Thank you, Mr. Chairman.
I am a self-employed Canadian. Unlike the guys with big business, I'm as small as it can get, but I'm affected by all of this, which is why I'm here.
The UBB presented by Bell Canada is not about the user-pay model; it's really about controlling adoption of new applications. Right now you're seeing early adopters, and those are the small statistics we are seeing from Bell, but Bell wants to prevent that from spreading.
The regulatory symmetry that Bell has been talking about and that the CRTC has accepted prevents choice. Without choice, people can't choose another ISP, because they're all going to be the same. That's a very important aspect that needs to be dealt with.
As Mr. Stein said, they're not based on cost. They were asked during the proceedings to justify this. They said they would not go on a cost basis. They're purely arbitrary rates. I don't think anyone in this country can justify arbitrary rates that have to fit with subsection 27(1) of the Telecommunications Act, which says that every rate has to be fair and reasonable. We can't measure that it they're arbitrary.
More importantly, they're designed to be punitive rates. The word “punitive” was used in the proceedings. In one of the early cable filings back in 2000, they admitted that part of the goal was to slow their investment in capacity because it would slow the growth in demand. That's a question the nation needs to ask.
The rates set by Bell are also not relative to congestion. Bell has argued that this is purely a congestion issue, but they actually charge more for people who have lower speeds, and these lower speeds generate less congestion. So it should be the reverse. Questions need to be asked. This was approved by the CRTC, but we don't know why.
The GAS rates, as they now stand, before UBB, are already profitable to Bell. They're not fixed rates. They have variable components, and I will go through them next. So the whole basis of Bell's argument falls.
On the next page of my brief I have a graph that shows the architecture of the GAS versus Bell's retail and IPTV. The GAS shares very little with the Bell retail ISP business. They're really two separate blocks. They only share the last mile aggregation, and that last mile aggregation is a raw data pipe that has no ISP features in it--none whatsoever. It's a raw data pipe. The regulation should be limited to that aspect only.
I also show the scope of the regulation beyond. When you introduce UBB, you put a regulatory scope that goes from the residence all the way to the connection to the Internet, which GAS does not provide at all. That has to be said. It has to be repeated.
First of all, it's not a resale service. We've heard the word “resale” used even by the chairman of the CRTC. It's not a resale. What they're offering has nothing in common with Bell Sympatico, or whatever it's called this week.
Applying symmetrical measures for services that are different makes no sense. There should be no aspect of an ISP retail service that should be applied to the GAS rate, because that rate is not an ISP service. So symmetry for those two services makes no sense.
In terms of GAS, we often hear Bell say that GAS is a fixed rate. GAS has two components: the GAS component, which is a fixed rate; and the AHSSPI component, which is a variable rate. It's capacity based. The more users you have, the more AHSSPI capacity you buy. The more AHSSPI capacity you buy, the more you can put through. If your users are more hungry, then you buy more AHSSPI.
The best analogy for this is the restaurant business. There is a lettuce wholesaler, and there is a fancy restaurant that buys a little bit of lettuce and an all-you-can-eat buffet that buys a lot. Nobody subsidizes anyone. They all buy their lettuce at the same price and everybody makes a profit. The buffet has a business model that it can work with and be profitable, and the high-end restaurant will make some money as well.
In closing, on the following pages of my brief, I've provided different regulatory scopes to show where the regulations should apply and where they have attempted to apply them, and the mess it has created.