. Just to add on what Kiko was saying.

I think what

is important is as LIRNE Asia is recommended is that

have

large data set as possible. Actually, we do not recommend a


large crowd sourcing because that may not be credible because
you

cannot compare one experience

kung hindi

sila

to another experience

nagtutugma

ng

minemeassure,etc. So, what does the

time,
LIRNE

ng

Asia

done is to, una sa lahat, set the multiple days in a

has

week.

Dapat may weekday ka, dapat may weekend ka kasi iba iba
naman

pattern

computing.

and

usage

ng

tao.

Pangalawa,

volunteer

We ask time and actually hired consultants to

follow a certain sets

of

parameters

before we conduct the test. We also

and

conditions

set the time slots

to different time slots in a day so that we can take

into

considerations the off-peak and peak hours. Pareho din dapat


ng minemeasure in terms of,kasi when you look at sourcing
really

(cont.Ms.Santos)
1% of youtube, facebook,tapos may local server din sya na
inaaccess. So, iba-iba ang result so hindi natin
sya pwede ikumpara

sa experience ng iba subscriber na

iba din ang minemeasure nila.

What we recommend is

set those conditions and parameters

multiple

days in a week, multiple time slots in a day. Kaya yung


times lang ang important doon sa nirerecommend. Kasi let us say
we have 100 data sets from different subscribers
within Quezon

City. Tapos makikita mo sa time stamp

nila na ang average out

mo

yonmalapit

oclock yung experience nila when they


download speed na ibinabato sa international
meron kang mga set of data na pwede mong i-compare.

are

sa

eight

measuring
server.

So,

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DIR. EDGARDO CABARIOS =


Thank you, Grace. As I have said noon pa, the one that is
being

used

in

cases

of

Commission. The idea here is

complaints

with

the

to get manynetizens as

possible. We have done this kasi meron

kaming kinausap

last year because of the issue in the internet

speed.

Then, merong kinausap and we did some measurements.


Ilalagay po doon kung ano ang inaccess nya at anong oras. So there
were tests conducted let say Globe, Globe lang and kung
Smart,

Smart lang. Lahat ng measure ay nandoon but

that was last year,

October or November. As I have

said, kapag bumili magiging

sigurado tayo on how we are

going to measure. Para walang

question later on na

paglabas nuncoming to that equipment is

based from

what we intent or what we want, etc. Iyon ang lababas


na result as reliable as what we want to be, base dito sa ating
pinagusapan.

MS. MARY GRACE SANTOS =


If I could site lang an example. I think in the U.S, though we
are not

following them, they usedEnlab. And whenever they

get

volunteers or subscribers to measure their

usersexperience may

condition silang dapat mameet. So,

I think that is also a one thing

and

distribute software then we should also be

if

we

do

wellthat

available

yo the conditions. Hindi pwedeng gamit ka ng gamit.


Depende of course sa measuring tool pero may measuring tool ba
sila na oang inirerecommend na applications or web

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browsers na

naka-bukas so yung mga ganon pwede

naman syang i-setdahil

hindi naman sya impossible.

ATTY. FRANCIS ACERO =


This is what we are talking about earlier from the local
hash file.

Then the time shifting and the synchronization

then the calculation

and may result din po iyon. And

then from there, you can copy it.

And

monitoring function, we get from how many

then

for
people

the
or

you can calculate it. You run the app wherever. Same
thing, again, with all those data sets you will create. Again the
measurement is from the modem.

DIR. EDGARDO CABARIOS =


The generation of data yon po ang gagawin dito.Ang ano
dyan is

yung data generated kaya hanggat maari

dapat mas reliable.

ATTY. FRANCIS ACERO =


Again, when we are talking about what we are going to be
measure, we joined LIRNE asia to their position
paper, Latency
MS. MARY GRACE SANTOS =

Bandwidth Jitter.

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Sir, we have been discussing that our concern is to


empower the

consumers. And I think there is a way to

educate the consumers

and how relevant this parameters

are their users experience. Wala

lang

po

dito

sa

powerpoint pero for example, download. Sino ba


nangangailangan ng downloads?

When is it highly relevant to

measure download speeds? There have been several


studies but are

only site oneby Calves, from the Information

Technology in India.

Browsing is highly relevant for

browsing of media, for

downloading files and

streaming media. When upload is being


uploading when you use your

relevant?

Or

drop box? Also in

streaming latency. It is highly relevant in VOIT. Jitter is


highlyrelevantfor VOIT and also for streaming media. And
when you are doing online games and pocket
lost, it is

highly

relevant to VOIT and relevant streaming

media and

games.

So,

halimbawa, I am online gamer, dapat

kahiti

papaano,

important

sakin

na ang latency ay hindi tataas ng thurty


milliseconds. When I am addressing to local server lang. Sir, di ba
po yung recent issue with some cyber athletes that
we have na

kapag nag-ttrain pala sila they need to go

abroad kasi yung

connection dito is not enough to

compete to online game.

ATTY. ANTHONY FERNANDEZ =


If you use the ordinary residential access you do not expect
the
there are

high quality you would ask for with othersthat is why


some that are guaranteed.

MS. MARY GRACE SANTOS =

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Yes, that is correct, Sir. Pero imagine nyo sir yung mga
nagcocompete na yon medyo techi sila alam
nila yon. But for us na

ordinary citizens, we need to be

educated of what parameters are

for

and

level para maayos yung experience nila

acceptable
whenever

they will used the internet service.


