Submission to the MED on the RBI Non-Discrimination Consultation Paper – March 2011

Dear Sirs,

A.) I am an independent consultant with a background in rural telecommunications and mobile co-location. In my former role as Managing Director of Araneo Limited, I co-located fixed wireless broadband access on rural towers from Kaitaia to Southland, providing wireless access to libraries, schools, farms, hospitals, power stations, and defence force installations. I have written a number of documents on rural towers and co-location based on my experiences which can be found on my blog: https://nztelco.com/.

B.) I would like to respond to “Question 3” of the “Response to RBI Non-Discrimination Discussion Document MARCH 2011.pdf”.

Q.3 Do you consider the proposed approach to co-location would be effective in providing fair access that will promote competition. If not, what do you consider to be the appropriate approach and why?

C.) I do not believe the approach to co-location will provide fair access that will promote competition for several reasons.
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RBI Fibre and Stranded Communities

In a TUANZ “After 5s” session in Wellington on Monday, March 21st, both the MED and Telecom came out to talk about the proposed Telecom/Vodafone RBI solution. One of the points made by Telecom is that while all new RBI fibre would be available to all comers as dark fibre, existing Telecom fibre would be restricted to “layer 2” wholesale services. Telecom says that their older fibre may not have enough cores for other users, may not have break-out pits in the right place, and really was only ever intended for use by Telecom.

Access to inexpensive dark fibre in rural New Zealand is a huge issue for alternative telecommunications providers. Rural areas are not large enough to support natural competition. The requirement for an alternative provider to purchase wholesale L2 services from an incumbent is enough to keep them out – either due to slow/no service provision or predatory pricing.
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Mobile Infrastructure Sharing / Mobile Co-Location

“Mobile infrastructure sharing is an alternative for lowering the cost of network deployment, especially in rural and less populated or marginalized areas.” (Lefevre, 2008) Infrastructure sharing can be as basic as sharing a hilltop or as complicated as sharing active network equipment. In this post, the various options available for passive infrastructure sharing will be discussed, with a focus on rural towers.

Passive Infrastructure refers to that infrastructure not directly involved in actively transmitting information. In addition to physical objects, elements such as electricity, cooling technology, and non-cellular transmission are considered passive, because management of these elements does not have an impact on the coverage or capacity of the mobile network.
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Rural Towers: Subsidies, Profit Motive, & Service to Rural New Zealand

From the advent of commercial radio it was recognized that rural radio and wireless communications were important to the development of the New Zealand. By the mid 1930s the government was already providing direct subsidies to broadcast radio operators in rural areas around the country in order to ensure universal coverage. The small number of commercial radio sites was expanded during a time of government administration of broadcasting from the mid 1930s through the early 1960s. The New Zealand Post Office increased again the amount of rural sites when it established mobile radio services in the late 1940s. Through the 1980s, rural radio broadcast and telecommunications sites enjoyed continued improvement and maintenance, to the benefit of rural areas that would not be economic to service otherwise.

With the split of telecommunications from the Post Office portfolio, and its sale to Telecom New Zealand, rural telecommunications towers came in to private ownership. Similarly with the corporatization of Broadcast Communications Limited (now known as Kordia) rural broadcast towers fell to management under a company required to turn a profit. These corporatization efforts have resulted in a low level of continued investment in rural towers, for a number of reasons.
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Cellular Spectrum in New Zealand

Radio Spectrum in New Zealand is allocated for a number of uses, including broadcast, narrow-band radio communications, point to point linking, and cellular, to name a few. Cellular spectrum in New Zealand is auctioned on the basis of blocks of a particular frequency range that is exclusive for the use of an operator across the entire country. These blocks are awarded on twenty year terms that appreciate the huge capital expenditure and time commitments involved in building national cellular networks.

Some carriers have dedicated an immense amount of resources to the acquisition of prime spectrum in New Zealand, while others have taken a value for money approach to acquisition. The following chart shows the amount of national spectrum licensed in megahertz (MHz), and the approximate aggregate dollar value of that spectrum (in Q3 2010 dollars), on a per-carrier basis.

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Traffic Demand: Gigabytes per Month

How much do Internet users download every month? How is this likely to change as the Internet becomes more a part of daily life? How far below the curve are Australia and New Zealand, compared to the rest of the world – and why? Today’s post talks about traffic demands, bitcaps, and what it all means.

In most of the world, broadband plans are sold by download and upload speed, with no restrictions on the amount of traffic consumed. This has allowed for the Internet to become a viable delivery method for music and video, increasingly via legal means since the emergence of Netflix Streaming, Hulu, and YouTube. This isn’t the case everywhere, as I’ll explain below.
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Chorus Cabinets Across New Zealand

Chorus is the infrastructure division of Telecom New Zealand, and is likely to be spun off in to its own company in the near future. Chorus maintains physical plant like copper and fibre optic cables, buildings, and cabinets.

A cabinet is typically a metal enclosure mounted on a concrete plinth which aggregates copper lines from an area called a sub-loop. Inside the cabinet is a copper distribution frame, and some active equipment. Installing a cabinet helps shorten the length of the copper between an end user and an Exchange building, by bringing some equipment from the exchange closer to the end users. Active equipment inside the cabinet can be a basic TDM multiplexer, allowing 30 analogue voice circuits to be transited across a single pair of copper as E1, or an advanced ISAM, or Intelligent Services Access Manager – a device allowing voice and xDSL services across sub-loop circuits.

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