• Home
• ICT
• Telecommunications
• Operational Separation
• Operational Separation process
• Consultation Document
• 12. Summary of Key Questions

• Telecommunications

• Operational Separation

• Operational Separation process

• Side letter - info disclosure
• Telecom's side letter - rural
• Minister's letter to Telecom
• Telecom's Separation Plan
• Notice of Requirements
• Submissions on Telecom’s
• The Amending Determination
• The Amended Separation Plan
• Submissions on Undertakings
• T'com Draft Plan
• Determination
• Submissions Regarding Telecom
• Consultation on T'com Proposal
• Submissions
• Consultation Document
• Background Documents
• Media Statements

1. Do you see any value in the Minister specifying additional objectives and outcomes in his Determination of further requirements for Telecom's separation undertakings?

Key Questions – Structural Requirements

2. Do you have any comments on the high-level role of the Access Network Services (ANS) Unit as described in section 6.2.1?

3. Do you have any comments on the services that the ANS Unit will be providing to wholesale customers as described in section 6.2.2, in particular, whether:

1. Services and assets should be closely aligned such that the ANS will not include "value added" services such as basic telephone services and number portability as discussed in section 6.2.2.1?
2. Or whether leased lines and partial private circuits should be excluded or included from the ANS Unit as discussed in section 6.2.2.1?

4. Do you have any comments on the assets that the ANS Unit will be controlling as described in section 6.2.3 and Appendix 1? In particular:

1. The inclusion of regional backhaul assets as discussed in section 6.2.3.1?
2. The inclusion of transport electronic assets as discussed in section 6.2.3.2?
3. The inclusion of fibre and future assets as discussed in section 6.2.3.3?

5. Do you have any comment on the people that will be included within the ANS Unit as described in section 6.2.4?

6. Do you have any comments on the services, assets, and people to be included within the Wholesale Unit as described in section 6.3?

Key Questions - Equivalence Standards for Service Delivery

7. Do you have any comments on whether Equivalence of Inputs (EOI) should be the preferred equivalence standard for service delivery as described in section 7.1?

8. Do you have any comments on the services that EOI is being applied to as described in section 7.2? In particular:

1. Do you have any comments on applying EOI to LLU and unbundled bitstream access services as described in section 7.2.2?
2. Do you have any comments on applying EOI to future regulated fixed network services as per the approach described in section 7.2.3?
3. Do you have any views on applying equivalence to resale services, in particular, basic telephone service as discussed in section 7.2.4?

9. Do you have any comments on the preferred approach to applying equivalence in the development and lifecycle of services as described in section 7.3?

Key Questions - Governance and "Arms-Length" Requirements

10. Do you have any comments on the proposed governance arrangements, arms-length requirements and reporting lines as described in section 8.1? In particular:

1. The management and reporting lines for the ANS and Wholesale Units as described in section 8.1.1?
2. The setting and implementing of ANS Unit policies as described in section 8.1.2?
3. The "arms-length" rules as described in section 8.1.3?
4. The staffing restrictions for ANS and Wholesale and the role of shared corporate functions as described in section 8.1.4?

11. Do you have any comments on the proposed approach to sharing information and influencing commercial policy as described in section 8.2?

12. Do you have any comments on the preferred approach to incentive arrangements as described in section 8.3?

13. Do you have a view on the extent to which separate accommodation and branding should be required in respect of the ANS Unit, or whether separate accommodation should be required in respect of the Wholesale Unit, as discussed in section 8.4?

Key Questions – Enforcement and Oversight

14. Do you have any comments on the proposed requirements for the IOG as described in section 9.1, in particular:

1. Do you have any comments on whether the functions of the IOG and with the Commission as described in section 9.1.1 will strike an appropriate balance and be effective in facilitating compliance with the undertakings?
2. Do you have any comments on the establishment and appointment of the IOG as described in section 9.1.2 will be effective in facilitating public and industry confidence in the IOG?
3. Should the Commerce Commission have any role in approving appointees to the IOG, or should this role be limited to consultation?

15. Do you have any comments on whether the reporting and transparency requirements, as described in section 9.2, are likely to be effective in facilitating transparency and compliance with the undertakings?

16. Do you have any comments on the value of an explicit exemption or exceptions process for the Commerce Commission to deal with technical breaches and/or minor implementation issues as discussed in section 9.3 is necessary?

Key Questions – Implementation

17. Given the wider regulatory context and potential trade-offs from EOI implementation as described in section 10.1, which EOI services do you consider should be implementation priorities?

18. Do you have any comments on mechanisms for ensuring the undertakings remain relevant over time as discussed in section 10.2?

Key Questions – Other Issues

19. Do you have any comments on the need for an industry consultative process to address NGN interconnection, service interoperability and related issues in New Zealand?

20. If so what do you consider should be the scope of NGN issues?

21. Do you have any other comments on any other matters described or arising from this consultation document?