Australian Regulator takes interesting LLU line.

spongebob

The regulator crunched the numbers as if they were an OLO trying to get into the incumbents exchange. Telstra are very very reminiscemnt of Eircom so this is highly relevant. One is left under the impression that the the Australian regulator will take less crap from Telstra than appears to be the case here. This Imputation Test methodology is impossible over in Comreg because nobody in there ever provisioned anything more complex than a 3 Pin Plug in their entire lives so they would inevtiably be laughed out the door at Stephens Green if they tried to Impute anything . Nevertheless they could create a pseudo licenced entity called muck.ie, indulge in bribery and brown paper baggery (over HERE , over HERE) and let meself and Adam model the process for them just so they see what its like out there

This is the first report to contain imputation testing of the unconditioned local loop core service (ULLS). The ULLS essentially allows a competitor to lease the use of the customer’s line from Telstra to supply any combination of access, voice, ADSL or other data services.
"The report strongly indicates that the average margins available in the provision of ADSL or of a bundle of ADSL and voice services over the ULLS are not sufficient to recover costs. The results are a concern, and are a warning signal to the ACCC to take a greater look at the costs of supplying retail services using the ULLS.

"The insufficient margins appear to result from the costs of transforming the ULLS core service into the downstream retail services, rather than the cost of the ULLS itself. The ACCC intends to examine possible price and non-price impediments to using the ULLS, such as costs of access to Telstra’s exchanges".

The ACCC notes that the imputation testing uses cost data that is highly aggregated.

"The test includes the higher costs of rural and regional areas, as well as metropolitan areas. Competitors are more likely to enter lower cost areas and target customers that generate above average revenues".

The ULLS test is in its infancy and the ACCC anticipates that it will require further development.

This imputation testing is different from the ACCC's investigation into wholesale ADSL pricing, which is currently subject to a Competition Notice. That investigation relates to the retail pricing of ADSL for competitors who resell Telstra's ADSL wholesale service, not competitors who use the ULLS.

Isolde can understand this stuff .....but she does not read this Board ? Right ?

M

jwt

i thought ComReg went off and created a virtual telco who is 100% efficient for modelling purposes.

They then throw figures at this virtual telco until they arrive at a figure/cost analysis that keeps their paymasters happy?????

John

spongebob

jwt wrote:

i thought ComReg went off and created a virtual telco who is 100% efficient for modelling purposes.

John

That would be what all the blank pages in your FOI request were about John , a seasonal reductio ad absurdum from those jolly japers in Comreg .

M

jwt

:eek:

Damm there goes my theory, I thought the dotted folding lines and "punch hole in top corner to hang on nail" instructions were for something else entirely


John

spongebob

jwt wrote:

"punch hole in top corner to hang on nail"

Thats a top secret eircom instruction leaflet on how to dangle a pairgain off a windswpet pole in 2 mins flat between tea breaks. Its what passes for rural line provisioning and . Shame on Comreg for letting such Commercially Sensitive stuff get into the public domain , what will people think of Ireland I ask ?

m

eircomtribunal

Muck wrote:

Thats a top secret eircom....Shame on Comreg for letting such Commercially Sensitive stuff get into the public domain , what will people think of Ireland I ask ?

m

ComReg were more careful when refusing my FOI request, where I asked to get "Existing, but not published current map (not older than 3 month) showing the up to date broadband coverage/availability in Ireland."

ComReg decided: Broadband coverage in Ireland to stay a State secret – (glad we made our own map.)

ComReg have only one broadband coverage map in their hands (!) and it is one of one operator (never named – I still wonder which one that could be). After asking the operator, whose broadband coverage map ComReg have, about his views on publication, and getting a no from him, ComReg had to make a decision about my request.

ComReg says: If they published the map, they might not get this information in future from this and other companies and this "would impact on ComReg's ability to make the optimum informed decisions in carrying out its functions." This would "undermine ComReg in the exercise of its statutory functions in a most efficient and effective manner."
"Disclosure could reasonably be expected to result in a material financial loss to the operator as information in the public domain could have an impact on the current and potential customer of the operator."

"The need to avoid impeding the commercial viability of private companies" is more important than "The public interest in awareness of operations of companies in the telecommunications sector."

P.

spongebob

eircomtribunal wrote:

ComReg says: If they published the map, they might not get this information in future from this and other companies and this "would impact on ComReg's ability to make the optimum informed decisions in carrying out its functions."

Quis custodiet ipsos custodes . ?

M

jwt

"Who is guarding the guardians" makes a huge assumption about ComRegs primary role

"Ex nihilo nihil" would be more in keeping I believe



John

spongebob

"Who is watching the watchmen" is the more apt translation

M

damien

Muck wrote:

"Who is watching the watchmen"

I think we all know that answer, don't we ?


