The Future Framework for the Regulation of Universal Service in the Irish Market.

kamobe

Nice long doc file found here. Quite long (as you'd imagine), but quite interesting also. I havent gone through it all(I'm fairly tired) but what jumped out at me straight away was on page 30, affordability.

Affordability is an important element of universal service and in Ireland this is maintained through mechanisms such as the Price Cap. The current price cap which has been in place since January 2000 and is currently under review provides that eircom must reduce charges to consumers by 8 per cent before inflation every year for that period.

And of course there's plenty more...

If this has been posted elsewhere, just reply and let me know, and I'll delete it. Otherwise, happy reading.

MDR

*groan* ...

spongebob

spongebob

The RFC period ends on the 11/02/03 so we can digest this along with the turkey over christmas. The Doc , may I re-iterate, is Here

The Key paragraph I noted in here is on page 13 of the word DOC.....what is wrong with PDF or HTML in this day and age ?

Given the growth in dial-up Internet access over recent years, the speed of data transmission over the network has become of increasing importance, particularly where it involves access to e-commerce or to e-government services. In a universal service context, the issue of social exclusion becomes relevant, particularly if the services being accessed by the majority come to be seen as essential for full social and economic inclusion. In this regard, the regulations require that the connection must be capable of supporting ‘functional’ Internet access. Functional is described in the recital 8 of the Universal Service and End Users’ Rights Directive as speeds of up to 56kbits/sec (current Legislation requires that a connection must be capable of transmitting data via modems at 2,400 bits per second), however, it is explicitly recognised that the data rate is dependent on a number of factors which include the level of network development, modem speeds, the subscriber’s terminal equipment, the given application for which a connection is being used, and the ISP connection.

Indeed.

Her 1999 USO regulation is described as 'legislation' , be the holy fcuk. I thought that minishter Ahern was the legislator while she belonged to the executive branch. Then again WTF do I know.

The interesting stuff from our point of view comes in in 3 separate strands.

The first is between pages 12 and 16 (Data Rates and Line Quality in the E-Tub ).

The second strand concerns Affordability ...FRIACO and other non marginally costed products between pages 29 and 30

The third strand also concerns FRIACO , Control of Expenditure as a separate issue from Affordability. This is in between pages 31 to 34.

I am aware taht many of the regulars here are in rented accomodation. I believe the responses to strands 2 and 3 should be couched in a manner that is not iniquitous to the rented sector....maybe even skewed in their favour..

Remember that these are Individual rights and not contract law. If there is a dispute then the right of the individual not to be discriminated against will always take precedence over the 'small print' last 10 pages of twaddle in the €ircon contract.

That makes 11 pages to read as an amuse-bouche or a digestif over the christmas.

Finally, on the last page it sez

Having analysed and considered the comments received, ComReg will review the position and publish a report in March on the consultation which will, inter alia summarise the responses to the consultation.

In rgspk this means!

Jan Feb we respond to this doc.
Mar she responds to the responses with a summarisation and a hint of which way she is minded to turn.
May (ish) She issues a new USO ......this may not have force of law until July

M

spongebob

The USO directive is seen by some as being a 'narrowband' directive. The Access directive is considered by some to be a 'broadband' directive. I have no opinion on that....save what I may post into a thread on the Access directive.

1. The USO directive stipulates standards for narrowband which are essential precursors to broadband. If your line is crap you cannot have broadband, way it is. If the standards in the USO are applied your line will not be crap and you MAY then get broadband.

2. It also stipulates that the user has the right to control costs and affordability and prepayment is a means to this end, therefore it could have a great influence on FRIACO which is a mandatory policy objective for Comreg....from around the 11/02/03 as it happens when the replies should be in.

M

Xian

<stolen from a moved thread>

Originally posted by Muck
I have an ambient dampness/linespeed drop correlation issue.


Here, I think, is the crux of the consultation - an amuse-bouche which, like other produce from the same confectioner, is sweet at first but leaves a bad taste in the mouth.

For argument's sake, say we ask for a minimum bit rate of 512Kb/s and it is accepted. In the consultation it notes:

Respondents should note that were a specific bit rate to be required, this would have to be set having regard to the overall capability of the network, including technical constraints. In addition, where a universal service obligation (such as meeting a functional internet access requirement) gives rise to net costs and an unfair burden on the operator concerned, the costs may be recoverable through an industry funding mechanism which ultimately may involve costs being passed on to consumers in terms of increased prices.

That means, in effect, that we would be paying for the upgrade, paying Eircom for the renovation job, so to speak. That should not be our intention. Our intention should be for Eircom to maintan their network as it should be maintained, no more, no less. The key phrase in Annex IV of the directive ("Calculation of Net Cost") is "services which can only be provided at a loss or provided under cost conditions falling outside normal commercial standards." Any owner of a network - be it gas, electricity or communications - should be responsible for the maintainance of its network. The purpose of the USO with regard to bit rate is to ensure this.

So what do we ask for? 56Kb/s? No. Because the above circumstance would be one of the many listed, in the consultation and the USO directive, that would bring the requirements for upgrade of the network to reach this minimum standard beyond the bounds of a "fair burden". How then, Muck, can we agree on a figure that will require Eircom to maintain their network to an acceptable level and yet not impose an unfair burden, a burden which, as sure as the bear's a Catholic, will be offloaded on us.

yellum

Originally posted by Xian


How then, Muck, can we agree on a figure that will require Eircom to maintain their network to an acceptable level and yet not impose an unfair burden, a burden which, as sure as the bear's a Catholic, will be offloaded on us.

Can't answer for Muck, how about if they are required to provide an alternative if the local network equipment isn't up to scratch ?

spongebob

46 - 48k within one mile of the exchange and then dropping no more than 2k a mile to 5 miles......

meaning 38-40k at 5 miles. I get 48k one mile from the exchange on overhead cable with a shedload of joints ....at least 7 in that mile.

That goes in the USO then as acceptable.

The fastest I ever got was 53k on the same modem but that was where the A/D conversion was on the premises and not down the exchange a mile away.

What we cannot get ...THIS time....is a faster than 48k standard, the USO directive refers to Analogue lines only. A good analogue connection is an essential precursor to Broadband in the next USO in 3 years. By then it should be available to 80% of the population or more.

Lest anyone think I am making excessive demands of Eircom we should look at what the ESB does.

The ESB provides 220 Volts + or - 10%. Thats the universal entitlement and they deliver that. I'm letting Eircom away with 56k -(8k to 10k ....comfortably over 10% of the notional maximum) for starters.

M