UNI-DSL Specification as maintained by NBN Co

Cameron Watt made this Freedom of Information request to NBN Co Limited

The request was partially successful.

From: Cameron Watt

Delivered

Dear NBN Co Limited,

I seek access to UNI-DSL Specification which defines the minimum performance and functionality for CPE to be used and registered on the NBN Co network.

Specifically I request the specification as it exists or is expected to exist at the time of launch in the following NBN Co published documents.

WBA Product Catalogue - Product Technical Specification – NBN Co Ethernet Bitstream Service - FTTB (http://www.nbnco.com.au/content/dam/nbnc... dated 24-08-2015

and

7/08/2015 notification – WBA Product Catalogue - Product Description - NBN Co Ethernet Bitstream Service (clean) (http://www.nbnco.com.au/content/dam/nbnc... FTTN Commercial Launch Date*

Yours faithfully,

Cameron Watt

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From: FOIOfficer
NBN Co Limited


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Attachment 02A.Request to Clarify.pdf
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UNCLASSIFIED

Dear Mr Watt,

 

Please see the attached in relation to your request.

 

Kind regards,

 

An Vo

Associate Legal Counsel – FOI, Privacy & Knowledge Management

P +61 2 8918 5655 | M +61 0408 253 295 | E [1][email address]

Level 11, 100 Arthur Street, North Sydney NSW 2060

Level 40, 360 Elizabeth Street, Melbourne VIC 3000

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From: Cameron Watt

Delivered

Dear An Vo,

I am writing to provide clarification to my original application as requested and in light of the recent updates and/or changes to the WBA2 documents referenced.

For simplicity's sake, I refer you to the "WBA Product Catalogue - Product Technical Specification – NBN Co Ethernet Bitstream Service - FTTB/FTTN" document that is available from the following webpage http://www.nbnco.com.au/sell-nbn-service... at the time of writing.

I would like to amend my request for copies of or answers to the following;

1. a)
The number of current "VDSL2 Equipment" registrations as it relates to section "7.1 VDSL2 Registration"

1. b)
The list of registered "VDSL2 Equipment" and their registration information, including VDSL2 Equipment Vendor ID, System ID, Version Number and clear-text name as it relates to section "7.1 VDSL2 Registration".

2.
The current "UNI-DSL specification" maintained by NBN Co and referred to in section "7.2 UNI Specification".

Yours sincerely,

Cameron Watt

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From: FOIOfficer
NBN Co Limited


Attachment 05A.Further Request to Clarify.pdf
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UNCLASSIFIED
Dear Mr Watt,

Please see the attached in relation to your email below.

Kind regards,

An Vo
Associate Legal Counsel – FOI, Privacy & Knowledge Management
P +61 2 8918 5655 | M +61 0408 253 295 | E [email address]
Level 11, 100 Arthur Street, North Sydney NSW 2060
Level 40, 360 Elizabeth Street, Melbourne VIC 3000
             
 
Notice to recipient: This e-mail is intended only to be read or used by the addressee. It is confidential and may contain information that is subject to legal professional privilege or protected by copyright. If you are not the addressee indicated in this message (or responsible for delivery of the message to that person), you may not copy or deliver this message to anyone, and you should destroy this message and kindly notify the sender by reply e-mail. Copyright, confidentiality and legal professional privilege are not waived or lost by reason of mistaken delivery to you. Emails to/from nbn co limited ABN 86 136 533 741 may undergo email filtering and virus scanning, including by third party contractors, however, nbn co limited does not guarantee that any email or any attachment is secure, error-free or free of viruses or other unwanted or unexpected inclusions. Any views expressed in this message are those of the individual sender, except where the sender specifically states them to be the views of nbn co limited.
PLEASE CONSIDER OUR ENVIRONMENT BEFORE PRINTING

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From: Cameron Watt

Delivered

Dear An Vo,

I have reviewed the document you linked regarding the "specification of the UNI-DSL interface" as mentioned in Section 7.2 on page 43 of linked document.

The document unambiguously states that the "specification" consists of three parts which are listed in Section 7.2 as;
* a DSLAM chipset and firmware list;
* a list of mandatory DSL and OAM Features that the VDSL2 Equipment must support; and
* a minimum rate-reach performance specification that the VDSL2 Equipment must achieve.

The document does not list DSLAM chipset or firmware, as such I do not see how it could be considered the complete "specification" in its entirety.

For further clarification, I am seeking the complete definitive specification as would be needed should I want to make available "VDSL2 Equipment" subject to registration for use with NBN Co UNI-DSL services.