ATTY. ANTHONY FERNANDEZ =
Di ba Ms. Grace the last time that we are talking, we are
discussing

several controlled testpoints. For exampleis the

NTC servers. We

are looking to thatsuggestions also kasi

when we test the NTC

subscriber I at the NTC server at

least ayon po iyon ay within our

network.

Fully

controlled po iyon.Gaya nga po ng sabi ni Ms. Beth,

once

we go through the internet, madami na pong uncontrolled. So,


ano kanyang pwedeng gawin doonjust for the starters yung pag
measure ng domestics to an NTC server. Kasi later
on, when we

have other most commonly access sites,

the carriers naman, not just

us

even

other

partners but other TelCos abroad,kahit

international

mag high traffic

naman increase naman nila yong capacity. Para


naman we are not being measured po on the total scale of the
experience.Kasi what we are providing naman po basically
with

numbers

broadband

now

is

broadband

connectivity.

And

connectivity is not equal to internet

experience.Kasi ang internet

MS. MARY GRACE SANTOS =


Sir, may sagot po kami doon.
DIR. EDGARDO CABARIOS =
Okay, Ms. Grace.

po is the use of broadband.

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MS. MARY GRACE SANTOS =


In connection to that, actually si Engr. Alvin also said that
dapat

yung location ng test servers yon. We would

like to respond lang

formally.

Ideally,

measurement should be carry out because

blind
the point is

to determined what does the subscribers experience. I


mean, we know that already but if the TelCos have insufficient
capacity to wherever the test servers is located then that
would

reflect

the

experience. But I think that

poor

customer

quality

service

is the whole point of measuring the

quality of service. It is what

the

consumer

experienced. The NTC would not be the best

actually
location for

the test servers. This is actually the position of our


Research Manager at LIRNE Asia. Because in the experience of the
other countries, it is likely that the TelCos would
provide the

possible service to the regulator.I think it

is but logical that the

regulatorwould

bestconnection in the city. This is been

have
the

case in the

other countries. I do not have evidence to show


here. So

the
that

having local known test location, we will give


incentive to the operators to provide good quality of service in
certain

locations.

subscribers might be

Other

locations

and

other

at the disadvantage. Sir, let me

finish lang po. Another option is to

have

high

breed

approach where we can all agree on some


location of the test servers but yong iba ay blind. It would be
interesting to see yung difference ng quality of service
doon sa test

servers na alam natin kung nasaan and

doon sa hindi.So we can

probably use that para lang

masatisfy yung sinasabi ng TelCos na

gusto naman nila

na kung saan. Because you do not want to have


TelCo to be disadvantage.Kasi ang sinasabi ni Alvin last time,

one

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(Cont.Ms. Santos)
baka merong test server location na maliit lang yung time
location

nyo doon. So, that would be a problem. But

again, that would

actually measure yung customer

experienceng subscribers na

nandoon sa location na yon.

Correct? So, if we can agree on a high

breed

approach,

LIRNEAsia would definitely welcome that.

DIR. EDGARDO CABARIOS =


Well, ito pong ginagawa po natin sa test drivewe do not tell
kung

saan pupunta iyon. And they do not know yong

Simcardsna

ginagamit. Pinapalitan po iyan kada test.

So, pag labas lang ng

result, tsaka lang sasabihin na dito

nagpunta yan, etc., etc. so that

we will know. Pero prior

bago iconduct ang test hindi po nila alam

kungsaan

pupunta at ang Simcards na ginagamit.


MS. MARY GRACE SANTOS =
Sir that is actually the approach of LIRNE Asia is
recommending.
ATTY. FRANCIS ACERO =
As for democracy.net, we want be oppose to that kind of
high-

breed

approach nor you have specific test

sitestargeted within a

certain marketlet say domestic and

then random also to the


domestic area. And certain specific sites
network and random outside the network.

domestic
for

within

that

outside

the

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DIR. EDGARDO CABARIOS =


Yes, Eric?

ENGR. ERIC DELOS REYES =


Like us, Dir. Egay it is not true that the drive test is talking
about

the CMTS. We are talking about the internet here.

There are so

many uncontrolled variable and in fact, it

is very good that

diagram but

actually implement this? How would

how do you
you actually do

this? We are trying to figure out this in coming up

with

those numbers medyo hindi ko rin maano yan. Kasi it is very


difficult to compare something katulad nung sa CMTSnetwork na
within the network only compared to the internet na
marami syang

dinadaanan marami syang variables. That is

outside our own

network. You want us to perform

something na may malaking

portion na hindi naming

nacocontrol kaya nga tinatanong naming

kanina,kung yung

pagkuha ban g speed na iyon ano ba ang


tinitingnan natin? Ang dami non e.So, bawat isa ba yon? Then,
how the NTC implement this for all the subscribers? Kais
sinasabi

kanina na may blind test na , okay. Tapos

sinasabi kanina na

maraming different line yan.

And remember that there would be

time that isconnected

to a particular server, would that be a


presentationon the quality of the subscribers experience compared
to what is being measured in the server?
Consideringnafactor din
server.

yong time na

pupunta sa

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DIR. EDGARDO CABARIOS =


Well, what we are looking at is what we have done indrive
test. In

drive test, we do not measure yet kasi kapag

mineasure mo yong

Smart,

Smart

mineasure mo ang Sun, Sun lang

lang

yan.

yan.

