Transcript Διαφάνεια 1
Open regulatory issues and challenges due
to next generation networks
Ioannis Zacharopoulos, Ph. D.
Senior Telecom Engineer
Telecommunications Directorate
Hellenic Telecommunications & Post Commission (ΕΕΤΤ)
Outline
Facts in Europe regarding NGA
variations & economics of NGA
The European Commission view
The new (draft) recommendation on regulated access to Next Generation
Access Networks (NGA)
In case of NGA based on incumbent’s initiative
Regulators’ view
Benchmark on European countries
Regulatory Issues of Next Generation (core) Networks (NGN)
Conclusions
NGA variations
Fiber To The Home (FTTH) Point-To-Point (P2P)
1 fiber pair per household up-to aggregation point
Fiber To The Home (FTTH) Point-To-Multi-Point (PMP) or
Gigabit Passive Optical Network (GPON)
1 fiber pair shared over a number of households
Fiber To The Cabinet (FTTCab) or
Fiber To The Node (FTTN)
1 fiber pair per neighborhood (partial copper
replacement)
Economics of NGA (1)
Vary with technology/mode
of deployment but…
… in any case there is high
CAPEX per connected
customer …
High CAPEX can be
reduced by coordinated
strategy on reduction of
construction costs and…
…in high density (urban)
areas…
… and this leads to high
total costs and makes NGA
infrastructure a really
non-replicable asset.
(First mover advantage)
The Economics of Next Generation Access, Study for the European
Competitive Telecommunication Association (ECTA), WIK-Consult
Economics of NGA (2)
NGA “Pareto Law”: The
main fraction (>65%) of
NGA CAPEX per customer
is due to civil works
Of this CAPEX, the intracable CAPEX (in case of
FTTH deployment) is
almost the same weighty
as the distributionnetwork CAPEX
The rest of the CAPEX is
due to CPE, CO Optoelectronic equipment,
etc.
Dr. Kátrin Schweren, EU Affairs Delegate, Swisscom "Swiss Fibre Optics or Fibre Suisse:
Multiple Fiber Multiply Innovation"
FTTH Europe Conference, Copenhagen, 11-12/02/2009
Commission view: new (draft)
recommendation on regulated access to NGAs (1)
The proposal refers to the case that there is NGA deployment after
initiative of incumbent
In Greece: announcements for NGA partially funded by the State (Public-PrivatePartnership (PPP) form)
How NGA impacts the defined wholesale markets
Wholesale Physical Access (Market #4)
Wholesale Broadband Access (Market #5))
Possible Wholesale products needed for competitors
Some critical details like pricing etc.
The proposal seems to be too prescriptive to be generic enough to
cover the various cases/countries throughout Europe
Commission view (2)
Remedies imposed to operators having SMP as a result of market
analysis
when planned or ongoing NGA deployment
Geographical market considered
Fibre roll-out probably limited geographic coverage (short & medium term)
Transparency: reference offer for all relevant wholesale products
conditions for access to ducts, other civil engineering works etc.
information regarding duct location, capacity etc.
FTTH case
Duct access: mandatory
Physical access to dark fiber (LLU-fiber): Conditional
If access to ducts, etc. services technically impossible or not economically viable
Intra-building wiring: NRAs facilitate cooperation on roll-out & sharing infrastructure…
enable end-users to have competitive choice
avoid duplication of infrastructure
…but perhaps more and tailored-made initiatives could be envisaged in order to promote it
Fiber sub-loop unbundling: mandatory
Commission view (3)
FTTN/FTTCab case
If partial replacement of existing copper access with fibre: Obligation on
determining deadline, appropriate migration path from the current access
products to new access products (timing, technical functionalities etc.)
Obligations:
Reference offer for sub-loop unbundling
Access to ducts, street cabinets
Co-location: either at the street cabinet itself or near it
Co-location facilities: power supply etc.
Ex ante price control on all wholesale products: ducts, etc.
Supplementary, appropriate backhaul wholesale products
Pre-determination of details by NRA: size of street cabinets, cost-sharing
arrangements, etc.
Access products: flexible enough to facilitate migration from FTTN to FTTH
Wholesale Broadband Access
As in case of existing services (both for FTTH, FTTN)
Commission view (4)
Principle of geographic averaging:
Not necessary use if substantial cost differences among various areas
Pricing of existing assets (including ancillary services):
Cost-orientation: Methodology same as today
Pricing of new assets (including ancillary services) and dark fiber (up
to a concentrating point)
Cost-orientation: but with a project-specific risk premium to be included in the
costs of capital for the investment risk.
Risk premium calculated by regulator after justified arguments of incumbent
about the investment risk incurred by the incumbent
Focus on striking balance between effective competition and encouraging
investment towards better evolution of the whole investment
Commission view (5)
Other issues
FTTH-PMP (GPON) seems like cable network (!?)
Gradation of remedies:
If passive remedies not active remedies
Reciprocal regulation (sharing):
NRAs may or not impose if commercial contracts initiatives
NRAs could allow SMP operators to refuse sharing new investments with
alternative operators who, do not agree to reciprocal sharing of their assets
Regulators’ view (1)
Agreeing with the general context and goals but …
..seems to be over-prescriptive on implementation of remedies and pricing remedies.
