If you want "Functional Internet Access" Read This Now!

spongebob

Bump

October 13th is the last day for responses. I recommend you read Seamus' one first.

M

damien

Consultation is extended until: November 5th 2004

spongebob

Bump . Deadline Friday this week for the Narrowband Access Consultation. Read Séamuses response and then dip into the docs , especially 04/94 , linked in the THIRD post in this thread .

I confess that I am afloat in a sea of consultations at present but this one seems to be of particular importance.

M

damien

IrelandOffline should be making theirs tonight or tomorrow.

Moriarty

The following is the submission Ireland Offline made to ComReg.

Reference: Submission re ComReg 04/94

"Q. 1. Do you agree with the scope of ComReg’s review of the retail fixed narrowband access markets?"

Ireland Offline agrees with ComReg's analysis of the fixed narrowband access markets and would like to draw special attention to the following points.


From 3.5
"This document concerns the provision of narrowband access at a fixed location. ComReg is considering a connection to the public telephone network which is capable of allowing a user to make and/or receive domestic and international calls, fax communications, and data communications at rates sufficient to permit functional internet access."

From 3.16
"In Ireland, fixed access to the telephone network can be provided by:
Analogue exchange lines. This provides a single channel, originally designed to provide voice traffic but capable also of supporting fax and data modems with speeds of up to 56 kbit/s. In Ireland, this is the predominant form of access and at the end of 2003, there were 1.6 million basic PSTN lines in service."

From 3.29
"This review is concerned with the ability of customers to access the telephone network. The focus is on access to traditional fixed telephony services. In line with European Union guidance, ComReg’s interpretation is that this means access which allows a user to make voice calls, fax calls and functional internet access; normally dial-up narrowband internet."

From 3.68
"All technologically-enabled fixed access lines, however offered, are functionally substitutable. All offer fixed access to networks capable of supporting telephony services. All offer similar quality of service for the purposes of making a voice call. All offer the possibility of access to other narrowband services such as dial-up internet."


Functional internet access is a requirement under the Universal Service Directive (2002). Ireland Offline consider even the maximum theoretical ceiling of 56kbit that analog modems could offer archaic and unsuitable for todays internet applications which require broadband connectivity. With DSL services and provision being so intrinsic to the knowledge-based economy which this country wishes to aspire to, it is the view of Ireland Offline that the minimum acceptable standard for functional internet access should be defined as a 512kbit/128kbit broadband connection.

However, Ireland Offline recognises that the analog modem is still unfortunately the predominant form of access in Ireland. Ireland Offline also recognise that many of the same problems which cause poor or nonexistent dial up access also result in problems when attempting to enable lines for DSL services. There has been significant under-investment in the access network over the past few years which is leading to deteriorating service levels across the board. Proof of this can be seen in the disastrous failure rates of lines connected to DSL-enabled exchanges.

Taking cognisance of the deterioration which has been allowed to take place in the incumbent’s copper network, (the delivery mechanism for both DSL based broadband and analogue internet access), and the low level of capital expenditure on both maintenance and improvements, it is necessary to regulate for the period until broadband becomes universally available. We propose that a penalty based regime be put in place, which would force the incumbent to provide alternative internet access where functional (i.e. broadband) access is not available.

We propose that the incumbent is required to provision the failing line for 44k analogue access, with no installation or upgrade charge and at a significantly discounted monthly rental. The penalty must allow for rectification of all failures, noise, crosstalk, and either the total removal of obsolete pair gain devices which constrain the line speed or their replacement with modern equivalents which allow a minimum of 44k access.

In order to encourage much needed capital investment, a 12 month moratorium on such penalties in relation to a specific exchange should be allowed where the incumbent gives an irrevocable commitment to DSL provision that exchange within the 12 month period.



Regards, etc
Ireland Offline

dahamsta

IrelandOffline wrote:

We propose that the incumbent is required to provision the failing line for 44k analogue access, with no installation or upgrade charge and at a significantly discounted monthly rental. The penalty must allow for rectification of all failures, noise, crosstalk, and either the total removal of obsolete pair gain devices which constrain the line speed or their replacement with modern equivalents which allow a minimum of 44k access.

Me likey a lotty.

In order to encourage much needed capital investment, a 12 month moratorium on such penalties in relation to a specific exchange should be allowed where the incumbent gives an irrevocable commitment to DSL provision that exchange within the 12 month period.

Me likey not so muchy.

IMHO 12 months is too long, and Eircom's past history guarantees that they will stretch the 12 month provision out even further. I would have said three months. Impossible? Maybe, but they'd stretch it out to 6 whether or which.