So,

interconnect na course na ginagawa kung

Kapag

wala

pong

within

the

network para po malaman yong drop calls. Once test is


done over a period of one month, titingnan na po natin yong
commonly use sites. Sasabihin naman after the test is
donena ito
(cont.Dir.Cabarios)
yan, ito yan. Now, what we do dito sa driver test is
simultaneous

yan, sabay-sabay yang ginagawa para

hindi magreklamo ang isa na

hindi isabay kasi dapat sabay yo

para the Commission are the

same. So, in this instance,

hindi ko alam kung it can be done na

sabay

sabay

although of course marami yan. As I have said, you

can

generatemany date as possible. Then yong accuracy mo is


higher. I-identify naman yan if it is within the network. Kapag
lumabas, dito yan, dito yan, etc.So, I think all of this, kapag
nirelease ang result it should be transparent
para alam natin kung

ano ginawa, ano ang sinukat.

ATTY. FRANCIS ACERO =


With

the

variablesthat

high

breed

approach,

regarding

these

unknowns who can be addressed.

We already have known sites

that

are

going

to

be

announced. We are able to create sufficient


benchmarking for that. And then, with the unknown sites, that
provides a better reflection of UX. Because again we do not
know.
which we can
we use to adjudicate a

And combination to that or the suitable combination


agree later canprovide benchmark that
particular things.

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ATTY. ANTHONY FERNANDEZ =


Yung last point natin dib a is blind testing? And known
points

reference for

not there

the testing? What ifshould

always be a control for known sites

like testing? So if there is any

variant for full-control

presentation. There is a comparison of data.


MS. MARY GRACE SANTOS =
That is why we are recommending a high breed approach.
Pero we

are totally opposed having all locations. If you

are opposing a full

(cont.Ms.Santos)
blind measurement, we are recommending a high breed
approach

wherein you have some known locations and

some unknown. We

are sayingthatdoon sa unknown,

doon natin mas makikita yong

experience.

Pero

we

are okay onhaving some locations identified.

ATTY. ANTHONY FERNANDEZ =


At least we can look for any deviations.

MS. MARY GRACE SANTOS =


Yes and I think that can also help the TelCos, the service
providers,

kung gaano kasama yong experience pala sa

ibang location. Kung


consumer itself or from NTCs

baga, you have data from the


own

tools inimproving thenetwork which is what we all

measurement
want.

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ATTY. ANTHONY FERNANDEZ =


That is why we are discussing that dahil kung minsan we
might be

providing

the

standard as committed. But

capacity
the

or

the

experience

technical
due

uncontrolled variables might be different. So,

to

parang

unfair naman samin na we will be penalized in whatwe


cannot control. But the other data supports us naman nawe
delivered on what was committed but mahirap pa din
talaga

iconnect sa internet.

MS. MARY GRACE SANTOS =


Sir,just additional lang. Halimbawa lang meron tayong NTC
test

server

dito tapos of course NTC is one Quezon

City, pero you also

(cont.Ms.Santos)
have ten other unknown locations within Quezon City.
Tapos

imposible naman po na sa NTC ang ganda

ganda ng lumalabas

tapos

yong

all

pangit. So, ano ang susundin ko don?

other
Yes,

Sir meron tayong point of comparison. Maybe there

ten

ang

tama

kayo

are

gaps

nathat can be addressed in publis areas. Pero pag nakita


na NTC na maganda ang result tapos six out of ten doon sa other
service sa Quezon City na maganda din, then we can say
na

probably merong mga variables don sa four

other na masama ang

results na beyond ng capacity or

control ng service provider.


ATTY. ANTHONY FERNANDEZ =
Di ba that is whyyou are suggesting multiple know sites not
only

one site?

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MS. MARY GRACE SANTOS =


Yes, Sir, more data more improvement.
ATTY. ANTHONY FERNANDEZ =
Parang okay din yong ganon kasi kung nasa Mindanao ka
you can

add your choice if testing with other servers.

And if may data satin

makikita natin.And what we need

kasi as TelCo, when there is a

report or complaint,we

can trace the exact route. Without the


will only

control, then we

guess because we are testing inclinely

from

Point A to whatever then you repeat that five times then


ibat ibang routing yan hindi na natin matetrace yan.
MR. REGIN BRIONES=
Clarification lang kasi medyo na-confuse ako. Kasi when we
say

blind, are we referring don saPoint A kung saan mo

kukunin yong

test samples? Ang sinasabi naming is

yong control and uncontrol is

(cont.Mr.Briones)
yong B where you do the test. Kasi Blind, what do
you mean by Blind? For example, YouTube is
not blind? Just a

point natest pointand then server?

ATTY. FRANCIS ACERO =


The testpoint, the dulong point is the subscriber muna. So
that is a

known point. The other point is also within the

network but not

known to the TelCo at that time nathe

test is being conducted. For


ba?We are going to a high breed
So there is a fixed point within the network na.
MR. REGIN BRIONES=

example, kasi high breed di


approach di ba?

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For example, I am coming out with the point of view just


like the

Oplahas been test. You know where the server

you choose. And

you expect nakapag nasa Los Angeles

yong server will be number

delayed compared don sa

isa. So, hindi ko magets yong concept

nong blind.

MS. MARY GRACE SANTOS =


Yong sa LIRNE Asia line measurement, hindi nyo alam yong
Point

A kung saan sya itetest. Tapos yong sa Point B, well,

when we

conduct the test hindi naming sinasabi. Basta

sinasabi lang naming

na internet server in the US,for

example or in Europe. Pero kung

saan eksaktong server,

hindi naming sinasabi. Pero definitely

whenever we do

the test six times slot sya within the day. Lahat ng

six

times slot na yon tinetest naming yong international server.


National ISP meaning from one ISP to another ISP server. And the
Local , from one ISP tapos yong pagbato ng data
within its own

network. So, tatlo iyon.Alam na alam mo

kung saan binabato pero

in terms of location ng test

kung saan ginagawa yong point ay

(cont.Ms.Santos)
unknown sya, sinasabi nalang sya after the test. Yes,
unknown to

the service provider.

ENGR. ERIC DELOS REYES =


I just want to ask. So, yong iba ng mga server it is assumed
that it is

in the same network?

MS. MARY GRACE SANTOS =


Yes, Sir, sa LIRNE Asia po ito Sir ah. Tatlo po yong
domains.Yong

isa po local, meaning, for example sa

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PLDT. PLDT na nagbabato ng

data

sa

network. That is the Local. Yong isa

server
Sir

within

is

its

own

National.

For

example I am on Globe, magbabato ako ng data

sa

server ng ibang ISPs. So that is a different measure. Tapos yong


pangatlo is International Server, so form local ISP na nagbabato
sa

server outside of the country. So, tatlong domains po

ang

minemeasure at least for the LIRNE Asias Line

measurement.
ENGR. ERIC DELOS REYES =
May question is relation to the blind test. Yong gagamiting
server

na hindi namin alam where will it be? Where

does it reside?

MS. MARIBETH SANTOS =


We just have to clarify. You mentioned earlier na yong blind
na

sinasabi nyo is don sa customer which is yong sa

Point A side pala.

Kasi

honestly

sinasabi nating Blind. So, can

kanina

yong

yong

you clarify?

MS. MARY GRACE SANTOS =


Sa ginagawa ng LIRNE Asia, actually, lahat yon Blind
totally.

Dinadivulge po ang information after the test is

conducted.

Ang

point non is that you can see the

where problem area when

the common subscriber uses

the internet using the specific data

plan. Pero control po

ang conditions at yong parametersna nakaset.


makikita yong problem area.So,that is the LIRNE
approach but what we are saying is that we can come up

Doon

po

mo
Asias

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with the high breed

approach that we are amendable. I think that

would be acceptable enough.


MR. REGIN BRIONES=
Basically, i-reenforce ko lang yong sinabi naming kanina.
Ang

concern lang doon sa B sidethat is why we need

dapat

controlled yon. Because if it goes to the B

side, it relies to the

internet, majority of them is

not controlled by TelCo. So, yong

mga

delay, whenever, is outside of our control I few

experiences

on

do expansions on

our network but not on the internet. That is why

we

were suggesting that the B side should have a new comers that
resultsof an equal connection to the TelCos. And it is a knownthat
would be actually to the location it could be
anywhere as long as

we know. And the A side naman is

we can test wherever but to the

radio, I am a radio guy,

yong radio conditionhas a lot of factor.

Yong B side yong

medyo we need to ano.

MR. MEDEL RAMIREZ =


Just to add to the point B, regardless of whatever server
that you

will be trying to test, ganito nalang ka-simple.

Kung meron

allowable na pwede mong i-trace

don palang nakita mo kung saan


time, ulitin mo din yong nakita mo.

tumakbo. At the same


Maniwala

ka

sakin, hindi ulit don dadaan yon. Kaya, what we are


saying is for those controllable na we will never know don sa mga

(cont.Ms.Santos)
magbabato. What we are saying actually is that we really
like to

know a specific.

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ATTY. FRANCIS ACERO =


To that point, we also want to identify din which part. There
is a

specified B and there is random B side. We will be

able to identify

outliers. If there is outlier to the data

then we can agree na that

outliers would be excluded.

The idea is if we have a specific B,

we need to have a

specific B, then we need to have a random B. Just

to

accurately represent UX.

MS. MARY GRACE SANTOS =


Sir, yong tungkol sa trace. Di ba sir kahit naman data caps
yan,

well, ideally, if nagbabato ka lang ng data within the

national

boundary dapat hindi naman talaga yan, kahit

ilang caps yan.

Meron lang tayong tinitingnan na dapat

thirty MS yan. Ideally,

may ganon po tayo di ba?I am just

giving example on the number.

For

example

latency, what we are trying to do is kung ang

yung

pagbato ng

data, local muna to local, syempre tataas ang latency


nyan kung pinapatunog sa labas bago bumalik dito. So that is what
we are trying to address.
MR. MEDEL RAMIREZ =
Pero remember, dalawa yong segment nyan. Dapat kapag
magoofer kayo ng service gusto mo talaga
yong guaranteed bigyan

kita

pumunta bibigyan kita ng CIR, thirty or


siguro yon. Kung yong plainly, I do not know

CIR.

