ComCom decision a win for government

COMMENT

The Commerce Commission has released its final determination on UBA pricing and the figure comes in at the high end of the range at $10.92 per line per month.

That means the total any ISP will pay for wholesale service is $34.44 per line per month, down from $44.98.

Chorus is very unhappy about this and will no doubt call for a FPP (a Final Pricing Principle) review. That won’t stop this figure coming into effect from December next year, but could result in a change to that number by the end of the following year. An FPP process requires the Commerce Commission to build an economic model to consider the actual costs to Chorus of providing this service. Chorus will hope the number will be substantially higher, but given we know how much it actually costs CallPlus to deliver the same service in the market today, it’s just as likely to be much lower.

The government  has said it will consider its options before making a decision on what to do next, and that’s a sensible call to make. We’re coming into an election year and trying to justify hiking the price of broadband from $34.44 a month to its preferred range ($37.50 to $42.50) is going to take some explaining.

The good news is, it doesn’t have to. The Commission has already given them exactly what they asked for.

UBA isn’t a single product – it’s a suite of products, and the basic UBA service (BUBA) has indeed been priced at $10.92 per line per month.

BUBA has no contention ratio to speak of. It’s a low-cost, entry level product that simply won’t do in this day and age for anything beyond a basic service.

Enhanced UBA (EUBA, rhymes with tuba) offers a less contended service. The CIR (Committed Information Rate) ranges from 40kbit/s through to 180kbit/s for the aptly named EUBA180 product.

That level of CIR might seem woeful – and it is – but it puts EUBA180 somewhat closer to the entry level 30/10 fibre product which the government is using as its benchmark in the fibre world. Entry level fibre has a CIR of 2.5Mbit/s which is a lot better than copper UBA provides.

The argument goes like this – if copper and fibre are similar in terms of service they should be similar in terms of price, that way customers will be able to migrate smoothly to fibre without any problem. You won’t stay on copper because it’s just as good but cheaper – you’ll migrate as and when you can.

EUBA180 is the closest UBA product to entry level fibre and EUBA180’s price, as determined by the Commerce Commission today, is $14.85 per line per month – well within the government’s price range.

The solution to both Chorus and the government’s problem is simple – encourage all customers on to EUBA180 and the discrepancy is resolved. Chorus will get its money, the government will get its fibre network, customers have the pricing and capability they deserve and, most importantly in my view, the Commerce Commission retains its independence and oversight.

Copper and fibre aren’t the same product any more than black and white television is the same as colour. We all know that, and the service specifications spell it out. But if we are comparing one with the other it’s important we compare not just headline rates, but what’s actually being sold to customers.

You could argue that EUBA180 is still less than a tenth of the CIR of entry level fibre and that it should be one tenth the price – we’ll argue that another day, but for now the government can claim victory and leave the market to get on with providing better services at better prices.

The telco world is made up of numerous silly terms - unfortunately we'll have to use a few here.

CIR - committed information rate. That is, the bare minimum speed your connection will run at if the line is fully loaded. 

UBA - Unbundled Bitstream Access. Basically part of the service that delivers wholesale broadband access.

EUBA - Enhanced UBA - a better version of the same product. The CIR is higher so even at full capacity, you'll still get a relatively good connection rate.

Paul Brislen is CEO of the Telecommunications Users Association of NZ