Today is the deadline for submitting comments to the CRTC on the proposed tariff increases for Usage Based Billing. These are the comments I submitted:

I am opposed to the current Usage Based Billing proposal.

 

The cost of Telecom in Canada is already among of the highest in the world. Allowing Usage Based Billing will only increase that cost for both consumers and business, especially the third-party Internet providers. Canadian-based business is already looking for foreign ownership for the telecom sector; don’t price those Canadian businesses out of the market by increasing the rates for telecom services.

 

I understand that the carriers feel the need to increase the capacity of their infrastructure, but they have provided no evidence of the current capacities or bandwidth usage, making me wonder if these extra charges are justified. I do believe that billing based on usage (akin to electricity or water use) is a fair way to charge for Internet use, but only if it is the only charge. Carriers must not charge for bandwidth AND set bandwidth caps with overage fees. It cost no more to deliver the first gigabyte in a billing cycle than it costs to deliver the 60th.

 

Also, there must be a clear separation of bandwidth providers and content providers. To the consumer, it certainly seems like the carriers are raising the cost of providing streaming media such as NetFlix, while at the same time introducing such services themselves. It certainly gives the perception of anti-competitive billing, trying to force NetFlix out of the market by making it too expensive.

 

–Bob Jonkman
6 James St.
Elmira ON Canada
+1-519-635-9413

(CRTC Comment Reference number: 139217 )

Feel free to use any of these comments in your own submission!

A few days after I posted my Canadian Copyright Consultation submission I received some e-mail feedback from Robert:

Hello Bob Jonkman,

I’ve read most of your input about U.B.B. and found it surprising that you, a software developer of all people, would oppose the U.B.B. ruling.

I’ve read your blog: [link]

While reading, I’ve stumbled upon this:

“I favour shorter copyright terms, no criminalisation for
non-commercial infringement, no criminalisation of circumvention of technical protection measures, and no media levies.”

Now, as a software developer, someone who uses copyright and programs protections, to what extent that you favour the above sentence?

My reply:

Hi Robert: As a software developer I am especially concerned with Usage Based Billing. I need to access online documentation, I use forums, blogs, and mailing lists to interact with other developers and clients, I run servers both for production and to test Web applications. But what will affect me most is downloading programs, software tools, and complete CD and DVD images with operating system distributions. All this activity puts me well beyond Bell’s proposed limit of 60 GBytes per month. Connection fees will nearly double for me under UBB, and I get nothing for it.

The statement on copyright, that I favour shorter terms and no technical protection measures are completely consistent with my position as a developer. In the first place, I need to use materials that are either freely available, or purchased from commercial sources. Bad licenses that use copyright law to restrict my use of material that I’ve legally purchased are harmful to me. For example, I want to write an addressbook program for a smart phone. But the vendor has restricted my ability to read the phone’s memory, and claims it is infringing that vendor’s copyright for me to reverse engineer the phone. This is harmful to me (I can’t do the work), it is harmful to my client (who can’t get the software he needs), and it is actually harmful to the phone vendor (because neither I or my client will ever buy that phone again).

Reduced copyright and fewer technical protection measures are also good for me, because more people will be able to make use of my software, leading to more work for me. Note that I never use “programs protections” for my software — it’s just not good for business. And while my software is copyrighted, I still grant licenses under GPL to make copies, requiring only that those who use my code give me attribution, and that their code uses the same license.

I don’t sell software, by the way. People pay me to write software. The software that gets written either belongs to the client (“work for hire”, so the client has the copyright), or I retain copyright and release the code under GPL.

Some of the submissions are now posted online. Alarmingly, many of the submissions I read online are not on the site. Hopefully the immense backlog has merely delayed the Copyright Consultation folks, and they’ll appear soon.

[Added 8 October 2009: It seems my copyright submission was posted on the Copyright Consultations web site on 2 October 2009]

Even if you didn’t make a submission, you can still write to your MP and the Honourable Minister of Canadian Heritage, James Moore and the Honourable Minister of Industry, Tony Clement to let them know your views.

You can contact me too. Post a comment, or send me e-mail.

–Bob.

The CRTC approved Bell’s request to charge the customers of third-party ISPs “Usage Based Billing”, to take effect in 90 days (November 2009).

There’s much discussion on DSL Reports. Rocky Gaudrault, the president of Teksavvy ISP, weighs in with some advice: We’ll all need to make a concerted effort to curb our downloading to ensure we don’t give a dime more to Bell than we need to. We all know this is a cash grab and anti-competitive tactic […]

Teksavvy offers a Premium package for $29.95 with $0.25/GiByte over 200 GiBytes, and an Unlimited package for $39.95, but with the new rates Bell won’t allow Teksavvy to offer an Unlimited package. Customers who use more than 60 GiBytes of bandwidth would be charged an extra $22.50 a month. For Teksavvy’s Premium customers, this is nearly double the current price. Customers who use more than 300 GiBytes in month would be charged an additional $0.75/GiByte. For that extra money you don’t get faster speeds than today. For that extra money you don’t get more downloads than today. For that extra money you don’t get a higher quality Internet. And that extra money goes to Bell, not Teksavvy.

Image from the OpenOffice spreadsheet Teksavvy possible UBB pricing.

Disclaimer: This is presented strictly as a comparison between what Teksavvy offers today and what might be the costs after UBB is implemented. This is sheer speculation; there has been no contact with Teksavvy staff on this.

60 GiBytes isn’t much, today:

• 1 GiByte is about 300 average Flickr photos.
• 1 GiByte is about 3 hours of watching YouTube videos — if you watch an hour a day you’ll use about 10 GiBytes/month.
• Using Bittorrent to download Ubuntu (or a movie) uses about 1.5 GiBytes.
• Downloading one season of a TV show is about 16 GiBytes.
• Downloading one High-Definition movie is about 40 GiBytes.

Remember that this is charged both coming and going, so you’ll be paying for all the spam that arrives in your mailbox, all the ads on websites, all the automatic Windows updates.

Customers who only use e-mail and do a bit of Web surfing probably won’t be affected by the rate increase. But anyone who uses the Internet more than casually will be paying more.

Even worse are the “Chilling Effects” – who’s going to develop new cool Web 2.0 applications if they’re constantly watching the meter to ensure they don’t exceed the 60 GiByte cap? Who’s going to sign up for online video services if the movies exceed the cap?

Canada has certainly fallen behind the technology curve. Usage Based Billing puts Canada in an even worse position than the OECD reported in 2008.

Image from the Excel spreadsheet Average broadband monthly price per advertised Mbit/s, by country, USD PPP (Oct. 2008) located at the OECD Broadband Portal.

If you want to protest this, submit a complaint to the CRTC.
For the type of application select Tariff, and as a subject, use File Number # 8740-B2-200904989 – Bell Canada – TN 7181. Thanx to Antonio Cangiano for these instructions!

I sent them this complaint:

I was disappointed to learn that the CRTC has approved Bell’s request to charge Usage Based Billing on connections for independent resellers, despite the CRTC’s own admission that most submissions from Canadians are opposed to such a tariff.

Usage Based Billing adds a significant cost to Internet services supplied by independent operators, reducing their ability to differentiate based on bandwidth and price. Worse, Bell’s proposed rates to its own customers appear to be less than what it is charging to independent ISPs. The obvious conclusion is that Bell is trying to eliminate its competition.

Recent reports on global bandwidth have already placed Canada next-to-last in cost per megabyte of bandwidth. This latest tariff will only increase prices for consumers, without providing any increase in service. Canada will surely be in absolute last place globally when the next report is issued.

The CRTC is mandated to provide telecom regulation to benefit Canadians. With this tariff, the only Canadians to benefit are Bell shareholders.

–Bob.