Constructive criticism guys, on the whole I'm very impressed by the submission. Good work, keep it up please.

adam

damien

dahamsta wrote:

I would have said three months. Impossible? Maybe, but they'd stretch it out to 6 whether or which.

Copy and paste and change our 12 months to 3 , or if you have made your submission already maybe Ma Dahamsta can make a submission ?

dahamsta

I had a feeling in my bones that I'd get a Rapid Response to that post, but I didn't think it'd come at me from quite so many angles.

adam

damien

Angles ?

I was being constructive !

Same goes for everyone else that wants to submit to ComReg. You can use our submission as a template.

spongebob

Excellent submission .

M

eircomtribunal

Moriarty wrote:

The following is the submission Ireland Offline made to ComReg....
"With DSL services and provision being so intrinsic to the knowledge-based economy which this country wishes to aspire to, it is the view of Ireland Offline that the minimum acceptable standard for functional internet access should be defined as a 512kbit/128kbit broadband connection."

I like it very much to be outdone in my demands by Irelandoffline
P.

My
"Submission to ComReg consultation "Market Analysis - Retail Fixed
Narrowband Access Markets"


While I am not in a position to respond to all of the questions raised,
I'd like to have these two responses considered:

1. On Functional Internet Access, probably falling under Question 1 (Q.
1. Do you agree with the scope of ComReg's review of the retail fixed
narrowband access markets? Please elaborate your response.)

While I agree with the overall analysis presented by Comreg in section
Three of Consultation 04/94, I'd like to stress the following:
Comreg must enforce the USO directive, particularly the Universal
entitlement to a telephone line capable of Functional Internet Access
where the line is supplied by the USO Carrier.

Comreg have still not enforced this directive of the 25/07/2003 and the
consequences are dramatic: A further degradation of the incumbent's
copper network was allowed to take place. At a time when Ireland
urgently needs a substantial rise in Internet users, people, who cannot
get functional Internet access have to accept the incumbent's operator
telling them: sorry, but we are only obliged to supply voice quality on
the line.

ComReg have to stop asking the incumbent what is possible and start to
look at successful Internet countries and set those standards. Example:
The Danish regulator set ISDN as the USO standard back in 1996. Denmark
is a country ComReg should look to: Like Ireland it had no cable
competition and contrary to Ireland it is one of the most successful
Internet and Broadband countries in the EU.

Functional Internet access requirements have changed since. For a
normal PC user it is no longer possible to keep up with service and
security updates on a 28k connection.

So, while really the standard for Functional Internet Access should be
set at 512k, I propose to at least set a minimum connection quality of
64k for Functional Internet Access. This standard will assure a line
quality virtually always capable to carry Broadband.



2. Vulnerable Users Scheme and Wholesale Line Rental, probably falling
under Question 31(Q. 31. Respondents are asked to provide views on
whether the remedies in section 6 of this consultation paper are
proportionate and justified and offer views on what factors ComReg
should consider in completing its Regulatory Impact Assessment in
terms of the impact of these remedies on end-users, competition, the
internal single market and technological neutrality)

Quote from the consultation document:
"Vulnerable Users Scheme
6.132 ComReg expects the cap on the Vulnerable User Scheme to continue
as this will contribute to protecting low users from large increases
in the cost of their telephone bill as agreed when the previous lower
quartile cap was removed."

This is a disgrace and Comreg and Eircom should not be allowed to
continue with this red herring.

ComReg intentionally removed the effective lower quartile cap to allow
Eircom the anti-competitive line rental increase of 23%, which
disproportionally hiked the overall bills of low users by up to 23%.
The VUS or low usage scheme had not and could not have an impact for
those low users. The payment of the Department of Family and Social
Affairs for its Telephone Allowance Scheme shot up to 92 million a year
as a result of the line rental hike.

Additionally this VUS is incompatible with consumer protection, as the
potential users (only very few takers, and only Eircom users can take
it) have no means to know the pricing level of their calls, when using
the scheme.

And worst of all: As Comreg had not defined the USO to include
meaningful Functional Internet Access, the huge profit increase from
the 23% line rental increase was not used by Eircom to improve the line
network.

I propose to remove the low usage scheme and introduce a sub-cap on the
line rental or reintroduce the sub-cap on the lower quartile of bill
payers. The goal has to be to bring Irish line rental back to the EU
average.

The whole sale line rental product Comreg introduced is not in
accordance with the DCMNR directive and should be changed to a product
that is not solely allowing single billing for the customer, but
competition in the market. The current Eircom resale -10% price
arrangement is a mocking of the DCMNR intentions. While it will reduce
churn to some extent, it is not what the doctor ordered and should be
changed."