eircom`s Response to DCENR`s National Broadband

eircom’s Response to DCENR’s National Broadband Plan Call for Input Date 8/10/2014
Table of Contents
Foreward......................................................................................................................... 5
Executive Summary ......................................................................................................... 6
Question 1:
Do you agree or disagree with the classification of Basic Broadband
networks that has been applied? . .............................................................. 9
Question 2:
Please provide proposals and supporting information on which
Advanced Wireless Technologies might be deployed to deliver NGA
broadband as part of any proposed NBP intervention and how? ............ 12
Question 3:
Do you agree or disagree with the classification of NGA Broadband
networks that has been applied? .............................................................. 14
Question 4:
Do you agree or disagree that upload speeds delivered under the
State-Led intervention should be several multiples of those speeds
available today from Basic broadband networks. Please provide
proposals on what Upload speeds should be provided under the
intervention? ............................................................................................. 19
Question 5:
Can you please provide suggestions and proposals on the type(s) of
current and planned digital services which should be supported by
any State-Led intervention in NGA? .......................................................... 20
Question 6:
Do you agree or disagree that the characteristics, as set out above,
correctly describe NGA Broadband? ........................................................ 24
Question 7:
Do you agree or disagree that a State-led intervention network
deployment should demonstrate at least all of the characteristics as
set out in this document to qualify as a NGA network? ........................... 27
Question 8:
Do you agree or disagree with the decision process that has been
applied to identify potential areas for the State-Led intervention? ......... 29
Question 9:
Do you agree or disagree with the principle of establishing contracts
for committed rollout in order to secure the delivery of planned
rollouts of NGA broadband services? ....................................................... 32
Question 10:
Do you agree or disagree with the proposed definition for a step
change as set out above? Can you please propose amendments to
the definition and provide supporting information as appropriate. ........ 34
Question 11:
What metrics do you believe are the most appropriate to measure
the reliability of a NGA service? ............................................................... 35
Question 12:
Do you agree or disagree that packet loss and mean one-way latency
are optimum metrics to determine the quality of an NGA service? ........ 37
Question 13:
Do you agree or disagree that download speed and upload speed are
the optimum criteria to measure speed? Please provide supporting
information to your response ................................................................... 38
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Question 14:
What is your view on the requirement for optical (or equivalent)
technology for data backhaul. Do you agree or disagree that optical
(or equivalent) technology will provide the optimum backhaul
solution to achieve the objectives of the state-led intervention under
the NBP? .................................................................................................... 39
Question 15:
How close is sufficiently close to user premises to guarantee the
actual delivery of the very high speed. ..................................................... 40
Question 16a:
Please provide details of:- Current set of products and services being
offered to NGA users in existing NGA areas. ............................................. 41
Question 16b:
Please provide details of:- Plans for new products and services which
may be offered over NGA networks. ......................................................... 42
Question 17:
Do you agree or disagree that affordability should be a defining
characteristic of an NGA service? .............................................................. 44
Question 18:
The Department would welcome inputs on the definition of the
download speed parameter and the viability of the minimum
threshold value that is set out. .................................................................. 46
Question 19:
The Department would welcome inputs on the definition of the
upload speed parameter and the viability of the minimum threshold
value that is set out ................................................................................... 48
Question 20 (a): The Department would welcome inputs on the definition of the mean
one-way latency parameter and the viability of the minimum
threshold value that is set out .................................................................. 50
Question 20 (b): The Department would welcome inputs on the points in the networks
which would act as origination and destination points ............................ 52
Question 21 (a): The Department would welcome inputs on the definition of the
packet loss parameter and the viability of the minimum threshold
value that is set out ................................................................................... 53
Question 21 (b): The Department would welcome inputs on the points in the network
which would act as origination and destination points ............................ 54
Question 22:
Do you agree or disagree with the specification of these supporting
definitions and principles? ........................................................................ 55
Question 23:
Do you agree or disagree with the placement of such commitments
on the RSP to secure the delivery of NGA broadband services to NGA
users in line with the objectives of the NBP? In particular, your views
are sought in the following:- a) What form should these
commitments take? b) Who should monitor the activities of the
RSPs? c) How should this be policed? d) What actions should be taken
in the event of breach of commitments? .................................................. 56
Question 24:
The Department is seeking views on the requirement for a RSP of last
resort? How would this work in practice? ................................................ 59
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Question 25:
What are your views on the level of wholesale services that should be
made available by a State-Led intervention? What conditions should
be set down along the various levels of the value chain to ensure that
NGA users have a reliable NGA broadband service from a choice of
multiple RSPs? ........................................................................................... 60
Question 26:
The Department is seeking inputs on how a performance
measurement system might be implemented that provides sufficient
assurance of the quality of the service to the State, to operators
purchasing wholesale services and ultimately to NGA users. ................... 63
Question 27:
The Department is seeking proposals on the kind of measuring
systems which will demonstrate, with reasonable accuracy, that the
NGA broadband service is reliable and of high quality. Where in the
network should such measurements be made to and from? For clarity
please reference the typical value chain, outlined in Figure 1, in order
to realise an appropriate performance management system. ................. 65
Question 28:
The Department is seeking inputs on what Wholesale services should
be measured and by whom? ..................................................................... 66
Question 29:
Do you agree or disagree with the proposed approach set out above
for accessing semi-state assets?................................................................ 68
Question 30:
Do you agree or disagree that only those companies which have
passed the pre-qualification stage would be allowed to access such a
database and what lead time would be considered appropriate in
advance of the tender for making relevant information available to
potential bidders? ..................................................................................... 69
Question 31:
The Department is seeking inputs on the form of the bidders’ infrastructure database, how it would be managed, by whom, who
could access it, etc.? .................................................................................. 71
Question 32:
Do you believe the likely benefits arising from the availability of
ubiquitous high speed broadband will, over the long term, outweigh
the likely costs. If so what do you believe the main benefits will be? ...... 73
Question 33:
What are your views on the most appropriate ownership model for
the State-led intervention under the NBIP? ............................................. 77
Question 34:
What are your views in relation to governance structures for
monitoring compliance and performance in relation to any
contract(s) terms imposed? ...................................................................... 79
Question 35:
What are your views in terms of an appropriate procurement
strategy for the proposed State-led intervention? ................................... 81
Question 36:
The Department is seeking views on how to identify areas where
there is significant demand for high-speed broadband? How can this
demand be quantified?. ............................................................................ 86
Appendix 1
LTE definitions ........................................................................................... 91
Appendix 2
Action points from Meeting with the Department Error! Bookmark not defined.
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Foreword
The document sets out our responses to the 36 questions which were raised in the Call For Input. As
requested we have incorporated a summary answer to each of the questions within the Excel spread
sheet titled Annex 1; the detail pertaining to each answer, including data and lessons learned from
our fieldwork rolling out FTTH, is included in this document. We welcome the opportunity to share
this information with the Department as we believe this is a crucial exercise which will underpin the
success of Ireland’s National Broadband Plan. eircom is committed to working with Government in developing robust, future-proofed solutions to meet the requirements of the National Broadband
Plan and deliver on the critical need for high-bandwidth services across Ireland. eircom looks
forward to developing proposals to meet the important public policy objectives of this initiative.
Process
Substantial work has been undertaken and great care taken to address the questions you have
raised. Information provided is based on our best current view of:the evolution of our network over the coming years
the evolution of customer demand to ensure a future-proofed solution
the availability of technology and development of same
State Aid Guidelines
Best-in-class industry practices both home and abroad
Network rollouts may change from those indicated for engineering or commercial reasons and plans
or expected rollouts are subject to normal business planning processes as each phase comes up for
implementation.
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Executive Summary
This document is eircom Limited’s (“eircom”) response to the National Broadband Plan Call for Input
Request issued by the Department of Communications, Energy, and Natural Resources (the
“DCENR”). The Call for Input sought views from stakeholders on key topics under consideration within the
programme to deliver the proposed State-Led Intervention under the National Broadband Plan
(NBP). The outcome of the CFI will inform the development of a comprehensive Intervention
Strategy, particularly from a technical perspective.
eircom’s views on key topics under consideration
eircom considers NBIP as a once-in-a-lifetime opportunity for Ireland to provide a future-proofed
solution to Rural Broadband.
Despite Ireland having one of the most dispersed rural populations in Europe, eircom believes that a
high-capability solution can be found that will deliver on the important socio-economic objectives
that the NBIP Programme is intended to address.
eircom agrees with the approach being taken to define NGA services and believes it is
essential to ensure that such services can be delivered to all customers within an
intervention footprint during Busy-Hour.
Headline broadband speed is important, but so too is the ability to sustain long-duration
data loads from multiple premises at the same time. The need for high-speed broadband is
being driven by explosive growth in the volume of data consumed by households and
businesses. The amount of data consumed has been growing at about 25% to 30% pa, with
industry forecasts projecting similar compound growth rates over coming years.
It is essential to ensure that a network has the ability to support a strongly growing data
demand from each customer to be served within the identified footprint, and to ensure
that the solution is future-proofed and will not require further intervention.
30 Mbps should be set as a minimum requirement to deliver a step change and a chosen
solution must have an ability to evolve to higher speeds as customer needs evolve in a cost
effective manner.
NGA services should support a full range of advanced digital services.
The increased consumer demand for a high-speed network requires a network architecture
that is robust, flexible, based on industry standards and should not require significant
physical infrastructure changes for decades to come. A solution that is based primarily on
FTTH is likely to be best because fixed line broadband has transmission characteristics that
make it eminently suitable for home-based broadband and because FTTH will cost-effectively
support very high data speeds as customer needs continue to grow.
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Advanced Wireless is suitable for only a small proportion of the intervention footprint as
even in low-density areas, it is likely to be cost prohibitive if deployed with the appropriate
architecture and capacity to support high data loads from homes and businesses.
Provisions should be included to adapt the intervention footprint to reflect evolving rollout
plans from the operators, as technology developments and reduction in infrastructure costs
will enable operators to extend beyond what they forecast in 2014.
Contracts for committed rollout should be utilised to ensure that indicated commercial
rollouts are reliable and that the intervention footprint is correctly identified.
A full end-to-end retail solution together with wholesale variants should be mandated, to
ensure that all customers in the intervention footprint can avail of NGA services and be
provided with a choice of retailers. Retail services providers, or other service providers in
the value chain, should be granted access only on condition that they will deliver a fully
compliant service to all users.
As well as the intervention footprint, DCENR should specify expected minimum data loads
per customer and minimum numbers of customers to be served within the footprint to
ensure that service levels do not degrade over time.
Rigorous measurement at multiple levels should be adopted.
Access to the infrastructure databases of all pre-qualifying bidders’ infrastructure should be made available in advance of the pre-qualification stage, with availability of information
being a condition of DCENR acceptance of registration of operator’s interests.
Socio-economic benefits can be measured and, based on evidence, can justify State-led
investment.
Public policy objectives would be most readily achieved if infrastructure is owned by
operators, but the ability to ensure that public policy objectives can be achieved over the
long term needs to be assured through long-term contracts (20 years) and through the
establishment of policy or governance arrangements that would include an appropriate
Monitoring and Compliance Agency.
Binding contractual terms should be used to ensure that all operators along the value chain
deliver fully compliant NBIP NGA services. Obligations should include regular reporting in a
standard format to the Monitoring and Compliance Agency.
eircom’s capabilities and commitment
eircom is committed to working with Government in developing solutions to meet the requirements
of the National Broadband Plan and looks forward to developing proposals to meet the important
public policy objectives of this initiative.
eircom has participated in the DCENR mapping exercise and has conducted further detailed analysis
of rural Ireland and the challenges of rolling out a rural broadband infrastructure. In that context,
the following points should be noted:
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eircom has built the largest broadband network in Ireland, extending to 90% of the
population, and is well advanced in deploying our fibre-based Next Generation Access (NGA)
network with coverage of 1 million addresses achieved to date. As technology and customer
requirements have evolved, the need to offer next generation services has greatly increased.
The challenge for large-scale infrastructural investment is being met by eircom even in the
challenging recessionary period we have experienced over recent years.
eircom is the largest fixed-line operator in Ireland and has extensive wireless networks.
eircom has an established NGA portfolio and an established wholesale business. eircom has
established IT interfaces and processes that can readily make NBIP wholesale service
available to all other operators, delivering competitive retail and wholesale offerings compliant with EU requirements for fairness and non-discrimination - and an abundance of
choice to the Irish consumer.
eircom has a fully developed set of retail and wholesale services and processes including
fault analysis and service level agreements (SLAs). Customer care processes are already in
place that can readily support NGA in rural areas.
In April 2014 eircom commenced the deployment of new ‘Vectoring’ technology which
enables the provision of speeds of up to 100 Mbps
eircom currently offers FTTH to 12,000 homes and businesses
In September 2014, we announced our plans to extend our fibre-based broadband rollout
to an additional 200,000 addresses to planned coverage of 1.6M addresses, together with
plans to extend our FTTH footprint as an on-demand service and as an in-fill in middle Ireland
as we progressively evolve our NGA network.
eircom has approx. 56,000 km of overhead network that already passes most buildings in
rural areas and we envisage that a very high quality of service would be provided by a
passive FTTH infrastructure that is not as susceptible not susceptible to wind, lightning and
moisture ingress in the same way as traditional copper infrastructure.
As an example of that evolution, eircom recently started deploying FTTH to the town of
Belcarra, County Mayo, on a trial basis – Our aim is to trial speeds up to 1 Gbps and assess
new construction and operating methods for non-urban areas.
We will partner with a number of hardware partners who will encourage engagement within
the community by providing the necessary devices to get those involved online and
benefiting from the high-speed broadband infrastructure. We would welcome the
opportunity to share our findings and results with DCENR.
eircom’s LTE network could be used in the NBIP, for those limited areas where it is likely to
be cost-effective. In the recent spectrum auction, eircom invested €145 million for spectrum
acquisition and €100 million for usage fees. Work is well-advanced in deploying LTE
infrastructure and rolling out services.
These investments form part of eircom’s €1.5 billion capital expenditure programme over
the course of our medium-term business plan and demonstrate our very strong commitment
to providing next-generation services to fixed and mobile customers across the country.
eircom’s investment will significantly reduce the number of premises which will require
public subsidy.
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Question 1: Do you agree or disagree with the classification of Basic Broadband networks that has
been applied? Please provide supporting information and examples in your answer.
eircom fully agrees with the classification of Basic Broadband networks that has been applied.
eircom fully agrees with the classification of Basic Broadband as set out by DCENR and in the EU
guidelines for the application of State Aid. eircom has been working towards the European
broadband ambition of Basic Broadband for all by 2013. We have to date deployed basic
broadband to exchanges serving 95% of the population. However, where population density is low
as is the case in some parts of Ireland, eircom has found it difficult to achieve the European
Broadband ambition. Given that user requirements are increasing, eircom is of the view that it is
better to move beyond Basic Broadband in these areas as part of the Intervention Programme. In
line with data growth requirements, eircom has over the past number of years worked towards
higher headline speeds that are a step change beyond Basic Broadband, through a programme to
deliver NGA to 1.6 million premises in Ireland, bringing speeds of up to 100 Mbps.
eircom fully agrees with the European ambition that:
Access to broadband with speeds of 30 Mbps or above should be available to all citizens by
2020
50% of European households should be subscribed to services of 100 Mbps or higher by 2020
While the technologies identified as Basic Broadband are still widely in commercial use in Ireland
and all European countries, the explosion in data services over the past number of years and the
predictions for the future would reasonably define these networks as first generation and hence
Basic Broadband networks. The main drivers of increased broadband network requirements are:
Increases to access bandwidth determined by applications and customer expectations of
shorter download times
o A recent report by SandVine highlights eircom internet users spending 60% of their
time at peak hours either on Netflix or YouTube. Where Netflix is the pioneer,
advanced video applications for eGovernment and eHealth are the "settlers" who
follow afterwards; consumer applications like Netflix pave the way for future services
which will further increase the demand
TV incl. larger screens and better resolution (Smart TVs and STBs)
Multiple connected devices
Increased broadband penetration
Tablets adding to fixed-line traffic (mostly WiFi)
Mobile data off-load through WiFi
Forecasts for the growth of broadband requirements over the next few years range from a CAGR of
20% (Cisco) to CAGR of 34-41% in Western Europe (Analysys Mason). Basic Broadband networks
cannot improve beyond their current data rates and are not future-proofed.
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ADSL up to ADLS2+
Traditional DSL technologies have limited downlink throughput and should indeed be classified as
Basic Broadband, as indicated in the table below which shows the achievable ADSL and ADSL2+
speeds for various cable distances.
Distance (m)
ADSL Bitrate
(Mbps)
ADSL2+ Bitrate
(Mbps)
500
1,000 1,500 2,000 2,500 3,000 3,500 4,000 4,500 5,000 5,500 6,000
8
8
8
8
8
6
5
4
3.5
2.5
1.5
1
23
19
16.5
14.5
12
10
6
4
3.5
2.5
1.5
1
Figure 1 Downstream speed versus loop distance for ADSL technologies
DOCSIS 2.0
The capability of older generations of DOCSIS such as DOCSIS1.x or DOCSIS2.0 is too limited to
consider them as NGA broadband technologies. In particular, channel bonding is not supported,
resulting in a maximum shared downstream throughput of a single DOCSIS channel of 50 Mbps.
Further, DOCSIS 2.0 could not be consider future-proofed with its lack of support for IPv6.
3G
3G (UMTS) should be considered a Basic Broadband technology.
Theoretically, as defined in 3GPP Rel. 7 and 8,evolved HSPA (HSPA+) can provide peak data rates of
42 Mbps in the downlink and 11 Mbps in the uplink (using 2x2MIMO, 64QAM and a single 5MHz
carrier). This theoretical data rate could be increased further using carrier aggregation (Rel. 11). For
example, by using all the 3 carriers in the 2100MHz band, HSPA+ could, in theory, deliver a peak
speed of 126 Mbps on the downlink and 33 Mbps on the uplink.
In practice, there are several issues:
Even in a perfect world, 126 Mbps would have to be shared amongst all simultaneously
active customers in the cell
These relatively modest peak speeds would be the best achievable speeds as there is no
significant future improvement for UMTS
Achievement of the higher bit rates depends on the functionality of the user’s equipment
which is not currently commercially available and is not likely to become so
For two aggregated carriers and beyond, LTE offers greater spectral efficiency and would
therefore be more appropriate for a network with a considerable life time
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Satellite
Satellite systems can offer a Basic Broadband service using the Ka band, typically capable of
delivering 20 Mbps on the downlink and 6 Mbps on the uplink. However satellite suffers from high
latency making it unsuitable for the real-time services which, in eircom's field experience, have
proven the great drivers for bandwidth usage including VoIP, interactive gaming and videoconferencing. With that in mind, eircom does not consider satellite as NGA broadband technology
but, under certain criteria, it may have a role in providing services to extremely remote isolated
buildings.
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Question 2: Please provide proposals and supporting information on which Advanced Wireless
Technologies might be deployed to deliver NGA broadband as part of any proposed NBP
intervention and how? Please provide worked examples
In response to later questions, eircom outlines its view as to why fixed technology, in particular
FTTH, is better for delivering NGA broadband. eircom recognises that Advanced Wireless
Technologies such as LTE-Advanced may have a role to play in the NBIP solution but would suggest
that LTE-Advanced has very significant limitations in terms of overall capacity, cell edge
performance, guaranteed in-building service and the scale of deployment required relative to the
actual number of customers it will serve. eircom would consider Advanced Wireless Technologies
to have a very limited role in the NBIP area if coverage and capacity guarantees are to be secured.
Further information is provided in many of our technical answers to support this statement.
LTE-Advanced (3GPP Release 10 and beyond) is an evolution of LTE (3GPP Release 8) and has many
of the attributes required to deliver, to mobile customers and mobile usage patterns, a high-quality
mobile broadband service. However, the combination of features, configurations and scale of
deployment needed to deliver a consistent, reliable, high-speed, NGA broadband service for fixed
users, limit the practicality of such a solution.
