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

[Paul Brooks]

Stephen - putting aside your business case and alternative structure for 
a bit (certainly they are important, but they're not something I can add 
value to),
many of your other issues have not been overlooked - they have either 
been sorted, or are actively being discussed and analysed to find the 
best way forward at the moment, within NBN Co itself and within the 
Comms Alliance project.

I don't presume to speak for NBN Co (I CAN speak for the Comms Alliance 
project :-), but most of these things have already been made public 
industry knowledge...


Stephen Carter wrote:
> [big snip]
>   
> 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
>   
correct
> b)	With easy porting to another reseller at very short notice by switching to another resellers aggregation circuits
>   
The role of the service provider is significantly greater than a 
'reseller' as I usually think of that commercial structure, but yes the 
operational group in Comms Alliance is looking at churn/transfer 
processes and B2B IT system interactions with an intention to make it as 
easy as possible
> c)	Together with the vast arrays of different delivery technologies (seemingly incorporating unapproved VDSL technology, thanks to Telstra, in Multi Dwelling Units MDU's)
>   
incorrect - nothing needs to be approved for in-building wiring - VDSL 
is perfectly viable and legal to use today on in-building cabling, and 
is being used in many buildings and by  service providers today. Its 
only in external street plant that VDSL is still not permitted by the 
ACMA code, and we appear to have moved on past the use of copper in the 
external plant. Also, to correct a common misconception, the hiatus in 
the VDSL2 working group was NOT 'thanks to Telstra' - they put a hell of 
a lot of work into trying to get it approved, the breakdown was truly an 
industry-wide effort that many parties need to take on the dubious 
credit for.

I don't see a 'vast array of seemingly different delivery technologies' 
in NBN Co's material. I see optical fibre, terminating on an ONT - that 
optical fibre might be underground or  overhead, and the ONT might be 
located indoors or outdoors, but thats completely immaterial. The 
optical fibre might be a GPON drop, or a direct point-to-point GigE 
line, plus the in-building VDSL2 makes it three delivery technologies? 
three is not such a 'vast array' - and they all end in ethernet ports as 
the customer interface in any case.
> 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?
>   
The ONT is the NBN Co's responsibility. I can't see ongoing 
replacement/damage/theft etc are a big issue - why wouldn't whatever the 
current arrangemnents for HFC NTUs work, or (say) the NTU on a DDS 
service (showing my vintage) - the network arrangements are lardely 
identical. (pedant - the ONT is not CPE, its network equipment - CPE is 
whatever the customer plugs into the ethernet port /pedant).


> 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?
>   
The NBN Co diagram shows they will be delivering to the ONT located 
on/in the dwelling, witha drop-cable from the street passing over the 
property boundary to the building, much like the current copper drop 
cable and HFC drop cables are done (it is FTTP after all, not 
FTTFootpath). Who is currently liable for damage to an HFC drop cable? 
who is currently liable for damage to your current copper phone cable? - 
there is no reason for the fibre drop cable to be treated any 
differently from the current arrangements in all of your issues raised 
here  - unless you think the current arrangements are broken of course.

> 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?
>   
What access concentrators?  Actually, it doesn't matter - NBNCo is 
delivering to each dwelling (either by fibre or copper/VDSL2) in an MDU, 
so any access concentrator, if there was one, would likely be part of 
their network, and their responsibility to feed and water - just like 
for a DSLAM that an ISP installs in a building basement/MDF room today, 
its the ISPs responsibility to maintain/power/cool.

Anyway, to see the current industry (well, the Comms Alliance NBN 
Project working group) thinking on this and much more, Draft NBN End 
User Premises Handbook 
<http://www.commsalliance.com.au/__data/assets/pdf_file/0017/20771/Draft_NBN_End_User_Premises_Handbook_Dec2009.pdf> 
- public comments due by COB tomorrow at CommsAlliance submit public 
comment. 
<http://www.commsalliance.com.au/Documents/public-comment/submit-comments>

We would very much welcome your review Stephen - and anyone else who 
finishes their NBNCo consultation paper response (due on the same day 
:-( ) early!

Paul

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