A Very Pertinent Question

DonegalMan

In my interview with Prime Time, Donagh Diamond asked me one very pertinent question which wasn't actually shown - "OK, that's the problems defined, so what do you guys (IrelandOffline) think should be done about it?"

I don't want to give my own answer just yet - I'd like to hear how other people would answer it.

Martin

Ripwave

DonegalMan wrote:

In my interview with Prime Time, Donagh Diamond asked me one very pertinent question which wasn't actually shown - "OK, that's the problems defined, so what do you guys (IrelandOffline) think should be done about it?"

I don't want to give my own answer just yet - I'd like to hear how other people would answer it.

The experience in the rest of Europe suggests that realistic LLU charges are important for driving improved services. But a big problem with that approach here is the number of "split" or pairgained lines. If I could make a single change, it would be a monthly fine on eircom for every pairgain in place, to give them an incentive to remove them.

(It would be fairer to insist that eircom couldn't charge full price for a split line, but the problem is that 30% of the population might start complaining that they have to pay for a full line when they'd be perfectly happy to save a fiver a month by having a split line!).

Mr_Man

Following on from Ripwave's point I'd suggest that if a user has a pairgain on their line Eircom have 5 working days to remove it, otherwise they are fined a substantial amount per day while it remains in place.

This would allow those who have pairgains to have them removed, those who have them but couldn't care less to stay as they are, and would allow Eircom to address the problem in an organised fashion.

Just my 2c

M.

Urban Weigl

To oversimplify: aggressive local loop unbundling prices. Not completely on its own, but this is the core measure that will solve the local loop issue.

Not only is this backed up by the experiences of other EU states, it will also allow for more innovative broadband products, as competitors will be able to do more than just resell a bitstream product.

Ripwave

Urban Weigl wrote:

To oversimplify: aggressive local loop unbundling prices. Not completely on its own, but this is the core measure that will solve the local loop issue.

Not only is this backed up by the experiences of other EU states, it will also allow for more innovative broadband products, as competitors will be able to do more than just resell a bitstream product.

Unless it is backed by an incentive to get eircom to remove pairgains, it will only have limited success, and tend to exacerbate the issue of patchy coverage.

As things stand, LLU is unlikely to lead to nationwide deployment of enhanced services. These innovative broadband products will become available, but only in higher density areas.

ganam

DonegalMan wrote:

"OK, that's the problems defined, so what do you guys (IrelandOffline) think should be done about it?"

I don't want to give my own answer just yet - I'd like to hear how other people would answer it.

Functional Internet Access to 64kbps on all fixed lines by end 2005?

Ripwave

ganam wrote:

Functional Internet Access to 64kbps on all fixed lines by end 2005?

And what should happen when eircom point out that that's not technically feasible?

spongebob

Ripwave wrote:

And what should happen when eircom point out that that's not technically feasible?

They would be wrong Ripwave as you well know . It IS technically feasible but at what cost. Are there cheaper ways to address the issue than upgrading copper or digging through granite to install fibre ?

Eircom have licences to deliver POTS/ISDN equivalents over exclusively licenced spectrum around 2Ghz (WLL) 2.3Ghz (Rurtel) and 3.5Ghz (Pots to BB type spectrum) . If they intend not to do so the spectrum should be taken off them and given to someone who will.......even a GBS . WLL spectrum is available nationally since those muppets in Chorus turned their WLL system off in the spring .

Eircom have installed Base station equipment in 48 locations nationwide , many on the west coast. These base stations have a nominal coverage out to 10km save where a mountain may be lurking . The nominal coverage is about 20% Geographic as compared to about 10% Geographic for DSL at present.

Eircom can simply substitute a Wireless FIA Capable loop for a Copper FIA capable loop . The fact that they ALREADY CAN explains the mysterious lack of coverage maps for their WLL Rurtel and 3.5Ghz networks. Changing the delivery from Wired to Wireless is permissible in the USO directive.