In theory, LTE-Advanced can be designed to deliver 30 Mbps at cell edge and deliver an increasing
amount of capacity per cell through techniques like carrier aggregation, NxM MiMo, external
antennas and various other features. However, eircom considers wireless technology too inflexible
for wider use as a fixed broadband technology.
In terms of coverage it can be very difficult to guarantee coverage in specific rooms of a house even
with external antennas. As more people use the service in an area it can become increasingly
difficult to ensure all users are guaranteed the minimum speed. It is highly likely that what initially
might be considered a step change in throughput for a customer, over time, will become significantly
eroded.
For a 20MHz FDD channel, with 4x4 MIMO on the downlink and 2x4 MIMO on the uplink, we can
expect approximately 74 Mbps of total downlink capacity and 40 Mbps of total uplink capacity for all
users in a cell. While these capacities are very good for mobile broadband, it would be very
challenging to guarantee 30 Mbps NGA broadband per active user on the downlink and 10 Mbps
NGA broadband per active user on the uplink.
Fixed broadband networks are normally dimensioned per contracted customer rather than per
active customer. The dimensioning capacity for eircom NGA broadband customers is currently
measured to be in the region of 500 Kbps per contracted customer. Based on projections and fixed
broadband experience, it is expected that this will rise to 2.5 Mbps per customer by 2020.
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Where a 20MHz channel provides an average capacity of 74 Mbps, we would expect a cell to support
approximately 30 NGA contracted customers by 2020. As an LTE-Advanced node normally has three
sectors (cells), this equates to a total of 90 NGA customers per site. This capacity constraint could
drive a requirement for a large number of sites for a relatively small number of customers in the
NBIP footprint – 7,000 sites would be needed to support 630,000 customers. In addition, as the
throughput per user is expected to increase continuously, sites will have to be added continuously in
line with the increased demand or upgraded with new technology to maintain the same level of
service. As a site can cost in the order of €150,000 this equates to a very high cost per customer.
eircom’s analysis (please see Appendix 1 for details) shows that LTE is coverage-limited to a cell
radius of maximum 6 km if it is to deliver 30 Mbps. Even taking future spectral efficiency into
account, it will be capacity-limited to 12-15 simultaneous users per site. In April/May 2014, eircom
conducted an RFI on wireless technologies with the three major international wireless and mobile
technology vendors. A key question for eircom related to using LTE as a “sweeper” technology which would provide coverage relatively quickly and would be replaced at a later date by a future proof
fibre solution. Analysis of the vendor responses, and subsequent intensive workshops involving
senior subject matter experts from eircom and the vendors, led eircom to conclude that it would be
extremely challenging and far too costly to use LTE as a “sweeper” technology in NBIP. However,
there are a limited number of particular use cases e.g. very remote clusters of houses at the end of
ribbon roads, where wireless could be applied.
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Question 3: Do you agree or disagree with the classification of NGA Broadband networks that has
been applied? Please provide supporting information and examples in your answer.
While eircom agrees with the classification of NGA Broadband networks from a technical capability
perspective, we are of the view that a predominantly FTTH solution will offer the most cost
effective NBIP solution, with limited roles for FTTN and for LTE Advanced. eircom has conducted
significant analysis of rural areas on Ireland and concluded that Ireland is quite different in terms of
population density compared to most other European countries. eircom recommends that FTTH is
the most appropriate NGA Broadband network for the NBIP.
After intensive research and assessment of the most workable and sustainable solutions, given
Ireland’s topology and housing patterns, and considering the requirement to deliver the fastest
speeds to as many people as possible in a way that would be scalable now and in the coming
decade, eircom has concluded that Gigabit Passive Optical Network (GPON - ITU G.984) is the most
viable option.
Fibre-based platforms
FTTx is a collective term for various optical fibre topologies that are categorised according to where
the fibre terminates. Standard definitions have been established by the FTTH Councils of Europe,
North America and Asia-Pacific for FTTH (Fibre to the Home) and FTTB (Fibre to the Building) but not
for the other FTTx terms1.In the figure below, the main definitions recognised throughout the
industry are illustrated.
Figure 2 Illustration of FTTx Technologies
1Reference :http://www.ftthcouncil.eu/documents/Publications/FTTH_Definition_of_Terms-Revision_2011-Final.pdf
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In Fibre to the Cabinet (FTTC) or Fibre to the Node (FTTN), the optical fibre terminates in a cabinet or
a node from where the remaining cabling to customers’ premises is copper. eircom has extensive experience with this technology and is investing over €400 million to deploy NGA services to 1.6
million premises nationally. This technology is distance-dependent i.e. the further away from the
cabinet the lower the speed. However, the customer is not sharing the bandwidth with any other
users. The technology has proven to be a significant first step in deploying fibre further into the
network and is extremely well suited to deployment where clusters of houses are the predominant
building style. The cabinet is located in areas with high building density to reduce the disadvantage
of the technology being distance-dependent.
FTTN and FTTC use VDSL technology to deliver reliable downstream bit rates up to 70 Mbps. The
addition of Vectoring technology at the DSLAM enables delivery of downstream bit rates up to
100 Mbps for copper loop lengths of up to approx. 0.3 km (depending on the type of cable). The
speeds achieved using VDSL with vectoring are shown for various cable distances in the table below.
These results were measured by eircom using 0.5mm copper cable which is the typical gauge of
cable in the urban access copper network.
Figure 3 Vectored VDSL bit rate [bit] as a function of distance [m]
Distance (m)
250
Vectored VDSL Downstream
Bitrate (Mbps)
104
500
750
92
60
1,000 1,250 1,500 1,750 2,000 2,150
40
28
22
18
14
11
Figure 4 Vectored VDSL 17MHz downstream speed vs. copper loop length
eircom has explored a smaller variant of the normal VDSL access multiplexer, the Mini-DSLAM, for
areas that we believe are likely to form the target area for NBIP. See Appendix 2 for further
discussion. VDSL broadband speeds are distance-dependent; a mini-DSLAM would be needed at
circa every 1.2 km to deliver 30 Mbps, given the typical dispersion of premises in the likely NBP area.
This would result in a very high level of active elements in the rural access network. In areas of low
housing density, the number of customers per mini-DSLAM will be low and the average cost per
customer will be high. The mini-DSLAM solution is not future-proofed and cannot be upgraded to
deliver increased speeds. Delivering increased speeds to these customers would require additional
mini-DSLAMs to be deployed closer the customer or a migration to either Fibre to the Distribution
Point (FTTDP) or FTTP technology.
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FTTDP refers to the deployment of optical fibre as far as the copper distribution point (DP) and
connection from the DP to the customer’s premises via existing copper infrastructure. The DP could
be located in a manhole, an enclosure on a pole or in the basement of a building. This architecture
could support VDSL or G.fast technology for a short copper drop connection, normally less than
250m. G.fast is particularly appealing for drops of less than 50m but the disadvantage is that it
requires a very significant number of active elements in the network (e.g. an element per 48, 32 or
16 users) which is operationally challenging. G.fast will be commercially available in late 2016,
although pre-commercial and pre-standardised versions are currently available. eircom will be
conducting a prototype trial of G.fast over the coming months to gain more experience. eircom
would consider G.fast to have advantages in cases where the connection to the house is underground and has been obstructed preventing installation of a replacement connection to the house.
However, as many rural homes are connected via overhead, eircom considers that it should be
possible, in the majority of cases, to deploy fibre all the way into the home. Nonetheless, G.fast
offers an additional technical option that will prove useful in an FTTH deployment.
In a Fibre to the Building (FTTB) deployment, optical cabling terminates at the building, which is
typically multi-unit. Delivery of service to individual units from the fibre terminating point may be
through any of a number of methods, including VDSL or G.fast.
Fibre to the Premises (FTTP) is used to denote both FTTH and FTTB deployments or is sometimes
used to indicate that a particular fibre network includes both homes and businesses.
In a Fibre to the Home (FTTH) deployment, optical cabling terminates at the individual home or
business. Most of the FTTx architecture deployments rely on the same underlying technology –
Gigabit Passive Optical Network (GPON - ITU G.984). With the current generation of commercially
available DPON, GPON is a single point-to-multipoint fibre architecture shared across a small
number of users (typically 32 or 64) and capable of delivering a bandwidth of 2.5 Gbps downstream
and 1.25 Gbps upstream and thereby avoid network and operational complexity.
After intensive assessment of, the most workable and sustainable solution, given Ireland’s topology and housing patterns, plus the requirement to deliver the fastest speeds to as many people as
possible in a way that would be scalable now and in the coming decade, eircom has concluded that
GPON is the most appropriate technical solution for the NBIP.
GPON is future-proofed with a strong roadmap evolving to 10 Gbps downstream and 2.5 Gbps
upstream and further to 40 Gbps of shared downstream bandwidth with the Next Generation PON
standard. Deploying in a splitter configuration of 1:32 with 100% utilisation (which would never in
practice be the case), GPON delivers guaranteed speeds of between 65 Mpbs and 78 Mbps
depending on configuration of e.g. multi-cast reservation per user. However, bursting far beyond
that would be possible if bandwidth is available.
October 2014
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Figure 5 ITU PON roadmap
eircom has deployed FTTH in the urban areas of Sandyford and Wexford since 2012 for circa 8,000
homes. eircom is currently trialling FTTH in a rural setting in Belcarra in County Mayo. By the end of
September, eircom will have deployed 12 km of All-dielectric self-supporting (ADSS) cable on the
existing eircom pole and duct infrastructure. Over the next 4 -6 months, eircom expects to gather
significant practical experience from this trial.
FTTH is by far the most flexible and future-proofed of the FTTx technologies. It has the further
advantage that there are no active nodes in the access network which makes it operationally
attractive and very stable. Analysys Mason has published its view of the operational stability and
superiority of FTTH versus VDSL2 for a rural copper network. eircom has carried out significant
analysis and we have concluded that:
As the technology has matured and as operational experience and understanding of the
deployment issues advances, lower equipment costs over recent years have made an FTTH
solution increasingly more cost-effective to deploy.
it has significant advantages in the ribbon development in rural Ireland
it is the only technology that is sufficiently future-proofed
All these FTTx technologies can be classified as NGA access technologies. As described above, eircom
maintains FTTH is particularly useful as a technology in the low density housing-ribbons that will be
the norm within the NBIP intervention area.
2
Reference: NGA operational expenditure: a comparison of opex on FTTH, VDSL and ADSL networks
,
Analysys Mason, August 2013
October 2014
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Advanced Cable Networks
DOCSIS 3.0 introduced the capability to bond multiple 50 Mbps channels with potential deployment
of 8 to 12 channels per bonded group (i.e. 400 Mbps to 600 Mbps speed), IPv6 support and
enhancements for IP multicast. At present, cable broadband networks typically bond four channels
and offer speeds of up to 200 Mbps to customers. The primary disadvantage is that this capacity is
shared between all users, typically hundreds, on a co-axial cable segment.
DOCSIS 3.1 has recently been standardised with the long-term aim to deliver up to 10 Gbps
downstream and up to 2 Gbps upstream. However, bandwidth would again be shared across a very
large number of users e.g. 500 homes. In addition, Hybrid Fibre Co-Ax (HFC) networks consist of
active nodes such as coax line amplifiers and optical transponders, which make greenfield
deployment and maintenance challenging.
While DOCSIS 3.0 has the ability to evolve to meet NGA requirements, it will have to evolve closer to
a GPON FTTH network over time.
Certain Wireless Networks
Certain advanced wireless access networks are capable of delivering reliable high speeds for mobile
customers and therefore can be considered to be NGA broadband networks. As outlined in our
response to Question 2, there are technical challenges and limitations which would make this a
costly and challenging solution to apply as a single technology solution across the NBIP area.
However, there are a limited number of particular use cases e.g. very remote clusters of houses at
the end of ribbon roads, where wireless could be applied.
eircom agrees that any advanced wireless network has to be compliant with the IMT-Advanced
requirements. LTE-Advanced is the best technology with the necessary industry support and
economies of scale. It also has a clear roadmap to meet the IMT-Advanced requirements.
As discussed in eircom’s response to Question 2, although LTE Advanced has the capability of
supporting Next Generation Services, it is likely to be cost prohibitive.
Where a 20MHz channel provides an average capacity of 74 Mbps, we would expect a cell to support
approximately 30 NGA contracted customers by 2020. As an LTE-Advanced node normally has three
sectors (cells) this equates to a total of 90 NGA customers per site. This capacity constraint could
drive a requirement for a large number of sites for a relatively small number of customers in the NBP
– 7,000 sites would be needed to support 630,000 customers. In addition, as the throughput per
user is expected to increase continuously this would suggest that sites will have to be added
continuously in line with the increased demand of upgraded with new technology to maintain the
same level of service. As a site can cost in the order of €150,000 this equates to a very high cost per customer. Consequently, while we understand that LTE Advanced will have a role in an NBP solution,
it is likely to be limited.
See Appendix 1 for additional details about LTE Advanced.
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Question 4: Do you agree or disagree that upload speeds delivered under the State-Led
intervention should be several multiples of those speeds available today from Basic broadband
networks. Please provide proposals on what Upload speeds should be provided under the
intervention?
eircom agrees that the upload speed should be several multiples of those speeds available from
Basic Broadband networks, especially considering future broadband services such as interactive
gaming, cloud/storage based services, video-conferencing and providing the necessary remoteworking arrangements to drive employment.
The following table indicates theoretical maximum and typical uploads speed of some Basic
Broadband technologies.
Upload speed (Max)
Upload speed (Typical)
Comments
ADSL2+
Up to 3.3 Mbps
500 Kbps – 1 Mbps
Using G.992.5 Annex M.
DOCSIS 2.0
Up to 27 Mbps
2 -4 Mbps
Using one 6.4MHz return
channel
3G (UMTS)
5 Mbps
1 – 3 Mbps
28 Mb/ss HSDPA+
(single carrier, 2x2 MIMO)
Figure 6 Basic Broadband – theoretical Maximum upload throughput
eircom suggests that NGA technology should offer at least 3 to 5 times more upload speed than
existing Basic Broadband technology to deliver step change to the customer experience.
However it is also eircom’s view that, while these step-changes in speed today would be considered
significant, customers’ expectations will increase significantly over the lifetime of the network. It is therefore essential that the network not only delivers the initial step-change but is also sufficiently
flexible to increase by multiples above this in the future. In its report Fixed network data traffic
worldwide: forecasts and analysis 2014–2019 of March 2014, Analysys Mason concluded that fixed
network data traffic will grow at a CAGR of 29% between 2014 and 2019, and the average on-net
and Internet usage per fixed broadband connection worldwide will be 188GB per month by 2019.
In addition, it is desirable that the NGA access technology be capable of supporting symmetrical
services e.g. for businesses applications such as cloud computing, home office/VPN or HD video
conferencing. For providing NGA broadband to businesses, an alternative to GPON-based FTTH
deployment is point-to-point (P2P) using Ethernet technologies. This solution consists of an Ethernet
aggregation switch, located at the POP/exchange or in street cabinets, that has dedicated fibres to
each customer premises. The main advantages of FTTH architecture using P2P Ethernet technology
are increased reach, no sharing of bandwidth and therefore increased security and higher speed,
and the capability to support symmetrical services. It has the capability to deliver a fully-dedicated
1 Gb/s service per customer. These characteristics make P2P Ethernet potentially a more suitable
technology for business applications than GPON.
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Question 5: Can you please provide suggestions and proposals on the type(s) of current and
planned digital services which should be supported by any State-Led intervention in NGA?
eircom considers that a State-led NGA should be able to support the same range of services that
are available in commercially deployed areas, including converged all-IP services, and have the
ability to support evolving customer and market demands.
The future use within rural areas should deliver on eHealth, eGovernment, eEducation and similar
services considering rural infrastructure and demographic changes. eGovernment services will be
key to servicing rural communities via reliable broadband service without the need for additional
investment.
Current Services in Commercially Deployed Areas
Broadband supports an ever-increasing range of services. At a high level, existing services include:
Internet browsing
OTT applications such as Skype, GoogleVideo, Apple TV, Netflix and YouTube
Smart TVs
Connectable devices including Games Consoles, PCs and Tablets
Catch up services such as RTE Player
Smartphones that utilise fixed broadband to off-load data
Upload and cloud storage
The increasing popularity of home working is leading to increased upload activity
eCommerce
Video conferencing
With the continuing convergence of networks and broadband to digital, eircom agrees that all-IP
must be supported.
Evolving Services
eircom considers that a State-led NGA should be able to support the same range of services as are
available in commercially deployed areas and in addition have the capability to evolve as customer
and market needs demand.
In its report Fixed network data traffic worldwide: forecasts and analysis 2014–20192019 of March
2014, Analysys Mason concluded that fixed network data traffic will grow at a CAGR of 29% between
2014 and 2019, and the average on-net and Internet usage per fixed broadband connection
worldwide will be 188GB per month by 2019.
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Other trends noted by Analysys Mason in relation to service include:
Traffic will become peakier and, more asymmetric. The highest average usage will be in
North America and Central and Eastern Europe.
The main drivers are smart TVs, TVs otherwise connected via peripherals such as IPTV set-top
boxes and games consoles, and multiple tablets.
The speed of Internet access is an enabler rather than a driver of traffic. Widespread multigigabit access has the potential to create very different commercial ecosystems that
generate far more traffic.
On-net traffic will grow faster not because of a breakdown in net neutrality, but because a
concentration of content in global content brands (and a concentration of viewing
preferences) will make bilateral interconnection between those content providers and
networks more efficient than the current hub-and-spoke architecture of the Internet.
Multicast traffic is much more supply-side driven than Internet or on-net.
Smartphones and tablets will account for 23% of worldwide fixed data traffic by 2019, but
mobile data will account for just 5.2% of total data
Cisco®’s Visual Networking Index (VNI), an on-going initiative to track and forecast the impact of
visual networking applications, found:
Global IP traffic has increased more than fivefold in the past 5 years, and will increase
threefold over the next 5 years.
Busy-hour Internet traffic is growing more rapidly than average Internet traffic
Content delivery networks will carry over half of Internet traffic by 2018 (55%, up from 36%
in 2013).
By 2018 traffic from non-PC devices will grow to 57% (up from 33% in 2013). PC-originated
traffic will grow at a CAGR of 10%, while TVs, tablets, smartphones, and machine-to-machine
(M2M) modules will have traffic growth rates of 35%, 74%, 64%, and 84%, respectively.
Global Internet traffic in 2018 will be equivalent to 64 times the volume of the entire global
Internet in 2005.
The number of devices connected to IP networks will be nearly twice as high as the global
population in 2018 (nearly three networked devices per capita).
Requirements for broadband speeds will nearly triple by 2018. By 2018, typical global fixed
broadband speeds will reach 42 Mbps, up from 16 Mbps in 2013.
Business IP traffic will grow at a CAGR of 18% from 2013 to 2018 (Increased adoption of
advanced video communications in the enterprise segment will cause business IP traffic to
grow by a factor of two between 2013 and 2018).
With consideration to these forecasts the following services can be provided for nationally when the
‘digital divide’ is significantly reduced:
October 2014
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e-Government: e-Government initiatives similar to the existing Revenue Online Services can
drive efficiencies throughout the civil service by automating common processes. However
national uptake of these services is reliant on reliable access to broadband, and will
increasingly become reliant on access to high-capacity broadband services. As the
penetration of reliable next generation broadband improves, the business case to offer more
efficient services through online methods becomes more viable, as the number of citizens
able to use the service increases.
e-Health: In developed healthcare markets providers are increasingly looking to e-Health
both on-site and in people’s homes as a means of improving patient care while driving cost efficiencies. Whether future healthcare services are implemented to support home care or in
relation to medical devices or communication devices within a hospital, it will be imperative
for these services to be supported by reliable broadband service. e-Health services
leveraging video have both the highest potential for citizen benefit and the highest appetite
for bandwidth. Any State intervention now must consider the bandwidth needs of e-Health
in particular – including video services already used in other geographies, as well as
innovative services yet to be developed – in order to ensure that a genuinely future-proofed
technology is at the heart of NBIP.
e-Learning: While it is not envisaged that e-Learning will replace traditional education,
education providers and governments can improve education services through improved
access to education tools, and assistance in setting exams and monitoring performance.
e-Agriculture: Next Generation Access is crucial for the application of ‘Future Internet’ Technologies to create a ‘Connected Agriculture’ ecosystem. The vision is to create unified,
ubiquitous and interoperable computing in Agriculture in line with Food Harvest 2020 as set
out by the Department of Agriculture. Innovation in Connected Agriculture has huge
potential to impact the major development issues we face today: climate change; economic
growth; social wellbeing and environmental sustainability. Connected Agriculture can
integrate the primary producing farmer with markets, financial systems and increase
knowledge transfer and sharing, making it possible to monitor resources and track products.
The Government can also benefit through the improved throughput of data and improved
data collection. The utilisation of this data in conjunction with records already managed and
stored will help the overall vision of eGovernment and Open Data. Pilot projects and open
beta applications will provide an astute opportunity to test the applicability of the
innovations and business models along with road-testing the technology used in the
solutions.
environmental issues: to encourage the appreciation and protection of Ireland’s unique natural environment, the aim is to empower community-based groups, schools, businesses
and individuals alike to protect and promote Ireland’s outstanding and valuable natural inheritance. The assistance of data collection can only be enhanced by the deployment of
high-speed broadband: in addition these projects offer real sustainable rural based job
creation plus promote tourism.
International Investment: Widespread penetration of a high-speed broadband network
would result in a more balanced deployment of inward investment, maximising our labour
pool, our raw materials and the consumer reach.
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As and when Government or private enterprise increases the use of the above services on a national
level, it will create an increase in the use of broadband services made available through State-Led
Intervention. It is imperative that the investment made will allow for introduction of any or all of the
abovementioned services without the need for:
Additional investment in the infrastructure
Compromising performance of the existing and evolving commercial services utilised.
October 2014
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Question 6: Do you agree or disagree that the characteristics, as set out above, correctly describe
NGA Broadband? Please provide supporting information and examples for each characteristic.
eircom agrees that the characteristics of step change; reliability and quality; very high download
speeds; substantially higher upload speeds (compared to Basic); Optical (or equivalent) technology;
support for a variety of advanced digital services; and affordability; correctly describe NGA
broadband.
eircom would also include future-proofing in terms of easy expansion to cater for the anticipated
growth in broadband usage; Internet of Things (IoT); IPv6 and other as-yet unknown demands; as
an additional key determinant of NGA Broadband.
An intervention such as the NBIP will put in place an asset which will deliver a solution to the digital
divide in Ireland and position Ireland as a leader in an increasingly information-driven economy.
Employment will also result over several years; NGA services are a crucial location factor when
attracting and securing jobs in both rural and urban areas. An increase in education and skills plus
significant benefits will result in the quality of life resulting from teleworking, as well as in areas such
as e-Health.
eircom would agree in principle with the listed characteristics however with the following additional
comments:
Step Change
eircom agrees that the characteristics of Step Change, as described in section 3.5.3.1, applies to
NGA with the caveat that we would view an upgrade from ‘FTTC/VDSL at the cabinet’ to ‘FTTC/VDSL at the cabinet with Vectoring’ to be a step change.
Upgrading from Basic Broadband ADSL / ADSL2+ to VDSL is a step change as it enables customers to
move from speeds of up to 24 Mbps (under ADSL2+) to speeds of up to 70 Mbps. The addition of
Vectoring technology at a cabinet enables a significant speed increase to up to 100 Mbps.
Reliability and Quality
eircom agrees that the characteristics of Reliability and Quality, as described in section 3.5.3.2,
apply to NGA.
Reliability and quality is a key characteristic of an NGA broadband service. Downlink and uplink
speeds, no congestion, low latency with high availability are all required to deliver a service of high
quality.
Reliability in the sense of delivering a quality service consistently is also a requirement.
October 2014
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Download Speed
eircom agrees with the characteristics of Download speeds, as described in section 3.5.3.3, applies
to NGA.
This is key characteristic for an NGA broadband service to support applications such as highdefinition video stream.
Upload Speed
eircom agrees that upload speeds for NGA should be substantially higher than for Basic Broadband.
This is key characteristic for an NGA broadband service to support applications such as cloud-based
storage, cloud-based applications, file sharing, interactive gaming, video conferencing and video
uploading.
eircom suggests that NGA technology should offer at least 3 to 5 times more upload speed than
existing Basic Broadband technology to deliver a significant improvement to the customer
experience.
Reliance on optical or equivalent technologies
eircom agrees that optical technology is essential for NGA Broadband networks. eircom’s view is that, for the NBIP, optical fibre must penetrate as deeply as possible into the network.
All of the technical solutions available for delivering NGA broadband depend on optical technologies.
Even mobile solutions are using an increasing amount of fibre to backhaul base stations in order to
support mobile broadband services.
Support a variety of advanced digital services including converged all-IP
services
eircom agrees that NGA Broadband networks must be capable of supporting advanced digital
services.
Affordability
eircom agrees that any Government intervention should have the objective of ensuring delivery of
affordable services to customers within the target area. This would encourage service adoption
and also ensure that the primary policy concern of eliminating the digital divide is met. The
definition and agreement of affordability is key.
Future-proofing
eircom would also include future-proofing (in terms of easy expansion to cater for the anticipated
growth in broadband usage; Internet of Things (IoT); IPv6 and other, as-yet unknown, demands) as a
key determinant of NGA Broadband.
October 2014
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eircom is of the view that longevity in terms of bandwidth scalability and future-proofing is an
important characteristic. Any NGA broadband technology should be able to cater for increases in
speed and throughput per user, driven by applications such as video-conferencing and highdefinition video streaming, without significant service disruption or technology changes. Features
such as quality of service and multicast capability to allow the effective delivery of video and voice
services; capacity to cater for growth such as the Internet-of-Things; and support for IPv6 are also
requirements.
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Question 7: Do you agree or disagree that a State-led intervention network deployment should
demonstrate at least all of the characteristics as set out in this document to qualify as a NGA
network? Please provide supporting information in your answer.
eircom agrees that a State-Led Intervention network deployment should demonstrate the
characteristics described. However eircom would go one step further and include the characteristic
of future-proofing. The need for broadband communications will in all likelihood speed up in the
future and, thus, become even more important and potentially also more disruptive than today.
Indeed, demand for capacity-intensive services is expected to increase in the future, as cloud
computing, a more intense use of peer-to-peer technologies, social networks and video on demand
services develop further. With that in mind, the technology must be future-proofed in terms of
performance and upgradability, its physical lifetime must be long (more than 40 years at a
minimum), catering for the growing demand for digital services. Including this additional
characteristic ensures that a State-Led Intervention with regard to broadband infrastructure would
not need to be revisited
eircom would agree in principle with the listed characteristics however with the following additional
comments:
Step Change
Upgrading from Basic Broadband ADSL / ADSL2+ to VDSL is a step change as it enables customers to
move from speeds of up to 24 Mbps (under ADSL2+) to speeds of up to 70 Mbps. The addition of
Vectoring technology at a cabinet enables a significant speed increase to up to 100 Mbps.
Reliability and Quality
eircom is of the view that reliability and quality are key characteristics of an NGA broadband service.
Downlink and uplink speeds, no congestion, low latency with high availability are all required to
deliver a service of high quality.
Reliability in the sense of delivering a quality service consistently is also a requirement.
Download Speed
Download speed is key characteristic for an NGA broadband service in order to support applications
such as high- definition video stream.
Upload Speed
Upload speed is key characteristic for an NGA broadband service in order to support applications
such as cloud-based storage, cloud-based applications, file sharing, interactive gaming, video
conferencing and video uploading.
October 2014
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eircom suggests that NGA technology should offer at least 3 to 5 times more upload speed than
existing Basic Broadband technology to deliver a significant improvement to the customer
experience.
Reliance on optical or equivalent technologies
All of the technical solutions available for delivering NGA broadband depend on optical technologies.
Even mobile solutions are using an increasing amount of fibre to backhaul base stations in order to
support mobile broadband services.
Support a variety of advanced digital services including converged all-IP
services
eircom agrees that NGA Broadband networks must be capable of supporting advanced digital
services.
Affordability
eircom agrees that any Government intervention should have the objective of ensuring delivery of
affordable services to customers within the target area. This would encourage service adoption and
also ensure that the primary policy concern of eliminating the digital divide is met. The definition
and agreement of affordability is key.
Future-proofing
eircom would also include future-proofing (in terms of easy expansion to cater for the anticipated
growth in broadband usage; Internet of Things (IoT); IPv6 and other, as-yet unknown, demands) as a
key determinant of NGA Broadband. An intervention such as the NBIP will put in place an asset
which will help determine the country’s economic and social future, deliver a solution to the digital
divide in Ireland and position Ireland as a leader in an increasingly information-driven global
economy. Employment will also result over several years; NGA services are a crucial location factor
when attracting and securing jobs in both rural and urban areas. An increase in education and skills
plus significant benefits will result in the quality of life resulting from teleworking, as well as in areas
such as e-health.
eircom is of the view that longevity in terms of bandwidth scalability and future-proofing is an
important characteristic. Any NGA broadband technology should be able to cater for increases in
speed and throughput per user driven by applications such as video-conferencing and high-definition
video streaming without significant service disruption or technology changes. Features such as
quality of service and multicast capability to allow the effective delivery of video and voice services;
capacity to cater for growth such as the Internet-of-Things; and support for IPv6 are also
requirements.
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Question 8: Do you agree or disagree with the decision process that has been applied to identify
potential areas for the State-Led intervention? Please provide supporting information in your
answer.
eircom agrees with the decision process steps as outlined in section 3.6. with the qualification that
it would be inappropriate to overbuild on commercially deployed infrastructure in Grey areas.
Additionally, in classifying proposed and existing services, eircom suggests that DCENR should
make provisions to adapt the intervention footprint to reflect evolving rollout plans of the
operators. Technology developments and reduction in infrastructure costs will enable operators to
extend beyond what they forecast in 2014. eircom also suggests prioritising deployment to the
extent practical on an ‘outside-in’ basis: this will ensure that those in most need of intervention are served first and cater for the possibility that high-quality Basic Broadband areas that are marginally
economic to serve commercially may be upgraded based on commercially viable means, reducing
the need for intervention.
DCENR has outlined four key steps to identifying potential areas for the State-Led Intervention as:
Classify existing services as NGA broadband services and Basic Broadband services
Classify proposed services as NGA broadband services and Basic Broadband services
Apply the Black, Grey and White definitions outlined in the SAG
The resulting White NGA and Grey NGA areas are currently considered potential intervention
areas.
eircom agrees with the steps of the process as outlined, and broadly agrees with the definitions as
outlined in the SAG. However, in our experience there are areas of further consideration that the
Department would benefit from assessing in advance, to ensure the most cost-effective and timeappropriate delivery.
In relation to Grey Areas
While the SAG guidelines make provision for potential intervention in Grey areas, eircom suggests
this would be inappropriate in Ireland’s case for the following reasons:
Overbuilding on this commercially deployed infrastructure that is already subject to market
protecting sectoral remedies would undermine eircom’s commercial deployment in a
situation where market failure does not exist and where it is unnecessary.
Ireland is already challenged by its low-density demographics, and the anticipated
Government intervention is likely to require significant investment by the State.
Sectoral regulations that apply nationally already act as a surrogate for infrastructural
competition in eircom’s commercially deployed NGA network and are directed at ensuring that competition is supported.
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In relation to services currently offered
SAG’s characteristics of NGA broadband, as summarised in section 3.5.3 of DCENR’s document, references DAE objectives for 2020 that (i) all Europeans have access to much higher Internet access
speeds of 30 Mbps and 50% or more of European households subscribe to Internet connection
above 100 Mbps.
Assuming the minimum of 30 Mbps is used for the intervention footprint, eircom feels such a
specific intervention boundary could potentially lead to State funding displacing high-quality Basic
Broadband that may well be upgraded to NGA on a commercial basis within the rollout timeframe of
an NBIP intervention. This could occur where eircom, or other operators, find ways through
technological developments or through falling equipment prices to improve broadband speeds and
to extend beyond what they were in a position to indicate in 2014.
It is important that the intervention footprint not overlap the commercial footprint, as described
above. To avoid such a situation, eircom suggests the Department consider prioritising towards the
most deprived areas, and that a ‘guard band’ should be adopted in specifying the intervention footprint.
The commercial footprint could be thought of as having two elements: the expected commercial
footprint as indicated by operators and the potential commercial footprint. Operators have already
provided an expected commercial footprint over a 3-year horizon; these projections may age quickly
as technology developments make it increasingly likely that the commercial footprint will extend.
For planning purposes with regards to NBIP we must therefore look also at the potential commercial
footprint, which we are calling the ‘guard band’. The guard band would be a no-go area for
intervention and for the purposes of planning would extend the boundaries of the commercial
footprint beyond that within which operators expect to deploy 30 Mbps NGA services.
The guard band area would act as an added buffer protecting against the undesirable situation
whereby State funds would be unnecessarily spent in an area that may benefit from commercial
deployment. Additional safeguards could be incorporated to ensure that sites within the guard band
don't fall between the cracks: for example if guard band areas do not benefit from commercial NGA
deployment within, say, two years of NBIP rollout commencement, the intervention area could be
extended into the guard band.
In relation to services planned
While eircom agrees in principle with the process described, we are concerned with the time horizon
over which this process would be applied.
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The Mapping Exercise commenced in mid-2013 and respondents were asked to indicate commercial
plans out to end June 2016, i.e. over a 3-year horizon as defined as ‘near future’ in the SAG. Updates to the mapping submissions have been requested for mid-2014. With all the appropriate
consultation, approval and procurement stages expected for the State-Led Intervention, there is
potential that the rollout of the intervention will commence at the far end of the projected
timeframe provided in the commercial plans.
Commercial organisations have provided, to the best of their ability, a view on commercial rollout
over 3 years. eircom suggests the Department should give consideration to the likelihood that
technological developments, and further potential reductions in infrastructure costs may enable
30 Mbps, therefore commercial footprints may grow beyond what commercial organisations are in a
position to submit to DCENR as committed plans in September 2014.
Another consideration is that State-Led Intervention should be prioritised in the most deprived
areas, if possible, rather than in areas that have reasonably good broadband and which are most
likely to benefit from further 30 Mbps commercial NGA footprint extension.
These considerations suggest that a concept of a ‘guard band’ should be considered to be included in areas expected to be commercially deployed.
October 2014
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Question 9: Do you agree or disagree with the principle of establishing contracts for committed
rollout in order to secure the delivery of planned rollouts of NGA broadband services? Please
provide supporting information and examples where appropriate.
eircom agrees with the principle subject to (i) the reasonableness of evidence that could be
provided for rollouts that would extend over a 3 year horizon, (ii) the reasonableness of
contractual remedies that would be sought, and (iii) flexibility for operators to respond to changes
in anticipated market conditions . In addition the sequence of events is key to an agreement of
reasonable commitments.
Clarity of Intervention Footprint
The input to the mapping exercise has been completed based on an informed view of the definition
of NGA services. For example, eircom has provided information on the projected footprint of its
services specifically where it intends to make services of 30 Mbps available. If the current mapping
exercise input is accepted, eircom would not have a difficulty in contractually committing to it.
However, the exact specification of the NGA services awaits the completion of this Call for Inputs
consultation. If the final footprint of the intervention area is based on a revised service definition
that overlaps into eircom’s intended investment – based on a higher speed requirement – eircom
would need to revisit its planned investment. In this context the issue of the NBIP displacing eircom’s investment needs to be considered i.e. areas where eircom has an NGA investment programme
which does not supply 30 Mbps to every premise in a specific locality but intends to do so over a
period of time. The SAG acknowledges this issue when it refers to “significant progress in terms of coverage” (not complete coverage) will be made within the 3-year period. Any contractual
commitment would need to reflect this evolutionary nature of the service.
Credible Business Plan
It is reasonable to expect that a credible business plan should be available to demonstrate an
operator’s rollout intentions. Such plans would be expected to be directional over a 3-year horizon,
and should be demonstrable in medium-term plans. Within a budget year horizon, plans would be
expected to be underpinned by budgetary provisions.
Board Approval
Board approvals should be available for strategic directions that have been adopted, for example in
a 3 or 5 year outlook that would typically be updated as part of an annual planning cycle.
Within a budget year, budgetary provisions that would include capital investment should be
available.
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Flexibility to Respond to Market Conditions
When an operator provides long-term forward-looking information on expected NGA deployment,
provision must be included for flexibility to respond to market conditions. For example, if NGA
rollout into a particular footprint is based on the number of competing infrastructures that exist in
that footprint, and subsequently another operator succeeds in rolling out into that footprint, then
provision should be included for the operator to modify its rollout plans.
Bank Agreements
Rollouts may be funded from internal cash generation and so rather than a bank agreement,
projected cash flows may be an appropriate way to demonstrate financial capacity to underpin
planned rollouts.
Where new funding is likely to be required over a 3-year horizon, appropriate bank agreements may
be in the form of covenants that would demonstrate provision for capital investment.
Planning Applications
Planning applications would typically be sought about 3 to 6 months in advance.
Deployment Plans
Deployment plans would typically be available over a 6-month horizon.
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Question 10: Do you agree or disagree with the proposed definition for a step change as set out
above? Can you please propose amendments to the definition and provide supporting information
as appropriate.
eircom agrees with DCENR’s definition of a step change outlined in 4.2.2.2, subject to clarification
of the definitions of level of service and customer experience.
In section 4.2.2.2 of the NBIP Call for Input, a definition of a step change is proposed as:
A ‘step change’ for an end user has occurred where:a NGA broadband network (as outlined in section 3.5 of this document) is introduced;
and
a substantially higher level of service and customer experience relative to what exists
today is introduced
We note that ‘level of service’ and ‘customer experience’ have not been defined and so there is a risk
of ambiguity in what is intended in the proposed definition of ‘step change’
In eircom's experience “step change” is in the eyes of the beholder. Increases in bandwidth availability throughout the world spur entrepreneurs to create bandwidth-hungry applications that
quickly become a must-have, causing consumer perceptions of "how good their broadband is" to
evolve rapidly and ruthlessly. Already an application called Twitch TV, which is a live streaming
service where video gamers watch each other play, has established itself above that of HBO Go
within the US, and is now rated as one of the top 15 application globally. With that in mind it is
important to implement an infrastructure that delivers an initial ‘step change’ but also an infrastructure that allows for growth for many years to come.
eircom already has experience in delivering a number of step changes. The evolution of our
technology has brought us from Basic Broadband delivering speeds of 5 Mbps to NGA delivering
speeds up to 70 Mbps to vectoring which has increased our speeds to 100 Mbps.
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Question 11: What metrics do you believe are the most appropriate to measure the reliability of a
NGA service? Please provide supporting information with your response.
Service reliability is defined as the persistence of quality over time and must relate to the user
experience.
MTBF and MTTR, mentioned in the preamble to this question (4.2.2.3), relate to the failure and
repair times for hardware elements rather than user experience and are not appropriate measures
for service reliability.
The most appropriate metrics to measure NGA service reliability are a combination of service
quality metrics and service availability metrics. The service quality metrics relate directly to the
end-user experience of the Retail Service Provider (RSP) NGA service and relate indirectly to enduser experience of the WSP service inputs. It is assumed that SLAs will be in place between the RSP
and the WSP to ensure network performance targets are met.
The most appropriate service quality metrics are a) packet loss, b) latency, c) download speed,
d) upload speed and e) link utilisation. The most appropriate service availability metrics are a)
customer service fault reports to the RSP, b) WSP network availability figures and c) RSP network
availability figures.
