Twitter stream summary of NBN Implementation Study

Last Thursday the Australian Government finally released the much heralded McKinsey/KPMG NBN Implementation Study. Costing the Government roughly $25million and taking over 9 months to prepare, the final report weighed in at just over 500 pages and almost 3Mb in size (which brings it close to being worth roughly $1 per bit). This post is just the raw tweets stolen directly from my live twitter stream (#nbnis). A more traditional critique will be forthcoming soon. Stay tuned for more.

Chronological (reversed order) dump of twitter-stream (#nbnis):

miscx #nbnis Walkthrough highlights commentary of KPMG McKinsey NBN Implementation Study http://bit.ly/dvpSWn
miscx #nbnis Report is intended to guide govt to manage NBN Co and market through policy. Report is not intended for any other persons or use.
miscx #nbnis Pg54 Coverage objective. 100% broadband coverage, 93% at 100Mbps (ftth) and 7% at 12Mbps minimum rates (wireless and satellite)
miscx #nbnis Coverage recommendation 93% fibre, 7% satellite (rural) with a separate tender for 4% coverage overlap/alternative via fixed wireless
miscx #nbnis Pg56 NBN Co to consider needs of consumers, businesses, public institutions, service providers, employees, suppliers and partners.
miscx #nbnis Pg59 Govt "national wholesale-only, open-access network" turned into "platform for service providers to compete on level play field"?
miscx #nbnis Pg60-61 Access and backhaul are bottlenecks. NBN Co to build only where necessary. No overbuild, no need for end-end nationwide net.
miscx #nbnis Pg61-65 NBN Co recommended to provide 'coverage' independent of 'connections'. Former is reqd deployment, latter is takeup driven
miscx #nbnis Pg66-67 Defining premises and addresses. Explicit inclusion of schools. Excludes things like ATMs, unoccupied monitor stations etc
miscx #nbnis Pg68 12.7 million addresses in G-NAF (geocoded national address file), est .10.7 million premises, growing by 1.3 million over 8yrs
miscx #nbnis Pg71 Recommendation to allow NBN Co to serve non-premises selectively where commercially viable
miscx #nbnis Pg73 Expectation is that competitive layer-3 nationwide providers will establish themselves utilising NBN Co and other assets
miscx #nbnis Pg73 NBN Co to facilitate competition by "leveling the play field", "reducing costs to reach users" and "averaging access prices"
miscx #nbnis http://bit.ly/aR7RCO http://bit.ly/cDSeJz http://bit.ly/c6dpT5 http://bit.ly/b9btuN strongly critique "level playing field" benefits
miscx #nbnis Pg74 Avoid 'swiss cheese' gaps in deployment. When constructing an area, ensure all premises are covered regardless
miscx #nbnis Pg76 OnsNet Netherlands example where community funded fibre rollout themselves. NBN Co should promote/support similar here
miscx #nbnis Pg79 66% of buildings are single premises, 11% 2-5 premises, 12% 5-25 premises and 11% are 25+ high density premises
miscx #nbnis Pg82 NBN Co should be granted 'right of access' powers to multi-dwelling buildings to ensure coverage. FTTP, not FTTB recommended
miscx #nbnis Pg88-97 NBN Co to fibre up and own infrastructure for greenfields (where appropriate). Extensive recommendations.
miscx #nbnis Pg98-100 Process for monitoring and reporting coverage progress by NBN Co
miscx #nbnis Pg101 NBN must ensure bottlenecks are removed, must accommodate innovation and growth, must ensure maximum flexibility
miscx #nbnis Pg102 NBN to secure rights to essential network assets and to encourage market entry by facilitating open access. Level? or fair?
miscx #nbnis Pg102-104 Support for growth in activations, bandwidth demand and provide flexibility for innovation in services
miscx #nbnis Pg105-108 Discussion on allowing use of HFC as an interim only technology towards FTTP. Implications for Telstra/Optus assets
miscx #nbnis Pg109 Encourage early and rapid takeup through uniform (nationwide) and competitive pricing. Focus on uptake not profitability.
