ComReg: FIA is 28.8k

damien

http://www.comreg.ie/whats_new/default.asp?ctype=5&nid=101969

On functional Internet access, ComReg is proposing guidelines for meeting a required minimum data rate of 28.8 kbit/s for functional narrowband Internet access. It is expected that the telephone lines for all end users who wish to have internet access will meet this minimum standard. Where this is not the case, ComReg will expect that eircom will use all reasonable efforts to rectify the situation.

Sponge Bob

Well Holy God Miley. !

That IS such an improvement .

damien

The IOFFL Committee are going to examine the 24 page consultation in a lot of detail before we make any formal comment on this. We'd welcome everyone else's opinion on this though.

damien

Functional Internet Access

• Requirement for eircom to adopt 28.8kbit/s as a reasonable minimum data rate for functional Internet access;

• eircom will be required to take full account of ComReg guidelines when planning network build, providing individual connections to the network and when responding to requests to address service quality including:

(i) meeting targets for the minimum number of telephone lines capable of meeting or exceeding the reasonable minimum data rate of 28.8kbits/s;
(ii) facilitating users who have legitimate doubts about the data capability of their telephone line and to establish procedures to diagnose individual lines, and
(iii) Where a user’s telephone line is not capable of achieving the specified data rate, eircom to use all reasonable endeavours to ensure compliance.

Request for connections:

• eircom will be required to consider all requests for connections as “reasonable” if the expenditure involved in meeting the request is less than a certain threshold. ComReg proposes that this threshold be €7,000;

• All such requests should be met within defined timescales and involve no more than a standard connection charge (currently €121.93 VAT inclusive);

• Requests for connections which involve expenditure by eircom in excess of €7,000 to be considered reasonable if applicant agrees to pay standard connection charge plus incremental costs above €7,000;

• eircom will be required to take full account of ComReg guidelines when dealing with requests for connections including:
(i) provision of information to applicants in respect of requests for connection, and
(ii)the publication of supply times and the setting of performance targets
for meeting reasonable requests.

• eircom will also be required, under Regulation 10 of the Universal Service Regulations, to publish information on its performance in meeting requests for connection.

Sponge Bob

I'm somewhat concerned at the bit where Comreg reckon that 93% of ALL Lines in Ireland can currently support 28.8k minimum . Even if that were a % of all analogue lines, 1.6 Million, Comreg are in effect saying that only 112,000 lines are so substandard that they even cannot support a continous 28.8k connection with no drops .

Comreg are then allowing Eircom to stretch the improvement progam for those 112,000 lines out so that 8000 get done every half year and 16000 a year , meaning that getting the whole network up to FIA 28.8k speed minimum will take until 2012 , this in a USO !

I tend to the opinion that 30% of lines nationally are either substandard or grossly substandard . That would be in around 480,000 lines nationally and it will take until 2034 to bring them up to a standard, v34 , formulated in 1994 if the 'upgrade ' program follows Comregs leisurely path.

Nevertheless it is nice to see Comreg address many of the issues put to them exactly 2 years ago by IoffL, however belatedly, and the FIA consultation is indeed worthy of very careful consideration before any submissions go in.

damien

4.5 Impact of proposals on applicants

Based on information provided by eircom on the cost range of applications for 2003, ComReg estimates that somewhere in the region of 0.13% of the total number of applications received for service, would exceed the proposed threshold of €7,000.

4.6 Impact of proposals on eircom

Based on information provided by eircom, ComReg does not believe that the proposed threshold of €7,000 would have a significant effect on the net cost to eircom of meeting the USO requirements. A regulatory impact assessment will be conducted as part of the final decision making process. Please refer to Section 10.

dahamsta

Should be 36.6, and I'm guessing IrelandOffline will suggest that if not higher, but 28.8 is an improvement on... what is it Muck?

However I can't see Eircom taking it lying down, I think they'll battle it with more vigour than the LLU stuff. Not least because a concentrated campaign by an evil lobby group that may or may not exist could cost them serious wodges of dough. Not that I'm trying to put ideas in people's heads or anything, I'm just not that kind of person.

adam

cgarvey

This is indeed good news.. I know there are a lot of people who feel 28K8 isn't enough, but if you can get on and stay on at that speed, I do think it's functional.. you can barely SSH and you can send/receive email (that doesn't have 13MB pr0n attachments). We'd all like BB as a minimum, but we do have to be realistic.. and I know a hell of a lot of people who can only get ~12K, so 28K8 is a big improvement.

That's the theory.

In practice, I think eircom are just going to turn around to those people, who must be rural in the majority, and say sorry, but we'd have to replace the entire line back to the exchange, or have to replace the exchange loop, which will cost more than 7K, so therefore we're not going to do it. "We're not required to do it".. but at least it should force them to look at the individual lines, rather than a blanket "no can do, we're not required to".

So, in theory, I think this is great news, but I'm sceptical on the practical implementation of the theory, and how well (if at all) it's going to be enforced.

.cg

damien

Hmmm

However, ComReg believes that eircom should publicly report on the numbers of lines which do not support the target data rate. As with the data rate itself, ComReg considers that there should be a general target set which eircom should strive to meet.

End June 2005 93.0%
End Dec 2005 93.5%
End June 2006 94.0%

ComReg believes that where carrier systems are inhibiting line capabilities, such devices should be removed. While eircom has indicated that 64 Kb Carriers can support a reasonable minimum data rate of 28.8kbit/s, ComReg believes that the continued use of carrier systems should be avoided in order to avoid potential problems in the roll out of broadband. Their future use should only be contemplated in a limited number of cases and only after a full evaluation of the future potential of the line capability.

Where the capability of the line at the network connection point is found to be below the FIA target rate, ComReg considers that it is reasonable to expect eircom to use all reasonable endeavours to remedy the situation including the removal of carrier systems equipment. ComReg would expect that such a scenario would arise in only a small number of cases as requests in respect of lines which do not meet the target data speed would be low, and a commitment by eircom to address requests would remedy the capability of the line except where there are technical or economic
constraints.

Sponge Bob

It was a stonking 2.4k from March 1999 until July 2003 .

Comreg reduced that speed from 2.4k to 0k from July 2003 until (probably) July 2005 , eg by the time this consultation process is finished.

The 56k modem standard, v90, was finalised in 1996 or 1997 while the 28k modem standard, v34, was finalised in 1994. Comreg intend to ensure that everyone can benefit from early 1990s technology, standardised over 10 years ago, by 2012 .

Progress, Irish style.

cgarvey

Does any country have a 56K USO ?
Could any company viably upgrade the entire (Irish) network in a couple of years to support 56K?

28K sounds like a small number, and it is old technology, but it's a hell of a lot better than what a lot of people I know have (as in 2-3 times better!!). I still say one-step-at-a-time, and set realistic targets, but aggressive ones.

I had hoped that the target percentage would be a lot higher by June '06 though, and I still think eircom are just going to reasonbly point-blank say "no can do, it'll cost too much"
.cg

damien

Anyone think there'll be another trip to the high court ?

cgarvey

Ahh jaysus , surely not!!? They knew it was coming, they don't have to do a whole lot to improve the situation (1% of bad lines over 2 years?), especially with the help of new lines coming on stream.

Yeah, I know what was I thinking .. "yes, I do think there'll be another trip to the High Court", I wonder do they have an eircom bench in the halls?
.cg

Sponge Bob

Nowhere outside a Lab supports 56k, I have seen 53k in the wild though.

28k and the later v34bis 33.6k standards are demonstrably attainable though.

The IoffL USO submission asked for target speeds according to line length, 50k at 1 mile and 40k at 5 miles kinda stuff.

The same submission also asked for impact statements from Eircom if they proposed to mess with your Copper Loop .

Blaster99

Dialup... dialup... dialup... It rings a bell. I can't even remember what kind of speeds I used to get.

I can't imagine dial-up speeds will be worth anyone's while fighting about. The world has kind of moved on. But eircom obviously thinks dial-up is still useful considering they think installing "carrier systems" is alright because it meets the USO. Why Eircom would be so stupid as to install an infrastructure that patently cannot deliver broadband is beyond belief. They should simply be told that all new lines have to be BB capable otherwise the country will just continue on its slippery slope in the BB league tables. Enough of this short-sighted bollocks.

jwt

BB and Dial up are not mutually exclusive. If your line will carry at least 28.8K analogue then its odds-on to carry BB (at least in other countries where the telco adopts a suck it and see approach s opposed to ours where an arbitrary limit is imposed)

So adopting a 28.8 limit enables a lot more people to gain access to BB whereas before they wouldn't.

Also, a lot of people will first dabble with the internet and email using dial up, and if there first experience is made more positive because they are able to download at least at 4k a sec then surely they are more likey to appreciate the benefits of being online.

Lastly, it forces the owner of the copper to maintain it to a reasonable standard, remove old splitters, fix noisy lines (important even for voice calls )and generally provide a better quality service.