The eircom target for link utilisation is less than 80% utilisation. Appropriate values for the remaining
service quality metrics are detailed in the specific questions relating to speed, latency and packet
loss. cf. responses to Q12, Q13, Q19, Q20, Q21, Q26, Q27.
eircom’s view on the most appropriate service quality metrics is borne out by international studies on broadband performance. For example, the metrics used in studies completed by SamKnows (for
clients including Ofcom, FCC and the European Commission) are packet loss, latency, download
speed and upload speed. SamKnows also reports on the service quality metrics for three specific
applications; Web browsing, VoIP and DNS resolution.
Service reliability is defined as the persistence of quality over time and must relate to the user
experience.
The end user experience depends on the performance of each of the individual networks in the
chain of networks (home network---access network ----IP Transport network----ISP network) involved
in delivering the broadband service. The Retail Service provider (RSP) would have to have SLAs in
place with WSPs to ensure network performance targets are met.
October 2014
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The most appropriate metrics to measure NGA service reliability are a combination of service quality
metrics and service availability metrics. The service quality metrics relate directly to the end-user
experience of the RSP NGA service and relate indirectly to end-user experience of the WSP service
inputs. SLAs are in place between the RSP and the WSP to ensure network performance targets are
met. The most appropriate service quality metrics are:
packet loss,
latency,
download speed,
upload speed, and
link utilisation.
The most appropriate service availability metrics are:
customer service fault reports to the RSP,
WSP network availability figures, and
RSP network availability figures.
Customer service fault reports directly reflect the user experience. The user report, once analysed,
points to the source of the service fault which may be in the home, access, IP transport or RSP
network.
The eircom target for link utilisation is less than 80% utilisation. Appropriate values for the remaining
service quality metrics are detailed in the specific questions relating to speed, latency and packet
loss. cf. responses to Q12, Q13, Q19, Q20, Q21, Q26, Q27.
eircom’s view on the most appropriate service quality metrics is borne out by international studies
on broadband performance. For example, the metrics used in studies completed by SamKnows (for
clients including Ofcom, FCC and the European Commission) are packet loss, latency, download
speed and upload speed. SamKnows also reports on the service quality metrics for three specific
applications; Web browsing, VoIP and DNS resolution.
Service reliability for a new service can degrade over time if the network is not capacity managed.
An increase in the number of users on a network element can lead to increased contention on the
backhaul and in some technology solutions, increased contention on the access channel. Congestion
leads to degraded service quality. eircom capacity manages the broadband network by monitoring
link utilisation on backhaul and IP transport links. Links that exceed the threshold of 80% utilisation
are upgraded.
MTBF and MTTR, mentioned in the preamble to this question (4.2.2.3), relate to the failure and
repair times for hardware elements rather than user experience and are not appropriate measures
for service reliability. Network availability is not the same as service reliability. For example the
failure of a network element that is backed up by a load-sharing or redundant network element is
unlikely to have any impact on the service. Similarly, faults that occur outside of the busy hour will
impact the service of fewer customers than faults that occur during the busy hour.
October 2014
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Question 12: Do you agree or disagree that packet loss and mean one-way latency are optimum
metrics to determine the quality of an NGA service? Please provide supporting information with
your response.
Packet loss and latency are necessary measurements of quality but we also need to measure
upload and download speeds to determine the overall quality of a broadband service.
Packet loss and latency are necessary measurements to determine service quality but they are not
sufficient on their own. We also need to consider download and upload speeds. A service that offers
zero packet loss and low latency could not be described as high quality if the bandwidth available to
the customer is prone to fluctuation and service-affecting decreases.
Packet loss has a significant negative impact on the quality of service that an NGA user will
experience and will impact a user’s perception of web browsing, video streaming and other applications.
Latency or delay is also an important metric for measuring the quality of an NGA service. A web
browser accessing a single content-rich web page can typically make well over 100 TCP connections
in order to fully load the page. Once the basic HTML is downloaded, there are multiple requests for
images and scripts that make up the page. The scripts may be used for advertising, analytics or
tracking purposes. These, in turn, initiate more requests. The bandwidth requirements may be
modest, but the repeated HTTP requests in quick succession mean that the latency of the
connection will play a large part in the speed at which the page renders.
Latency is also critically important for online gaming. Small differences in the latency experienced
between players can make large differences to game play. And in situations where latency has
increased above normal expected levels, a game can become effectively unplayable.
VoIP calls are also impacted by high latency which results in noticeable long pauses between the two
sides of a conversation which greatly affects the user’s perception of the service.
The impact that latency has on customer experience is heavily dependent on the application. While
a gamer requires minimal bandwidth, low latency is essential. Streaming video, on the other hand,
requires adequate bandwidth but increases in latency can go unnoticed.
To get a complete picture of the quality of an NGA broadband service, the latency and packet loss
along with upload and download speeds of the connection must be measured.
October 2014
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Question 13: Do you agree or disagree that download speed and upload speed are the optimum
criteria to measure speed? Please provide supporting information to your response
Download speed and upload speed are necessary measurements of quality but we also need to
measure packet loss and latency to determine the overall quality of a broadband service.
Download and upload speed are key criteria to measure service speed but latency and packet loss
must also be considered.
A service that provides high bandwidth but with high latency such as satellite links may provide fast
bulk data transfer for downloading files but would appear extremely slow when browsing media-rich
web pages where many small transactions are required in quick succession. Equally, a link that
offered high bandwidth but moderate packet loss might support the streaming of a video file (given
large enough buffers), but would offer very poor performance on live interactive voice or video
conferencing services.
High download speeds are required for streaming high definition video and for large file transfers
generally. With the advent of cloud computing upload speeds have become more important and this
trend will continue. Upload speed is also important for video conferencing and for users who want
to host information on their own premises such as small web servers or family music/photo/video
archives.
Actual measurements of download and upload speeds are better reflections of the delivered service
speeds than quoted headline technology speeds because actual field conditions impact the speeds
achieved in practice.
October 2014
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Question 14: What is your view on the requirement for optical (or equivalent) technology for data
backhaul. Do you agree or disagree that optical (or equivalent) technology will provide the
optimum backhaul solution to achieve the objectives of the state-led intervention under the NBP?
Please provide supporting information with your response.
eircom agrees that optical technology will provide the optimum data backhaul solution. We
recognise that in a small number of exceptional cases it may not be feasible to provide end-to-end
optical connectivity. In these cases radio backhaul technologies may be appropriate to provide a
solution equivalent to the lower end of the capability of optical technology.
We believe that optical technology will provide the best data backhaul solution. All of the candidate
technologies for delivering high-speed broadband make use of optical backhaul but microwave radio
may have a role to play for a small number of remote or hard-to-reach sites.
GPON technology is entirely fibre based, with passive splitters connected to Optical Line Terminals
which then connect to the operator’s IP network using, normally, 10 Gbps links on fibre.
Point-to-point fibre access solutions are also entirely fibre based, with the access fibres being
aggregated on an IP or Ethernet device and then backhauled to the operator’s IP network over fibre.
FTTDP solutions use mini-DSLAMs (with 1 to 48 ports) which are backhauled to an aggregation point
using fibre, which could be GPON based or gigabit Ethernet on dedicated fibre.
VDSL DSLAMs are also normally connected via fibre to an aggregation point, typically using gigabit
Ethernet on fibre.
DOCSIS hybrid-fibre-coax systems are also dependent on fibre backhaul, although it is unlikely that
an operator would install co-axial cable in a green field situation.
Mobile networks today are using an increasing amount of fibre to connect base stations as the
capacity of microwave backhaul is not sufficient to support mobile broadband traffic, particularly for
larger sites. However microwave still plays a role for small and remote sites.
In addition to providing backhaul for mobile base stations, microwave backhaul can be used, in
theory, to backhaul VDSL or indeed G.fast DSLAMs.
The best microwave solutions today can deliver a speed of ~500 Mbps and E-band radio can deliver
speeds of ~2 Gbps reliably for distances up to 2 km. Additionally multiple hops would be needed to
connect many hard to reach locations. The radio solutions would be suitable only for small sites that
are exceptionally hard to reach via fibre such as islands or very remote locations.
October 2014
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Question 15: How close is sufficiently close to user premises to guarantee the actual delivery of
the very high speed. Please provide examples.
eircom maintains that the high-capacity backhaul bearer should be fibre and that the connection to
the customer’s premises should be fibre wherever practical.
If the customer ‘drop’ uses optical fibre there is no practical distance limitation to the speeds that can be achieved. This approach guarantees the actual delivery of the very high speed with no
technical barrier to speed now or in the future.
The length of the customer drop connection is relevant where copper cable is used. In this case the
fibre backhaul and the access node must be brought as close to the customer as possible. In
general it is necessary to bring the fibre to within 1 km of all the customers in a served area to
guarantee the actual delivery of a 30 Mbps service using VDSL technology today. To increase the
speed beyond 30 Mbps the fibre would have to be brought closer again to the customer with the
highest speeds restricting distances to less than 250m.
eircom concludes that the high-capacity backhaul bearer should be fibre. Furthermore eircom
believes that the connection to the customer’s premises should, where practical, be fibre. FTTH brings fibre into the customer’s premises and guarantees the actual delivery of the very high speed
with no technical barrier to speed now or into the future.
The use of a copper or a wireless bearer to connect the customer’s premises requires that the fibre backhaul and the access node be brought close the customer. In general one would need to bring
the fibre to within 1 km of all the customers in a served area to guarantee the actual delivery of a
30 Mbps service today. As the need for speed increases beyond 30 Mbps, the fibre would have to be
brought closer again to the customer with the highest speeds restricting distances to less than
250 m.
While wireless technologies can deliver high peak speeds at distances greater than 1 km (see answer
to Question 2) there is a trade-off between coverage and capacity. The capacity constraint per
wireless site precludes the use of wireless to guarantee the delivery of very high speeds. While
wireless does not have the capacity to deliver the very high speeds that will be delivered over fibre,
it may have a role to play to deliver service to very remote locations such as islands or mountainous
regions.
Both copper and wireless access technologies will need to be continually upgraded to keep up with
the ever-increasing demands for high speeds and throughputs, while fibre technology has significant
headroom to cater for increasing demands. GPON technology can also be upgraded to 10GPON and
40GPON without changing the cable infrastructure.
October 2014
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Question 16a: Please provide details of:Current set of products and services being offered to NGA users in existing NGA areas.
The eircom product portfolio utilises two NGA platforms – FTTC and FTTH. The FTTC technology
utilises a VDSL DSLAM to provide high-speed broadband (up to 100 Mbps) over a copper
connection to a customer’s premises. eircom also utilises an FTTH GPON technology on a subset of
the NGA footprint to provide customers with speeds of 150 Mbps. eircom Wholesale sells NGA
Bitstream products provided over both FTTC and FTTH technologies under a product name of
Bitstream Plus, which is uncongested and includes features to enable QoS and Multicast on a
customer’s connection. These NGA products are made available to operators as either a POTS
Based variant (including an underlining PSTN line) or as a Standalone service.
eircom Wholesale currently has 15 operators interconnected into the eircom NGA network. These
operators can provision, create appointments and manage in-life customers through eircom’s Unified Gateway portal.
The eircom product portfolio utilises two NGA platforms – FTTC and FTTH. The FTTC technology
utilises a VDSL DSLAM located in street cabinets to provide high-speed broadband services over a
copper connection to a customer’s premises. Customers connected over FTTC can avail of speeds of up to 100 Mbps depending on the distance their premises are from the serving cabinet. eircom also
utilises an FTTH technology on a subset of the NGA footprint to provide customers with speeds of
150 Mbps. To date, the 150 Mbps profile has been limited to align with our distribution network but
the FTTH infrastructure is capable of significantly higher speeds. FTTH utilises a GPON technology to
connect customers on fibre from the local exchange to the customer’s premises. eircom Wholesale sells NGA Bitstream products provided over both FTTC and FTTH technologies
called Bitstream Plus. Bitstream Plus products provide an uncongested broadband service and
include additional features which are not available on existing eircom ADSL consumer type products.
These additional features include the ability to enable QoS and Multicast on a customer’s connection. There are three levels of QoS available – Best Efforts, Expedited Forwarding and Assured
Forwarding -- that allow operators to prioritise traffic to customers depending on the applications
being provisioned e.g. VOIP. The Multicast feature allows operators to inject a broadcast service into
the eircom NGA network (such as TV).
The Bitstream Plus product caters for operators who wish to interconnect into a single exchange and
utilise the eircom network to carry all their traffic to this point for the entire NGA footprint.
Operators have an alternative option instead of Bitstream Plus and can interconnect at every NGA
exchange and thereby utilise their own network to carry the traffic from the Access Network. This
variant is called VUA (Virtual Unbundled Access) and contains the same features as Bitstream Plus
except that operators will not be charged a usage element for carrying their traffic.
The NGA products are made available to operators as either a POTS Based variant (requires an
underlining PSTN line) or as a Standalone service.
October 2014
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Question 16b: Please provide details of:Plans for new products and services which may be offered over NGA networks.
eircom Wholesale has a number of new products and services under development. Key
developments include a new variant of Bitstream which focuses on business type customers. In
addition, eircom has proposed to industry that an E-VDSL technology should be deployed in the
eircom network which will allow the NGA footprint to expand. Node level vectoring is also due to
be deployed in the NGA network which will expand the reach of customers that can achieve
100 Mbps. A new operating model is also due to be rolled out which will provide customers with
the option of having evening and weekend appointments for provision of services. And finally a
new variant of FTTH is due to be piloted.
eircom Wholesale has a number of new products and services currently under development. These
requests for product changes can originate from a number of sources including from operators at
the industry fora we attend, and also internally to improve operational efficiencies. There is an
interactive process in place whereby eircom Wholesale communicates with operators throughout
the full development life cycle to ensure the development is integrated as per the needs of the
requestor. Initial requests are normally analysed by eircom Wholesale and potential solutions are
presented to industry. Once a consensus is agreed requests are then translated into a detailed
process and systems development specification including timelines for development. Throughout
the integration cycle, we incorporate feedback from operators to maximise the business benefit of
the development. These developments are contained on the eircom Wholesale Development NGA
Roadmap which we update and present to industry every two weeks. Presently at any given time
there are in excess of 30 development requests open at any one time on the NGA Roadmap. A
subset of these requests are summarised below:
VDSL Ethernet Access (VEA) – is a business type product that allows operators create a
virtual dedicated pipe on their customer’s circuit. In addition, operators will be able to add CVLAN tags to their traffic which can be utilised in a wide range of business applications.
Exchanged Launched VDSL (E-VDSL) – eircom has proposed to industry that E-VDSL
technology should be deployed in the eircom network. E-VDSL allows the VDSL DSLAM to be
located in the exchange rather than in a street cabinet. This technology will be utilised to
allow customers that are currently direct fed from an exchange (rather than served via a
copper cabinet) to avail of an NGA product.
Node Level Vectoring – this is a technology being developed which allows Vectoring to be
deployed in two DSLAMs in a single cabinet. Vectoring itself has already been successfully
deployed in over 80% of the eircom network: this functionality allows customers on FTTC to
obtain speeds of 100 Mbps instead of up to 70 Mbps in non-vectoring cabinets. The nonvectoring cabinets in the eircom network are cabinets that currently or are likely to require a
second DSLAM due to demand. Dual DSLAM cabinets require the node level vectoring
technology to deploy the vectoring for this subset of customers.
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Out-of-Hours Delivery – the existing NGA provisioning processes where our customer
appointment is required are delivered during normal working hours. The Out-of-Hours
Delivery functionality will allow NGA services to be delivered in the evening and at
weekends.
New FTTH – a new FTTH variant is due to be piloted in the eircom Network in Belcarra
County Mayo. This variant is expected to significantly increase speeds over existing NGA
wholesale products.
October 2014
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Question 17: Do you agree or disagree that affordability should be a defining characteristic of an
NGA service? Please provide supporting information with your response.
eircom agrees that any Government intervention should have the objective of ensuring delivery of
affordable services to customers within the target area. This would encourage service adoption
and also ensure that the primary policy concern of eliminating the digital divide is met. The
definition and agreement of affordability is key.
In the current Universal Services regulatory framework, affordability is ensured through an
obligation (on eircom) to charge uniform retail access charges on a nationwide basis and not to
recover the full connection costs either in part or in full through high connection fees. This means
that affordability is delivered in general through application of the same prices in the noncommercial areas of the market (as defined by the USO footprint) as those prices in the commercial
areas of the market.
This principle seems to be a corner-stone of the approach promoted in the State Aid Guidelines for
high-speed broadband and has also been implemented in State Aid projects in the recent past. State
Aid seems to ensure that the investment for the network provider meets commercial return criteria
as if it was an investment in the competitive commercial market. The Guidelines and practice to date
suggest that affordability should be defined in general as prices that reflect those prices for similar
NGA services provided by the competitive market in commercial non-intervention areas.
While this seems to be a logical approach it does raise related issues.
For example, if the intervention is to be as efficient as possible, thus minimising the amount of State
Aid, the price paid by users should be as high as possible, while still being affordable.
In addition, in a competitive market, what is the real cost of broadband when it is sold as part of a
bundle that is calibrated differently among various offers? Most operators sell bundles of
Broadband, Voice service, TV and even mobile. Consider that a customer might be able to buy TV
and Broadband for €48 monthly, or TV alone for €29. Is broadband really only €19? The reality is that
a broadband-only offer is likely to cost €35-€40: because all the services share the cost of the common infrastructure, any service on its own must cover the cost, and any additional service in a
bundle has a low incremental cost. One also has to have regard to price differentiation (e.g. offers
with unlimited downloads, and offers with low download limits, at different prices).
Affordability has also been interpreted at times as requiring that average bills, or the bills of certain
users (e.g. the lower quartile, i.e. the 25% with least call volumes), must not increase faster than
inflation. How will affordability be ensured for a customer who may have a high-speed bandwidth
connection but will never require broadband? In a market of bundled services, this approach may
not be feasible given the difficulty of defining the average bill which historically was a rental and
calls-only bill.
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A further challenge on affordability is the need to ensure that genuinely vulnerable users are
assisted in taking up the retail services. As in the legacy USO regime, the retail providers are allowed
to target this customer cohort, subject to eligibility criteria, with special tariffs that are approved in
advance by ComReg. For example, workers earning a good salary might consider €50 monthly to be
affordable, whereas an unemployed job seeker or a retired pensioner might consider anything over
€20 unaffordable. A standard fixed price of €30 might only achieve the same low take-up as a €50 price, but require a higher subsidy. Offering two alternatives, at €50 and €20 might be affordable for everyone and require far less subsidy.
October 2014
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Question 18: The Department would welcome inputs on the definition of the download speed
parameter and the viability of the minimum threshold value that is set out in Table 8.
eircom agrees with the specification of download speed, but notes that this requires specification
of the applicable data load that is a function of the anticipated number of concurrent customers
and the anticipated data load per customer. Consequently it will be necessary to specify these
design parameters.
In section 4.2.3.1, NGA performance thresholds are proposed and input has been sought on the
proposed definitions and on their viability.
As noted in the Call for Input, paragraph 57 of the SAG states:
“(57) At the current stage of market and technological development, NGA networks are access networks which rely wholly or partially on optical elements and which are
capable of delivering broadband access services with enhanced characteristics as
compared to existing basic broadband networks.”
Subject to being engineered to conform to the SAG requirements, FTTH, FTTC, and Advanced LTE are
potential contenders for the NBIP. FTTH and FTTC can be engineered to meet the proposed
minimum performance thresholds, with Advanced LTE potentially being able to do so also.
The key challenge is to determine viability, and this unavoidably has to lay heavy emphasis on
considerations such as cost and ability to sustain evolving customer needs in a digital society and
economy.
Consequently, it is necessary to provide comments against the three likely candidate technologies.
Download Speed NGA Performance threshold> 30 Mbps
FTTH
FTTC
October 2014
Viability
Can readily support the minimum
threshold and is also likely to offer the
most cost effective solution in lowdensity NBP areas.
