Level 3 Communications Issues Statement ConcerningComcast'sActions

Mikael Abrahamsson swmike at swm.pp.se
Tue Nov 30 03:52:34 CST 2010

On Tue, 30 Nov 2010, Joly MacFie wrote:

> Afterwards, I asked her about the effect of competition. She remarked 
> that, according to her research, countries with competition, such as the 
> Euro unbundling regimes like the UK, actually had a much higher 
> likelihood of such network management practices that the duopolist USA 
> as the providers were under greater pressure to optimize the economic 
> value of every bit put through.

I am not expert on the UK market, but I'd say the UK is a bad example of 
infrastructure unbundling.

For unbundling to be successful, there needs to be the possibility of 
having rented (decent price) L1 connectivity to the COs as well as L1 to 
the customers. Without all of this in place, true competition can't 

One needs to look at the whole supply chain so that there is L1 all the 
way, as soon as someone puts L2 or higher equipment in the way and there 
is only 1-2 suppliers of this "service", it doesn't matter if you have a 
bazillion ISPs, the market still won't work.

Recipe for success is to have a neutral entity whose business idea is to 
rent out fiber to anyone who wants to rent it, and who goes all the way to 
residential customers. Aggregate at nodes with several thousand households 
and let ISPs colocate at these nodes to reach end users.

Think COs but instead of copper, use fiber, and the entitity who owns this 
doesn't do anything but L1.

Mikael Abrahamsson    email: swmike at swm.pp.se

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