John

bminish

Sponge Bob wrote:

I tend to the opinion that 30% of lines nationally are either substandard or grossly substandard . That would be in around 480,000 lines nationally and it will take until 2034 to bring them up to a standard, v34 , formulated in 1994 if the 'upgrade ' program follows Comregs leisurely path.

In cases where customers have Lines that do not meet the new USO of 28k8 perhaps they should be entitled to a 50% reduction on line rental until such time as the line is improved.

Perhaps pairgained customers should also be entitled to a similar rental discount?

google dug this link up.
http://whirlpool.net.au/article.cfm?id=989&show=replies

.Brendan

SkepticOne

damien.m wrote:

Anyone think there'll be another trip to the high court ?

No. They would only do that if the 28.8 recommendation was binding. As it stands, there's plenty of ways around it. Almost everything in the document allows Eircom to continue exactly as they are. I don't see anywhere where it is stated that the consumer has a right to 28.8 low as it is and that Eircom are obliged to provide it.

Capt'n Midnight

cgarvey wrote:

Does any country have a 56K USO ?
Could any company viably upgrade the entire (Irish) network in a couple of years to support 56K? ...
28K sounds like a small number, and it is old technology,

56K is produced by a 64K digital line , you always loose something in the digital to analog conversion and noise on the line.
Next 56K is the download speed, upload is only about half of this because you are going in the opposite direction analog to digital.

28K is symmetrical - up or down is the same and less fancy tricks are needed than for 33.6 or 56K. Rock Solid 28.8K with no upstream bottlenecks or overcontention would be ok in remote areas if it were truly flat rate. ( 70 users on a 128Kb Leased line with large attachments )

ISDN is an alternative that dates back to the 70's
ISDN means most people could already have had 128Kb with the always on of about 9KB on the 16KB back channel.. http://www.calcuttatelephones.com/isdnfaq.shtml

Q 1 : Does ISDN connection require any special cable to be laid ?
Ans : No. ISDN line works on the same copper cable up to a distance of 5 Km (approx.) from the
Exchange/RSU. However, ISDN lines cannot be extended over longer distances as of now.

http://www.jet.net/isdn/isdnintro.html

. But even if ISDN achieves its goal of 95% deployment by the end of 1995,

- this is where we should have been a decade ago.

eircomtribunal

We now know that ComReg asked Eircom to write the (scam called) vulnerable user scheme, which enabled the company to hike the line rental. This USO is co-written by Eircom. No need to go to court over this.
It has get out clauses all over.
The target dates are ridiculous.
The language alone is telling: carrier systems should be "avoided".
"Their future use should only be contemplated in a limited number of cases and only after a full evaluation of the future potential of the line capability."
"...except where there are technical or economic
constraints."

And don't think the €7000 thresh-hold is as reasonable a it sounds at first glance. My neighbouring farmer wanted Eircom to slightly reposition three telephone poles (on a real old and vertically challenged rural make-shifty line), to the side of a field: he got a quotation for several thousand euros (I've seen it myself).
P.

damien

SkepticOne wrote:

Almost everything in the document allows Eircom to continue exactly as they are. I don't see anywhere where it is stated that the consumer has a right to 28.8 low as it is and that Eircom are obliged to provide it.

This is where the alarm bells start going off:

http://www.rte.ie/business/2005/0304/comreg.html

Speaking tonight on RTE radio Eircom's commercial director David McRedmond welcomed ComReg's consultation as he thinks it is the correct way to do regulation, with everyone contributing to the debate.

He said that if is an universal service obligation then telecoms should be designated as an essential service.

mike65

from electric news

On the surface, lobby group IrelandOffline has welcomed the ComReg announcement. "IrelandOffline welcomes ComReg finally recognising the importance of a minimum data rate after the many years of our campaigning for one. We're still examining this current consultation but any directions which will improve the quality of a customers line and increase their chance of getting broadband will be met with positive feedback," Damien Mulley, chairman of IrelandOffline told ElectricNews.Net.

Mike.

De Rebel

Mediocrity
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Mediocrity
Mediocrity
Mediocrity
Mediocrity
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Mediocrity
Mediocrity
Mediocrity
Mediocrity
Mediocrity

eircomtribunal

"He said that if it is an universal service obligation then telecoms should be designated as an essential service."

Why is Eircom so keen for USO-Telcos to be designated as an essential service? McRedmond is on about it since a while. What is in it for the company?
P.

bminish

eircomtribunal wrote:

"He said that if it is an universal service obligation then telecoms should be designated as an essential service."

Why is Eircom so keen for USO-Telcos to be designated as an essential service? McRedmond is on about it since a while. What is in it for the company?
P.