Future Evolution
Readily supports evolution to
increasingly higher download speeds,
without revisiting the cable
infrastructure.
Can readily support the minimum
threshold but would require fibre to be
driven to within 1 km of the most
distant customer and so is likely to be
less cost effective than FTTH in lowdensity NBP areas.
Can support evolution to increasing
download speeds, although cost
challenges would arise, if for example,
new mini-VDSL units had to be
installed closer to customer premises.
46
LTE Advanced
Viability
Future Evolution
Compared to an FTTH or FTTC solution,
it would likely be far more expensive
to design an LTE Advanced network to
support 30 Mbps and the associated
high data throughput requirements
from homes and business premises
during busy hour.
Can support evolution to increasing
download speeds, although significant
cost challenges would arise, if for
example, a larger number of smaller
cells had to be introduced.
eircom agrees with the above description of a download performance threshold, but notes that this
requires specification of the load that is a function of the anticipated number of concurrent
customers and the anticipated data load per customer. Consequently it will be necessary for DCENR
to specify these design parameters.
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Question 19: The Department would welcome inputs on the definition of the upload speed
parameter and the viability of the minimum threshold value that is set out in Table 8.
eircom agrees with the specification of upload speed, but notes that this requires specification of
the applicable data load that is a function of the anticipated number of concurrent customers and
the anticipated data load per customer. Consequently it will be necessary to specify these design
parameters.
In section 4.2.3.2, NGA performance thresholds are proposed and input has been sought on the
proposed definitions and on their viability.
As noted in the Call for Input, paragraph 57 of the SAG states:
“(57) At the current stage of market and technological development, NGA networks are
access networks which rely wholly or partially on optical elements and which are
capable of delivering broadband access services with enhanced characteristics as
compared to existing basic broadband networks.”
Subject to being engineered to conform to the SAG requirements, FTTH, FTTC, and Advanced LTE are
potential contenders for the NBP. FTTH and FTTC can be engineered to meet the proposed minimum
performance thresholds, with Advanced LTE potentially being able to do so also.
The key challenge is to determine viability, and this unavoidably lays heavy emphasis on
considerations such as cost and ability to sustain evolving customer needs in a digital society and
economy.
Consequently, it is necessary to provide comments against the three likely candidate technologies.
Upload Speed NGA Performance threshold>10 Mbps
FTTH
FTTC
October 2014
Viability
Can readily support the minimum
threshold and is also likely to offer the
most cost effective solution in lowdensity NBP areas.
Future Evolution
Readily supports evolution to
increasingly higher upload speeds,
without revisiting the cable
infrastructure.
Can readily support the minimum
threshold but would require fibre to be
driven to within 1 km of the most
distant customer and so is likely to be
less cost effective than FTTH in lowdensity NBP areas.
Can support evolution to increasing
download speeds, although cost
challenges would arise, if for example,
new mini-VDSL units had to be
installed closer to customer premises.
48
Viability
LTE Advanced
Compared to an FTTH or FTTC solution,
it would likely be far more expensive
to design an LTE Advanced network to
support 10 Mbps and the associated
high data throughput requirements
from homes and business premises,
and during busy hour for all customers
who would be active simultaneously.
Future Evolution
Can support evolution to increasing
upload speeds, although significant
cost challenges would arise, if for
example, a larger number of smaller
cells had to be introduced.
eircom agrees with the above description of a download performance threshold, but notes that this
requires specification of the load that is a function of the anticipated number of concurrent
customers and the anticipated data load per customer. Consequently it will be necessary for DCENR
to specify these design parameters.
October 2014
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Question 20 (a): The Department would welcome inputs on the definition of the mean one-way
latency parameter and the viability of the minimum threshold value that is set out in Table 8
When measuring latency, eircom favours round trip times over mean one-way figures. We believe
that a round-trip time target of 30ms is viable for an NGA broadband service.
eircom believes using round-trip latency is a more useful measurement than one-way latency. The
difficulty with one-way latency is that it is not easy to measure reliably. While a single device can
initiate a round-trip time measurement, gathering one-way latency figures requires that both
devices involved in the measurement are synchronised which can be difficult to achieve in a packet
switched network. Almost all services on the Internet today require two-way communication. The
round-trip measurement is therefore a well-established key performance indicator and tools to
measure round-trip times are widely available (Internet Control Message Protocol echo
request/reply or ‘ping’ tests).
One-way latency figures are of limited use in isolation. One-way latency figures must be measured
for both directions on a link to assess its performance and these two one-way measurements
comprise a round-trip measurement. However, one-way latency figures can be useful when
troubleshooting a circuit where there is a problem that is asymmetric in nature.
A threshold value of 40ms for round-trip times as stated in Table 8 of the CFI document is certainly
viable, but eircom believe is a more acceptable figure for next-generation broadband access to the
Retail Service provider (RSP) within Ireland. It is important to note that this figure of 30ms is
dependent on how far into the network the service is tested. See part (b) below for some discussion
on this aspect.
While some access technologies can offer RTT times as low as 2-3ms, eircom engineers have found
that this figure can increase to approximately 20ms depending on the exact configuration used e.g.
with the use of interleaving for error correction. Because there is scope for intermediate routers and
end hosts to add to the latency of the end-to-end path, an upper round-trip time threshold of 30ms
should cover normal expected operation for NGA installations.
October 2014
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The following figure shows latency for different technologies as measured across Europe using the
SamKnows system and supports our view that a target figure of 30ms is viable.
Figure 7 Peak and 24-hour latency by technology (lower is better)
(from Quality of Broadband Services in the EU, Final Report, October 2013:
http://ec.europa.eu/digital-agenda/en/news/quality-broadband-services-eu-samknows-study-internetspeeds-second-report)
October 2014
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Question 20 (b): The Department would welcome inputs on the points in the networks which
would act as origination and destination points
To measure performance of the RSP’s service the origin point should be a dedicated test probe located at the customer’s residential gateway. The destination point should be close to the
broadband network gateway on the RSP’s network. The performance of the WSP network can be measured between the access node and the handover point to the RSP.
The response to this question needs to be understood in the context of the answers to Q26 and Q27
which outline how a performance management system could be implemented.
To measure the performance of the RSP service, we would use a test probe at the customer’s RGW (Residential Gateway) and a test responder at the BNG (Broadband Network Gateway) on the RSP
network.
If it is necessary to measure the overall performance of an RSP’s service there should be multiple
destination points for tests in the RSP network and beyond. These should be placed progressively
further away from the BNG which is the origination point of the customer’s IP service on the RSP network. The destination points depend on the structure of the RSP’s network, but we would suggest that these destination points could be 1) at the BNG on the RSP network, 2) at INEX where
the RSP’s network connects to other Irish networks, 3) at LINX or a large UK site where the RSP’s network connects to the wider Internet, 4) at a large EU site to represent the performance to other
European networks and 5) at a large US site to represent the performance to networks in the US.
To measure performance on the WSP network, we would connect a test probe to a dedicated port
on a representative sample of access nodes at the edge of the WSP’s network, which in the case of
GPON would be the OLT and in the case of VDSL it would be the DSLAM node. We would place a test
responder at the handover point to the RSP’s network. October 2014
52
Question 21 (a): The Department would welcome inputs on the definition of the packet loss
parameter and the viability of the minimum threshold value that is set out in Table 8
Packet loss significantly impacts TCP performance. The maximum threshold should be 1%.
eircom agrees that a packet loss of 1% is viable for a broadband service with modern access and core
networks. Measuring packet loss to sites outside of the local provider network may incur packet loss
greater than 1%, however this may be due to loss beyond the control of the local service provider.
The following figure shows packet loss for different technologies as measured across Europe using
the SamKnows system and supports our view that a target figure of 1% is viable.
Figure 8 Peak and 24-hour packet loss by technology (lower is better)
(from Quality of Broadband Services in the EU, Final Report, October 2013:
http://ec.europa.eu/digital-agenda/en/news/quality-broadband-services-eu-samknows-study-internetspeeds-second-report)
Packet loss has a significant negative impact on the quality of service that an NGA user will
experience. In practice, packet loss is often concealed behind multiple applications and multiple TCP
(Transmission Control Protocol) sessions within those applications. Large buffers when streaming
media can also make packet loss effectively invisible if the bandwidth requirements of the stream
are modest. Also note that TCP behaves differently than UDP. Applications using UDP may be able to
tolerate packet loss better than TCP.
October 2014
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Question 21 (b): The Department would welcome inputs on the points in the network which would
act as origination and destination points
To measure performance of the RSP’s service the origin point should be a dedicated test probe
located at the customer’s RGW. The destination point should be close to the BNG on the RSP’s network. The performance of the WSP network can be measured between the access node and the
handover point to the RSP.
The response to this question needs to be understood in the context of the answer to Q26 and Q27
which outline how a performance management system could be implemented.
To measure the performance of the RSP service, we would use a test probe at the customer’s RGW (Residential Gateway) and a test responder at the BNG (Broadband Network Gateway) on the RSP
network.
If it is necessary to measure the overall performance of RSP’s service, there should be multiple
destination points for tests in the RSP network and beyond. These should be placed progressively
further away from the BNG which is the origination point of the customer’s IP service on the RSP network. The destination points depend on the structure of the RSP’s network, but we would suggest that these destination points could be 1) at the BNG on the RSP network, 2) at INEX where
the RSP’s network connects to other Irish networks, 3) at LINX or a large UK site where the RSP’s network connects to the wider Internet, 4) at a large EU site to represent the performance to other
European networks and 5) at a large US site to represent the performance to networks in the US.
To measure performance on the WSP network, we would connect a test probe to a dedicated port
on a representative sample of access nodes at the edge of the WSP’s network, which in the case of GPON would be the OLT and in the case of VDSL the DSLAM node. We would place a test responder
at the handover point to the RSP’s network. October 2014
54
Question 22: Do you agree or disagree with the specification of these supporting definitions and
principles? Please provide supporting information with your response
eircom agrees with the specification of the supporting definitions and principles
eircom agrees with the specification of the supporting definitions and principles. Busy hours and the
intervention population versus nomadic population are important supporting definitions and
principles. The distinction between the two user groups is particularly important if mobile
broadband solutions are implemented, and in that case the handling of nomadic users is
undoubtedly a challenge.
There is clearly a need to ensure that nomadic users do not impact the service delivered to the NBIP
broadband users. One approach would be to dedicate spectrum to NBIP customers only and reserve
a different frequency band for nomadic users. It would also be possible to prioritise the traffic on the
air interface for NBIP users, in which case nomadic users could be allocated air time only when free
capacity is available beyond what is used by NBIP customers which, all else being equal, would be
more resource effective but it could mean that there is little or no actual bandwidth available to
nomadic users.
In any event as discussed in previous answers, the throughput requirements for an NGA service are
so onerous that the number of sites required to adequately cater for nomadic and NGA users could
be very substantial.
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Question 23: Do you agree or disagree with the placement of such commitments on the RSP to
secure the delivery of NGA broadband services to NGA users in line with the objectives of the
NBP?
In particular, your views are sought in the following:a) What form should these commitments take?
b) Who should monitor the activities of the RSPs?
c) How should this be policed?
d) What actions should be taken in the event of breach of commitments?
Please provide proposals and examples.
eircom agrees that a minimum set of commitments should be placed on all RSPs to ensure that
fully compliant NBP NGA services are delivered, and to deliver customers’ expectations of the NBP
NGA service to be provided. eircom believes these commitments should be contractually binding
as a voluntary code would be ineffective.
a) What form should these commitments take?
eircom believes that RSPs should be granted access to the NBIP infrastructure subject to a
contractual condition that they will offer fully compliant NBIP services to the end-user.
RSPs should be required to enter into contractual commitments with the wholesale network
provider to deliver fully compliant NBIP NGA services to the end user:
The Wholesale Network Provider (WNP) should be obliged to provide fully compliant NBIP
NGA service features included to the RSP.
The RSP access to subsidised NBIP NGA services should be conditional on it delivering fully
compliant NGA services to end users.
Service commitments should be fully aligned with the NBIP NGA service specification and
with SLAs that may be specified, and would include key characteristics of NBIP NGA
broadband services including:
o Upload/Download speeds
o Reliance on optical (or equivalent) technologies
o Support of advanced digital services
o Reliability and quality including NBIP NGA QoS parameters such as jitter etc.
o Affordability
o As would ordinarily be the case, a condition of access to NGA wholesale services should
include that normal commercial Terms & Conditions would be transparently published
including contract periods, termination and switching arrangements.
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b) Who should monitor the activities of the RSPs?
eircom believes the best approach would be to embed responsibility for monitoring and
compliance of the operational aspects of NBIP NGA within the WNP. The WNP would be
underpinned by contractual arrangements with the DCENR
An appropriate NBIPNBIP NGA monitoring and compliance authority should be established, whose
role would include monitoring and compliance of the activities of all operators along the value chain,
including RSPs.
Two high level options can be envisaged. First, a monitoring and compliance agency could be
established that would have extensive operational supervision capabilities enabling direct
supervision of each operator in the value chain. A second option would be to embed much of the
Monitoring and Compliance (M&C) operational responsibilities in the Wholesale Network Provider.
A high level assessment is provided below.
A Monitoring and
Compliance (M&C)
agency with
extensive
operational
supervision
capabilities
Operational aspects
of monitoring and
compliance
embedded in the
Wholesale Network
Provider
Advantages
Enable detailed
supervision of each
operator in the value
chain
Disadvantages
Positions the M&C
agency as an end-to-end
operational coordinator
deeply involved in
technical and
operational interface
issues on a day-to-day
basis.
Comment
Likely to be impractical
and to lead to too many
governance and control
layers and to replication
of expertise and cost
Responsibility for
delivery of complex
operational issues across
all operators would be
assigned to the WNP
that would have the
necessary operational
expertise and resources
The WNP could have a
conflict of interest as it
needs to be supervised
to ensure that it delivers
on the NBIP socioeconomic objectives
The WNP would be
obliged to report
regularly to
Government’s Monitoring and
Compliance agency that
would have intervention
powers
eircom believes the best approach would be to embed responsibility for monitoring and compliance
of the operational aspects of NBIP NGA within the WNP. This would enable Government’s
Monitoring and Control agency to focus on supervision from a policy perspective, and to rely on
operational processes for monitoring and control within the WNP that it can mandate through
contractual arrangements.
October 2014
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c) How should this be policed?
As discussed above, eircom suggest that the best approach would be to embed responsibility for
monitor and compliance of the operation aspects of NBIP NGA within the WNP underpinned by
contractual arrangements with the DCENR
The RSP would be required to report against the minimum commitments on a Quarterly basis, in a
standard format to be specified for the NBIP NGA service to provide transparency.
Results should be submitted to Government’s Monitoring and Compliance agency and should be
published through that process for all RSPs on a quarterly basis, and a link to those quarterly
results should also be made available from each RSP’s Website. The results should be published
in a clear and transparent manner and in a format that specified by an appropriate NBIP
monitoring and compliance process.
d) What actions should be taken in the event of breach of commitments?
Access to NBIP NGA infrastructure by RSPs that are not in a position to deliver fully compliant NBIP
NGA services should be restricted on an escalating basis from not being permitted to advertise or
take on new customers, to ultimately having their retail customers transferred to a compliant RSP.
A RSP should be prohibited from advertising services that meet NBIP NGA before it has submitted a
statement of compliance to an appropriate NBIP monitoring and compliance agency (delegated to
the WNP as discussed above).
If the NBIP monitoring and compliance agency is not satisfied that the RSP is in a position to launch
NBIP services, it should have the power to issue an instruction to the WSP to withhold access to the
NGA infrastructure and to issue an instruction to the RSP not to offer NBIP NGA retail services.
Following launch by the RSP of NBIP services, if breaches arise, the NBIP monitoring and compliance
agency should issue a warning to the RSP that their right to offer NBIP services will be constrained,
or withdrawn. In the first instance and pending remedying the inability to deliver NBIP NGA services,
a RSP could be prohibited from adding new customers to the NBIP service. In the event that the
remedy is not implemented in a reasonable time, a process would be activated to transfer NBIP
retail customers to a compliant NBIP NGA RSP.
October 2014
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Question 24: The Department is seeking views on the requirement for a RSP of last resort? How
would this work in practice?
An NBIP outcome where certain customers or groups of customers are stranded without service
challenges the logic of intervention in the first place. If the mapping exercise confirms industry
consensus that no premises in the NBIP footprint will be served commercially, the primary
objective of the NBIP should be to ensure that all premises are entitled to service on the same
basis in the rollout of the programme.
The tender should call for an end-to-end solution from bidders who would carry an ex-ante
obligation to agree arrangements with an RSP or a selection of RSPs to ensure delivery of the
specified NGA service to all premises within the NBS footprint.
A last resort provider approach – which is likely only to arise where the overall business case for
retail service provision is compromised through disaggregation - would amount to a de facto “USO within a USO”. The NBIP itself is a de facto provision of a universal high-speed broadband service
funded by the Government to ensure a reasonable rate of return for the network provider(s) who
will build the network. A RSP of last resort is a further layer of universal service where a network
provider (presumably the winning wholesale network provider) would meet the retail requirements
of a cohort of stranded premises where there is no case for a RSP to extend the service to those
premises. This would require a further subsidy which would have to be included in a complex
reworking of the overall State Aid assistance or else remunerated on an individual basis as each
“stranded” customer is served.
This scenario can be avoided if an end-to-end solution is required from bidders who would carry an
ex-ante obligation to agree arrangements with an RSP or a selection of RSPs to ensure delivery of the
specified NGA service to all premises within the NBS footprint.
October 2014
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Question 25: What are your views on the level of wholesale services that should be made
available by a State-Led intervention? What conditions should be set down along the various
levels of the value chain to ensure that NGA users have a reliable NGA broadband service from a
choice of multiple RSPs?
The view of eircom is that a wholesale operator should provide the full end-to-end NGA products,
service and processes to allow any potential retail telecoms providers participate in the market.
There are normally three elements that a wholesale operator should be required to consider –
Access, Core and Interconnection. The NGA services that a wholesale operator provides across
these three elements should be uncongested and scalable to cater for high-volume and high-usage
customers within the NBIP footprint. The wholesale system infrastructure should allow retail
operators interface efficiently for the provision and management of their end customers. The
products should also be flexible and cater for various types of retail operators which may want to
interconnect at various network layers. All interfaces along the value chain should be implemented
through contractual conditions that ensure that fully compliant NGA services will be delivered to
end users.
The view of eircom in terms of wholesale services and conditions at various levels of the value chain
that should be required of the wholesale operator for the NBIP footprint falls into three categories:
Access Product
Core Network Infrastructure
Interconnection
In addition, contractual obligations should be obligatory at all interfaces between service providers
along the value chain, to ensure that fully compliant end-to-end services are made available to endusers.
The wholesale system infrastructure should allow retail operators interface efficiently for the
provision and management of their end customers. Once a retail provider is an NGA operator, the
wholesale operator should have in place clearly defined products that support NBIP NGA services.
The wholesale operator should also have processes that allow for smooth migration of existing
customers to an NGA platform. This is critically important for FWA operators who have been
servicing local rural locations and have a relatively small customer base. The products should also be
flexible and cater for various types of retail operators which may want to interconnect at various
network layers.
October 2014
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eircom’s existing wholesale platform is designed to cater for operators of all sizes and capabilities.
Larger operators can interface directly into the eircom Wholesale systems architecture thereby
ensuring all their CRM systems are integrated seamlessly. Operators of a smaller scale can still avail
of all the benefits of eircom Wholesale’s processes without integrating at a system level. Instead these operators can manage their operations through eircom Wholesale’s dedicated online secure portal. In addition, operators have similar options when integrating at a network level. Operators
have the choice of integrating their backhaul at a single point in the eircom network or for larger
scale operators at multiple points, allowing them the opportunity to utilise their own network
infrastructure. eircom Wholesale has a dedicated product management function that manages
operators’ needs from initial service establishment through to complex in-life developments.
