On 6 May 2010 the Australian Government released the National Broadband Network Implementation Study. The Implementation Study examines the Government’s coverage, commerciality and competition objectives as well as the detailed operating arrangements of NBN Co Limited, its ownership and structure, ways to attract private sector investment and longer term privatisation.

Totalfair has reviewed the NBN-Implementation-Study-complete-report and added comments to the wiki where appropriate, comments added are as follows:

Chapter 02:Establishing a Mandate for NBN CO

Recommendation 01

That NBN Co only enter markets where there is insufficient infrastructure to support superfast broadband or where retail service providers are unable to access bottleneck assets on reasonable terms.

Freedom of Communication disagrees:

The NBN should not just be built because of a lack of fast broadband in some areas. It is generally recognised that The NBN is being built because of a failure of the free market to provide:
a) A fair competitive environment on (due to incumbent monopoly) factors NOT just limited to providing access eg: length of contract, price, etc
b) Ability for ISP’s to work together for the greater good on core issues, standards, technologies, thereby causing massive overheads and disparities due to lack of unanimity.
c) Long sighted vision and investing which equates to an ability to build it right the first time.
So it is all of the above, and not just geographical access to broadband that the free market has failed to provide Australia. Despite being of a commercial nature, a large part of the appeal of NBN Co is its benignity, and purpose built design which by nature should both provide, and provoke the above mentioned qualities from its competitors.

Reccomendation 02

That Government’s objective of providing superfast broadband to premises be measured in terms of coverage, with premises considered covered by the NBN where:

1. NBN Co is able to provide a wholesale service to those premises at the request of a retail service provider within a maximum number of days, specified by Government. For premises to be defined as ‘covered’, NBN Co should not be required to install CPE, or for fibre to perform the ‘drop’ and install the ONT. NBN Co should not perform the ‘drop’ and install the ONT until services are ordered via a retail service provider;

2. The ACCC or appropriate agency has declared the premises to be ‘adequately served’ by other providers where premises already have access to last-mile services of the required speed, with infrastructure-based competition and/or open-access wholesale arrangements in place, and with pricing comparable with NBN services; that to the extent that premises are deemed to be ‘adequately served’ by FTTP infrastructure, these should be counted towards the FTTP coverage objective.

Freedom of Communication disagrees:

The recommendation is flawed and dangerous in the suggestion in point 2 that “connectivity” with technologies other than fiber should be “counted towards the FTTP coverage objective”. It can not be understated how important the coverage is fiber and not some other technology eg copper for the following reasons:
a) The speed requirement of what is considered super fast broadband will most certainly outgrow any speed requirement set in the current time, it will grow to such a point that fiber is the only technology which can provide these speeds, therefore fiber is future-proof, copper is not, and premises served by other technologies will need to be declassified as covered when these requirements change. Counting inferior technology such as copper under the title “Fiber to the home” gives a false impression of the value of the network, and the classification of “covered” will needlessly degrade over time whereas strictly classifying fiber premises as covered will never degrade.
b) Ubiquity using a single technology in a networked system makes it far easier to conceptualise, administer, and upgrade, the overhead costs involved working with fragmented technologies will be cumbersome and unending.

Recommendation 03

For the purposes of NBN Co’s coverage requirement, that premises be defined, to mean any building (or part of a building) that meets one of the following criteria:

1. Currently has a standard telephone service activated as defined under the USO;
2. Currently has a fixed-line residential or business broadband product activated;
3. Is used on an ongoing basis for residential, business, health or educational purposes; or,
4. Is defined as a school by the Department of Education, Employment and Workplace Relations.

Freedom of Communication disagrees:

This excludes permanently inhabited dwellings which aren’t “buildings” per se, it is recommended that the definition include “permanently inhabited dwellings”.

Recommendation 08

That until the FTTP roll-out is complete in a given area, only premises that cannot access a metro-equivalent service as defined under the Australian Broadband Guarantee program be eligible for an NBN satellite service.

