Online Copyright Infringement – Submissions

The Attorney-General department has finally released the approximately 600 submissions that the public had made to the consultation process of the Online Copyright Infringement discussion paper.

Some journalists were “fortunate” enough to have these submissions physically mailed to them (in all of its 5kg glory). Others, like myself, received them in a slightly more accessible form of scanned PDFs.

I’ve processed roughly ~370 submissions to date. Rather than uploading them as binders with hundreds of submissions like what the Attorney-General’s department did, I have attempted to split the submissions up into separate PDFs. All PDFs have also been OCRed for searchability.

The final ~200 couldn’t be processed because the Attorney-General department accidentally scanned only every second page. I have contacted them in a hope that we can access the last few documents in full.

View ~370 of the separated and ‘OCR’ed submissions here

There may be the odd occasion where multiple submissions are in the same PDF. The process was done semi-automatically… so that is to be expected. Let me know if you find anything, and I’ll fix it 🙂

~ enjoy.

It’s official: NBN Co lowers CVC charges

It’s official. NBN Co released details of their amendment to the Wholesale Broadband Agreement signed by Retail Service Providers, revealing that they will lower the cost of their CVC (connectivity virtual circuit) “from $20.00 per Mbps to $17.50 per Mbps effective 1 February 2015”. In their letter to service providers, available on the NBN Co website, the company says they are “pleased to advise that it will reduce the CVC recurring Charge”.

The CVC is a product purchased by service providers, allowing a fixed amount of data (or bandwidth) to pass through from the NBN network to the ISP’s network. End users within a common point of interconnect share a common CVC to pass the data between networks. If an inadequate amount of CVC is purchased, end users may find their connection to slow drastically during peak hours.

MTM technology guidelines: help crowdfund this FOI request!

Update – Crowd-funding Target Reached!
Thank you to everyone who contributed. I’ll have a quick follow-up blog post up soon.

Do you want NBN Co to release the detailed multi-technology guidelines used to determine which network technology (FTTP, FTTN or HFC) in which areas?

Only a very short summary has been released by the company, and in order to better understand their rollout model, I’ve made a “Freedom of Information” (FOI) request to NBN Co to asking them release the underlying technical guidelines behind the summary.

However, NBN Co is intending to charge $245 for the processing fee of this request… and we need your help to make this request possible!

All the funds raised in this campaign will go towards funding the Freedom of Information request. The costs breakdown charged by NBN Co can be found here on the Right to Know website.

Any financial support towards funding this request would be much appreciated. If successful, it will bring about a better understanding of how NBN Co intends to choose technologies around Australia.

If you’re interested to read more about this request, it can be chronicled here on the Right to Know website.

Important note: Just to add, while I think it’s likely that NBN Co will release this information (as they have already released a summary of it), there is a possibility that the FOI request may not lead to a release of information at all. Depending on what NBN Co decides, the full FOI request charges may still be imposed even if the information is not released.

By donating, you understand that you may not necessarily get a refund of donation even if the FOI request fails. However, I will endeavour to the best of my ability to refund those costs if they are refunded to me by NBN Co.

If you had donated prior to this update, and no longer wish to donate, please let me know. I’d be more than happy to refund the donation.

P.S. I had initially intended to run a Pozible campaign — however, due to age restrictions, it became a bit more problematic. Hopefully this method will be suffice.


Fibre rollout may be one-third less than Strategic Review

(analysis) NBN Co may rollout as little as 16% fibre to the premises under new principles released by the company. Their new guidelines reveal that within the fixed-line footprint, only new developments with over 100 premises or areas where fibre rollout are in advanced stages will likely receive Fibre to the Premises (FTTP). Remaining premises will be served by a mix of HFC and Fibre to the Node or Basement in the fixed-line footprint. This is despite the NBN Co Strategic Review initiated by the incoming Coalition government released 11 months ago suggested that at least 24% of premises in Australia will get FTTP.