[Off topic] It was a great graphic novel.

d-j-k

Just as a point, I have heard pretty bad things about the regulatory situation in New Zealand. Apparently Telecom New Zealand is behaving like Eircom were several years ago!

Might be interesting to do some comparisons as Ireland and NZ are similar size countries.

eircomtribunal

d-j-k wrote:

Just as a point, I have heard pretty bad things about the regulatory situation in New Zealand. Apparently Telecom New Zealand is behaving like Eircom were several years ago!

Might be interesting to do some comparisons as Ireland and NZ are similar size countries.

"20 April 2004 from http://www.point-topic.com/content/operatorSource/profiles/New+Zealand/NZ+broadband+overview.htm&comp_id=751

New Zealand was among the leaders in the early days of broadband. Telecom New Zealand launched DSL services in the major cities in June 1999 and even by the end of 2002 it was still ahead of countries such as Australia and the UK in DSL penetration. But growth has levelled off and New Zealand was one of the lowest-performing countries on Point Topic's Broadband Growth Index for 2003. Broadband numbers increased by 40% in 2003, less than half the average rate achieved by other countries at the same stage of development.

Looking at DSL alone, New Zealand has been falling behind comparable countries such as Australia, the UK , Norway and Canada as the figure below shows. Even this picture is slightly flattering to New Zealand as far as total broadband usage is concerned because all the other countries have relatively large cable modem markets as well as DSL, but in New Zealand cable modems account for less than 10% of total broadband.

Figure 1 New Zealand is falling behind comparable countries in DSL penetration

As of April 2004 it also looks unlikely that increasing competition will do much to raise the rate of growth. There is no local loop unbundling in New Zealand, and the Commerce Commission, which regulates telecoms, has recommended against it. The only concession to competition in the Commission's recommendations, published in December 2003, is a requirement for Telecom New Zealand to offer a low-performance ADSL bitstream product for resale, with the associated backhaul. Competing carriers were hoping that the Minister of Communications, Paul Swain, would overrule the Commission, at least as far as requiring higher performance bitstream offers. Even if this happens, it still seems likely that New Zealand will remain one of the less competitive telecoms environments in the developed world.

Competitive landscape

The New Zealand broadband market is currently dominated by Telecom's DSL offerings. Telecom's biggest fixed network competitor is TelstraClear, now wholly owned by the Australian incumbent, Telstra. TelstraClear resells Telecom's DSL services and operates cable television networks in Wellington and Christchurch. These served about 5,700 cable modem customers at the end of 2003."

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eircomtribunal

Look at this chart from the International Telecommunications Union for the NZ pricing of broadband.
P.

damien

Muck wrote:

The regulator crunched the numbers as if they were an OLO trying to get into the incumbents exchange. ... This Imputation Test methodology

So then, why not do our own imputation test ? Take the ARO price list, crunch additional costs of equipment and for digging to an exchange, add in marketing and NOC costs and see how much it is to enable an exchange.

It would make a great briefing document for the press.

spongebob

Kinnegad

M

dahamsta

Isn't anyone going to do a joke about a ComReg amputation test?

Our man in Havana

Have you guys appealed your FOI refusals to the information commissioner?

eircomtribunal

Bond-007 wrote:

Have you guys appealed your FOI refusals to the information commissioner?

It'll be a waste of time and money.
I made three FOIs. Two were refused and the refusals are just as, or even more telling than the withheld information. I don't need to see the eircom dls coverage map, but it is very informative for me and others to see that our Communications regulator does not even have its own dsl/broadband coverage map and is not regulating eircom, but is at eircom's mercy for information about the development of Ireland's future.
The information I got on ComReg's response to the DCMNR on foot of the March 2004 DCMNR directions about ComReg's broadband goals ( reaching the EU average by mid 2005) are a damning indictment and will be the content of Dail questions in the new year. They show
1. that ComReg has not done the right things to achieve these goals (or come anyway near to achieve the goals) and
2. that ComReg has no difficulties to deliberately misinform the DCMNR about the failure. (for example by claiming that Ireland's broadband availability is in line with the EU-15 average; by making Eircom's broadband goals its own) See Three blind mice

ComReg's recent trick to hide the abysmal Internet development statistics (home Internet penetration not growing, but falling and online shopping not growing but falling for the whole year of 2004 – when Internet and Broadband growth is exploding in the rest of Europe, especially in the UK, France, Italy and Spain, countries that were up to now lagging behind) under misleading headings in the quietly sneaked out Q4 Quarterly Report speaks volumes.



P.

damien

IrelandOffline have yet to appeal an FOI request denial. One of ours requests was appealed by a large telecoms company though. It's being dealt with by the Information Commissioner who takes a minimum of 4 months to deal with an appeal. It's a handy way of witholding information as long as possible.