LLU Discussion Document

Thanks RPM, alot of users (myself included) have been waiting to read this long awaited document.
 
ICASA said:
2.2.3 An outline of earlier steps to introduce local loop unbundling

1. In 2006 the then Minister of Communications (Minister) announced a committee headed by Professor Tshilidzi Marwala to recommend how incumbents' local loop networks could be unbundled.

The overall task of the committee was to investigate possible Local Loop Unbundling (LLU) methods and to make appropriate recommendations in this regard.

2. In the report*(3) presented to the Minister in 2007 the LLU committee recommended that:

- a combination of three unbundling models would be appropriate;

- any form of collocation of facilities for LLU must be allowed; and

- any operator appropriately licensed by ICASA should have access to the local loop to deliver voice and/or broadband regardless of who owns it.

3. As a result of this report, it was proposed that a regulatory guideline be developed and overseen by ICASA to ensure that strategic issues such as the quality of the local loop, its maintenance and technical compatibility are optimised for regulation and service delivery. It would also be necessary to prescribe regulations that govern access pricing. It was also recommended that ICASA should implement carrier pre-selection regulations to support successful implementation of LLU.

4. The report further recommended that Telkom form a new facilities and services management entity on such terms and conditions as shall be agreed with ICASA. It was also emphasised that ICASA must be capacitated to physically inspect the incumbent's premises for issues that may be required for the implementation of the unbundling of local loop.

5. ICASA published a notice on 28 February 2008 to invite stakeholders to take part in the LLU process. The notice process was followed by an exploratory workshop on LLU on 23 September 2008.

6. However, access to the local loop represents a specific form of facilities leasing, which is governed by the principles in Chapter 8 of the ECA. ICASA chose to refrain from continuing work on local loop unbundling until the framework regulations for electronic communications facilities leasing agreements were finalised as required by Section 44 of the ECA.

7. ICASA published the electronic communications facilities leasing regulations, on 31 May 2010, which outline the required content of all facilities leasing agreements.

8. As part of fulfilling the recommendations made by the Local Loop Unbundling Committee (LLUC) and in line with Section 42 of the Act, ICASA further published regulations on carrier pre-selection, on 27 September 2010, as precursor regulations for the successful implementation of LLU.
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5 years later and we have moved on to discussion.
 
OCRed.

ICASA said:
4. Developing a guideline to introduce local loop unbundling: the way forward

1. ICASA has identified four options for unbundling the local loop,
described below.

4.1 Option 1: Bitstream access- Wholesale access

1. Bitstream service may be defined as the provision of transmission capacity between an end-user connected to a telephone connection and a facilities seeker, where the point of interconnection available to the licensee that requests access to facilities is upstream of the network providers network edge broadband equipment (for example, upstream of a DSLAM)

2. In most cases Bitstream access depends in part on the PSTN or Electronic Communication Network (ECN) operator and may include other networks such as the ATM network.

3. It is important to note that direct resale offerings are not a substitute for Bitstream access because they do not allow facilities seekers to differentiate their services from those of the facilities provider

4. In providing a bitstream service, the facilities provider typically provides both the transmission medium (e.g. copper cables) and transmission system (e.g. xDSL transmission on copper cables). Technically, bitstream can be provided to any transmission system, since it requires reservation of a specified bandwidth, rather than dedicated use of a physical loop.

5. This option does not entail any unbundling of the copper pair, but employs the high frequencies of the copper loop as in the case of shared use of the copper pair, for example. A facilities seeker does not have access to the actual network infrastructure elements of the facilities provider but has access to the bit stream on the network side of the Digital Subscriber Line Access Multiplexer (DSLAM). In this case, the DSLAM is installed and operated by the facilities provider who sets up the speed and quality of service (QoS) of each user's DSL access link.

6. This type of service may be attractive to the facilities provider as it does not involve physical access to copper pairs.

7. In a situation where the facilities seeker would be able to distinguish their services, such as VoIP and email, from those of the facilities provider, the seeker must be granted access at a point where they can control certain technical characteristics of the service to the end-user and/or make full use of their own network or other network offerings. This would present facilities seekers with an opportunity to change the quality of services or other factors such as adjusting their offerings in terms of rates, contention ratio or other features.

8. The advantage with the bitstream access option is that it would not hinder any progressive modernisation of the local access network by replacing copper cables with optical fibre cables.

