TELEFÓNICA UK LIMITED RES PONSE TO OFCOM · PDF filerks ica UK Lim consultat Leased Li...
Transcript of TELEFÓNICA UK LIMITED RES PONSE TO OFCOM · PDF filerks ica UK Lim consultat Leased Li...
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onsultations/bus/consultation, Ofcom emphey building blal to the effectets for these sy, efficient androviders.” [§2mber 2008.
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5.
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7.
4 Ofc[§4.2
N CONFIDE
deploym
Etherne
As Ofc
implicat
s response
We hav
the BCM
i)
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iii)
iv)
For eas
in the C
We hav
relevan
com notes tha213 BCMR]
ENTIAL VE
ments are
et backhaul
com itself
tions for com
e
ve structure
MR:
Ofcom’s pr
Ofcom’s pr
Ofcom’s pr
Ofcom’s LL
se of refere
Consultation
ve general
ce to us an
at Ethernet is s
ERSION
driving mo
(both to ba
emphasis
mpetition, m
ed our respo
oposed ma
oposed ass
oposed rem
LCC propos
nce, we ha
ns.
ly restricte
d our exper
seen by mobil
4
bile operat
ase stations
ses, the B
markets and
onse in a s
arket definiti
sessment of
medies
sals.
ve sought t
d our com
rience.
e operators as
tors to dep
but also de
BCMR and
d consumer
similar mann
ons (both p
f SMP
to use simil
mments to t
s particularly s
loy much h
eeper in the
d LLCC h
rs.
ner to the r
product and
ar headings
those area
suited to 4G a
higher capa
e network).4
have impo
running ord
geographic
s to those u
as with spe
applications
acity 5
rtant
er in
c)
used
ecific
NON
EXE
Ove
8.
9.
The
10.
WD
11.
N CONFIDE
ECUTIVE S
erall
We not
price co
BT and
Genera
current
circuits)
some k
e pricing of
The ch
excessi
constra
allows B
Etherne
a speci
1Gbit/s
basket.
DM
We hav
on WDM
wholesa
enable
within s
Openre
availab
build ag
all usin
ENTIAL VE
SUMMARY
te that Ofco
ontrols fram
KCOM’s re
ally, we are
regime (fo
). However,
key issues s
1Gbit/s Ethe
harge contr
ive pricing
ain the ove
BT flexibility
et sub cap i
ific sub cap
circuits se
ve reservati
M products
ale service
multiple p
shared phys
each regime
le only for i
ggregation
g a fraction
ERSION
om has conc
mework rem
espective S
e supportiv
or example
, notwithsta
still remain.
ernet circuit
ol structure
of 1Gbit/s
rall basket
y to price 1
s set at RP
p, we belie
t at no less
ons in resp
(e.g. OSA
e. In partic
roviders to
sical WDM
e which, we
its own use
networks w
n of availab
5
cluded that
mains an ef
MP.
ve of the a
in respect
anding these
We summa
ts
e fails to p
circuits. W
of BT’s E
1Gbit/s circu
PI-RPI. In t
eve that the
s than the
pect of Ofco
, OSEA) wh
cular regula
o provide s
circuits. Th
understand
e. This crea
with these p
ble capacity
t, with some
ffective and
adjustments
t of ECCs,
e adjustmen
arise the ma
protect mob
Whilst the b
Ethernet pro
uits at their
he same wa
ere should
RPI – X lev
om’s propos
hen WDM a
ation of O
services ov
his would be
d, requires
ates a situat
products wo
. WDM circ
e adjustmen
d proportion
s Ofcom pr
RBS, and
nts, we are
ain ones be
bile operato
broad Ether
oducts [ to
current lev
ay that RBS
be a speci
vel of the o
sal to not im
affords grea
penreach
er individua
e in contras
each CP to
tion where
ould build si
cuits would
nts, the exis
nate remed
roposes to
above 1G
concerned
low.
ors against
rnet basket
o RPI], this
vel because
S are subje
ific sub cap
overall Ethe
mpose reme
ater flexibili
products c
al wavelen
st to the cu
o invest in W
CPs wishin
imilar netwo
appear to
sting
dy to
the
Gbit/s
that
t the
t will
still
e the
ect to
p for
ernet
edies
ty of
could
ngths
rrent
WDM
ng to
orks,
offer
NON
Pas
12.
WE
13.
Cos
14.
N CONFIDE
increas
architec
econom
such w
regulati
ssive Acces
We con
or wher
market
Ofcom
access
product
necessa
ECLA
We bel
the WE
st orientation
We ar
requirem
previou
justified
in respe
ENTIAL VE
ing oppor
ctures and
mies of sca
e are conc
ion.
ss
ntinue to be
re not avai
power in th
has expre
remedies,
ts and ser
arily be a ba
ieve Ofcom
ECLA region
n
re concern
ments. We
s BCMR a
d given the
ect of Exces
ERSION
rtunities t
d build st
le can be r
erned that
lieve that p
lable, dark
he Business
essed in re
for examp
rvices. We
arrier to the
m over estim
n.
ed at Ofc
believe th
and that th
history prici
ss Construc
6
to create
rategies e
realised tho
Ofcom pro
passive acce
fibre) affor
s Connectiv
espect of t
ple, the reb
are not c
e introductio
mates the o
com’s prop
his is incon
here is cle
ing well bey
ction Charg
competiti
emerging i
ough sharin
poses to le
ess remedie
rd a real op
vity Market.
he potentia
balancing o
convinced
on of passiv
opportunity
posals to
sistent with
ar evidenc
yond inputs
es and vari
ve altern
n mobile,
ng at wavel
eave these
es (duct an
pportunity to
We note th
al implicatio
of the pricin
any such
ve access.
for greater
remove c
h Ofcom’s
e that cos
(see Ofcom
ous dispute
ative netw
particularl
ength level
products o
d pole acce
o address
e concerns
ons of pas
ng of other
issues sh
r competitio
cost orienta
decision in
st orientatio
m’s conclus
es/ appeals)
work
ly if
l. As
ut of
ess -
BT’s
that
ssive
r BT
hould
on in
ation
n the
on is
sions
).
NON
Ofco
15.
BT
16.
N CONFIDE
om modellin
We pro
efficien
some c
Commitmen
We are
the star
of the n
enter th
believe
ENTIAL VE
ng
opose som
cy assumpt
ontradiction
nts
concerned
rt of the new
new period n
he new char
protection
ERSION
me adjustm
tions in res
ns and the n
that the ga
w controls w
notwithstan
rge control
should be p
7
ments to O
pect of RBS
need for cla
ap between
will permit B
ding its com
period at a
provided to
Ofcom mod
S and Ethe
arity in a num
the lapse o
BT to increas
mmitments.
higher leve
prevent this
delling (for
rnet) as we
mber of are
of the existin
se prices pr
This would
l than other
s.
example,
ell as identif
eas.
ng controls
rior to the s
d enable BT
rwise. We
the
fying
and
tart
T to
NON
OFC
This
17.
18.
19.
Who
Com
20.
6 Trabelow(WDBCM7Andabov8“Cogene
N CONFIDE
COM’S PRO
s section
In this
and Ge
Genera
econom
Alternat
We not
definitio
differen
conclus
connec
Etherne
specific
olesale Pro
mbined mar
We no
backha
voice/ d
appears
services
solution
aditional Interw) and Multi
DM) and otherMR] d we note Ofcve 1Gbit/s. ombined markeral, CPs are l
ENTIAL VE
OPOSED M
section, we
eographic m
ally, we ag
mic markets
tive (AI) or
te that Ofc
ons are sim
nces betwee
sion that the
ctivity and th
et market ca
c market for
oduct defin
rkets exist fo
te that Ofc
ul market
data or TI a
s operators
s, noting “T
ns that wo
rface (TI or Tiple Interface r leased line s
fcom has conc
kets exist forlikely to conti
ERSION
MARKET DE
e comment
market defini
gree with O
s exist on
Multiple (M
om explain
milar to thos
en its 2012
ere are sep
hat a specif
an be distin
r MI product
nitions
for wholesal
com consid
(e.g. carryi
and AI serv
s continue
There is no
uld entail
TISBO), Alter
(MI or MISservices (regar
cluded that it
r wholesale anue to purcha
8
EFINITION
on Ofcom’
itions.
Ofcom’s ap
the basis
I)6), bandwi
ns that, with
se identifie
analysis a
perate mark
fic wholesa
guished. W
ts7.
le access a
ders the p
ing leased
vices). As re
to split n
reported us
TI services
rnative InterfaBO)(Wavelenrdless of inter
is a single m
access and base access and
S
’s proposal
pproach to
of interface
idth and ge
h some ex
ed in the 20
nd that of t
kets for regi
ale Multiple
We believe O
nd backhau
possible em
lines, broa
egards the
etworks us
se of circuit
s being run
face (AI or AIngth Multiplerface type) ab
market for WD
backhaul prodd backhaul tog
s in respec
assess w
e type (Tra
eography.
ceptions, it
007/8 Revie
he 2007/8
ional and n
Interface/ H
Ofcom is rig
ul products8
mergence o
adband, mo
latter, Ofco
sed to deli
t emulation
n over Eth
ISBO) (Etherxed Services
bove 1Gbit/s).
DM and other
ducts, particugether.” [§1.1
ct of Whole
whether dis
aditional (A
ts 2012 ma
ew. The m
Review are
national TI t
High Bandw
ht to consid
8
of a conve
obile and f
om notes th
iver TI and
or pseudo-
hernet.” [§4
ernet – 1Gbit/at any bandw
[§4.52 and
r Ethernet ser
ularly becaus17 BCMR]
esale
stinct
I) or
arket
main
e the
trunk
width
der a
rged
fixed
hat it
d AI
-wire
.175
s and width §4.55
rvices
se, in
NON
21.
22.
23.
N CONFIDE
BCMR]
to disti
evidenc
We con
observa
conclud
being ru
We ag
Backha
were al
a separ
howeve
On the
is theor
limited
ENTIAL VE
. But overa
nguish a s
ce of use or
nsider that
ations of CP
des there is
un over Eth
ree with O
aul. The typ
lways “poin
ration could
er enable Ac
Access sid
retically ava
in practice.
