Telecom draft separation plan disappoints
InternetNZ (the Internet Society of New Zealand Inc) today responded to Telecom’s draft operational separation plan,
filing a detailed submission that exposes serious deficiencies in Telecom’s proposed approach.
InternetNZ Executive Director Keith Davidson says Telecom’s draft plan has the potential to severely compromise the
intent and viability of a robust operational separation because it fails to live up to requirements prescribed in the
Government’s Operational Separation determination.
The determination calls for robust Chinese walls, transparency and behavioural changes regarding the operation of
Telecom’s network access, wholesale and retail divisions. Telecom’s draft plan however dilutes a wide range of
provisions designed to bring about the desired behavioural changes set out in the determination.
Davidson describes Telecom’s draft undertakings as “death by a thousand cuts,” saying they lack detail and subtly dilute
specific requirements of the Government’s determination in numerous ways.
“This is a matter of great concern to the industry. The combination of the multiple departures from the Minister’s
requirements have such a damaging effect that they make the operational separation quite weak. We call on the Government
to review and seek major changes and additions to Telecom’s implementation plan,” says Davidson.
Perhaps the biggest concern for InternetNZ is reserved for those sections of the plan that will govern the rollout of
future NGN services, including fibre rollout.
“The determination states that Telecom must include its detailed commercial policy and plans on access to
Fibre-to-the-Premises yet Telecom’s draft plan contains very little such information.”
InternetNZ urges the Government to consider the formation of an industry forum similar to NGN UK that provides a
mechanism for industry to develop joint technical and commercial arrangements for NGN development; and provide an early
warning system that would identify emerging NGN policy issues.
Other areas in which Telecom’s plan falls short are those relating to governance and the ability of the proposed
Independent Oversight Board to carry out its role effectively.
In another example, the determination forbids wholesale unit employees from having short term incentives for performance
unrelated to wholesale; yet in Telecom’s draft undertaking up to 80 percent of the wholesale manager’s incentive can
reflect the performance of Telecom as a Group.
InternetNZ’s submission, including a detailed Appendix, is available on the InternetNZ website: