PageContinuation of Public Consultation on Broadband SpeedApril 23, 2015/2PM | 36

REPUBLIC OF THE PHILIPPINESNATIONAL TELECOMMUNICATIONS COMMISSIONQuezon 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. Right now, he was in Malacaang. We can continue our discussion last time. I think may kopya na po ang bawat isa. We can continue our discussion with this summary of 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 received an e-mail yesterday from, I would assume from CCAD sending us a revised updated draft. So, we just want to put

(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 the participants of the previous technical 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 I speak? I am Engr. Pierre Cantara,PECE. I am one of the co-founders 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 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 one. But it is up to the NTC whether or not to. ATTY ROY IBAY = 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 a need to include the Minimum Standards. What we read upon is Number 1 on the past meeting is that we need to empower the 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 value-added service. So, if I adequately cover what was discussed previously, we also mentioned that similar to the broadcasters, we would like also to address the self-regulation for the ISP Providers. In a sense that we believed that the worst penalty that the service provider 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 are 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 =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, 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 =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 like video, live streaming, MOOCs, Massive Online 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 young bandwidth kasi magreresend and then service time-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 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. The location of point B shall be (1) within 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, 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 hadbeen discussed. We were simply discussed as options but after meeting with the group you were more confident that you would be more available if you will test us within in the full context 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 servers which are created by the NTC. Initially, there is one control point at NTC but Ms. Grace of LIRNE Asia suggested that there will be multiple points in across the 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 that comes outside your network. But from within 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 I only getting ninety pesos worth, siguro naman it is worth returning the ten pesos to you. So that is where we coming from. In Annex F, you will find the propulsive of the citizens charter by which the quality of service complaint will be handled and mediated by the NTC. And Annex G, it is the service provider who has complaint. Especially if the service provider A, 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 the TelCo being complaint about, should not also be 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 TelCos. Hence, the proposed processes of Annex F and 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 network and conversely outside of the land of the Telco and outside of the network. I 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. But I guess this was just assigned 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 the past two meetings, we have discussions with DOJ, 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 certain parameters, how to measure in order to comply. We are already actually gone on 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 to the DTI and DOJ to have measure. So, as we said, internet should be a value-added service. It should be deregulatedbut 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 alreadypreviously discussed and there was submittedposition 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 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 incorporated their statement like best effort, that the minimum 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 =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 whatever is necessary in order to come up with the proposed MC on Minimum Broadband Speed. So, we will hear 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 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 the objective is empowering the public on their regulatory

(cont. Mr.Briones)consumers, I think this technical parameter metrics are already 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 download is relevant, upload is not, latency is not, Jitter 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 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 sorelevant, again, Latency, Jitter and packet loss are very relevant. This is why you cannot just be in volume, you cannot just be upload 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: training, conversation, interactive and the background. 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 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 is already an enough measure download, upload speed plus the volume per plan doing on what we offer since it is 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 =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. Where is the cab? Probably if the cab is here in the area wherein traffic and there so many people using the internet? That 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 user experience. That is why for wireless, for mobile and fixed internet there are also certain variables that is why were saying that is why we are discussing now. Maybe we could also be proper now to schedule those certain field tests to be able to really 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 speed and download volume metrics are to be considered. 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 us gain developers from developing products which 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 latency and minimal pocket loss and this does not only on gain developing 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 being absolute like tangent and expensive.

ENGR. PIERRE TITO GALLA =Yes, you are right. You are talking about the IDVTO can we recognize 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 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 bandwidth for a free wifi that a hundred consumers will be able to used. May consumers in carinderia not been able to serve toward subscribed to residential. ENGR. SUSANA PANES =Excuse me lang po. Atty. Roy, I understand. Anyway, I just like to remind the group that hopefully we can come up with the 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 are going to consider the technical parameters before 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 residential or to small base but they took it up in internet caf which is unfair also. There are consumers naman na residential there are willing to pay sa service and they can defied their connection which is high. So, the higher CIR, the more stable it is. That is why we are saying if you have 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 indexes and then they rate us excellent or fair or whatever. We are not something like that po. But in the 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 business already. Yung Jitter, Packet Loss and latency po, it is our best interest po na to give this figure within acceptable limits kasi when you are there kahit sabihin namin na we are delivering the 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 subscriber says, goodbye I am leaving you, wala na po kaming 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 should be better if they know. Let say 3.6 rating which is very and so 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 should be able to contain vanity, of course not. I think we will just submit 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 in whatever quality whatever we discussed today or 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 = 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 that we are discussing for the past hour, those are the readily 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 consideration of the Commission. ENGR. PIERRE TITO GALLA =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 document. That I do not know if it happen or not. Based on the standards for the service offerings that are in the Annex B of the new draft, this is what we took together. We do not 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 why you have technological minimum speed is because service providers typically put them all together to trans the range. What happen is if I can go back to this one, from 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 declared standards by edge those for the building edge. Edge revolution type one the max speed of the download is 1.2 MBPS. I do not know if they are 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 have that. The mobile internet basically starts with 13MBPS. In the 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 LTE4x4. So we do not know which one we are using in 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 service. So that we do not want our achievements in the past just in the few 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 what you are implementing but there are public documents from the ITU that declare all this. So, we put this here. You are correct 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 NTCs publication of your Jitter or other parameters? 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 support consumer awareness and their right to what they are 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 = 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 speed. No, you cannot advertise a minimum speed but on our declaration, we are compliant of 07-07-2011. But this is different. You want to avail with 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 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, 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 are all considered. So, other comments from Globe? MR. MEDEL RAMIREZ = Nothing, your honor.

ENGR. SUSANA PANES =From PAPTELCO? MS. MARIBETH SANTOS = 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.

Transcribed to the best of my ability.

ELIZABETH G. LAMADRID