9. It should be noted that Bitstream is normally offered only for subscribers at locations where the incumbent already offers broadband. Therefore the capital costs of establishing a broadband capability will already be covered.

10. However, in providing a bitstream service, a facilities provider is likely to face upfront capital costs, including:

- Specifying and establishing the ordering system and internalprocedures

- Establishing the backhaul

- Establishing the testing arrangements

11. A facilities provider will also face certain variable costs, including:

- The costs of the DSLAM

- Per subscriber order costs

- Per subscriber modem costs

- Traffic volume costs of backhaul services

- On demand testing costs

12. Figure 1 illustrates a simplified arrangement for bitstream access.

13. In evaluating the introduction of a bitstream service, certain quality of service parameters also have to be established. Below is a list of such parameters that have to be standardised:

- Packet loss in the backhaul.

- Maximum delay added by the backhaul

- Maximum delay variation added by the backhaul.

4.2 Option 2: Line Sharing (Shared Access to the Local Loop)

1. Line Sharing takes place when the facilities provider retains use of the loop for its baseband, PSTN services, but unbundles the higher frequency part of the spectrum for use by a facilities seeker. This model enables facilities seekers and providers to share the same line where both the facilities provider and the seeker provide different services such as voice and data on the same loop.

2. In this situation, consumers can acquire data services from facilities seekers while retaining the voice services of the facilities provider. Some facilities seekers may choose to offer data services only, so with line sharing consumers can retain their facilities provider service for voice calls while getting higher bandwidth services from another operator without needing to install a second line.

3. Technically, a splitter is connected to the wires in the Main Distribution Frame (MDF). The splitter separates the frequencies for voice telephony and those for higher bandwidth services. It is located between the MDF and the facilities provider's local switch - downstream of the network edge. It is connected to both the facilities provider's switch and to the DSLAM connected to the facilities provider's high-speed network. The local loop normally includes the splitter which remains a part of the facilities provider's network.

4. Furthermore, line-sharing allows the facilities seeker to provide the service of their choice by covering either low frequency bands or high frequency bands. For instances, when one frequency band is occupied by one operator the other frequency band can be occupied by another operator.

5. This option would broaden choices available to the end-user as it would allow them to retain the network operator as its provider for voice telephony services and at the same time choose the new entrant or any operator as the provider for broadband high-speed internet services over the same loop.

6. However, in providing a shared service, a facilities provider is likely to face upfront capital costs, including:

- Specifying and establishing the ordering system and internal procedures

- Establishing the testing arrangements

7. A facilities provider will also face certain variable costs, including:

- The costs of the DSLAM

- Per subscriber order costs

- Per subscriber modem costs

- On demand testing costs

8. Figure 2 illustrates a simplified arrangement for shared loop unbundling

4.3 Option 3: Full Local Loop Unbundling (Full Access)

1. The Full Unbundling option assigns the entire copper local loop to the facilities seeker, which means that the facilities seeker gains access to the copper local loop and sub-loops or other format of loop (network). This option enables the facilities seeker to install its own broadband equipment and co-locate, i.e. the facilities seeker may place all required equipment inside or outside the facilities providers' premises, depending on which co-location model is most appropriate.

2. In this option, the facilities seeker takes over the full operation of the allocated local loop. It also means that it will have access to both low and high frequency. In some cases this option may mean that the facilities seeker has all loops dedicated to it. The capital costs incurred by the facilities provider are represented by:

- Specifying and establishing the ordering system and internal procedures

- Installing a handover frame

- Co-location costs

- Establishing the testing arrangements.

3. The variable costs to be faced by the facilities provider are the:

- Per subscriber order costs

- On demand testing costs.

4. Figure 3 below shows a simplified arrangement for full loop unbundling

Figure 3: Full loop unbundling

4.4 Option 4: Sub Loop Unbundling

1. Sub Loop Unbundling represents a situation where the facilities seeker accesses the network of the facilities provider at the primary connection point (PCP) within the network, at street level. This form of unbundling may be used for emerging technologies such as VDSL, which requires very high bandwidth and therefore a much shorter length of cable. In this situation the facilities seeker would provide its own network all the way to the PCP

2. In this situation the equipment that transfers the connection from the facilities provider to the facilities seeker is adjacent to the PCP, rather than in the exchange.

3. In all other respects, sub-loop unbundling is analogous to full-loop unbundling.

4. The capital cost incurred by the facilities provider is the cost of the link between the PCP and the facilities seeker's network. Variable costs, including maintenance of the line should be negotiated between the facilities seeker and provider.
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(cont)
5. Conclusion and stakeholder input

1. This discussion document represents ICASA's proposed approach to the introduction of local loop unbundling in South Africa. The approach may be summarised as follows:

- Access to the local loop is mandated under the obligation to lease electronic communications facilities

- All ECNS licensees face this obligation until otherwise exempted

- The pricing of access to the specified facilities must be non- discriminatory at all times

- There are four potential options for the introduction of access to the local loop, namely:

- Bitstream

- Shared loop unbundling

- Whole loop unbundling

- Sub-loop unbundling

- To ensure the introduction of a stable regime of gaining access to any ECNS licence holders' network it is crucial to standardise the format in which any request for access to facilities is governed by an industry- wide accepted standard.

- This standard, specified as a guideline from ICASA, is necessary so as to facilitate the actual conclusion of facilities leasing agreements

2. ICASA therefore seeks stakeholder input on the following:

- Is ICASA's proposed approach to unbundling the local loop through the implementation of the facilities leasing regulations reasonable, feasible and acceptable?

- What form of local loop unbundling do stakeholders realistically favour in the South African market?

- What other cost items should be included in each form of local loop unbundling?

- Should a standardised ordering and specifications system be developed?

- In the event that an access line deficit is identified, would you be willing to contribute to an access line deficit recovery scheme?

3. On the basis of stakeholder responses, ICASA seeks to establish two collaborative working groups. The first working group, the Access Working Group will address technical matters. The second working group, the Pricing working group, will address pricing and non-discrimination concerns.
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Please make a point of emailing these guys and participating in the upcoming one-on-one sessions in August. It seems we may be able to make a difference. FULL LOOP UNBUNDLING - THIS. IS. SOUTH AFRICA.
 
it would be useful to have a small delegation from MyBB representing the views of the forum...
 
Very good idea...

If I was in that part of the world I would offer my pretty useless services....
 
ToxicBunny said:
Very good idea...

If I was in that part of the world I would offer my pretty useless services....
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as attractive as the non-offer is....

I must admit i got sidetracked by one part of the document relating to bundling and non-discrimination which is probably far more useful than LLU itself. Once i have gone through it i will put up some thinking for the forum to consider.

The critical thing here - as someone who participates in most ICASA processes - is that there is hardly ever a consumer voice presented and there is therefore both a need and a gap for a reasonable consumer perspective to be expressed - MyBB is in many ways the obvious candidate to fill it.
 
MickeyD said:
Good idea. Proposals? Rudolph + ???
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not sure - but i would go for a max of 2-3 people with a tight presentation using the figures reported on the site to show the consumer interest and potential benefit
 
dominic said:
not sure - but i would go for a max of 2-3 people with a tight presentation using the figures reported on the site to show the consumer interest and potential benefit
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Not so easy as we will need folks with a combination of sharp minds and excellent presentation skills (there are quite a few here!) who are not directly involved with any of the major players. Or else it could be a career limiting move.

*looks around*

Nominations?
 
Well I do nominate rpm for this one at the very least.

Then I would suggest (if we can convince him with enough alcohol AFTER the fact), maybe a person like DJ... who does seem to have a relatively sharp business mind.
 
MyBB will be submitting its comments on this document, and needs your input.

Please comment in this thread, identifying the option(s) you believe to be the most ideal and provide your reasons for it. You can also provide reasons why you think a particular model would not work. Feel free to add any additional comments you may have.

We will collate your responses and present it as the consumer submission.

If you have any questions, ask them and we will do our best to provide an answer.

Keep it reasonable, folks.
 
I would think all the unbundle options should be considered (implemented) as we want as many player (ISPs) as possible to develop products. If we only go for one or the other or even 2 or 3 we may leave out some ISPs as it will not be feasible to use the loop.

In a South African market it makes sense to make the options as granular as possible to allow everyone from the small to the large the option to get involved on the same cost per line (user).

Secondly any legal action against the published LLU process should not stop the process from being implemented until the courts rule. This will prevent any delaying tactics by LL owners.
 
That would result in consumers saving - we cant have that. Dont you know?
 
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