I have been a little occupied lately, but fortunately I still managed to complete a submission in time.
The proposal seems to believe that wholesale unbundled dark fibre is the best method to serve all customers, which is absolutely incorrect. The negative impacts identified in this submission are caused by this, and forcing LFCs to engineer the networks in such a way.
Unbundled dark fibre is only suitable for a small percentage of customers and is completely unsuitable for the remaining customers that make up the vast majority. It is important that this distinction is understood, and that the proposal targets the distinct needs of these two categories of customer.
The full 21 page submission is available in PDF format here.
{ 2 comments… read them below or add one }
A well thought out submission… I have long thought that true competition occurs and should well occur at the higher (logical) layers so that transfer from provider or service A to provider or service B occurs at the logical level. I also agree with you that in todays environment the deployment of an PON architecture with pre-provisioned connections to each home passed by the new fibre roll-out is the way to go, however, this in itself is fraught with difficulty. Take for example the average home the does not have structured internal wiring, it will be difficult for them to experience the same service they currently do, i.e. be able to plug a phone into an existing jackpoint and have the phone work without additional internal wiring work. True this wiring could be minimal but it must also be addressed.
Also, by deploying a flexible PON architecture today you are not actually precluding upgrading that to point to point in the future by simply transferring the feeder fibre to a multicore feeder, this will result in disruption of service but could be done.
Thanks for your feedback about my submission.
The internal wiring is a problem, that is why I’ve submitted to the Government, as far back as 2005, that they need to adjust the codes accordingly. I imagine something will be sorted out about that soon.
It is not entirely bad though. If the house is already wired for RF television then the RF output on ONT can be connected to this. Similarly, the internal telephone wiring can still be used (even if Telecom protests). The wiring for Ethernet is problematic, but given this is New Zealand I can see many people taking out a drill and happily doing it themselves, so long as they’re given the correct guidance.