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NBN design under-represents regional Australia: Telstra

IT Policy - Regulation

Australia's dominant carrier Telstra has warned the Australian Competition & Consumer Commission that the proposed design for the National Broadband Network leaves regional centres with too few points of interconnect (POIs). Meanwhile, according to Telstra, densely populated urban centres have POIs geographically too close together in the NBN Co design.

The Telstra submission to the ACCC, penned on 11 January and released yesterday as the the ACCC released its revised list of 121 POIs, argues that the design for the NBN has been determined erroneously, largely as a result of the location of the legacy copper network exchanges.

The submission states:

'Telstra believes these anomalies in part arise due to the ACCC assessing historical outcomes from the copper access network and then imposing them onto the design of the new NBN Co fibre access network. That is, the proposed POI locations are heavily influenced by where competitors currently have DSLAM equipment, which has been dependent on access seekers having a concentration of customers within a suitable copper loop reach. This conversely has relied upon where Telstra deployed its exchanges for a 100 year old copper network.

However, the move to FTTP results in a very different access network architecture, with the fibre reach typically being much greater than the copper '” generally 12km for fibre as opposed to around 4 km for copper.'

According to Telstra, simply using legacy exchanges for POIs could result in an efficient and more costly network and instead more suitable alternative sites should be considered. In particular, Telstra claims that regional Australia is not getting an adequate number of POIs:

'Regional POIs are under-represented from an efficient network design perspective. Telstra believes given Australia's geography, there should be a greater number of regional POIs which would provide a more efficient network, account for larger regional population centres and potential future growth in these areas, and be in the long-term interest of end users.'

The Telstra submission points out that it does not appear to be logical for metropolitan areas to be serviced by 85 POIs - many of which are very close to each other - while just 35 regional POIs are spread wide and thinly throughout vast geographical areas which could affect the network performance:

'Of the 120 POIs, NBN Co has classed 80 as metropolitan POIs and 40 as regional POIs. Of the regional POIs, Telstra would describe 5 of these as being outer urban POIs rather than regional POIs, leaving only 35 regional POIs.

'Telstra questions whether there is any advantage or network efficiency gains of having a POI distribution where there are too few regional POIs, and the metropolitan POIs are located in close proximity. The transmission links in regional areas will have to cover greater distances than they otherwise should, and this could affect the end user experience of the network.'

Telstra argues that a more efficient design would come from reducing the number of metropolitan POIs and increasing the number for regional areas - or at least progressively adding more POIs for regional areas:

'Should the ACCC and NBN Co proceed with 120 as the initial number of POIs then, given the likely benefits from having more regional POIs and the diminishing returns from having metropolitan POIs in close proximity to each other, greater benefit could be derived for the long term interest of end users from having more regional POIs and fewer metropolitan POIs.

'As another option, Telstra believes that additional regional POIs could be readily identified and added to the initial 120 POIs, especially along the eastern seaboard of Australia, that make sense on the grounds of network efficiency. This would help to alleviate some of the inefficient network design problems in regional areas that have unintentionally been created by the criteria used to select the initial POIs. This addition would also provide for large regional population centres to be served, and account for future growth anticipated in these areas due to such things as the expansion of the resource industry.

'Further, it is Telstra's view that the current distribution of POIs should be examined further to determine whether that distribution may generate other anomalies in the distance between POIs and the communities which they serve. There is the potential for higher costs and decreased network performance if, communities were to be served by POIs located in distant regional centres. This could be avoided by applying more flexible criteria for the selection of POI locations.'