Unofficial Video Rebuttal to CRTC 2011-77

Or “billing by the byte might be illegal”

Also available in written form on The Mark News.

This is an unofficial video rebuttal to Telecom Notice of Consultation CRTC 2011-77 – Review of billing practices for wholesale residential high-speed access services. But first, you might want to find out Why I’m Not Participating in the current round of hearings.

This unofficial rebuttal is what I would have presented to the CRTC proceeding if I were capable of doing so. Be advised however that this practice video might be a bit rough around the edges. But that’s okay since one day, I will have to do a presentation in front of the Commission, and these videos are excellent training tools.

Yes, the video does include new ways of seeing certain elements of our technology that may appear a bit unusual at first, but do consider the possibilities.

And to better understand the full implications of Usage-Based Billing on our society, please watch the video that officially launched this Web site and my personal campaign against all volume based Internet billing schemes.

For reference purposes, here is the CRTC rebuttal text. However, I wouldn’t advise anyone to actually read it at the CRTC proceeding.

Unofficial Video Rebuttal
to CRTC 2011-77

  1. Hello, I’m François Caron, and I’ve been following the CRTC Usage-based Billing and Aggregated Volume Pricing proceedings for a few years now. And I must say that I’m extremely disappointed that such a deceptive and potentially fraudulent concept for an Internet billing scheme has survived for this long.

  2. Despite not having made a presentation in front of the CRTC, I still felt the need to record a video rebuttal for the current proceeding, and possibly help clarify a few of the many misconceptions that have been disseminated over the years, and which I regret to say the intervenors opposed to “billing by the byte” have failed to thoroughly denounce during their many appearances in front of the Commission.

  3. First. Data doesn’t exist.

  4. Unlike other products we buy every day, data is neither a manufactured product, nor a consumable product. Data is nothing more than a series of electrical signals travelling through a bunch of wires over short and long distances. The presence or absence of these signals barely has an impact on the networking equipment.

  5. The equipment’s operating environment however has a much greater impact on the operating costs than the data flowing through it, especially with outdoor equipment where the elements have a real impact on operating costs. Data volume has such a low impact on networking equipment that it can be considered as non-existent.

  6. Second. Congestion doesn’t exist.

  7. What would happen if demand for Internet services reached the maximum capacity of a provider’s network? The networking equipment would simply not go any faster.

  8. This is why Internet congestion doesn’t really exist. Congestion implies that the “pipes are dirty” and you need to “clean them up.” But computer networks don’t work this day. What happens to a network pushed to its limits is that it just keep pushing data through as fast as it can, with any extra data packets wanting to go through now required to wait their turn.

  9. If the network’s speed usage patterns have been properly calculated and configured into the system, the network’s actual traffic degradation could be so low that very few people will every notice that anything is wrong.

  10. Third. Billing by the byte is unreliable.

  11. It’s reasonable to believe that if independent ISPs are charged AVP fees by the large telephone and cable companies, the ISPs will most likely pass those costs to their customers in the form of UBB fees. And this is what might happen.

  12. At the beginning of each billing cycle, everyone overuses their Internet connection to take advantage of their available monthly caps. The network maxes out, and everyone’s Internet experience is severely degraded.

  13. Now it’s the end of the billing cycle, and everyone rushes to consume what’s left of their monthly caps. The network maxes out once again, and everyone’s Internet experience is severely degraded.

  14. Usage-based Billing could make it next to impossible to properly configure and manage a data network due to these wild fluctuations in data usage. But on a speed-based network, there is no need for anyone to binge on huge volumes of data during certain times of the month. Everyone uses the Internet at their own pace with no worries about caps, resulting in comprehensive usage patterns suitable for most network management requirements.

  15. In fact, speed based measurements are so reliable that they can also be used for billing purposes, and for calculating the true operating costs of networking service. Volume based measurements are useless for these critical business objectives.

  16. Fourth. Billing by the byte might be illegal.

  17. I’ve contacted Measurement Canada a couple of years ago about the use of bytes as a unit of measurement for the purpose of trade. I was informed that bytes aren’t in Measurement Canada’s list of approved units of measurement, and that they do not regulate the use of bytes for the purpose of trade.

  18. But considering the huge revenue streams that would be generated through the implementation of faulty UBB or AVP based pricing schemes — on top of the existing subscription fees — it’s not impossible that this large scale use of an unregulated and highly inaccurate unit of measurement could be considered as fraud. The Commission might want to look into this.

  19. These are just a few examples of what’s wrong with Usage-based Billing of Internet services. It is a highly deceptive and potentially destructive billing scheme that should have never been considered or even taken seriously in the first place.

  20. If you would like more information on how Usage-based Billing can be used not only to empty our wallets, but also to compromise our freedoms and our democracy, please visit my Web site at The UBB Deception dot ca .

  21. I’m François Caron, thank you for watching.

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