Money (I.e Subsidy's & grant aid for infrastructural improvements / expansion) along with added political clout.

Perhaps they would also then push for onerous conditions that other telcos would have to meet to offer service.

.Brendan

d-j-k

In many other countries 9600bps is all that the telcos have to support as this is fast enough for group 3 fax. I've had plenty of problems getting phonelines in other countries to support 56K modems, and that includes downtown Boston, USA.

It must be remembered that the telephone network pre-dates high speed modems by quite a bit. Most of the digital technology that's in use was developed in the 1960s, 70s and early 80s and was designed to carry voice traffic only.

Pairgain devices that date from the 1980s (which are in use by eircom) basically multiplex a number of voice lines and send them down a single copper pair. They sound perfectly acceptable for voice calls but will mangle high speed modem data due to the way the pairgain device samples the signals on the line.

Unfortunately, it seems that eircom are using pairgain as part of normal practice rather than as a last resort.

BT had similar issues a few years back where loads of lines were being provided using a pairgain technology known as DACS, the older versions of which crippled modems.

28.8kbps is a pretty reasonable speed and should also mean that the line might have more chance of passing tests for ADSL.

Btw: 56K modems don't generally connect anywhere near 56K on any phoneline anywhere in the world connections in the 30-48K band are more likely.

Also it's worth noting that US specified modems will not perform as well on a European telephone line as they will in the states. This is not due to a poor quality line, it's due to a difference in the audio codec (coding/decoding) used by switches here. 56K modems are tweaked to deal with Mu-log (US codec) or A-Log (European codec). A European modem will work fine in the US and a US modem will work fine in Europe, but they won't be as efficient outside of their home market.

I suspect that quite a few modems that made it to the Irish market are actually US spec rather than European simply because we use the US RJ11 connector system.

One final tip regarding modem speed in Ireland:

If you have a relatively recent eircom line installation you should have a white network termination unit (NTU) box as the first socket. This is a white phone socket with an eircom / telecom eireann logo and 2 screws on the front (the old style one is beige and has a single screw at the centre). This system allows you to eliminate any internal wiring faults within your home when you're testing your line.

All of your internal wiring is connected to the front plate of the socket. To test the line itself, remove the two screws and the plate will slip out. You will find another RJ11 socket behind the plate. Plug your phone or modem in here and you will be directly testing the exchange line.

If you're waiting for an ADSL test / have failed an ADSL test it might be worth doing this and plugging your phone directly into this outlet for a while as it will eliminate any internal wiring faults.

(If you have the older style beige sockets you'll need to trace the wiring back to a small square or "soap bar" shaped junction box where it enters your home. This could be in the hallway, in the attic etc... Try disconnecting everything from this and running a clean new CAT5 cable from this point to your first phone socket it can produce dramatic improvements)

Finally, there was a spate of aluminum cable used in the irish telephone system. Apparently this wreaks havoc with DSL. Check your home for grey and white twisted pair telephone cable or old (1960s/70s) twisted pair cables that have been painted over.

Any old cabling like this should, ideally, be replaced with CAT5.

lucernarian

Would CW1311 cable not suffice for connecting phone sockets? Cat5 cable is a bit heavy handed isnt it? Anyway, CW1311 is the kind of cable that was used by TÉ and Eircom for the last 10 or so years and it's twisted pair.

Regarding the setting of FIA, I'm pretty happy but I'm worried about what Comreg had to say about pairgains. Economic and "technical" get-out clauses. There is no such thing as a technical issue when it comes to v34. Every single phone line can handle it with enough investment. Many of the areas that have pairgains in use are far from exchanges, where the cost of supplying more pairs, unfortunately, will be very high. This is probably because of the fact that its very hard to lay a few miles of cable through existing ducting.

d-j-k

Well, there's no harm in running CAT5 a few extra pairs won't hurt you can always ditch the phone connections and move to ethernet as time goes on. CAT5's also cheap and easy to pick up on the web.

MadsL

CAT5's also cheap and easy to pick up on the web.

Even cheaper and easier to pick up out of a skip, there must be several kms of CAT5/CAT6 cable thrown away in Dublin every week....

damien

So back on topic. Opinions on the USO and FIA.

AndrewMc

damien.m wrote:

So back on topic. Opinions on the USO and FIA.

Quick notes, that I hope to get time to flesh out and submit properly.

Q.1. Do you agree with the considerations which ComReg has outlined
regarding the setting of a threshold? Please state why. If you disagree please
give reasons. If there are any other considerations which should be taken into
account by ComReg in setting a threshold, please provide your reasoning.

