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

[Mark Smith]

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
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