ERSION
ll, Ofcom co
separate a
r demand fo
Ofcom’s as
Ps outside o
no reported
ernet,
Ofcom’s con
pes of TDM
t to point” f
d not exist.
ccess and B
de Openrea
ailable from
9
oncludes th
access and
or separate
ssessment
of the mobil
d use of cir
nclusion on
M link purch
from cell to
The move
Backhaul to
ch remain d
use of Virg
hat at this st
d backhaul
access and
here appea
le industry.
cuit emulati
n historic p
hased for m
mobile swi
to Ethernet
o be disaggr
dominant, a
gin Media fi
tage it woul
market (th
d backhaul)
ars to be ba
For examp
ion or pseud
urchasing
mobile back
tching cent
t in the mob
regated.
although so
bre and mic
ld be prema
here is lim
.
ased in par
le, while Of
dowire serv
of Access
khaul previo
tre and so s
bile industry
ome compet
crowave, th
ature
mited
rt on
fcom
vices
and
ously
such
y will
tition
his is
NON
TISB
24.
25.
26.
Who
Ser
27.
9 “MSymmnew]10 Oncomp11WhStati1.17 12 Anbaseincluor co13 Foconn
N CONFIDE
BO, AISBO
As abov
assessm
In respe
we beli
Constru
AI (e.g
Ofcom’s
product
where t
deploye
there a
BCMR)
In respe
is a com
and WD
bandwid
olesale Loc
rvices11
We con
Markets can co
metric Broad] MI Symmetrn the basis ofpetitive condiholesale serviion (RBS) serBCMR]
nd we note th stations and
uded within thore). [§4.195 aor RBS, as Onectivity betw
ENTIAL VE
O and MISBO
ve, general
ment.
ect of Tradit
eve that in
uction Costs
at 100Mbi
s proposals
t is more e
the CP site
ed 21 CN.
are “signific
).
ect of Multip
mbined mar
DM circuits1
dth Etherne
cal Loop Un
nsume both
ontinue to be dband Originaric Broadbandf demand sideitions [§4.101 ices used to prvices still fall
hat Ofcom’s “Rd the core nehe scope of mand §4.196 BCOfcom notes ween RBS sit
ERSION
O markets9
ly we agree
tional Interf
addition to
s (ECC) to
it/s and 1G
s in respect
expensive t
e is within t
We also no
cant barriers
ple Interfac
rket for circ10. We sup
et services i
bundling (L
LLU and R
distinguished
ation (TISBO)d Origination e and supply s
BCMR] provide backhl within the m
RBS backhautwork. Core obile backhauCMR] the “The lowes back to B
10
9
e with Ofco
face (TI) an
o those asp
establish f
Gbit/s) is c
t of ECC la
than EAD
the serving
ote that oth
rs to switch
ce (MI), we
cuits above
pport the co
is required.
LLU) and Ra
RBS wholes
d according to), AI Symmet(MISBO);” [§side constrain
haul for Locamarkets for wh
ul” refers to thnetwork conn
ul for market d
wer bandwidthBSC/RNC and
m’s use of
d Alternativ
ects identif
ibre mean t
constrained
ater in this
–LA, but th
g area of a
her mobile
hing from T
note that O
1Gbit/s (re
onclusion th
adio Base S
ale services
o the interfacetric Broadban§ 1.17 BCMRnts (between E
al Loop Unbuholesale symm
he connectivitynectivity (sucdefinition pur
h 2Mbit/s lind the higher
interface ty
ve Interface
fied by Ofco
that switchi
. We comm
response. A
he latter is
n exchange
operators h
TI to AI pro
Ofcom concl
gardless of
hat the regu
Station Back
s1213.
e of the leasednd Origination]
Ethernet and W
undling (LLU)metric broadb
y over SDH lich as betweenrposes (as this
nks are predobandwidth 15
ype in its ma
(AI) (Ether
om, the Exc
ing from TI
ment furthe
Also, BT’s
s only avail
e whereBT
have noted
oducts” [§
ludes that t
f interface t
ulation of hi
khaul (RBS)
d line producon (AISBO) a
WDM) and si
U) and Radio band originati
inks between n switches) is is more like
ominantly use55Mbit/s link
arket
net):
cess
and
er on
EAD
lable
has
that
4.31
here
type)
gher
)
ts (TI nd [a
imilar
Base on [§
radio is not trunk
ed for ks are
NON
28.
29.
typica “hu14 AtMEAEtheincorbasereliaIEEE“RB15 An16 Inthey 17 PDtechnrespemobthat becoBCMand o
N CONFIDE
We not
(technic
demand
identify
conclud
such th
market
relevan
We hav
i)
ii)
cally used in Mub” site that st §4.222 BCM
AS which usesernet connectirrect. Pseudowd radio base s
able timing toE1588v2 servS” PDH/SDHnd presumably
n the previoususe the same
DH and SDHnical requiremect of Ethernile Ethernet ahaving spoke
ome essentiallMR]. As suchother Ethernet
ENTIAL VE
te that Ofc
cal14, dema
d for mobil
ing separa
ded that the
at mobile b
(depending
t AISBO ma
ve the follow
Technical
would also
Sync E pro
Supply side
Virgin Med
backhaul s
such, this
general Eth
market to s
MNOs’ core nerves a numbe
MR, Ofcom ns ‘Pseudowireions in order wires are usedstation equipmo act as a syvice as part ofH E1 TI producy the relevant s BCMR Ofcowholesale inp
H are internatiments for mobnet, Ofcom noare potentially en to vendorsly standard feh Ofcom conct (AISBO) ser
ERSION
com has co
and/ supply
e or LLU b
ate wholes
e technical
backhaul ca
g on interfa
arket [§4.19
wing comme
assessmen
draw Ofcom
ducts.
e substitutio
ia) have pro
solutions in
suggests
hernet lease
supply Eth
networks and er of base statotes that: “BTe’ technologyto deliver syn
d to emulate Tment. A pseudynchronisationf the product, ct in order to pMISBO mark
om concludedputs (PPCs) [§onal standardbile backhaul otes that in p
different to es “it seems li
features of cacludes that thervices.
11
onsidered w
y substitut
backhaul th
sale mark
, demand/
an be includ
ace type15)
92 BCMR].1
ents on Ofc
nt - We no
m’s attentio
on - Ofcom
ovided, or
addition to
that mobile
ed lines ma
hernet circu
in some casestions”. [§4.21T has deployey. This enablenchronisation
TDM circuits adowire emulatn source. WitBT has to prprovide this syket for high bad that RBS ba§ 4.197 BCMds used for m
(including syprinciple, the enterprise custikely that therrier Etherneere is unlikely
whether the
tion, compe
hat rely on
kets [§4.19
supply and
ded in the re
and LLU b6
com’s asses
ote Ofcom’
on to our co
m notes that
are about t
o their exist
e Ethernet
arket (i.e. ne
uits to mobi
s as high capa6 BCMR]
ed an interim es 2Mbit/s TDn”. To clarify and therefore ted TDM circuth BT MEASovide a separynchronisatioandwidth (aboackhaul to beR]
mobile and fixynchronisationtechnical (syntomers (usinge synchronisaet services ovy to be a distin
ere are par
etitive cond
leased line
90 BCMR]
d competitiv
elevant AIS
ackhaul is
ssment here
s conclusio
omments lat
t some prov
o provide, m
ing Etherne
can be in
ew entrants
le networks
acity links to b
solution in itsDM circuits to
Ofcom’s undprovide suppouit does not p
S, pending thate, or leave in.
ove 1Gbit/s) e in the TISB
ed applicationn) can be metnchronisation)existing Ethetion methods er the next fenction betwee
rticular feat
ditions) of
es that just
]. Ofcom
ve features
SBO and TIS
included in
e:
ons here17
ter in respe
viders (suc
mobile Ethe
et solutions
ncluded in
could ente
s). We sug
backhaul traff
s Ethernet proo be emulatedderstanding, tort to legacy
provide sufficihe provision oin situ an exi
BO market be
ns and the get by TI circui
n) requirementernet solutionss [for mobile]few years” [§4en mobile Eth
tures
the
tifies
has
s are
SBO
n the
but
ect of
h as
ernet
s. As
the
r the
ggest
fic for
oduct d over his is TDM iently of an sting,
cause
eneral its. In ts for s) but ] will 4.223
hernet
NON
18As
N CONFIDE
iii)
iv)
discussed bel
ENTIAL VE
that the fa
Ethernet se
no interven
prevailing s
have histor
mobile op
establish it
operators n
already con
wayleaves.
wayleaves
change. Th
challenged
this absen
market and
access to
services is
effectively a
A combine
there is no
premium fo
operators w
increased
high capac
constraint
Ofcom’s co
Competitive
competitive
to general
(it is not un
single prov
low.
ERSION
act that jus
ervices doe
ntion or reg
situation, p
rically taken
erators me
self in the m
need to re-
nnected by
. Practical
within Tele
his leaves o
due to hig
ce of real
d in the abs
BT’s fibre
key to su
against lice
d RBS/ Eth
ot a comb
or TI circuits
would not s
(SSNIP tes
city is not n
on RBS p
onclusion he
e conditio
e conditions
circuits to s
nique to MN
vider of circu
12
st one alter
es not in its
gulation,
particularly f
n more BT l
eans that
market face
-invest sign
BT, but als
experienc
efónica has
only microwa
gh costs as
alternatives
sence of m
e, then effe
pport the m
nce covera
hernet back
ined marke
s above 2M
switch to RB
st)). And in
needed, Eth
pricing. [§4
ere.
ons – Ofc
s for mobile
substantiate
NOs that the
uits; nor is
rnative sup
elf indicate
We wou
for Telefón
eased line t
any altern
es not only
nificantly m
so the chal
ce of tryin
s proven th
ave as an a
sociated wi
s/ competit
ore radical
ective regu
mobile indus
ge obligatio
khaul marke
et since th
Mbit/s relativ
BS/ TISBO
respect of
hernet is un
.235 and §
com conc
backhaul a
e a separat
ere could be
it unique to
pplier is off
a healthy m
ld also poi
ica ( and V
transmissio
native sup
the challen
ore CapEx
lenge of ob
g to get
ese to be
alternative, a
ith dish righ
tion in the
measures
ulation of B
stry in depl
ons.
et – Ofcom
ere is a s
ve to Ether
services if
f base stati
nlikely to be
§4.236 BC
ludes that
are not suffi
te mobile b
e benefits o
o mobile tha
fering back
market nee
nt out that
Vodafone)
on than the
pplier trying
nge that mo
x to reach s
btaining sec
these sec
real barrier
and this is
hts etc18. G
mobile acc
such as PI
BT’s AI “E
loying LTE
concludes
significant p
rnet (and he
Ethernet pr
ion sites w
e a compet
CMR]. We
t overall,
iciently diffe
ackhaul ma
of supply fro
at there ma
khaul
eding
t the
who
later
g to
obile
sites
cond
cond
rs to
itself
Given
cess
A or
EAD”
cost
that
price
ence
rices
here
titive
note
the
erent
arket
om a
y be
NON
30.
