Transparency may be the new motto at NBN Co but the company building the National Broadband Network (NBN) has slowly but steadily reduced the technical information available to the public about how the network is to be built. And why the updated Design Rules have not been released is discussed in Business Spectator with an explanation of why the Design Rules are an important aspect of the NBN debate.

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Transparency may be the new motto at NBN Co but the company building the National Broadband Network (NBN) has slowly but steadily reduced the technical information available to the public about how the network is to be built.

Key tenders worth more than $500 million have been sent to select vendors without the media being informed, technical documents including the NBN Design Rules have not been updated to include the multi-technology mix (MTM) NBN technologies, nor released for public scrutiny.

It does beg the question about the validity of the Abbott government’s mantra that the NBN rollout will be “open and transparent”.  Is NBN Co simply trying to prevent public scrutiny of the underlying network architecture to hide weaknesses with the technology selection and network design?

NBN design scrutiny is important

The NBN is a national wholesale access network that is to provide Australians with improved broadband access to the online world for both business and pleasure. It is vital therefore that the NBN be designed using key criteria such as connection speeds, traffic class management, Quality of Service (QoS), capacity, and a low-cost upgrade path that’s compatible with the existing NBN and provides flexibility for telcos, service providers and customers.

The NBN should be built with resiliency, redundancy and enough capacity to ensure that customers don’t have to suffer connections slowing to a crawl during peak hours which is a phenomena experienced daily right across the nation. And the NBN should have enough capacity to be able to cope with increased demand due to changes to the broadband landscape.

Netflix’s entry in the Australian market and the kerfuffle it has caused is just the latest symptom of the pressure the growth in media streaming is placing on our existing infrastructure. In the US Netflix and YouTube now account for more than 50 per cent of internet traffic and in Australia Netflix has grown to more than 20 per cent of internet traffic in its first month of operation.

As streaming becomes mainstream total Australian network traffic should grow this year at a rate faster than that experienced at any time in our history and our telcos should have been prepared. The recent broadband speed slowdowns experienced by iiNet customers apparently due to the growth in media streaming is exactly the type problem that NBN Co must ensure that it does not become responsible for in the future.

Fairfax recently reported that iiNet network services manager Roger Yerramsetti told readers on a Whirlpool forum that "In some areas we're seeing network traffic reach levels that were projected to occur well over 6 months from now, so under the bonnet we have been rapidly upgrading our network to keep pace with the demand and to ensure we're continuing to provide a high quality service."

Missing multi-technology mix design rules

During a talk at the Committee for Economic Development of Australia business luncheon held in September 2014, NBN Co chairman Dr Ziggy Switkowski indicated that NBN Co would release updated network design rules early in 2015.

NBN Co’s design rules were last updated in July 2014 and provided to the Australian Competition and Consumer Commission (ACCC) “pursuant to and for the purposes of NBN Co’s Special Access Undertaking.”

The ACCC is still working through NBN Co’s new agreement with Telstra and NBN Co could be sitting on revised Design Rules until the ACCC has made a determination and is ready for a variation to NBN Co’s Special Access Undertaking (SAU). However if this is the case, the opportunity for public scrutiny of the NBN Design Rules is being lost at a time when NBN Co is stitching up major contracts for its HFC and FTTN/VDSL2 access networks.

Irrespective of the reason, NBN Co should release the Design Rules, even if the document is a draft, so that there can be an informed debate about how NBN Co will upgrade and build the HFC and FTTN/FTTB components of the NBN.

There needs to be greater technical scrutiny of the NBN. An example of the technical nonsense appearing in the Coalition government’s NBN related documentation is the definition of “adequately served” in the Telecommunications (Migration Plan Principles) Determination 2015 that was signed off by the Communications Minister Malcolm Turnbull on 21 January 2015.

“adequately served in respect of a premises, means:

1. that premises is capable of being connected to a network (Alternative Network) to receive fixed-line carriage services where:
2. that Alternative Network is used, or is capable of being used, to supply a carriage service where the download transmission speed of the carriage service is normally more than 25 Mbps; and
3. a Layer 2 bitstream service (as defined in the Act) is available for supply to carriage service providers by the owner or operator of the Alternative Network by virtue of that Layer 2 bitstream service being declared by the ACCC under Part XIC of the Competition Act or otherwise being required by law to be supplied on the Alternative Network; and
2. either:
3. that Alternative Network is a Telstra fibre network which is capable of supplying a standard telephone service under the universal service obligation and Telstra has connected the premises with a fibre line; or
4. that Alternative Network is not a Telstra fibre network but is capable of supplying a standard telephone service which would enable Telstra to perform its universal service obligations and is connected to the premises with a fixed line; and
3. that premises is:
4. not passed;
5. not connected only by a copper line which is owned by Telstra;
6. not connected only by a copper line which is owned by Telstra and a line that is part of the hybrid fibre-coaxial network or a line connected to the Optus HFC Network;
7. not connected only to the Optus HFC Network; or
8. in the fixed footprint list for any rollout region at any time.

What this means is premises are deemed to be adequately served if they’re “capable of being connected to a network” that can be used “to supply a carriage service where the download transmission speed of the carriage service is normally more than 25 Mbps”.

What does “where the download transmission speed of the carriage service is normally more” actually mean? Does it mean that the network is to provide more than 25 Mbps download for 13 hours per day and for the rest of the day the download transmission speed can slow to a crawl? Does it mean that for 50.1 per cent of consumers the download speed is normally more than 25 Mbps and it does not matter if the remaining 49.9 per cent get less?

With such a definition in place, it would be impossible to hold NBN Co to account if it were to provide Australians with the worst “new” broadband access network in the world.

Failure to provide a technical meaningful definition of “adequately served” provides a strong indication of the exceedingly weak technical documentation released by the government and NBN Co since the last Federal election, but to be fair some of the earlier NBN related documentation was just as technically weak. Perhaps this an indication that engineers are being sidelined in favour of spin-doctors.

The lack of meaningful technical key design criteria, such as capacity, upload and download speeds, traffic management, QoS, and low-cost upgrade path, indicates that the government , and by association NBN Co, are using meaningless language rather than the precise technical definitions that should be found in documentation about a telecommunications infrastructure rollout.

A successful completion to the NBN rollout is, according to the definition of the “End of the Rollout Date”, when “the number of premises that have been either passed or adequately served is at least 92 per cent of the number of premises in Australia as at that date.”

Here we go again. Many Australians live in suburbs where premises are “passed” by HFC, yet cannot get HFC connected for one reason or another. The rollout should not end until “at least 92 per cent of the number of premises in Australia as at that date” are connected to the NBN or there is a legislated guarantee that premises will be connected to the NBN when requested by residents. Why should Australians expend $43 billion only to find 15-30 per cent of consumers cannot get connections similar to the areas deemed to have HFC now?

No excuses

Now that NBN Co is on its path to incorporate the existing HFC access network and to have a substantial new FTTN/VDSL2 access network it’s even more important to have a technology and design debate than would be necessary if the NBN were to be built using fibre-to-the-premises (FTTP). But it’s not just about the last mile so there is a need to scrutinise the aggregation, transit and points of interconnect (PoIs) as well.

NBN Co has been asked monthly for the new or draft design rules and other associated technical documents that will provide an engineering perspective on what the MTM NBN will look like but NBN Co has indicated the documents are not yet ready for release. How can this be? How can NBN Co release tenders worth more than $500 million (possibly several billion dollars) without an engineering solution?

There can be no reasonable excuse for NBN Co’s failure to publish the updated final or draft Design Rules and associated technical documentation. 

Mark Gregory is a Senior Lecturer in the School of Electrical and Computer Engineering at RMIT University.