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ALTO NGA Consultation Response

ALTO NGA Consultation Response

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Published by: ronanlupton on Jul 16, 2012
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Response to Consultation - Proposed Remedies for NextGeneration Access – NGA, Markets Ref:12/27Submission By ALTO
Date: June 13
 ALTO is pleased to respond to the Consultation -
Proposed Remedies for NextGeneration Access – NGA, Markets
Preliminary Remarks
 ALTO welcomes this Consultation on the proposed remedies for NGA, however weapproach this debate extremely apprehensively owing to what has occurred andthe behaviours exhibited by the incumbent – eircom, and the regulator – ComReg,during the previous two EU regulatory frameworks. ALTO members havesignificant fears that what occurred historically will be replayed in current market. ALTO’s entire membership engaged with ComReg and ComReg’s independentlychaired Next Generation Industry Steering Group – NISG, since the year 2005.Since that time, only some minor movements have occurred in the Irish market todrive on the Next Generation Access technological debate. The industry has beenoffered and watched with particular interest, the various pilot schemes relating inthe main to the incumbents own field-testing and various ideas of what the IrishNext Generation Access might look like throughout the various iterations of ownership of eircom, the Irish incumbent. ALTO drafts this response in the full knowledge that, ETNO, ECTA, the EUCommission, other European regulators and EU trade associations may look at theresponse in a relatively significant level detail. To that end, we feel that it isimportant to state that ALTO views the issue of Next Generation Access and veryspecifically the issue of vectoring as a lab based offering at this time only, and itmay not do what it is that the incumbent and various other proponents says it will. ALTO currently views the vectoring debate as something of a ‘white elephant’ thatmay not prove fit for purpose offering in the medium to long term. Further, eircomare on record publically as stating that they are a technology follower, not innovator in the sense that a technology trial may emerge in Ireland. Our response to Q. 5.,below provides further information relating to our thinking.
ComReg’s Approach
 ALTO cautiously welcomes the approach that ComReg has taken to this area, butsuggest that extreme caution must be exercised when reviewing various offeringsthat may emerge over time, to include the margin modelling/price squeeze andnetwork forecasts relating to NGA that have been made publically available toindustry. De-regulation should not be a feature of anything that emerges as a resultof this consultation. ALTO seeks to impress on ComReg the importance of the maintenance of theCurrent Generation Access – CGA, product sets. ALTO urges ComReg to use all powers and framework remedies available to it,without fettering its discretion in any regard. Industry cannot withstand another ten-year battle in order to get to where we need to be. ALTO refers to the Local LoopUnbundling – LLU, battle in that regard.
Economic Backdrop
While ALTO welcomes the newly emerged eircom, the Examinership process isone which in an appropriate case, enables an enterprise, in the instant caseeircom, to continue in existence throughout the process for the benefit of theeconomy as a whole and, of equal, or indeed greater, importance to enable asmany as possible of the jobs which may be at stake in such enterprise to bemaintained for the benefit of the community in which the relevant employment islocated.With this in mind, ALTO suggests that investment in the future, or Next Generationof products and services is still going to challenge eircom and its management of an extraordinary extent in the coming years.

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