N CONFIDE
v)
We are
be dist
market
custom
particul
specific
ENTIAL VE
“first-mover
unique to m
with BT out
here. Howe
distributed
premises s
mobile ind
outside the
mover adv
§4.250). F
these cable
Self supply
cannot me
cannot act
in the conte
unlikely tha
We wou
be engaged
e not convin
inguished.
we believ
ers are pr
ar, via the
c sub cap on
ERSION
r” advantag
mobile that
tside the ma
ever, we w
nature of c
serviced by
ustry has
e footprint re
vantage/ loc
urther, BT
e accesses.
y – microwa
et MNO’s
as substitu
ext of an inc
at an MNO
uld urge Of
d here to ad
nced that a
However,
ve that it
otected in
RBS specif
n 1Gbit/s Et
13
ge in the su
alternative
ain urban a
would add t
cells (as not
y BT’s AI a
invested s
equired by
cations of
has obtain
.
ave links. O
backhaul re
te for mobil
crease in le
would swit
fcom to co
ddress this
market for
in the abs
is essentia
the design
fic cap and
thernet circ
upply of cir
providers c
areas). We
that in addi
ted in the B
and TI prod
significantly
the majorit
base statio
ned and us
Ofcom concl
equirement
le backhaul
eased lines
tch to micro
nsider wha
issue.
r mobile ba
ence of th
al that mo
n of the c
, moreover
uits (discus
rcuits; nor i
cannot com
note Ofcom
tion to the
CMR), com
ducts, over
in BT’s a
ty of other c
ons as deb
ed its own
udes that m
ts in all cas
leased line
charges (S
owave. In o
t regulatory
ckhaul can
e identifica
obile opera
harge cont
, with the in
ssed elsewh
is it particu
mpete effect
m’s assessm
geographi
mpared to o
r the years
access netw
customers
bated §4.24
n wayleaves
microwave
ses and he
es. Furtherm
SSNIP test),
our experie
y response
nnot necess
ation of suc
ators and
trol baskets
ntroduction
here).
ularly
ively
ment
cally
other
s the
work
(first
42 to
s for
links
ence
more
, it is
ence,
can
sarily
ch a
their
s: in
of a
NON
Sep
ban
revi
31.
The
32.
33.
A hi
34.
19 “Tof thregiosigni20 “Tthe mnetwtrafficircu[§6.221“CwholWDM
N CONFIDE
parate mar
ndwidth brea
iew still hold
Genera
ere are sepa
By “trun
whethe
Aggreg
propose
it outwa
We not
BCMR]
adjacen
circuits
definitio
to point
market
technica
igh bandwid
We agr
There are sepahe market we onal trunk mificantly differTrunk or coremajor urban
works is combfic on their neuits) are ofte2BCMR]
Consistent withlesale MI maM equipment a
ENTIAL VE
rkets can
aks we defi
d.”) [§1.17 B
ally, we agre
arate marke
nk” we und
r the curre
ation Node
ed a “comp
ards to a low
te that Ofco
, but that “a
nt TANs (m
on the bas
on criteria.”
t Ethernet
(i.e. acces
al and econ
dth/ Multiple
ree with the
arate marketsdefined a sin
market are verent from those networks arecentres where
bined with othtworks more een used to p
h our provisioarket which inat the end-use
ERSION
be disting
ned for TI a
BCMR]
ee.
ets for regio
derstand O
ent market
s [§6.19 BC
petitive core
wer tier of s
om conclud
a distinction
more simila
sis of variat
[§6.129 BC
circuits suc
ss and bac
nomic limit o
e Interface E
determinat
for regional ngle TI trunk ery similar tse of national e used to trane businesses a
her traffic streefficiently. Byprovide the
onal view in rncludes any seer’s premises,
14
guished acc
and AI whol
onal and nat
Ofcom to m
definition b
CMR] need
e” redefining
maller node
des that the
n can be ma
ar to termin
tions in com
CMR]. We n
ch as EAD
ckhaul) [§6
on them bei
Ethernet ma
tion of a hig
and national k market. We to those of strunk routes.”
nsfer data oveare concentraeams (using my contrast, term
connectivity
relation to theervice faster irrespective o
cording to
lesale servi
tional TI trun
ean “core”2
being a circ
ds to be alte
g the trunk
es) [§6.77 B
e TAN conc
ade between
nating segm
mpetitive co
note that Of
are part o
.138 BCMR
ing used for
arket21
gh bandwidt
TI trunk connnow considersymmetric br” [§1.18 BCMer long distanated”. Data tmultiplexers), minating segmfrom end-us
e retail markethan 1Gbit/s
of bandwidth a
bandwidth
ces in the p
nk connecti
20. And Of
cuit linking
ered (for ex
market bou
BCMR].
cept remain
n regional c
ments) and
onditions an
fcom determ
f the termin
R] – that t
r trunk.
h/ MI marke
nectivity. In our that the charoadband orig
MR] ce national ro
transposed ovwhich allows
ments (such asser sites into
et, we are propand any serv
and interface.
h breaks
previous ma
ivity19.
fcom consi
different T
xample, BT
undary, pus
ns valid [§6
circuits cros
d national t
nd other ma
mines that p
nating segm
there is bo
et.
ur previous rearacteristics ogination, and
routes and betver trunk (or s CPs to trans AISBO or T
o core netwo
oposing to defvice delivered.” [§1.18 BCM
(“the
arket
ders
Trunk
has
shing
.102
ssing
trunk
arket
point
ment
oth a
eview of the d are
tween core)
nsport TISBO orks.”
fine a d with MR]
NON
Who
Sep
35.
Hull
36.
WE
37.
38.
22 “Sdefindefin8Mb
N CONFIDE
olesale Ge
parate geog
We agr
l
We agr
rest of t
ECLA
We no
compet
In our
arrange
emerge
Separate geogrned area of Loned wholesalebit/s) and very
ENTIAL VE
eographic d
graphic mark
ree.
ree with Ofc
the UK. We
ote Ofcom
tition are mo
experience
ements) wh
e. We discus
raphic marketondon (the Wee leased lines p
high bandwid
ERSION
definitions
kets can be
com’s concl
e discuss H
concludes
ore favoura
e, there re
hich limit th
ss these in
ts exist: (i) in estern, Easternproduct markedth (above 155
15
e distinguish
lusion that
Hull in more
s that the
ble in the W
emain certa
he degree
the section
the Hull arean and Centralets other than5Mbit/s) TISB
hed: Hull, W
Hull should
detail elsew
prospects
WECLA than
ain aspects
to which
n on SMP.
a for all wholel London Area
n the low bandBO markets.”
WECLA and
be distingu
where in this
for the d
n outside (fo
s (for exam
effective c
esale leased lina, or ‘WECLAdwidth (up to a[§ 1.19 BCMR
rest of UK2
uished from
s response
developmen
or Ethernet
mple, wayle
competition
nes, and (ii) inA’) for all the and including R]
22
m the
.
nt of
).
eave
can
n a
NON
OFC
This
39.
SMP
40.
41.
Hul
42.
43.
N CONFIDE
COM’S PRO
s section
In this s
and KC
P designat
We agr
Ofcom
Etherne
here, w
We als
compet
regulate
“core”.
part of t
l
We agr
Mobile
the Hu
“interco
ENTIAL VE
OPOSED A
section we c
COM.
tions of BT
ree that BT
concludes
et products
which we dis
so note tha
titive and th
ed). [§10.1
RBS acces
the TI trunk
ree with Ofc
“We propos
alternative
share in ea
wholesale l
is therefore
KCOM’s be
backhaul T
ull area ha
onnect links
ERSION
ASSESSME
comment on
T and KCOM
T and KCOM
that BT do
(MI) in the
scuss below
t Ofcom co
hat BT does
87 BCMR]
ss and back
k market.
com’s identi
se to find th
fixed netwo
ach of the m
level in the
e unlikely t
ehaviour.” [§
TI services c
ave proved
” charged to
16
ENT OF SM
n Ofcom’s p
M - Ofcom’
M have SM
oes not hav
WECLA. A
w.
oncludes th
s not have
. By “trun
khaul being
fication of K
hat KCOM
work infrastru
markets is a
Hull area i
to be a su
§1.34 BCM
connecting
d particula
o BT by KC
MP
proposed S
s approach
MP in the m
ve SMP in
As above w
hat the TI t
SMP in the
nk” we und
g classified
KCOM’s SM
has SMP b
ucture in th
at, or very cl
is very unlik
ufficiently cr
MR]
sites in Hu
rly expens
COM. Microw
MP designa
h and prop
markets iden
respect of
we have som
trunk marke
e market (an
derstand O
as TI term
MP in the Hu
because the
he Hull area
lose to, 100
kely in the r
redible thre
ll to switch
sive due to
wave has b
ations for B
posal
ntified. We
high bandw
me reservat
et is effect
nd hence is
Ofcom to m
minating and
ull area:
ere is almos
a, and KCO
0%. Entry a
review perio
eat to cons
sites outsid
to the cos
been used t
T
note
width
tions
ively
s not
mean
d not
st no
OM’s
t the
od. It
strain
de of
st of
to try
NON
44.
Out
45.
46.
N CONFIDE
and ove
in the U
Whilst s
believe
that eg
circuits
appear
or an is
tside Hull a
In respe
of BT’s
AI and
recogni
AI serv
largely
ENTIAL VE
ercome this
UK have pro
strictly a co
the BCMR
gress the H
within the
to be avail
ssue for reg
and WECLA
ect of low b
SMP in this
“In the cas
propose th
WECLA. W
despite gro
unchanged
circumstan
of this revie
are unlikely
means that
to serve ne
has been m
However,
despite stro
position sin
currently es
MI are o
ises. We ag
vices betwe
a question
ERSION
s but high a
ovided only
omment in
should add
Hull area fo
Hull area.
able and it
ulation.
A
bandwidth A
s area:
se of AI s
at BT has
We conside
owing CP in
d from the 6
ces are not
ew. The cos
y to reduce
t OCPs will
ew custome
more infras
despite ex
ong growth
nce the las
stimate to b
of increasin
gree with O
en up to a
n of volume
17
ancillary/ re
partial mitig
respect of
dress the p
or connectio
Howe
is not clear
AI/ Ethernet
services, sim
SMP in the
er that outs
nvestment,
69% we est
t likely to ch
sts of diggin
e significan
l continue to
ers. In the W
structure inv
xtensive alt
h in demand
st market r
be in the ran
ng importan
Ofcom’s ass
and includin
e and curre
ntal costs a
gation.
remedies,
rice regulat
on to BT, a
ever, compe
r whether th
, we agree
milar to ou
e UK exclud
side the W
BT’s 67%
timate in 20
hange over
ng trenches
tly, and the
o incur high
WECLA our
vestment th
ternative n
d, BT has
review with
nge 45%-50
nce to mo
essment of
ng 1Gbits, a
ent expecta
associated w
we mentio
tion of interc
and not jus
etitive servi
hat is just a
with Ofcom
ur last mark
ding the Hu
WECLA and
share of vo
007. We bel
the forward
s and buildin
e ubiquity o
her average
r analysis sh
han in the r
etwork infr
maintained
a volume
0%.”[§1.26
bile operat
f the split in
and above
ations in the
with microw
on here tha
connect circ
st regulatio
ices do not
a matter of t
m’s identifica
rket review,
ull area and
the Hull a
olume is alm
elieve that th
d-looking pe
ng duct netw
of BT’s netw
e costs than
hows that t
rest of the
rastructure
d its compet
share that
BCMR]
tors as Of
n the marke
1Gbits. Th
e areas of
wave
t we
cuits
on of
t yet
time,
ation
, we
d the
area,
most
hese
eriod
work
work
n BT
there
UK.
and
titive
t we
fcom
et for
his is
use
NON
47.
N CONFIDE
within a
1Gbits)
for serv
access
network
parts of
traffic f
Points o
capacity
alternat
alternat
BT’s DW
In respe
that BT
“W
the
has
vol
exp
per
app
the
hig
com
adv
are
sup
Con
thro
effe
ENTIAL VE
a mobile ne
, Telefónica
vices at 1G
technology
k where BT
f the netwo
from multip
of Concentr
y managed
tives to BT
tives could
WDM produ
ect of high
holds SMP
We are propo
e Hull area
s been grow
umes have
pect that thi
riod. We es
pears to be
e volumes o
gh average
mpetitive en
vantage fro
e delivered
pport effe
nsequently
oughout the
ective comp
ERSION
etwork. In t
a and othe
Gbits (the ne
y above 10
T has SMP.
rk. Here, th
ple sources
ration (e.g.
d bandwidth
T available
be encoura
ucts.
bandwith E
P in this mar
osing that B
and the W
wing very fa
e increased
is rate of gr
stimate tha
highly conc
of the secon
revenue p
ntry in this
m the ubiq
with WDM
ective inte
CPs whic
e entire rou
petition and
18
the low ba
r mobile op
ext and onl
00Mbitbeing
. 10Gbit se
he economi
(cell sites
BT LLUs) f
h services
e. However
aged and in
Ethernet/ MI
rket:
BT has SMP
WECLA. Dem
fast since th
d more tha
rowth will co
at BT’s sha
centrated, w
nd largest
per custom
market may
quity of its n
equipment
erconnectio
ch use thei
ute of such
d gives BT a
ndwidth ma
perators wil
ly available
g 1Gbit/s)
ervices will
es of scale
s) and the
from other
mean that
r, as disc
ncentivised
I, we agree
P in the MI m
mand for se
he last revie
an threefold
ontinue thro
are of volu
with BT sup
provider. W
mer sugges
y be favour
network. Mo
whose tech
on betwee
ir own infra
h a service
a strong adv
arket (up to
l have sign
capacity s
in the acce
feature in t
of providin
increased
providers o
t there are
cussed els
through reg
with Ofcom
market in th
ervices fast
ew. We bel
d since 20
oughout the
mes is 59%
pplying more
Whilst the h
st that the
rable, BT d
ost services
hnology cur
en differe
astructure n
. This limit
vantage.” [§
o and inclu
nificant dem
step in Ethe
ess part of
the aggrega
ng links carr
accessibilit
of fibre and
e, to a deg
sewhere, th
gulation aro
m’s assessm
he UK exclu
ter than 1G
lieve that ci
006/07, and
e coming re
%. The ma
e than six ti
high growth
e prospects
derives a st
s in this ma
rrently does
ent netwo
need to do
ts the exten
§1.28 BCMR
uding
mand
ernet
f the
ation
rying
ty of
high
gree,
hese
ound
ment
uding
Gbit/s
ircuit
d we
view
arket
imes
and
s for
trong
arket
s not
orks.
o so
nt of
R]
NON
WE
48.
49.
Tru
50.
N CONFIDE
CLA
As abo
effective
may ex
These a
nk TI
Noted.
ENTIAL VE
ve, in our e
e competiti
xist in WECL
i. Investm
installat
operato
duct in
investm
backha
alternat
ii. BT ins
Telefón
provide
negotia
negotia
aspects inc
ERSION
experience,
on can em
LA:
ment in BT
tion simply
ors have pa
addition to
ment that BT
ul market a
tives; and
ists on us
nica to use
er requires n
ate Waylea
ate upfront to
rease the b
19
, the followi
merge, notw
solutions m
y duplicates
aid BT (thro
o the capita
T derives i
and which
sing its ow
its own. Ac
new Waylea
ves on thi
o allow alte
barriers to sw
ing aspects
withstanding
means that s
s investme
ough Exces
al for equip
ts significa
now make
wn Waylea
ccordingly,
aves. Were
ird party p
ernative prov
witching.
s limit the d
that altern
switching to
nt already
ss Construc
pment. It is
nt presence
es it difficul
ves. BT d
switching to
BT to perm
premises/ la
viders.
degree to w
native provi
o an alterna
made. Mo
ction Costs
s from this
e in the mo
lt to implem
does not a
o an alterna
mit Telefónic
and, we c
which
ders
ative
obile
s) for
very
obile
ment
allow
ative
ca to
could
NON
OFC
This
51.
Ofc
52.
53.
N CONFIDE
COM’S PRO
s section
In this s
respect
i)
ii)
iii)
iv)
com’s overa
Ofcom
As Ofc
continu
provide
service
submiss
ENTIAL VE
OPOSED R
section we c
t of Ofcom’s
not to requ
not to impo
to impose a
to impose a
safeguards
all approac
notes:
“In providin
heavily on
the Hull a
appropriate
which wou
services.”[§
om will rec
e to provide
ed as they w
, choice co
sions
ERSION
REMEDIES
comment on
s proposals
ire Passive
ose a Cost O
a sub-baske
a single Eth
s.
ch
ng their cus
wholesale
area) prov
e SMP rem
uld ensure
§1.35 BCM
cognise, it
e services.
would be in
omponents
20
n Ofcom’s p
:
remedies;
Orientation
et for RBS;
hernet baske
stomers wi
leased line
vide on re
medies in t
that BT an
MR]
is not just
It is also a
n a compet
etc. As Ofc
proposed re
obligation;
and
et and asso
ith services
es services
egulated te
this review,
nd KCOM
about ens
bout ensur
titive marke
com will be
emedies, in
ociated sub-
s, CPs curr
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m our prev
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54.
55.
56.
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N CONFIDE
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that MNOs
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com will r
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ns will brin
sly).
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sions: we
unity to add
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ders.ofcom.org
ERSION
m does not
e we consi
milar benefi
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that in resp
dies should
nd transmis
nt view is
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its passive
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, and with i
s’ concerns
by price c
BCMR]
recognise,
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as per our r
continue
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ponse to ou
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khaul could
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ognise, we h
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ly to
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than
ly to
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and
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58.
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i)
ii)
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te Ofcom’s
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in respect
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introduced
appreciate
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cumulative
Ofcom als
remedies c
practice, B
higher ban
charges for
1Gbit/s are
operating
underlying
be much sm
noted that
ERSION
s assessme
ve and as a
uding:
lains that M
ssed by th
our conce
dressed by t
f the BCMR
duplication
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of NGA in
sessed the
rify? As it s
is here. In
ermined tha
duct and
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the roll ou
that the ris
cost is mat
so express
could lead to
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at 100Mbit
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maller” [§ 8
the re-bala
22
ent of the
at §8.43 – §
MNO’s conc
he propose
rns in resp
the propose
R Ofcom ex
n of costs a
rs. Ofcom
support of
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stands, we
any event,
at passive a
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grid arrange
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sk of passiv
terial.
ses concer
o BT rebala
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sale Etherne
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t/s, even t
osts of the
8.62 BCMR
ancing conc
case for
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cerns about
ed price c
ect of the p
ed price con
xpresses co
nd add to t
points to ou
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ent in the
are unclea
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access solut
cess oblig
odafone alr
ement to i
services to
ve access re
n that the
ancing its ta
ately more
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though the
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cern is not
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pricing of 1
ntrols;
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nding the co
tions were a
ations. Of
ready propo
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ariffs. Ofcom
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tive costs o
he models u
r whether th
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appropriate
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ose to enter
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duplication
ion of pas
m notes tha
mon costs
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e same ser
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ervice is like
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issue to BC
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cess
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aken
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and
ssive
at, in
from
rrent
ng at
rvice
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ely to
nputs
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NON
59.
Cos
60.
61.
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N CONFIDE
iv)
We bel
remedy
with NG
st Orientati
We also
apply c
control”
the spe
the ove
means
propose
impositi
[§5.72 L
For RB
remedie
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charge
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his is contraste
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and that
intervention
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strategic in
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costs. W
determinati
such that a
ieve that pa
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ion
o note that
cost orienta
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ecific design
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of addressi
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LLCC].
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am 16
nnection se
for all othe
k of the exce
Ofcom conc
ed with the ex
ERSION
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hat Ofcom
ncentive to
osts in the B
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ion elsewhe
a specific ch
assive acce
anding that
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ation obliga
CMR]. We n
n, structure
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tional cost o
ul, we unde
specific (
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ervices; ca
r services w
essive pricin
cludes that
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of rebala
y passive a
is not awa
achieve ina
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nclear how
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note that (in
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f excessive
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onal cost o
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consistent
entives in r
s required.
n appropora
ot emerged
om “[does]
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posed charg
sub caps) a
pricing for t
as such, w
would be di
ncludes tha
sket on R
ervices; su
ervice and
asket effecti
nd assocat
orientation
ss has been us
any regula
hat BT has
in allocatin
increase M
with Ofco
relation to
ate and just
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m considers
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the services
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ted services
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ctive
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on
each
sses
s. As
nt to
e.
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62.
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ensure
priced i
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that each
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aul. Howeve
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acknowledg
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operators a
in a way th
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orientated (
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for most s
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till be exces
tation provi
ntrols rely
udgments th
nding charg
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we do note
services [wh
nificantly ab
plained whic
erators will
e Ethernet
the migratio
MNOs are
n of this rev
24
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sal to app
e a number
:
ges [§4.21 L
rge control
arge contr
fic RBS con
xplains, RP
transparan
rientation ob
licit obligati
om conside
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ssive.
ides an ong
on Ofcom
hat BT has
ge controls.
nues to hav
Ofcom’s a
hich?] we p
bove curren
ch services
have a con
is not feas
on of mobil
e likely to co
view.” [§10.7
ssociated s
ply specific
of concerns
LLCC] cost
s. Indeed,
ols in pre
ntrol is new
PI controls
ncy in respe
bligation do
ion to ensu
rs means c
C] – charges
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ve the ince
ssessment
proposed t
nt price leve
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ntinued reli
sible. Indee
le circuits t
ontinue to re
72 BCMR]
service is n
charge co
s regarding
orientation
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evious yea
in this revie
can give B
ect of charge
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ure that ch
charges sho
s may be t
cit requirem
ment of cos
on a cost o
Ofcom note
ntive to pri
that “the D
to include i
els.” [§6.113
this level.
ance on RB
ed, Ofcom r
to AI servic
equire TI RB
not excess
ontrols to
g the remov
can be use
been use
ars (albeit,
ew).
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ould lie betw
transparent
ment, whilst
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v)
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with Art
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te Ofcom in
ticle 13 of t
ective make
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its prices,
including a
operator co
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ERSION
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concludes
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mpetitive co
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MR].
ndicates th
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25
an overall b
vious BCM
ese (albeit n
that the cu
er necessa
irement wa
ime which i
now – partic
onditions ar
ed to 2007/
conclude th
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s Directive [
t:
as an obliga
n of proof t
le rate of re
step to remo
basket and
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not a specif
urrent cirum
ry. Howeve
as deemed
ncluded an
cularly, giv
re not mate
8.
at BT has
igh prices i
in downstr
oval of cos
[§2.24 LLC
ation regard
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certain sub
ientation wa
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stances are
er, we are n
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rially differe
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ding the cos
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vestment sh
rden of proo
b baskets w
as still requ
sket). We
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not clear w
te in 2007/
sket and ce
com recogn
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ve to, amo
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ets [§10.12
on is consis
er, Article 1
st orientatio
ived from c
hall lie with
of from BT.
were
uired
note
cost
hy a
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rtain
nises
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ongst
affect
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stent
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on of
costs
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NON
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66.
67.
68.
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69.
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N CONFIDE
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Ofcom
place t
(require
regulate
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compon
basket
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internal
basket
below).
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[§A5.14
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network
accomo
An obligation uding 2Mbit/signed to ensur[§ 1.85 BCM
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neering of BTices) to requir
vided without
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han the ad
proposes t
today inclu
ements to p
ed with a pr
nderstand
nents, Ofco
along with o
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consumed
cap for RB
pport the es
ere). We n
quirement,
me underly
42 LLCC An
vices
elcome Ofco
k access
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to provide R
s to mobile nere BT provideMR]) manner
derstand this afcom does not
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dition of a
to maintain
uding the e
provide PPC
rice control
that beca
m proposes
other PPCs
e of the ince
d services,
BS. This ap
stablishmen
ote that, in
since befor
ying costs
nnexes].
om confirm
includes a
d power to
RBS Backhauetwork operates RBS Backhr with suitabpplies to botht consider it prg systems wheTI services to brimination. [§
26
specific RB
n the same
existing PP
C and RBS
[§ 1.46 BC
ause of c
s to include
s and LLU b
entive on B
Ofcom p
pproach is
nt of a sub
respect of
re RBS was
component
mation that
ancillary se
o make us
ul traditional tors in the UKhaul in a non-ble Service Lh terminating aroportionate (
en the TI markbe provided o10.85 BCMR
BS sub cap
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PC and R
Backhaul26
MR] .
commonalit
e RBS back
backhaul se
BT to conce
proposes to
discussed
basket for
f RBS, a sp
s indirectly
ts as PPC
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ervices (
se of the r
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(see below
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BS Backha6) and that
ty of und
khaul servic
rvices.
entrate price
o establish
in detail in
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pecific char
controlled
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ral requirem
(such as
regulated s
cuits at bandthe Hull area. ry (no undue dcompensationegments [§ 10
ould require mg with migratis but rather th
w) we note
ons that ar
aul directio
charges wi
derlying co
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e reduction
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the LLCC
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rge control
via their us
were regula
ment to pro
the neces
service [§1
dwidths up to [§ 10.68 BCdiscriminationn for below 0.200 BCMR]
major re-ion to Etherne
hey should be
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re in
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ill be
osts/
he TI
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sub-
(see
ments
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se of
ated)
ovide
ssary
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]
et
NON
70.
71.
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72.
73.
74.
27 FoEBD
N CONFIDE
BCMR]
charge
terms,
with ap
the incr
As Ofc
migratio
nearby
absenc
areas o
custom
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growing
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discuss
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(exclud
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product
betwee
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control, TI
whereas th
ppropriate m
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on to Ether
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ce of alterna
of the coun
er impact a
mment on t
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r our previ
g demand fo
te and sup
s our comm
ote Ofcom
ing Hull).
pport the re
ts. We note
n services
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t 11.30 to 11.3onnectivity is l
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note that
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hose of Eth
migration si
ward lookin
cognise, fo
rnet lines is
onnectivity a
ative supply
ntry will incr
and implicat
the detail o
ous submis
or Ethernet
pport speci
ments on th
proposes
egulation of
e Ofcom’s a
at 1Gbit/s
33, Ofcom disclimited to the
27
Ofcom con
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hernet servi
ignals beca
ng costs” [§5
or mobile th
s not feasib
and/ or res
y, the impli
rease in re
ions for the
of the RBS
ssions and
backhaul p
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a seperat
both low (A
assessmen
and below
cusses the 21Crelevant BT c
ncludes tha
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ause the inc
5.78 BCMR
here will be
ble (for exa
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ication is th
al terms. T
economics
control be
d as noted
products.
controls o
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nt that there
and servic
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t “Over the
prices will in
crease. Th
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e circumsta
ample, beca
th of EAD
hat the bac
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s of rural co
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in the BC
on Ethernet
rols in the
for WECLA
h (MI) band
e continues
ces above 1
rchitecture andnd ASN nodes
e course of
ncrease in
his is consis
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ause of lac
circuits). In
ckhaul costs
has an ov
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section on
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s to be a b
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nd that this mes.
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tion).
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reak
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75.
76.
77.
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78.
79.
N CONFIDE
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orientat
BCMR]
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respect
i)
ii)
iii)
iv)
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WDM E
below.
cing of Eth
Ofcom
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and we
wholesa
control
WDM a
multiple
would
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ve reserva
tion obligati
pport Ofco
t of low ban
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the allocata
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include se
“including a
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regulated p
e Ofcom’s p
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ernet and W
explains tha
ment at end
e do not p
ale product
on BT’s wh
affords grea
e providers/
appear to
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ations conc
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m in seek
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agree with O
ation of acco
y explicitly
eparate acc
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th circuits th
reach proc
product rath
proposal to
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WDM
at “Whilst m
d-user prem
propose to
s in this ma
holesale sing
ater flexibilit
multi servic
offer incr
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cerning Ofc
arges that a
king to ach
ernet produ
Ofcom’s pro
omodation
that BT’s
cess and
on”;
hat cross bo
cess reques
her than a co
distinguish
ent on Ofc
most MI ser
mises, WDM
o impose p
arket. Howe
gle-service
ty of whole
ce over the
reasing op
com’s prop
are subject t
hieve greate
cts [§ 1.50]
oposal to e
and power;
wholesale
backhaul s
oundaries, a
sts to deve
ommercial p
h between s
com’s propo
rvices are de
M technolog
price contro
ever, we do
Ethernet pr
sale service
same circu
portunities
osal to rem
to the price
er clarity o
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extend EoI r
Ethernet
services. W
and
lop new AI
process [§1
single servic
osals in re
elivered by
gy is still e
ols on BT
propose to
roducts”. [§
e. In particu
uits. As such
to suppor
move the
e control. [§
of regulatio
ple:
requiremen
products m
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1.51].
ce Ethernet
espect of W
installing W
evolving rap
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ular, suppo
h, WDM circ
rt the netw
cost
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on in
ts to
must
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as a
and
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WDM
pidly,
ased
price
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rting
cuits
work
NON
Syn
80.
81.
82.
WE
83.
N CONFIDE
architec
concern
nchronised
We note
i)
ii)
Whilst
Synchro
capable
the rollo
upgrade
addition
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regulato
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to avoid
future a
CLA
Ofcom
inside
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cture and
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d Ethernet S
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nal costs (s
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nica would
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explains t
and outsid
ERSION
build strat
com propos
Services
m conclude
cessary to
ation provid
for synch
are able to “
anges” and
EAD that wil
ernet Servi
sket [§10.24
welcomes
ernet we a
ducts by BT
networks. T
ion of 1000
site access
y.
welcome p
agement to
ing Etherne
k situation w
l cost.
hat “the on
de the WE
29
tegies eme
ses to leave
es that:
introduce a
ders with ac
hronisation
“self provid
also Open
ll be availab
ices need
4 – §10.26 L
the propos
are concern
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costs and
protective
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et in large v
where all th
nly differen
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e WDM circu
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ccess to a r
purposes
de timing inf
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ble on EoI.
to be inclu
LLCC]
sed price c
ned that th
ts a risk of
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s, than hav
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elerate its S
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ld be the
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uded in the
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at we will p
ve to re-vis
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need to be
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84.
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85.
86.
87.
N CONFIDE
Reflecti
compet
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compet
commodati
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allocate
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require
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and mo
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ons in resp
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ERSION
com conclu
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ork access i
n the basis
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pect of alloc
ments.
30
udes that th
ble in WEC
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ion
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e note that w
mmodation
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in the AI m
s of EOI”.
d provision
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he prospec
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in limitatio
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pose SMP c
he basis of
whilst at §1
and power
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market other
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is on EoI.
pful to ensu
comodation
cts for the d
sewhere. [§
ns on the
ssues with
conditions
EoI. [§11.1
1.11 Ocom
r on an EO
e to require
r than interc
stand Ofcom
ure that it is
n and powe
developmen
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prospects
wayleaves.
requiring B
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says that i
OI basis, in
e BT to pro
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m to mean
s clear that
er apply to f
nt of
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s for
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BT to
t will
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ovide
and
that
t the
fixed
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OFC
This
88.
N CONFIDE
COM’S LLC
s section
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ntrol Design
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ts for RBS a
ation of the
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the charge
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onship with
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NON
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N CONFIDE
rm and dura
We sup
subject
costs. W
We com
which w
controls
arge Contro
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approac
baskets
data (b
the rest
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ain reservati
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ERSION
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arises beca
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ntation, cost
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ment on all
e generally
uring baske
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ions are:
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ervices;
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of the ince
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32
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he section
ause of the g
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t standard,
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ace service
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he LLCC in
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use for geo
ost differen
cts Ofcom
ve of Ofc
ably design
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discusses
com’s reco
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with
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etail.
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on of
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ntrol
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s vs
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We dis
proposa
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oposed con
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b basket for
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note Of
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ser
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+3.25%
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to discr
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ation backh
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rvices” (sinc
e sub bas
tential ince
erators.” [§5
e Ofcom pr
ent with PP
backhaul se
C circuits” [§
to protect m
riminate aga
ERSION
uch as RBS
et services.
below. We
ve cost orie
raditional I
haul service
haul
m’s decision
essment tha
ence of an
te price re
ce the form
sket would
entives BT
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roposes an
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rvices are p
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mobile oper
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at:
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rators from a
e operators.
specific con
ark elsewh
igations.
ervices
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n PPCs, ra
nsumed inte
RBS backh
ve to disc
of +0% to
allow for eff
sing the sam
he same tim
any potenti
[§5.44]
ntrol has be
ere in resp
ket for RBS
re may be a
ather than
ernally) [§5
aul custom
criminate a
+6.5% (mid
ficient cost
me underlyin
me, requires
al incentive
een establis
pect of Ofco
backhaul.
an incentive
RBS back
5.42 LLCC]
mers from
against mo
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recovery (s
ing compon
s a specific
es BT may h
shed
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98.
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103
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N CONFIDE
We not
experie
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elsewhe
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not feas
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welcom
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basket
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backha
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to favou
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are 4.4
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te that Ofco
enced as vo
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this may be
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me the oppo
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ver, we note
ul POP in
intends to r
), together
does not nee
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because, gi
ur one type
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cline, unit cos
” [§5.5 LLCC]
ERSION
om conclud
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approach
omment on
esponse.
e the case. A
ome circuits
hermore, Of
e controls is
that RBS m
to re-alloca
rtunity to di
ort Ofcom’s
ernet baske
anagement
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the “main T
refer to the
with PPC P
ed to create
trategic ince
iven that all
of POH pro
hat Ofcom’s
that equiv
T has the in
sts may rise, s]
34
des that the
ine faster th
is consiste
n the trans
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s (RBS incl
fcom highlig
s to avoid re
may be pen
ate certain
scuss with
s proposal t
t to reflect
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m conclude
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interconnec
POH servic
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entive to re
l are purcha
oduct over a
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centive to d
ince fixed cos
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han costs29
ent with mig
sparency o
also notes e
luded) whe
ghts that on
esidual serv
nalised in th
costs from
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to re-allocat
a declining
umes declin
es that it is
(note we p
ction sub ba
ces. [§5.51
sub baskets
-balance th
ased by CP
another”. [§
is that RBS
C POH, g
discriminate
sts are shared
lects the ris
[§5.7 LLCC
gration sign
of the vol
elsewhere, t
re migration
ne of its gu
vices being
is fashion, n
TI to Ether
w this can be
te £101m co
allocation o
ed and Ethe
appropriate
resume this
asket and n
LLCC]. Of
s since “We
he charges a
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5.52 LLCC]
S backhaul
given Ofco
e against mo
over fewer sa
se in unit c
C]. Furtherm
nals from T
lume forec
there is like
n to Ethern
uiding princ
penalised.
notwithstan
rnet. We w
e addressed
osts from th
of certain c
ernet increa
e to place
s is a typo
not the “mai
fcom conclu
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across diffe
no clear rea
].
l POP serv
om’s prece
obile opera
ales and econo
costs
more,
TI to
casts
ely to
et is
iples
nding
would
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he TI
costs
ase.
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and
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udes
lieve
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ason
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tors,
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NON
Sub
104
Cap
105
Pro
Gen
106
107
N CONFIDE
we are
separat
PPC int
b cap on ea
4. We su
(discuss
charge
p on each c
5. We not
controll
oposed con
neral
6. We not
deal wi
services
i)
ii)
iii)
iv)
7. Whilst
protecte
bandwid
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e concerned
te sub bask
terconnectio
ch ancillary
pport Ofco
sed below)
at the same
harge for al
te Ofcom’s
ed by the s
ntrols for E
te Ofcom ha
th the iden
s at an exce
Single Ethe
WECLA inc
Sub cap fo
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Excess Co
we suppor
ed from exc
dth service
ERSION
d that Ofcom
ket for RBS
on.
y service
om’s propo
) and to im
e level as th
ll other serv
proposal to
pecific sub
thernet ser
as conclude
ntified risk t
essively hig
ernet baske
cluding anc
r all other E
t for interco
nstruction C
rt Ofcom’s
cessive cha
es should b
35
m has not d
S interconne
osal to intr
mpose a su
he overall b
vices within
o set a sub
caps etc. W
rvices
ed that the
hat BT mig
gh level [§6.
et (for low a
illary servic
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nnection se
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conclusion
arging (and
be price co
decided to b
ection and
roduce a s
ub cap on
basket cap.
the TI bask
b cap on all
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following c
ght fix and
.184 LLCC]
and high ba
ces)
rvices
ervices
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ns that the
d we welco
ntrolled), w
be consiste
a separate
specific con
each rema
ket
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com propos
controls will
maintain its
:
andwidth E
ese service
me the pro
we are conc
ent and crea
sub baske
ntrol on E
aining anc
s not otherw
ses RPI+10%
be sufficie
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es need to
oposal that
cerned that
ate a
et for
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wise
%.
nt to
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tside
o be
high
t the
NON
108
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109
110
111
112
113
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114
N CONFIDE
overall
of 1Gb
basket
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ingle Ethern
9. As we
pricing
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x).
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network
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.
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need to
to discr
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that “W
depend
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design will
it/s service
is necessar
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net basket c
explained i
of Etherne
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recognises
o protect mo
riminate ag
for RBS ba
ch, we beli
d at no less
dient pricing
considers t
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ding on the
considers
ERSION
not address
s. We belie
ry (rather th
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controlled a
in our resp
t products
bit/s EAD. T
n with 100M
be a small
ng box to su
all these a
obile opera
ainst mobil
ckhaul is ju
eve that a
s than the s
g
the “bandwi
rnet service
capacity o
whether “
36
s one of ou
eve a spec
han RPI-RP
ow in more
at RPI-12%
ponse to the
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There is a
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l difference
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le operator
ustified.
a specific 1
single Ether
idth gradien
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of the circu
“Openreach
ur key conce
cific sub ca
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detail.
e Call for I
icant conce
significant
products (L
e in the cos
instead of
d has alread
any potentia
s in the TI
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net basket
nt” pricing o
al price pa
uit [“bandwid
h may hav
erns: the ex
ap no less
nputs (see
ern. Primari
differential
Local Acces
st of the int
100Mbit/s,
dy identified
al incentives
market –
ernet sub
RPI –X%.
f Ethernet s
id for a cir
dth gradien
ve been in
xcessive pr
than the b
Annex 1)
ly in relatio
cost of 1G
ss variant) (
terfaces on
the fibre is
d that there
s BT may h
and that a
cap should
services, no
rcuit increa
nt” pricing]”
n a position
icing
road
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on to
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n the
s the
is a
have
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d be
oting
ases,
and
n to
NON
115
116
117
118
119
N CONFIDE
produce
[§A5.16
5. Ofcom
100Mbi
increas
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6. Ofcom
bandwi
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bandwi
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differen
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o deliver
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concludes
higher pric
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plain wheth
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nnexes].
at “...the st
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appears to
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37
gradient with
tep increas
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s and 1Gbit
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ote that “...
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per Mbit/s
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fcom notes
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recovery of
reach will te
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notes in §A
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les.” [§6.30
external co
al sales. Fo
o BT Whol
Providers)
e categorise
of the mix
penreach h
pacity circui
could have
y and/ or
ere purcha
han BT itse
mes, we are
rnal volume
5.174, §A5
bleA5.16 sh
were purcha
capacity at
nclusion on
plains:
rnal custom
of total sales
proportion to
s, the propo
cast to grow
LLCC].
onsumption
or example
lesale sale
categorise
ed as “inte
of “interna
has an incen
its. Allowing
e an
anti-
ased
elf.”
e not
es by
.175
hows
ased
this
n the
ers.”
s for
o fall
ortion
w by
n for
, are
es to
d as
rnal”
l” vs
ntive
g for
NON
123
WD
124
Sub
125
BES
126
Anc
127
N CONFIDE
an upw
may be
this is
Openre
Annexe
3. The evi
transpa
DM
4. We not
control.
b cap on inte
5. Noted.
S
6. We not
(EAD a
flexibilit
increas
custom
cillary servic
7. We not
ECCs,
remaini
will be
cap on
the bas
ENTIAL VE
ward-sloping
e an efficien
accompa
each’s curre
es].
idence upo
arent in the
te that Ofc
We have r
erconnectio
e Ofcom pr
and EBD) s
ty in pricin
es on sin
ers.
ces
te that Ofc
it would b
ng ancillary
included in
each charg
sket) would
ERSION
g bandwidth
nt way to rec
nied by d
ent chargin
n which Ofc
BCMR asse
com does
reservations
on services
roposes tha
should be
g within th
ngle charge
com consid
be dispropo
y services.
the genera
ge (protectin
adequately
39
h gradient
cover fixed
decreasing
ng structure
com relies
essment.
not propos
s in this resp
at both legac
in the sam
hat basket
es, would
ders that, h
ortionate to
Accordingl
al Ethernet
ng increase
y address t
(i.e. higher
and commo
average
re in Table
to substan
se to includ
pect, see be
cy (BES an
me single b
but also,
give adeq
having crea
o apply a
y, whilst re
basket, O
es above th
the remaini
r costs for
on costs, pa
costs, as
e A5.15.” [§
tiate that co
de WDM w
elow.
d WES) Eth
basket. Thu
the genera
quate prote
ated a spec
separate
emaining an
Ofcom intend
he cap for e
ng ancillary
more capa
articularly w
s observed
§A5.179 L
onclusion is
within a ch
hernet and
us allowing
al sub cap
ection to
cific contro
basket for
ncillary serv
ds that the
each eleme
y services.
acity)
when
d in
LCC
s not
arge
new
g BT
p on
BES
ol for
the
vices
sub
nt of
Can
NON
Syn
128
129
The
130
131
30Synservi31As enco32PayFacil
N CONFIDE
Ofcom
Ofcom
nchronised
8. We no
services
confirm
that it w
adjustm
9. We sup
Howeve
BCMR
e Price Con
0. Given t
proposa
i)
ii)
. Ofcom
services
LLU, t
nchE allows ices are likely Ofcom rema
ouraging the uyable by LLUlities to Acces
ENTIAL VE
clarify how
applies to T
d Ethernet s
ote that Of
s30 within th
ms the launc
will consult t
ments. [§6.6
pport Ofcom
er, we are
and LLCC w
ntrols on A
the importa
al to apply s
To require
the same a
under the L
A specific
aspecifc ca
notes that
s: Co-mingl
he latter e
the distributi
y to be used inarks, the availuse of disaggreU operators ss Locate term
ERSION
w (and if so
TI ancillary s
services
fcom consi
he relevant
ch and pric
to propose
65 LLCC].
m’s propose
not clear,
why Ofcom
ccommoda
ance of acc
specific cap
Openreach
as co-mingli
LLU WLR ch
price cap o
ap on Cable
Openreach
ling and Ac
enables C
ion and mon
n the first instalability of accegated servicewho want to
ms
40
o why) its
services?
ders it ne
t Ethernet b
ing of Sync
the this (in
ed decision
having ma
needs to is
ation and P
commodatio
ps on these
h to price le
ing (the latt
harge contr
on the Acc
elink of RPI-
currently p
ccess Locate
Communicat
nitoring of acance by mobilcommodation es.[ §7.47 LLCo convert the
approach
cessary to
basket and
chE, Ofcom
cluding the
to regulate
ade the pr
ssue a furth
Power
on and pow
services:
eased lines
ter being su
rol [§7.48 LL
ess Locate
-0%)32
provides two
e. The form
tions Provi
ccurate netwoe operators foin BT excha
CC] ir Revised A
here differs
include S
that at the
m’s “current
need for a
e Synch Eth
roposal to
er consulta
wer31, we su
accommod
ubject to a s
LCC];
fee of RP
o types of a
mer provided
ders to p
rk timing ovor mobile backnges is an im
Agreement for
s to that w
Synch Ethe
point when
expectatio
any start ch
hernet serv
regulate in
ation?
upport Ofco
dation prod
separate ba
PI-0% (and
accommoda
d exclusivel
put site-spe
ver Ethernet. khaul. mportant enab
r Access Net
which
ernet
n BT
n” is
arge
ices.
the
om’s
ducts
asket
also
ation
y for
ecific
Such
ler in
twork
NON
The
132
133
134
135
136
The
RBS
137
N CONFIDE
commu
the sam
e Price Con
2. Ofcom
new cir
3. We sup
(rather
Ofcom’s
the RPI
4. We also
adjustin
base).
recover
5. Ofcom
the curr
6. We beli
conside
and gen
to remo
e baskets
S
7. We sup
ENTIAL VE
nications e
me price. [§7
ntrols on Ex
notes that
rcuit”. [§7.22
pport Ofcom
than includ
s proposal
I.
o note Ofco
ng the base
We suppor
ry upfront a
also conclu
rent ECC ch
ieve Ofcom
ers Ofcom’s
nerally. Ou
ove cost orie
pport a spec
ERSION
quipment in
7.45 LLCC]
xcess Con
“The level o
2 LLCC].
m’s intent to
de them in
to use the
om’s propos
e year cost
rt steps to
nd via renta
udes that a
harge levels
m’s conclusio
s proposal to
r reservatio
entation obl
cific control
41
n BT’s exch
.
nstruction C
of ECCs is
impose a s
the genera
General Bu
sal to preve
ts to remov
address th
al charges t
starting cha
s. We supp
ons in respe
o remove c
ons remain
ligations.
for RBS.
hanges. Bot
Costs
significant
separate co
al Ethernet
uilding Cost
ent double r
ve capitalise
he double r
too). [§7.11
arge adjust
ort an adjus
ect of ECC’
cost orientat
here in res
th are curre
in relation
ontrol on ea
basket). W
t Index (GB
recovery of
ed ECCs fr
ecovery of
LLCC]
ment is also
stment.
s are instru
tion obligati
spect of Ofc
ently charge
to the cost
ach ECC ch
We also sup
BCI) rather
f ECC costs
rom BT’s a
ECCs (i.e
o justified g
uctive when
ions from E
com’s prop
ed at
of a
arge
pport
than
s (by
asset
. via
given
one
CCs
posal
NON
Ethe
138
139
Pro
in th
140
141
142
BT
143
N CONFIDE
ernet Baske
8. We no
encomp
WECLA
9. We beli
oposed con
he WECLA
0. We note
the WE
mobile
services
cannot
every c
. We no
“potenti
network
own fib
2. As expl
may be
Commitme
3. We are
the star
of the n
enter th
believe
ENTIAL VE
ets
ote Ofcom
passing bo
A) in the sam
ieve a spec
ntrols for lo
A
e Ofcom’s c
ECLA over t
operators
s) [§8.5 LLC
increase c
harge.
ote that Of
ial of prov
ks” [§8.13L
re deploym
lained elsew
e overestima
ents
concerned
rt of the new
new period
he new cha
this must b
ERSION
m proposes
oth low an
me basket.
cific sub cap
ow bandwid
conclusions
time (and t
as well a
CC]. As suc
charges in
fcom consi
viding CPs
LCC] (pres
ents – since
where, we b
ated.
d that the ga
w controls w
notwithstan
arge contro
be guarded
42
s a relat
nd high ba
[§6.111 BC
p for 1Gbit/s
dth (1Gbit/
s that the pr
that Ofcom
as more co
ch Ofcom p
nominal te
ders the s
with great
sumably us
e passive a
believe the
ap between
will permit B
nding its com
ol period a
against.
tively broa
andwidth E
CMR]
s is justified
s and belo
rospects for
expect a c
ompetition
proposes a
erms (RPI-
safeguard
ter incentiv
ing BT leas
access reme
prospects
the lapse o
BT to increa
mmitments
t a higher
ad basket
thernet se
.
w) Etherne
r competitio
considerable
from altern
safeguard
RPI applied
cap at RP
ves to deve
sed lines ra
edies are no
for compet
of the existi
ase prices p
. This wou
level than
for Ethe
rvices (out
et (AI) serv
on are great
e demand
native Ethe
cap so tha
d to each
PI-RPI has
velop their
ather than
ot proposed
tition in WE
ng controls
prior to the
ld enable B
otherwise.
rnet:
tside
vices
ter in
from
ernet
at BT
and
the
own
their
d).
CLA
and
start
BT to
We
NON
Ofc
Gen
144
Volu
145
146
147
Effic
148
N CONFIDE
com’s appro
neral
4. We no
Ofcom’s
we do
discuss
ume forecas
5. We not
volume
expects
2010/11
25% pe
is likely
need fo
services
6. At §A5.
operato
A5.4 a
whethe
Ofcom’s
7. In respe
circuits
ciency assu
8. In calcu
the effi
[§A5.53
ENTIAL VE
oach to Co
ote Ofcom’s
s assessme
not have.
s below.
sts
te that Ofc
of TI serv
s the total n
1 (and a de
er annum) [
y to be a res
or synchron
s) [§A5.26 L
31, Ofcom
ors and that
nd A5.5.
r these Fig
s clarificatio
ect of Ethe
will increas
umptions
ulating the v
ciency gain
3 LLCC]. An
ERSION
ost Modelli
s explanat
ent is base
However,
com has ta
vices and
number of T
cline in tota
§A5.23 LLC
sidual base
isation whic
LLCC].
explains th
t the trend
However,
gures reflec
on here.
rnet, we no
se by more
value of X f
n BT is exp
nd Ofcom a
43
ng
tion of its
ed on acces
we have a
ken into ac
that by the
TI circuits t
al capacity d
CC]. Althou
e remaining
ch cannot c
at it has de
forecasts o
these Figu
ct mobile fo
ote that Ofc
than 140%
for each ch
pected to m
assumes se
costs mod
ss to BT in
a number o
ccount an
e end of t
to decline b
delivered th
gh, Ofcom
on TI serv
currently be
erived its for
of these ope
ures are re
orecasts.
com forecas
relative to 2
arge contro
make over
eperate effic
delling and
nformation c
of observat
anticipated
he charge
by over 70%
rough TI cir
also recogn
ices (e.g. w
e replicated
recasts from
erators is s
dacted. W
We would
sts the num
201/11 [§A5
ol basket, O
the charge
ciency gains
d assumpti
costs etc w
tions which
decline in
control Of
% compare
rcuits at aro
nsies that t
where there
using Ethe
m those of t
shown in Fi
We are unc
be gratefu
mber of Ethe
5.118 LLCC
Ofcom forec
e control pe
s for the TI
ions.
which
h we
n the
fcom
ed to
ound
here
is a
ernet
hree
gure
clear
ul for
ernet
C].
casts
eriod
and
NON
149
150
151
Ass
152
33 Foeffici34 “Afor a
N CONFIDE
Etherne
for TI a
9. We not
charge
declinin
of the r
conside
Etherne
improve
should
1% to 2
0. In respe
5% per
sources
trend a
the grow
. We not
internal
Openre
clear ho
BT sho
set and cost
2. We not
(Wholes
options
historica
or example, Oiency savings
AVEs and CVEa 1% change i
ENTIAL VE
et baskets (
nd Ethernet
te that in re
controls b
ng [§A5.81 L
range, we d
er that notw
et, in a com
e efficiency
at least ref
2% .
ect of Ether
r annum.Gi
s of evidenc
nalysis33, c
wth in Ethe
te Ofcom’s
targets [§
each with a
ow Ofcom m
uld be able
t volume ela
te that Ofc
sale and O
discussed
al analysis)
fcom calculatbetween 2.7%
Es are in essenin volumes” [§
ERSION
(0% to 3%
t.
espect of T
because th
LLCC]. Whi
do not bele
withstanding
mpetitive m
y and so w
flect the low
rnet, we no
ven that 2%
ce identified
coupled with
rnet volume
comment t
6.165 LLCC
n incentive
makes the j
to make ab
asticities (A
com propos
Openreach)
at §A5.106
).
tes that “over % and 4.6%” nce the percen§6.168 LLCC]
44
(BTW) and
TI, the range
e TI servi
ilst, this ass
eive that 0%
g the matu
market there
we believe
w end of th
ote Ofcom a
% is below
d at Table
h the oppor
es, we belie
that this ra
C] but that
to exceed
judgement
bove the ch
VEs/CVEs3
ses to use
via Informa
6 LLCC (e.
the period fro[§A5.89 LLCntage changes]
d 2% to 3%
e is relative
ces are m
sessment m
% should b
urity of the
e would re
the low en
he historica
assumes an
w the bottom
A5.8 [LLCC
rtunities and
eve the lowe
ange is also
t Ofcom co
the model
as to what
arge contro
34)
AVEs and
ation Requ
g. those us
om 2007/08 toCC] s in capital an
% (Openreac
ely low com
mature and
may apply to
e set as th
market an
main incen
nd of the e
l trend ana
n efficiency
m of the ra
C] including
d incentives
er end is too
o below Op
onsiders tha
led efficien
level of eff
ol?
