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Continuation of Public Consultation on Broadband


Speed
April 23, 2015/2PM |1

REPUBLIC OF THE PHILIPPINES


NATIONAL TELECOMMUNICATIONS COMMISSION
Quezon City
--------------------------------------------

Continuation of Public Consultation on Broadband Speed


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

ENGR. SUSANA PANES =


Good Afternoon everyone. Pasensya na po, Dir. Cabarios
cannot

attend this Technical Working Group Meeting.

He has an important

commitment.

Malacaang. We can

continue our discussion last time. I think

may kopya na po ang

bawat

discussion with this summary of

isa.

Right

We

now,

can

he

was

continue

in

our

what we did last time. So,

any comment po dito sa pinrepare ni Dir. Cabarios?


ATTY ROY IBAY =
Good Afternoon po, Madame Chair. Before we start on what
we

talked during the last technical meeting, we just

want to clarify, we

have

yesterday from, I would assume from

received

an
CCAD

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

e-mail

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(cont. Atty.Ibay)
on record, what is the status of that e-mail and the
attachments

supposedly draft stating that it is

now the subject which is quality

of

service

standards for internetconnectivity services. We just want


to ask to put on the record on what is this document that
was

circulated

among

previous technical

the

participants

of

the

meeting.

ENGR. SUSANA PANES =


Actually, I am not aware of that e-mail but I can verify this
one

with our secretary.

ENGR. PIERRE TITO GALLA =


Madam

Chair,

may

Cantara,PECE. I am

speak?

am

Engr.

one of the co-founders

Pierre
of the

democracy.net with me is Carlos Nazareno also from


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

then

resubmitted

the

said

proposal.

You

probably noticed from the document that the definitions


were no longer included in the definition of terms. It was
moved towards an Annex. Individual parameters were

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


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

ENGR. SUSANA PANES =


Okay, so that was submitted for Comment.
ATTY ROY IBAY =
I would like to clarify Madam Chair and will be put on
record that this is their suggestion and not adopted in Toto by
the NTC. And

that this is the input or suggested draft by

democracy.net and

nothing anyway an adoptive draft. So, it

is on record.
ENGR. PIERRE TITO GALLA =
Democracy.net does not represent this working draft of the
NTC, instead, as you have seen the previous proposal, right?
There have been a lot of good suggestions from ISPs and a lot of
discussion on

that. And we think that TWG will be best serve

if we can use this as


not to.
ATTY ROY IBAY =

one. But it is up to the NTC whether or

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


where

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

also look on the


(cont. Atty.Ibay)
Transcript on the Stenographic Records and quoting the
NTC on
Page 19 of the Stenographic Records. We would like to
state that

during the last meeting, paraphrasing on what NTC

said on Page

19 that current meetings that we are doing now or

conducting now

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

is stated here that this

Minimum Standards if ever should be discuss

earlier if there is still

need

to

Standards. What we read upon is

include

Number

meeting is that we need to empower the

the

Minimum

on

the

past

consumers to make it

more transparent to make them known on

what

they

are

paying for and that they get what they are paying
for. And in relation to what the other agencies like DTI and
the

DOJ are doing that it is the NTC that shall have the

mandate to at

least verify if what the carriers or ISP providers are

really what are

supposed to be advertise. But short of that, no

standards no

regulations because we again reiterate that

internet is a valuewhat was discussed

added service. So, if I adequately cover


previously, we also mentioned that

similar to the broadcasters, we


self-regulation for the ISP Providers.
believed that the worst penalty that the service

would like also to address the


In

sense

that

provider

we

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could received is our consumer itself will transfer from

one

provider to another. Because of inadequacy and because the


fact that we really not address, supposedly, service providers as
profess to deliver to the consumers. And so, we would also like to
(cont. Atty.Ibay)
address what we have addressed in the other meeting.
Another,

would

be,

moving

forward

from

our

meetings

previous to this

meetings today is that we would like to address

mainly three issues

to measurable standards, download speeds,

upload speeds and

volume. So, I think those three are all

adequate and sufficient

enough for our consumers to know

whether or not the internet

service that he/she would pay for

would be adequate enough

already

or

not.

So,

anything

forward we feel that aside from what

the technical principles

being discussed now, we also feel that it

would

also

be

good

probably to have a series of technical or field,

validation tests in

order to find out whether or not the suggested

points as contain

here in the official minutes of the NTC being

circulated now is

actually adequate for testing. So, it may be

pointless if

we limit ourselves to discussing them here in this

Conference

Room. And we feel that would be good to go out and

actually

conduct these tests to find out if it really works or if there


other better ways to find out accurately the measures of the
standards that we are proposing without being uncontrollable
variables. That is all, Madam Chair.
ENGR. SUSANA PANES =

are

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Any other comments from the group?

ENGR. PIERRE TITO GALLA =


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

to as the gentleman

mentioned just like the broadcasters there would be so


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

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we take that index, X divided by Y is times let say number


of pesos and then you will find out that we were getting
90% or 80 %. It is also part of the proposed metrics of
secondary proposed draft. However, also, reliability should
be something that

(cont. Engr.Galla)
we think be included because not just been it is good if we
are able to get 90% speed all the time that is great.
However, if outages are not included in the metrics, it
would be similar to excising the amount for our customer
experience so if we are able to include service reliability it
would also be good for all of us. And then, finally, on the
parameters that are presented here in the official minutes,
we also include them on the proposed draft. We agree that
some sort of first field measure

should be done so that

it would also be able to see where we are in establishing a


based line, such that if we are agree that this is the
parameters that we will set then maybe we can move
forward and establish a standards mandated. Thank you,
Madam Chair.
ENGR. SUSANA PANES =
Thank you.
MR. CARLOS NAZARENO =

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I would also like to add to that. The other party mentioned


the

download, upload but latency and packet loss is also very


important. Because for drop packets, it can render your

real-time

applications

Massive Online

like

video,

live

streaming,

MOOCs,

Video Learning Services so when you drop

packets, the client will tend to resend packets in the server and
it can add to bandwidth.

Sayang

magreresend and then service time-

young

bandwidth

kasi

outs. So there are also

numbers of real time applications will break

(cont. Mr.Nazareno)
when packet loss reaches a certain level. And then also
latency is

very important because some real-time applications

is rely on real

time.

ENGR. PIERRE TITO GALLA =


Madam Chair, maybe it will be useful for the bodies to see
the

comparison for this performance metrics versus the

subscribers

experience.

ENGR. SUSANA PANES =


Before we continue our discussion. I think we have a copy
of this

one. This came from Dir. Cabarios. This was part of

the minutes of

what we have discussed last time. It is written

on the paper that the

growth agreed on following aspects. The

following parameters

shall be measured (1) Downstream and

upstream average speed,

(2) Latency, (3) Jitter and (4) Packet

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loss. The location of point A shall be hybrid, i.e., some of the


locations shall be known and other locations shall be determined
by NTC staff who shall conduct

the

measurements.

location of point B shall be (1) within the

The

local area of the

TelCo, (2) outside the LAN of the TelCo but within

the

national network and (3) outside the LAN of the TelCo and
outside the national network. And the last point is the
results,

including the locations of points A and B, shall be

released

within five (5) days after the end of each month. I

think this was

what we have discussed last time. And we

were expecting that we

(cont. Engr.Panes)
will be dealing on this agenda because we are trying to
come with the parameters that we are going to consider in
measuring the

minimum bandwidth. But I would like to ask

now is that are we all

agreeable with this for what we had

discussed last time. Yes, Atty.

Ibay?

ATTY ROY IBAY =


Madam Chair, as I previously mentioned, on the point of
the

TelCos we discussed doon. Actually, we agreed upon what

was

suggested by both TelCos and democracy.net previously.

That is

for item B. This is for the items that we measured.

But we did not

commit in fact we said that we will discuss

among industry. But we

will submit whatever factors or

variables that we have agreed upon

to be measured. So,

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that is the reason why we disclose early what

the factors that

we want to measure only are upload, download

speed

and volume. So, we submit that is our position, we do not


submit to latency, jitter and packet loss. Instead of latency,
jitter and packet loss is volume for the consideration of the NTC.
And

the other methodologies, these are also discussed but I

think we

will limit ourselves to the process by which there will

be no

uncontrollable variables meaning within the network.

I think our engineers here will be more adequate to discuss.


ENGR. SUSANA PANES =
Any other comments?

ATTY. ANTHONY FERNANDEZ =


Madam Chair the testing on the testing point. All of these
points

had

been

discussed.

discussed as options but

We

were

simply

after meeting with the group

you were more confident that you

would

available if you will test us within in the full context

be

more

of

our

network where we have control not outside our network.


Again, with due respect to the test points, we were discussing last
time na the controlled points would be
which are created

by the NTC.

control point at NTC but Ms.


suggested that there will be multiple points in

Grace

servers

Initially, there is one


of

LIRNE
across

Asia
the

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country also advised in the NTC offices. I think if it is


within our network then we have control.
ENGR. SUSANA PANES =
Any other comments?
MR. CARLOS NAZARENO =
I think we also have measurements on controlled points or
not

controlled points outside the network. Because that

is the actual

used case that the consumers used. They

connect the servers

overseas which the local ISPs have no

control over but that is what the consumers accessed.

ENGR. PIERRE TITO GALLA =


In fact Madam Chair and for the acquisition TelCos, we
proposed if you look at the Annex F and Annex G of the
proposed draft,

what you will able to see there a process by

which a TelCo should

not be penalize or should not be made

accountable for any

variability

network. But from within

that

comes

outside

your

the network, obviously, because

that is the subscribers connection, in fact, it becomes fair. But


again, it is not about the TelCo that we penalized. So, if I am
paying a hundred pesos for X,Y and Z, but

ninety pesos worth, siguro naman it is worth

returning the ten

pesos to you. So that is where we coming from. In

only

getting

Annex F,

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you will find the propulsive of the citizens charter by which


quality of service complaint will be handled and

mediated

by the NTC. And Annex G, it is the service provider who


complaint.

Especially

if

the

service

the

provider

A,

has
the

substandard service of the service provider A is not cause


by this

network but is cause by somebody elses network. I

would

resumed for instance that Cable TV internet provider

have such means to be able to show that it was not their


connectivity to their

cable internet but rather their backend

that was their problem.

Now, if all the citizens charter also

provides that the second TelCos,

meaning

complaint about, should not also be

the

TelCo

being

unaccountable. A, if the

service provider A complaint properly to

(cont. Engr.Galla)
his counterpart TelCo. B, if the service provider B provide a
penetration measures for our service provider A. And C, if
there is

none, then that is the time that the NTC step C. But

we will, of course, make sure that we will respect contractual


relationship

between

processes of Annex F and

TelCos.

Hence,

the

proposed

Annex G. So this is again in line

with allowing for measurement out of the national outside of the


land but within the

network and outside of the land of the

TelCo and within the

nationalize

outside of the land of the

network

and

conversely

Telco and outside of the network. I

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am sure Sir, perhaps, you have

sufficient

time

to

review

these new decks.


ATTY ROY IBAY =
Actually, that was only said yesterday but per year we
actually

met. We understand. We took a look at, actually it is

also the

reaction of their previous draft.

was just assigned

But I guess this

if the NTC put on record that it is not

their job. What we are saying

is that if the NTC will consider

this in Toto as a working draft then

there is really no point

that we are going this TWG because we are

already

submitted a position paper largely on this version. And


moving forward which we would like to say that it is really
their right to submit such a draft. But considering the gains and
heavy

way that we are already achieved in conducting this

TWG, it

(cont. Atty.Ibay)
should be two steps backward if we are going back to this
discussion on standards. It is better if we already, Engr.
Pierre was not here on
discussions with DOJ,

the past two meetings, we have


we have discussion with DTI that is very

productive. That is why

we are working this TWG to be able

to move forward to agree

on

measure in order to comply. We

certain

parameters,

how

to

are already actually gone on

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the discussion on which jurisdiction

across

the

hook

meaning, DTI and DOJ have their jurisdiction to enforce truth and
advertisement. And the NTC has also has its own

jurisdiction

in terms of being measure in accordance, and with

relation

the DTI and DOJ to have measure. So, as we said,

internet

to

should be a value-added service. It should be deregulated but


we support consumer rights, we support that the consumer has
to get what they pay for. And we agreed that

in

accordance with the mandates of the DTI and DOJ that on


whatever it is that service

providers advertised, there has to

be a way to measure whatever it

is that they are supposed to

get. So, because of that, we are able to

move forward but if we

are able again to dwell on the draft which

has been already

previously discussed and there was submitted position


paper then there is nothing for us to say.

We are already

submitted that position.

ENGR. PIERRE TITO GALLA =


We would like to point out that I know I was not present but
siguro

naman minutes and everything were able to read.

But that is it,

PAPTELCOs position, TelCos position will be

valuable enough. We have been using that and that NTCs


position, DTI and DOJs inputs, those were all part of the creation
of the draft. So, we do not

consider

this

as

two

steps

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backward because again, the end goal is a

working

document as an MC by which the NTC will raised. What

we

are saying is that we will listen to you and we have meetings, in


fact with such ISPs and DTI and DOJ. And the end result of
that is

we are proposing this draft. I am sure you have no

time to really

read through it because as you said NTC just

based on what you

said. Everything that has been discussed

on the past meetings was


best effort, that the minimum

incorporated their statement like


should be set by the ISPs and

so on. They were not missing.


ATTY ROY IBAY =
I categorically disagree. I just like to maintain that we just
move

forward on what will be discussing. And if that is their

right to

submit a draft, so practically okay with us. But we

submit to the

NTC that we just proceed on what we will be

discussing and that it

is their position to give consideration to

supposedly being

discussed. But we maintain that it did

not.

ENGR. PIERRE TITO GALLA =


Can you tell us how?
ENGR. SUSANA PANES =

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Excuse me. Before we continue with our discussion, maybe


first we

will hear from Globe then afterwards I would like to

remind you

that the Commission is hoping that we can to

come up with

parameters that we are going to discussed.

That was the instruction

to Dir. Cabarios, otherwise, the

Commission will be the one to

prepare

necessary in order to come up with the

whatever

proposed

Minimum Broadband Speed. So, we will hear

MC

is
on

from Globe.

MR. MEDEL RAMIREZ =


Good Afternoon, Madam Chair. Actually, we coordinate with
these

past minutes. This is also being agreed among us.

And for Globe,

we follow on what was said by Atty. Roy, as a

PCTO and a

member of Globe.

ENGR. SUSANA PANES =


Yes, but I would like to ask if, yes, according to Atty. Ibay,
he is not favorable of measuring latency, Jitter and packet loss.
Kasi I just

based on what was written here in this paper that

was given to me by Dir. Cabarios. It is my understanding that


during the meeting

we are all agree to take this parameters

as our basis for the

measurement. However, it was noted

that according to Atty. Ibay,

(cont. Engr.Panes)
it is the position of Smart that they are not favorable in
considering

Latency, Jitter and Packet Loss that we will take

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into consideration

that we will put that on writing so that

the Commission can study

this aspect. Yes, Anthony? Would

like to say something?


ATTY ANTHONY FERNANDEZ =
Yes, Madam Chair, just to further solidify the point. We
agreed to

discuss that point but there is no fine agreement. We

just simply agreed

that

we

consider

the

following

for

consideration.
ATTY ROY IBAY =
We discussed in our group what would be acceptable to the
industry and after discussing it came out that we all
consider at least the three: the upload speed, download and
volume.
MS. ALELIE GERMAN =
Good afternoon everyone. Perhaps, the ISPs could help us
to

understand on why there is a vision on Latency, Jitter

and Packet

Loss so that it could put on record also. Thank

you.

MR. REGIN BRIONES =


Latency, Jitter and Packet Loss are very technical metrics.
And if
regulatory

the objective is empowering the public on their

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(cont. Mr.Briones)
consumers, I think this technical parameter
already

metrics are

be has the right impact on the download speed,

upload speed.
ENGR. PIERRE TITO GALLA =
That is incorrect, Madam Chair. May I use the projector?
ENGR. SUSANA PANES =
Yes.
ENGR. PIERRE TITO GALLA =
Perhaps, for the benefit of the DOJ. As you can see their
differences in how performance metrics affect the subscribers
experiences. So, if you are browsing a text based tsaka wall of
text, typically like

ghost.ph. Download is important, upload

is irrelevant, latency is relevant, Jitter is not, Packet Loss is not.


Browsing download is

important

for media for example, you

are watching You-Tube. Download is

important, upload is

not relevant, latency is very relevant, Jitter is relevant, Packet


Loss is relevant. Redundantly,

only

the

relevant, upload is not, latency is not, Jitter is

download

is

not, packet loss is

not. Transactions like BIR recently, download is not very relevant,


upload speed is not very relevant, latency is very

very

relevant, and Jitter is very relevant as mentioned

by

Carlo

earlier, packet loss is not relevant. Streaming media, if you


are

going to watch, download is very relevant, upload is not

relevant,

latency is very relevant, Jitter is very relevant and

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Packet loss is

very relevant.

VOIP,

Skype

and

other

applications, download and


(cont. Engr.Galla)
upload are not as relevant as Latency, Jitter and Packet
Loss. This is

where you will see all those corrupt pixelized

the conversing in Skype. Even if your speed is really good but


your Latency, Jitter,

Packet loss are high, you do not have

those pixilation. For games,

online

gaming

like

those

is

performed by people in general or speed particularly you have


done with. Upload speed not so

relevant,

Jitter and packet loss are very relevant.

This

cannot just be in volume, you cannot just be

again,
is

Latency,
why

upload

you

speed,

you cannot just be download speed.

MR. REGIN BRIONES =


I think this is refers to the relevance not with direct impact.
Obviously, packet loss has always effect on any media
browsing.

If you will get the document, Jitter and Packet Loss,

generally, is

very important to real-time services. So, VOIP

and games these are

real-time applications. But speaking from

radio just like the fuji

unji UMTS from radio perspective, we

have four classes of

services:

interactive and the background.

training,

conversation,

Voice is categorized as real

time but it is not a packet switch. But all

internet

connections

we get via UMTS and LTE are class as

interactive. So, it is

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not categorized as real time service. Then, that

is

interactive.

ENGR. PIERRE TITO GALLA =


Yes, that is one of things we took there in the proposed
draft. We

include the definition of the best efforts there for

exactly what you are saying.


MR. REGIN BRIONES =
So, that is why on my point of view, speed can already be
measured

or

there

download, upload
what we offer since it is

is

already

an

enough

measure

speed plus the volume per plan doing on


an interactive class of measure.

ENGR. PIERRE TITO GALLA =


Interactive class of service? And you are mentioning UMTS?
LTE? Will this position of PAPTELCO cover the fixed broadband
and all

that? Will it still a plan? So, we will not measure? You

do not

intent

to support the measurement of these

parameters for fixed?

MS. MARIBETH SANTOS =


Yes, we have this in our position.
ENGR. PIERRE TITO GALLA =

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Do you submit to the DOJ that, that it is not exactly fair?


Because

as you see, this run is the gallop of subscribers used.

So, I released

my LTE phone to Skype, is that something that

I should able to

do? Or should my contract say please do not

use your Skype while

(cont. Engr.Galla)
you are on the cab. Because I will not know my Jitter is. I
think my

speed is good based on LTE. Assuming that I am

getting what

speed I am getting the advertised speed,. But

it is clear here that it

is not really about the speed. It is about

latency, jitter and packet

loss.

ATTY ROY IBAY =


I think what Engr. Pierre was saying is that you are using a
wireless, LTE? That is precisely I am saying. Fixed line,
wireless

or a mobile, there are so many uncontrollable

variables. He was

saying that let us say that I cannot use

my Skype and the cab, it

depends.

Probably if the cab is here in the area

Where
wherein

there so many people using the internet? That

is

the

cab?

traffic

and

would

affect your internet user experience. Or if you are in the

cab

and the cab is somewhere out in the rural area or something


then that would really affect the usage experience. There
are some

variables that you were saying that may affect your

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user experience. That is why for wireless, for mobile and fixed
internet

there are also certain variables

saying that is

that is why were

why we are discussing now. Maybe we could

also be proper now

to schedule

tests to be able to really

those

certain field

accurately simulate our suggested

metrics. This is probably our suggested metrics. And to be able


to compel and find out which

(cont. Atty.Ibay)
would be accurately in terms of being determined what is
the

actual

considered.

speed and download volume metrics are to be


Considering

what

the

TelCos

are

only

suggesting or pointing out is that this will be done in a controlled


environment.
MR. CARLO NAZARENO =
I would also like to speak as a member of International
Team Developers Association Manila Chamber. I would like to
point out

that gaming is not necessarily all man. Game

development has been bringing billion of dollars in China and


Korea. And the terrible latency we have in the Philippines in the
packet loss has been

hampering

developing products which

us

gain

developers

from

can bring dollars in the Philippines.

It has been very distractive. It

has been hampering us for

fifteen years. So, it is crucial that we get good


minimal pocket loss and this does not only on

latency
gain

and

developing

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industry. This also extends to the creation of start-

ups

which

involve real time video and document sharing, real time


communication apps. I, myself, download with this but the
problem is within the same room. I am on Bayantel and I
am

PLDT, I am a subscriber of both. I build an app which is

multi platform video. The latency was so terrible. There are


about 200-300

milliseconds between two devices in the same

room. And it is

destructive to the Philippine software industry.

ATTY ROY IBAY =


It is easy to quote without any data to backup your
statement, Madam Chair. Because let say that the video industry
has been

driving in fact it is going big and

mount and that

you have data to show that the data you are saying let say you
are saying I am sure

it happens. But to quote to

absolute like tangent and

being

expensive.

ENGR. PIERRE TITO GALLA =


Yes, you are right. You are
we

recognize

talking about the IDVTO can

your efforts on that note? But remember the

quality of this connection of IDVTO is not covered by this


memorandum circular. It is covered by the existing
Memorandum Circular the

one that is mentioned na MC

No. 12-19- 2004 which is committed informationally. That is

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what they are getting, that is what they are using, that is the
context they

have with you.

ATTY ROY IBAY =


So, you are saying in connection with the industry? So
maybe you have to specific what subscription are you using. If
probably your

coming from an industry and you really want a

committed rate

then you will subscribe. Why you are saying

bandwidth the

adequate only for a residential and let say for

example for a

(cont. Atty.Ibay)
demand that would probably approximately something for
a small

enterprise. That is what the enterprise packages.

MR. CARLO NAZARENO =


I would like to comment on that. The problem is our
customers are

using home subscriptions. So, that is why

destructive.
ATTY ROY IBAY =
I think the problem is we would like to relay to the
consumers or

really adequate residential consumers.

We do

not want to talk to

people to subscribe to residential plans

and we would like to

ascribe unlimited bandwidth to a service

that should probably

subscribe that are committed internet

bandwidth rate. How can

you say that your carinderia and

you would like to assume that

your

business

will

allow

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bandwidth for a free wifi that a hundred

consumers will be able

to used. May consumers in carinderia not


serve

been

able

to

toward subscribed to residential.

ENGR. SUSANA PANES =


Excuse me lang po. Atty. Roy, I understand. Anyway, I just
like to
the

remind the group that hopefully we can come up with

parameters. That is why we set for another schedule or

date for this

technical working group so that we can arrive

to the parameters

that

we

technical parameters before the

are

going

to

consider

the

Commission can react to the

MC. So if we may not able to come with

the

parameters

then

maybe the Commission can prepare the


(cont. Engr.Panes)
MC. But we are given a chance to the TelCos to really make
recommendation to the Commission on how we can
measure. That

is why we are considering all your inputs

together with LIRNE

Asia. Sana po we can able to settle on

this points na we have already listed the measure that we are


going to consider. Sana we

can only focus on these items that

we have already enumerated to

this paper so that meron po

tayong output today. Sana po we can

have a good decision.

Thank you.
ATTY ROY IBAY =
Madam Chair, at least two points lang po on the gaming
site. We

actually have several subscribers of ours on slow

internet rate

because

sometimes

they

subscribe

to

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residential or to small base

but they took it up in internet caf

which is unfair also. There are

consumers

residential there are willing to pay sa service

naman
and

na

they

can

defied their connection which is high. So, the higher CIR,


more stable it is. That is why we are saying if you have

the
a

higher requirements subscribe to a higher plan. Because of the


basic residential basically your CIR will be a low number
but not as high as other packages. If you want a higher CIR,
subscriber to a

higher package. Second item is why only for

the reservations only

the speed of download, upload and

volume because that is what we only commit to our subscribers


po. So if in our regulatory

environment that we will measure

on the truth and advertising

(cont. Atty.Ibay)
then let us measure on what we are going. Yung kinomit is
worth

accurate delivery? But again, if other subscribers,

consumers or

those who want to measure other parameters

outside the regulatory bandwidth let us say the uninformed


charge for the

consumer protection like

they rate us

excellent or fair or

something like that po. But in the

indexes and then

whatever. We are not

regulatory environment po,

what we commit is what

we measure. Kasi kung dinidikta na

po samin na parang dapat

ganito sukatin mo ito, parang they

figure upon on how to run the


Packet Loss and latency po, it is our

business already. Yung Jitter,


best interest po na to

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give this figure within acceptable limits kasi

when

there kahit sabihin namin na we are delivering the

you

are

speed

and

the volume, kalaban po naming ang subscriber naming

na

magsasabi na, I do not like you, we will leave. That is more of a


penalty na it is hard to make from us. So, kung sabi ng
subscriber na I am happy with you that is more than reward for
us. Just your

interest to keep this figure on a acceptable

level kasi po mahirap po

kung

san

ka

kasi

ang

pinakakalaban mo is yung customer mo. Yung public perception


pwede mo pang defend yourself. But when

the

says, goodbye I am leaving you, wala na po kaming

subscriber
laban doon.

ENGR. PIERRE TITO GALLA =


We took that in college dati na in so far as standards are
concern, as

I presented you this presentation. In Annex B,

you will notice the

speed, how to measure the data and so

on, so forth. In Annex C,

what we propose is exactly what

you are saying but we are not

going to tell you what your

maximum Jitter is is or what is your

maximum

latency

is.

We will provide that index a connectivity quality index. Let us


say for Plan 999 of wi-tribe, you will get a

Connectivity

Quality Index of let say 2.6, so it is good. We are not saying that
you should penalize for it. It is just sounding that the public

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should be better if they know. Let say 3.6 rating which is


and so

very

on and so forth. We are not telling you what is your

minimum should be, that is up to you. What we are saying


is that

the metrics should be measured and it should be

included in such an index so that in consumers, we purchase


the right higher end

plans if we are higher end requirements.

And if you do not, then let

us speak to that. We are saying

that a carinderia who uses those

speed

contain vanity, of course not. I think we

should

will

be

just

able

submit

to
our

position paper to this Commission.


ATTY ROY IBAY =
And looking forward, I think on the approach as you
mentioned earlier that we commend a field or simulation test on
what you

suggested

discussed today or

in

whatever

quality

whatever

we

previously. Because I think it is pointless

if we can go on and
(cont. Atty.Ibay)
discuss until the end of the time if we do not really try to
simulate

test, we cannot achieve on something.

ENGR. PIERRE TITO GALLA =


Madam Chair, it is good idea that we have a field test, in
fact, LIRNE Asia was not here but we can able to see a previous
test that

the LIRNE Asia tested for South-East Asia. Maybe we

can ask

LIRNE Asia to submit methodology in such items.

MS. ALELIE GERMAN =

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It is okay to have the field test but do we have the


equipment too?

Perhaps, the TelCos you have but how about

the NTC? How can

we validate that?

ATTY ROY IBAY =


I think for the NTC, my suggestion is, they already have
agreements that they can secure but again, this is
probably

depends on the call of the NTC. We just like to state

that this are the what they are suggesting. That would be the
more or less the contention of the test. So we are able to come
with the more

accurate metrics. And on the benefit of the

DOJ, a lot of these tests

is in fact to that require tools. They

are just programs and we

need just to record the data. So if

the TelCos wanted for instance to

measure for a certain areas,

that will be their tools. But for the

parameters

discussing for the past hour, those are the

that
readily

we

are

available

used metrics on a cable.


ENGR. SUSANA PANES =
Before we are going to take into consideration on your
suggestion regarding on what test we are going to conduct, we
will put that on

record and will consider that. Probably, we will

inform the Commission if they are okay with your suggestion.


ATTY ROY IBAY =
Madam Chair, the democracy.net agreed also to our
suggestion in

order to come up with well-informed and

accurate. So, just for they


ENGR. PIERRE TITO GALLA =

consideration of the Commission.

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We would like to say here that our position paper is


completely not

adversarial with yours. We understand that

there is a really big

difference between enterprise level users

and consumers. So, hence,

the change of the title that you are

recommending change of the

title is quality of service. And

that, Annex C provides an index on all standards. Annex B is


probably something that we are going to hammer

out

whether or not we agree on the minimum. Well, we

ask

again to the position of the Chair. This is something that we


took together, in Control 11 and Commissioner Cordoba
promised

on an apple

happen or not.

document. That I do not know if it

Based

on

offerings that are in the

the

standards

Annex

what we took together. We do not

for

the

service

B of the new draft, this is

have comparison

for

the

proposed max speed against the current corresponding


technologies that are available today and that

(cont. Engr.Pierre)
the TelCos can use not just the TelCos but ISPs such as
Cable TV

and so on. So, for example, service offerings invested

for minimum

speed that shall be used by the ISP, maximum

speed shall be used

by the ISPs. This is the current practice,

is not it? So, the internet

which is the based line of all the

internet around the world. So

without prior to go through to

take all of the implementations in

the standards. The reasons

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why you have technological minimum

speed

is

service providers typically put them all together to

because
trans

range. What happen is if I can go back to this one, from

the
GSM

2G of 14.4 KPBS down and up, you moved app to its absolute
maximum of edge of 1.9 MBPS and so on and technologically
speaking that is for them to control, that is for the

networks to

manage. So, that is why we made a definition. And

please also

note that the proposed maximum speed is very far from


technological max speed. We recognize that you need to
manage

your networks, the number of subscribers you have.

Because it is

not definitely costly efficient if you are going to

spend too much to

be able to deliver something that is

already too high. So, this us up

to you.

MR. REGIN BRIONES =


In relation lang doon sa what is edge type two EO type one
EO type

two. These are the

standards by edge those for the


Edge revolution type one the max
download is 1.2 MBPS. I do not know if they are

declared
building edge.
speed

of the

implementing it

right now that is why I am asking. Previous night,

we do have

GSM 2G. I do not know what 2.5G is. I think Goble,

Smart, Sun

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have

that.

The

mobile

MBPS. In the

internet

basically

starts

with

13

technological point of view?

ENGR. PIERRE TITO GALLA =


It is with edge.
MR. REGIN BRIONES =
Okay. But edge is after the implementation of GSM as well.
ENGR. PIERRE TITO GALLA =
Yes it is.? We have to this hard way because there is no
public

declaration of what Telecom Industry is using in the

Philippines.

You have mentioned the technological brand

name but not the

technology. I found out in instance that

the TV we are using here in

the Philippines we are not sure

because there are two kinds, LTE

2x2 and LTE

do not know which one we are using in

4x4. So we

the country. And the

max speed of the 2x2 is 173 megabits per

Second for 4x4 is

326 MBPS per second. What we are proposing for

the

definition is high speed broadband of the Philippines, it is

(cont. Engr.Pierre)
proposed minimum speed of 2 Megabits per Second which
is less

than 1/3 of technological max speed.

ATTY ANTHONY FERNANDEZ =


Madam Chair, I just want to interject while it is nice to
know that

we are discussing this briefing. Now, we are giving

our focus on

the Memorandum Circular

for fixed internet

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service.

So that we do

past just in the few

not

want our achievements in the

meetings.

ENGR. PIERRE TITO GALLA =


Yes, sir, thank you very much.
ENGR. SUSANA PANES =
Any other comments from the group? From PAPTELCO?
MR. CARLO NAZARENO =
So we just clarify that what we are discussing is more for
fixed parameters?
ENGR. SUSANA PANES =
Hindi , it is a new.
ATTY ANTHONY FERNANDEZ =
The Commission wants a separate?
ENGR. PIERRE TITO GALLA =
We actually considered yong discussion in the past na isa
nalang na

document para klaro lahat. That is why the definition

of wireless,

(cont. Engr.Pierre)
mobile internet, mobile broadband all came out is based
on the

implementing rules in the Philippines. We, as

consumers, do not

know technically

implementing but there are

what

you

are

public documents from the

ITU that declare all this. So, we put this

here. You are correct

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when in pointing out that we do not

use

edge revolution

one and two? So, if not then that is not part of spectrum of the
speeds that we are looking for but we know how

we

are

going to fix again the technology.


ATTY ROY IBAY =
Just to clarify. I think what we discussed is that there will be
one

MC that will deal at least on the methodology of

measurement. But

the approach of measuring wireless and

fixed will be different. But

that

will

be

containing

one

document.

ENGR. SUSANA PANES =


Any other comments? So, if none, we are going to consider
your suggestions for what we have discussed today and we will
just

inform you on what will be the position of the Commission

as

regards with you have all suggested today. So, if there are

no other

comments, can we adjourn the meeting?

MS. ALELIE GERMAN =


Just a clarification. The ISPs are willing to be deregulated
on

volume, download speed and upload speed? But you are

also open

on

parameters?

NTCs

publication

of

your

Jitter

or

other

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ATTY ROY IBAY =


First of all, we said that based on our discussion, the
carriers have

agreed based on what we have advertise or

what we will offer to

our subscribers which will be focus on

upload speed, download

speed and volume. Since those are

the factors or those are the

service parameters intend to offer

to our consumers. And because

we

awareness and their right to what they are

support

consumer

paying for and to

get what they are paying for. Therefore, it is the

NTC should

in partnership I guess with the service providers to be


available and also to the consumers to come with the
methodology

measurement.

ENGR. PIERRE TITO GALLA =


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

speed, download speed, and volume.

ENGR. PIERRE TITO GALLA =


Not on the reliability?
ATTY ROY IBAY =

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Just reliability is really question of how controlled or


uncontrolled

the conditions are existing in the area.

ENGR. PIERRE TITO GALLA =


But currently, you are already complying with the paper
07-07-2011

which

says 80% reliability.

ATTY ROY IBAY =


On minimum speed. What we are proposing is average
upload or

advertised

minimum speed but

speed.

No,

you

cannot

on our declaration,

advertise

we are compliant

of 07-07-2011. But this is

different. You want to

so you are saying that you

want to be measure based on what

we advertised and offer to

our subscribers then you could

measure your upload, download

avail

with

and volume.

ENGR. PIERRE TITO GALLA =


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

ATTY ROY IBAY =


Well, basically, again, we are going back to your draft.
What you

are saying is we are now on this page, we are now

discussing on

what

standards

are

we

agree

with.

So,

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resubmit, upload, download

and volume. I cannot go beyond on

what the industry has already

agreed upon.

MR. CARLO NAZARENO =


When would be a possible time for other stakeholders to
weigh in

on this possible figments on the MC? Kasi parang

unlearned presented yong like industry people like developers


aside from the

consumers.

ENGR. SUSANA PANES =


This technical working group is limited because we are only
dealing on technical parameters. And as what we have
discussed a

while ago, all your inputs are all noted and all

your proposal is also

take into consideration. At this point, I

cannot give the position of

the Commission as regards to your

suggestions. Maybe we can

inform you in a few days on what is

the position of the

Commission. We will just notify you. But

all your comments and inputs


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

ENGR. SUSANA PANES =


From PAPTELCO?
MS. MARIBETH SANTOS =

are

all

considered.

So,

other

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None, your honor.


ENGR. SUSANA PANES =
From DTI?
MR. RONALD CALDERON =
None.
ENGR. SUSANA PANES =
From DOJ and democracy.net?
MS. ALELIE GERMAN=
None.
MR. CARLO NAZARENO =
None.
ENGR. PIERRE TITO GALLA =
None.
ENGR. SUSANA PANES =
From Atty. Ibay?
ATTY ROY IBAY =
None.

ENGR. SUSANA PANES =


So, if none, thank you very much.

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Transcribed to the best of my ability.

ELIZABETH G. LAMADRID