Kahit
forty,

san

ka

whatever,
kung

asan

ka don, it can never guarantee a specific. Kung sa CIR


ka, kung point B to Point B, siguro na and ano ang given time yon
din ang ibibigay sayo, CIR. Pero hindi ko alma kung
ano

maibibigay in a given time. Hindi ko ma-

iaassure.
MS. MARY GRACE SANTOS =

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Sir you are saying CIR means yong sa mga higher data
plans?
MR. MEDEL RAMIREZ =
Yes.
ATTY. ANTHONY FERNANDEZ =
Doon po sa control and uncontrolled, sa known B and
unknown B,

siguro naman we are measuring that. Our

services efficiency is

being measured dapat based on

the known kasi dyan na kami

mayroong control. But if you

are saying you want to measure yung

uncontrolled,

siguro you can measure all you want. But it should

not

down to penalty or any backslash to the operator siguro nice to


know to the users experience pero yong unknown will not be a
measure of the efficiency of the TelCo kasi nga
unknown yon e.

MS. MARY GRACE SANTOS =


Sir, you are saying you are completing no way for us to
know the

unknown and not to address those things? Kasi

hindi naman

pwedeng nice to know lang.

ATTY. ANTHONY FERNANDEZ =


Hindi naman po.
MS. MARY GRACE SANTOS =
I just want to drive on the point. Sir, pag meron po tayong
uncontrollable variables at na-identify based on
a large date tapos

nakita na may problematic thing

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hindi namandapat nice to know

yon. Let us see how it

can be address. I think that is the whole point

of the exercise.

ATTY. ANTHONY FERNANDEZ =


Kung nice to be address Maam, it can be pointed to out
that there

is something to addressed.

ATTY. FRANCIS ACERO =


I am going to point. If there is a poor result that is not the
end of the

process. It is just the start of the process. Then it just

means that you

have to ask drill down to where the problem

occurs. In the random

B area, if the failure of the random

area is due to default, we leave

that

to

providers. That is why. But if it turns out that the

the

service

random

entirely within the serviceproviders jurisdiction, then


there should be somecorrective actions. Not necessarily a penalty
immediately. We can agree on that grievance later.
But the

important is that when it is found out

that there is a problem there

should be action taken.

DIR. EDGARDO CABARIOS =


Well, yong sinabi na experience last year on power
equipment,

inaccess ng international website sabay

yan sa Smart, Globe atSun

tapos

sinusukat

parameters and ganon din ang ginawa then

we

yong
have

the result. Pero sabay sabay iyon. One side sa international


server, sabay sabay kasi nila inaaccess at the same and at the same
place. Iyon ang ginawa dati ah of course hindi na
kami equipment

ngayon, etc. Perhaps, I do not know if

that can be also done.


ATTY. ROY IBAY =
Kaninong methodology yan, Sir? Doon sa supplier?

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DIR. EDGARDO CABARIOS =


Yes. Hiniram kasi naming yon and meron ng method.

MS. MARIBETH SANTOS =


I just have a comment on that, Sir. Would you know kung
sabay

sabay? Kasi for example, I am the ISP and then

I have

interconnection

with

this

ISP

wherein I get my bandwidth.


I do not have an idea kung saan nya ako papadaanin, kung
sa

Skyway ba or wherever.

iadvice sa Globe na

pwede

kung

pinadaan sya sa Skyway

tapos

nung test sya sa PLDT ay pinadaan

Then,

sya doonserve sup yon

yung sa sinasabi nila nakikita nilang

nakikita sa

trace rap. Nagiiba-iba yon kasi every ISP has its own
router. That is all automatic even the ISP which is connected to
other ISPs. Wala din syang control don. Iyon ang sinasabi
naming

namayroong uncontrollable variable.

MS. MARY GRACE SANTOS =


Yes Maam that is correct. That is why we are getting the
averages

and not just one instance. And that is why we

recommend having

large data sets. Yong sa LIRNE Asia

po ay average data po iyon ng

halimbawa

nag-test

kami ng eight oclock from Quezon City to an


international server , local server and to another server. Eight
oclock po pero average of six days. Ganon po sya so hindi
po sya
halmibawa, nagbato sa

one

instance

tapos

penalty

agad.

Kahit

isang server ng ibang ISP , tama po

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kayo na of course you would

know better pero kung sa iba

papadaanin, halimbawa yong one

instance.

Pero

imposible naman posiguro na nag six days, one

week

ka na nagtetest doon parin pinapadaan. Kahit papaano di ba


makikita natin yong differencenon. Especially, if you get the
average.

MS. MARIBETH SANTOS =


You maybe right pero hindi nga naming alam kung saan
sya nag-

roroute. Kaya nga sinasabi naming na why you

penalize us na wala

nga kaming control don.

ENGR. ERIC DELOS REYES =


Then, saan mo icocorect?Hindi nga naming ma-control e
kasi nag-

average na nga, okay ganito bagsak tapos

sasasbhin na hindi samin

yan. So, how do you correct that? It

has to be implementable.You

want to correct it. But we can

do as far as the TelCo is concern.

Otherside,

ma-control yon. How do we do that?

hindinamin
Everyone

should be guided also.


ATTY. DEREK LIM =
Dir. Egay, I think the backforce that we are witnessing now
only

shows howcomplex the issue is. So I think we need to

have a more

reasonable timeline before this. Maganda

yong flow ng discussion.


candidly wala akong naiintindihan.

I really appreciate it although


But I really appreciate

kasi magandang pakinggan. But I can only


final language of the circular will be able to be accurately,

hope

the

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simply capture behind the approach that Ms. Grace and Atty. Kiko
are proposing. And be able to address the carious
situation, the

exemptions, the justifications that the

industry is raising. Pero of

course, when we are talking

to penalties, we need to discuss also

that

aspectsthat

we proposed. No immediate penalty. Di ba if there

is any

penalty to be discussed there is a due process hearing. Wala


akong naintindihan pero it sounds nice. But I can say that it is
really a complex situation. I do not think if timeline
next week is

achievable.

MS. MARY GRACE SANTOS =


As compare po don sa sinabi nyo kanina. When you are
testing a

CMPS, kasi nga it is within your network. Tapos

ngayon na

sinasabi nyo na are we the right service

na bibnayaran ng customer

within

talagang binibigay po naming iyon. Agree

the

network
ko

don

ay
di

ba. Pero pag labas non syempre yon na nga, a different


issue already.

MR. REGIN BRIONES =


So, you are saying nait would be a minor capacity to
expansion

on the intranet?

DIR. EDGARDO CABARIOS =


Yong drive test kasi, we measure the Smart sige Smart lang
sya, etc.

Pero yong measuring speed ay hindi kasi naiaccess

mo the same
sabay naman ginagawa yon.
lang.
ATTY. FRANCIS ACERO =

server outside the Philippines, sabay


So, hindi lang yon Smart

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Again, the idea is that is why we need the large data set so
that you

can throw out the false hits. If the problem is not

within your

network, makikita naman sa trace nyo yon

then you get that ISP.

As far as the NTC is concern.But as

far as to your concern as a

regulator.But as far as your

concern because drill down yan e.

kung hindi na sayo ibig

sabihin sa customer then okay ka na.

ATTY. DEREK LIM =


I think it is important to stress that one customer complaint
alone

should not be enough basis to penalize a TelCo. Even

if there is one
(cont.Ms.Santos)
customer complainant that is very noisy that should not be
enough

reason for the NTC to clop down the TelCo.

What must be

considered is whether the services

is consistently bad and has

already become incorrigible

or nearly incorrigible. Apart from this,

I think we cannot

over-emphasizehow really important it is for the

TSN

to accuratelycapture what we are all saying. So that when we


look at the thing on what we are saying, paano ba natin
iaaddress

yong

concern

Anthony? And then how

na

naraise

nitong

si

Engr.

will we write it down symbol

easy to understand language. That is

why I think next

week is the best timeline. Yes, Eric?

ENGR. ERIC DELOS REYES =


Yes, sir, I agree with that. I think, looking at the
constructive way,

you have heard our concerns, we

have heard your suggestions as


concerns as well. Kasi kami we have agreed to

well

and

so

your

continue

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the

discussion, in fact, I am proposing that we will sit


down againbecause our intentionis also to improve the service
and want to know how. But we do not want to be measured
regarding our performance which is something

that is not

applicable

correct. So I would like to

or

something

that

is

not

suggest if you agree to Dir.

Egay that allows us to convene again

working

and see based on what we have heard now see

group
what

we come out the constrictive suggestion that we can again


hopefully suggest to the NTC. Tingnan natin kasi we are doing to
discussed it but we do not know the phase.
things

There

are

that really need to measure. Kasi madaling

pagusapan when it

comes todiagram at concept lang.

But when it comes to the real

implementation

nga ang tanong natin, okay na-trace na natin

kaya

then paano

yong corrective measure? Because the bottom-line is


you want to improve the experience of the subscribers. May legal
question din kami, are we going to be penalize based
on the
(cont.Engr.DelosReyes)
average? I think anybody would agree on that. So, I think
these are

things that we need to consider. And it think

the two is over-

emphasized. As much as to agree

to the NTC that this would be

done nextweek based on the

issue that we raised now. Dir. Egay,

can you relate to

the Commission that if we rush this it will create

more

problems to the solution. I think everybody would agree on


what we want. Sabi nga kanina nung opening statement, we are not
here to oppose whatever measure the NTC wants. In fact,
we just

want to do it right. We do not oppose it. We

want a policy that

encourages

improvement on the internet and


services here in the Philippines not to prevent anybody

growth
broadband

and

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from offering a better experience to our subscribers. So, having


saidthat,I so moved.

ATTY. FRANCIS ACERO =


Obvious naman that we agree that we are not going finish
to finish

this

today

because

technical. Again, we agree

we

just

started

the

that the operational, why we

measure and what we measureand

where these lines can

be drawn. This will take some times maybe

by

next

week. We need to be fair because if we are going to the


extent on setting even in the administrativeprocedure in putting
actions on a particular carrier then that is a big too far.
Siguro what

we are considering in terms of code and

codes actions in terms of

let say a prepaid system.But

not in terms of cutting down the

particular carrier.At this

point in time, I think that is not a

workable

right now. Again, even this system that we are

time

proposing

that is also within the context except for this line.We are
talking about this in context of users experience and getting a
process by which aconsumerswhere we can get a retake of
service

that was not deliver. Because that process is

kinda in the air.It


(cont.Atty.Acero)
depends on the carrier and there is no specific time that a
particular

consumer can refer to and say that I did not have

this kind of

service.

