Further Input to Consultation Document No. 09/39 on Local Loop Unbundling (‘LLU’) and Sub Loop Unbundling (‘SLU’) Monthly Rental Charges

In response to: http://www.comreg.ie/_fileupload/publications/ComReg0962.pdf Comreg Note “In Consultation Document No. 09/39, ComReg expressed the preliminary view that 1,600 lines represented a highly conservative point at which to draw the boundary between those exchanges that are considered viable for unbundling during the control period (large exchanges) and those that are not (small exchanges). ComReg now believes that a threshold of exchanges containing at least 2,500 lines is appropriate because: In operator responses to Consultation Document No. 09/39, the majority of operators believed that a cut-off of 1,600 lines was inappropriately low. A number of the operators indicated that the cut-off point...