Freedom of Communication disagrees:

Access to the broadband guarantee is rightfully limited because costs are borne by the government in providing access, however it is completely different if a consumer wishes to pay for 12Mbps satellite available through the NBN – if so it would indicate that the customer was not being served properly by their current ISP’s who are under no obligation to actually provide the speeds of 512k/128k (which are already far below the 12Mbps minimum the NBN would provide). Limiting access of customers willing to pay would is pointless especially when servicing these customers would provide instant income with out the burden of extra infrastructure, which is unique to satellite technology.

Recommendation 16

That NBN Co overbuild third party FTTP networks that do not comply with the FTTP design standards; that, where a deployment does comply with the FTTP design standards established by Government, NBN Co may:

1. Apply to ACMA to have the premises declared ‘adequately served’;

2. Attempt to secure access from the network owner that would allow NBN Co to offer wholesale services over the network;

3. Overbuild the network where NBN Co is unable to secure necessary access and the premises are not declared ‘adequately served’.

Freedom of Communication disagrees:

Declaring a premises ‘adequately served’ based on “design standards” is missing the point of the NBN.
The NBN is important for service levels and competitiveness, which is completely different to design standards.
If 3rd party FTTP providers know this, they could preemptively roll out FTTP that conforms to “design standards”  thereby relieving NBN Co of its duty but with no intention of providing a level of service or competitiveness that NBN Co would otherwise be obliged to offer.

Recommendation 17

That all new developments where fixed telecommunications infrastructure is deployed be required to provide a duct, pit and pipe network with sufficient additional capacity to allow for an FTTP deployment by NBN Co; that this infrastructure be provided at the developer’s expense—an exemption being made for new premises where no fixed-line telecommunications infrastructure is installed.

Freedom of Communication disagrees:

With the increasing trend of IP enabled devices increasingly becoming integrated into every day electronics  it would be tragically short sighted to negate a requirement to only ‘fixed line telecommunication infrastructure”. This should be re-written to: “fixed line telecommunication or electricity distribution infrastructure”. It is extremely important to grasp that in the not too distant there will be IP enabled devices wherever there is electricity being used, and even more fundamentally there will be IP enabled devices monitoring and controlling the flow of the actual electricity.

Recommendation 43

That NBN Co be required to provide a next-generation satellite service ensuring access to at least 12 Mbps peak data rates to all premises beyond the fibre footprint. Satellite system capacity should be dimensioned to offer an average data rate per premises that reflects potential growth in usage patterns over the lifetime of the satellite system.

Freedom of Communication disagrees:

The NBN Co should be required to provide satellite service ensuring access across all of Australia, not just outside the fiber footprint, this is most likely possible technically but needs to be available officially as consumers within the footprint of the fiber network should not be excluded from access if they happen to be one of the many whom fall through the cracks and find themselves officially “serviceable”, but otherwise technically unserviceable. There is also a lack of support generally in the NBN for people who live or work transiently who can’t access the internet from a fixed location and require satellite services despite being inside the ‘coverage zone.

A video highlighting the benefits of the NBN that even sheep can understand.

The Australian Department of Broadband, Communications, and the Digital Economy is holding a forum called Realising Our Broadband Future; We congratulate the government on taking a proactive democratic approach to the issue and involving many thinkers and doers in the process.

Everyone in Australia and many oversees will be affected by the NBN rollout and consequential policy and ideas, this is an event not to be missed if you have anything to add.

Multiple locations

The conference will be held in Sydney, with video streaming to multiple locations around the nation; discussion will be held in remote groups and contributions will be made to a wiki.

Speakers

Senator, the Hon. Stephen Conroy

Minister for Broadband, Communications and the Digital Economy

Senator Kate Lundy

Vinton G. Cerf

Vice President and Chief Internet Evangelist Google

Jeffrey Cole

Director USC Annenberg School

Five streams of discussion

After various keynotes and discussions, from people from organisations such as Google, and ICANN the will divide into five groups

Smart infrastructure

Digital Education

e-Community

e-Health

e-Business

Once again the website is http://broadbandfuture.gov.au, if you can’t make it to Sydney, sign up to one near you.