Access Product
The Access Product should be contractually specified to provide an uncongested broadband service
to the end consumer in conformance with NBIP NGA requirements. In addition to the speeds
available, other features should include QoS and Multicast. The wholesale operator should utilise
proven technology to construct the Access Network for the NBIP. The Access product should be
constructed as both a Bitstream variant and a Virtual Unbundled product. The wholesale operator
should be required to have in place the provisioning processes and systems to allow customers
migrate from current generation technologies to the technology deployed in the NBIP footprint. (In
eircom’s existing NGA Product portfolio there are over 2,300 migration scenarios managed by
eircom Wholesale). The wholesale operator should have in place the necessary in-life product
management processes and systems infrastructure. That is, a wholesale capability should be in place
to allow RSPs manage the product performance via the wholesale product architecture – e.g.
Prequalification Tools, Profile Management, Synch Checking, Line Testing and Fault Management. In
addition, the wholesale operator should have in place a fully trained field force to cater for onsite
provisioning and repairs. The wholesale operator should have the necessary billing architecture in
place to charge RSPs.
Core Network Infrastructure
The Core Network Infrastructure should be of an appropriate scale to support and to manage the
volume of customers within the NBIP footprint. The infrastructure should be scalable to deal with
future growth in broadband usage. The Core network infrastructure should have contractually
specified services that fully support the NBIP NGA services and should include appropriate attributes
for handling security and network performance characteristics such as latency and jitter.
Interconnection
The interconnection options available to RSPs should provide flexibility in terms of the NBIP variants
available. That is, operators should be able to interconnect for local handoff for Virtual Unbundled
Access or interconnect into the network to handoff at a single point to serve the entire NBIP
network. The Interconnection should also provide diversity and avoid single point of failure.
October 2014
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The system infrastructure should allow retail operators interface efficiently into the wholesale
operator for the provision and management of their end customers. The wholesale NBIP products
should also be flexible and cater for various types and sizes of retail operators which may want to
interconnect at various network layers.
As with all interfaces along the value chain, contractual conditions should apply that support the
NBIP NGA services.
Conditions along the value chain
All operators along the value chain should be contractually obliged to enter into commitments that
are fully compliant with delivery of NBIP NGA services to the end user:
The WNP should be obliged to provide fully compliant NBIP NGA service features included to
the RSP.
The RSP access to subsidised NBIP NGA services should be conditional on it delivering fully
compliant NGA services to end users.
Service commitments should be fully aligned with the NBIP NGA service specification and
with SLAs that may be specified, and would include key characteristics of NBIP NGA
broadband services including:
o Upload/download speeds
o Reliance on optical (or equivalent) technologies
o Support of advanced digital services
o Reliability and quality including NBIP NGA QoS parameters such as jitter etc.
o Affordability
o As would ordinarily be the case, a condition of access to NGA wholesale services should
include that normal commercial Terms & Conditions would be transparently published
including contract periods, termination and switching arrangements.
October 2014
62
Question 26: The Department is seeking inputs on how a performance measurement system might
be implemented that provides sufficient assurance of the quality of the service to the State, to
operators purchasing wholesale services and ultimately to NGA users.
eircom recommends that each stakeholder reports on measurements of the part or parts of the
value chain that they use. The RSP’s service should be measured end-to-end from the customer
premises to a destination point close to the BNG on the RSP’s network using a test probe and a responder. The measurement system must be capable of detecting customer activity to ensure
that these end-to-end measurements are not distorted by user activity. The performance of the
WSP network from the access node to the handover point to the RSP can also be measured using a
test probe and responder. The end to end RSP measurement should be a good indicator of the
performance of the access link, supplemented by reporting from the WSP’s performance management system for the access technology in question.
Performance measurements are needed at the different levels of the value chain referred to in Fig.1
of the Call For Information (CFI). The performance measurement, collection and reporting systems
are likely to be separate for the different levels parts of the value chain.
The reporting should assure the quality of the service offered by measuring similar parameters to
those discussed above i.e. download speed, upload speed, round-trip latency and packet loss. There
should be three different measurements taken throughout the lifetime of the installation:
Measurement pre-installation to establish the performance of the customer’s existing broadband service (where a customer has an existing broadband service)
Measurement after installation to demonstrate that the step change has been achieved
Ongoing measurements to ensure the step change is preserved and the user does not
experience degradation of service over time
NGA user tests measure the performance of the overall value chain without isolating the
performance of individual components of it. Separate wholesale measurements and reporting on
the Wholesale Network Provider (WNP) transport network are needed to isolate the performance of
that part of the network.
To measure the performance of the RSP service, we would use a test probe at the customer’s RGW and a test responder at the BNG on the RSP network. This would measure IP performance between
the customer’s premises and the closest possible point on the RSP network. The measurement would include the overall performance of the access link, the WSP network, the connection between
the WSP and RSP along with the RSP’s network up to and including the BNG where the customer’s service profile is applied.
With this approach there is a risk that the performance measurements may be impacted by factors
outside the control of the service provider. These factors include the load on the access line, the
processor utilisation on the customer’s RGW and the customer’s internal network. A measurement system with a probe that can address these risks by detecting customer activity must be used.
October 2014
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A system that offers this capability is supplied by the vendor SamKnows which is used by a number
of Regulators to measure broadband performance. See http://www.samknows.com .
If it is necessary to measure the overall performance of RSP’s service there should be multiple
destination points for tests in the RSP network and beyond. These should be placed progressively
further away from the BNG which is the origination point of the customer’s IP service on the RSP network. The destination points depend on the structure of the RSP’s network, but we would suggest that these destination points could be 1) at the BNG on the RSP network, 2) at INEX where
the RSP’s network connects to other Irish networks, 3) at LINX or large UK site where the RSP’s network connects to the wider Internet, 4) at a large EU site to represent the performance to other
European networks and 5) at a large US site to represent the performance to networks in the US.
To measure performance on the WSP network we would connect a test probe to a dedicated
performance management port on a representative sample of access nodes at the edge of the WSP’s network. In the case of GPON this would be at the OLT and in the case of VDSL at the DSLAM node.
We would place a test responder at the handover point to the RSP’s network. The test probe could then measure performance from the access node to the handover point to the RSP network using
ICMP echo request/response packets. This would measure the quality of the WSP’s network including backhaul from the access node excluding the access portion.
The end-to-end performance measurements for the RSP outlined above will incorporate the access
portion as part of the overall measurement. This will be a good indicator of the performance of the
access link where the WSP and RSP core networks are not congested, which we expect would
normally be the case particularly in the case of fixed access technology. Direct assessment of the
performance of the access link in isolation will require reporting from the WSP’s network/performance management system for the access technology in question.
The Large-Scale Measurement of Broadband Performance (lmap) IETF Working Group is
standardising and coordinating this area, particularly a framework that includes the measurement
agents and access technology independence. This agent functionality may be dedicated equipment
or, subject to equipment vendor support, be integrated into the CPE.
October 2014
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Question 27: The Department is seeking proposals on the kind of measuring systems which will
demonstrate, with reasonable accuracy, that the NGA broadband service is reliable and of high
quality. Where in the network should such measurements be made to and from? For clarity please
reference the typical value chain, outlined in Figure 1, in order to realise an appropriate
performance management system. Please provide supporting information with your response.
Our response to Q26 outlines how a set of measurement systems can be used to demonstrate the
quality of an NGA broadband service. This response expands on our response to Q26 which also
addresses some of the issues raised in this question. In this section we outline the features we
would expect from a performance management and reporting system.
The performance management system should be designed as a unified platform that has a
capability to collect the necessary network events and metrics, with the ability to analyse and
aggregate the data and a presentation layer supporting performance dashboards and specified
reporting. The solution must have the ability to support multi-tenancy with data segregation and
be accessible via a web-based interface or portal to both the WNP and various RSPs.
The performance management solution should be a modern web-based application that has been
developed using open standards on an open architecture with a set of APIs that allows for easy
integration into the wholesale network provider’s IT, OSS and BSS infrastructures and supporting
systems. The solution should be highly configurable with out-of-the-box workflow and rules engine
with centralised configuration, administration and system management.
Support for secure multi-tenancy with powerful dashboard and reporting capability with deep drill
down to specific events is a key capability. This should include the segregation of tenants’ data such
that each tenant has no visibility of data or dashboards which they are not authorised to view. The
solution must be highly scalable to meet the ever-increasing growth in IP traffic and devices
connected to the WNP’s network.
Collection of network events, metrics and statistics from various network element managers and
individual network elements is a critical component of the performance management system. The
ability to collect, correlate and aggregate large volumes of data is a core capability required to
support data analytics for threshold-based monitoring, SLA management and effective capacity
management.
The WNP has responsibility for the provision, assurance and service quality for services provided to
the RSPs. An effective performance management system, supporting agreed service levels providing
open access to performance data to RSPs is an essential management tool in ensuring the highest
levels of service are continually being achieved.
As outlined in 20 (b) above, RSP measurements should originate at the RGW and terminate at a
number of points further out in the network. Referring to the typical value chain in Figure 1, the test
will simulate an NGA user, run transparently across the PIP, the WNP, and terminate in the RSP’s network or a network connected to the RSP.
October 2014
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Question 28: The Department is seeking inputs on what Wholesale services should be measured
and by whom?
The view of eircom is that a wholesale operator should measure the performance of the products
and services across a number of metrics with quarterly reviews on performance conducted by the
appropriate monitoring and compliance agency. A range of metrics should be applied including
product performance metrics such as congestion, latency and jitter that are consistent with
ensuring that end-to-end NBIP NGA services can be delivered to end users. An appropriate NBIP
NGA monitoring agency should be established.
Just as should be the case for all operators along a value chain, wholesale services should be
monitored and reported on a quarterly basis to an appropriate NBIP monitoring and compliance
agency.
Those results should be published by the NBIP monitoring and compliance agency on a quarterly
basis.
A comprehensive set of metrics should be measured by the wholesale operator for each wholesale
service offered. These metrics must ensure that the wholesale services provided support the
delivery of fully compliant NBIP NGA services.
The wholesale services provided for the NBIP should have performance measures applied as follows:
Service commitments should be fully aligned with the NBIP NGA service specification and
with SLAs that may be specified, and would include key characteristics of NBIP NGA
broadband services including:o Upload/download speeds
o Reliance on optical (or equivalent) technologies
o Support of advanced digital services
o Reliability and quality including NBIP NGA QoS parameters such as jitter etc.
o Affordability
o As would ordinarily be the case, a condition of access to NGA wholesale services should
include that normal commercial Terms & Condition would be transparently published
including contract periods, termination and switching arrangement
At a specific product level this is the level of granularity eircom Wholesale are expected to adhere to.
Product Performance
The performance of the broadband technology itself should take account of the stability of the
service, the consistency of the speed provisioned and network attributes such as congestion, latency
and jitter.
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Provisioning Performance
The ability of the wholesale operator to provision the service should be reviewed by measuring:
Average time to prequal a line
Success of provision – provisioning without fault
Availability of appointments – length of time between order accepted and order provisioned
Volume of appointments completed daily
Missed appointments
Electronic migrations (without appointment)
Migrations from other services
In-Life Product Management
The In-life services provided by the wholesale operators should be measured as follows:
Average time to synch check a line
Average time to test a line
Average time to change a profile or add an ancillary service
Repair Performance
The repair performance should be measured as follows:
Average time to repair fault
Quarterly availability metrics
Fault Index
Rollout of NBIP Network
The pace of the rollout of the NBIP service should be measured against an agreed plan.
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Question 29: Do you agree or disagree with the proposed approach set out above for accessing
semi-state assets? Please provide supporting information and examples to your answer.
eircom agrees with the principle that all Government-owned assets should be applied to make the
delivery of the NBIP as efficient and effective as possible.
In the first instance, eircom suggests that the inventory of assets should not be confined to the SemiState area. Passive infrastructure owned by other Government agencies including e.g. physical sites
for antennae etc. should be examined for feasibility and made available to potential network
providers on favourable terms and conditions, including less-onerous licensing processes.
The infrastructure database should be available as early in the process as possible before the tender
documentation is issued.
While access conditions should be negotiated, there is a role for a dispute resolution procedure in
the event that reasonable requests for access are refused or unreasonable terms for access are
proposed.
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Question 30: Do you agree or disagree that only those companies which have passed the prequalification stage would be allowed to access such a database and what lead time would be
considered appropriate in advance of the tender for making relevant information available to
potential bidders?
eircom disagrees that only those companies which have passed the pre-qualification stage would
be allowed to access such a database. To ensure that adequate information is made available in
sufficient time, operators should be required to register their interest at the commencement of the
procurement process, and before the pre-qualification stage. A precondition should be set for
acceptance of such notifications, that operators must already have provided all of the required
infrastructure information to DCENR so that it can be made available to all qualifying interested
parties, from the time of close of notifications by operators wishing to participate in the tender
process. Details of engineering practice that would have to be adhered to, as well as indicative
commercial terms, should also be provided at that time.
As noted in the Call for input, the SAG state in paragraph 78 (f):
“Use of existing infrastructure:……Any operator which owns or controls infrastructure (irrespective of whether it is actually used) in the target area and which wishes to
participate in the tender, should fulfil the following conditions: (i) to inform the aid
granting authority and the NRA about that infrastructure during the public consultation;
(ii) to provide all relevant information to other bidders at a point in time which would
allow the latter to include such infrastructure in their bid…..” [Emphasis added]
A wish to participate in the tender would clearly be demonstrated by an operator seeking to prequalify. Consequently, it is clear that the obligation to make information available on its
infrastructure crystallises on seeking to pre-qualify. The SAG guidelines do not make any provision
for extinguishing of the obligation to make passive infrastructure available in the event of an
operator failing to pre-qualify.
There is a risk that bidders competing with each other are likely to delay providing information to
each other, or to provide a bare minimum amount of information, or to omit or delay engagement
or finalisation of commercial terms. In the event of an operator failing to pre-qualify, that operator
may be even less inclined to provide access to, or information on their passive infrastructure.
It also must be recognised that developing a proposal for the NBIP, that is a major infrastructural
initiative, will take a considerable amount of time, and so information on available infrastructure
needs to be made available at the earliest possible time.
Consequently, adequate time must be included in the overall NBIP programme between when the
information would become available to potential bidders and when first submissions would have to
be made to DCENR on an outline solution. A period of at least 6 months would be required to enable
review of the infrastructure databases and to incorporate infrastructure from these databases into a
first response to DCENR.
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To ensure that adequate information is made available in sufficient time, operators should be
required to register their interest at the commencement of the procurement process and before the
pre-qualification stage. A precondition should be set for acceptance of such notifications, that from
time of close all operators must have provided the required infrastructure information to DCENR so
that it can be made available to all qualifying interested parties wishing to participate in the tender
process. Details of engineering practices that will have to be adhered to, as well as indicative
commercial terms, should also be provided to DCENR at that time.
Of particular significance to this question is DIRECTIVE 2014/61/EU OF THE EUROPEAN
PARLIAMENT AND OF THE COUNCIL of 15 May 2014 on measures to reduce the cost of deploying
high-speed electronic communications networks. All Member States are obliged to adopt and
publish the laws, regulations and administrative provisions necessary to comply with this Directive
by 1 January 2016 which is a date that will probably coincide with the tender stage of the NBIP.
This Directive establishes the arrangements under which telecommunication operators shall access
infrastructure of other utility companies for the purpose of extending the reach of high-speed
telecommunication networks. The Directive applies to any extensive and ubiquitous physical
infrastructures suitable to host electronic communications network elements, such as physical
networks for the provision of electricity, gas, water and sewage and drainage systems, heating and
transport services. Under the Directive, operators can access physical infrastructure of other utility
companies irrespective of its location under fair and reasonable terms consistent with the normal
exercise of property rights.
The Directive also envisages that, in order to effectively plan the deployment of high-speed
electronic communications networks and to ensure the most effective use of existing infrastructures
suitable for rolling out electronic communications networks, undertakings providing or authorised to
provide public communications networks should be able to have access to minimum information
concerning physical infrastructures available in the area of deployment. Such minimum information
should make it possible to assess the potential for using existing infrastructure in a specific area, as
well as to reduce damage to any existing physical infrastructures. In view of the number of
stakeholders involved, and in order to facilitate access to that information, also across sectors and
borders, such minimum information should be made available via a single information point.
In summary, the EU Directive provides a clear template for optimising the use of existing and
planned utility infrastructure for high-speed broadband rollout (with a legal obligation on Ireland to
do so after 1 January 2016). Essentially, whether a utility company has an interest or not in
participating in the NBIP or even if that utility company exits the process either before or after the
prequalification stage, there will be a binding obligation on that utility company to provide the
information on its network and the basis for allowing access to its network on fair and reasonable
terms. In order to ensure an optimum outcome to the NBIP process, this regime envisaged to be
legally binding before the NBIP network is built, should be foreseen by the NBIP in the planning and
implementation of the project.
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Question 31: The Department is seeking inputs on the form of the bidders’ infrastructure database, how it would be managed, by whom, who could access it, etc.?
Infrastructure databases should include sufficient information to enable operators to make a
reasonable assessment of the suitability of infrastructure as part of a proposed NBIP NGA solution.
It should include a description of the infrastructure and any constraints on its use that may apply,
as well as geographic information on its deployment.
Operators should be required to prepare their own databases in conformance with a set of
principles to ensure adequate provision of infrastructure information and should include provision
in the NBIP procurement process to disqualify any operator that deliberately withholds
information with the intent of frustrating the requirement.
Only those operators whose notification of interest has been accepted by DCENR should have
access to other bidder’s infrastructure databases, and that acceptance should be conditional on having provided a database on their own infrastructure.
Infrastructure databases should be provided in an accessible format and should enable operators to
make a reasonable assessment of the suitability of infrastructure as part of a proposed NBIP NGA
solution.
Form of the bidders’ infrastructure database
This is likely to require information such as the following:
A description, including engineering drawings and specifications, of the infrastructure in its
primary role
Summary tables setting out the amount of each category of infrastructure
A description of constraints that may apply in the use of this infrastructure and an indication
of the likelihood of these constraints being common
A database in accessible format providing information such as geo-codes of the location of
the infrastructure or strip maps of where the infrastructure is deployed
Management of bidders’ infrastructure database
It is probably unrealistic to expect that information on a diverse set of operator infrastructures could
be integrated into a unified database within the timeline of the NBIP programme. Even if it could be
built in that timeframe, the cost would likely be prohibitive.
A more practical approach would be to require that each operator expressing an interest would be
required to prepare its own database in conformance with a set of principles such as the following:
Sufficient information made available to enable other operators to assess the practicality of
utilising the infrastructure as part of an NBIP NGA solution
Information should be up to date
Information not unreasonably withheld
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Note: Provision should be included in the NBIP procurement process to disqualify any operator that
deliberately withholds information with the intent of frustrating the requirement.
Accessing bidders’ infrastructure databases
As explained in response to Q30, eircom believes that operators should be required to register their
interest at the commencement of the procurement process, and before the pre-qualification stage.
A precondition should be set for acceptance of such notifications, that operators must already have
provided all of the required infrastructure information to DCENR so that it can be made available to
all qualifying interested parties, from the time of close of notifications by operators wishing to
participate in the tender process.
Only those operators whose notification of interest has been accepted by DCENR should have access
to other bidder’s infrastructure databases.
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Question 32: Do you believe the likely benefits arising from the availability of ubiquitous high
speed broadband will, over the long term, outweigh the likely costs. If so what do you believe the
main benefits will be?
Evidence drawn from European, UK and Irish research reports shows that online access delivers
substantial social and economic benefits to citizens and communities. The benefits include
education, entertainment, better job prospects, better access to public services, cheaper goods
and products, access to advice, information and knowledge, improved communication with family
and friends and enhanced democratic and civic participation. As faster and more advanced
broadband technology develops, the range of services delivered online is expanding dramatically
and the benefits of being online are increasing further still.
Employment will also result over several years during the construction and rollout phases which
will deliver a double impact for Government investment within the economy.
Extensive research and reports exist demonstrating that economic growth is enhanced through the
availability of broadband and high-speed broadband. According to a study from the European
Commission, the 27 countries that make up the EU can expect to receive cumulative benefits of
between €200 billion and €600 billion in the period of 2012 to 2020 as a direct result of investment in broadband and high-speed broadband, representing a benefit-to-cost ratio of between 2.7:1 and
2.9:1.
With regard to more specifics and expected impacts closer to home:The contribution of the SME sector to the overall economy is lower in Ireland than almost
anywhere else in Europe, but small businesses still provide most of the Irish jobs, according
to a Europe-wide study of SMEs by professional services firm Mazars.
The Irish SME sector needs competitively priced quality broadband services to enable it to
reach internationally. Case Studies from the Western Region (carried out by WDC)
demonstrate the extent of international trade within the SME sector and that broadband is a
pre requisite in enabling this. Technology can reduce distance to market for more peripheral
locations; but it is only where quality services are available at competitive prices that SMEs
will be able to contribute to the domestic economy to a degree comparable with SMEs in the
rest of Europe.
In terms of overseas investment, NGA services are a crucial location factor with regard to
attracting companies to Ireland. The experience of companies highlighted in the WDC report
Next Generation Broadband in the Western Region demonstrates the value of a fibre
network in establishing and securing further investment over that of our neighbouring
countries.
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#DG Communications Networks, Content & Technology (DG Connect)
commissioned Analysys Mason and Tech4i2 to undertake a study The Socioeconomic impact of bandwidth (SMART No 2010/0033).
This study comprises of:
a review of the existing literature on the socio-economic benefits of broadband access;
a high-level research on the technologies that are capable of delivering download speeds of
at least 30 Mbps to the mass-market by 2020;
the preparation of case studies describing local or regional markets where very high-speed
Internet is widely used;
the development of a model to examine the demand for 30 Mbps+ broadband in EU member
states plus Croatia, Iceland, Norway and Turkey to 2020, the extent to which this demand
would be met by commercial broadband rollouts, the cost of commercial rollouts and the
cost of extending terrestrial broadband coverage to a larger proportion of the population in
each country; and
the development of models to examine the overall socio-economic impact of investing in
high-speed broadband.
The literature review identified benefits including:
Community: local information and facilitating social networking
Crime, public safety and online Government services: ability of public service groups and
first responders to receive and share text, pictures and videos more quickly from the public
and colleagues, thus enabling them to better prepare for the emergency conditions that they
may encounter
Education and skills: distance learning and access to online information
Employment and economy: increases in employment or economic output
Environment: improving environmental sustainability largely by reducing the need to travel
and improving the management of buildings
Equality and inclusion: empowering the ‘voiceless’, connecting isolated individuals and communities and tackling social exclusion – rural areas were expected to benefit most from
the introduction of broadband
Finance and income: help people save money largely through online shopping
Healthcare: reduce the cost of providing health and social care services and/or improve
outcomes, e.g. through remote diagnosis and monitoring
Wellbeing: improving people’s quality of life and social wellbeing, e.g. by reducing the time
spent commuting and facilitating greater social interaction with friends, family, and others
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A Socio-economic benefit modelling demonstrates that considerable benefits will arise from
investment in broadband deployment:
Under a major intervention scenario (Fibre To The Premises), total NGA investment of €211
billion would be required across the EU 27 countries, with benefits of €569 billion
Job creation benefits were also stated as relatively high but are relatively slow to commence
with only 27.5% (1.083 million jobs) created in the first 3 years
UK Broadband Impact Study
This report was commissioned by the UK Department for Culture, Media & Sport, to assess the
benefits from improvements in broadband performance, and what return will be seen from the
substantial public funds going into upgrading the UK’s broadband infrastructure.
The report was prepared by SQW consultants and comprised a literature review published in
February 2013 and a final report published in November 2013.
The literature review published in February 2013 identified benefits including:
Economic impacts:
There is strong consensus in the literature that broadband has material positive impacts for
national economies (construction effects, productivity growth through enhanced business
innovation and international trade, as through teleworking)
Economic benefits take time to be realised
The few empirical studies on faster broadband mostly point to a positive incremental
economic impact
Environmental impacts:
ICT is a major source of carbon emissions and broadband networks are themselves significant
consumers of energy, however, ICT and particularly broadband can offer opportunities to
reduce emissions through a variety of mechanisms. (Please note it is eircom's view that FTTH
would be an exception to this conclusion in the UK Broadband Impact Study, as FTTH would
be comprised of passive optical fibre without the need for regenerators, thereby
substantially avoiding the need for electricity.)
There are likely to be positive environmental impacts from faster broadband around
teleworking as well as through reduced business travel and through enabling a shift to cloud
computing
Social impacts:
Broadband internet access has clearly had far-reaching positive impacts in areas such as
communication, entertainment, shopping, learning, health, access to employment, and
interactions with Government
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The incremental social benefits of superfast broadband are likely to include an increase in
time spent consuming video entertainment, and an increase in the use of video
communications. For areas with poor current levels of connectivity, improvements in
broadband speed will mitigate the extent of adverse impacts on the usability of the web for
these users from the trend towards increased file sizes for webpages.
The final UK report published in November 2013 built on the literature review by developing an
integrated model of the projected economic, social and environmental impacts associated with
faster broadband. Additional findings were:
Over the modelling period (to 2024), interventions in the UK are projected to return
approximately £20 in net economic impact for every £1 of public investment
The bulk of the impact comes from improvements in the productivity of broadband-using
firms, but there are also significant benefits from safeguarding employment in areas which
would otherwise be at a disadvantage, from productivity-enhancing timesaving’s for
teleworkers, and increased participation in the workforce
Intervention will have a material impact on reducing the digital divide for both households
and businesses
Quantified social impacts were identified through an increase in teleworking facilitated by
faster broadband, estimated to save 60 million hours of leisure time per annum by 2024; and
by avoiding commuting costs, teleworking was estimated to lead to total household savings
of £270M per annum
Quantified environmental impacts include savings of 2.3 billion km in annual commuting
through teleworking, 5.3 billion km in annual business travel, and 1 billion kWh of electricity
usage per annum, through broadband-using firms shifting part of their server capacity onto
more energy-efficient public cloud platforms
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Question 33: What are your views on the most appropriate ownership model for the State-led
intervention under the NBIP? Please provide supporting information in your response?
A private design build and operate model is likely to be most cost effective, because it would avoid
conflict of interest between Government’s role in policy making/supervision, implementation
and/or operation. It would also enable private-sector operators to commit infrastructural and
operating cost synergies from existing extensive infrastructure that is likely to form a major part of
any solution.
The Broadband State Aid Rules Explained, An eGuide for Decision Makers identifies a number of
potential business models that could apply. Below is a high-level assessment of these from the
perspective of Effectiveness, Government Ownership and Control, Value for Money, and
Government Responsibilities.
Bottom-up (or local community) model
It should also be borne in mind that the NBIP is likely to utilise a mix of existing telecommunications
infrastructure, passive infrastructure, and new NBIP dedicated infrastructural elements. In addition a
full suite of wholesale services will be required.
Effectiveness
Government Ownership,
Control & Responsibilities
Value for Money
If a national program were to
depend on initiatives being driven
from local communities, it is likely
that effectiveness would be very
low as many areas would not have
the community organisations, the
time or the resource lead in terms
of commitment and skillset.
oA comparison could be drawn
with local water schemes, or
build-your-own-home groups
that would highlight the
challenges that would arise.
oNonetheless, there may be merit
in one of the other models of
including provision for
involvement where community
groups want to champion
broadband rollout.
Large variability in services, retail
price and service quality would
arise.
Issues would arise when
communities with strong
representation achieve delivery
versus those that cannot get the
local resources behind the project
– blame may find its way to the
local politician’s doorstep.
While Government could retain
ownership, possibly on a joint basis
with local communities, this would
be a very challenging model to
sustain.
Challenges faced by the water
systems run by local authorities
demonstrate the need for scale
and efficiencies to be able to
deliver a cost-effective, highquality service throughout the
country.
Potential conflict of interest
between policy or supervision and
operational delivery.
Government would be increasingly
drawn into operational issues.
Such issues would likely quickly
expand beyond the capability of
the NBIP office and lead to the
need to set up an operational unit
like the National Roads Authority,
Irish Water, or BordGais.
Value for money would be very
difficult to achieve.
Business model would be
disaggregated.
Would restrict the ability of private
sector businesses from committing
synergies from their own network
or infrastructure.
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Private design, build, and
operate (DBO) model
Public outsourcing model
Joint venture
Public design, build and
operate (DBO) model
Effectiveness
Government Ownership,
Control & Responsibilities
Value for Money
Effectiveness likely to be high
Expect high level of consistency in
services, retail prices and service
quality.
Full range of wholesale services
would be readily specified.
Responsibility to meet the
comprehensive range of
requirements could be assigned to
an organisation with the requisite
skills and capabilities.
Absence of Government ownership
and so control would need to be
secured contractually.
Avoidance of conflict of interest
between policy/supervision, with
an implementation role.
Value for money would be more
readily achieved.
Private sector businesses could
more readily commit synergies
from their own network or
infrastructure.
Government risk is minimised as
the subvention could be
determined at time of award.
Effectiveness likely to be high.
Expect high level of consistency in
services, retail prices and service
quality.
Full range of wholesale services
would be readily specified.
Responsibility to meet the
comprehensive range of
requirements could be assigned to
an organisation with the requisite
skills and capabilities.
Government ownership retained
and so there is a direct mechanism
of control.
Conflict of interest between
policy/supervision, with an
implementation role likely to arise
as time progresses.
Government would increasingly be
drawn into operational issues.
Value for money could be difficult
to achieve as Government would
need to assess value of its assets
and appropriate payments to a
Managed Services Entity.
Would restrict the ability of private
sector businesses from committing
synergies from their own network
or infrastructure.
Also likely that Government would
have to retain considerable risk in
association with its asset
ownership.
Effectiveness likely to be good.
Expect high level of consistency in
services, retail prices and service
quality.
Full range of wholesale services
could be readily specified.
Responsibility to meet the
comprehensive range of
requirements could be assigned to
an organisation with the requisite
skills and capabilities.
Government ownership of some
assets retained and so there is a
direct mechanism of control,
however conflict of interests may
arise between the parties that
make up the joint venture.
Conflict of interest between
policy/supervision, with an
implementation role likely to
increasingly arise as time
progresses.
Value for money could be difficult
to achieve as Government would
need to assess the value of its
assets and appropriate payments
to a Managed Services Entity.
Would restrict the ability of private
sector businesses from committing
synergies from their own network
or infrastructure.
Also likely that Government would
have to retain considerable risk in
association with its asset
ownership.
Effectiveness likely to be poor as
Government would not have the
expertise to operate.
While Government could retain
ownership, this would be a very
challenging model to sustain.
Clear conflict of interest between
policy or supervision and
operational delivery.
Operational issues would require
the immediate creation of an
operational unit like the National
Roads Authority, Irish Water, or
BordGais.
Value for money would be difficult
to achieve as Government would
seek to build a high capability
organisation.
Would restrict the ability of private
sector businesses from committing
synergies from their own network
or infrastructure.
Government would carry full risk.
It should also be borne in mind that the NBIP is likely to utilise a mix of existing telecommunications
infrastructure, passive infrastructure, and new NBIP dedicated infrastructural elements. In addition a
full suite of wholesale services will be required.
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Question 34: What are your views in relation to governance structures for monitoring compliance
and performance in relation to any contract(s) terms imposed? Please provide supporting
information in your response.
eircom recommends that utilising binding contractual terms to ensure that all operators along the
value chain are contractually bound to deliver fully compliant NBIP NGA services. Contractual
obligations on the WNP and RSPs should also extend to operational responsibility for physical
monitoring for compilation of reports as they will have in-house implementation expertise and can
also design their facilities to collect the necessary performance information. Obligations should
include regular reporting in a standard format to the Monitoring and Compliance Agency.
eircom recognises that a key policy objective for the proposed State-Led Intervention is to ensure
that its socio-economic objectives are fully met, and on a long-term basis.
A mechanism for doing this will be through the contractual arrangements for providing access to the
State-Led Intervention infrastructure or services.
Special consideration has to be given to the wholesale network provider, because much of the StateLed Intervention is likely to be provided through this part of the value chain. Consideration also must
be given to RSPs and all operators along the value chain.
Several mechanisms are available to DCENR to ensure governance of its public policy objectives
including:
Terms and conditions of the contract offered to the WNP for provision of a State-led
investment or subsidy, that should rigorously reflect the NBIP services to be provided
Duration of the contract that should be very long (should be at least 20 years as suggested in
our response to Q35)
Roles of the retail service providers and terms under which the wholesale network provider
is permitted to provide access to the NBIP infrastructure, for example the WNP should be
contractually obliged to offer contractually binding conditional access to RSPS.
If some of the subsidy is to be provided by DCENR directly to RSPs, contracts between DCENR
and RSPs should similarly reflect NBIP requirements.
Role of an appropriate NBIP monitoring and compliance agency
In the CFI, it was indicated that DCENR is considering alternative governance options, including
setting up a new agency or requiring an existing agency or Regulatory Authority to monitor
compliance and performance.
To evaluate these options, it is useful to consider the nature of the monitoring of compliance and
performance that would arise.
Monitoring of the Wholesale Network Provider is likely to include network rollout
milestones, network performance, and network capacity, delivery of fully compliant NBIP
NGA services, customer numbers and network utilisation.
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Monitoring of Retail Service Providers is likely to include delivery of fully compliant NBIP
NGA services, customer numbers and end user service performance.
Monitoring will probably have to include an end to end monitoring to ensure that
coordination and handoff between the WNP and RSPs is operating effectively.
Operational responsibility for physical monitoring and for report compilation should be imposed
through contractual arrangements on the WNP and RSPs as they will have in-house implementation
expertise and can also design their facilities to collect the necessary performance information.
Depending on how DCENR designs the value chain, DCENR may not have a direct contractual
relationship with RSPs. Compliance by RSPs may be delivered through contractual arrangements
between the WNP and RSPs, in line with mandated requirements as specified to the WNP.
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Question 35: What are your views in terms of an appropriate procurement strategy for the
proposed State-led intervention? Please provide supporting information in your response.
A single stage end to end offers the best approach to cost effectively meet the requirements of a
State-led NBIP intervention. eircom recommends a single-stage deployment end to end to avoid
the drawbacks of a staggered deployment over time. If deployment were to be undertaken over
time, in stages -- with a first stage being the provision of fibre to a large number of nodes within
small communities, in expectation that it would stimulate competition in ‘Last Mile’ footprints -- it
is likely that this would result in an ineffective first phase. Many ‘Last Mile’ footprints would not be
built out with NGA infrastructure; and even in those for which NGA infrastructure may be
provided, it would likely be only for those that are economic to serve within those footprints.
In section 7.4 Procurement of the NBIP Call for Input, DCENR make reference to some potential
approaches including:
Award to one bidder or more than one bidder
Deployment in stages, e.g. in initial investment to certain points of the network with further
intervention later as required
Built on an area-by-area basis
Contract duration
Award to one bidder or more than one bidder
It is eircom’s view that the contract would best be awarded to a single bidder with overall
responsibility for coordinated development and delivery of NBIP services. It is our view that operator
would undertake to build ‘Last Mile’ infrastructure throughout the full NBIP footprint and would be
obliged to offer NBIP retail services to all customers within the intervention footprint. That operator
should also be obliged to offer end-to-end wholesale NBIP services to all operators to ensure that no
operator is frozen out of their existing customer base.
It should be noted that this does not exclude the possibility of other ‘Last Mile’ operators utilising
core backhaul capability from the NBIP infrastructure. This could be permitted, but this is an issue
that would warrant consideration by DCENR as to how it would impact the overall business case of
the primary NBIP provider that would have the obligation of RSP of last resort.
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Deployment in stages, e.g. in initial investment to certain points of the network
On 25 April, the Minister for Communications, Energy and Natural Resources, Pat Rabbitte TD,
announced that the Government has committed to a major telecommunications network build-out
to rural Ireland, with fibre as a cornerstone of its investment under the National Broadband Plan.
The description in the announcement included the following:“The Government has given the green light to the principle of a fibre build-out which will
be the cornerstone of the State’s strategy to deliver high-speed broadband to rural
areas. Over 1,000 rural communities have already been identified as target areas for the
proposed fibre based connections. The strategy will include additional measures to
ensure that consumers and businesses can avail of services being provided off the new
fibre network. It is envisaged that telecommunications operators will be able to offer
multiple services off the fibre network, including fixed wireless, copper-based and mobile
services, as well as offering the possibility of direct fibre connections.” While the approach described was subject to further consideration and development, as is clearly
being done through the Call for Input, the concept implicit in the announcement seemed to be a
Fibre To The node (FTTN) backhaul network to which ‘Last Mile’ infrastructure providers would connect.
If Government funding were to be applied exclusively to an FTTN solution, this would disaggregate
the business case between the subsidised component of the FTTN and potential business cases from
large numbers of independent small footprints. This would lead to frustration of achievement of the
intended socio-economic benefits for the following reasons:
Commercial deployment in very many of the small ‘Last Mile’ footprints would be unlikely to be economically viable as the challenge for business cases becomes greater further from
towns and villages, as building densities reduce
In those ‘Last Mile’ footprints that would be commercially viable, where an operator would
establish a ‘Last Mile’ infrastructure all others would likely be economically excluded thereafter
The potential for exclusion in ‘Last Mile’ footprints that can only economically sustain a single infrastructure highlights the need for a wholesale network obligation that extends all
the way to the customer’s premises, to avoid displacing or freezing out existing retail
operators and the creation of de-facto monopoly footprints
Consequently, we believe that provision of FTTN would not be sufficient to stimulate the
market
Moreover, ‘Last Mile’ operators would likely not deploy infrastructure to uneconomic customers in the footprint, thereby leaving many customers frustrated despite Government
intervention
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In this context, we note that the possibility of the Wholesale Service Provider acting as a ‘RSP of last resort’ is explored in Section 5.5 of the Call for Input. Please see our answer to Q24 in which we explain our view that making provision for a RSP of last resort needs to be
considered from the perspective of (i) An absence of an explicit obligation on a RSP to offer
NGA service to all addresses within its coverage area, which we believe would lead to a need
for a second ‘Last Mile’ infrastructure in the same footprint – that would be unaffordable, or
(ii) To provide for a situation where no operator is prepared to build a ‘Last Mile’ infrastructure, which we also consider is unstable with all the most challenged areas being
left for the ‘RSP of last resort’, or (iii) Where a ‘Last Mile’ operator fails commercially
There is also a strong likelihood that, in such a disaggregated model, multiple retail prices
would emerge and in many cases would not be close or similar to urban based prices,
thereby frustrating the SAG objective of ‘affordability’
An alternative approach would be for Government to maintain the integrity of the business case
rather than disaggregating it on either side of FTTN nodes. To ensure that the FTTN infrastructure is
built, Government could specify a minimum architectural requirement of an FTTN with a specified
number of nodes or distance from end-user premises.
Further intervention later as required
If a first phase is a tentative one and a period of a few years is provided to observe market reaction,
before finalisation of a full intervention, there would be a risk of little impact being achieved until
the second phase is implemented.
If a first phase were to focus on the set of customers in the next-lowest cost band to serve beyond
commercial deployments, this would result in intervention being focused on areas where very good
broadband with speeds up to 24 Mbps would be available based on commercial deployment. While
these customers would not yet be availing of NGA broadband envisaged in EU 2020 targets, many of
these customers would currently have access to very good broadband that is likely to be sufficient
for their needs for several more years.
eircom’s view is that it is unwise to require the most disadvantaged customers (those at the extremities of existing networks who only have access to very low-speed Basic Broadband) to wait
several more years before a second phase is considered from which they would benefit, as this
would defer substantial public policy benefits.
An additional consideration is whether phasing would be under the control of a single network
operator that could develop a coordinated and integrated business plan for such phasing. For
example, a network developer could consider phased deployment of FTTC or wireless followed by
fibre. However, this would require that the developer would control the evolution of the
infrastructure within an overall footprint. For example, FWA might be deployed as an interim
solution with a later phase to bring in fibre to carry the increasing data load. Such an approach
would require a single operator to be in control of the technology mix over time and would not be
compatible with individual small footprints being controlled by different operators.
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We also note that in Section 3.5.4.5 of the Call for Input, the following requirement is set out:
“Any such infrastructure which is properly designed and implemented is expected to sustain broadband connectivity for at least 20-40 years and should be easily upgradable
(i.e. requiring no change-out of the actual bearer/medium) throughout its lifetime to
keep pace with the future requirements for broadband services.”
Phased development is likely to lead to require change-out of the actual bearer/medium, particularly
in the ‘Last Mile’.
Built on an area-by-area basis
Building on an area-by-area basis may be practical, provided that areas were large regions of a
sufficient scale to enable coordinated development of an infrastructure.
Although dividing the NBIP into large regions may be practical, it would inevitably increase overall
costs as purchasing power would be fragmented.
It would also give rise to significant regional variances and operational challenges that would have to
be supervised and managed by DCENR’s NBIP implementation team.
So while building on an area-by-area basis may be possible, it would be at significant monetary and
operational cost.
Contract Duration
We note that in Section 3.5.4.5 of the Call for Input, the following requirement is set out:
“Any such infrastructure which is properly designed and implemented is expected to
sustain broadband connectivity for at least 20-40 years …...”
From an infrastructure investment perspective, the NBIP will be a long-term investment with asset
lifetimes of 10 years to 40 years.
Rollout is likely to take 3 years or more, and it will take several more years for customer numbers to
migrate to the NBIP services and to reach a steady state.
Consequently, contract duration should be at least 20 years to enable a business case to be
developed that would support such long duration investment.
From a DCENR governance perspective that would seek to influence the provision of NGA services to
drive socio-economic objectives, a long-duration contract would facilitate this directly.
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It would also be possible to conceive of governance structures that would extend beyond a longduration contract to ensure that Government, or the telecommunications industry, would continue
to be able to exert influence over the very long term. For example some form of review and policy
endorsement group could be established with a role that would extend beyond the contractual
period.
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Question 36: The Department is seeking views on how to identify areas where there is significant
demand for high-speed broadband? How can this demand be quantified? Please provide
supporting information in your response.
Since a key NBIP objective is to ensure that NGA broadband is made available to every household
and business, the purpose of demand assessment must be to determine the amount of
infrastructure required in each area, so that the network is appropriately dimensioned in each
area.
We believe there are two approaches that the Department could take to quantify the areas where
there is or could be significant demand for high-speed broadband.
1. Infer from existing data sources using household demographic and socio-economic data to
prioritise EDs where demand for high-speed broadband is more likely to exist from both a
residential and commercial perspective.
2. Quantify from primary research using a face-to-face or self-completion survey to understand
current and future demand for high-speed broadband within individual areas.
Caution will have be applied in interpreting market research to identify demand within NBIP areas
as many customers will not be in a position to envisage the evolution of their needs over the long
timeframe of the proposed NBIP intervention.
The primary objective of the National Broadband Plan is to deliver high-speed broadband services to
all parts of Ireland where it is evident that the commercial sector will not deliver.
Since a key NBIP objective is to ensure that NGA broadband is made available to every household
and business, the purpose of demand assessment must be to determine the amount of
infrastructure required in each area, so that the network is appropriately dimensioned in each area.
Caution will also have to be applied in interpreting market research as:
some customers will have strong views on the capability of broadband services that they will
require over coming years
other customers will not have a sufficiently deep understanding of the information age and
the benefits that could be made available to them, or how such services will impact on the
type of broadband service that they will require
the time horizon envisaged for this major intervention is very long term and is likely to
extend beyond what people can envisage
Identifying the level of demand for high-speed broadband within a catchment area is a complex and
challenging exercise. Historically, residents in these areas will not have had the option to subscribe
to high broadband speeds, so levels of suppressed demand need to be quantified. In addition the
demographic and socio-economic profile of such an area would also need to be taken into account
to understand the likely demand for high-speed broadband amongst the area population.
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It is unclear whether the Department intends to identify significant demand for high-speed
broadband within the total White NGA area, or if demand needs be quantified within the Electoral
District (EDs) or even subdivisions such as CSO Small Areas (SA). For the purpose of this response, we
have assumed that the demand for high-speed broadband needs to be quantified at individual SA
level.
We believe there are two approaches that the department could take to quantify where there is
significant demand for high-speed broadband at individual SA level:
Infer from existing data sources
Quantify from primary research
Infer from existing data sources
The universe for any existing data analysis would initially need to be defined. The exact definition of
this universe would need to be agreed following the results of the Department’s mapping exercise currently in progress. Commercial broadband will have been prospectively identified as being
available in Grey and Black NGA areas and it is expected that White NGA areas will specified to
identify where State-Led Intervention will occur under the NBIP. Thus the focus for any existing data
analysis should be on White NGA areas and the Small Areas within.
Household demographic and socio-economic data for each SA would need to be drawn from the
Central Statistics Office population estimates to identify the individual SAs where demand for highspeed broadband is more likely to exist. For example based on current fixed broadband penetration
levels, SAs predominately made up of smaller households with older occupants across the lower
socio-economic grades are likely to have a lower requirement for high-speed broadband and a
lighter infrastructure solution could meet their needs. Conversely, SAs with a higher proportion of
larger households with younger occupants who are working or in full-time education are more likely
to need a higher capacity infrastructure to support their high-speed broadband needs.
The profile of rural dwellers commuting and immigrating to towns and gateways for work purposes
due to the absence of high-speed broadband should also be taken into account (Ref: WDC Policy
briefing no. 6 on Commuting to Work: Rural Dwellers, Urban Jobs) when inferring demand for highspeed broadband. The WDC briefing policy quotes that in 2011 there were 1.7 million workers of
which 35.5% were rural dwellers, but only 21.3% of all jobs were located in rural areas. The
Department could look to quantify what proportion of the 78.7% of jobs currently located in urban
areas are dependent on high-speed broadband and could be located in rural areas should highspeed broadband be available. Industry type and socio-economic data such as occupation and
employment status could be used to identify the SAs where demand for high-speed broadband is
likely to be highest for work related purposes. For example, the latest eircom household sentiment
survey (Feb 2014) suggests that 19% of rural dwellers currently work remotely at home from time to
time and this decreases to 16% for those residing in Connacht/Ulster.
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The availability of high-speed broadband in rural areas therefore could increase the proportion of
workers who could set up business from home and reduce the dependency on urban areas for work.
In addition when considering suppressed demand, it is important to take into consideration how lack
of local infrastructure will impact demand. For example a rural White NGA area local infrastructure
will differ to that of an urban area in terms of access to banking, large retail food stores along with
postal services that may not be available. Demand and take-up may therefore differ as broadband
delivers such services via a quality broadband connection.
The output of any demographic and socio-economic analysis should be used to build a prioritisation
matrix, to ensure high-speed broadband is delivered to the SAs where the greatest demand for highspeed broadband is most likely to exist from both a residential and commercial perspective.
Quantify from primary research
As per the above, we have assumed that the demand for high-speed broadband needs to be
quantified at individual SA level within the White NGA areas that will ultimately determine where
State-Led Intervention should occur. Should our assumption be accurate, we would recommend that
all individual households within each SA be surveyed using an approach similar to the census.
Alternatively, if the intention is to understand the demand for high-speed broadband within the
total White NGA area defined post mapping, we feel a representative survey of this sample area
would be sufficient.
A face-to-face or self-completion survey would need to be administered with each respective
household. A current and future measurement of broadband requirements would need to be
conducted and gaps in current broadband usage identified as a prompt to consider how high-speed
broadband could resolve and ‘release’ behaviour. We would advise that the topic of any survey conducted be disguised to lessen the sensitivity towards infrastructural coverage and self-selection
of respondents. It is crucial to not only measure current broadband experience and expectations,
but also to explore attitudes to imagined future and high-speed broadband needs. The survey should
not be introduced as solely relating to broadband speeds, as people could self-screen out and claim
broadband has little or no relevance to them. The respondent should not be primed with the
knowledge that you are interested in coverage, network or infrastructural opinions as this would
lead to a) a heightened awareness and sensitivity to any issues and b) an increased level of
expectation for high-speed broadband coverage i.e., they raise the expectation bar higher than
everyday consumers would.
Once the sampling area(s) is defined and agreed, the next step would be to:
Decide on the appropriate sample size
And then develop a stratified sampling procedure to ensure a representative sample is
harnessed within the designed sample area(s).
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In determining the most appropriate sample size the following must be considered: - The margin of
error on the sample. We have provided guides below for different sample sizes; very large sample
sizes have lower error margins.
Sample N
3000
2000
1000
800
500
300
±margin of error
1.8
2.2
3.2
3.5
4.5
5.8
Figure 9 Guide to margin of error based on sample size
Once the sample sizes have been decided, the sampling procedure or methodology must be decided
upon.
Three sampling methodologies could be considered for each Small Area (SA):
A census type sampling approach where every household is contacted.
A random probability sampling approach.
A quota controlled sampling approach.
The most practical sampling approach in terms of cost and timelines, that will also deliver the
required data, is random probability. With random probability, an interviewer must continue to call
to a building that is selected until an outcome is achieved. From each chosen address, interviewers
follow a random route procedure (first left, next right etc.) calling at every nth house to complete an
interview, until their controls have been filled. The person responsible for selecting the broadband
provider within each address randomly selected would be interviewed. Only one interview should be
harnessed per household/business.
Should quota controlled sampling be applied the interviewer would need to conduct a number of
interviews within an assigned Small Area (SA), in accordance with household demographic controls
for that region which are drawn from Central Statistics Office population estimates (i.e. household
size and socio-economic status). The interview scheduling would also need to be controlled by:
Day of the week: weekday vs. weekend
Time of day: morning vs. afternoon
A questionnaire would need to be designed with the Department’s primary objectives for the National Broadband Plan in mind.
Some potential question areas that we would advise including are as follows:
Profiles / demographics
Levels of broadband uptake
Current barriers to broadband uptake
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Current broadband usage patterns
Type and number of devices currently used to connect to the internet
Number of devices connected to the Internet simultaneously
Overall satisfaction levels with current broadband service
Satisfaction levels across various broadband elements e.g., reliability, download speeds,
upload speeds etc.
Future broadband usage needs
Likely uptake of high-speed broadband if available
Current understanding of what benefits and services could be available from high-speed
broadband
Potential for flexi working hours in terms of home working
The research findings would need to be grossed up to quantify the levels of demand that exist for
high-speed broadband in the designated areas where State intervention is required.
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Appendix 1 LTE definitions
Capacity
The key constraint is the finite capacity of the air interface, which means that for NGA broadband,
capacity dictates the solution design. This and managing the interference profile results in small cell
sizes, even in rural areas of low population density. The key features of LTE-Advanced for delivering
broadband services are outlined in the following paragraphs.
Carrier Aggregation
LTE-Advanced enables carrier aggregation (intra-band or inter-band) to increase the amount of
spectrum available and thus increase the overall capacity available.
The downlink and uplink can be configured completely independently, the only limitation being that
the number of uplink carriers cannot exceed the number of downlink carriers. Each aggregated
carrier is referred to as a component carrier (CC). The CC can have a bandwidth of 1.4, 3, 5, 10, 15 or
20 MHz. With a maximum of five CCs, the maximum aggregated bandwidth is 100 MHz. Three types
of allocation have been defined in 3GPP to meet different operators’ spectrum scenarios.
Intra-band continuous
The simplest way for an operator to arrange aggregation would be to use contiguous CCs within the
same operating frequency band (as defined for LTE Rel-8/9), called intra-band contiguous. The
spacing between centre frequencies of contiguously aggregated CCs is a multiple of 300kHz to be
compatible with the 100 kHz frequency raster of Release-8/9 and to preserve the orthogonality of
the subcarriers with the 15 kHz spacing.
Intra and Inter-band non-continuous
Most operators are currently facing the problem of a fragmented spectrum. The non-contiguous
allocation has been specified to fit those scenarios; the allocation could either be intra-band, i.e. the
component carriers belong to the same operating frequency band, but have a gap or gaps in
between, or it could be inter-band, in which case the component carriers belong to different
operating frequency bands.
For example, if 10MHz of LTE800 and 15MHz of LTE1800 spectrum were dedicated to NBIP, the
combined 25MHz FDD bandwidth could provide 92.5 Mbpss (25x3.7) of average cell capacity on the
downlink and 50 Mbpss (25x2) of average cell capacity on the uplink. (This also assumes no use by
other, non-NBIP mobile broadband customers). Assuming a dimensioning of 2.5 Mbpss per customer
by 2020, this spectrum configuration could support 37 customers per cell or 111 customers per site.
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Peak Spectral Efficiency and Multiple Antennas
The peak spectral efficiency is observed when the user equipment (UE) is the sole active user in the
cell and has the optimal radio reception (highest modulation and coding). The use of multiple
antennas (MIMO – multiple input and multiple output) increases the spectral efficiency by a factor
of N or M when MxN MIMO3 is used.
The peak spectral efficiency for LTE without MIMO is 3.75 bps/Hz. For LTE with 2x2 MIMO, the peak
spectral efficiency is 7.5 bps/Hz, resulting in a peak downlink bit rate of 150 Mbpss for 20 MHz of
spectrum (FDD).
MIMO is effective only in good radio conditions (high signal-to-noise ratio). As reception deteriorates
towards the cell edge, the use of multiple antennas enable better signal reception, but does not
significantly increase the bit rate.
The target LTE-Advanced peak spectral efficiency is 30 bps/Hz for the downlink and 15 bps/Hz for
the uplink. This is based on using 8x8 MIMO on the downlink and 4x4 MIMO on the uplink (3GPP
TR36.913).
4x4 and 8x8 MIMO antenna configurations are not currently available for base stations or customer
user equipment. There will be significant cost and practical challenges associated with the use of 4x4
and 8x8 MIMO which the industry will need to explore and test.
NGA broadband speeds can be achieved where users are in good radio reception and MIMO is at its
most effective. However, the optimal reception for all users would require high sites, small cell sizes
and/or the use of external antennas and a delicate balance of the interference profile.
Average Spectral Efficiency
The average spectral efficiency is defined as the overall throughput of all users normalised by the
overall cell bandwidth divided by the number of cells. This is the best measure of the actual capacity
available to deliver NGA broadband. The average spectral efficiency is impacted by the height and
location of the LTE-Advanced sites, the customer distribution and location, whether indoor or
outdoor. MIMO increases the average spectral efficiency but to a lesser extent than it increases the
peak spectral efficiency because MIMO loses its effectiveness as radio reception quality (signal to
noise ratio) reduces. Techniques such as beam-forming and active antenna systems (AAS) can be
used to improve the average spectral efficiency.
3
NxM MIMO means a configuration with N receiving and M transmitting antennas.
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The LTE-Advanced target average spectral efficiency for the downlink is 2.4bps/Hz for 2x2 MIMO and
3.7bps/Hz for 4x4 MIMO. The LTE-Advanced target average spectral efficiency for the uplink is
1.2bps/Hz for 1x2 MIMO and 2bps/Hz for 2x4 MIMO (3GPP TR 36.913).
This means that for a 20MHz FDD channel, with 4x4 MIMO on the downlink and 2x4 MIMO on the
uplink, we can expect approximately 74 Mbpss of total downlink capacity and 40 Mbpss of total
uplink capacity for all users in a cell. While these capacities are very good for mobile broadband, it
would be very challenging to guarantee 30 Mbpss NGA broadband per active user on the downlink
and 10 Mbpss NGA broadband per active user on the uplink.
In practice, user activity and the number of active users will constantly vary. Hence, the number of
customers that can be supported is not simply the average downlink capacity divided by 30 Mbpss.
Fixed broadband networks are normally dimensioned per contracted customer rather than per
active customer. The dimensioning capacity for eircom NGA broadband customers is currently
measured to be in the region of 500 kbps per contracted customer. Based on projections and fixed
broadband experience, it is expected that this will rise to 2.5 Mbpss per customer by 2020. This
implies that for the example above, where a 20MHz channel provides an average capacity of
74 Mbpss, we would expect a cell to support approximately 30 NGA contracted customers by 2020.
As an LTE-Advanced node normally has three sectors (cells), this equates to a total of 90 NGA
customers per site. This capacity constraint could drive a requirement for a large number of sites for
a relatively small number of customers in the NBIP – 7,000 sites would be needed to support
630,000 customers. In addition, as the throughput per user is expected to increase continuously this
would suggest that sites will have to be added continuously in line with the increased demand or
upgraded with new technology to maintain the same level of service. As a site can cost in the order
of €150,000 this equates to a very high cost per customer.
Cell Edge
LTE-Advanced uses techniques such as Coordinated Multipoint (CoMP) to improve the cell edge
performance. However, the requirement to guarantee 30 Mbpss for every active user in the busy
hour is very challenging. At a minimum, the link budget will have to be designed to allow 30 Mbpss
for a user at the cell edge. This would be an extremely high cell edge target for commercial mobile
LTE-Advanced networks. In practice, it is likely that there will be more than two customers active
during the busy hour. If both happen to be at the cell edge, then the network would have to be
designed for a 60 Mbpss cell edge, which would result in extremely small cell coverage, unless
extensive use was made of high sites and external customer antenna.
In-building coverage
As with any wireless technology guaranteed in-building coverage is a significant challenge. The most
effective way of dealing with this challenge is using external antennas on the buildings, however this
would be costly, operationally complex and time consuming.
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Latency
The latency for LTE on the user plane is 5ms (one way). LTE-Advanced is targeted to be lower and
therefore outperforms the IMT-Advanced target of 10ms. Hence LTE-Advanced latency is in line
with expectations for fixed NGA broadband of 10ms (one way).
TDD
An alternative option for LTE is to use TDD spectrum. This spectrum is more cost effective and at
3.5GHz is in more liberal supply. However eircom would have concerns over the suitability of 3.5GHz
LTE TDD for the NBIP. Below is a plot comparing LTE 3.5GHz TDD (red) vs LTE 1.8GHz FDD (blue).
Both use the same amount of spectrum (20MHz) with the same RBS output power. As can be seen,
for a 30 Mbpss scenario, 1.8GHz FDD has a cell range of approximately 6.5 km while LTE 3.5GHz TDD
has a cell range of approximately 2.1 km. Even with LTE-A Carrier Aggregation and external
antennas, LTE TDD 3.5GHz will struggle to provide any meaningful level of guaranteed coverage.
DL bit rate versus distance for LTE 3.5GHz TDD (red) vs LTE 1.8GHz FDD (blue)
Summary
In conclusion, LTE-Advanced could contribute to the NBIP solution, but there are challenges in terms
of guaranteed indoor coverage, overall capacity, cell edge performance and the scale of deployment
required relative to the actual number of customers served.
Features which would help enable LTE-Advanced to deliver a fixed NGA broadband experience are
Carrier Aggregation to maximise the spectrum used and available capacity (an aggregate of
25MHZ FDD or higher or an aggregate of 50MHz TDD or higher would help the overall
available capacity)
Dedication of spectrum to NBIP or very limited mobile broadband use in spectrum bands
shared between mobile and NBIP NGA.
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4x4 or 8x8 MIMO and active antenna systems at the base station, 2x4 MIMO at the user end
Use of CoMP and other techniques to improve performance at the cell edge
External integrated radio/antennas at the user end to optimise radio reception. This
eliminates building penetration loss, cable loss and can place the user equipment above the
height of local clutter/obstructions.
Use of high sites to maximise line-of-sight and ensure optimal radio reception but the tradeoff here will be interference and capacity
Use of small cells and relay cells to provide localised coverage for black spots
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