miscx #nbnis Pg113 Migration of services considered under both a co-operate and compete model against Telstra copper network
miscx #nbnis Pg114-118 Support for POTS (phone), including lifeline and emergency, lawful intercept and law enforcement services
miscx #nbnis Pg118-120 Assessment of USO, including options to leave with Telstra, reestablish through tender or create 'retailer of last resort'
miscx #nbnis Pg122-123 Estimate 9mil individuals spending $1000 pa, 700k small business $6000 pa, 3k enterprises $1.3m pa & 12k other $160,000 pa
miscx #nbnis I think consumer group should have been broken out into Power Users (vpn+), General Users (3-play) and Basic Users (pots, Internet)
miscx #nbnis Pg129 Recommendation for NBN Co engagement charter to include "commitment for consultation with industry and end-user groups"
miscx #nbnis Pg132 NBN to focus on layer-2 services for fttp and layer-3 for wireless footprint
miscx #nbnis End user revenue has grown by 5%pa, broadband subscribers have grown by 51%pa and fixed-voice services are down by -1%pa (2004-2009)
miscx #nbnis Pg136 Internet activity in Australia, 2004 1.2Gb per user per annum, 2009 11.9Gb per user per annum (+58%pa growth). Still low!
miscx #nbnis Pg136 Marginal cost per Gb for Internet data, ranging from $0.35c on TPG to $1.19 on Telstra
miscx #nbnis Pg137 "Current usage caps for fixed-line broadband packages in Australia are amongst the most restrictive in the world" - I concur
miscx #nbnis Pg139 Example new svcs include 3DTV, interactive TV, HD video conferencing, virtual reality gaming, medical diagnostics etc
miscx #nbnis Pg141 See only 3 svc delivery models. Over-the-top (Internet), Specified-Bitstream (RSP), Wholesale-Bitstream (ASP). Bit limiting!
miscx #nbnis No mention made to multi-QoS tiering, end-to-end QoS services. See that "NBN unlikely to capture" any new revenue. This can be fixed.
miscx #nbnis Pg143 See that NBN service offerings can only be differentiated by layer in stack and geographic extent (point of interconnect)
miscx #nbnis Misses all discussion of bandwidth and other possible performance characteristics in addition to logical layer and physical POI
miscx #nbnis Pg145 See fibre footprint as having a trade-off between enabling greater competition (lower entry barriers) and enabling innovation
miscx #nbnis Why the assumption that a single solution must be found to address all players equally. Other markets do not adopt this approach.
miscx #nbnis Other markets establishing wholesale national broadband providers focus on offering multiple product choices on a best-fit basis.
miscx #nbnis Pg149 QoS mentioned as useful to differentiate svcs but is then ignored on the basis that "layer 2 is still relatively unproven ..."
miscx #nbnis Pg150 Discussion on opportunities to move beyond 100Mbps to 1Gbps
miscx #nbnis Pg152 Recommendations for NBN Co to offer layer-1 for optimal market performance longterm and layer-3 if there is market failure
miscx #nbnis Pg153-165 Video delivery discussion. IPTV (recommended and favoured), RF-overlay (supported if shared) and Internet-OTT (default)
miscx #nbnis Pg160 Supporting IPTV requires layer-3 multicast support and QoS capabilities
miscx #nbnis Pg163 metered data could limit OTT video services, IPTV platforms need a scale of 1m+ users to achieve a $70-100 capex cost per user
miscx #nbnis Pg165 IPTV market in Australia has issues. Few content channels (US have 100+), low penetration (<30%) and high prices (1.8 US avg)
miscx #nbnis Pg165 "Unless the content obstacles change, it is not likely that the NBN will enable another ... Foxtel or Austar to enter the market"
miscx #nbnis Pg166 e-Government services discussed including e-education, e-health, smart infrastructure and online services.