Agree that "consumer interest" is far more important than Eircom's costs. However, are we the least-densely populated country, or so unique in our dispersal that this is justified?

(Note - anybody have details on how other countries charge for installation based on geographical remoteness? Or how the ESB charges?)

Q.2. Do you consider that in order to provision a connection to the eircom
network a €7,000 threshold is reasonable in the context of the Universal Service
Obligation regarding the provision of access at a fixed location? If you
disagree, please propose an alternative along with your reasoning.

Setting any such threshold immediately counteracts the whole point. Anybody remote who's not rich enough can't get a phone line, which is the opposite of "universal access".

Secondly, no monopolistic commercial entity should be trusted on setting price, ever. This is even more critical on a service people don't really think of as optional. Having no such cost threshold, but certain standards, encourages efficient, forward-looking, sensible implementation. If a company doesn't want to do something the easiest way to make the consumer go away is to set a price it knows the consumer cannot bear.

Q.3. Do you agree with measurement of the connection costs as proposed by
ComReg? Please specify any alternative measurement and outline your
reasoning.

I disagree with measurement of connection costs entirely. As well as the reasons in reply to Q3, it adds administrative overhead for everyone.

Q. 4. What are your views regarding the setting of performance targets for
meeting requests for connection.

Performance targets are crucial, especially in an essential service operated by a commercial monopoly. I believe the targets given are too light - the 52 week target, in particular, is far too long, and should be certainly no more than six months.

The force majeure criteria should be explicitly listed to be things such as planning difficulties (due to the council/authorities, not slow/late applications) and acts of God. It should, in particular, not include things such as Eircom claiming they can't get the contractors to do the job. I know from personal experience they can find them if they really want to.

Q. 5. What are your views on information to be provided to the customer;
should these issues be addressed in some other way? If so state what other
options you consider appropriate and your reasons and justifications for them.

• The customer must immediately, or within one working day, be notified if an installation is non-standard. Eircom should be able to make a genuine effort when an application is made to determine if this is the case, and not just guess.
• I agree that customers must be kept regularly informed. However I suggest a certain minimum amount of contact be specified, such as either (a) every four weeks, or (b) any time the delivery date changes. It should never be the case that the customer discovers the delivery date has changed due to a customer-initiated enquiry. Chasing up a company every few weeks for a year is ridiculous.
• Delivery dates should be realistic.

Basically, the customer should always know what's going on without having to chase up the company. Over-optimistic delivery dates can cost the customer dearly when they decide to forego interim measures (ah, sure, it's only two weeks), or make other decisions on the basis the line will be provided on time.

Q.6. What are your views on a reasonable minimum data rate of 28.8 kbit/s
being set as a minimum target speed?

In modern times such a data rate is very, very low and would be considered by few to be "functional" in terms of actual use. Although current USO requirements do not include broadband, the limit could be considered an opportunity to ensure that lines are kept to a quality that would have a better chance to provide broadband in the future. After all, investment in the network is why our line rental is astronomically high.

Q.7. What are your views regarding non-binding performance targets for the
overall network in respect of minimum data rates?

Non-binding targets are useless in a market operated by a commercial monopoly. If the network is in a poor state, that is as a result of low investment (less than depreciation) by the owner of the network. They should not be compensated by giving them extra leeway.

The target line improvement rate is very slow (at 1600000 lines, it's just 60 per working day), although I accept you don't want to give Eircom an excuse to pull back on DSL even more... More useful would be to give priority to customers who complain about line quality, since they obviously need it, with a maximum time for resolution of say 3 weeks.

I agree that Eircom should report, perhaps on a quarterly basis, the total number of lines upgrade, the number of lines about which complaints were received, and the time taken to resolve those complaints.

Q.8. What are your views on the use of Carrier Systems Equipment? Should
their future use be limited in the interest of DSL deployment? What should the
position be where limiting new deployment might result in an applicant for
service having to pay excess charges or in delaying the provision of a telephone line?

I agree carrier use should be discontinued for the good of broadband in the future. Carriers could be used only in extreme cases, and only with the consent of the customer on the understanding that it limits data throughput. If the customer does not agree, they should not be used, and the operator should be prepared to remove them if the customer subsequently requests broadband.

Q.9. What are your views on the guidelines to apply in connection with
functional Internet access? Are there other issues which should be specifically
addressed by the guidelines?

Partially answered before. Note that Eircom's system for testing line quality should allow for the fact that failures can be intermittent. Intermittent failure is not "functional". A phone line that gives poor quality on a breezy day might test as clear on a calm day.