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USO Comreg Finally Respond to Consultation
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18-06-2003 10:06pm#1
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Originally posted by Muck
What did ye think of Eircom stating it would cost €2Billion to rewire the network to guarantee 56k (or 48k which is technically feasible except that nobody asked for it)
This was their response to the setting of a bit rate of 56kb/s, something we explicitly did not ask for. What we asked for was for a bit rate to be set such that pairgain systems are removed. The telling response, therefore, followed:
5.1.2.2...the cost of replacing all existing carrier systems would be at least €90 to €100m.
This is the first indication we've had of the extent of the problem. As the document says:
10.3...A [...] respondent felt that services which fell within the bounds of a reasonably maintained network should be outside the definition of an unfair burden
The decision of the cost to the USP in relation to "unfair burden" remained undecided. The possibility remains, therefore, to call on ComReg to include the request for a full copper pair in the "reasonable request" criteria based on the fact that the cost to Eircom will be a percentage of the full stated cost to remove all splitters from the network, and therefore fulfill the "fair burden" requirement, given the fact that
5.1.2.4...there is a need to reduce the number of carrier access systems in use
and
5.1.1.4...reasonable endeavours should be made by the USP to provide users with 'full' connections
also taking into account the fact that
5.1.2.4...some pairgain systems support 56Kbit/s
viz. http://www.inoviatele.com/Products_PtP/PtP_PentaGain.asp [thanks Ray]0 -
Maybe not relevant here, but at work today I read some of the Comreg documents, and were literally shocked to see they talk about ISDN as being broadband
ComReg definition of broadband can be found here
3.1 Definition of Broadband
The concept of broadband is normally defined in terms of capacity6 (or speed of data transfer) provided on a telecommunications network. A relatively high level of telecommunication capacity is generally referred to as ‘broadband’7. However, this definition can create confusion as it raises the question as to what constitutes a ‘relatively high level of telecommunications capacity’. In 1997, the ITU issued a recommendation that transmission rates greater than Primary Rate ISDN (i.e. approx. 2Mbit/s or above) be considered to be ‘broadband’8. However in its studies, the OECD defined broadband as providing downstream access of 256kbit/s and upstream access of 128kbit/s. Elsewhere, in a study of 14 countries by the Canadian National Broadband Task Force, broadband definitions ranging from 200kbit/s to 30Mbit/s were reported9. The extent of the disparity reflects ‘forward-proofing’ by some countries10. Given this emergence of multiple definitions, there have been some suggestions recently towards defining broadband in terms of functionality rather than a specific minimum capacity. In 2001 the ITU suggested that any network capable of carrying full motion video could be considered broadband11. Such an approach would counter the problem of evolving end-users’ expectations of broadband, but would exclude most of today’s ‘broadband’ connections via cable modem and DSL technologies. In May 2002, in their most recent report, the OECD stated that “it may be better to think of broadband as a wide set of technologies that generate some minimum level of high speed bandwidth interconnection”12. By including the words ‘high-speed’, but not specifying a minimum capacity this definition brings us back to the earlier definition of “a relatively high level of capacity”. Furthermore, the always-on or packet-based (e.g. IP based) characteristics of some broadband technologies (e.g. DSL, Cable) are becoming generally accepted as part of the broadband definition. For the purposes of this report, we have decided to define ‘broadband’ as capacities of 512kbit/s13 and above in the portion of a network that a customer uses to connect to a service provider – i.e. the access network14. However, we regard this as a somewhat arbitrary working definition, and we recognise that technological and market developments may require us to revisit this definition in the future. It should be noted that the definition excludes Basic ISDN connections (max. speed of 128kbit/s) of which there has been strong growth over the past 18 months.
So, according to this (and the extremely helpful person who directed me to the link) 128k ISDN figures are not included in any of their broadband reports. Only connection speeds above 512k are considered broadband.
[edit]
wtf
2 billion euro!!! muppets 0 -
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Originally posted by Xian
Originally posted by Muck
What did ye think of Eircom stating it would cost €2Billion to rewire the network to guarantee 56k (or 48k which is technically feasible except that nobody asked for it)
This was their response to the setting of a bit rate of 56kb/s, something we explicitly did not ask for. What we asked for was for a bit rate to be set such that pairgain systems are removed. The telling response, therefore, followed:
5.1.2.2...the cost of replacing all existing carrier systems would be at least €90 to €100m.
This is the first indication we've had of the extent of the problem.
The IoffL submission gave Comreg a reasonable plan of action which was NOT an unfair burden. Without reading it again it was
48k at 1mile
44k at 2 miles
40k at 3 miles
36k at 4 miles
33.6k at 5 miles
I believe that the number of lines that are over 5 miles from the exchange is 2% nationally (figures submitted to cabinet by Eircom but not published).
So 98% of Irish Homes and Businesses are within 5 miles of an exchange. A line is Designed by international standards to work at up to 5 miles from the exchange. 1% of lines is 14,000. The maximum number of lines outside the limit is 28,000 .
These international standards have been around for 20-25 years. Precisely how the fúkc is it an 'Unfair Burden' on Eircom to enforce a standard they have known about for years. A standard is a standard is a standard The ESB does not widdle around splitting 220v lines and complaining that a standard 220v connection is an Unfair Burden on them, here ya go, have 136v coz yer off up a boreen.
