Incumbent Australian fixed-line network provider Telstra has thrown its support behind structural separation of its retail and wholesale arms, and the continuing transition to the National Broadband Network (NBN), but has indicated that significant changes need to be made to the network.
The call was made in Telstra's submission to the government's broadband cost-benefit analysis panel, headed up by Michael Vertigan, that will, in part, determine the future broadband technology options and regulatory structure of the NBN.
Telstra's submission, which has not yet been made public, but has been provided in part to ZDNet, threw the company's support behind the continued "progressive structural separation" of Telstra's retail and wholesale fixed line businesses. However, it said that NBN implementation needs to be refined to improve the experience for customers migrating from Telstra's copper network to the NBN.
"Industry, regulators, and policy makers need to focus on how to build more efficient end-to-end migration processes, to develop a wider range of NBN products to allow a smoother transition from legacy networks to the NBN, to improve service quality and functionality on the NBN and to achieve more transparency about the NBN rollout," Telstra said in its submission.
Telstra is not the first company to make such a call. iiNet has previously argued that NBN Co's rigid product model, ranging from 12Mbps down right up to 1Gbps down is inflexible for what customers are wanting from the network.
Telstra also said that the existing regulatory framework around the NBN has "proven to be slow and inflexible", and needs to be shifted to an industry code of conduct.
"Better end-user outcomes could be achieved by an industry-led process of rule making for NBN implementation, within a framework of Ministerial Migration Principles, which would apply to all industry players. In this framework, industry-based rules would be lodged with and enforced by the Australian Competition and Consumer Commission (ACCC) to ensure competition and consumer issues are addressed," Telstra said.
"NBN Co also would not be a de facto standards setter, but would refer to the industry process technical standards on its network, which impact across access seekers. This model is likely to deliver a more collaborative, 'problem-solving' approach to managing the complexity of NBN implementation."
Telstra has already indicated that it may follow in TPG's footsteps and begin rolling out fibre to the building to directly compete with NBN Co. In the company's submission to the Vertigan panel, Telstra said that facilities-based competition should be allowed for new housing estates, metropolitan apartment buildings, and "elsewhere as defined by legislation".
"The extent to which facilities-based competition to the NBN is permitted is a policy decision for government. Telstra's position is that if facilities-based competition is permitted, there must be a level playing field between all alternative builders, whether under regulatory restrictions like the super-fast broadband rules or under contractual commitments to NBN Co," Telstra said.
NBN Co has indicated that it may have to speed up plans to roll out fibre into the apartment blocks where TPG and others roll out their own networks unless the government steps in and closes the regulatory loophole that allows TPG to expand its network out into those locations.
Industry lobby group the Communications Alliance said in its submission that VDSL2 services over fibre to the node or fibre to the basement would need for the existing regulatory framework for wholesale services over the copper network to be changed to allow for a single provider to access the copper line, and then provide wholesale services to other companies.
"To reap the maximum performance benefits of vectoring and prevent service instability (eg dropouts), no more than one provider can offer vectored services within each cable sheath. This effectively means that there can only be one provider of VDSL2 network services in a node serving area or within a multiple dwelling unit or business centre development. This could be a wholesale-level provider, giving the opportunity for open access to enable other providers to offer services through the node," the alliance said.
Fibre to the premises must not be excluded
In iiNet's submission (PDF) to the review, the internet service provider argued that although the NBN Co strategic review has recommended a multi-technology model network of majority fibre to the node, this was only ever determined based on the cost of building the network, rather than the benefits that fibre to the premises may offer.
iiNet said that the panel should not rule out fibre to the premises just because the government's policy seems to exclude it.
"The government's rejection of the FttP attribute has preceded the panel's cost-benefit analysis," iiNet said.
"It is at least possible that the fact that the costs and time frames of implementing the FttP attribute have gone beyond what was stated in the NBN implementation study may be due to implementation issues on the part of NBN Co, rather than the FttP attribute being bad in principle."
iiNet said that the panel should form its own view on FttP, and consider whether the multi-technology model would result in a "patchwork" NBN that may not make it possible for one standardised OSS/BSS system.