NBN Regulatory Submission - June 2008
Wednesday, 25 June 2008
The Australian government called for public submissions into the regulatory framework and consumer safeguards that should exist around a future “National Broadband Network” (NBN):
My submission to this regulatory enquiry may be downloaded here:
http://www.simonhackett.com/submissions/NBN-Regulatory-Internode.pdf
This builds on a presentation made at the Comms Day summit in Sydney earlier this year:
http://www.simonhackett.com/submissions/inconvenient-truth-fttn-hackett.pdf
The core thesis of this submission is that the best consumer safeguards result ensuring that the existing competitive access regime and its existing, cost effective ADSL2+ services from many providers continue to be available to consumers in parallel to an NBN deployment, for a minimum transition period of at least 5 years.
This preserves competitive tension - and that, in effect, provides consumers with insurance against a variety of possible challenges and failure modes in the NBN, including escalation in price and reduction in available technical services.
The submission explains why this is technically achievable with technology available today, and why this is important to do. It also contains references to technical proof points (both theoretical modeling and practical testing) that prove coexistence between ADSL2+ from exchanges and VDSL2 from Node cabinets works just fine.
Some have contended in the media of late that coexistance doesn’t work, or that doing so creates interference that limits DSL range severely. This is a bald-faced exercise in ignoring the truth because the truth is inconvenient. The truth is that there is no technical barrier to coexistence. It just needs the correct software settings for the power mask used by the VDSL2 equipment in Node cabinets. Those settings do not significantly impact range or speed.
Accordingly, anyone arguing against coexistence is doing so simply because it suits them to have a monopoly over consumer access, consumer price, and consumer benefit. Their submissions should be viewed in that light.
The crux here is that the NBN isn’t an exercise in propping up any individual company or its share price - its supposed to be an exercise in consumer benefit. Accordingly, delivering consumer benefit, with safeguards to ensure that this occurs, is what matters - ahead of the absolute build price of the network and ahead of who happens to build it.
Given that coexistence of the existing access regime (and existing ADSL2+ competitive services, technologies and price points) with the NBN is both technically feasible and logistically straightforward (and it is), then any future NBN should be evaluated with this as a primary requirement in the name of consumer benefit.
And consumer benefit is the whole point of the exercise... isn’t it?