Calculations conducted using’s extensive statistics reveal that only around 70 Fixed-line Service Areas (comparable to cities, see tables below) around the whole of Australia are “completed” or “in advanced stages” of the rollout (at least 50% of the rollout modules have at least begun build preparation). This accounts for roughly 1 million premises, or 8% at the end of the rollout in 2020. In addition, NBN Co expects another approximately 1 million premises in new developments (known as greenfields areas) with over 100 premises, accounting for a further 8%1. The total of 16% is roughly one third less than the original 24% suggested in the Strategic Review, or approximately 1 million premises around Australia.

The Government’s statement of expectations mandates the company to provide at least 25 mbps download speeds to all Australian premises with at least 90% of premises in the fixed-line footprint able to get 50 mbps or faster download speeds. NBN Co will only consider installing fibre in areas, not individual premises, where NBN Co finds the existing copper infrastructure to be incapable of delivering speeds required by the mandate. NBN Co is also investigating the possibility for installing fibre in limited “high-profit” areas as well as providing an end-user co-funded “fibre on demand” model.

The figure for greenfields fibre rollout may decrease further as the Government considers new rules that encourage property developers to use alternative fibre providers such as Opticomm.

In previous testimony, NBN Co’s CEO Bill Morrow had indicated that the Fibre to the Premises rollout mix may in fact be higher than that modelled in the Strategic Review:

Bill Morrow: In fact, the number that I recall is a bit higher than that in the early stage of the modelling that we are working on right now.

However, it appears that the modelling has reversed in terms of the number of FTTP premises. In less than 11 months, the multi-technology modelling conducted by NBN Co in their strategic review appears to have been proven to be inaccurate.


NBN technicians

Nextgen’s NBN aggregation closes: should we reconsider 121 POIs?

As a wholesale service provider for NBN Co’s “tails”, Nextgen finally fallen to its knees after they announced order halts, price increases and encouragement to their RSP customers to migrate their customers off its “Virtual Connect” product – in essence, they are closing.

As one of the first providers to provide aggregated wholesale products to Layer 3 retail service providers, Nextgen initially gained footing as a wholesale platform for providers who wanted a mix of UNI-V products as well as data. They sold fixed quota plans to service providers who also marked up the price for a fixed profit. A pretty good deal to dive into the NBN service provider business with little overhead or risks.

As customer numbers grew, however, Nextgen struggled to scale their network to cope with the demand. No doubt the high cost of transit to the multiple NBN points of interconnect and CVC/NNI charges would have played a massive role in this. From the people I’ve spoken to, the network’s quality continued to deteriorate over the years. I suspect for most areas, they didn’t have the numbers or the capacity to purchase CVC and transit above that of the 150Mbps “CVC credit” provided by NBN Co.

However, as the market for wholesale service providers grew (especially with the rise of AAPT’s Layer 3 National Wholesale Broadband product), many Layer 3 providers began to shift to this alternate platform which gave them control over contention and network capacity. The AAPT product is a whole different ball game with the risk of contention falling right at the hands of the service provider. Also, AAPT’s recent introduction of their “NBNPhone” product meant that Layer 3 providers no longer had to rely on Nextgen to get provide UNI-V services to their customers.

What now?

Well, what now? It’s obvious that without solid customer numbers, a network provider would struggle to get into the game of wholesale service for NBN. With the investment required to get transit and CVC/NNI at each of the 121 Points of Interconnect, it’s unlikely that this will change in the near future.

While I know providers like Telstra Wholesale and Optus Wholesale all provide Layer 2 products for resellers, I don’t know if they provide the all-in-one “Layer 3” product that many start-up RSPs need in order to get started. Start-up providers rely on these Layer 3 products and simply don’t have the funds or resources to buy and set up their own co-lo equipment and their own upstream bandwidth at the IX level.

Final thoughts

With Nextgen now out of the game, this leaves AAPT and (I think) M2 Wholesale in the running to attract RSPs for Layer 3 products. Despite ACCC’s intentions, the 121 POI decision has actually led to decreased competition at the wholesale aggregation level. Oops.