M

eircomtribunal

Ripwave wrote:

And what should happen when eircom point out that that's not technically feasible?

You are pointing exactly at what's wrong with ComReg ever so often: They are asking and taking Eircom's word for do-ability of things and then set the regulatory aims accordingly.

P.

Ripwave

Muck wrote:

They would be wrong Ripwave as you well know . It IS technically feasible but at what cost.

Muck, FTTH for every house in the land is technically feasible, but is unlikely to be doable at an acceptable cost.

Defining FIA at 64K doesn't mean fixing pairgains, it means ripping out the existing telecoms infrastructure for the whole country and replacing it with some other technology. If your only solution is to bypass the existing infrastructure entirely, why bother with eircom at all?

Ripwave

eircomtribunal wrote:

You are pointing exactly at what's wrong with ComReg ever so often: They are asking and taking Eircom's word for do-ability of things and then set the regulatory aims accordingly.

And what technology do you propose eircom invent to provide 64K connections over analog phone lines, Peter?

MarVeL

How about requiring the reasons behind line fails to be made available (preferably including whether or not there is a pairgain on the line) along with an estimated cost to correct any issues, other than distance obviously.

eircomtribunal

DonegalMan wrote:

I "..so what do you guys (IrelandOffline) think should be done about it?"

Martin

1. Noel has to understand that the MAN's are not competition to the last mile and therefore not the solution, he makes them to be. (Rereading his Prime Time Interview answers is painful)

2. We need to know about the Magaziner episode, or we might analyse and plan in a reality different from the one the gov is in.

3. ComReg needs a competent Commissioner. Doherty and Goggin (her self congratulatory talk lately makes for a depressing read) are not up to the mighty task ahead. There is a vacancy for the third position of Commissioner, isn't it?

4. As a country with no cable or other substantial last mile competition, we have to go the LLU path.
The DCMNR has to hinder Doherty castrating the MAN by setting the € 14.65 +inflation price for the next three years. While the regulator cannot simply set a sub-cost price, he can very well include the factor of the enormous competitive advantage the incumbent got from blocking any LLU progress so far. He can and should as well orientate the costing on an efficient operator. I saw in Ofcom's contemplation about their LLU pricing that they have no difficulty to look abroad and compare pricing.

5. One of the biggest disincentives for Eircom to go for all-out broadband is the enormous profit they still make on dial-up. Dial-up minutes have overtaken call minutes.
Eircom are very satisfied when they talk in the SEC filing of Comreg not having revisited the FRIACO pricing, despite the fact that they could.
IOFFL should come clean on their illusionary"big" FRIACO success. It was a failure.
It didn't improve the domestic Internet penetration. Without a substantial rise in Internet penetration all our bb progress will be severely curtailed.
Eircom must not be allowed to make money on the unfortunate ones who cannot get broadband or on those who have to be tempted to try out the Internet.
FRIACO port prices have to be set at a level so that €10 per month real flat rate access can be offered.

6. Functional Internet Access has to be defined by the regulator according to the needs of the country.
Why not set it as 512k? And set a time table for the incumbent to work towards 100% coverage. Like 85% by mid 2005 (I estimate that would be the goal that D. Ahern has set in his March 2004 directive = average EU-15 broadband enduser coverage by mid 2005), 90% by end 2005 and so on.
The current bb coverage is worse than dismal. All experts agree that achieving a 60% coverage is very easy and cheap, 80% is still easy and cheap, 90% takes longer to recover the cost, 95%+ is more challenging.

P.
SEC page 52
Flat Rate Internet Access Call Origination (FRIACO) FRIACO prices are set out in our RIO. FRIACO is used by other authorised operators who are ISPs to enable them to offer bundled or unmetered Internet access to their customers. It is also used by other authorised operators to offer capacity for onward sale to ISPs. The price at which we are required to offer FRIACO is set by reference to the number of ports provided to the authorised operator, and the price that would be charged under our RIO for the projected volume of traffic for each such port. Having reviewed our cost information, on 21 February 2003 ComReg determined a final price to apply for six months for our FRIACO product. ComReg reserved the right to review FRIACO pricing at six month intervals, but to date has not exercised this right.