miscx #nbnis Many e-government services could be provided over some layer-3 wholesale provider (natural or govt established)
miscx #nbnis Pg172 "Government should aim to work with NBN Co and service providers to develop .. discounted services" for various institutions
miscx #nbnis Pg177 High level reference network diagrams. NBN Co to provide access network and intervene to provide targeted competitive backhaul
miscx #nbnis Pg182 Guidelines for network architecture. 'Design Passives' to support longterm futures and 'Deploy Actives' to support 100Mbps now
miscx #nbnis Analysis of fibre deployment architectures. Home-run (which is essentially a dedicated fibre per home) vs Shared (PON network)
miscx #nbnis Pg188 "Geospatial modeling indicates a home-run topology covering 50% ... adds about 5% to the overall ... investment"
miscx #nbnis Pg191 They "modeled a mix of 50% home-run (p2p) and 50% shared" and "believe that this mix is achievable". NBN Co concur.
miscx #nbnis Pg192 NBN Co should adopt the most cost effective deployment approach area by area (aerial, trenched, ducted, duct re-use)
miscx #nbnis Pg193 Assessing GPON versus Ethernet P2P. Recommendation is to consider offering a mix. NBN Co plan to offer GPON.
miscx #nbnis Pg195 GPON has much better future performance characteristics via 10GPON (up from 2.4Gbps) and WDMPON (another fourfold gain)
miscx #nbnis Pg196 Looking at services layer. Recommend offering ATA-voice and Layer-2 during build and add dark-fibre unbundling post build
miscx #nbnis Pg197 Service parameters include Point of Interconnect (network side), Point of Termination (user side) and data link specification
miscx #nbnis Pg198-199 Recommendation that entry level product be at least 20Mbps. Indicate that upsell based on speed is not market efficient
miscx #nbnis Pg199 Noted that "Price differentiation is an important mechanism for network businesses to optimise revenues and demand"
miscx #nbnis Think that the only price differentiation opportunity is headline speed or rate! I think a visit to http://bit.ly/9utB1B is in order
miscx #nbnis Pg201 Recommendation to offer pure voice (POTS replacement) service independent of data services to support retiring of copper nw
miscx #nbnis Pg201 Say "NBN Co will have to enable higher levels of performance, through QoS parameters" yet fail to illustrate how. Need help?
miscx #nbnis Pg202 Require NBN Co "to offer wholesale services that support the implementation of carrier grade QoS" so RSPs can offer premium svc
miscx #nbnis Admit that they are unsure as to how to achieve this requirement. Again, I think a read of http://bit.ly/9utB1B would help greatly
miscx #nbnis Pg203 Recommendation that NBN Co engage with Enterprise and Government to understand non-consumer requirements (secure, big links)
miscx #nbnis Pg205/6 70% of deployment costs will be civil works, 13% will be fibre plan, 8% exchanges and 9% will be ONT (shoebox on premise)
miscx #nbnis Pg207/8 Marginal cost curve shows the knee point is approximately at 90% penetration and the rapid diminishing returns point is 93%
miscx #nbnis Pg209 Uniform pricing seen as possible given cost curve, competitive backhaul transit and via leverage of migration incentives
miscx #nbnis Pg209 Risks are to ensure NBN Co business case remains vaiable and to prevent damage from 'cherry picking' competitors
miscx #nbnis Pg214 Maximum aerial deployment is estimated at 72% (based on aerial power), target is estimated at 55% based on assumed bad poles
miscx #nbnis Pg215 "It is not assumed that the NBN Co utilises existing exchanges". NBN Co will build their own. Telstra take note and others too
miscx #nbnis Pg216 Estimated per-user OLT (network side) cost is less than $100, cabinet costs are around $30
miscx #nbnis Pg217/8 Recommendation to try to co-operate with utilities (power) during rollout but notes that such efforts have no precedent
miscx #nbnis Pg219 Recommendation based on international experience and cost to deploy ONT (premise shoebox) internally, not externally!
miscx #nbnis Interesting challenge. If NBN Co can cooperate with utilities to save costs, outdoor unit makes sense, else indoor unit only option
miscx #nbnis Pg220 Estimated cost to connect home is $500. A migration incentive of reduced connection costs ($300) can be used initially
miscx #nbnis Pg222 Claim that "The geospatial modeling is detailed and rigorous"
miscx #nbnis Pg229 Fixed-voice line penetration in Australia is still at 87% (EU is 50-60% in favour of mobile)
miscx #nbnis Pg230 Historically voice has been anchor for fixed line, broadband is now expected to be the anchor. Mobiles, VoIP etc blamed
miscx #nbnis Pg233 Mobile broadband seen as complementary to fixed broadband
miscx #nbnis Pg234 "Australian fixed-line broadband services are slow, expensive and usage constrained when compared with international peers"
miscx #nbnis Pg234 among the OECD our "services are third slowest, prices seventh highest and usage 'caps' are the norm". Only 4 countries 'cap'
miscx #nbnis Pg244 suggests "take-up rates in the range of approx 6-12% of homes passed per annum can be achieved and sustained" (well until 100%)
miscx #nbnis Pg248 "as fibre penetration increases, the economics of Telstra's copper network will deteriorate" forcing a migration regardless
miscx #nbnis Pg253 Create a robust revenue model by "setting initial price levels" and "pragmatically increasing avg prices over time"!!
miscx #nbnis Moore's law often means "faster, better, cheaper". Why is NBN Co going to be "faster, better, more expensive over time"???
miscx #nbnis Pg254 "gradually increasing prices over time" due to "relative value of fibre" growing to increase "NBN revenues" No growth drives $$
miscx #nbnis Pg254 Trajectory achieved by "new or higher priced services" (Yes) "or a price increase on basic services" (No)
miscx #nbnis This is why it so important to understand how to offer and price multiple tiered services (QoS) into the market to drive revenues
miscx #nbnis Pg255 admits that the mechanisms for driving increased revenue opportunities through premium services is not understood at all well
miscx #nbnis Pg256 "Pricing decisions are dynamic and challenging. They are best left to the company (NBN Co) ..." NBN Co also have no answer!
miscx #nbnis Pg257 Provides a good list of opportunities "Price differentiation", "commercial terms and charges", "bundling" (tying), "fixed" rent
miscx #nbnis Plenty of good overview and high level recommendations for managing pricing but no or very little concrete guidance
miscx #nbnis Pg255 "ensure entry level services continue to uphold the NBN requirement for take-up and affordability"
miscx #nbnis Pg257 support NBN Co "price differentiation (except where it is based on geolocation) ... that are consistent with equivalence"
miscx #nbnis Pg257 broad agreement that "price differentiation in telecommunication ... is appropriate to achieve social benefits" and "returns"
miscx #nbnis Pg257 "the alternative ... a single price--would be inefficient" No price to balance returns and take-ups could be found
miscx #nbnis Pg258/259 Is a summary of price differentiation approaches only. For solutions see http://bit.ly/9utB1B http://bit.ly/bu1zyi
miscx #nbnis Pg260 "NBN Co avoid usage-based wholesale pricing for uncontended services in the long term" or at least be world comparable
miscx #nbnis Pg261 "NBN Co ensures general pricing for NBN services is transparent and modular" Bundling and tying should be avoided
miscx #nbnis Halfway point - I'm taking a break, check back later for the rest (Monday) - Michael
miscx #nbnis Part-II: Walkthrough highlights commentary of KPMG McKinsey NBN Implementation Study http://bit.ly/dvpSWn
miscx #nbnis Pg271 91% of Au landmass empty, 0.2% contains 90% of pop, 0.3% contains 91%of pop. 3.7% contains 99% of pop. 9% contains everyone.
miscx #nbnis Pg273 Broadband DSL currently reaches 92% of pop. Telstra 3G wireless broadband reaches 99% of Pop. Optus 2G=98%, 3G <90%.
miscx #nbnis Pg274 4G Wimax or LTE analysed. 12Mbps requires proximity of 1-2kms to transceiver typical (no better than DSL) or 7-14kms max.
miscx #nbnis Pg277 Nextgen ka band satellites offer 10x bandwidth over existing Optus/IPSTAR ku band. 2x55Mbps GEO birds could cover 350k homes.
miscx #nbnis Pg278 Satellite life expectancy is 15years. Pg279 has great comparison graph of fibre vs wireless vs satellite costs/coverage.
miscx #nbnis Pg280-282 Conclude that fibre to 93%, wireless to 97% and satellite to remaining 100% is recommended balance
miscx #nbnis Pg282/3 Approx 400k homes are close to existing copper exchange outside fibre area. Could re-purpose DSL to serve and backhaul
miscx #nbnis Pg285 Estimates of traffic growth/patterns. Video to be 91% of traffic, APAC 42% annualised growth, current user avg 2-5gb pcm
miscx #nbnis Pg292 Satellite Technologies: LEO cannot support BW reqmt, MEO is untested??, GEO is considered as only choice despite 500ms latency
miscx #nbnis Pg293 Recommend two 100Gbps ka band GEO satellite, offset by 2 orbital degrees from each other, load balanced with degraded failover
miscx #nbnis Pg293 Recommends dimensioning satellite to max 12Mbps and average 300-400kbps (up from todays 10kbps for existing services)
miscx #nbnis Pg297 Recommendation that a satellite service be offered as a Layer-3 service, not at layer-2 like the fibre and wireless
miscx #nbnis Pg300/1 Recommendations for govt to increase costs coverage through ABG to drive uptake of nextgen services
miscx #nbnis Pg307 Assessment of 2.3GHz spectrum versus 700MHz (analog TV). 2.3 is available for immediate use, 700 is more cost effective
miscx #nbnis Pg308/9 Recommend backhaul be implemented to address wireless POIs and that interconnect be offered to others on an open fair basis
miscx #nbnis Pg313 Analysis of indoor versus outdoor 12mbps wireless coverage estimates that 80% of those households will require external antenna
miscx #nbnis Pg314 Recommendations for minimum wireless service intended to drive uptake. Offer basic 4Mbps with an upsell option to the 12Mbps
miscx #nbnis Pg315 Study indicates that cost-plus pricing is difficult due to distortion from govt subsidies and other complexities
miscx #nbnis Concludes that retail-minus pricing strategy is preferred for wireless fixed broadband services
miscx #nbnis Pg314 Benchmark pricing for wireless spectrum established by AUSTAR offering to sell 2.3GHz spectrum to OPEL for $65million
miscx #nbnis Pg316 Recommendation to modify existing wireless spectrum conditions to ensure carriers build rural and metro and offer at same price
miscx #nbnis Pg317 Discussions with industry indicated that existence of competitive backhaul was a key requirement to drive build outs into rural
miscx #nbnis Pg317 Govt recommended to require NBN Co to build backhaul and offer open connections to existing and new wireless transmitter sites
miscx #nbnis Pg319-320 USA Telstra copper access network provides voice to 99.75%. Remaining 0.25% use radio and some satellite (Iridium)
miscx #nbnis Pg321 HD-Voice for mobiles, spectrum sampled and encoded from 50Hz-7KHz for more natural voice, uses 12.65kbps versus legacy 12.2kbps
miscx #nbnis Pg326 Defines backhaul. International capacity, Intercapital transit and Community reach (getting to the 5000+ community exchanges)
miscx #nbnis Pg326 Existing community backhaul costs are high due to duo/monopoly pricing, build costs and conflicts from vertical integration
miscx #nbnis Pg327 Notes that 20% of service costs can be taken up by backhaul
miscx #nbnis Pg328 Backhaul is a natural monopoly: High upfront sunk costs, cheap upgrade capability and small demand/coverage
miscx #nbnis Pg329 Summary of several issues associated with regulating the prices/access to backhaul transit capacity
miscx #nbnis Says choosing service to regulate is difficult but fails to justify appropriately. For instance dark fibre argument is very weak.
miscx #nbnis Other points valid such as trending towards LRIC regulation across backhaul, one-size-fits-all is bad and risk of gaming is real
miscx #nbnis Pg330 Estimates about 70,000 kms of backhaul required to interconnect all fibre and wireless areas to POIs with 2 or more providers
miscx #nbnis Pg331 Estimated total backhaul construction cost is$3.5billion
miscx #nbnis Validity of "competitive backhaul is assumed to coincide with DSL entry by providers other than the incumbent" in existing exchanges?
