We would like to observe that we find it very difficult to approach this document as it appears to proceed from the core assumption that there are no NGN assets in the state.
There are a number of operational NGN networks already , particularly the ESB and eircom core .
Yet no data is forthcoming on their operation and traffic growth and on the advantages that appertain to their being operational .
We have had an operational NGN in Ireland for 6 years ….surely we must have learnt something from that and from which we can push its advantages closer to all stakeholders.
Because of this that the consultation appears to be a greenfield exercise where a greenfield exercise is not appropriate in this instance . In fact it is quite infuriating at times .
Question 1: What speeds and other quality of service parameters will be demanded by businesses and consumers over the next 3 to 5 years?
Please explain your reasoning. Do you believe the market itself will deliver these capabilities, and within what timeframe?
Irelandoffline . We believe universally or near universally available speeds should be in the region of 25Mbs or greater, with at least 10Mbs upload , tail length permitting .
Furthermore Net Neutrality is an important concept . That is often ignored. Operators should allow any IP protocol on their systems and should not prioritise one protocol over another or shape arbitrarily .
The market can never realistically deliver these speeds as the market in Ireland is very underdeveloped. We have waited 10 years for LLU which still does not function smoothly as an industry process.
The only possible way anything like these speeds is through government intervention in the market as is clearly seen in most other developed countries where NGN have been deployed and through clear sighted regulation.
We also feel that Comreg should have bitten the bullet and stated outright that NGN is Ethernet …which it is . Comreg should also have pointed out that there is a great deal of unanimity in the industry on Core Ethernet and its workings but that there is some disagreeement and a consequent protocol was on Metro and Last Mile segments .
Furthermore we believe that Comreg has to state what infrastructure it envisages pushing nearer the end customer to achieve these speeds and state how long the metro and last mile uncertainty may be allowed to last before a decision is made . It will certainly be a live issue over the the next 3-5 years but should be put to bed by then .
Question 2: Do you agree that NGB network deployments can provide a socio-economic benefit? If so, who are likely to be the greatest beneficiaries and why? Should the policy framework explicitly favour the development of NGB in Ireland, and with what specific socio-economic goals in mind?
Irelandoffline . NGB is less costly than traditional SDH and Docsis deployment , being simple ethernet . As Comreg is still struggling with basic competition 101 issues and with industry matters we feel that socio economic goals may be too abstract for Comreg until some clarity and vision is apparent in their approach to fundamental competition and to its delivery .
Question 3: How important will cross-platform competition be to the development of NGB Networks? Do you consider that all broadband platforms are capable of supporting NGB? In what circumstances might some such platforms be more suitable than others in providing timely and efficient NGB
Irelandoffline . Through pushing a state owned and fully lit NGN network to within 50km of each citizen over the period in question . This extension of backbone allows easy entry to the market nationwide. At present the only meaningful competition is coming from Cable which is an urban technology with spotty availability .
Final mile technology normally delivers an ethernet layer to a core , it is somewhat irrelevant what that is of what encapsulation is performed .
Question 4: Do you consider that substantial (both in cost and coverage terms) private sector led investment in the development of NGB networks is likely over the next 3-5 years? If not, and should a gap occur in comparison to other European countries, what will be needed to encourage such private sector investment in Ireland?
Irelandoffline . Functional separation of the eircom retail and wholesale functions.
A clear and unambiguous regulatory environment
The lack of such an environment , together with patchy rollout of NGN assets such as ESB/Aurora fibres and pops, is the chief structural deficit now as it was 5 years ago .
Question 5: In what circumstances would any of the above (or other) approaches be appropriate in stimulating NGB roll-out in Ireland? How might such interventions safeguard the development of competition?
Irelandoffline . Extending state owned NGB networks ( ESB/ IE / Bord Gais to within 50km of each citizen to a local handover point. A stated objective to get it to 30km within 5-7 years would also be a help .
All fibre assets in the state (private and publicly owned) be joined up into one overall network and with NGN interconnect and transparent end to end operation .
If these were achieved over the next 3-5 years it would be wonderful , sadly they are not even envisaged by Comreg ,
Question 6: Do you consider that the issues identified are the main enablers and inhibitors of NGB developments or are other issues of greater relevance? Who are the key stakeholders who might be in a position to influence these issues and how might they best do so?
Irelandoffline . Equipment makers and different ethernet protocols and interoperabilit issues . They are currently in a spat over MPLS/PBBTE which is likely to resolve itself shortly . This leads to clarity of standards from which investment may be planned .
Question 7: Are the areas identified the relevant tools available to ComReg for accelerating NGB investment in Ireland, or could other regulatory levers be as or more effective? What might be the impact of these activities on both the level and timing of NGB developments?
Irelandoffline . Comreg cannot blissfully sit on a fence for ever. It has to lay down standards and aspirations and hard targets and not to wallow in permaconsult . The fluffy aspirational nature of this consultation with no reference to standards ….not even ethernet ….leaves us in a position where we are eying up the starting gate but not actually entering it .
Question 8: Do you see a role for collaborative industry approaches in seeking to agree wholesale models for open access to SMP operator NGB networks? Will infrastructure sharing be critical for early deployment of NGB in Ireland? What do you see as being the appropriate regulatory response in such circumstances, particularly in light of the need to promote effective competition, innovation and incentivise investment?
Irelandoffline . Where else does meaningful employment generating and employment maintaining competition in Ireland come from ( paltry as it is) , certainly not from LLU .
Early NGB deployment in Ireland was achieved years ago by carriers who use ESB fibre . Surely some lessons have been learnt from that by now ???? Yet we are being asked to model a model that exists ….and which should be extended further and maybe improved .
Question 9: What role has the regulation of investment incentives such as wholesale pricing to play in stimulating the development of NGB networks?
Irelandoffline . A key role but Comreg have not chosen to share any real vision of this role with anybody , have they ??? . What have other countries done ???
Question10: Is there a case for allowing a differentiated regulated rate of return for Eircom in relation to risky NGA investments, and would this in fact be effective in encouraging early and widespread development of NGB fixed line networks?
Irelandoffline . There is , again the vision thing would be useful and we should have some idea of whether these deployments would be universal or merely designed to compete in cities with cable . We feel that such an approach cannot work in teh absence of functional separation in any case.