NTC TWG Meeting On Broadband Speeds Dated 5.26.15

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TWG Meeting on Minimum Broadband Speed

May 26, 2015/2:30PM |1
REPUBLIC OF THE PHILIPPINES

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

-----------------------------------------TRANSCRIPT
OF THE STENOGRAPHIC NOTES TAKEN DURING THE PUBLIC
HEARING ON MAY 26, 2015 AT 2:30 IN THE AFTERNOON, BEFORE
ALL CONCERNED OFFICIALS AND REPRESENTATIVE OF DIFFERENT
GOVERNMENT AGENCIES AND STAKEHOLDERS
----------------------------------------
DIR. EDGARDO CABARIOS =

Good afternoon po. Again, thank you very much for
attending this meeting. This is the end time na siguro na
mag-memeeet tayo. We have here this afternoon from the
Committee on ICT sa Congress, we have Ranier Alvarado.
Sa Committee on ICT po sya. The chair is Cong. Susana
Yap. Perhaps, para makilala tayo, siguro let us introduce
ourselves muna para makilala tayo ni Ranier. We will start
with Pierre.
ENGR. PIERRE TITO GALLA =
Hello,
am
Pierre
Tito
Galla,
PECE,
co-founder
of
Democracy.net.ph. along with my collegue Atty. Francis

Acero.
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May 26, 2015/2:30PM |2
MS. MARY GRACE SANTOS =

Hi, I am Mary Grace Santos. I am from LIRNEasia, a
regional ICT policy and regulation think tank. I am also a
member of Internet Society Philippine Channel.
MR. WINTHROP YU =
I am Winthrop Yu of Internet Society-Philippines.
ATTY. ANTHONY FERNANDEZ =
Anthony Fernandez from SMART.
ATTY. ROY IBAY =
Roy Ibay From PLDT-SMART.
MS. MARIBETH SANTOS =
Maribeth Santos from PAPTELCO.
MR. ENRICO DELOS REYES =
Eric Delos Reyes from PAPTELCO/PCTO.
Okay, thank you, we are just waiting for Derek. We have
circulated last time, I guess last Friday if I am not mistaken,
the copy of the draft of the rules on the technical as
measurement, etc. And we also have given you copies of
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May 26, 2015/2:30PM |3
the submission of the LIRNEasia na nareceived namin

kahapon. Well, perhaps, we could go over yung
(cont.Dir.Egay)
draft na cinirculate natin last time. There are comments
etc., we can discuss it now para matapos natin yan so that
we can go to other issues. By the way, sinabi lang dyan
kung ano ang susukatin at kung papaano, iyon lang yan.
We have not incorporated there yung standards. Wala pa
diyan kasi paguusapan pa lang natin dyan. Just yung imemeasure na parameters and how it is going to be
measured ung point A and Point B as discussed here last
time. And there are four diba iyong DSL, FTTA, yung fixed
wireless tsaka yung cable TV kasi apat po iyan e. So, iyon
ang Point A mo then we have point B and so on. Iyan lang
po ang content nya. We have received although this was
not circulated kasi nabasa lang natin. PLDT soft the opinion
na huwag isamang sukatin ang Packet Loss at Jitter. Iyon
po ang suggestion nila. All the parameters except Packet
loss and Jitter. Sabi nila, on parameters to tested, we
suggested two, Packet loss and Jitter.
MR. FRANCIS ACERO =
You mean, we will measure it but not release?
Yes.
MR. FRANCIS ACERO =
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May 26, 2015/2:30PM |4
I think that is helpful din sa inyo. Just to my expeience with

your technician come over, hinahanap din niya yun. So,
based on the industry standard?

Yung pag-seset
ng standards ay i-didiscusss pa natin
and how will the result be released paguusapan pa po

natin yan, wala pa po tayo dyan. Because this is a
contentious issue kung paano irerelease kasi medyo
masalimoot po yon. Kung mali kasi iyon,
the report can
have so many interpretations kasi mas mahirap. So let us

discuss yung issue na yan later yung how it is going to be
publish etc.
MR. FRANCIS ACERO =
It is helpful nung dumating yung service
person sakin
mineasure din nya yun.

Lima ang nariyan, yung average, down/up speed and then
yung latency, packet loss and jitter.
MR. FRANCIS ACERO =
For example, yung packet loss. Packet loss can gain
indication that problem is inside the subscribers. If it is
measured according to this then wala masyadong packet
loss. And then the subscribers proofs himself reported that
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May 26, 2015/2:30PM |5
notary post a complaint that there was a packet loss. Then

it is easier to point to the subscriber that the problem is
inside in the subscriber. Just a suggestion.

We believe that is a way of educating the consumers
themselves. Kasi di ba we are trying to teach the
consumers and subscribers how to use the internet
properly. So, if they now understand and they begin to
understand the different factors that affect their internet
service. Then, would that be a win-win situation? Just a
comment po on that suggestion on PLDT. LIRNEasia, the
one that we have submitted yesterday suggests that we
measure everything here that the NTC recommends but we
are also amenable to having two sets of metrics. One is for
compliance and one is for monitoring purposes only. So,
our recommendation is that, for compliance, we can
measure and set minimum standards for specific metrics
those are download and upload speeds and also the
latency. For monitoring purposes only, just so that we can
have information about those metrics. We recommend to
measure volume, packet loss and jitter. But the metrics for
monitoring only, we do not want to be publish astringently
like as widely as those for the compliance.
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May 26, 2015/2:30PM |6
Of course, the suggestion is that we measure, we set

standards for speed and for latency. So, yun po ang
suggestion ng LIRNEasia. Kasi, presently, we are being
compared to other countries kasi based on speed, average
speed lahat ng measurement. So, perhaps,
(cont.Dir.Egay)
what I can suggest is if we are going to set standards and
iseset natin is on average speeds. Kasi iyon po ang
minemeasure. Kinocompare kasi tayo sa ibang bansa on
average speed. But how are we going to set the standards?
Iyon po ang paguusapan, kung paano. Yung latency, it is up
for the discussions pero perhaps iyong average speed iyon
po ang atin. Iyon po ang kinukumpara tayo. So, we have to
work on that one. Yes, Roy?
ATTY. ROY IBAY =
Going to our discussion earlier, we respect the decision of
LIRNEasia, democracy.net.ph. and ISOC-PH. However, we
stand by our recommendation that the speed and volume,
so, upload and download speed and volume be the
parameters that should be subject to measurement.
However, we respect you position. Again, we submit as to
the PCTO to the carriers. We would like to limit the
measurement to speed, download, upload and volume.
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May 26, 2015/2:30PM |7
So, perhaps, we can stand there. Dun muna tayo,

pagusapan muna natin iyon, speed and then set. Kasi the
talk of speeds, iyong ating inissue nung 2011 is minimum
kasi, minimum speed of 80% of the time, speed. So, iyon
po noong 2011. There is a proposal now to measure the
average speed but you need to compare that average
(cont.Dir.Egay)
speed. Ano iyon? Shall we set the minimum average speed
or we compare it to other parameters like yung suggestion
is yung up to? So, i-compare mo sya sa up to and then set
the duration. Ito rin yung suggestion, yung original
suggestion. You have the average, up and down, and then
compare it with up to and then get the ratio etc. Ito po
yung suggestion as of now. Iyon ang nasa draft rules. The
other one is of course, setting the minimum ng average
speed. Okay, but I do not know, if we set the minimum
average speed that may tataasan mo. Kasi hindi naman
maganda if you will set the minimum average na lower
than what is being publish and then magseset ka ng
minimum average than that nakakahiya naman, etc. So,
yes, please?
Sir, yung current minimum, for example, I just picked up a
flyer from Globe and the current minimum setting for flyers
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May 26, 2015/2:30PM |8
is 48 to 56 MBPS tapos 80% reliability. When I picked up a

flyer from SMART is the same. Tapos doon sa wire is
different naman. It is reasonable naman, I think, to pursue
stick that we present this to the public what the minimums
are. Hindi po siguro nakakahiya, it is not embarrassing. But
we know the minimums are. For as long as we are just
clear that the minimums are these. It is going to be unfair
then for service providers that we will impose a minimum
that they
(cont.Engr.Galla)
cannot meet whether it is fixed wireless, wire or mobile, we
are going to impose let us say the broadband definition of
the ITU of 256 MBPS to them but they cannot meet that,
then that would be a duly burdening with them naman. So,
it is fine if we will stick in publishing what the minimums
are. We just require the service providers na whatever your
minimums are, let us declare it to public in proper. That is
the position that we have on the draft.
So, the suggestion is we let them specify their minimum
average speed.
So, currently they are already complying with the old 7-72011 that the minimum speed is X, Y and Z? They are
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May 26, 2015/2:30PM |9
complying with that. Are we fine with that? Dapat continue

nalang yan. That is our position. Dapat i-continue nalang
yan i-publish ang minimums na ganun.
But yung kanila kasing minimum is to be experience 80%
of the time. So, it is different to what we are trying to do
now is to measure the average. Kasi yon ang kinukumpara
tayo sa ibang
(cont.Dir.Egay)
bansa especialy the average speed. So, we will just
continue asking them to specify the minimum that can be
experience 80% of the time. Yes, Eric?
I have heard, Dir. Egay, that before with regards with the
comparison. I think it is a big unfair if we will have to
mention
what
we
have
mentioned
earlier
regarding
compared. As we have mentioned in the past, before we

even go to the metrics, before we even go to the metrics
what we are discussing, we have to look to at the available
infrastructure that we have in the country right now. I think
during last meeting, we have mentioned that there are
places
that
cannot
even
released
by
the
available
terrestrial bandwidth, the available bandwidth that you can
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use to be exact.
So, I think we have to qualify that we
cannot just upset to what we allocate compared to other

countries. We have to qualify which country. It may be
compared to Korea or more developed countries then I
agree and to compare with other then it would be better.
So, except that you want to re-progress, you want to
progress also. But we can use that siguro as a basis just
look at what we have right now.

Iyon kasing measurement done by others, mas mabuti if
we come up with our own measurements and then sabihin
natin na ito yan this is based from our own measurements,
ito yan hindi yan. So ito yung point natin. Of course, iba
kasi ang methodology nila and I will let them do it. But we
can come up with our own measurement basis naman.
MR. FRANCIS ACERO =
Just to repeat what they are saying. If we impose a
minimum, that is not going to be fair to the TelCos because
again, lalo na with mobile these are a highly variable
environment. When it comes to fixed, we written that open
competition is going to be the best way to all minimum
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speeds. That is why we believe that measurement and

publication of these variables would be the best way to
uplift speeds and errors. If regard with the download
speeds that is the average household, download speed for
fixed line. And that is based on people who make to their
internal things using speed test. If we go and set a
minimum based on, it represents a whole. For what level?
Is there be a minimum for what price? Should there be a
minimum? When others come in the market can come in
and offer something that is more destructive, we do not
want to stop that.

I just want to emphasize that this is actually what we are
doing. It is actually an opportunity for the Philippines to
correct whatever ranking is out there, whatever conception
is out there. We can always go about complaining about
the methodology used by ookla or by akamai. But unless
we have our own way of measuring and then there is no
way for us to say that no that is not true. Of course, these
running sites do this for profit. They have their own
reasons. So, it does not matter to them if in their ranking
the Philippines is only second in Afghanistan in terms of
lowest average speed. But what do we have to counter
that? We do not have anything. So, unless we have an
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official
measurement
tool
or
something
that
is
methodology we can agree on to present that this is

according to our testing and methodology. This is the real
situation. And also, I want to repeat the LIRNEasiass
recommendation from the beginning. We are not for
imposing
minimum
average
speeds.
We
are
for
measuring typical and average speeds across the country

using large data sets as much as possible. We cannot just
measure, let say NCR and then say that minimum average
speed sa NCR ay ganito, so, i-impose na natin yan
nationwide that we are not for that. We actually want to
have
measuring
tool
with
credible
reasonable
methodology something
(cont.Ms.Santos)
that the NTC, the TelCos and all consumers can all agree on
and understand we want to educate the public on what
factors are affecting the internet use. And, so that we will
know what kind of plan do I need the data plan. If I am
using the, probably, I will get a plan that is very good in
latency. Or I used a VOIP a lot especially for communicating
with OFW or to my business and then maybe I will get a
plan that is very good in latency, jitter and packet loss. So,
I think that is a first step to educating and also setting our
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own standards without being compared unnecessarily and

unreasonably to other countries.
So, ang ibig sabihin nyan is that we do not set the
minimum average speed. And we just measure and then
release the results. So, we do not set any minimum etc. So,
iyon po ang aking gagawin then the result will be released
per area basis, NCR ito ang NCR kasi magkakaiba yan and
then you take the average.
If that is the approach that we are going to take for the
moment and then
alter on we can set standards then
essentially yung draft na pinresent ng democracy.net.

cannot
be released
without
the standards. But
the
measurements of the publication siguro pwede na iyon?

Yes, so we will the discuss the publication side later. What I
understand now is that we do not set standards. We
measure and then release. So let the consumers choose
the plan, etc. Yes?
And then it would help correct any misperceptions with
regards to what are the actual speeds are. Kasi for
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instance, yung 3.6 ni Ookla ay baka 3.6 because saka lang

sila nagmemeasure ng connectivity nila when they are
pissed off with their connection. They do not measure as a
normal basis. They do not monitor their connectivity. So,
saka lang nila minemeasure and that is why the numbers
are like that because
they only measure when they fee
or they perceived that something is wrong which is wrong

naman din. What we need to have is a methodology that is
consistently and continually, good results, publication na X,
Y and Z periodic results ito ang actual ng Pilipinas. It would
help correct any misperceptions that are brought about by
such firms who do those user generated results.
Yes, Eric?

Thank you, Dir. Egay. Sorry but we cannot agree to the
measurement and then publish. Again, I have mentioned
before, the problem is that there are so many resellers and
those resellers are competing again to those who buy their
bandwidth. So, what do you want us to do? You want us to
fold up? That is just coping up with other carriers. They are
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getting into our areas. So, what happens? I do not think

that we can agree on that kind of proposal.

Well, let us first take a look at the situation where yung sa
kanila yung access kasi they are just providing the access
kasi last mile yung sa kanila. So, they are very independent
on the connectivity. Kung pangit ang connectivity nila they
will suffer. Don kasi sila sa huli, the last mile. Yung access
site, yung connectivity site kasi they are leasing from the
network provider. So, iyon po ang situation nila katulad ng
CATV and the others. So, we fully understand. Let us look
at their situation. Ihiwalay po natin ang situation nila as the
situation of those who providing connectivity also at iyon
po an gating ihihiwalay para po hindi sila maapektuhan
whatever results of what we will be publish. Titingan nyo
yung situation na yan para hindi kayo ma-prejudice. Yes?
MR. FRANCIS ACERO =

We were saying before na we were not oppose beard
measuring system where resellers are being measured on a
different standards as opposed to network providers. In that
way na if per persons na who are similar situated are
measured na equal. The point is the market has to be able to
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meet an inform choice. If the market is kept in dark above,

the choice is not they have above call it link then that
defeats the purpose of the market itself.
Yes, Eric?
I do not think they can keep on the dark. There is an
experience alone can have the providers the action that
whether they are going to use the providers or not.
Competition yan, may competition ka. The problem of what
you are saying is what you want us to do is that okay, i-label
na natin yan.
Ito yung
mga first
provider, ito yung
secondary. Doon pa lang, kinaclasify mo na lang kami para

okay ito yung mga second class sets at ito yung mga
first
class citizen at ito ang first class citizen. We were not

competing in one market. We are not competing okay into
high-end market. You are competing across the ball. So, it
would be prejudicial to the resellers. Di ba?
(cont.Mr.DelosReyes)
Icaclasify mo na agad. Tapos sasabihin mo, PLDT and Globe
ito yung sa kanila then imeasure natin into resellers.
We
are comeoting across the ball. Hindi naman natin kinukuha

yung CD market e, lahat yan. So paano? So, sasabihin natin ,
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ito class A to at ito class B? icaclasify mo na din di ba?

Prejudicial sa mga resellers yan.
MR. FRANCIS ACERO =
Our idea is that there is a feeling in
consumers
that
no
matter where you go the experience is going to be the

same.
Yes, but why will you easy for us to fold up? Sige sasabihin
mo sige, i-lalabel na natin agad yan without even know the
feeling of the subscribers. I-prelabel nalang natin sila. Ito
yung opera sa kanila yung second class, the second
secondary players and the primary players mo. Kasi if you
do
that, i-pupublish mo then i-memeasure mo, then
ipupublish tapos sasabihin mo dito ka nalang. Why you do

not let the subscribers experience? Kasi para may power of
suggestion yan, hindi pa naeexperience then sige primary
ito. Ito yung mga high end so dito nalang tayo. Parang
sinasabi mo na agad na, pre, dito yan without even trying.
Yes. Ang ibig sabihin nyan kasi is you compare kung pareho
sila. Yes,
(cont.Dir.Egay)
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I understand kasi when you publish, comparative kasi yan

kung pinublish mo. Kung hindin naman sila parepareho, so
yung
result
may
be
distorted
kasi
hindi
naman
sila
parepareho ng standing. Perhaps, you can compare the big

players so ito ang results etc. Yes? Go ahead please.
MR. FRANCIS ACERO =
The whole point is that I believe na if you let the people
decide based on that work of mouth and that is even worst
for the smaller players na because with how fast things
circulated. I mean there is no way to verify or report that
market experience alienation because that is anecdotal
evidence on that point and there is no way that you can
repack anecdotal. At least, with the publish figures, there is a
way to know our experience like this. The reason why they go
to these ISPs instead of service providers that are more
vertical integrated is you offer other things that are not
available from the other big service providers, service that
are more personal touch that are not available to them. That
is a good thing. That should what market play up.
Yes, Eric?
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Question, if I am getting 10MBPS from PLDT and they owned

the whole pipe of bandwidth. How can you change the
perception? Sinasabi mo anecdotal, okay, let us go factual.
The package is 100MBPS then I can only afford 10MBPS as a
reseller in a particular area. So you publish that and then
they probability because I can provide 100 MBPS in a
particular area. This particular PAPTELCO reseller can only
have 10 MBPS. That is factual that is not an anecdotal. So
where do you think the subscribers will go?
MR. FRANCIS ACERO =
Yes, for the same price.
Yes, yung sinasabi mo na ito mas mabuti ito kahit hindi
sabihin na mabuti may capability ito to provide this one ito
lang ang kaya nito, di ba? Sinasabi ko na agad sa kanila.
Mineasure ko sinabi mo na ito ang kaya nyan. Nasabi mo
na. Nilabel mo na agad yan.
MR. FRANCIS ACERO =
What I am asking nga is what you measure is not just to two
variables but to five variables. Because there are other things
that go into an internet experience is not just stated. The
reason why we go through
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(cont.Mr.Acero)
that, as a consumer, you tolerate all these other ISPs is that
you believe that they can provide better service over other
aspects. So, if you are for example a PLDT and you offer
10MBPS in your reseller you offer also a 10MBPS. You should
able to meet on the same speed that you deliver. Now, of you
believe that PLDT is joking your bandwidth then that is the
time they will issue, that you should take up with PLDT. It
should not happen.
Yes, we are discussing the publication kasi yong parameters,
tapos na yon and we will not presenting the standards. So, ito
yung publication side. We are discussing that merong
concern ang resellers that they maybe prejudice with the
publication of the results etc. So, ito po ang concern nya. This
is what we are trying to address. Perhaps, what we can do is
first, dito muna sa NCR. The equipment will be in NCR, dito
muna yan and there is only one. Mahirap gamitin yan all over
the country na sabay sabay. So, perhaps, what I suggests is
kung meron man later on amendments these one to cover
yung kanilang concerns, we go out when equipment are
available na to measure throughout the country. Saka natin
iaaddress perhaps yung concern ng mga small players
outside
Metropolitan
Manila
area
kasi
NCR
muna
maumpisahan. So that we could start to release the MC and

we could start measuring and then release to within the NCR
muna in the mean time. So, we are in the concern of the
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resellers and smaller players outside the NCR. Isusunod na

lang natin later on para mapabilis na ma-promulgate yung
rules. Marami ng naghihintay kasi. So we will have to move
faster. That is a suggestion kung okay then we can move.
Iyon muna, the NCR muna wala muna all the media players
are Metro Manila so that we can compare. Mabilis nalang
icompare iyon. After all, the market is here. And of course, we
are looking at the other markets later on malapit dito kasi
nariyan yang CALABARZON area, malaki din ang market dyan
going towards Bulacan, Pampanga malaking market yan. Yes,
please?
MR. MEDEL =
I am just trying to catch up to the conversation that you are
talking. With respect to the measurements, as you know we
already have hearing last week at Congress with respect to
this. Recently, it is accepted by Cong. Yap. That he accepted
that wireless broadband, there are lot of controllables. Okay?
These composers are such as latency, jitter and packet loss.
So, how we are going now to do to measurement within those
parameters? How can move forward with those types of
parameters? I have prepared something on it. In following the
last hearing, with respect to the accepted environment which
they are already reaccepted.
For example, the time of
handset, , gadget, location with regards to indoors or

outdoors, number of subscribers in malls. So, these are all
uncontrollables. I do not think we could measure on a specific
point in time where we get a consistent measure on a given
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point A to Point B. And the next thing is that in point B, if I

may say Point A with respect to my client that I may using
where it is gonna be an Ookla, open signal, akamay, there
are all different in terms of measurement. And exacalty,
according to delap, when they offer ookla versus akamay,
there is a big difference in terms of measurements. So, we
have the so particular to take a look of what type of line that
we will be using if we are going to do testing. And on the
server side, we never know what type of server that you will
be using because for how many concurrent users that
particular server that you are going to take up is we will able
to accommodate in a certain given time. And I will take yes,
the truth a certain server has to be given in order for you to
really measure what is really true to measure because it can
be testing the web, the web server, the training servers they
will be getting a different results in a given time. So, as we
have mentioned, you have already said that there is a speed
of up to? And we have already agreed that on the past
hearing in NTC that we will only be
measuring
the
download,
upload and the volume which was already be known to the
subscribers. And especially, what are these given fact notes
that we will be interpret by the consumers? What are those?
Will it help then? How we are going to interpret them in terms
of download and upload speed? I do not think these
subscribers or consumers will be able to interpret it. That in
the consumers side in terms of publication, it will going to be
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M a y 2 6 , 2 0 1 5 / 2 : 3 0 P M | 23
harmful instead of going to be competitive in publication

environment. So, I do not think for us that it is going to be
measurement for us to measure Jitter, packet loss and
latency.
MR. FRANCIS ACERO =

Okay, just because you have a multiple variables no matter
how far or wide in those variables that will not be cannot
measure. By the way, exemption to the fact that, to the
assession that the subscribers they could not, the TelCos
cannot provide the subscribers with information of usage.
Now, but immediately, you mentioned ookla, akamay and
how the measurements vary. But clearly, regardless who
does the measurements and how they do it from abroad you
will see actually near the bottom. So, what Dir.Egay is
proposing earlier is simply do this information on not
mandatory. There is a series of test here locally and make
those tests available to the public. So, I think the bottom line
question here is would you rather have public only be see the
results from ookla and akamay? because they will keep
seeing those. So, regardless of whether the NTC comes out
with the publication or not the public will always see the
akamay and ookla results. So, in a sense, the NTC proposal
what they intend to come out with the MC is actually good
because it is our measurement so at least we have
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M a y 2 6 , 2 0 1 5 / 2 : 3 0 P M | 24
something to point to dito satin na ganito ang measurement

natin.
MR. MEDEL =
But the point is what we are saying in the public is download
and
upload speed. So happen to say this is the significant figures
for the subscribers. Let us say 100 latency? Ano ito? Dagdag
bayad ba ito o bawas bayad? So, what can you see is how
fast the downloading in a given time, the uploading, the
downloading, the streaming.

Hindi naman idodownload yun. Ang i-dodownload ay speed.
Yes? go ahead.
MR. FRANCIS ACERO =
If I were the subscriber, I think the public already know these
things. They just do not what it called yet. The biggest use
now of this wherein packet loss and jitter, number is online
gaming. So they keep on hammering that out of the public
and there will be no way to reback that.
The firm in online gaming they called it log. They do not call
it latency. They call it log, na-log ako. They have the term but
they do not know the proper term which is latency.
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M a y 2 6 , 2 0 1 5 / 2 : 3 0 P M | 25
MR. FRANCIS ACERO =

We have these commercial that are running. If there is a
serious Jitter and latency issue there, you will see it.
And
then you will be the first one to hit by this question. For us,
because we know some technical, we will know the problem
is. And you will say, all you have to do is this, is this and you
will be fine. But to them? This is the whole point of the
exercise you have to head of these questions because you
want to be literate. Right now, I have my plan and I talked to
my sister, she is in the states and he works personally. So she
kinds of used to magandang bato. And whenever I talked to
her on multiple platforms just to see to which platform
delivers the most consistent and each and every single time
even though there I pay for a speed that is theoretically
should allow me to string things up to 7Mb. kahit void
transactions lang hindi rin matapos tapos. And so the best
way if that is not really important, I will go back to voice. If
for example, I want to see my youngest, because these are
the applications that matter in the dealings in the future.
Yes, Eric?
Just a question. So it matters to them and they found out that
the Jitters is not more less in the standard perhaps they set to
themselves latency and everything. So, what will be the next
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M a y 2 6 , 2 0 1 5 / 2 : 3 0 P M | 26
measurement? Soon the company or disconnect? Or look for

another provider?
MR. FRANCIS ACERO =
Under the market, you supposed to look for another provider.
One that provides better service for you. Second, whatever

that provider offers, for example given a particular pay
system, you look for that.

But our plans are not based on Jitter, latency and other
metrics. So, our plan is based on download and upload
speeds. Okay, sige alam na naming yung Jitter, alam na
namin ang latency, okay tumawag ka sa kapatid mo sa states
then hindi kayo nagkaintindihan. So what is the value now?
What will be the use of this information? I just want to know
what the plan is.
Actually, assuming they had publish tapos si reseller A, si
TelCo B and so on parepareho sila ng connectivity in so far as
to advertise. Parepareho din ng performance in so far as
proven by publish. Pero si reseller A has better performance
in as so far as latency dahil mas maganda yung network
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M a y 2 6 , 2 0 1 5 / 2 : 3 0 P M | 27
management nila. Edi doon sya magmomove. Because

people moved based on publish speeds. Yung publish speed
nyo is 1mbps,the other one is performed giving for the same
price 2mbps, moved sila dun sa 2mbps kasi it is market. That
is how it works.
MR. WINTHROP YU =
Just to addressed this question directly. Actually, to offer
theTelCos
a
possibility
product
differentiation
or
service
differentiation. Bakit? Yung mga gamers, kahit yung mga sa

liblib na internet cafe, kahit sa pisonet alam nila yung log.
Ibig sabihin ng log, binabaril mo yung kalaban yun pala patay
na. So, they understand the principle of latency. So, how can
you repackage this? You can actually give up a very low
usage cut plan with a very low latency in otherwise mabilis
itong mag-react. Pero hindi ganon kalaki ang data usage mo.
Bakit? Gaming is actually a very low data usage sa activity.
So, you can actually device, your marketing department can
device a special plan for gamers only or yung data usage cut
ninyo ay mababa. I mean yung latency ninyo ay mabilis hindi
kayo mauunahan sa barilan. So, these are the possibilities.
Yes? Go ahead Eric.
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M a y 2 6 , 2 0 1 5 / 2 : 3 0 P M | 28
So, if that is the point, this should not be imposed. This

should be measure samin nalang. If we will used that later on
for product differentiation marketing strategy then, it is up to
us. It should not be imposed. We can market it on our own.
Wala namang standards na iseset just measure it and it will
not be
publish.
But
kung
mayroong
may
gusto,
they
can.
Halimbawa, kung gaming ka and you want to know , sige

ibibigay sayo. But it will not released. Ang ipupublish is yung
speed but all the others, hindi. If you want then you can get
information. Ganon iyon, iyon ang gating suggestion dyan.
Hindi sya ipupublish but it will be available.
MR. FRANCIS ACERO =

With all due respect, you say that is available it just means
that the newspapers will publish it. If not in newspapers then
not publish it then some blogger will get it and publish it. So,
it is better that if you will publish it with yourself it is always a
primary source not hearsay.
Just a quick comment. What we actually advocating is to
have a more transparent way of measuring things. Of course,
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M a y 2 6 , 2 0 1 5 / 2 : 3 0 P M | 29
the TelCos and ISPs do their measurements. We already know

that but we want to be able to have a measuring tool that the
regulator can use and that consumers will use as a basis.
Because as if we go the status scope, the status scope is to
disuse ookla and akamay and ganon lang talaga sya. In fact,
if you go to forums, if you visit online forums and talk about
how bad the internet is, anong sinasabi ng OFWs? Sorry,
maingay, choppy. But what is that di ba? That is Jitter, packet
loss. So, again, it would be good to really know what is
causing the problem. And in fact, in other countries, where
LIRNEasia was also provided the results of our quality of
service experience study, ang isang naging result is that the
TelCos and the regulators themselves nakikita yung problem
areas. When a subscriber says pangit ang internet, ano ba
ang ibig sabihin ng pangit? So, tiningnan nila, anong
characteristics or saang aspeto pangit. Okay naman ang
download speed, actually na-achieved ang 80% advertised
speed. Saan pangit? Nakita nila na ang pangit ay latency sa
international segment. So, that is an example of how this
measurement can be beneficial to the TelCos and ISPs also.
Yes, Roy?
ATTY. ROY IBAY =
Sir, question. We actually want to clarify even I think the NTC
mentioned the equipment will be more or less located here in
NCR. Our question is what if for example there is a
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M a y 2 6 , 2 0 1 5 / 2 : 3 0 P M | 30
complainant outside the NCR? Or in the other hand, what if

the conditions are far ideal or better in let say areas outside
the NCR? How does NTC intend to balance those factors or
conditions? For example, if there is a complainant should not
be the drive test be conducted if there is a complaint? Or in
the other hand, in other areas outside the Metro Manila? I
mean, it is clear to say that if Metro Manila more or less
would show a certain trend or standard in case the
measurement will come out. As in comparison also to the
other location outside the Metro Manila that may or may not
be equivalent. So, we will just want to raised that question to
the NTC.
The software is downloadable so that you can download
measure etc. The measurement in the NCR will be regular
measurements. But outside the Metro Manila kung may
reklamo, perhaps, the equipment may be, kasi dalawa lang
naman yan meron kasing equipment na gagamitin, may
hardware component yun. So, yun siguro yung dadalhin nun
kung may reklamo. But the equipment released dito lang sa
NCR at regular ang measurements dito. So, we will done
regularly etc.
Sir, just to raise an example. Di ba recently sa media yung
Cebu Provincial Board nagrereklamo sila? They want to have
an investigation of their own to see why their internet service
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M a y 2 6 , 2 0 1 5 / 2 : 3 0 P M | 31
daw is poor. So, if you have something like Cebu Provincial

Board trying to figure why their internet service in province is
poor then would the NTC equipment be available to them?
Kasi may official na reklamo nga Sir.
Yes, that will be done. We are hoping by next year kasi
madadagdagan sila ng equipment na bibilhin. So, kapag
nadagdagan yan then we can have this equipment station in
Cebu and other urban areas. So, iyon po ang gagawin. But
ngayon is iisa lang yan so dito lang sa NCR.
Just thinking aloud sa gaming.There is complaint in the
gaming. Is the plan considered investigating the problem of
the gamers, the requirement?
No.

Kasi we also have our Technical Working Group Meeting and
they are also asking ano bang plan kasi halimabawa yung
lowest plan then you are trying to use the gaming talaga
sigurong hindi pupwede or for other applications. Di ba? And
also yung sa Cebu di ba they are complaining about the
speed. Anong plan ba iyon? And anong application ang
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M a y 2 6 , 2 0 1 5 / 2 : 3 0 P M | 32
gagamitin nila? Kasi I think I also mentioned this before, kasi

satin din binabalik, maraming variables, you cannot please
everybody even the reseller or budget users.
Just to answer. That is why we are doing this. In methodology,
as we have mentioned in previous meetings, we will be the
first one who will oppose if the methodology not sound. That
is why we want to discuss this here. That is why we want to
measure and publish because if you just hear people or
means all the publish all the time on this ookla and whatever
testing sites are available then there is no way for you to
counter those measurements.
Yes, Pierre?
And if there is solid numbers that we can present, the poor
quality claims of anybody can be immediately dismissed.
Pero what are you talking about the poor quality? That is
what you are trying to say that you are expecting 5MBPS out
of you are paying for 2MBPS. That is not fair. So, the
presentation of measurement of actual numbers prevents the
perception that something is poor. Kasi mayroon ka ng basis
to say na you are not receiving for service, in fact, you are
receiving service of what you are paying for.
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M a y 2 6 , 2 0 1 5 / 2 : 3 0 P M | 33
Well, all of the decision should be done by the Commission.

The software is downloadable, so any who wants to measure
pwede nyang i-download iyon.
MR. FRANCIS ACERO =
To answer the point which is sometimes it shows unfair usage
in some variables that is the status for now na the
measurements are already done and there is no control over
all the variables because there is no methodology. If you are
going to measure down to the resellers they are going to
measure their service using ookla with five other people
using the internet and probably while downloading. It is not
going to be fair and then you are always going to get this
complaints and if others or some bloggers or posts also using
the ookla that the big companies are offering this too much
performance. You are just going to moved and there is going
to be no way to repack those things.
MR. MEDEL RAMIREZ =
Just following your statement because we really do not want
the controllables that is why we, TelCos, say that it is up to
service. Let say we want to move to another service then we
do have some plans. It is up to you choose from. The point is
what we advertise is up to and we were going to be putting
our balls up to that ball. As you can see we are now again
mentioning the uncontrollable. We are trying to do some
methodology which is uncontrollable.
MR. FRANCIS ACERO =
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M a y 2 6 , 2 0 1 5 / 2 : 3 0 P M | 34
We are already done in the methodology. The thing is let us

look at what is going to happen if we do not agree on this
methodology. What is going to happen is that the people will
keep on publishing their results, fair or unfair.
MR. MEDEL RAMIREZ =
But the point is, it is clear to the DTI that we are not falsely
advertising the service.
MR. FRANCIS ACERO =

We are not going to falsely advertising now. All that we want
to do is have the market decide where to go. If they believe
nga na if they have to get that better service then they
should stop complaining about how bandwidth service and
realize that that is what they pay for. Ganon lang iyon.
When the equipment is available dito then the Commission
will perhaps request you including the consumer group sit
down with our staff that will do the measurements and
discuss para there is only one method etc. where everybody
agrees na ito ang direction nya etc. Para there will be no
issues later on na nung ginawa ito wala ako noon.
One quick point. These measurements are not unique to us.
So much countries
are doing this for a long time. I can
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M a y 2 6 , 2 0 1 5 / 2 : 3 0 P M | 35
provide you of the list of those countries and what their

methodologies are and what their parameters are. So, this is
not that we are trying to impose what we just want measure.
Para may benchmark tayong local. So, this is not something
na parang you are doing this for TelCos and ISPs tapos were
climb, no. There are so many methodologies out there and
regulators have initiated this quality service management
and some have even provided through the regulator yung
software and web based tool. So this is not something new. It
is global practice and if we are worried about all these
uncontrollable variables we can always look at what the other
countries have been doing not necessarily copy them but
paano ba nila inaddress yung controllable variables na iyan.
Hindi kasi sya imposible, Sir. In fact, the reason why as the
LIRNEasia recommended, if you conduct the measurements
you conduct based on the peak and off-peak hour kasi if you
have a data set large enough it will actually addressed
anomalies in your data. So, you do would not have, let say
100 subscribers testing the internet when it is raining. You
would not have that. Kasi sa methodology, we will be very
specific about uncontrollable variables, about when to
conduct the test and how and who will conduct the test and
how to determine the anomalies. Kasi there is way, it is a
scientific method. We actually just want to be more scientific
about how to characterize the Philippine internet because
that is actually right now. When you say Philippine internet
people will just say, It really sucks.That is it, so what does it
mean? Ako, as a researcher, that is actually my personal
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M a y 2 6 , 2 0 1 5 / 2 : 3 0 P M | 36
interest in this exercise. Whenever I talked to someone who

asked me, Bakit ba ang pangit ng internet? Ano ang
isasagot ko sa kanya? My family members asked me not all
the time because they think I would know better. What do I
presented them was I tried to present them what LIRNEasia
has been doing. Some of them understand fully, some of
them do not. But the thing is we have evidence to prove that.
MR. MEDEL RAMIREZ =
So, the point is when you turned your relatives what your
respond is because the latency is this much, the back lash is
this much. Do you think they understand that? Those
parameters? And you are trying to tell them?
Sir, yes, they do because if you reached a certain educational
level, I think most of us will understand. You can actually put
in lay mans term. Pero ako nga, if you asked me personally I
do not think the consumers will really mean to know the
technical details. They just need to put a label on those
problems, so they put no, bakit ganon ang internet nila.

Okay, so mukang na-exaust tayo don sa point na iyon. Any
other comment on that issue? Publication ito. Yes, please?
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M a y 2 6 , 2 0 1 5 / 2 : 3 0 P M | 37
MS. MARIA ALELIE GERMAN =

Good afternoon everyone. I am Alelie German from DOJ.
Given that ISPs agreed to be measure solely on speed and
volume, it is okay, but this should preclude the NTC as the
regulator to measure other parameters. With regard to
publication, okay, ISPs can say na NTC should not publish but
regardless there will be other platforms and channel while
these results can publish. Like for instance, DOJ, can come up
with market study on telecommunications and we can
request data from NTC including all of the measurements on
Jitter, packet loss and such and we can publish that and we
can inform the public. Dapat mawala yung fear sa ISPs
because if you are really performing, walang danger.
Siguro, kung i-pupublish mo siguro dapat generalize kasi ang
fear nila ay the companies are identified. Siguro what we can
do is when you publish, generalize sya walang mention of
this and that tulad din ng ookla. Mayroong sinasabi na this is
the average speed, NCR, it is general. This is the average
measure
of
latency
etc.,
ganon,
without
mentioning.
Naintindihan ko yung concern nila kasi nga the companies

are identified etc. So, yun ang concern nya. But if we publish
it without the names of the company, that would not
prejudice anybody.
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M a y 2 6 , 2 0 1 5 / 2 : 3 0 P M | 38
Thank you, Dir. Egay, for mentioning that. Just a short

reaction. We are not living in the ideal world and it is a
problem. Only, kapag puro reseller lang ang nag-cocompete
doon sa lugar, that is fine. That is the source of power
objection. Sabi mga, in can be use by any marketing people
that will be prejudicial to other carrier. But if the NTC cannot
do that without means, you want to measure, for example,
even siguro per province without mentioning the names so
that you do not have an idea.
And the results, kasi by company yan, we will give the results
to dun sa kumapanya mismo and then ito yung result, ito
yung test namin para sayo. But when you publish the result,
generalize sya.
I think you mentioned, Dir.Egay, about on off-com dun sa
ginagawa nila. May problema yung ISPs or carriers to to
cumpolse their attention to correct kasi mayroon silang
pinirmahan di ba? Yung sinasabing self-regulation, mayroon
silang pinirmahan na they will have to provide this quality of
service. And there is a problem, ano ang unang-unang
gagawin? Sige, wag muna pagbayarin yung subscribers pag
na-prove mo na may problema talaga sya. Tapos i-cocorect
yun until such time kasi may commitment sya. I think
maganda yun, may concern sa isang particular na carrier.
Kasi bottomline ano bang gusto natin? To improve the
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M a y 2 6 , 2 0 1 5 / 2 : 3 0 P M | 39
services. We have these measurements, we need to improve

this. Kasi samin pabor yunb , dadami ang subscribers
naming. Pero yung process lang, that will be prejudicial to us
particularly kasi yun yung objection namin.
If we are going to publish without any move from the ISPs,
how will the public make an informed choice about which ISPs
is better in a particular area?
Well, yun din yung back lush nya kasi marketing kasi ito. Ang
ibig sabihin kasi nyan is when you publish nariyan ang mga
pangalan etc. although they survey based on actual test, yun
nga lang it may be due us kasi marketing yan yung sales etc.
So, ito yung medyo iniiwasan din na situation. Tama kayo,
people has the choice kung san sila etc. So, ito kasi yung
ibabalanse natin on what we are going to do to balance this
interest, interest ng consumers. So, medyo mahirap hanapan
ng middle ground kung paano ko gagawin iyon.
Sir, lalo na kung network access providers naman sila.
Meaning, the TelCos who actually owned the infrastructure
and also provide the last mile. Di ba nga sabi natin we cannot
compare apples with oranges. But in this case, these are all
TelCos and I do not see the value in publishing tapos hindi
ilalagay kung sino yung ganong may performance. Because
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M a y 2 6 , 2 0 1 5 / 2 : 3 0 P M | 40
the main reason you want to publish, yung publication po

mismo, is to help the public make an informed choice as to
whom the better ISP is in a particular area.
For correction. In fact, while you mentioned earlier we just
want to have the basis when they ask bakit pangit ang
internet sa Pilipinas? You should be able to answer that, sabi
mo nga kanina and that will answer it. Because if you
mentioned the names of the companies, you are practically
suggesting a fine line interfering with the market forces and
regulation. Ang sinasabi mo is teka dito ka. You say kapag
pangit nag internet service, bakit? We need to have the form
of
measurements
or
at
least
mayroon
tayong
pinagbabasehan. That is how we understand it.

MR. FRANCIS ACERO =
I think you are more appropriate with industry analog. In a
case where people have soda, may Coke, may Pepsi. Let say
FDA comes in and publish how much. The totality of internet
service does not just depend on the speed. Speed is one part
but service is also another part. This is just, when we publish
this results, its just the speed, its just they experience at the
computer. But let say attention to detail, attention to the
consumer that place as a consumer to meet at least a bigger
part in my selection of an ISP as oppose to their speed. If I
have an ISP who works with me to get better speed that is
better for me as a consumer. But just to put the data out
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M a y 2 6 , 2 0 1 5 / 2 : 3 0 P M | 41
there because it is agnostic it is not in favor of anyone. Again,

what will be the alternative be? The alternative is being
called cable using ookla to judge the resellers. That is far
more unfair.
I think progressive naman yung sinabi ni Dir. Cabarios na
sinasabing i-pupublish without any means then they will be
inform, the specific company, if they are not in accordance or
they are not performing in what is expected with them. Is it
not that we are all for this? To improve the service? Or do you
want to suggest to public to which particular company they
want to choose?
MR. FRANCIS ACERO =
No,
there
is
no
suggestion.
Measurements
are
measurements, metrics are metrics.

We have to go to other industries you are talking about Soda
industry, so let us look at what the other industry are doing.
For example, they go for the final details on what course they
can offer or what they publish? O di ba sila mismo ang
naglalagay sa kanilang brochure. Yung DTI ba nilalagay kung
anong klaseng makina pinapublish before you can buy a car?
Which publication do we go through?
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M a y 2 6 , 2 0 1 5 / 2 : 3 0 P M | 42

Actually sa DTI, if you compare brand X, Y, Z, you cannot
name your competitors na Pepsi, Coke, etc.
Exactly, kaya nga pinagbawal yung indorsement na ganon.
And then you blind fold and test, kung nakuha and then yun
yung i-rereveal mo but you do not reveal the brand of those
matters.
MR. FRANCIS ACERO =
But that is on marketing. This is agnostic.
That is advertising.
MR. FRANCIS ACERO =
Yes, that is advertising. This is agnostic. This is just the
regulator publishing the results of these tests.
But those informations will be use also. Those informations
canbe use against a particular company. Kaya nga yung
advertisements natin ay brand X lang hindi katulad sa staes
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M a y 2 6 , 2 0 1 5 / 2 : 3 0 P M | 43
na siguro may specific na satin hindi. Sa toothpaste ay brand

X. Hindi naman ilalagay. Kung ilalagay nyo yun parang
sinasabi nyong Coke versus Pepsi. Kasi gagamitin nila yun,
you cannot prevent those marketing people to use those
informations.
MR. FRANCIS ACERO =
Siguro, the more appropriate example will be you brought a
car at some point there are statistics will come out. They are
the consumers, we are already going to get a credit rating.
We are going to get the credit course.
Well, this is the issue now. Wala pang middle ground dito, if
none, we can describe here the middle ground. This will be
up to the Commission to decide. Meron tayong dalawang
positions dito; one is publish without the names of the
providers and publish with the names of the provider of the
service. May advantage at disadvantages. So, perhaps, we
will leave in that way and we will let the Commission consider
deciding kung saan doon. Kasi mukang walang middle
ground. Two options yan so tingnan natin kung saan dun ang
idodopt ng Commission.
Dapat po sa Methodology, when you do the test dapat
agnostic ang brand. Because if later on you have the data of
the company and you will not release and high government
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M a y 2 6 , 2 0 1 5 / 2 : 3 0 P M | 44
offices then akin ayaw mo irelease then kukunin ko yan. So

dapat from the source agnostic na yun.
Yes, Grace?
Just put it on record. This will be the first time that there will
be measurement for internet service na anonymous in any
country, just put it on record.
That will be the decision of Commission but we do not know
yet kung ano decision ng Commission because mukang wala
tayong middle ground. You just leave the matter to the
Commission. So, ayun nga na-take up natin yung publication
side, this is a difficult issue pero malinaw linaw na din that
there will be two option that the Commission will take. So, all
the others ay madali na lang yung ibang issues. Yung setting
standards, tapos na tayo, we agree na hindi natin ilalalagay,
publication, ito na yung issue and then the other issue ay
madali na lang.
Perhaps, what we can do is run through
this one ipeprepare naming based on the discussion now

yung modification dito sa draft kasi tatanggalin na yung
standards dito sa draft and then we will circulate and then we
run through and then yung hindi pinagaareehan gayon yun
yung lalagyan natin ng bracket for the Commissions side. So,
we will meet perhaps, para mabilis ay next week na. We
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M a y 2 6 , 2 0 1 5 / 2 : 3 0 P M | 45
prepare this based on todays discussion. Perhaps, we will

meet on Thursday next week so that we will have one week
to prepare. We will give you the copy of this siguro Tuesday
next week. E-mail po sa inyo. And the notice, buo na iyon,
hindi na TWG, those will be entire na, the entire TWG na buo
na and then after that present it to the Commission for their
decision. Whatever the decision of the Commission ay iyon
na ang ipupubilc hearing. Kung magbago pa isip based on
public hearing, kung magkaroon pa ng middle grounds during
that public hearing that will be define. So, the notice will be
send to you by e-mail yong meeting Thursday next week,
also copies of this one will be modified. So, other comments
pa? Again, thank you very much for coming over.
It
has been very fruitful malapit na matapos ito. Thank you very
much.
Transcribed to the best of my ability.
ELIZABETH
G. LAMADRID
Stenograpic Reporter I

NTC TWG Meeting On Broadband Speeds Dated 5.26.15

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TWG Meeting on Minimum Broadband Speed

REPUBLIC OF THE PHILIPPINES

TWG Meeting on Minimum Broadband Speed

DIR. EDGARDO CABARIOS =

Democracy.net.ph. along with my collegue Atty. Francis

MS. MARY GRACE SANTOS =

the submission of the LIRNEasia na nareceived namin

I think that is helpful din sa inyo. Just to my expeience with

DIR. EDGARDO CABARIOS =

ng standards ay i-didiscusss pa natin

and how will the result be released paguusapan pa po

the report can

have so many interpretations kasi mas mahirap. So let us

mineasure din nya yun.

notary post a complaint that there was a packet loss. Then

MS. MARY GRACE SANTOS =

Of course, the suggestion is that we measure, we set

So, perhaps, we can stand there. Dun muna tayo,

is 48 to 56 MBPS tapos 80% reliability. When I picked up a

complying with that. Are we fine with that? Dapat continue

compared. As we have mentioned in the past, before we

terrestrial bandwidth, the available bandwidth that you can

So, I think we have to qualify that we

cannot just upset to what we allocate compared to other

DIR. EDGARDO CABARIOS =

speeds. That is why we believe that measurement and

MS. MARY GRACE SANTOS =

methodology we can agree on to present that this is

measuring typical and average speeds across the country

own standards without being compared unnecessarily and

alter on we can set standards then

essentially yung draft na pinresent ng democracy.net.

the standards. But

measurements of the publication siguro pwede na iyon?

DIR. EDGARDO CABARIOS =

instance, yung 3.6 ni Ookla ay baka 3.6 because saka lang

they only measure when they fee

or they perceived that something is wrong which is wrong

MR. ENRICO DELOS REYES =

getting into our areas. So, what happens? I do not think

DIR. EDGARDO CABARIOS =

MR. FRANCIS ACERO =

meet an inform choice. If the market is kept in dark above,

provider, ito yung

secondary. Doon pa lang, kinaclasify mo na lang kami para

class citizen at ito ang first class citizen. We were not

are comeoting across the ball. Hindi naman natin kinukuha

ito class A to at ito class B? icaclasify mo na din di ba?

matter where you go the experience is going to be the

that, i-pupublish mo then i-memeasure mo, then

ipupublish tapos sasabihin mo dito ka nalang. Why you do

I understand kasi when you publish, comparative kasi yan

parepareho ng standing. Perhaps, you can compare the big

MR. ENRICO DELOS REYES =

Question, if I am getting 10MBPS from PLDT and they owned

maumpisahan. So that we could start to release the MC and

resellers and smaller players outside the NCR. Isusunod na

For example, the time of

handset, , gadget, location with regards to indoors or

point A to Point B. And the next thing is that in point B, if I

harmful instead of going to be competitive in publication

MR. FRANCIS ACERO =