Market Analysis: Leased Lines (04/59) (04/60) Submission to ComReg Consultation Process

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1 Market Analysis: Leased Lines (04/59) (04/60) Submission to ComReg Consultation Process 16 July 2004

2 Market Analysis: Leased Lines (Retail and Wholesale Markets) 1 Introduction In this paper we are responding to two ComReg consultations on leased lines as part of the market analysis process. We have an overall concern that ComReg has defined the leased line market in too narrow a manner. Services such as ATM, IP, and Ethernet are effectively excluded from consideration in this paper but have been used by eircom to compete with leased line offerings from other operators. These services are operating as substitutes for leased lines. We believe that Ofcom has considered the leased line market in a more broadly-based manner and reached more realistic conclusions. ComReg should undertake a more comprehensive analysis on this point. These comments should be taken into account by ComReg for both the wholesale and retail leased line markets considered in this paper In this paper we address the component markets in the following order Wholesale Retail - International (retail) Retail - Up to and incl. 2Mb Retail - Above 2Mb We consider market definition, analysis and remedies for each market in turn. We have addressed most of the questions in the two consultation papers, but in the main respond specifically to those set out in the main consultation 04/59. question numbers are contained in [square brackets].

3 2 Wholesale leased lines (04/59) In general terms we agree with the market definition outlined by ComReg in Section 5 of the consultation paper i.e. a single national market including all bandwidths and services. We share ComReg s analysis, from Section 6, of eircom s dominant position in the market for wholesale leased lines [Q9, Q10]. Furthermore, we believe that this analysis should be wholly replicated for the retail leased line markets. ComReg s differentiation between a standard access obligation on eircom and what is actually proposed in the consultation paper is not entirely clear. We agree that an access obligation should be imposed on eircom mandating Partial Private Circuits and also the obligation to meet reasonable requests for access [Q22, Q23]. Our view is that a general access obligation should also be applied to eircom in this market. No strong argument for the lighter form of regulation is made in the consultation paper and this proposal is not justified given that wholesale leased lines are the only methods of competing against eircom in many areas of Ireland. We agree that a remedy of non-discrimination should be imposed on eircom for PPCs and wholesale leased lines [Q 24]. We agree that eircom should be required to grant open access to technical interfaces, protocols, or other key technologies and should also be required to provide such Operational Support Systems (OSS) or similar software necessary to ensure fair competition in the provision of services [Q 25]. OAOs have set out such requirements in the past and will contribute to the PPC forum or other industry groups in future. We agree that eircom should be required to negotiate in good faith [Q26], and should not withdraw access to facilities already granted, save without prior ComReg approval which would only be granted following public consultation [Q27]. We share ComReg s assessment of SLAs, covering all process points, as a vital element of any wholesale offering from eircom. SLA penalties have been proven to achieve the desired outcome in the past, for example better leased line delivery, and should be retained. Overall, we agree with the approach to Service Level Agreements for access obligations outlined by ComReg [Q 28]. ComReg should ensure that SLA cover is available for such services on a 24 hour basis. We are considering making a submission to ComReg on this subject in the near future. 3

4 We agree that an obligation of non-discrimination is appropriate to mandate the provision of a wholesale leased line offer by eircom and that SLAs and reports on SLAs are necessary to monitor non-discrimination this obligation [Q 29, Q30]. ComReg and operators have invested considerable time in developing these reports and they have delivered real results. We believe it is appropriate to impose an obligation of transparency on eircom [Q31]. It is vital that the current reference offer obligations be maintained for PPCs and that all documentation relevant to wholesale leased lines be assembled in a single reference offer document [Q32]. Easy access to this kind of information is essential for OAOs to be able to provide services on a comparable basis to eircom. While we support ComReg s proposal to continue with the application of LRIC price control for PPCs, we believe that ComReg should, as part of a wider consideration of wholesale pricing, consider the application of wholesale price caps for these services [Q 34]. ComReg will be familiar be with our views on wholesale price caps. We favour the continuation of the current retail-minus price control approach for wholesale leased lines. In the consultation paper ComReg proposes that the minus factor would remain at 8%, in order to prevent a margin squeeze. ComReg does not analyse how or why this level of discount will ensure that margin squeeze does not arise. We would urge ComReg to initiate a separate consultation on the issue of margin squeeze to establish a set of reasonable and transparent principles. [Q 35] ComReg proposes relaxing all obligations on eircom in the retail market for leased lines above 2Mb. In the entire wholesale market, eircom is obliged not to discriminate and to make prices available in a transparent manner. We are not clear as to how obligations for non-discrimination and transparency, for wholesale leased lines above 2Mb, can be effectively enforced when details of the retail equivalent will not be publicly available. ComReg needs to clarify this issue. We agree that eircom should have obligations in respect of cost accounting and accounting separation [Q36, Q37]. The full implementation of these obligations will be vital, particularly if ComReg proceeds to relax controls in the retail market. The regulatory accounts will be the only method of seeing what eircom retail is implicitly paying eircom wholesale for leased lines. 4

5 3 Retail International (04/60) ComReg s proposal to define a separate market for international leased lines is not adequately supported in the consultation paper. This market is not identified separately in the Relevant Markets Recommendation and has not, to our knowledge, been treated as a separate market by any other National Regulatory Authority.[Q1] In general, an international leased line will be sold with a national leased line as elements of an end-to-end customer solution. ComReg s analysis does not seem to consider this factor in any detail. We are concerned that, were ComReg s proposals to be implemented, eircom might be in a position to use pricing of an international leased as a form of loss leader to support its sale of regulated products. ComReg needs to provide assurances that controls will be put in place to ensure that eircom does not use the relaxation of regulation in certain market sectors to unfairly compete in others. ComReg also needs to clarify whether below-cost selling would be permitted for leased lines where specific regulatory controls are being removed. 5

6 4 Retail market definition for national leased lines (04/59) As outlined in the previous section we do not support ComReg s analysis of the international market as being separate from that for national leased lines. In relation to whether leased lines of all bandwidths are in the same retail market, we do not fully agree with ComReg s analysis. As broadband usage grows, there is evidence of increasing movement from relatively low bandwidths to higher specification services. We have evidence that eircom is now substituting customers with 5 x 2Mb or more onto a fibre connection, obviously in order to switch to enable a switch to a 34 Mb service or higher. This trend seems set to continue on a wider scale. The same logic would also apply for movement on to even higher bandwidth services (e.g. 155 Mb). We have an overall concern that ComReg has defined the leased line market in too narrow a manner. Services such as ATM, IP, and Ethernet are effectively excluded from consideration in this paper but have been used by eircom to compete with leased line offerings from other operators. ComReg should undertake a more comprehensive analysis including these services within the scope of this market [Q11 Q17]. We support a conclusion that the retail market for all national leased lines is national in scope [Q18] 5 Retail - above 2Mb (04/59) We are very concerned at the depth of analysis carried out by ComReg in relation to leased lines above 2Mb. In section 9 of the consultation paper, an analysis of about one page is presented in support of very important conclusions. This is not an adequate attempt at analysing this market. It contrasts with the ten pages of detailed analysis used to support proposals in the market for sub 2Mb leased lines. Our main concerns are as follows: The market shares data, in section 9.2, is unclear. ComReg should clarify what is meant by all leased lines in the two tables printed and what services are included for eircom and other operators. No pricing data is analysed in contrast to the analysis in section 10, for leased lines under 2Mb. Eircom s prices for leased lines above 2Mb have not changed for a number of years. We believe this is evidence that 6

7 eircom is not being forced to adjust its prices to respond to competitors and supports a conclusion of dominance in this market. ComReg states that barriers to entry in this market are lower as potential revenue is higher, making entry more economical. This point is not substantiated. ComReg can only point to very limited instances of market entry. The advantages which eircom holds in the sub 2Mb market (ubiquitous access and backbone network, economies of scale and scope, vertical integration, and barriers to entry) also apply in the 2Mb+ market. For example, ubiquity of network (which is apparently important for lower bandwidth customers who wish to achieve full geographic coverage) will equally be relevant to high bandwidth customers who wish to purchase full geographic coverage. ComReg does not address these issues in sufficient detail to justify any other conclusion. ComReg also makes comments about buyer power in this section, referring to a small number of large purchasers of high capacity leased lines. ComReg concludes that this indicates the existence of countervailing buyer power. Our view is that countervailing buyer power can only really exist if the value of the buyer s business is large in relation to the revenues of the supplier and that customer has a real opportunity to switch. It is clear that the value of any one leased lines contract is not significant for eircom s overall business and that these consumers do not have a wide choice of alternative providers. ComReg have not substantiated this element of their market analysis. Our view is that all leased lines, including national leased lines under and above 2Mb, should be considered as the one market for the purposes of this market analysis exercise. We do not agree with ComReg s proposal to withdraw obligations on eircom for leased lines above 2Mb [Q19]. The current obligations should be maintained. We believe eircom will use this relaxation of regulation to aggressively target other operators in the leased line market, thereby undermining competition and choice for business consumers. Eircom may seek to link the sale of regulated sub 2Mb services with unregulated 2Mb+ services. We are concerned that, were ComReg s proposals to be implemented, eircom might be in a position to use pricing of a 2Mb+ leased line as a form of loss leader to support its sale of regulated products. ComReg needs to provide assurances that controls will be put in place to ensure that eircom does not use the relaxation of regulation in certain market sectors to unfairly compete in others. 7

8 6 Retail up to and including 2 Mb (04/59) We agree with ComReg s conclusion for the market for leased lines up to and including 2Mb that eircom is dominant [Q20]. We support the proposals to impose obligations of non-discrimination, costorientation, and cost accounting on eircom [Q38 Q40] We do not support ComReg s proposal to relax the transparency obligations on eircom [Q42]. The current obligations should be maintained. Eircom s very dominant position, as outlined in the consultation paper, would not point to any need for relaxation of regulatory controls. Eircom has in the past repeatedly breached the letter and spirit of publication obligations by, for example, publicly announcing new prices before they are approved by ComReg. This action has had the effect of foreclosing the market for different services, e.g. broadband DSL. ComReg should not allow even greater flexibility for eircom to undermine competition and to flout regulatory controls in this manner. We do not agree with ComReg s proposal to maintain the current practice of not formally approving changes to prices. In the interest of transparency and certainty for all operators, ComReg should introduce a transparent price approval procedure. [Q42]. ENDS 8

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