Comreg publish USO consultation,

spongebob

Discussion Here and links.

Page 19/20 (The IoffL and Eircom positions in part)

IoffL

"One respondent noted that information on eircom’s current policy for assessing the
reasonableness of requests was not available during the consultation period. This
respondent, who agreed with the approach to establish requirements around the
obligation to meet reasonable requests for access, stated that the USO should recognise
the right of every user to a full copper pair and, in general, this should be considered a
reasonable request. If provision of a full copper pair is not feasible then access
provision by other means such as wireless or through an alternate operator should be
considered. The respondent states that the current USP has licence obligations that
require it to deliver services over Fixed Wireless Access, additional to those currently
provided as part of the USO. In this regard, they considered that ISDN should be part
of the USO.
This respondent also agreed with the proposal to incorporate the reasonableness test as
part of a wider policy statement regarding the delivery of all services under USO.
They are of the view that an enhanced customer charter is also required.
They recommended that in tandem with the publication of the policy statement that the
USP should be required to inform users where ‘Pairgain5’ devices (carrier systems) are
used. In such situations they recommended that consumers should have the option to
submit a reasonable request for removal of these devices from their line. This same
respondent also believed that Copper Loop Impact statements should be required from
the USP if it is likely that a reasonable request for service will lead to degradation of
copper in an area.

(Now for Eircom)

Another respondent also agreed with ComReg proposals on requests for access, but felt
that it was primarily a consumer issue. This respondent supported an approach that
allows the USP to recover its efficiently incurred costs in providing access to
geographically remote locations. They noted that in the UK, BT has the flexibility to
raise extra connection charges if installations exceed 100 man-hours (the “100 manhour
rule”)."

Comreg said

"ComReg does not propose to designate a mobile
operator as a USP at this time"

NOW for the juicy bit

"• Carrier systems A significant amount of telephone service is provided over
carrier systems which essentially is a means of splitting one telephone line to
The Future Framework for the Regulation of Universal
Service in the Irish Telecommunications Market
25 ComReg 03/68
provide multiple lines. These systems are used to ensure greater access to a basic
voice service where line resources are scare. However, in splitting the line the
bandwidth, and therefore the data rate experienced, is reduced. The provision of
service by carriers means a limit on internet access to between 14.4 to 19.2kbs.
• Cost Factors eircom state that if a bit rate of 56kbits where set this would require
the reduction of the maximum distance from subscribers to an exchange from 9km
to 4.5km – effectively doubling the number of switches required and this would
cost approximately €2bn. In addition the cost of replacing all existing carrier
systems would be at least €90m to €100m."

€2 Billion OMFG thats taking the piss even by Eircom standards.

Page 28 , Comreg feel that 20k is enough it seems.

"ComReg is of the view that data speeds of 14.4 to 19.2 kbps (note that these speeds
may not reflect actual modem speeds as experienced by users via their Internet Service
Provider) may not constitute satisfactory internet access. While ComReg does not
intend to specify a specific bit rate, there is a need to reduce the number of carrier
access systems in use and/or allocate the resource to those users who have no
requirement for internet access. ComReg will therefore engage with the USP to assess
the level of use of carrier access systems and may require the USP to develop a detailed
plan on how to address this issue moving forward."

Click the link on top to see how you can respond personally to this ridiculous position. 20k is nowhere near enough. Nobdy should have a speed under 33.6k and that only 5 miles (8km) from the exchange .

Comreg are in listening mode for the next fortnight or so.

M

shinzon

There copper must be in a right mess if it is indeed gonna cost 2 billlion to repair it lol

regards

Shin

Calibos

No it just means that in spain the same job would cost 200,000,000 whereas here in Rip off Central it costs 2 billion, much like the way Barcelona's new metro cost 1.5 billion but Dublins will cost 9 billion.:rolleyes: :rolleyes: