ISPANZ Responds To Operational Separation Proposal

May 1, 2007

ISPANZ Responds To Operational Separation Proposals

Local Loop Unbundling (LLU) and Unbundled Bitstream Access (UBA) must not be delayed by the Government's focus on Operational Separation. This is one of three key points made in the submission on Operational Separation filed with the MED on Friday by ISPANZ (The ISP Association of New Zealand). ISPANZ' submission is attached.

ISPANZ president David Diprose says LLU and UBA are critical in bringing the benefits of telecommunications reform to consumers as quickly as possible. "The entire reform process is important but we must have our priorities straight to ensure that we do not have to wait until next year for LLU, enhanced UBS and Naked DSL." ISPANZ is please that the Commerce Commission's Standard Terms Determination process for LLU and UBA appears to be on track for delivery in the fourth quarter of this year.

Another key point is that Operational Separation is not an end in itself and bringing equivalence to the industry should be the focus.

"Delivering equivalence in how Telecom's network and wholesale divisions treat its wholesale customers is what will deliver the competition and benefits for end-users. The details of the separation plan should always be predicated on delivering equivalence," says Diprose.

The third key point is that ISPANZ acknowledges that full Equivalence of Inputs may take some time and can be delivered in stages. "ISPANZ is seeking a roadmap to full equivalence; products must be delivered first, then systems and processes can come later - we don't want Telecom to wait to deliver products until it can deliver on the full Equivalence of Inputs requirements," says Diprose. Separation will be a complex process that will require detailed specification and negotiation.

In respect to the Operational Separation plan for the Access Network Service Unit, ISPANZ is seeking adjustment to the Government's proposals around which assets and services reside in the access network and are available to wholesale customers under equivalence provisions.

As stated in the submission "It is essential that the access network division treats all its customers equally (including Telecom) using Equivalence of Inputs for all its services, not just those services that have been regulated under the access regulation regime."

Another important issue is disclosure of Telecom's Next Generation Network plans. ISPANZ would like to see a full consultation process to ensure future bottleneck services based on Telecom's NGN are addressed before they emerge in the market.

ENDS

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