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Transcript of VP Network Separation and Access Regulation Final neu Separation... · roll-out; the upgrade of an...
![Page 1: VP Network Separation and Access Regulation Final neu Separation... · roll-out; the upgrade of an existing VDSL Network needs only swap the DSL line cards and the CPE Key benefits](https://reader031.fdocuments.in/reader031/viewer/2022030502/5aaf3be37f8b9a190d8d138f/html5/thumbnails/1.jpg)
Network Separation and Access Regulation – We make ICT strategies work
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Introduction – Why now ?
The evolution of NGA requires a redefinition of technology neutral access regulation including products and processes, and it may involve separation and business models.
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– 2 –
With the evolution of regulation, network separation models and the related business cases have to be re-considered
Regulatory principles for access provisioning, e.g., Equivalence of Outputs or Pinputs (EoO or EoI)
Structural separation for NGA business units Related to the new regulatory realities, the optimal
response for operators might be different from the status quo, requiring to re-calculate the current business cases and re-adjust business models
Technology neutral access regulation is related to two meanings1. Evolve regulation with technology2. Regulate independent of technology
With NGA technology, options for access and unbundling obligations change
Bottleneck definition and rationale for regulatory intervention
Technology assessment
Wholesale product definition
– Local Loop Unbundling
– Bitstream access options / VULA
– Ducts and dark fiber
Technology neutrality involve further regulatory instruments and policies
Potential Obligations such as unbundling and bitstream but also multicast obligations
Benchmarks and recommendations
NGA technology neutral access regulation Network separation models and business cases
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Overall Trend – Adjustment Areas
The adjustments in NGA regulation are related to regulated network access products, processes, conditions and business models.
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Strategic focusRe-Balancing weight and focus on retail versus wholesale, increased emphasis on partnering approaches
Pricing innovationNew tariff models (e.g., including risk sharing elements, QoSpricing)
Roll-out processes Coordination, rights of way, property rights in general
Retail processesProvisioning, but also servicing etc.
Wholesale processesProvisioning, but also servicing etc.
Joint retail and wholesale processes with regard to equivalence principles, i.e. Equivalence of Outputs/Inputs EoO/EoI
RetailFTTx and ultra-high speed DSL and coax technologies such as Vectoring VDSL and Hybrid Fiber-Coax (HFC)
WholesaleNew access and transport products reflecting retail service and technology evolution such as Virtual Unbundled Local Loop (VULA) as well as passive products
Regulated productsRevision of bottlenecks and rationale for regulatory intervention
Business models and structureTechnology & products Processes & conditions
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Challenges – New Technology Trend Vectoring in Fixed Access
On example for new technology is Vectoring VDSL as the next evolution of VDSL2 pushing coverage and bandwidth of standard VDSL.
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Sub-loop unbundling with different systems needs to be prohibited in the respective roll-out area, otherwise the vectoring effect will be reduced to almost zero. Regulator will most likely allow only fist mover to roll-out VDSL in an Central Office area.
As an alternative the regulator will force the Vector VDSL operator to offer bitstream access. An agreement with other fixed line operators should be negotiated offering a V-VDSL wholesale product for a reasonable price to avoid the roll-out of competitive VDSL2 networks in operators’ central offices
Increased power consumption
Proposed vectoring solution Regulatory implications & risks
Vectoring improves VDSL maximum speed and enlarges the VDSL coverage by reducing the far-end and near-end crosstalk
Standardized by the ITU Standards Association as G.Vector
Vectoring improves possibilities for guaranteed bandwidth The CAPEX needed for a Vector VDSL roll-out is much lower than FTTH
roll-out; the upgrade of an existing VDSL Network needs only swap the DSL line cards and the CPE
Key benefits
Reach
Mbp
s
80
100 m 300 m
VDSL2
17 MHz-Profile
VDSL2 + Vectoring
50
1,000 m
27
16
500 m
VDSL50
VDSL25
VDSL50+
(VDSL80)
+ Coverage
(VDSL50)
+ Rate
(VDSL80)
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Challenge and Solution
The regulatory solution to the current challenges with NGA evolution balances adjustments against continuation and extension of regulation.
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NGA technology neutral access regulation Network separation models and business cases
Adjust current regulation to incorporate new technologies while minimizing disruptive regulations
Relax physical unbundling obligations and introduce substitute options such as Virtual Unbundled Local Access (VULA), i.e. local bitstream access in addition to national and/or regional bistream access.
Ensure that new technologies are strictly regulated if new bottlenecks arise. With persistent problems introduce appropriate Equality Obligation to minimize need for structural separation as this approach only partially addresses competition issues.
Avoid new competition problems and reduce potential for anti-competitive behavior
Continue to safeguard competition by minimizing risk of stranded assets to ensure maximum investment certainty
Implementation of new regulations, e.g., with regard to roll-out priorities, rights of way, and exclusivity rules in a way that balances existing assets and the incentives to roll-out new technology.
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Challenges – Regulatory Challenges of and Solutions for Vectoring VDSL
The regulatory changes from Vectoring VDSL include duct access, migration rules, investment and competition protection, and may be extended to cable networks.
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Vectoring VDSL challenges
Central office (CO) Street cabinet (SC) Customer premises
Distribution point (street)
DP
DA+VULA
LLU/SLUVDSLV-VDSL
ADSL CopperFibreCopperwiring loom
In order to realize the potential of V-VDSL, the complete wiring loom has to be driven by one vectoring DSLAM.
Line unbundling (LLU and SLU) rendered technically infeasible
Necessity to drive the complete wiring loom by one DSLAM means only one operator for whole loom
Investment and competition protection (stranded assets)
Regulatory challenges Substitution of Local Loop/Subloop
Unbundling (LLU/SLU) by Virtual Unbundled Local Access (VULA)
With VULA as substitute for SLU, duct access between CO and SC required
Vectoring register and compensation
Regulatory solutions Migration of existing LLU requires
adaption at access-takers, too First mover SC registration must be
carefully designed (incl. roll-out obligation) to avoid strategic reservation
Fair access to SCs for roll-out for equal chances for first mover effects
Side conditions
DA+SLU
App 1
App 2
VULA follows concept to mandate the provision of the highest-quality access product at the lowest possible level.The “Local Bitstream Access” approach provides a path to extend access regulation to Coax networks, too.
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Challenge and Solution – Snapshot of Equivalence Concepts
Independent of the particular network type and technology of a given NGA network, any access regime has to consider some separation.
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EoO: The concept in which, in respect of a particular retail product or service, the wholesale input supplied to the incumbent’s own retail arm is equivalent to the comparable wholesale product or service supplied to other communications providers but not necessarily supplied in an identical manner.
EoI: The concept established by the BT/Openreach undertakings in which the incumbent provides, in respect of a particular retail product or service, the same wholesale product or service (input) to all communications providers (including its own retail arm) on the same timescales, terms and conditions (including price and service levels), and by means of the same systems and processes.
Source: Oxera based on Ellare
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Challenge and Solution – Equivalence Concepts in Detail
With regard to the implementation complexity, the main step is between EoO and EoI, whereas the latter requires significant changes at the regulated entity.
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The Equivalence of Output principle implies a parallel usage of WS CRM for external wholesale customers and of a separated CRM for “internal” retail customers.
In Equivalence of input the WS CRM must be used by retail unit in the same way as by ISPS, i.e. the usage of WS CRM will not be parallel, but cascaded and used after the orders will come to RT CRM.
Requirement that same systems and processes shall be used for provision of identical products and services to external and internal customers.
Retail CRMRetail
EoO retail process
Ordering & provisioning
WholesaleCRM
WSgateway
EoO wholesale process
Comp. CRM
Ordering & provisioning
Compe-titors
WholesaleCRM
EoI processes
Ordering & provisioning
Compe-titors
Retail Retail CRM
Comp. CRM
WSgateway
EoO EoI
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Challenge and Solution – Equivalence of Inputs Concept
With Equivalence of Inputs, the network unit shall provide exactly the same products and services to all operators (including own retail arm).
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EoI concept
Available to other operators:
Same…
products and services(including reliability & performance)
terms & conditions(including prices and timescales)systems
(including ordering, provisioning, fault clearance)
processes
information about products, services, systems, processes
The Equivalence of Input concept leads to far-reaching consequences and high cost and thus should only be applied where significant problems have been identified or where new access regimes are to be designed.
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Equivalence of Inputs – Same Products, same Prices
EoI is suited to solve competition problems at the passive and active input product level simultaneously, and without the requirement of legal separation.
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A transfer pricing system might support transparency, however it might not be strictly required with margin squeeze testing.
* WS may receive share of one-off fees for handling as one option.
ULL and BSA serving as illustrations for all passive and active products.
Same products and services Same terms & conditions (prices & payments)
Access
Competitors
Aggregation
Retail
EoIEoIBSA
BSAULLULL
Access
Wholesale
Competitors
Aggregation
Retail
EoI
ULL BSA–ULL
*
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„Classical“ Structural Separation – AccessCo Example
„Classical“ structural separation should be stricly separated from Equality principles, as separation variants focus network elements rather than products and processes.