De Rebel

Its all here ............. In the words of the politicians themselves.

I've highlighted recommendations 2 and 7 which are the over arching ones.

1. Defines broadband as a service that provides at least 512kb connectivity and sets as a target 5Mps connectivity by 2006 with widely available 10Mps connectivity in 2008 being the further target.
2. Develop a National Broadband Infrastructure Plan in 2004.
3. Appoint a single Minister of State with cross department responsibility for the rollout of a national broadband infrastructure and the development of e-Government services.
4. Encourage closer co-operation between the Government, the telecoms industry and the end-users of broadband services.
5. Mandate that all national, regional, county and city development plans incorporate the provision of broadband infrastructure with such plans.
6. Ensure that all new developments are ‘future-proofed' for broadband.
7. Focus on “bridging of the first mile” as the first key policy issue.
8. Establish the proposed Management Service Enterprise (MSE) to ensure all existing broadband assets are put to full use.
9. Introduce measures to widen the ‘reach' of broadband technologies.
10. Improve skills to allow greater broadband access.
11. Encourage business to increase their usage of broadband technologies.
12. Fully examine the potential of Government to use broadband.

Paddy20

De Rebel is absolutely correct in pointing out the aims of the Oireachtas Committee, although the Government needs to give a further commitment to the citizens and commercial sector who need to utilise broadband ASAP.

That is :- Where the incumbent i.e. Eircom, who currently hold a monopolistic advantage over the roll out of broadband, abuse their current position to the detriment of this Countrie's social, educational and economic needs and aspirations.

Then they will legislate to remove Eircom's ability to block a fair and equitable marketplace, so that a level democratic playinig field of competitiveness is created, whereby all Telco's wishing to enter the Irish telecoms and Internet marketplace are not Stillborn due to a lack of proper legislation.

Ireland needs a state of the art telecommunications infrastructure immediately, and the Government has a responsibility to ensure that it can be delivered unhindered in an open and fair marketplace .

SkepticOne

De Rebel wrote:

Its all here ............. In the words of the politicians themselves.

I've highlighted recommendations 2 and 7 which are the over arching ones.

I agree. Most of the other ones simply follow from these two. I would say that #2 follows from #7. The devil is in the detail on how #7 (bridging the last/first mile) should be solved and which should be the subject of the plan.

The two characteristics of the broadband situation are:

1. Lack of broadband in large portions of the country.
2. Poor variety and low specification of services in areas where broadband is available.

---

Looking at the first, although there is no broadband available, demand for broadband translates into dial-up and ISDN profits for Eircom. If broadband were to be provided, revenues from these inferior services vanish. From Eircom's monopoly point of view, revenue is what matters not benefit to consumers.

It appears that DCMNR have attempted to solve the lack of broadband problem by dangling carrots in front of Eircom. It appears, predictably, that Eircom have taken some of the carrots but not delivered the results.

The following, therefore, explores the alternative approach.

What needs to be encouraged (by encouraged, I mean financial incentives) is services by companies other than Eircom for the reason that they don't currently make revenues that are threatened by the introduction of broadband. Once in place, they have more of an interest in providing the services the community wants.

While for small communities these providers may become the local broadband monopolist, they are at least competing with the national monopolist in the area of general internet access and may force some improvement in the national monopolist's infrastructure in that area. Regardless, if a monopoly is to be created, it is vital that the community is consulted on the types of services to be made available and public funding should be conditional on this.

LLU needs to be looked into as one of the means of providing broadband by companies other than Eircom is likely to be some form of DSL which involves the placing of equipment in Eircom's exhanges, though the government should not get involved in dictating what technologies are used. This should be down to the community in question primarily. The important thing is that the services delivered is what the community wants.

To facilitate such companies, issues such as the availibilty and of backhaul. The MANs, while not providing last-mile competition, are an important part of this and need to be examined in this regard. Will they provide the same level of service that similar schemes in countries like Sweden and Canada provide?