miscx #nbnis Pg332 Recommendation for NBN Co to seek guaranteed access to dark fibre assets in preference to overbuilding
miscx #nbnis Pg333 Needs of evolving industry "will require creating a level playing field", "NBN Co will need to carefully choose POI locations"
miscx #nbnis No Government mandate for a "level playing field", this has been an industry creation to allow handicaps for inefficient players
miscx #nbnis "Level playing field" is a figurative invention of corporations. It is an often abused and overloaded 'feel-good' phrase to divert $
miscx #nbnis http://bit.ly/aR7RCO http://bit.ly/cDSeJz http://bit.ly/c6dpT5 http://bit.ly/b9btuN strongly critique "level playing field" benefits
miscx #nbnis http://bit.ly/c2kjnh is a good historic review of the origins of the phrase "level playing field", now relegated to industry jargon
miscx #nbnis Pg334 Recommendations for ongoing evaluation of backhaul competitiveness and POI location
miscx #nbnis Pg334 Recommendation that backhaul service should be modular (not bundled) and end-to-end (aggregate, not per svc)
miscx #nbnis Pg335 This misdirection inevitably leads to implementing a replacement monopoly, placing NBN in breach of the WTO and reducing takeup
miscx #nbnis Pg335 Target backhaul cost component is estimated at 10% of retail service cost for entry level products
miscx #nbnis Pg336 Formal recommendations regarding backhaul and POI. Agree with point 1 and 2, strongly disagree with point 3 - will update later
miscx #nbnis Pg337 "Level playing field" target becomes all-pervasive. Now driving argument for linear pricing (no-economies of scale benefit)
miscx #nbnis Avoiding abusive distortion is to be commended but not at the expense of passing on economies of scale benefits to end-users
miscx #nbnis Pg339 "level playing field" approach now introduces problems preventing future privatisation of backhaul. Complex analysis of options
miscx #nbnis Pg341/2 More analysis of problems caused and also some good recommendations, that can still be offered without the current complexity
miscx #nbnis Pg346 Reports recommendation is to provide fibre to 93%, fixed wireless to the 94-97% and satellite to the 98-100% for $42.8billion
miscx #nbnis Pg350 Study estimates NBN Co to hire 1000 staff for network design, project mgnt, procurement and contract mgnt during rollout phase
miscx #nbnis Pg351 Estimate is conservative. $5B savings if ducts, pits etc shared; assumes increasing costs, no scale benefits, non-optimised
miscx #nbnis Pg356 The fibre access network alone is expected to provide 95% of NBN revenue (93% coverage). Not bad
miscx #nbnis Pg357/8 OPEX for NBN CO is expected to be $1B (35% lease, 65% staff and maintenance). Active components 5-10yrs, passive 40+ yrs
miscx #nbnis Pg359 Worst-case analysis of performance indicates a 3.6% return, best-case upto 8.3%. Low numbers for high risk, but still positive
miscx #nbnis Pg361 Pragmatic recommendations to accommodate model innacuracies. Respond to market by (de)accelerating rollout to match take-up %
miscx #nbnis Pg362-4 Set of policy change recommendations to prevent third parties from preventing NBN Co deployments where impacts are minimal
miscx #nbnis Pg367 "appropriate funding model for NBN Co is one in which the Gov achieves its policy objectives and uses it resources efficiently"
miscx #nbnis Returns rate and risk of NBN Co make it difficult to attract or even justify private sector equity (look for 9-25% returns)
miscx #nbnis Pg370-1 Further recommends avoiding private equity as that would focus NBN on delivering commercial gains not govmnt policy outcomes
miscx #nbnis Pg373 NBN Co could in the middle stages acquire private sector debt which could help to ensure an more robust business case
miscx #nbnis Pg377 NBN Co would likely require more funds that Australia's debt markets could provide. International debt markets may be needed.
miscx #nbnis Pg381 Conditions that apply for NBN Co as a Government Business Entity, note the competitive neutrality means playing by common rules
miscx #nbnis Pg383 Study notes that grants and/or subsidies shouldn't be required!
miscx #nbnis Pg385 Nice graph showing the cycles in Australian equity funding. 2008 was a low (like 2001), next peak expected around 2012.
