16 Rev2b NGA Opinion Supplementary doc - IRG

ERG (07) 16rev2b NGA Opinion Supplementary Doc 1 / 69
Supplementary Document to the ERG Opinion on Regulatory Principles
of NGA
Part 1: Consultation Report
In the Consultation Document on Regulatory Principles of NGA (ERG (07)16) interesting
parties were invited to comment on the 5 questions, each related to a particular
chapter of the document. The Consultation Report is structured along these questions
as raised in the Consultation Document:
Q1: Do you agree/disagree with the general approach?
There were slightly more agreeing (mainly competitors / respective associations) than disagreeing
comments (mainly incumbents / respective associations)
Q2: Do the scenarios describe the relevant roll-out alternatives for NGA?
The majority of comments considered the 2 scenarios appropriate. Dissenting views mainly
missed consideration of alternative technologies.
Q3: Do you agree/disagree with regard to the conclusions on economics and business
case studies?
Several respondents commented that the economics of NGA varied substantially between
geographic areas. Several altnets stressed that NGA costs and cost savings should be considered
together and some felt that NGA increased the scope for the access to be a bottleneck.
They also called for investment plans to be disclosed by incumbents prior to deployment.
On the other side, incumbents advocated a regulatory approach that did not deter investment
and innovation.
Q4: What is your opinion on the regulatory implications and on the evolution of the
ladder of investment? Additionally please provide more specific comments regarding
the issue of multicast capabilities and their regulatory treatment.
Those who welcomed the general approach also agreed to the regulatory implications drawn
by the ERG and stressed the need of having available different rungs of the ladder simultaneously.
In particular, they welcomed the inclusion of fibre in Market 11 and some stressed
the importance of an enhanced Bitstream product. Broadly, the opposite view was taken by
the incumbents, who constitute an extension of existing regulation to the NGA environment.
Thus, they reject the inclusion of fibre in Market 11 and express doubt with regard to the appropriateness
of the ladder concept in an NGA environment.
Q5: Do you agree/disagree with the conclusions?
Comments to this question overlap in particular with the comments to question 1, but also
with the other questions. Therefore the remarks to question 5 are addressed under the other
questions.
In total 37 comments were received from the following stakeholders:
1) Alcatel-Lucent
2) Arcor AG & Co. KG
3) Association Française des Opérateurs de Réseaux et de Services de Télécommunications
(AFORST)
4) British Telecom
5) Broadband Stakeholder Group (BSG)
6 Bundesverband Breitbandkommunikation (BREKO e.V.)
7) Cable & Wireless