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JTRockville
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Who wants a SLA in Mont. Co. MD?


In case you think Montgomery County MD Bill 28-02, which specifies minimum standards for internet (among other things), isn't necessary, consider this:

NOTHING IN OUR CURRENT AGREEMENT COVERS "CABLE MODEM" SERVICES

Cable modem services, or any other new service (VOD, VOIP, etc.), are exempt from any local regulation. So here's our current situation:

Our local call center is not open 24/7 for internet. On your bill, right beside the number of our local center, it says: "24/7", but fails to mention that this is true only if you choose CATV instead of internet on the phone tree.
Subscribers do not have to be notified of appointment cancellations for internet service calls. For CATV, if an appointment is missed, it must be rescheduled at the *subscriber's* convenience.
Internet system malfunctions do not have to be responded to. If there is a CATV system malfunction, it must be responded to *immediately*.
No notice of internet service interruptions is required. Advance notice must be given either to subscribers, or the county (depending on time of day, and duration) for CATV service interruptions.
Subscribers must be notified of service changes at least 30 days in advance. Did anyone get advance notification of the recent VPN policy change (except from a public forum rumor mill)?
Refunds for internet service interruptions are determined at the whim of the provider. For CATV, if the repair isn't *complete* at the time of the scheduled appointment, the credit clock starts ticking.
Requests for internet billing inquiries, service, repair, or maintenance do not have to be responded to. If these requests are made regarding CATV, they must be responded to within 24 hours, or close of next business day, whichever comes first.

IF WE CAN'T RELY ON INTERNET, OR ANY OTHER NEW SERVICE, WHAT GOOD IS IT?

•Will you be willing to sign up for an expensive on-line class, knowing that about half way through (definitely *after* roll has been taken and the door has been locked), it will rain, knocking your internet connection out?
•Will you shop or pay bills on line, if you're never sure the confirmation will be displayed after you click "submit"?
•Will your employer be happy you're a telecommuter, if you can't complete a file transfer to an important work client who is waiting for the information (especially international clients)?
•How productive will you be, if on the day you decide to work from home to wait for a contractor (because your roof leaks or something), you discover you're not connected?
•How many instant message window conversations will you have, if just moments before the conversation climax, you drop, leaving your buddy or client wondering what it was that you found so objectionable?
•How much fun will you have gaming, if your pings spike?
•What quality research paper will you produce, if your connection is down and you're waiting for a service call during the two weeks leading up to the deadline?
•How good will your children's grades be, if when they check the homework page for their class, DNS fails to resolve the address, or email correspondence from their teacher arrives late?
•Would you like VPN restricts put back in place? VPN is not restricted *right now*, but nothing prevents restrictions on VPN, or other protocols.

It seems to me, that Montgomery County Bill 28-02 is a no-brainer. But our county executive and councilmembers need convincing. Follow this link to find out why:

MC Bill 28-02 - Will the politicians vote for me?

The vote is scheduled to take place on November 26th. You can find the latest draft at this link:
Bill No. 28 02, Concerning: Cable Communications – Amendments

WE ALL NEED TO TELL OUR COUNTY EXECUTIVE AND ALL COUNCILMEMBERS THAT WE WANT THEM TO VOTE IN FAVOR OF MC BILL 28-02

Doug Duncan, County Executive (240) 777-2500
Douglas.Duncan@co.mo.md.us

Montgomery County Md Councilmembers:

*Phil Andrews (D-Rockville, Gaithersburg-District 3), 240-777-7906
Phil.Andrews@co.mo.md.us

Nancy Dacek (R-Upcounty-District 2), 240-777-7811
nancy.dacek@co.mo.md.us

Howard Denis (R-Betheda, Potomac-District 1), 240-777-7964
councilmember.Denis@co.mo.md.us

*Blair Ewing (D-At-large), 240-777-7966
councilmember.ewing@co.mo.md.us

Isiah Leggett (D-At-large), 240-777-7955
isiah.leggett@co.mo.md.us

Donnell Peterman (D-Tacoma Park, Silver Spring-District 5), 240-777-7967
councilmember.peterman@co.mo.md.us

*Marilyn Praisner (D-East County-District 4), 240-777-7968
m.praisner@co.mo.md.us

Steven Silverman, President (D-At-large), 240-777-7960
Steven.Silverman@co.mo.md.us

Michael Subin (D-At-large), 240-777-7828
michael.subin@co.mo.md.us

* indicates the councilmember is a sponsor of Montgomery County Bill 28-02.

You can also send email to all councilmembers: county.council@co.mo.md.us

DonLibesBad

join:1999-12-10
Potomac, MD

Well put JT. The final vote will be November 26th - IN EIGHT DAYS! If you want quality service, now is the time to express support for it. A simple call or email to the county council NOW will be worth a thousand complaint postings to dslr!!!

If the vote fails, future complaints about Comcast's internet service will be a total waste of time. Now is the time your voice will be heard. Give the county teeth to deal with Comcast. Call the county council and tell them to support 28-02!


mabus
Dissociated But Not Disconnected

join:2002-11-12
Fort Wayne, IN

reply to JTRockville
wow... i've read the bill over, and although I am not a resident of that area, and I have decent service through Comcast, I hope that it passes for y'all. I think it's really sad that it had to come to government intervention in your area.

I only wish more areas would adopt laws such as this... and more so now that comcast has officially become ma bell-cast, or monopolycast or whatever.

Much to Comcast's disdain - this very bill may be the one thing that could save it's subscriber base in that county.

-/\/\

ihaddsl

join:2001-12-05
/dev/hda0
·Comcast

reply to JTRockville
While I agree that Comcast and other cable companies in many cases can do more to solve problems that they do, this proposal is utter crap and will only result in much higher internet bills

what you describe is available in (SLA) in business class services from Cable / DSL / and Teclos but for much more that the ~$50/month you pay for your residential class cable service.
--
War has no winners, only losers

CTW
Premium
join:2002-03-30
Bethesda, MD

said by ihaddsl See Profile:
this proposal is utter crap and will only result in much higher internet bills

I don't agree. Even without the SLA portions, this is a good bill -- it provides some teeth to the current Citizen's cable advisory committee to help people with long-standing problems get some help from Comcast. I testified in favor of this bill at a recent hearing, and I think something I said there is worth repeating (or at least paraphrasing):
quote:
People who have "difficult" problems with their cable internet service shouldn't have to become "cable activists" or technical experts just to get a decent level of service.
Three people on my block had intermittent connectivity (around 70% ! uptime) for about one year, almost two years in one case, yet we kept being told "reboot your modem" by Tech support. Maybe if there were a review board, who could look at complaints and impose fines on Comcast, it would tip the economic scales just enough to make them a little more responsive to complaints.

Personally, I get great service now, ever since the broken mini-bridge near my house got fixed. But as can be seen here on this very forum, Montgomery County seems to have a disproportionate share of users with unsatisfactory service. If this bill helps change that, even a bit, then it's worth it.

It's easy to say, "if you regulate a business, it'll cost everyone more", but I counter that if Comcast would make their troubleshooting/complaint resolution process more efficient, it would go A LOT further in cutting costs than a few fines here and there.

-CTW

ihaddsl

join:2001-12-05
/dev/hda0
·Comcast

said by CTW See Profile:

It's easy to say, "if you regulate a business, it'll cost everyone more", but I counter that if Comcast would make their troubleshooting/complaint resolution process more efficient, it would go A LOT further in cutting costs than a few fines here and there.

-CTW
Agreed, and I'm certainly no right wing hands off business guy, however I think these SLA's go too far for a residential service and will require the ISP to invest significant amounts of money in purchasing redunant equipment, redundant or upgraded backhaul capacity and not give them time to fix problems before incurring some sort of penalty.

I don't live in the area, so this won't affect me but I urge you all to consider the fact that this bill may be taking the SLA too far, and some sort of middle ground is probably much more appropriate.

anyway...
--
War has no winners, only losers


mabus
Dissociated But Not Disconnected

join:2002-11-12
Fort Wayne, IN

reply to JTRockville
What we are talking about here is perhaps an SLA... but what is defined in the bill, is the type of service that Comcast is already providing to other areas of the country... so I honestly don't see how comcast is going to need to 'raise' their rates to comply with this. If comcast would just get the system right in the first place, they would probably be better off financially, because they won't have to pay people to take all the phone calls of complaints, and they won't have to be paying techs to be putting out fires all over the place.

-/\/\

ihaddsl

join:2001-12-05
/dev/hda0
·Comcast

said by mabus See Profile:
What we are talking about here is perhaps an SLA... but what is defined in the bill, is the type of service that Comcast is already providing to other areas of the country... so I honestly don't see how comcast is going to need to 'raise' their rates to comply with this. If comcast would just get the system right in the first place, they would probably be better off financially, because they won't have to pay people to take all the phone calls of complaints, and they won't have to be paying techs to be putting out fires all over the place.

-/\/\
I don't know which bill you read - but that proposed bill does not represent what is to be had in the rest of the country - it's an SLA. I don't have anything approaching that agreement in place, however I am generally happy with my (residential) service.
--
War has no winners, only losers


JTRockville
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reply to JTRockville
said by mabus See Profile:
What we are talking about here is perhaps an SLA... but what is defined in the bill, is the type of service that Comcast is already providing to other areas of the country... so I honestly don't see how comcast is going to need to 'raise' their rates to comply with this. If comcast would just get the system right in the first place, they would probably be better off financially, because they won't have to pay people to take all the phone calls of complaints, and they won't have to be paying techs to be putting out fires all over the place.
The standards set forth in this bill are *puny* (at least compared with the T1 SLA's I've look at), and would only require enforcement in extreme cases.
said by MC Bill 28-02, beginning on page 13:
Functional requirements. Internet service must:
•provide and maintain download bandwidth of at least 1.0 megabits per second (Mbps), except that, during any 24-hour period, the bandwidth may be less than:
(A) 1.0 Mbps for not more than a total of 6 hours;
(B) 512 kilobits per second (kbs) for not more than a total of 1 hour; and
(C) 56 kbs for not more than a total of 30 minutes;
•provide and maintain upload bandwidth of at least 128kbs for a total of at least 23 hours during any 24-hour period;
•limit IP latency, during any 24-hour period, to not more than:
(A) 60 milliseconds (ms) for more than a total of 1 hour; and
(B) 30 ms for more than a total of 6 hours;
•provide and maintain download capacity of at least:
(A) 3 gigabytes (Gb) in any 24-hour period;
(B) 100Gb in any 28-day period;
•provide and maintain upload capacity of at least:
(A) 2Gb in any 24-hour period; and
(B) 33Gb in any 30-day period;
•provide mail servers that are available to actively accept in-bound email messages during at least 95 percent of any 1-week period;
•provide mail servers that, during any 1-week period, actively attempt to send out-bound email messages:
(A) within 5 minutes during at least 95 percent of the period;
(B) within 24 hours during at least 99 percent of the period; and
(C) within 72 hours at all times;
•provide email service that allows:
(A) at least 5 megabytes (Mb) of storage for each mailbox;
(B) at least 6 email addresses per account;
(C) messages with up to at least 100 recipients;
(D) messages that show a user-provided return address;
(E) individual mail messages of at least 1 Mb;
(F) a subscriber to retain on the provider’s servers, up to the limit of the subscriber’s allocated storage space, any in-bound or out-bound email to or from the subscriber;
•provide DNS root-server based responses during at least 95 of any 1-week period;
•ensures that no TCP/IP [[ports are not]] port is blocked in either the incoming or outgoing direction;
•allows all methods of multiplexing multiple hosts onto single IP address (such as NAT); and
•allow all subscribers to use any method of sending and receiving encrypted or encapsulated data (such as those generated by a virtual private network, or VPN).
Those are very minimum standards, and there is a *generous* lag time, including 30 days of assistance from our Cable Office, before any penalties kick in for unresolved problems.
said by CTW See Profile:
if Comcast would make their troubleshooting/complaint resolution process more efficient, it would go A LOT further in cutting costs than a few fines here and there.
I agree with CTW. Comcast stands to save *tons* of costs with the improvements in the resolution process that can be accomplished with MC Bill 28-02.
said by DonLibesBad See Profile:
Well put JT.
Thanks Don.
said by DonLibesBad See Profile:
The final vote will be November 26th - IN EIGHT DAYS! If you want quality service, now is the time to express support for it. A simple call or email to the county council NOW will be worth a thousand complaint postings to dslr!!!
post count / ???
=
count of councilmembers
contacted


Don? We don’t have to *limit* the number of councilmembers we contact based on our post count do we?
said by mabus See Profile:
Much to Comcast's disdain - this very bill may be the one thing that could save it's subscriber base in that county.
MC Bill 28-02 is a huge step in the direction I intend to see Comcast take. I've made my intentions clear to Comcast too, in no uncertain terms:

IF COMCAST IS GOING TO BE MY ONLY CHOICE FOR HIGH SPEED RESIDENTIAL COMMUNICATIONS, I'M GONNA MAKE SURE THEIR SERVICE ROCKS!