miscx #nbnis Pg387 wait till NBN Co have "stable business model...proven track record...stable regulatory regime...clear governance structure"
miscx #nbnis Pg389 "Separating NBN Co into Active and Passive companies could make privatisation easier"
miscx #nbnis Pg390 A full IPO of NBN Co post rollout would be an ASX 20 company worth an estiamted $41Billion
miscx #nbnis Pg392 Separation would however have tax considerations (such as stamp duty on transferred assets)
miscx #nbnis Pg393 Recommendation to establish a stapled trust to hold NBN Co assets prior to any asset acquisition to improve attractiveness
miscx #nbnis Pg404-5 Government guarantees would essentially derisk NBN Co but would need to be managed carefully to not be inappropriate for GBEs
miscx #nbnis Pg406-9 Careful management of funding required to ensure policy mandates are met in a commercially responsible manner
miscx #nbnis Pg415 Summary of equivalent risk profile companies to final NBN Co
miscx #nbnis Pg417 Build NBN & transition industry 2009, Prepare for privatisation 2018, Sustain a world class competitive telco industry 2035+
miscx #nbnis Pg419 "NBN Co's open-access, wholesale-only status is not sufficient to preclude development of adverse competition scenarios"
miscx #nbnis "Concentration of ownership in backhaul... can stifle market dynamics... limited investments in infrastructure can stifle innovation"
miscx #nbnis Pg420 "the full extent of the innovation (long-lifespan infrastructures) would unleash has never been accurately predicted"
miscx #nbnis Pg424 "choices today that limit the range or bias the (...) models can distort the natural evolution of a healthy competitive market"
miscx #nbnis Pg425 Overview of market risk areas: Backhaul, interconnect, layer-3 market, content concentration and retail margin erosion.
miscx #nbnis "if Telstra is granted access to connect below NBN Cos POI ... it will gain a cost advantage" which could then be passed to end-users
miscx #nbnis Backhaul can be made more competitive "by permitting NBN Co to provide additional backhaul links". I agree, additional, not replaced
miscx #nbnis Pg426 "NBN Co's intervention in the transit backhaul market is likely to drive further third party investment in the Layer-3 market"
miscx #nbnis Pg427 "It is reasonable to expect...wholesale layer-3 providers will emerge--either as standalone businesses or as wholesale arms..."
miscx #nbnis Pg428-9 Recommendations to carefully monitor emergence of competitive layer-3 wholesale providers or have NBN Co intervene about
miscx #nbnis Pg431 Commodity price war risk can be mitigated by ensuring a "portfolio of layer-2 Ethernet products" are available for innovation
miscx #nbnis It is desirable to allow "scope for premium service providers to differentiate themselves from low-cost operators" of best-effort IP
miscx #nbnis Pg436-8 Various competition model case studies from Portugal, Japan and Singapore
miscx #nbnis Pg439 "The creation of a single national open-access ... access network is economically efficient, as it avoids wasteful duplication"
miscx #nbnis "Competing networks will erode the economics of NBN if allowed to cherry pick the most attractive areas"
miscx #nbnis Pg440 "Flexibility to differentiate pricing by service and user type will be important to achieving take-up and usage on the network"
miscx #nbnis active svcs "allows the company to differentiate pricing between a greater diversity of products to maximise penetration and revenue"
miscx #nbnis Pg441 "the Government must consider how to achieve appropriate dynamic outcomes--innovation" at the active layer http://bit.ly/dBQqa3
miscx #nbnis Pg443 NBN Co "must not be allowed to become the central obstacle to competition in the future"
miscx #nbnis Report indicates we must anticipate risk of NBN Co monopoly expanding its scope, operating inefficiently and/or failing to innovate
miscx #nbnis Pg447-450 International examples provided for South Korea, Malaysia, New Zealand and Sweden
miscx #nbnis Pg453 Mandate "An open, transparent and consultative approach will reduce the risk of misalignment and assist more rapid adjustments"
miscx #nbnis Pg454 recommend "subjecting NBN Co to full public transparency (to) apply valuable discipline to (the) company" and rigour
miscx #nbnis Pg457 No need to explicitly address the scenario of "sophisticated end-users" from establishing their "own service provider entities"
