This paper discusses the various issues on the introduction of 3G mobile services and consults the industry

New T & T

Informations

• Publié par: Ormo
• Nombre de lectures: 14
• Langue: English

Extrait

Date: 23 October 2001
Wharf New T&T Limited
WHARFT NEW T&T LIMITED
SUBMISSION IN RELATION TO
REVIEW ON THE TELECOMMUNICATIONS AUTHORITY'S
STATEMENTS NO. 4, 5, 6, 7 (REVISED) AND 8 ON INTERCONNECTION AND
RELATED COMPETITION ISSUES
A CONSULTATION PAPER DATED
11 SEPTEMBER 2001
1Date: 23 October 2001
Wharf New T&T Limited

TABLE OF CONTENTS
Page
1. INTRODUCTION............................................................................................................4
2. THE RELATIONSHIP BETWEEN THE INTERCONNECTING PARTIES - EQUAL
STANDING WITH EQUAL
RESPONSIBILITIES……………………………………..5
3. THE USE OF LONG RUN AVERAGE INCREMENTAL COST ("LRAIC")
APPROACH TO MEASURE THE RELEVANT COSTS FOR
INTERCONNECTION....................................................................................................7
4. OTHER TYPE II INTERCONNECTION ISSUES ON LRAIC AND FDC.................13
5. IS THE HISTORICAL OR THE FORWARD LOOKING OR CURRENT COST
MORE APPROPRIATE WHEN APPLIED TO TYPE I AND TYPE II
INTERCONNECTION? ................................................................................................14
6. WHAT SHOULD BE THE APPROPRIATE STRUCTURE FOR THE
INTERCONNECTION CHARGES FOR THE RECOVERY OF THE COSTS FOR
INTERCTION LINKS, PORTS, SWITCHES AND NETWORK
CONDITIONING?.........................................................................................................17
WHAT SHOULD BE THE APPROPRIATE COST RECOVERY MECHANISM FOR
THE ESTABLISHMENT OF LINKS AND NETWORK CONDITIONING? ............17
7. INTERCONNECT LINK COSTS .................................................................................20
8. NETWORK CONDITIONING COST ..........................................................................20
9. THE FORECAST OF TECHNOLOGY OBSOLESCE ................................................22
10. LONG RANGE ASSET REPLACEMENT STRATEGIES..........................................24
11. ACCOUNTING PRACTICE AND DEPRECIATION SCHEDULE............................24
12. WHAT MODIFICATION, IF ANY, SHOULD BE MADE TO THE PRINCIPLES
CONCERNING RESPONSIBILITY OF PAYMENT FOR THE SPECIAL CALL
TYPES IDENTIFIED IN THIS SECTION OF, AND THE ANNEX TO,
THE PAPER? ................................................................................................................29
13. ECONOMIC AND TECHNICAL EFFICIENCY .........................................................30
14. TRANSPARENCY AND PUBLICATION OF INTERCONNECTION CHARGES
AND JUSTIFICATIONS...............................................................................................33
2Date: 23 October 2001
Wharf New T&T Limited
15. ANNUAL REVIEW OF CHARGES.............................................................................35
16. RELATIONSHIP BETWEEN RETAIL AND WHOLESALE CHARGES .................36
17. COMPETITION FIRST AND FOREMOST.................................................................39
18. "HEAVY-HANDED" REGULATION VS. "LIGHT-HANDED" REGULATION......40
19. OTHER ISSUES............................................................................................................42
20. CONCLUSION..............................................................................................................43
3Date: 23 October 2001
Wharf New T&T Limited
SUBMISSION IN RELATION TO
REVIEW ON THE TELECOMMUNICATIONS AUTHORITY'S
STATEMENTS NO. 4, 5, 6, 7 (REVISED) AND 8 ON INTERCONNECTION AND
RELATED COMPETITION ISSUES
A CONSULTATION PAPER DATED
11 SEPTEMBER 2001 (the "Consultation Paper")
1 INTRODUCTION
1.1 Wharf New T&T welcomes the opportunity to present its views on the issues raised in
the Consultation Paper.
1.2 The role of the Telecommunications Authority (TA) is to promote and attain the
telecommunication policy objectives of the Hong Kong Government. The TA has the
duty to lay down a regulatory framework that is conducive to the development of
long-term sustainability in competition.
1.3 Wharf New T&T advocates that the TA should adhere to the following principles for
interconnection:
(a) Interconnection is a necessity in a multiple network environment. The TA
must undertake whatever necessary to ensure prompt and efficient
interconnection. The relationship between the parties is one of equal standing
with equal responsibilities and the terms of interconnection must truly reflect
that relationship.
(b) Operators should bear its own cost for meeting their licensing obligation.
Operators should not have to compensate the other operators through
interconnection charges for such obligations such as network conditionings.
(c) If compensation is warranted the cost of the most efficient operator should
prevail. This will minimize costs, avoid overcompensation to the inefficient
operator and encourage efficiency.
(d) Ensure transparency and publication of interconnection charges of the
dominant operator. This will minimize delay and anti-competitive conduct.
(e) There must be a level-playing field. Adopt light-handed regulation when and
only if the market is ready which means that consumers are FREE to move on
from one network to another and when the operators concerned are not
dominant.
4Date: 23 October 2001
Wharf New T&T Limited
1.4. To lay down a regulatory framework that is conducive to the development of long-
term sustainability in competition and the TA must remove ALL barriers which come
in the form of :
• excessive charges imposed by the dominant operator for implementation of
various interconnection facilities;
• Lack of transparency in charges imposed by the dominant operator;
• refusal to provide sufficient point of interconnection capacity on fair and
reasonable terms, promptly and efficiently;
• the insufficient quota unilaterally set by the dominant operator in the cutover
of local access links;
• the insufficient quota unilaterally set by the dominant operator in the
processing of number port requests; and
• unreasonable delay in the implementation of various interconnection requests
including broadband Type II interconnection.
2. The Relationship Between the Interconnecting Parties - Equal Standing with
Equal Responsibilities
2.1. Liberalization of the fixed line industry means that there are multiple fixed networks
operating in Hong Kong. In a multiple network environment traffic will be passed
between the various networks as subscribers of one network operator access another
subscribers, services or service providers, of another network operator, the network
operators must therefore interconnect their respective networks for the passing of
traffic between them. Interconnection is therefore a necessity in order for
operators to operate in a multiple network environment. General Condition (GC)
13 of the FTNS licence thereby requires each FTNS operator to provide prompt and
efficient interconnection.
2.2. Interconnection is also one of the essential elements in meeting the licence obligation
under GC 10(1), which requires each operator to operate, maintain and provide a good,
efficient and continuous service in a manner satisfactory to the TA. In order to meet
the obligation under GC 10(1) each of the FTNS operators must ensure that its
subscribers can access any subscribers, services or service providers, of another
network operator, any time.
2.3. It is also a fact that insufficient interconnection capacity over the interconnect route or
failure to interconnect will result in subscribers of one network not able to access
subscribers or services or service providers of another network operator. This poses
real threat to the efficient operation of multiple networks; to the consumers and to the
development of competition.
5Date: 23 October 2001
Wharf New T&T Limited
2.4. Notwithstanding the recognized benefits of interconnection it is true to say that the
incumbent operator has absolutely no incentive to establish and maintain
interconnection promptly and efficiently. Effective interconnection ensures the
working of multiple networks. Efficient working of multiple networks encourages the
development of competition, which poses real threat to the incumbent operator. It is
therefore crucial for the regulator to mandate interconnection and to lay down very
clear rules in establishing and maintaining interconnection. The regulator must also
be prepared to step in promptly to direct interconnection when there is a failure to
adhere to these rules.
2.5. In mandating interconnection and constructing clear rules for establishing and
maintaining interconnection amongst the network operators, Wharf New T&T submits
that the TA must make it clear the relationship between the interconnecting parties,
particularly in the case of Type I interconnection; number porting. Each party has the
obligation to establish and maintain interconnection pursuant to GC 13 of their
respective FTNS licences in order to operate in a multiple network environment; and
each party has the obligation to operate, maintain and provide a good, efficient and
continuous service to meet their respective obligation under GC 10(1) of their
respective FTNS licence. The relationship between them therefore is one of equal
standing with equal responsibilities. It is therefore