I trust part 1(a) and 1(b) required no further clarification and will be considered in addition to the above.

Yours sincerely,

Cameron Watt

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From: Cameron Watt

Delivered

Dear An Vo,

I would like to confirm that I have adequately clarified my request and that you do not require anything further from me at this stage.

If you do require anything further please advise.

Yours sincerely,

Cameron Watt

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From: FOIOfficer
NBN Co Limited


Attachment 08A.Joint Ack ADR Letter and Third Party Extension.pdf
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UNCLASSIFIED
Dear Mr Watt,

Please see the attached in relation to your FOI request.

Kind regards,

An Vo
Associate Legal Counsel – FOI, Privacy & Knowledge Management
P +61 2 8918 5655 | M +61 0408 253 295 | E [email address]
Level 11, 100 Arthur Street, North Sydney NSW 2060
Level 40, 360 Elizabeth Street, Melbourne VIC 3000
             
 
Notice to recipient: This e-mail is intended only to be read or used by the addressee. It is confidential and may contain information that is subject to legal professional privilege or protected by copyright. If you are not the addressee indicated in this message (or responsible for delivery of the message to that person), you may not copy or deliver this message to anyone, and you should destroy this message and kindly notify the sender by reply e-mail. Copyright, confidentiality and legal professional privilege are not waived or lost by reason of mistaken delivery to you. Emails to/from nbn co limited ABN 86 136 533 741 may undergo email filtering and virus scanning, including by third party contractors, however, nbn co limited does not guarantee that any email or any attachment is secure, error-free or free of viruses or other unwanted or unexpected inclusions. Any views expressed in this message are those of the individual sender, except where the sender specifically states them to be the views of nbn co limited.
PLEASE CONSIDER OUR ENVIRONMENT BEFORE PRINTING

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David left an annotation ()

It's absolutely unreasonable that they now want to charge you for 22 hours of decision time as to whether to release a document that on 2 October they told you was already part of a public document on their website!!

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Matt Carter left an annotation ()

From NBNCo

UNCLASSIFIED
Hi Guys

The FTTB/N VDSL spec referenced in the Solution Brief is part of the WBA set of documents available at the following link.
http://www.nbnco.com.au/sell-nbn-service...

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From: Cameron Watt

Delivered

Dear An Vo,

I have received your response indicating that my FOI request has been assessed and the fee determined to be $370, the majority of which is decision making time.

I am surprised it was determined that 22 hours decision making time was required, presumably for the purpose of consultation with third parties.

I would contend that there would be no expectation of privacy of the registration data as requested in my application, the NBN Co documents make no mention of confidentiality of the information. Together with the fact that it is a registration database of equipment for use on a nominally government owned network.

I ask that the consideration be given to reducing the decision making time and/or waiving the fee levied.

Whatever the fee, I would like to claim a public interest exemption. I have been following the NBN Co’s rollout and I am aware that the lack of the information being available in the public domain is having a detrimental impact on end users, even at this early stage.

I believe the public interest exemption is applicable as the NBN Co Corporate Plan 2016 indicates that 38% of premises will be serviced by UNI-DSL (FTTN/FTTB) by completion or 4.5 million premises. This could conservatively affect 10 million people, which I believe qualifies as public interest.

End users will find the information requested in this FOI helpful as end users will pay for the UNI-DSL modem directly or indirectly. So any opportunity for end users to reuse existing premium equipment they might have is in their own interest. Particularly given that there may be unanticipated ramifications of using unregistered “VDSL2 Equipment” for fault finding or debugging.

I have already seen issues relating to “VDSL2 Equipment” for use on the nbn for a number of reasons, not limited;
* Some RSPs are not providing end users with the “VDSL2 Equipment” for use on the nun, leaving the end user to source it,
* Some RSPs provide reduced/limited feature set “VDSL2 Equipment” but the end user wants additional features or control (e.g. different VOIP provider)
* Some employer’s require their employees (nbn end users) to use employer provided hardware for integration with their IT systems (e.g. managed VPNs etc)
* Some end users have existing premium hardware that might have bee tested and registered since the time of purchase or might in the future by firmware upgrade
* End users may need to update the firmware of their registered “VDSL2 Equipment” for additional finality or bug fixes, knowing what newer firmware is registered is helpful.

Although the above is a brief and non-exhaustive list of issues, I think it is pretty clear that the information requested in this FOI will be of significant public interest.

I will be making this information readily available for public access, but also NBN Co will be required to publish this information as well under the Disclosure Log requirements.

I look forward to the release of the information requested.

Kind regards,

Cameron Watt

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From: Cameron Watt

Delivered

Dear An Vo,

Could you please acknowledge receipt of my previous response sent on the 9th November 2015 as can be found here, https://www.righttoknow.org.au/request/u...

Yours sincerely,

Cameron Watt

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From: FOIOfficer
NBN Co Limited

UNCLASSIFIED
Dear Mr Watt,

Thank you for your email. Yes, we also received your response on 9 Nov 2015.

A member of the nbn FOI team will issue a charge decision in relation to your FOI request in due course.

Kind regards,

An Vo
Associate Legal Counsel – FOI, Privacy & Knowledge Management
P +61 2 8918 5655 | M +61 0408 253 295 | E [email address]
Level 11, 100 Arthur Street, North Sydney NSW 2060
Level 40, 360 Elizabeth Street, Melbourne VIC 3000
             
 
Notice to recipient: This e-mail is intended only to be read or used by the addressee. It is confidential and may contain information that is subject to legal professional privilege or protected by copyright. If you are not the addressee indicated in this message (or responsible for delivery of the message to that person), you may not copy or deliver this message to anyone, and you should destroy this message and kindly notify the sender by reply e-mail. Copyright, confidentiality and legal professional privilege are not waived or lost by reason of mistaken delivery to you. Emails to/from nbn co limited ABN 86 136 533 741 may undergo email filtering and virus scanning, including by third party contractors, however, nbn co limited does not guarantee that any email or any attachment is secure, error-free or free of viruses or other unwanted or unexpected inclusions. Any views expressed in this message are those of the individual sender, except where the sender specifically states them to be the views of nbn co limited.
PLEASE CONSIDER OUR ENVIRONMENT BEFORE PRINTING

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From: David Mesman
NBN Co Limited


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Attachment 11A.Final Fee Decision.pdf
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UNCLASSIFIED

Please find attached a decision in relation to your fee reduction/waiver
request.

 

If you have any questions, please don’t hesitate to contact me on the
number below or via email.

 

Best regards, DJM

 

David J Mesman

General Counsel – FOI, Privacy & Knowledge Management

P +61 2 8918 8596| E [1][email address]

Level 10, 100 Arthur Street, North Sydney, NSW 2066

[2]cid:67DF297C-E4F7-4057-B96D-81E38821B52C   
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[8]cid:4EA8D93D-C8C4-4162-BD29-AFDAA18B3714

 

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From: Cameron Watt

Delivered

Dear David Mesman,

Please note that I wish to proceed with my request and as such have paid the deposit of $92.50 by electronic funds transfer

Having said that, I would like to register my disappointment with your method for determining public interest by looking for mainstream media reports.

The mainstream media is notorious for being poorly informed regarding the NBN and the challenges endusers might face. I believe mainstream media will eventually become aware of the issue, even if they not at the yet aware.

Yours sincerely,

Cameron Watt

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Matt Carter left an annotation ()

Dear David Desman,

I have been watching this case with interest. I note your correspondence to Mr Watts. You stated that "On balance, I am not persuaded that a fee waiver or reduction is appropriate in this instance." and "This was reinforced by
a summary review of various media sources, which found no general coverage related to the Requested Information. While not determinative, the lack of recent or any significant media coverage by major news publication websites suggests that the provision of access to the Requested Information would not be in the
general public interest or be in the interest of a substantial section of the public."

Firstly, I would like to take this opportunity to point out to you the obvious "Catch 22" or "Chicken and Egg" situation that you present to the Applicant. In all likelihood it is quite possible that information provided as part of the FOI request will drive media engagement and news articles on the subject. Therefore, looking at what media articles exist on the subject today when making your determination is great for subjects which have already been brought to the public attention, however this works against an FOI applicant who is undertaking investigation on a matter which may not have been brought to the public attention.

Secondly, I would like demonstrate that in fact the areas of interest to the applicant such as 'minimum performance and functionality for
CPE to be used and registered on the nbn network' and 'The list of registered "VDSL2 Equipment" and their registration information' has been discussed widely in industry circles and in some cases advice has been provided by NBNco privately to certain wholesalers and not others. I would draw your attention to the following "mainstream media" articles. This is by no means a definitive list, but all of the information below was obtained by searching for nbn co vdsl in google and clicking "news" which stands in contrast to your finding that nothing exists in the mainstream media.

(1) VDSL and ADSL Co-existence issues
Australian NBN can only use VDSL2 at low speeds
"it seems the NBN is very quickly descending into a farce, the need to co-exist with ADSL2+ in the network and a frequency plan that limits VDSL2 to using the same spectrum as ADSL2+ means that until the up to 8 MHz, 17 MHz or 30 MHz bands are opened up to VDSL2 the FTTC deployments will be limited to 12 Mbps to avoid destroying exchange based ADSL2+ signals. For FTTB where the DSLAM is in the basement of an apartment building the speeds allowed are doubled to a massive 25 Mbps."
http://www.thinkbroadband.com/news/7039-...

(2) NBN declares only certain VDSL chipsets should be used (to iiNet and noone else mind you)
NBN Co tells iiNet: Use Broadcom chips in VDSL routers
"iiNet, Australia's third-largest internet service provider in terms of subscriber numbers, has been told by NBNCo that it should consider only Broadcom chipsets for its future VDSL modems."
http://www.theregister.co.uk/2014/02/24/...

(3) NBN rep notes the criticality of getting technical parameters correct
'VDSL2 standards for NBN to clean up interference
“But unless the technical parameters are set correctly, the speed increase available through vectoring will be largely lost, and VDSL2 can also seriously erode the quality of the legacy services located in its vicinity.”

That’s especially important during the 18-month transition period each area of the country will go through migrating to the NBN, Stanton said. During this time, new and legacy services will need to co-exist without interference to each other, he said.'

(4) NBN admits in it's trials it turned VDSL masking on to avoid interference with other VDSL
Leaked NBN document helps the case for FttDP
'On copper runs of 100 metres from a basement to a fifth floor apartment of the multi-dwelling unit, speeds of 522Mbps down/78Mbps up were seen. However, NBN pointed out that during the trial, it has had to turn on VDSL masking in order to avoid interference with other VDSL lines;'
http://www.zdnet.com/article/leaked-nbn-...

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From: David Mesman
NBN Co Limited


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Attachment 16A.Final FOI Decision.pdf
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Please find attached an FOI decision in relation to your request
concerning nbn UNI VDSL2 equipment specifications.

 

Best regards, DJM

 

David J Mesman

General Counsel – FOI, Privacy & Knowledge Management

P +61 2 8918 8596| E [1][email address]

Level 10, 100 Arthur Street, North Sydney, NSW 2066

[2]cid:67DF297C-E4F7-4057-B96D-81E38821B52C   
[3]cid:2A7730FD-888B-430F-A80B-19FF030ECB54 
[4]cid:96E8DD86-300F-4E07-90CA-584EFAF1831A 
[5]cid:F6EF3436-8BDE-4B7F-A675-8FDAFD10DE91 
[6]cid:E93E7EFA-A9D8-4689-915B-7649E37C40C4 
[7]cid:E95F0813-5FB7-4B66-8796-5FFD5FF8FC80 
[8]cid:4EA8D93D-C8C4-4162-BD29-AFDAA18B3714

 

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Matt Carter left an annotation ()

"Document 1 contains the business know-how, technology choices and intellectual property
of nbn customers (the Registrants), provided to nbn for the purposes of the VDSL2
equipment registration process. This information was and is provided to nbn on the
understanding that it would remain confidential, per the WBA Head Terms. If Document 1
were released, the information could be used by others in the marketplace to gain a
competitive advantage over the Registrants. In particular, an informed reader might be able
to determine who the Registrant is and what their future business plans might be depending
on the type of equipment registered. This understanding could potentially be used by others
in the marketplace to register similar equipment to beat the Registrant to market."

That is the biggest load of shit I have ever heard and does not reflect the nature of the request. The applicant asked for a list of the VDSL2 equipment that has been registered for use on the NBN network, he did NOT ask for a list of "The registrants" or details of who made those registrations.

The intention of the request is to understand what VDSL2 equipment has been validated for use on the nbn network, it is irrelevant who the equipment belongs to and this should not form part of the response as it was not part of the request.

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This message has been hidden. Message was not sent by the agency. More details are in an annotation below. Please contact us if you have any questions. If you are the requester, then you may sign in to view the message.

Henare Degan left an annotation ()

A message above was removed because it wasn't from the department. It was a message intended for the requester from a barrister offering pro bono assistance with this request. We've contacted the person that sent it and instructed them on how to contact the requester.

Henare
Right To Know administrator

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Things to do with this request

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NBN Co Limited only: