[AusNOG] reminder on submissions to NBN Co, Comms Alliance and DBCDE....

Stephen Carter Stephen.Carter at workingtech.com
Wed Feb 10 08:33:43 EST 2010

Some of my Comments (2 cents)

NBN is destined to either fail or cause all Australian citizens to be laden with more debt than can be realised from productivity benefits of the NBN. I think it is a great idea, but only an unwise politician that does not like his job would make an impossible election promise without having given this some thought. It is not possible for the public sector to deliver this service. What is even worse is that the government is making the same mistake as before creating a single monopoly that a future government will have to clean up. And at the amount they intend to spend without any chance of every recovering back from the NBN investment I am certain that our children's children will still be complaining about the stupidity. Not that the bonds market are complaining.

The obvious and easy answer is to encourage two companies to achieve certain diluted measurable outcomes, it is not impossible. A commercial view to rollout will alter the end result and achieve very similar productivity outcomes. Sure both companies should be equally funded by the government at a much smaller amount and allow them to create true competition and true choice. This will also in my view result in a faster rollout and better resources for all. Sure the NBN co can go and rollout services in remote areas as this is a social responsibility of the government. But let businesses run business not bureaucrats and the government fulfil their social responsibility.

I would estimate that with a fraction of the suggested public funding and new government enforced network consistency standards imposed by the government, that reliable fast speeds can be delivered in short term to over 75% of the population within the 8 years and that public debt could commence being repaid. This would also introduce redundancy to the node (seemingly overlooked to date). But I would guess that that horse has bolted already.

The government should be actively encouraging a competitor to the NBN not trying to destroy one.

Even small issues have been overlooked that has significant risk of altering outcomes and budgets. One example is:

As a director of a SP and looking at the intended delivery models I am a bit confused as to the following:
a)	Having the NBN service theoretically appearing to be an always on service and
b)	With easy porting to another reseller at very short notice by switching to another resellers aggregation circuits
c)	Together with the vast arrays of different delivery technologies (seemingly incorporating unapproved VDSL technology, thanks to Telstra, in Multi Dwelling Units MDU's)

Who will be responsible for the CPE? If it is the NBN co how much will that cost for ongoing replacement, damage, theft, etc.. if it the reseller then (a) is not possible, if it is the end user then what happens when they move to another location that requires different CPE due to circuit type?

Will the NBN be delivering into the dwelling or terminating at the property boundary like most other services in most states (gas, water etc). Who will pay for the final delivery from the property boundary to the CPE? Who will be liable for future damage to fibre if there are issues within the boundary of a premises. Can the NBN just access your property if they want and dig up your property? Will they be able to enforce easements over owners of fixed property?

In MDU's who will be managing the access concentrators? What about real world operational issues (heat, security, environment, space to install, poor power feeds, providing power to the access concentrators etc...) or will the buildings be forced to buy and maintain these devices that they will not be able to control or have the skill to?

If the NBN co do not buy the existing exchanges from Telstra or sign very long access leases and rather decide to introduce their own mini pop's bypassing the Exchanges, the NBN will destroy Telstra as they are today. I am not a shareholder in Telstra, but if I was I would be rethinking my position as the legacy services of copper as the last mile will have to become extinct leaving a very debt laden company in ruin, what is the real net employment position of all those "new jobs" the NBN is supposed to be creating?

I generally agree with many of the other commentators opinions and observations. I do however wish the NBN Co well, but I would bet my house on this either costing over twice what they intend (when has the government ever come close to delivering to budget on large projects) or will become a very expensive huge white elephant. Just look at the achievements of the Department of Broadband and the Digital Economy and how well they handle their budget and outcomes. Two years up and not much outcome, the proposals I have seen to date seem to come from an Alcatel product brochure :) .

The Public Sector just can't achieve the outcome at the price needed.

I do wish them luck and hope that they are successful for all our sakes.

Stephen Carter
Working Technology 
Level 20
31 Market Street - Sydney - 2000 
Tel: 02 9475 7777 - Fax: 02 9475 7788
Internet: www.workingtech.com
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Stephen Carter
Working Technology
-----Original Message-----
From: ausnog-bounces at lists.ausnog.net [mailto:ausnog-bounces at lists.ausnog.net] On Behalf Of Mark Smith
Sent: Tuesday, 9 February 2010 6:42 PM
To: Narelle
Cc: ausnog at ausnog.net
Subject: Re: [AusNOG] reminder on submissions to NBN Co, Comms Alliance and DBCDE....