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O DF
MDF
Metallic access Core
Fiber access
Aggregation
DSLAM
OLT
Core network
IC
BTS
BSC
Fixed
Mobile (only shared elements of relevance)
Radio access
CPE
CPE
*
*
Aggregationring(s)
CCC
PODP
NT
ONT
FTTx
Cu
Mobile
ST’s service
platforms
Services
Competitors service
platforms
Act. WS
Competitors
Duct access** ULL and SLU** TLL***
Dark fiber P2P, e.g., for mobile backhaul
VULA(BSA local)
NetCo products
NetCo(s) demarcation (Cu passive only)
Dark fiber P2P WS
Bitstream access (Eth., local)
Bitstream access (Ethernet and IP, national)
If BSA Multicast is introduced,
MC option has to be added to all
BSA products of NetCo and ServCo!
* CPE includes Splitter, Modems, HAGs etc.** Where feasible*** Termination Leased LinesSource: DTC project
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„Classical“ Structural Separation vs. Equivalence of Inputs
Contrarily to EoI, with a separation in two entities, only one possible “problem level” is solved “really” structurally, while the other is solved through separation of accounts.
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Depending on the allocation of products to the separated entity, the stronger remedy is either on ULL or BSA related objections:
Objections and value chain Solution focus
Margin squeeze
%!
%
%Passive upstream products (“ULL”)
Active products (“BSA”)
Retail / resale competitorsRetail products
Vertically integrated Telco
=!
=!
Ret
ail
mar
ket
WS
infr
astr
uctu
re
acce
ss m
arke
tW
S br
oadb
and
acce
ss m
arke
t
End users
ULL
BSA
Competitors RT
=!
=~
Rem
. ris
k
%
%
%
Rem
. ris
k
ULL
BSA
Competitors RT
=!
=~
%
%
%
separated =!
=~ Softened:
Contract/transfer p.
Solved:Nondisc.supply
Explanations
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Equivalence of Inputs – Same Products, same Prices
However, from a systems and processes perspective, the implementation of EoI might come very close to a separation scenario, as both, retail and wholesale are affected.
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Which systems have to be split/duplicated (partially)?
What would be the estimated cost and duration?
How would bundles affect the feasibility/complexity of such an approach?
What would be the information to be shared by WS with the competitors, and what impact would that have?
Should the implementation only focus the regulated products, or should this approach be a business architecture modification in general?
What organizational changes are required to implement the concept?
Same systems, processes and information* Questions
CRM
New 2nd “WS CRM”
Compe-titors
Network
Retail
Ordering + provisioning
Comp.CRM PGW**
Old (path)New (path)
xEoI
WS
serv
ice
prov
isio
nPa
ckag
ing
& d
istr
ibut
ion
* Illustrative – other systems to be adjusted, too.** Provisioning/partner gateway PGW might not necessarily be required.WS information available to retail arm has also be available to competitors.
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Separation and Equivalence Approaches – Efficiency of Intervention
Accordingly, to ensure efficient regulation, (non-discrimination-) benefits and cost have to be balanced taking the actual shape of the cost curve into consideration.
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The cost to improve the assured level of non-discrimination (x-axis) increase massively with separation (expensiveness of the remedy; y-axis).
This is especially true, as cost are largely independent of operator and country size.
By the regulatory bodies it is assumed that different behavior of incumbents (x-axis) can directly be linked to different levels of separation (intrusiveness of the remedy; y-axis).*
Stylized (BEREC) view Actual cost curve
Discriminatorypractices are very likely
Level of non-discrimination
Leve
l of i
nter
vent
ion
Discriminatorypractices are very rare
Very intrusive
Leastintrusive
4 Functional separation +incentives/governance
5 Legal separation
6 Ownership separation
3 Functional separation
2 Virtual separation
1 Creation of a Wholesale Division
0 Accounting separation
Level of non-discrimination
Cos
t of i
nter
vent
ion
Very expensive
Leastexpensive
4 Functional separation +incentives/governance
5 Legal separation
6 Ownership separation
3 Functional separation 2 Equivalence of Inputs
(Virtual separation)
1 Creation of a Wholesale Division (andEquivalence of Output)0 Accounting separation
*Source: DT; based on BEREC Guidance on functional separation under Articles 13a and 13b of the revised Access Directive and national experiences, February 2011, p.7.
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Implementation Cost Estimation – Cost Composition
IT CAPEX and FTE increases from necessary duplications are the main drivers of the implementation cost of Equivalence of Inputs as well as functional and legal separation.
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Implementation cost composition (cumulated payments, m EUR)
Functionalseparation*
2.0 3.0 0.0
40.0
200.0
140.0
3.0290.0
Access-to-aggregation
54.0
(NPV 160.0)
3.0
4.0
2.0
3.0
1.084.0
Functional-to-legal
35.0
6.0
General OPEXNT CAPEX Restructuring including FTE increasesIT OPEX* IT CAPEX
* The cost of implementation of Equivalence of Inputs comes very close to the implementation of Functional Separation.
Realistic example figures
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Options and Solutions
A unified access regime such as requiring VULA for all networks would yield really technology-independent regulation which could then be SMP-dependent only.
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The European Commission accepted the introduction of Vectoring DSL in combination with VULA despite the fact that ULL then would be rendered technically infeasible.
As VULA comes very close to physical network element unbundling (with regard to the control over network parameters), it is a suitable substitute if offered at reasonable terms and conditions.
With the decision of the European Commission, a single access form now became available for two types of networks (xDSL and FTTx, especially PON).
Consequently, VULA would be a natural candidate for an obligation for HFC operators, as then FVNOs could source their inputs from the fastest available network in a given region.
Focus on Equivalence of Outputs or Inputs rather than on (partial) network separation
Focus on access products at lowest possible level (ULL, VULA) Especially VULA as local bitstream access would allow to require
symmetric access obligations independent of underlying network technology, i.e., VULA is possible for xDSL including Vectoring DSL, HFC and FTTx networks.
Solution International trend
EU members and European Commission
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Why Detecon
Having Detecon as partner means optimizing NGA regulation tailored to the specific country conditions while avoiding mistakes made by other players.
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Client Benefit
HolisticTeam of expertsfrom all disciplines
PracticalReal-world solutions instead of “theory”
ImpactSolutions with lasting value
CustomizedInternational experience adapted
A dedicated project team brings together all regulatory, technical, commercial and financial expertise and experience related to NGA access regulation in accordance with Client’s business strategy
Based on sound regulatory strategy, Detecon’s solutions have been implemented in practice for many Clients worldwide
Tangible solutions ready for implementation
Integration of NGA regulatory strategy within Client’s overall regulatory strategy
Understanding of NGA challenges from NRA’s and operator’s perspective and staff involvement
Full understanding of Client’s reality of targets, business and local market challenges
Project team knows Client’s environment
Presence with a local office in Client’s region of operation
One experienced and competent partner regarding NGA regulation
Regulation of NGA is optimized in the light of Client’s policy imperatives
Benefit from hands-on strategic expertise while avoiding mistakes made by other regulatory authorities and operators worldwide
Coherence of regulatory approach to NGA with overall strategy
Ownership over regulatory solution
Regulatory solutions designed for NGA and tailored to the specific country are relevant to Client’s actual policy goals and business needs
Detecon Leverage
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Regulatory experience & references
Since more than 30 years, Detecon successfully supports regulatory authorities, governments, operators and investors in regulatory affairs all over the world.
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References and clients of our regulatory projects worldwide
Sector liberalization and privatization Regulatory instruments Licensing and authorization regime Access and interconnection regulation Spectrum management & monitoring Interconnection regulation Price regulation (retail & wholesale) Market analysis, definition and SMP assessment Universal services & access Dispute resolution & consumers‘ complaint Regulatory enforcement Promoting broadband development …
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Selected References
The Client leverages Detecon’s lessons learned from similar assignments in regulatory strategy for Next Generation Access and regulation.
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Slovak Republic
UAE
UAE
Slovak Republic
Turkey
European Commission Competition CaseElaboration and analysis of different regulatory options including network separation and equivalence of output and equivalence of input models. Economic assessment and quantification of options.
Development of FTTX cooperation modelsDetecon defined complimentary FTTx rollout strategies and developed regulation friendly cooperation models with competitors to facilitate CAPEX efficient rollout.
NGA BSA, ULL, dark fiber reference offerDetecon developed a successful, optimal and sustainable access regime that enabled the operator (“du) to grow its customer base while protecting its current revenues.
Development of Reference Bitstream Access OfferDefined wholesale reference broadband access portfolio and setup a regulatory negotiation strategy based on state of the art costing and pricing strategies
BSA, LLU regulatory scenarios for Turk TelekomBenchmarking of tariff regulation regime and regulatory decisions in selected EU member states. Recommendations for Turk Telecom on rebalancing and retail tariff regulation. In-house cabling strategy
Client Reference Case
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Dr. Arnulf Heuermann
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Dr. Olaf Nielinger
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e-Mail: [email protected]