Note: it will be necessary to allow Eircom to also bid for services for legal reasons. The key is that other companies will be available to undercut them and the objective is simply to get broadband rolled out.

---

Now on to the second problem: Poor variety of services at reasonable prices and low specification of services in areas where broadband is available.

I don't know whether the government should get involved in this or whether they should concentrate on getting broadband to areas where none exist, however if they do the key to improving services is genuine competition. The overwhelming evidence is that countries that have outstanding broadband services also have fierce competition which forces competitors them to improve services.

None of this will be recommended by an "industry forum" since the "industry" has a vested interest in keeping competition to a minimum.

What I would recommend here is an organisation similar to the IDA, whose job is to attract investment in broadband services with the emphasis placed real competition (not reselling).

As the attached graph shows


Countries with advanced services also have high levels of real competition. Historically this has been cable as in the graph, but it need not be. It could be, for example, DSL provided through LLU, wireless or other technologies, the important thing is what is provided in terms of availability, speed, latency, reliability etc, not the technology.

This is my submission in answer to Martin's request.

spongebob

SkepticOne wrote:

2. Poor range and low specification of services in areas where broadband is available.

---

<snip>

Now on to the second problem: Poor range and low specification of services in areas where broadband is available.

I don't know whether the government should get involved in this or whether they should concentrate on getting broadband to areas where none exist, however if they do the key to improving services is genuine competition. The overwhelming evidence is that countries that have outstanding broadband services also have fierce competition which forces competitors them to improve services.

You will no doubt remember that jamie Smyth was fed an interesting titbit from his Press Release suppliers in Eircom. This titbit was that ADSL2+ would be deployed next year. The rationale behind such a deployment is simple. ADSL2+ allows more ADSL lines in a cable bundle with reduced crosstalk. The current RADSL program is heading for 20% penetration is some affluent areas . Once about 30% of lines on a given cable are enabled they all fall over together because of Crosstalk .

ADSL2+ will be deployed at the same price point and with the same packages as RADSL, maybe it will work out to 5.6km or so. Do tell me why I picked That Specific distance Ripwave like a good lad .

ADSL2+ will NOT result in a better offering in terms of Bandwidth and will NOT result in a lowering of prices, not before the second half of next year. It is the Cheapest way Eircom can knock more DSL lines out of the same copper and it also reduces certain fixed running costs such as power to the port when not in full use. TechnoGabble here.

The government can help by REFUSING to provide a tax break on services under 5Mbit , well within the capability of ADSL2+ . I commend SCHLUP as always .

M

Sleepy

A simple approach to force Eircom to come good on broadband.

Define Broadband to be a minimum of 128kbps and force Eircom to provide dial up internet access free of charge to anyone who fails the line test for broadband.

They'd have the problem sorted in a matter of months.

damien

Does anyone know how to use the "New Thread" button ?

DonegalMan

Right, now that the technical arguments have been taken out of the thread, it seems to me that the suggestions so far can be summarised:

1. The Oireachtas Broadband Report as an overall framework.
   
2. Reduce prices for Local Loop Unbundling to encourage competition
   
3. Action to improve existing dial-up through FIA and price reductions
   
4. Get rid of pairgains or at least upgrade them to a better standard
   
5. Implement penalties for Eircom when they fail to perform, be it failure to reach FIA or line failures for Broadband

Is that a reasonable summary?

Any more suggestions ?

Martin

spongebob

Push FRIACO , it has hardly been advertised for 6 months and is becoming a forgotten part of the product mix .

M

SkepticOne

I think the above summary relies a little too much on Eircom and the Regulator whose performance to date has not been spectacular (a bit controversial I know ). So I have proposed an additional two:

* Provide greater incentives for companies to provide broadband outside of urban areas and larger towns.

* In addition to LLU, promote competition generally. In particular, infrastructural competition which has proven to be a major driver of advanced services internationally.