On Tue, 9 Feb 2010 15:04:02 +1100
Narelle <narellec at gmail.com> wrote:

> I promise I will make a comment on addressing or technical reasons for
> my favourite kit soon, but in the light of all the politics that has
> gone on lately, it seems timely to remind folks that a few submissions
> are due this week...
> Responses to the government's filtering paper: see
> http://www.dbcde.gov.au/funding_and_programs/cybersafety_plan/transparency_measures
> due 12 Feb
> NBN Co's product paper: see
> http://www.nbnco.com.au/events.aspx
> due 12 Feb
> Comms Alliance's End User Premises Handbook: see
> http://www.commsalliance.com.au/Activities/national-broadband-network
> due 12 Feb
> ISOC-AU is intending to submit to all three, but if anyone would like
> to further inform our submission, please send me email either here or
> at the address below.
> Vague, ill formed thoughts are welcome. 

Happy to provide some of those ;-)

Having a brief look at the CA wholesale services, I feel that some of
them are vulnerable to the same problems the industry has with Telstra
having both wholesale and retail service goals, specifically the 

o  Point-to-Point Protocol (PPP) / Layer 2 Tunneling Protocol (L2TP)
o  Application Service Provider (ASP) Internet Protocol (IP) 

services, out of Wholesale Services list of :

o  Layer 2 Ethernet NSP Wholesale Access
o  Layer 2 Ethernet NSP Wholesale Backhaul
o  Layer 2 Ethernet NSP Multicast
o  Point-to-Point Protocol (PPP) / Layer 2 Tunneling Protocol (L2TP)
o  Application Service Provider (ASP) Internet Protocol (IP) 

Rather than going into specifics of these services, I think it's better
if I describe what I think the NBN is supposed to be achieving:

o  it's fundamental and primary goal is to replace the existing copper
telecommunications infrastructure, namely the copper local loops, and
the exchanges they are aggregated in. The primary drivers for that
replacement are financial costs of maintaining it (or expanding it),
and technological limitations on further increasing the bit rates
available over it.

o  for Service Providers who have invested in networking
infrastructure that is specific to the the legacy copper network
e.g. DSLAMs, it should therefore provide them with some form of
compensation for "destroying" that existing opportunity. That doesn't
just mean financial compensation for decommissioned equipment (and may
not). I think it also means compensating them by creating new
opportunities for them to create new and different value, to replace
the value they added by taking the risk of investing in their own
DSLAMs, and therefore creating a competitive telecommunications market.

o  Those new opportunities for existing or new Service Providers
should be provided by both:

-  minimising overlap between what the services the NBN provides to
  Service Providers. Another way to look at this is that the NBN
  shouldn't get into it's customers' business. Providing services to
  your customers and your customers' customers creates incentives to not
  provide the best services to your direct customers. In a monopoly
  resource situation, such as the one that is going to be created with
  the NBN, I think it is essential that a supplier cannot provide
  services to customers' customers.

-  providing as much service provider facing flexibility possible, to
  provide them with as many innovation choices or opportunities as
  possible that they can implement themselves. As much as possible,
  their service innovation shouldn't be constrained by the NBN and it's
  technology or service choices.

So in summary, I think the NBNs scope is (or should be) limited to:

o  replacing the existing copper network infrastructure with more future
proof performance and capabilities (i.e. flexibility)

o  not getting into it's service provider customers' business, by
avoiding selling services to their customers

o  providing as many opportunities for innovation as possible to it's
service provider customers

I think the NBN providing Ethernet services, as per the first three
items on the CA's wholesale list suit those requirements.

As for the latter two, I don't think it is necessary for the NBN to
provide them. According to Whirlpool there are at least 227 ISPs in
Australia. Any of those ISPs, or new non-existent wholesale service
providers, could use the NBN's Ethernet services to provide those
services to the market. By not having the NBN provide those services,
we avoid:

o  NBNco also being in it's customers' business. 

o  NBNco using it's huge layer 2 equipment and other service purchasing
power to negotiate layer 3 equipment discounts (e.g. on routers, LNSes
etc.) better than anybody else in the industry can get.

o  Reducing the business opportunities for organisations that have
helped create a competitive telecommunications market in Australia.

Anyway, as requested, there are some "Vague, ill formed thoughts" :-)

> Well argued, intelligent
> commentary would be appreciated, and even potentially cited.
> All the best
> --
> Narelle
> vice-president at isoc-au.org.au
> _______________________________________________
> AusNOG mailing list
> AusNOG at lists.ausnog.net
> http://lists.ausnog.net/mailman/listinfo/ausnog
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