d CVEs su
ests rather
sed in prev
2010/11 BT h
nd operating c
ch) respect
mpared to o
the marke
o the upper
he low end.
nd migratio
ntives on B
efficiency ra
alysis at aro
range of 2%
ange for all
g BT’s histo
s as a resu
o cautious.
penreach’s
at this prov
cy. We are
ficiency “bo
ubmitted by
r than the o
vious LLCC
has achieve an
costs respectiv
ively
other
et is
r end
We
on to
T to
ange
ound
% to
l the
orical
ult of
own
vides
e not
nus”
y BT
other
and
nnual
vely
NON
153
Star
154
155
Ass
156
Ass
157
N CONFIDE
3. Whilst
would b
sources
idenitifie
rting charge
4. Ofcom
of price
Openra
subject
that Of
services
5. As Ofco
regardin
well as
an “abs
sessment of
6. We not
subject
as C&W
sessment of
7. We (an
pricing.
bandwid
differen
ENTIAL VE
Ofcom may
be prudent f
s of informa
ed and teste
e adjustmen
notes that “
es and th
ach flexibilit
t to meeting
fcom does
s.
om recogni
ng the ban
more gene
sence of com
f BT Wholes
te Ofcom’s
to previous
WW (PPC A
f Openreach
nd others)
As Ofcom
dths as one
ntiation at a
“...the step
EAD, 12%
ERSION
y rely on t
for Ofcom t
ation menti
ed.
nts
“in the abse
e pricing s
ty to determ
g the charg
not propo
ses elswhe
dwidth grad
eral compet
mpetition co
sale charge
conclusion
s Ofcom sc
Appeal).
h charges fo
have expr
m notes the
e goes up th
product lev
increase in
for BES a
45
the BT sup
to sense ch
oned). Sign
ence of com
structure,
mine the m
ge control c
ose any st
ere, Telefón
dient pricin
ition conce
oncerns”.
es for TI ser
nsand in pa
rutiny as we
for Ethernet
ressed con
ere is signif
he bandwid
vel too:
n price betw
and 32% fo
pplied inform
heck it (for e
nificant adv
mpetition con
we conside
most approp
conditions.”
art charge
nica and oth
g in respec
rns. We do
rvices
articular tha
ell as that o
t services
ncern abou
ficant step
th gradient
ween 10Mbit
or WES. Ho
mation, we
example, ag
verse varian
ncerns on th
er it appro
priate struc
[§A5.182 L
adjustmen
hers have r
ct of Ethern
o not consid
t PPC char
of the CC (a
t the band
changes in
– and furth
t/s and 100M
owever, the
e believe th
gainst the o
nces should
the current l
opriate to
cture of pri
LLCC] We
nts to Ethe
raised conc
net service
der that the
rging has b
and others s
dwidth grad
n the pricin
hermore the
0Mbit/s is 8%
e step incre
hat it
other
d be
level
give
rices,
note
ernet
cerns
s as
ere is
been
such
dient
ng of
ere is
% for
ease
NON
158
159
160
Ofco
161
35 Ofbandcomm
N CONFIDE
8. We not
“tend[s]
discrim
higher
and §A
consum
conclud
9. Howeve
vs prop
ask for
proport
whethe
classifie
0. Ofcom
concen
at the c
apply a
forms a
om modellin
. We not
sensitiv
TI volum
volume
welcom
fcom also con
dwidth accompmon costs [§A
ENTIAL VE
between 1
100% incre
e that Ofco
]” to have a
inatory and
prices for h
A 5.178 LLC
me Ethernet
des that BT’
er, Ofcom’s
portions of a
r greater c
ions) of ex
r BT Whol
ed as extern
has of cou
tate price re
cost of RBS
at the cost
a significant
ng
te that Ofco
vities of the
mes fall by
s increase
me clarificati
ncludes that supanied by decA5.179 LLCC
ERSION
00Mbit/s a
eases for all
m’s respon
an incentive
d/ or anti-co
high capac
CC Annexe
t circuits as
’s pricing ca
s assessme
all Ethernet
clarity as t
xternal vs in
lesale’s use
nal consum
urse already
eductions (f
S circuits, w
of 1Gbit/s
proportion
om seeks to
costs base
70% over
by over 80
on:
uch pricing (recreasing averaC Annexes].
46
and 1Gbit/s
l three serv
nse to this is
e to price t
ompetitive w
ity circuits
es]) becaus
s well as ex
an be an eff
ent here ap
circuits, no
to Ofcom’s
nternal con
e of circuit
mption.
y concluded
for example
we see no r
s Ethernet
of the dem
o provide so
e case to its
the charge
0%. There
ecovering morage costs) may
s is substan
vices.” [§A5.
s that it doe
the differen
way (i.e. no
(relative to
e BT’s own
xternal cust
ficient appro
pears to be
ot specifical
s assessme
sumed 1Gb
ts for resa
d that there
e) on those
reason why
circuits wh
and for 1Gb
ome transpa
modelling
control per
e are some
re fixed and cy be an efficie
ntially grea
166 LLCC A
es not consi
t bandwidth
o strategic i
low bandw
n downstre
tomers. Mo
oach.35
e in respect
ly 1GBit/s.
ent of the
bit/s circuits
le to mobi
e is an ince
PPCs cons
such incen
ere externa
bit/s.
arency as t
assumption
riod, whilst
apsects w
ommon costs ent way to rec
ater: more
Annexes]
ider Openre
h products
incentive to
width) [§A5
eam busines
oreover, Of
t of the inte
Hence, why
balance
s. In partic
le operator
entive for B
sumed by it
ntive should
al consump
to the indica
ns (for exam
Ethernet ci
where we w
from higher cover fixed an
than
each
in a
o set
.173
sses
fcom
ernal
y we
(and
cular,
rs is
BT to
tself,
d not
ption
ative
mple,
ircuit
would
d
NON
N CONFIDE
i)
ii)
iii)
ENTIAL VE
Ofcom rem
cost foreca
this has be
The degre
example,
information
1Gbit/s se
Ofcom use
We note th
increase by
estimates a
ERSION
marks that “
asts carried
en achieved
ee of robu
we note
n for modell
rvices. [§A
d in respec
hat Ofcom’s
y 80% over
a 140% incr
47
“EAD servic
d out at com
d and wher
ust sense
that Ofco
ing the esti
A5.228 LLC
ct of 1Gbit/s
s sensitivity
r the period
rease?
ce costs co
mponent lev
re that analy
checking
m propose
mated cost
CC Annexe
circuits?
y analysis a
d. However
ould be obt
vel”. We a
ysis can be
of 1Gbit/s
es to use
ts of WES a
s]. What in
ssumes Eth
, at §A5.11
tained from
are unclear
found.
services.
e Openrea
and BES ab
nformation
hernet volu
8 LLCC Of
m the
how
For
ach’s
bove
has
umes
fcom
NON
CO
162
163
164
165
Tele
Sep
N CONFIDE
NCLUDIN
2. We not
price co
BT and
3. Genera
exampl
above)
particul
from ex
inputs),
up acce
aggrega
Openre
4. We trus
conclus
5. We look
efónica UK
ptember 20
ENTIAL VE
G COMME
te that Ofco
ontrols fram
KCOM’s re
ally, we ar
e in respec
that Ofcom
ar, that the
xcessive pri
that Ofcom
ess to BT’s
ation netw
each DWDM
st Ofcom fi
sions and B
k forward to
K Limited
012
ERSION
ENTS
om has conc
mework rem
espective S
re supportiv
ct of ECCs
m has not
e charge co
icing of 1Gb
m could stim
s assets via
works, Ofc
M systems.
nds our co
CMR and L
o hearing ho
48
cluded that
mains an ef
MP.
ve of the
s). However
t addressed
ontrol struct
bit/s circuits
mulate opp
a passive a
com shoul
omments in
LLCC regula
ow Ofcom p
t, with some
ffective and
adjustmen
r, we are c
d certain k
ture fails to
s (and is no
portunities fo
access solu
ld support
this respon
atory framew
proposes to
e adjustmen
d proportion
nts Ofcom
concerned (
key issues
o protect m
ot reflective
or competit
utions and,
t multiple
nse helpful
work.
deal with o
nts, the exis
nate remed
proposes
(as we disc
for mobile
mobile opera
e of the cos
tion by ope
in the cas
CPs sha
in finalisin
our concern
sting
dy to
(for
cuss
e. In
ators
ts of
ening
se of
aring
g its
s.
NON
ANN
Inpu
Ethe
As w
in co
may
supp
Fibr
a ful
We
very
1Gb
EA
EA
EA
1000
EA
1000 (
period
For
the p
cost
N CONFIDE
NEX 1 - Ext
uts: 5 Sept
ernet 1Gb p
we say in the
omparison w
y be a small d
port 1Gbits in
re is dedicate
ll Gbit make
note (see fol
y different, ev
bits vs the 10
AD Local Access
AD Local Access
AD Local Access
AD Local Access
(60 month minim
d)
the non “LA
per km charg
ts of providin
ENTIAL VE
tract (Ann
tember2011
pricing vs 10
e covering let
with and 100M
difference in
nstead of 100
ed to each ser
es no differen
llowing table
ven though t
00Mbits.
Effective
10 30/09
100 01/10
22/04
mum
15/12
A” variant and
ge is the sam
ng dedicated
ERSION
ex 2) from
1?
00mbit
tter, there is
Mbits EAD p
the cost of t
0Mb, the fib
rvice in all c
nce to traffic
e) that the dif
this gives the
e date
9/2010
0/2011
4/2009
2/2010
d a main link
me for all vari
fibre to supp
49
Telefónic
a significant
products (Lo
the interfaces
bre is the sam
ases, so whe
loading (the
fferential bet
e same propo
Capacity
increase
compared
to lower
b/width
product
x 10
x 10
k charge app
iants, re-enf
port any of th
ca response
t differential
ocal Access v
s on the netw
me.
ether that fibr
ere is no rout
tween 10Mb
ortional incre
Connection
1,560.00
1,950.00
2,500.00
2,500.00
lies because
forcing the vi
hese services
e to Ofcom
[Opex] cost
variant) (2.25
work terminat
re is carrying
ing equipme
its and 100M
ease in bandw
%
difference
to product
25.00
28.21
it crosses ex
iew that in pr
s is the same
m Call for
of 1Gbits EA
5 x). Whilst t
ating box to
g a few Mbit
ent involved)
Mbits service
width as the
Annual
Rental
2,125.00
2,131.20
4,800.00
3,600.00
xchange area
ractice BT’s
e.
AD
there
ts or
).
s is
%
difference
to product
0.29
125.23
as,