ALTO is pleased to respond to the Consultation -
Proposed Remedies for NextGeneration Access – NGA, Markets
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.