Transcript Chris Witteman

SEPARATING THE TRANSPORT LAYER,
LEVELING THE PLAYING FIELD?
Chris Witteman, Staff Counsel*
California Public Utilities Commission
[email protected]
*These comments do not necessarily represent the views of the Division or Ratepayer Advocates or the CPUC.
Special Access - U.S. – Sometimes
referred to as Middle Mile
Last Mile – US
Middle and Last Mile:
U.K.
(pretty much the same)
Keep it Simple?
Base and Superstructure
•
At its most basic level, the Internet runs on wires (PSTN):
•
Application
• Physical
Transport
Internet Protocol, the new Lingua Franca
Electronic communications networks are
becoming packet switched, mostly or completely
based in the IP [Internet Protocol]. They will be
multi-service networks, rather than service
specific networks for audio (including voice), video
(including TV-services) and data networks -allowing a decoupling of service and transport
provision…
European Regulators Group Consultation Document
On Regulatory Principles of IP-IC/NGN Core (2008)
Apropos Layers
• A crucial point is the adoption of open
and standardized interfaces between
each functional level in order to allow
third parties to develop and create
services independent of the network.
– European Regulators Group Consultation Document, supra
The BT/Ofcom solution
Openreach’s self-description
• The local access network – the wires and fibres
that connect tens of millions of homes and
businesses to local telephone exchanges is one
of the UK’s most important assets, and
Openreach was created to give communications
providers equal access to it.
• Our customers are Communications Providers the companies end users choose to provide
telephone, internet, and more recently television
services to their home or business. openreach.co.uk
Scope of Openreach
limited to areas of SMPCustomer premises
Local Telephone Exchange
5,600
Core Node.
CP
Core
Node
BTW
Core
Node
LLUO
Space
Line
Card
Main
Distribution
Frame
~26m homes
Distribution Point (DP)
~8m poles
Secondary
Connection Point
Primary
Connection Point
~90,000 cabinets
E-side
Cables
Backhaul products
D-side
Cables
Copper Cables
Overhead
and
underground
distribution
openreach
Openreach is also responsible for all duct, access fibre and copper & fibre backhaul
Regulated asset value
c.£ 9.6 billion
Demarcation Points
Backplate of
NTE
In U.S.: Incumbent’s view
And why is it imprudent?
Ofcom Result – Greater
Competition
Result - lower price
X Degrees of Separation –
US History
• Kingsbury Commitments (1913) –
separation of telephone & telegraph,
mandatory interconnection
• Carterfone (1968) – separation of network
from end-user equipment)
• Whitehead Report (Nixon White House
1974) – separation of cable network and
content
• Computer II (1980) – structural separation
The Great Unravelling
of the concept of competition and open access
• Computer III (1986)
– non-structural “safeguards”
• 1996 Telco Act –
– Unbundling and wholesale access as substitute for separation
(didn’t work)
• 2003 Triennial review
– Eliminated fiber unbundling
• DC Circuit USTA II 3/2/04
– Effectively eliminated UNE-P, precipitated mergers
• Cable Modem/Brand X –
– No telco, common carrier, unbundling requirements for
broadband
Google’s “Range of Tools”
• 6 Proposed NN Rules (or 5
Rules only, or Disclosure only)
• More Detailed Openness
Rules – re, e.g., QoS
• More Detailed Access Rules –
UNEs, Dom Carrier Pricing…
• Non-Structural Sep’n – Access
as Telco Serv (vs Info Serv)
• Computer III –
“Comparably Efficient”
• [Functional Separation]
• Structural Separation –
Computer II
• Ban: No Cross Ownership
is Openreach going to do fiber?
• Next Generation Access (NGA) is the
Openreach programme dedicated to shaping
tomorrow's communications environment. We're
working with our customers, the regulator,
industry and other stakeholders to ensure that
we build a clear picture of an access network
that's fit for the future. www.openreach.co.uk
• Fibre to the Premises
• Fibre to the Cabinet
• Generic Ethernet Access
OK, What’s the Catch?
• ILECs - “Not going to use my pipes”
• Argument: Cable Cos - Different History
• Argument: Doesn’t apply where cabletelco competition
• Argument: Difficult to apply to fiber
• Argument: Requires rate-setting on basic
network services