Space Management Part II

1
Space Management Part II

• Grooming, Market Share Assessment
  Rationalisation

2
Draft STD space management is costly, difficult
and impractical

• Key elements of TCF paper, which were reflected
  in STP, have been overlooked in the draft STD
• The space management components of grooming,
  market share assessment and rationalisation are
  too complex and would drive cost into Chorus and
  our customers
• Some of the key processes are simply unworkable

3
Key TCF Recommendations have been overlooked

• The TCF recommended funder priority in new
  cabinets to give those who fund a cabinet
  confidence that they can utilise the space they
  require for their business case. This was
  overlooked by the Draft STD.
• The TCF agreed First come first served (after
  funder priority). The Draft STD makes this
  conditional on an overriding 50 cap and a
  complicated market share assessment.
• The TCF agreed Use it or lose it for inactive
  equipment and specifically dismissed
  rationalisation as being too costly and
  disruptive. The Draft STD introduces
  rationalisation of space to reflect market share.

4
Draft STD space management is too complex and
costly to operate

• The draft STD introduced a complex and
  impractical space management regime, that will
  require considerable resource to manage. The
  regime includes
• Preliminary, conditional and final orders all
  with notification requirements
• Guaranteed occupancy notices and period
  management
• Market Share assessments
• Rationalisation notices and
• Grooming notices
• The complexity of the process would generate
  confusion, be costly and very difficult to
  manage, and drive errors and disputes.
• Importantly, the regime would not solve the
  problem it seeks to address. Complex cabinet
  co-location situations cannot be sensibly
  addressed by complicated and inflexible rules.

5
Market Share process is impractical

• The Market Share Assessment process is used at
  several points to determine space available for
  allocation. As the organisation required to
  manage the regime, Chorus does not consider it to
  be workable, as
• Cabinets are small and DSLAM equipment comes in
  fixed sizes, not variable to match market share
  percentages
• Chorus has no visibility of the wholesale market
  data required for the calculation and no way of
  validating information provided by our customers
• Once calculated, the result may be vetoed by the
  cap
• The Market Share assessment is locked in for a
  year so could limit growth to 25 per annum
  whereas some areas experienced growth of greater
  than 100 per annum and
• Ignores SLES exchange based services.
• The TCF agreed a market share allocation in some
  cases. This will need further consultation on the
  impact of information sharing under operational
  separation.

6
Space management should not be prescriptively
regulated

• Grooming and Rationalisation can be costly and
  disruptive
• Service outages required to relocate either
  equipment or termination blocks must be
  coordinated with Chorus, our customers and end
  users
• Chorus must be able to recover the cost of
  grooming from our customer requesting the groom
  as we have no other way to fund this expenditure
• It may not be practical for our customer to
  rationalise equipment and hard rules may produce
  perverse results. Cabinet co-location is a
  complicated business case, not suited to
  one-size-fits-all rules.
• Case by case solutions will be more sensible in
  the circumstances.
• Our customers have indicated that 10 days is far
  too short a timeframe in which to rationalise
  their equipment.
• The sensible solution is to give Chorus the
  chance to work with our customers to develop
  workable, cost effective solutions in each case.

7
Space management and rationalisation

• Rationalisation is complex and, as our customers
  have indicated, will require long lead times.
• Those leads time may vary from case to case.
• Our customers may have to relinquish end-users
  where, for example, they are required to
  rationalise equipment that cannot support all
  their customers, or where they have gained
  customers between the date of the market share
  assessment and the date of rationalisation.

8
Space management by Chorus

• We support all the agreements made by the TCF,
  including
• Funder priority
• First come first served
• Use it or lose it
• Chorus is a professional network operator acting
  in its own commercial interests. Were in the
  business of providing co-location space to our
  customers.
• The operational process should be sufficiently
  flexible to allow solutions to be tailored to our
  customers circumstances, achieve cost
  efficiencies and reduce the risk of errors and
  disruptions.
• We need the flexibility to manage our cabinets
  effectively and meet our customers needs. We
  should not be required to implement complex rules
  which may drive perverse outcomes.