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III. Comments on Leased Lines
i. Retail market -- the Minimum Set of Leased Lines (Market 7): Eliminated
According to different services provided by different leased lines, the retail market of leased lines can be divided into two categories, say narrowband leased lines (A) and traditional broadband leased lines (B).
A. Narrowband leased lines (Up to 64 Kbyte/sec): Eliminated
First, from supply side this market was developed primarily for the voice market and sales are declining considerably for these types of services moving towards digital, broadband and IP based delivery. Second, from demand side this market sees a declining demand within the last few years and customer’s demand is increasingly shifting from lower bandwidth to leased lines with higher bandwidth as more and more new applications need high speed connections.
Since analogue and 64 Kbit/s leased lines are becoming less important for customers, Belgacom believes there is no need to regulate this market.
B. Traditional Broadband leased lines (Between 64 Kbyte/sec and 2 Mbyte/sec): Eliminated
Leased lines with bandwidth of such are used to provide services of voice and data. On the one hand, from supply side more and more operators are providing leased lines with the minimum capacity up to 10 Mbyte/sec as traditional broadband leased lines have been an old technology. On the other hand, from demand side considering the increasing demand for video transmission consumers prefer using leased lines the bandwidth of which are above 2 Mbytes/sec. Therefore, this market is intensively dynamic.
In the view of Belgacom, it is technologically unnecessary to maintain a retail market within such band width so far.
C. Conclusion
Taking account of the liberalisation achievement in this market, Belgacom believes that there is no need for regulation of the minimum set of leased lines.
• The retail market of leased lines is mainly concerned with non-residential customers. It is a cherry-picking area and therefore was one of the foremost sectors subject to liberalisation.
• The revenue of Belgacom in national leased lines market is continuing to decline.
• Most retail leased lines are already replicated or will be replicated in the near future.
Therefore, according to Belgacom, Market 7 can be eliminated from the list of relevant markets.
ii. Wholesale market: Wholesale Terminating Segments of Leased Lines (Market 13): Maintained but modified
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