25 September 2013 Ms Aileen Chia Deputy-Director General (Telecoms & Post) Infocomm Development Authority of Singapore 10 Pasir Panjang Road #10-01 Mapletree Business City Singapore 117438 By Email:
[email protected] Dear Ms Chia, CONSULTATION PAPER ISSUED BY THE INFO-COMMUNICATIONS DEVELOPMENT AUTHORITY (“AUTHORITY”) OF SINGAPORE LONG FORM CONSOLIDATION APPLICATION SUBMITTED BY OPENNET PTE LTD (“OPENNET”), NETLINK TRUST, CITYNET INFRASTRUCTURE MANAGEMENT PTE LTD (“CITYNET”) AND SINGAPORE TELECOMMUNICATIONS LTD (“SINGTEL”) 1. The Asia Pacific Carriers‟ Coalition, M1 Limited, MyRepublic Pte Ltd, Nucleus Connect Pte Ltd, StarHub Ltd, SuperInternet Access Pte Ltd, and ViewQwest Pte Ltd (the “Operators”) hereby jointly submit this response to the Authority‟s public consultation. 2. We believe that the approval of the proposed consolidation application would have a significant negative impact on the Next-Generation Broadband Network (“Next-Gen NBN”) and its strategic objectives, on customers, and on competition in the Singapore telecommunications market. 3. For reasons stated in this response, the Authority should not approve the consolidation. Further and/or in the alternative, in the event the Authority decides to approve the consolidation, it must impose stringent Conditions on SingTel, OpenNet and CityNet, to safeguard the public interest. The Authority must also establish significantly improved Quality of Service (“QoS”) and performance guarantees, to ensure that customers benefit and competition is not substantially lessened. Page 1 of 38 The Next-Gen NBN – the objective and vision of the Next NGN has yet to be realised more than 3-years after OpenNet’s service launch 4. The Next-Gen NBN was intended to represent an alternative and ubiquitous fibre network, which would allow open access to all industry players.