Can the L1 provider offer L2 services?

Owen DeLong owen at delong.com
Sat Feb 16 06:22:43 UTC 2013


On Feb 15, 2013, at 18:55 , Jay Ashworth <jra at baylink.com> wrote:

> ----- Original Message -----
>> From: "Owen DeLong" <owen at delong.com>
> 
>>> With BT/OpenReach's FTTC and FTTP there's no difference in terms of
>>> layer 1 unbundling - it's impossible with either as they are both
>>> shared mediums aggregated before the exchange.
>> 
>> Which is a classic example of why I say the L1 provider must not be
>> allowed to participate in or act as a related party to the L2+
>> providers.
> 
> Submitted: you're saying, Owen, that L2+ providers should not be able
> to own the L1.  I agree with that, and the case in point example is here:
> 
>  http://money.cnn.com/video/technology/2010/03/15/tech_tt_fiber_fios.cnnmoney/
> 
> That's orthogonal to the question as we discussed it before, though, 
> which is what I've adjusted the title to here: I don't see that there
> is a bar to competition if a *municipal* L1 provider offers L2 service,
> as long as they offer that service to all comers, at the same, published,
> cost-recovery rates, including themselves.
> 

I don't see a difference between an L1 provider offering L2 service and
an L2 provider owning L1 infrastructure. The problem is that the minute
you give an organization an ability to compete with its customers for
product (A) as customers for product (B), you create a conflict of interest.

If company A offers L1+L2 and company B offers L2 and up, then company
A has an incentive to provide better L1 service to those who are also getting
their L2 from company A than they might provide to those company B's
L2 customers using only the L1 product from company A.

> Arguments can be made about "whose tickets take priority" and such, but
> those seem easy to hand: FCFS.

FCFS sounds like a great theory, but the devil is in the details. Since many
tickets are always being processed in parallel and since there will be
inevitable shuffling of ticket priorities due to standard externalities
(there are always customers you have to take care of more than others,
etc.).

The more thought I give to this question, the more I think that the L1 provider
should be strictly L1 only and not allowed to affiliate with anyone higher
up the stack.

Owen





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