Comreg Consultation On ADSL and Leased Line Prices.

spongebob

This ain't light reading, there are pages of Kompetition Spik in there with some 125 pages in the document.

It is a very good analysis overall though and goes a long way towards explaining what the missing commissioner was up to recently

Comreg have decided , in a nutshell, that there is competition on International Leased lines....ie Fibre. That is a separate document. I agree with that.

Comreg then looked at National circuits and decided that there is competition on circuits of over 2Mb. Normally these run over fibre too but some (around 2-30Mbit) can run over bonded copper pairs, eg 2 pair or 4 pair. Over 30 Mbit they are fibre or fibre/wireless circuits .

Then, knock me over with a feather please, they noticed by the process of elimination decribed above that the circuits where competition was MISSING were the ones which NORMALLY run over a single copper pair and where guess who owns all the copper. These can include ADSL or SDSL or normal leased lines. The document is Here and contains a lot of good stuff. Muck is impressed but Muck will be a lot more impressed if action is taken .

The full list of questions is at the end with page refs . Consultation season last till mid July or so.

Believe it or not Comreg will have to amend the USO after this consultation possibly including ADSL in the "minimum set of leased lines" . That depends toa degree on the submissions to this consultation. Pigs could fly people.

The questions for Consultation are at the end to give ya a quick idea before you start eatin a bit.

spongebob

You may choose to answer any or all of them as you see fit.

I note that the lmited number of POPs on the Eircom network along the West Coast have not blipped onto the urban centric Comreg radar. The tail cost of a leased line in the west can be wicked....some are nearly 100km from a pop ........unlike other parts of the country which would have shorter tails...and certainly not 100km.

Comreg do not appear to be minded to tell Eircom that there should be a CAP on the tail which is a very effective way of telling them to build more POPs and stop feckin people around.

If ADSL is included in the final directions arising from this Consultation it will probably follow that ADSL will make it into the "Minimum set of leased lines" portion of the USO .....hopefully a 64k ADSL or higher ............. but this is Comreg and their regard for the consumer is not the highest. Q's 17 22 23 and 24 together .

Comreg Questions .

Page numbers on the right.

Comreg assumptions and factoids on the pages preceding each Question.

Submissions

All responses to this consultation should be clearly marked:-
“Reference: Submission re ComReg 04/59”