Remember that Eircom have squatted on a large chunk of National Airwave to provide them with alternatives to a wired solution.....for the other 2% of the population or even for some of those within 5 miles. Eircom have frequencies around 2.1Ghz 2.3Ghz(Rurtel) and 3.5Ghz(FWA) with which they can provide POTS ISDN and DSL type connections at up to 384k . Comreg issued these licences to Eircom. Why?, what have we got from Eircom (or Comreg for that matter) in return for these licences. Nothing.
Let us also look at why this is being discussed. In Early 2002, the EU published This directive. It is part of Irish Law from next month. Comreg are cleaning up their own rules in order to comply with it after it becomes law. On page 2 of the directive we see, stated in the CLEAREST POSSIBLE TERMS for the likes of Comreg to follow.(8) A fundamental requirement of universal service is to
provide users on request with a connection to the
public telephone network at a fixed location, at an
affordable price. The requirement is limited to a single
narrowband network connection.
<snip>
There should be no
constraints on the technical means by which the
connection is provided, allowing for wired or wireless
technologies, nor any constraints on which operators
provide part or all of universal service obligations.
Connections to the public telephone network at a fixed
location should be capable of supporting speech and
data communications at rates sufficient for access to
online services such as those provided via the public
Internet.
<snip>
For this reason it
is not appropriate to mandate a specific data or bit rate
at Community level.
<snip>
Flexibility is
required on the one hand to allow Member States to
take measures where necessary to ensure that
connections are capable of supporting such a data rate,
and on the other hand to allow Member States where
relevant to permit data rates below this upper limit of
56 kbits/s in order, for example, to exploit the
capabilities of wireless technologies (including cellular
wireless networks) to deliver universal service to a
higher proportion of the population.
<snip>
Member States should be
able to require the connection to be brought up to the
level enjoyed by the majority of subscribers so that it
supports data rates sufficient for access to the Internet.
Now I did snip it a bit but it sez use wireless if the cost of wired is too much. It also sez that the INTERNET is PUBLIC while the Comreg waffle seems to imply that the INTERNET is not part of the PUBLIC NETWORK. This is important becuase the Public Network is what the USO covers.
Finally I looked again at some of the convoluted waffle between pages 12-25 where Comreg turned themselves inside out trying to remove Wireless from the USO and NOT at the same time. The Directive is pretty straight. Use wireless if wired solutions are too expensive. ABOVE ALL get the speeds up to "to the
level enjoyed by the majority of subscribers" . That was why the IoffL submission REQUIRED at least 33.6k speed at 5 miles. IoffL had READ the directive properly not least because I made them
The Comreg definition of the carrier activity that comes under the USO is essentially:
A Connection to the Public Network which is AT a fixed location .
They went through linguistic hoops in their trying to exclude the INTERNET (or Online Services) from the PUBLIC NETWORK. By induction, they decided that a mobile phone was not at a fixed location, even if it was !!!! (Don't try Jesuitical logic on me lads) and excluded Vodafone from the USO as a consequence. In excluding Vodafdone and O2 they neatly encapsulated all non wired technology into the exclusion, or so they thought! I think that their painful definition of what is to be provided AT a fixed location by Eircom can be cleaned up into a logical and consistent policy in plain english.
Comreg really dropped the ball in the following excerpt from page 15. They Confused Fixed Carrier with Wired Carrier and then developed the analogy down the cul de sac where it belongs.. They never acknowledged that Fixed Wireless (or Nomadic Wireless solutions) existed that would deliver the Universal Service Required in the Directive but FROM the Fixed Carrier , the USP.
Page 15
But this following bit is what the directive said (quoted above too) !At present, universal service obligations only apply to fixed carriers. Mobile operators’
statutory ‘public service requirements’ tend to be included in the tender documents and
licence provisions of mobile operators which require them to guarantee extensive
geographic coverage. Under current and the new EU framework, they may also be
required to contribute to any universal service funds. The use of mobiles to deliver the
services falling under the USO would give rise to considerations regarding
affordability (i.e. the retail cost of the universal services via mobile may be more
expensive than via traditional fixed means). Furthermore, one of the key differences
between fixed and mobile services is that mobile service normally connects individuals
irrespective of their location. On the other hand, a fixed service normally connects
households/businesses. The Directive also requires that access is capable, amongst
other things, of supporting functional internet access. Mobile services may not
currently satisfactorily supported these requirements.
Eircom have delivery options including wireless where they can deliver 56k POTS over 2.1Ghz 2.3Ghz 3.5Ghz and Copper. Comreg seem to state that only MOBILE operators have Wireless options, this is not the case at all.There should be no
constraints on the technical means by which the
connection is provided, allowing for wired or wireless
technologies,
Fortunately there is a further consultation period during the next fortnight....up to 04/07/03. I advise anyone reading this to concentrate on pages 12-30 of the Doc linked in the first post and to deconvolute them and to submit to Comreg. Remember that you should Submit Early and Submit often, once this is put to bed there will be no change to the policy for 3 years from October or so. That means Late 2006 at the earliest. There will be no rural economy by 2006 if this ain't sorted NOW!
M0 -
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Plagiarise away No copyright reserved in you case .
I am now minded to say to them that they have
"Unilaterally, and without showing good cause, constrained the technical means of delivery contrary to section 1(8) of the USO Directive which states that there should be no technical constraint."
Which could make the Proposed USO Ultra Vires of course.
M0
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