This bill is *pro Comcast*, imo.

ihaddsl

join:2001-12-05
/dev/hda0
·Comcast

said by JTRockville See Profile:

The standards set forth in this bill are *puny* (at least compared with the T1 SLA's I've look at), and would only require enforcement in extreme cases.
Yes but you also pay a *puny* amount for this service compared with the cost of a T1

but I wish you all luck - heck if it works out that's great for everyone.
--
War has no winners, only losers


items
Is Items Good For America?

join:2002-06-26
Lancaster, PA
clubs:

reply to ihaddsl
said by ihaddsl See Profile:

Agreed, and I'm certainly no right wing hands off business guy, however I think these SLA's go too far for a residential service and will require the ISP to invest significant amounts of money in purchasing redunant equipment, redundant or upgraded backhaul capacity and not give them time to fix problems before incurring some sort of penalty.
Well I am, and I think this bill is fine given the locality and the problems at hand on a local level. That is the whole point of local governments. Obviously MCMD is having some of the most egregious problems of all.

Now on the national level this would be inappropriate as I could easily see rising rates, as much as some wouldn't want to admit it. All it takes is Comcast to justify a rate increase due to increased infrastructure requirements and compliance.

Keep us posted.

Mike
--
As always, Talking Points Memo appreciates your comments.
/ hasps.net North America


halfband
Premium
join:2002-06-01
Huntsville, AL

reply to JTRockville
Our non-comcast local cable provider has a service tier targeted at dialup customers and the casual email checker/surfer who would not touch a $40/mo service. Something like 256k down/128K up for around $23/mo. Probably does not have more than one or two email accounts. Would this type of service be prohibited by the proposed bill.

Top Flight

join:2002-11-18
Netherworld


I am curious as to what other Internet providers offer an SLA of this type on a residential type service. I have only seen these on business class services. After reading over the proposed bill, I can see a scenario where Comcast may bow out of their franchise agreement and leave MO. CO. residents high and dry. While I am all for Comcast providing a high level of service for all of its customers, I cannot see them providing an SLA on its residential service for only $45 per month.

<language removed that came across stronger than intended>

Oh well, good luck nonetheless!
[text was edited by author 2002-11-18 19:06:11]


JTRockville
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said by Top Flight See Profile:
I am curious as to what other Internet providers offer an SLA of this type on a residential type service.
Welcome to BBR's Comcast Forum Top Flight!

Maybe I'm flattering myself, but I like to think of Montgomery County MD as a progressive community that looks to the future, and what's *possible*, rather than a community who follows in the footsteps of others.

Motorola seems to think it's not only *possible*, but will even be *profitable* to provide such guarantees.
said by Motorola whitepaper: One HFC Network, Multiple Revenue Streams:
Best-effort data services provide limited revenue growth potential for cable operators. Mere compliance with Data Over Cable Service Interface Specification (DOCSIS) 1.1 and EuroDOCSIS 1.1 specifications is essential but insufficient for meeting the QoS requirements of diverse applications and services. However, by implementing end-to-end Quality of Service (QoS) controls, operators can expand their customer bases by offering a wide variety of business and residential services.

(snip)

The power and flexibility of policy-based QoS control and measurable QoS levels can create increased revenue streams from both residential and corporate subscribers – as well as from revenue-sharing business partners.

(snip)

Standards compatibility and the adoption of next-generation technologies are enabling operators to:
• Provide measurable Service Level Agreements (SLAs) across the cable network.

(snip)

Network operators are now able to offer multiple services via shared cable infrastructure while providing guaranteed QoS levels to each service and user.
JT + Motorola
said by Top Flight See Profile:
After reading over the proposed bill, I can see a scenario where Comcast may bow out of their franchise agreement and leave MO. CO. residents high and dry.
I can't imagine any company abandoning a franchise that covers a large, wealthy, installed subscriber base such as ours. Plus, Comcast has invested a lot of money here.


J D McDorce
Premium
join:2001-12-29
Westland, MI

reply to Top Flight
One other perspective is that this is put your money where your mouth is legislation. If you have seen or heard the print, radio, and television ads or poked around »www.comcast.com/Products/Interne···inkID=21 or »www.comcastonline.com , I do not see where any of the Functional requirements listed would be outside of the realm of expectations for most prospective Comcast High Speed Internet customers.

I do not see this as a business class versus residential issue. It is more of a question of delivering the service that people are expecting based on the published promotions for the service. The people who drafted and are supporting this legislation are not the ones that packaged the bundle and offered it to the public for a given price.

Regardless of whether this bill passes, it should serve as a wakeup call, both to Comcast and other providers of residential internet services - deliver what you promote. Alas, this will likely go unheeded until Congress gets involved. And I am not looking forward to the mess that could generate.

DonLibesBad

join:1999-12-10
Potomac, MD

reply to Top Flight
said by Top Flight See Profile:
I am curious as to what other Internet providers offer an SLA of this type on a residential type service. I have only seen these on business class services.
You're not thinking deeply enough. First of all, we've been over this many times here at DSLR. There is general agreement that there is a point at which even residential service is unacceptable. For example, no one in these forums would accept continual 1sec latency to their ISP gateway. That then represents an SLA in the sense that anyone would feel comfortable approaching their ISP and stating that the service is unacceptable. We would correspondingly expect that all ISPs would agree that a 1sec latency needs fixing.

Once you accept this line of reasoning, the only thing left is to dicker over the actual values. As JT pointed out, the values in 28-02 are appropriately low. For example 28-02 says your connection can be out for a half hour EVERY DAY, clearly something way below what you'd get from a T1 SLA.

One other thing the 28-02 permits is adjustment of the standards. It is not the bill's intent to drive Comcast into financial ruin. That would be stupid. The standards will be adjusted as necessary.
quote:
After reading over the proposed bill, I can see a scenario where Comcast may bow out of their franchise agreement and leave MO. CO. residents high and dry.
I think they would be unable to justify leaving MC. Not only would they pay an immediate financial penalty in the millions, but Comcast would also be required to sell their equipment, either to the county or another franchisee.

Furthermore, if 28-02 passes, I expect that other jurisdictions will copy the legislation in whole or in part. So it would be pointless for Comcast to try and run from this. Much more sensible would be to get over it and just solve the problems that engendered its creation.
quote:
While I am all for Comcast providing a high level of service for all of its customers, I cannot see them providing an SLA on its residential service for only $45 per month.
You've got to get your head around the fact that this is not a business-class SLA. It is a residential-class SLA. Just because you've never heard of one before doesn't mean the concept doesn't make sense.


Descent
Wrap It Up
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WDC Suburb
reply to JTRockville
sent!


JTRockville
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cbrain

join:2000-05-21
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reply to JTRockville
I'm sure everyone on this forum knows JT. Just look at the date she joined and the quantity of posts. Anyone can follow her threads to see what she has gone through in an attempt to get a fraction of what Comcast portrays in its constant, numerous, costly advertisements for High Speed Internet access.

Did anyone know that prior to joining DSLR, JT had Comcast HSI for over a year without complaint? She actually bragged about this connection. That she prefers to spend time with her family than on troubleshooting her Comcast connection. Get her away from these cable issues she is a normal, even delightful person.

The current system in Montgomery County, Maryland is simply failing many cable users. How many names do you see on this forum month after month with the same problems? How would ihaddsl react if his connection had the problems JT has for over 8 months, even if the price went down?

Montgomery County has never levied a single fine against Comcast.

The CCAC and every independent consultant recommended against the franchise transfer. The county executive ignored his experts and recommended it go through. The Council, in a divided vote for the transfer, acknowledged many ongoing problems but concluded these issues could be handled by the executive doing his job or in later legislation.

It’s now later. I see many of the same names with the same problems. I don’t know if this bill is perfect but I know it is necessary.

If not this . . . what?


Floppy

join:2002-07-03
reply to JTRockville
Not to be negative, but the online requirements on page 13 more then likely won't fly. I haven't heard or seen any ISP being held to speed and latency guarantees.
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