and sent to suzanne.monaghan@comreg.ie by 17/07/04

Appendix A – Consultation Questions
Q. 1. Do you agree with the methodology proposed by ComReg? Please
detail your views. ................................................................................ 18
Q. 2. Do you agree with the functional characteristics that are understood
to be offered by leased lines products and services as described above? Please
detail your response. ........................................................................... 26
Q. 3. Do you believe that network termination points represent the
boundary of a leased line? Please detail your reasoning. ........................... 26
Q. 4. Do you agree that there should be separate markets for trunk
segments and terminating segments? Please detail your response with
supporting evidence............................................................................. 30
Q. 5. Do you agree that given the prospective analysis, the boundary
between trunk segments and terminating segments should be drawn at the
customer’s serving exchange? Please detail your views with supporting
evidence. ........................................................................................... 31
Q. 6. Do you agree that there is a single relevant product and service
market for terminating segments, not differentiated by bandwidth? If not
please provide rationale for your argument. ............................................ 32
Q. 7. Do you agree that there is a single relevant product and service
market for trunk segments, not differentiated by bandwidth? If not please
provide the reasoning for your views...................................................... 32
Q. 8. Do you agree with ComReg’s view that there are two distinct markets
at the wholesale level for terminating and trunk segments, (not segmented by
bandwidth) which are both national in scope? Please provide evidence to
support your response. ........................................................................ 34
Q. 9. Do you agree with ComReg’s preliminary market analysis of the
wholesale trunk segments? Please support your response with evidence. .... 43
Q. 10. Do you agree with the above preliminary conclusions regarding
market analysis? Please provide evidence to support your response............ 49
Q. 11. Do you believe VPNs should not be included in the market? Please
provide evidence to support your response. ............................................ 62
Q. 12. Do you believe that IP VPNs should not be included in the market?
Please provide evidence to support your response. Please give your views on
whether the functional definition should be amended................................ 63
Q. 13. Do you believe that ATM services should not be included in the
market? Please provide evidence to support your response. ...................... 64
Q. 14. Do you believe that Frame Relay should not be included in the
market? Please provide evidence to support your response. ...................... 64
Q. 15. Do you believe that Ethernet should not be included in the market?
Please provide evidence to support your response.................................... 65
Q. 16. Do you believe that SDSL should not be included in the market?
Please provide evidence to support your response.................................... 66
Q. 17. Do you believe that ADSL should not be included in the market?
Please provide evidence to support your response.................................... 66
Q. 18. Do you agree with ComReg’s conclusion that the market for retail
leased lines up to and including 2 Mb/s, is national in scope? Please provide
evidence in support of your response. .................................................... 69
Q. 19. Do you agree with ComReg’s conclusion to withdraw obligations from
eircom for leased lines above 2 Mb/s? Please provide evidence in support of
your response..................................................................................... 71
Q. 20. Do you agree with ComReg’s conclusion for its market analysis on the
market for retail leased lines up to and including 2 Mb/s? Please provide
evidence in support of your response. .................................................... 81
Q. 21. Do you agree with the principles which ComReg believes should be
used when selecting remedies? Do you think there are other principles that
ComReg should consider when selecting appropriate remedies? ................. 95
Q. 22. Do you agree that an access obligation should be imposed on eircom
pursuant to Regulation 13? Do you agree that this access obligation should
mandate Partial Private Circuits and also impose on eircom the obligation to
meet reasonable requests for access? Please detail your response.............. 97
Q. 23. If you believe that eircom should be required to answer reasonable
requests for access, do you require any further wholesale products or features
or additional associated facilities to be provided by eircom? Please provide
details of such products........................................................................ 97
Q. 24. Do you agree that an access obligation is not the most appropriate
remedy to mandate Wholesale Leased Lines and that a remedy of nondiscrimination
is more appropriate?........................................................ 98
Q. 25. Do you agree that eircom should be required to grant open access to
technical interfaces, protocols, or other key technologies and should also be
required to provide such Operational Support Systems (OSS) or similar
software necessary to ensure fair competition in the provision of services?
Please detail your response................................................................... 98
Q. 26. Do you agree that eircom should be required to negotiate in good
faith? Please detail your response. ......................................................... 99
Q. 27. Do you agree that eircom should be required not to withdraw access
to facilities already granted, save without prior ComReg approval which would
only be granted following public consultation. ? Please detail your response.
Q. 28. Do you agree with the approach to Service Level Agreements for
access obligations set out above? Are there any other conditions which should
be attached to the proposed obligations? Please detail your response. ...... 100
Q. 29. Do you agree that an obligation of non-discrimination is appropriate
to mandate the provision of a wholesale leased line offer by eircom? Do you
believe that SLAs and reports on SLAs are necessary to monitor nondiscrimination?
Please detail your response. .......................................... 101
Q. 30. Do you agree that obligations of non-discrimination should be
imposed on eircom? Please detail your response, making references to
ComReg’s interpretation of such an obligation set out above.................... 102
Q. 31. Do you agree that an obligation of transparency should be imposed
on eircom? Please detail your response................................................. 102
Q. 32. Do you believe that reference offers should be maintained for the PPC
product set and introduced for the wholesale leased line product set and any
new offerings developed in accordance with Regulations 11 or 13? Please
state in your answer any precise information that you believe should be made
available, the level of detail required and the manner of publication. ........ 103
Q. 33. Do you believe that ComReg should require eircom to make public
any further information? Do you agree with ComReg that an obligation of
transparency is required to monitor non-discrimination? What type of
information should be published? Please specify how you believe this should
be made available. Please provide support for your response................... 104
Q. 34. ComReg proposes to continue with the application of a FL-LRIC price
control for PPCs. Do you agree with this position? Do you believe there are
alternative price control methods that have not been considered by ComReg
which are less onerous but equally effective as FL-LRIC? Please support your
response with economic analysis. ........................................................ 107

spongebob

(cont'd)

Q. 35. ComReg proposes to continue with the application of the retail-minus
formula price control for wholesale leased lines so as to prevent the
application of a margin squeeze. Do you agree with this position and the
approach described above? Do you believe there are alternative price control
methods that have not been considered by ComReg which are less onerous
but equally effective as the retail-minus formula currently applied? .......... 108
Q. 36. Do you agree that obligations in respect of cost accounting systems
should be imposed on eircom? Please detail your response...................... 109
Q. 37. Do you believe eircom should have an obligation of accounting
separation? Please detail your response................................................ 110
Q. 38. The legislation obliges ComReg to place a non-discrimination
obligation on any SMP operator in this market. Do you support ComReg’s
proposed approach to defining this obligation? Please detail your response.111
Q. 39. The legislation requires ComReg to impose an obligation of cost
orientation on any SMP operator in this market. Do you agree that cost
orientation should be interpreted as Fully Distributed Historic Costs, or do you
believe other costing methodologies would be more appropriate? Please detail
your response to ComReg’s proposed implementation method. ................ 112
Q. 40. The legislation requires that ComReg impose an obligation of cost
accounting systems on eircom. Do you agree with the approach set out?
Please detail your response................................................................. 113
Q. 41. Do you agree that Part 14 of the eircom Telecommunications Scheme
provides sufficient detail on the technical characteristics of leased lines in this
market? Do you believe more detail should be given? If so, please provide
details of any further information you believe should be made accessible, and
how you believe it should be made accessible....................................... 114
Q. 42. Do you agree with the proposed approach to transparency of retail
prices and other terms and conditions for leased lines in the retail minimum
set (up to and including 2 Mb/s)? In particular, what are your views on the
advantages and disadvantages of imposing an obligation of advanced
notification and publication? Please set out reasons for your answer. ........ 116
Q. 43. Do you agree that eircom should be required to publish the
information in respect of supply conditions as set out above? How do you
consider information should be made easily accessible? Please provide details
as to format, frequency of publication and other parameters you consider
relevant. .......................................................................................... 117
Q. 44. Respondents are asked to provide views on whether the remedies in
section 6 are proportionate and justified and offer views on what factors
ComReg should consider in completing its Regulatory Impact Assessment in
terms of the impacts of these remedies on end-users, competition, the
internal single market and technological neutrality. ................................ 118


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