Not really, the law can say must provide standards compliant access for interconnections with a agreed upon base set of features it must support. Any provider that wants something extra can negotiate the reasonable costs of implementation.
On 8/1/14, 8:44 AM, "Owen DeLong" <[email protected]> wrote: > >On Aug 1, 2014, at 12:08 AM, Mark Tinka <[email protected]> wrote: > >> On Friday, August 01, 2014 08:54:07 AM mcfbbqroast . wrote: >> >>> This would be my humble suggestion: >>> >>> - lines provider runs fibre pair from each home to co. By >>> default the lines provider installs a simple consumer >>> terminal, with gigabit Ethernet outputs and POTS. > >The problem with this is it allows the lines provider to dictate >the technology to be used by all higher-layer service providers. > >IMHO, this is undesirable, because it blocks innovation and >service differentiation on this basis. > >Ideally, the lines provider is simply a lines provider and provides >a number of dark fiber pairs between the serving wire center (what >you called a CO) and each premise served by the SWC. > >Termination at the customer end should be a box in which a customer >terminal can be installed and the fibers should all be terminated on >some standard form of patch panel (ST or LC probably preferred, >but others may be acceptable). > >It would then be up to the service provider(s) to provide the terminals >and decide between customer self-install and truck-rolls for service >turn-up. > >>> - lines provider provides a reasonably oversubscribed >>> service to soft hand over to ISPs (think 96 Gbps lines >>> to 2 10gbps ports). Perhaps upgrading so such a ratio >>> never becomes congested could be a requirement? > >Putting the lines provider into this part of the equation preserves >many of the problems with the existing model. > >>> - lines provider also rents individual lines to ISPs >>> which they can use directly. Rent should be lower than >>> soft handover. > >Now you¹ve got competition operating at a disadvantage to the >incumbent lines provider, preserving this aspect of the problems >with the current system. IMHO, this should be the only service >the lines provider is allowed to sell. In that way, the lines provider >is not in competition with its wholesale customers. > >If you want examples of how well the model you propose tends to >work, look no further than the incredible problematic nature of MCI¹s >attempt to offer local phone service over Pacific Bell/SBC/AT&T >circuits. > >>> This way ISPs can easily offer services. POTS over VoIP >>> can be setup on installation of the terminal (so >>> handover to the ISP is seamless). Finally business and >>> residential services can also be provided over the fibre >>> directly (this will be attractive to ISPs with many >>> ports, to reduce costs, and premium/business ISPs to add >>> control). > >This is also true of dark fiber pairs, with the added advantage >that the service providers can differentiate themselves on >chosen technology, can offer innovative services and can >leverage existing infrastructure to deploy newer technologies as >they develop. > >>> >>> - ideally the lines provider would aid in providing cheap >>> backhaul from the co (while still allowing 3rd party >>> users to bring fibre in). > >I don¹t think this is so ideal. Again, it creates an opportunity for >the lines provider to leverage their infrastructure in a way that it >can become a barrier to competition. This is, IMHO, the opposite >of good. > >> Wholesale mode. Doable. >> >> Works best if the lines provider is not a service provider; >> or regulation in your market ensures a service provider who >> is also a lines provider is mandated to unbundle at >> reasonable cost. > >Even when mandated to unbundle at a reasonable cost, often >other games are played (trouble ticket for service billed by >lines provider resolved in a day, trouble ticket for service on >unbundled element resolved in 14 days, etc.). > >IMHO, experience has taught us that the lines provider (or as I >prefer to call them, the Layer 1 infrastructure provider) must be >prohibited from playing at the higher layers. > >Owen >