ENGR. ERIC DELOS REYES =


Yan din ang ginagawa ng Ofcom nga e. And Ofcom kasi is
starting

a code of conduct, self regulation. I think I

mentioned that last


dapat ganito kayo,hindi, code of
you have your understating to comply

time. Self regulation instead of


conduct is you sign and

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ATTY. FRANCIS ACERO =


But again, that is different because voluntary. My example
is the

KBP. Most of the networks now, TV Networks,

outside the KBP

because

of

that

internalcannot keep standards to shape

reason

that

themselves

bound. I mean just to out that into official document

that

notjust to bind the TelCos but also the time that will be an
ideal output for us here. But at least all over unknown, we are
making progress and we are saying eye to eye naman on
something

that we do believe din that anything that is not

reasonable or

entirely outside the scope of the TelCo

should not be put upon

the TelCo. And It is just a

matter of finding and doing the details

what we measure

and where we measure and how we measure.


ATTY. ROY IBAY =
With regards to the advisory of D.O.J to this.MayI ask the
D.O.J

on how you intend to involve the NTC with regards to

like for

example in enforcing the advisories that you

came out. Will you

ask NTC if there is no agreed upon

measuring tools? Will you task

the NTC to enforce or

help you to the foresaid advisories?

MS. ALELIE GERMAN =


Good afternoon everyone. With regards to the enforcement
of

advisory, we just compile cases and we do not have

the mandate.
actually assess these
this to DTI and DTI is the one
handle or mediate the case. So in

Actually, the NTC has its best position to


cases. Actually, we just transmit
whether to forward to NTC or
that case, wala na po

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kaming habol doon. Kami ay taga-follow lang

kasi

ng

mga subscribers.
ATTY. ROY IBAY =
Thank you for enlightening us. That is basically what we
raised last

meeting

here

overlapping

thatto

serveinstead,there

are

function already between the D.O.J,

D.T.I and the NTC. So, we

asked that carriers we will

just like to be guided accordingly. And

to really find out

which agency has jurisdiction in that issue. For

example in

truth and advertising, is here in the NTC call or should


be on the D.T.I? Well, my understanding is it should be in the D.T.I
should take it even the D.O.J should actually refer
that complaints

if the consumer goes to D.O.J then we

have to refer the matter to

the D.T.I. If it is D.T.I then we

could include also the NTC if the

measuring

tools

already there. There is actually a bridge or a

are

violation on

the advertising code or D.T.I rules.

DIR. EDGARDO CABARIOS =


The M.C. on benchmarking meron penal provisions yon.But
we

have not use that penal provisions. Kasi noong

pinublish yong

resultsat

improve na sya. Mas matindi

nag-fail,

next

quarter

nag-

kasi ang epekto non whether

it is beingpublish. So yon po iyon.

You

do

the

measurements and just leave it, publish mo, etc., and


everything will improved kasi makikita naman nila tna yong
problem is nag-iimprove sya. Now on the rebate, please
check the

General Order No. 1, 1950. Hindi pa ata

naammend iyon, if I am
(cont.Dir.Cabarios)
not mistaken. There is a provision there that if the service
is out for

twenty four hours or more, meron pong rebate.

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General Order No.

1, 1950, Public Service Commission

po iyon.Hindi pa po

naammend iyon basta the

when service is out for at least twenty

four hours, then

rebate.
ATTY. ROY IBAY =
Just on the first the jurisdiction of the NTC and DTI.As a
consumer, we would like to know langbecause
one of the things

that

we

know

complaint? Again, we cannot give

lang

is

where

them

the

do

instruction.

And the Supreme Court is very particular on

the primary

jurisdiction then it all goes there. Second is on the


rebate.Yes, we are aware that it is there. For example, the
violations of SLA or particular standards. Then, we can
already

agree on that. And I think value might not get

there at least we get

the point and understand that this

is the capacity of the network.

This

is

particular

standard nathe network should give the


infrastructure and should at least hit whenever using the network.
If we moved to the point then at least we will have
some progress.

MR. RONALD CALDERON =


Good afternoon po. For the information lang po of
everybody.

Actually, there is a proposed MOA between the

NTC and DTI

hopefully ma-sign na sya next week on

the jurisdiction of the

complaints.

proposed kung ano ang complaints

Meron

kaming

for DTI and for the NTC.

Pagdating don sa technical problems it is


talaga ni NTC. Yong samin kasi more on warrantee
advertisements.And we are going to give you naman the
MOA kapag napirmahan na.

na

the

jurisdiction
and

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ATTY. DEREK LIM =


Baka pwede maka-comment naman muna kami kasi it will
reflect

like the Bangsamoro Basic Law etapos nung

pinakita sa tao, ayon,

madami ng objections.

MR. RONALD CALDERON =


Actually, it is more on kung sino ang mag-hahandle ng
complaints

talaga, iyon lang yon.

ENGR. ERIC DELOS REYES =


Baka makapagbigay kami ng kaunting comment with the
intention

of enhancing the MOA between the DTI and

NTC.
ATTY. DEREK LIM =
Because there might be some complaints that we will turn
over to

the DTI which the TelCos used to know that is

should be handled

by the NTC and vice-versa.

ATTY. FRANCIS ACERO


We would like to second on that. Actually, from our point of
view,

especially from what happened yesterday, actually

the past

few weeks with the BIR.Understanding

Telecom Issues now

requires plenary approachna

if you just na, ok, this particular is

not enough anymore.

You really have to break it down this issues

na with the

technical aspects, for example is the truth and


advertising. This goes to the heart of truth and advertising that we
are discussing now. We would like to know if the DTI
is after that if
capacity

to

know that if where is the

if goes out and did DTI would haveenough


understand this. We just want to
delegation on that.

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DIR. EDGARDO CABARIOS =


Perhaps, mabuti na iyon. Ang problema lang is yung
naimpose na

penalty naming for day is two hundred

pesos a day. Nakalagay ata

sa Consumer Act yan. Yes,

Anthony?

ATTY. ANTHONY FERNANDEZ =


Boss Egay, I just want to raise one reservation lamang
although I

not exhaustibly discuss it, it is under rebates.

In rebates, we

currently know all the process on

rebates. You just have to tell us

when you experience

that service. It is also the duty naman of our

consumer

to report now. Because later on we really need to


validate and it is based on the time that we report it. You cannot
report naman it three months ago. Kasi there might be an
impression that based on the true put results of
the consumerafter

end without verification they can

wait for carrier, I cannot apply

because it is only what

I got and there is so many factors. AsBoss

Egay

publishing the results of certain tests, that is why some data


pwedeng nice to know.Nice to know if it is already published by
the consumers group.We actually might used it
because sometimes

what

might not sounds coming from the


is coming from the base itself. We will act

here

from

the

engineers

forest. At least that one


naman

appropriate.
DIR. EDGARDO CABARIOS =
If we want a provision on rebate dito sa MC na ito para
maamend

natin. Kasi nakalagay nag anon lang iyon e

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wala ng iba. Yong

sinuggest

specific period pwedeng ilagay na

nyo

nga

na

dapat

dyan.

ENGR. ERIC DELOS REYES =


But the customer really needs to report.

ATTY. FRANCIS ACERO


These things are internal within and for many consumers it
is only

after the complaint then they found out and

they will call to us and

they will say that they received

these messages. Then we will ask

them do you report it

immediately? It will go like that. That process

is

counterproductive. And we prefer that something to put down


here and it is common reference point if you have something
procedure better than that, then follow that. Also, it
would be good

if we put in no particular provision

nabefore you go to the NTC,

you should have come to the

providers first to the TelCos and done

your part according to

your SLA. That is pretty fair.


ENGR. ERIC DELOS REYES =
Exactly, kapag ginagawa nga naming kapag tinatanong
naming

kung ano ba ang ginagamit nilang device and

kumusta ba ang

wiring mo, as you mentioned. For all you

know yong

problema

nyan o yong device yong may

nyan

yongmoden

problema or may virus

na yong laptop nya. Iyon ang problema.

DIR. EDGARDO CABARIOS =


Before that, i-set natin yong susunod.
ENGR. ERIC DELOS REYES =

ay

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Nextweek, Dir. Egay we will also confirm again our


technical

working group to consider and to look into your

suggestions. KAsi

constructive

natin. We will tryto find out kung

naman

ang

gusto

paano nga ba? Ganyan

din nangyari samin kahapon, we are trying

to

get

solutions but whenever we come up to the solutions there is


still question. Actually, we asked ourselves that also kaya

(cont.Engr.DelosReyes)
vinavalidate namin yong issues na niriraise. Our suggestion
siguro

is maybe nextweek?

DIR. EDGARDO CABARIOS =


Yes, we could have it on Thursday at 2PM?
ENGR. ERIC DELOS REYES =
Okay.
ATTY. ANTHONY FERNANDEZ =
Last time Sir para may positive naming tayo. I just want to
assure

Mr. Kiko nato put that system on rebates in

writing. We have

already

done

conditions on the subscribers on


siguro since you are close to the consumer
can help. And thank you also for the clarifications

that

on

terms

and

the location forms. So,


groups, you
which

is in the jurisdiction of the DTI. Thank you po.


ATTY. DEREK LIM =
I really believed that we should first get a copy of that MOA
before

they sign. You know why, Sir? You want me to

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demonstrate why?

You said as far as the NTC is

concern, the highest penalty is two

hundred

pesos

yong sa kanya is fifty thousand. So, before that

then
MOA

is implementedour parties are entitled to seekung saan yong


lines of that two agencies. If the MOA is already sign before we
see

it then you subjected us to one hundred thousand

pesos baka two

hundred lang dapat.

MR. RONALD CALDERON =


Yong sa MOA kasi more on the delineation of duties wala
namang

penalties na nakalagay doon. Pero if si TelCo

nagviolate under

Consumer Act, the admin fine isfive

hundred to three hundred

thousand

Consumer Act yon a. But I think merong


finepagdatingdoon sa pagiissue ng advertisement.

pesos.

Under

specific

admin
As of

now kasi wala pang hinahandle naviolation ang TelCos on


advertisements.

DIR. EDGARDO CABARIOS =


Thank you. Anymore?Marami pong salamat. We will meet
again

nextweek.

Transcribed to the best of my ability.

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ELIZABETH G. LAMADRID