16 Rev2b NGA Opinion Supplementary doc - IRG

ERG (07) 16rev2b NGA Opinion Supplementary Doc 7 / 69
Question Chapter 2: Do the scenarios describe the relevant roll-out
alternatives for NGA?
Consultation Comments
The Consultation Document distinguishes between two main scenarios - Fibre to the Cabinet
and Fibre to the Home / Fibre to the Building – as these broadly appear to be the most relevant
cases in several Member states. The majority of comments considered the distinction
between these two scenarios appropriate (Arcor, BSG, FTTH Council Europe, ONI, QSC,
Silver Server, Sonaecom, TDC, Tele2). A more critical view was taken in particular by the
incumbents and cable stakeholders (BT, Cable & Wireless, Corning, KPN, PT, TI, Telefónica).
Their main point of criticism was that alternatives technologies (e.g. cable) are missing.
Another incumbent (FT) considers FttB to belong to the FttCab-Scenario (similar
ETNO).
Besides these rather general points some specific issues referring either to the FttCab-
Scenario (Chapter 2.2) or the FttH/B-Scenario (Chapter 2.3) were raised in the comments.
Scenario I: Fibre to the Cabinet
One comment considered FttCab a simplification (ECTA, similar Tele2), as incumbent’s
passive metallic cable distribution systems being closer to the MDF are not always located in
street cabinets but of placed in (e.g.) operators’ own small buildings or building’s cellars.
Thus, ERG should apply a more open approach when addressing the issue of access to cable
distribution systems, not limiting access to street cabinets only.
The key characteristic of Scenario I is not the fact that fibre is brought lower in the network
hierarchy. Instead, key characteristics are the new risks of spectral interference with ADSL2+
deployed higher in the network architecture, and that there is a risk that dominant operators
could undermine or breach the unbundling mandate (Tele2).
Another stakeholder emphasized that there will be no clear FttCab scenario “for a very long
time” because the roll-out will only be economical in some areas (ETP).
Scenario II: Fibre to the Home / Fibre to the Building
In one comment it is criticized that point-to-point fibre NGA is not considered (C&W). Another
comment stressed that point to point FttH and point to multipoint FttH roll-outs are highly distinctive
(PT).
A competitor points out that currently “probably more point-to-point Ethernet is being rolled
out than GPON (Tele2). This is attributed “to the fact that incumbent operators are lagging
behind competitors and behind the publicly funded and the utility fibre networks. Thus, footnote
39 is seen as overstating the importance of GPON. Moreover, the ERG is invited to further
investigate wavelength access, in particular whether splitters could be utilized, enabling
wavelength unbundling at higher levels in the network hierarchy.
An incumbent considers the scenarios “reasonably comprehensive for fibre” (BT) and another
comment considers FttB/H to be the sustainable long-run solution (FTTH Council
Europe).