miscx #nbnis Pg457 Recommend against NBN Co providing layer-3 "however, in light of representations from some industry" the ACCC should monitor
miscx #nbnis Pg458 Guidelines to ensure Government restrict NBN Co from acquiring any telecommunications retailers in the future
miscx #nbnis Pg459 "The Government recognises that open access and equivalence are an essential part of fair wholesale dealings"
miscx #nbnis "We therefore believe that equivalence should be implemented principally by means of transparency and common availability"
miscx #nbnis Substantial discussion on equivalence and the need to a loose definition as opposed to an actual "all things absolutely equal"
miscx #nbnis Its a pity all this discussion is then rapidly forgotten by Pg 461
miscx #nbnis Pg461 NBN to establish backhaul wherever the market is considered uncompetitive to provide an alternative (keep everyone honest)
miscx #nbnis but then says equality mandates that "NBN Co should not allow access to its network except at points reached by competitive backhaul"
miscx #nbnis There is much confusion between "absolute equality", "level playing fields" and loss of flexibility and stifling of innovation here
miscx #nbnis Report continues "NBN Co should be prohibited from discriminating between customers"=="like services, like terms, like circumstances"
miscx #nbnis Pg461 Many of the issues regarding determining availability of competitive backhaul are resolved if the exclusive approach is dropped
miscx #nbnis Pg462 Recommendation 50, same as before, agree with (1) and (2), strongly disagree with (3). Will cover at http://miscx.wordpress.com
miscx #nbnis Pg462 All service providers take note, NBN Co POIs will not be located in existing Telstra exchanges. Meaning new fibre runs reqd.
miscx #nbnis Pg462 NBN Co to accommodate for RSPs "seeking access to its layer-2,... transit backhaul,... unbundled physical fibre or wavelengths"
miscx #nbnis "It is important to ensure that NBN Co's service offering and pricing architecture are not prejudiced in favour of a particular model
miscx #nbnis Recommendation is to avoid tying, bundling etc and instead adopt an a-la-carte or modular approach for service components
miscx #nbnis Pg463 "a truly innovative and dynamic retail market will be created only if competition is facilitated within the home" (multi ports)
miscx #nbnis Pg463-7 Analysis of cherry-picking risk, avoid by mandating carrier standards of implementation and open-access equivalence
miscx #nbnis Pg471 Recommendation that the Government ensure that NBN Co can and will unbundle at the passive layer in a competitive manner
miscx #nbnis Pg471-5 Recommendation that NBN Co demonstrate support for physical unbundling and the ACCC regulate the unbundling
miscx #nbnis Pg476-8 Recommendations to ensure healthy privatisation (not another Telecom), including support for structural separation in future
miscx #nbnis Pg479 Explicit recommendation to keep backhaul assets and services in the public hands, potentially a non-issue if POIs are inclusive
miscx #nbnis Pg482-491 Recommendations and analysis of other entities with regard to restrictions on domestic and international ownership levels
miscx #nbnis Pg492 Recommendation for NBN Co to support mobile backhaul transit services unless prohibited by the Government
miscx #nbnis Pg496 The "rapid pace of the planned roll-out of the NBN makes it critical that NBN Co develops a comprehensive corporate plan"
miscx #nbnis The plan "will provide a mechanism for Govt to verify that plans are consistent with Govt's objectives and to identify issues"
miscx #nbnis Pg498-9 Details recommending content and elements that should be in the initial plan
miscx #nbnis Pg500-1 Recommend a governance model that addresses the unique start-up nature of NBN Co and the high pressure to achieve outcomes
miscx #nbnis "NBN Co will seek rapid policy guidance and, if it is not forthcoming, will respond with indecision ... or its best judgement"
miscx #nbnis warns that "timely intervention (may) be compromised, especially given the technical complexity of many of the issues"
miscx #nbnis Govt need ppl "with sufficient depth of expertise..., sufficient confidence in the detail that they can challenge NBN Co's positions"
miscx #nbnis Pgs502+ Guide to moving forward on recommendations through legislation, competition, funding, regulation, instruments and expectation
miscx #nbnis I'm done. Hope this was of some help. I'll be refocusing on various key areas through submissions to my blog, NBN Co and to the DBCDE