Passive remedies and especially duct access do not necessarily suffice, neither are
the “ultimate” treatment
Pricing
Vague methodology for risk premium calculation
Not geographical averaging approach:
unrealistic
variant from the current Commission approach (used for existing assets, well accepted,
applied regulatory practice)
Opinion that “GPON seems like cable” might give incentive to incumbents to deploy
GPON expecting regulatory holiday
There is no “one-size-fits-all”: Every country should be in position to select remedies
according to its market status
Regulators’ view (2)
Active remedies might be a good alternative especially in case of
FTTN/FTTCab scenario and at least for the first period
Advanced-enhanced WBA might keep service competition in case of
FTTN scenario
Quality parameters (for example low jitter for high video quality)
Ethernet backhauling
Different levels of IP hierarchy/nodes (e.g. Main Distribution Frame, MDF)
Support of multicasting (for high video quality)
Benchmark on European countries
Most operators are in early announcements, trials etc.
In general, incumbents prefer FTTN (FTTCab/VDSL) or GPON or
Hybrid-Fiber-Coaxial (if they have access to cable)
Except France where FT applies FTTH as well
In general, alternatives/utilities prefer FTTH (P2P or GPON)
Issues regarding Next Generation (Core)
Networks (NGN)
NGN: single packet switched network transporting multiple
services (audio, video, data, both fixed & mobile)
Decouples the service and transport provision.
(Potential) innovation opportunities at both service,
infrastructure level.
(Potential) increased economies of scope and thus cost savings
Impact market structure, interconnection regimes,
interoperability and regulation
ERG opinion: separation between transport and service layer
will in practice be blurred by the implementation of services by
means of a centralised platform. This impacts the ability of
independent services providers to integrate their services into
the NGN platform.
Regulatory issues of NGNs (2)
Points of interconnection (POIs)
Due to centralisation of the control function, POIs for transport and for service will likely be
different.
Transport interconnection could take place at a greater number of locations than service
interconnection (e.g. transport interconnection at any network node, but service
interconnection only at centralised platform location).
Quality of Service (QoS)
New dimension of interconnection agreements,
It could be exploited by SMPs for new forms of discrimination (SMP arm, competitors)
NRAs should have the possibility to impose minimum QoS levels.
Costing/pricing
Single network to deliver multiple services (economies of scope)
In other words: costs will be mainly fixed and common; incremental costs for each service will
be relatively low.
Change of cost standard?
Bill & Keep (B&K) wholesale billing regime
Conclusions – Open issues
Cost sharing and procedures’ facilitation makes NGA deployment
easier
Duct access do not necessarily suffice, neither is the “ultimate”
treatment
FTTN/FTTCab mode
Collocation at street cabinets is expensive for OLOs and might multiply today’s procedures
thus delaying roll-out
Incumbents (except for France) in Europe definitely prefer FTTN/FTTCab mode
WBA might be more important for OLOs, especially if enhanced
FTTH-P2P mode
Main barrier: Intra-building wiring (Costs and roll-out complexities)
NGN might impact to a number of critical regulatory issues (POIs,
QOS, wholesale interconnection billing scheme)
In Greece: depending on evolution of the State subsidized plan,
there are additional issues that are expected to handle by the
Regulator
www.eett.gr
www.broadband.gr
Supplementary slides
Commission view (6)
Risk premium
estimated by regulatory precedent/benchmark or
direct statistical, financial comparator methods like equity beta with benchmarks from
other sectors but providing comparable services (e.g. media).
Include project-specific capital employed, labour costs, building costs, efficiency
gains, assets’ terminal value (rec. 20 Access Dir.)
Risk premium not applied for fibre backhaul from the street cabinets to the MDF
Principle of equivalence: avoid discrimination in favor of SMP’s retail
arm
Equivalence on asset information
Infra availability (location of ducts, street cabinets, manholes, availability, etc.)
Access points: network topography, location of concentration points and list of
connected buildings.
Equivalence on provisioning times: through platform/tool
Equivalence on service management & SLA
QOS indicators & pre-defined target service levels (time limits for replying to
requests for information, etc. )
Regular reporting
Regulatory issues of NGNs (3)
Bill & Keep (B&K) wholesale billing regime
Each network bears the costs of terminating traffic coming from other carriers
Not receive payments at the wholesale level for termination.
Recovers its costs (termination and any payments for upstream connectivity) in other
ways, e.g. by billing them to its end customers.
B&K can be considered by NRAs
Where B&K applies, it is unlikely to have SMP in the termination market.
“Silent requirement”: sufficient competition at the retail level
Concept of termination charge will not disappear at all. Traffic from outside the B&K
area needs to be treated in such a way as to prevent extensive arbitrage (tromboning,
call-back etc.).
Billing migration to B&K
Not full migration to all-IP: keep existing regime
Requirements: clear distinction between different services & use of services measurable
Possibility for price differentiation based on QoS classes
migration to B&K is easier:
the lower the absolute level of interconnection rates;
the smaller the relative difference between interconnection rates of different
networks
the higher the proportion of flat rate tariff packages at the retail level.