NGA State Aid and technological neutrality

clohamon

Responses to the new EU draft guidelines on State Aid to broadband have been published.
http://ec.europa.eu/competition/consultations/2011_broadband_guidelines/index_en.html
It's interesting (though not surprising) to look at some of the different responses - Question 2.3 for example

"In line with the NGA Recommendation5, the Broadband Guidelines define very high speed, Next Generation Access ("NGA") networks in paragraph 53 as follows: "NGA networks are wired access networks which consist wholly or in part of optical elements and which are capable of delivering broadband access services with enhanced characteristics (such as higher throughput) as compared to those provided over existing copper networks."

2.3. Do you think that this definition is still adequate? In other words, at this stage of technological and market development, besides fixed, mainly fibre based networks, would you consider any other broadband technologies as falling into the definition of NGA networks? Please provide detailed justification and examples of commercial utilization to motivate your answer."

FTTH Council
"Yes, this definition is still adequate but may need to be adjusted to limit the extent to which non-fibre elements should be used. In particular, the FTTH Council notes that many of the business cases put forward by different analysts identifying current and future trends identify a variety of services which require radically higher upload speeds (e.g. real tele-presence and tele-working, home security, home health-care for the elderly etc.).
The main problem with cable and FTTC networks is that even if they can deliver improved download speeds, there is relatively little increase in upload speed and this requires significant resources to be put in place. A second iteration of network investment to ensure an adequate network will inevitably be delayed by such an investment. The EU2020 Strategy document identifies ‘a target of 50% or more of European households subscribing to internet connections above 100 Mbps’. In order to achieve a subscription rate of 50% an availability rate of more than 80% will be required. A 100% availability of 30mbps is also targeted. Any proposal which does not meet or have a low cost path to these minimum standards set by the Commission should be deemed inadequate for State Aid.
A second consideration in the context of comparing FTTH and other networks is the quality parameters that attach themselves. In terms of capacity related network characteristics, FTTH networks deliver a much higher performance than any other network type whilst also proving remarkably robust. Such quality and resilience allows more mission critical elements to be delivered remotely with confidence.
Wireless solutions (whether mobile or satellite) face far greater capacity constraints and importantly, as shared resources and spectrum, are greatly impacted by take up. While acting as important complements to fibre networks, they will in no way act as substitutes, not only due to capacity constraints but also due to wildly different quality parameters."

eircom
"Firstly, there seems to be some uncertainty regarding the current definition of NGA. Upgraded cable networks are explicitly included in the current Guidelines (2009/C-235/04 Clause 3.1 Par 52). Also, Governments have tended to include cable broadband in the benchmarking of national performance against the EU Digital Agenda 2020 targets. However this inclusion seems to have had little consequence in the evolution of related regulatory measures in that cable NGA footprints are not considered in market definition exercises and in the consideration of regulatory remedies to encourage effective competition.Secondly, the current NGA definition does not include emerging wireless technologies in particular LTE which potentially offers the most effective method for delivering high-speed broadband to rural and very rural areas. This exclusion raises the obvious question of how State Aid Guidelines can only apply to one technology category (wired access networks with optical elements) and at the same time purport to be technology-neutral.
All public policy aspects of NGA - regulation, State Aid rules etc - should be developed on a technology neutral basis."


DCENR
"We support a technology neutral approach. In addition to fibre, wireless solutions are likely to remain important in Ireland, particularly to serve large parts of the country, which have a highly dispersed rural population. It is important that any such State Aided high speed interventions, which may involve wireless or other technologies, are not discriminated against in terms of the ease of receiving State Aid Clearance from the Cion."



Hardly needs saying that the DCENR response was being prepared at the same time it was developing the National Broadband Plan.

That's incorrect. It was during the NGB Taskforce period.

watty

DCENR doesn't mean decent Fixed Wireless but Mobile Networks engineered to make money from Voice.

clohamon

watty wrote: »

DCENR doesn't mean decent Fixed Wireless but Mobile Networks engineered to make money from Voice.

I suppose not, but the the Wik Consult report, which the EU commissioned as part of the exercise, also excluded Fixed Wireless from its definition.

2.1 Basic principles
2.1.1
Definition of NGA
(1) The NGA definition of the Guidelines is developed from a technological point of view and it is the same as the NGA definition of the NGA Recommendation and it is in line with the broadband targets of the Digital Agenda.
(2) The Digital Agenda has defined a distinction between “basic broadband”, “fast broadband” and “ultra-fast broadband”. Only the latter one is regarded as NGA. The Guidelines should in principle follow this differentiation. If a thorough analy- sis proofs this approach to become too complex, then it makes sense to distinct between basic and fast broadband on the one hand and ultra-fast broadband on the other hand. In any case, the understanding of NGA as “ultra-fast broadband” has to be applied consistently throughout the complete text of the broadband Guidelines.
(3) The capabilities of LTE will be expanding over time. In the foreseeable future, however, LTE will only support basic up to fast broadband and not ultra-fast broadband. The same assessment holds true of broadband access via fixed wireless access and satellite technologies. Technological developments therefore do not justify updating the definition of NGA networks by including other technologies as wireless, mobile or satellite solutions.

So no NGA State Aid for LTE or FWA according to the consultants.

Question is whether the EU Commission will now cave in to the mobile lobby and the likes of DCENR.

watty

I hope not.

The question to ask is who in the Civil Service / Quangos has been benefiting from the lax regulation and pro-mobile policies of the last 6 years?

bealtine

watty wrote: »

I hope not.

The question to ask is who in the Civil Service / Quangos has been benefiting from the lax regulation and pro-mobile policies of the last 6 years?

I doubt there are brown envelopes involved but you never know...

I suspect it's the mobile industry was expected to pay a huge bonanza to the gov in spectrum fees and this has coloured civil servants view...Money always equals favourable conditions

watty

Irish Policy, the NBS and now the RBS are so stupid either Civil servants should be sacked for being incompetent (destroying and holding back even private funded infrastructure) or an investigation of corruption.

It's either gross stupidity or corruption in Civil Service/Quangos/Regulators/Advisers.