RE: Eircom meeting

dahamsta

I think someone needs to echo what My Perfect Cousin said in another thread: There's no point in asking Eircom's Director of Regulatory Affairs about consumer pricing, caps, or anything technical for that matter. It's simply not part of their job. Asking questions outside their field will result in non-answers, and so limit the amount of time available for Ireland Offline to ask questions about regulatory issues that can and should be answered and addressed by Eircom.

Ireland Offline can - and should - tackle these other important issues by requesting meetings with other representatives from Eircom, who would be more suited to answer these kind of questions. The manager of broadband operations would be the first person that comes to mind, since broadband is fast becoming a contentious issue. If other representatives refuse to meet with Ireland Offline, or appear to be stalling on meeting with the organisation, the option is always there to report this to the press and force the issue.

The questions in this meeting need to concentrate solely on regulatory issues and the issues that surround regulation. Some examples follow, in no particular order. (For simplicity, the Director of Regulatory Affairs will henceforth be referred to as "the DRA".)

1) Does the DRA believe that Eircom is co-operating to the fullest extent with the ODTR[1] and the OLO's[2] to facilitate LLU[3] and fair competition in the telecommunications marketplace?

1a) Please explain in detail, from a regulatory perspective, what Eircom are doing to facilitate the issues mentioned above.

2) Eircom has still not agreed some of the pricing structures for LLU, which is seen by many as a stalling tactic on the part of Eircom. Will the DRA concede that this demonstrates, or has demonstrated, Eircom's lack of commitment to their regulatory responsibilities?

2a) If the DRA concedes to the above, what is the DRA doing to correct this problem?

2b) If the DRA does not concede to the above, who does the DRA hold responsible for the problem? There are three primary parties involved here, the ODTR, the OLO's, and Eircom. Which does the DRA feel is most responsible?

(Please note that a political answer will not suffice for this question. The LLU process is over six months behind schedule, in contravention of a European Commission Directive, and this can be attributed almost entirely to the pricing issue. Blame has to be apportioned so the problem can be corrected and future problems can be avoided.)

3) A comparitively large number of complaints have been filed against Eircom with the ODTR, not just with regard to local loop unbundling, but also other issues that come under the brief of the Regulator, including, but not limited to: pricing, interconnects, SLA[1] breaches, and general co-operation issues. A large majority of the Notices issued by the ODTR on these matters have been decided against Eircom. Does Eircom believe they have been unfairly treated by the Regulator, or do they concede that the Regulator was correct and that Eircom have been mishandling some or all regulatory issues?

4) From a regulatory perspective:

4a) Are Eircom prepared for LLU?

4b) Do Eircom have comprehensive plans in place to facilitate access to exchanges and the local loop, as required by the Regulator?

4c) Do Eircom have a timetable in place for LLU?

4d) Please give an overview of the above-mentioned timetable.

5) Have Eircom brought any legal proceedings against the OTDR, or are Eircom preparing to bring legal proceedings against the ODTR? (Note that an initiation of legal proceedings against the ODTR is a regulatory issue, even if it is related to pricing. Obviously, I will respect any legal reason which prevents the DRA from commenting, but if there are none I would like an answer. (Citing company policy is not an answer.))

6) Does the DRA believe it has a monopoly on fixed lines in Ireland?

6a) If the answer to the above is yes, please explain why Eircom is allowed to continue in its dominant position. Is the monopoly sanctioned by the Irish government or legal system in some way?

6a) If the answer to the above is no, I would like to point out that according to competition law, Eircom is by definition a monopoly in this particular sector. Please explain how you have come to this conclusion.

7) The telecommunications infrastructure in Ireland was developed using taxpayers money before the company was privatised. Does Eircom believe it has an exclusive right to that infrastucture now that the company has been privatised?

7a) If Eircom believes the above is true, please explain the reasoning behind that belief.

7b) If Eircom does not believe the above, please explain why Eircom has not facilitated fast-track access to that infrastructure?

8) Eircom has stated publicly that it is not content with the wholesale pricing guidelines the ODTR has released with regard to LLU. What pricing would Eircom be content with?

9) Will the DRA give a guarantee to Ireland Offline and the consumers and businesses it represents that the DRA and Eircom will assist the ODTR and OLO's in every way possible to facilitate LLU quickly and efficiently?

adam

[1] Local Loop Unbundling
[1] Office of the Director of Telecommunications
[2] Other Licenced Operators (Esat, etc.)
[3] Service Level Agreement(s)

[There's always something, isn't there?]

[This message has been edited by dahamsta (edited 13-07-2001).]

LegacyUser

<font face="Verdana, Arial" size="2">Originally posted by dahamsta:
Asking questions outside their field will result in non-answers...
Ireland Offline can - and should - tackle these other important issues by requesting meetings with other representatives from Eircom, who would be more suited to answer these kind of questions. </font>

We're thinking of doing same thing as we did with ODTR - give them list of prepared questions in advance so they have no excuse for non-answers and *hopefully* will have people present to deal with the areas we are talking about.

Martin

LegacyUser

I agree w/ both of you in terms of asking the right questions and sending them a prepared list. I cant imagine anything more infuriating than trying to get answers out of an eircom "suit",looking like a rabbit caught in headlights when you put the tough q's to him/her. If this was to happen the meeting would most likely not be very productive.Thus I think we should all try to contribute to a comprehensive list (like the ODTR meeting) to allow the cmmtee to forward it on. Adam a usual has thrown up some intriguing q's for eircom to answer.

(any news on a venue for thurs yet??)

80p.

LegacyUser

<font face="Verdana, Arial" size="2">Originally posted by o_donnel_abu:

Originally posted by dahamsta:
Asking questions outside their field will result in non-answers...
Ireland Offline can - and should - tackle these other important issues by requesting meetings with other representatives from Eircom, who would be more suited to answer these kind of questions. </font>

We're thinking of doing same thing as we did with ODTR - give them list of prepared questions in advance so they have no excuse for non-answers and *hopefully* will have people present to deal with the areas we are talking about.

Martin

you lads are taking this very professional,

LegacyUser

Based on dahamsta's question 8 I would like to add a follow-up:

8a) The ODTRs pricing was based on the European average for "efficient operators". If the Eircom will only be content with a higher price , please outline the factors that raise this price above the European average.

Bard

<font face="Verdana, Arial" size="2">Originally posted by Gladiator:
you lads are taking this very professional,</font>

It has to be done when dealing with big businesses. Acting in a professional manner is important in such situations, Gladiator. Besides ensuring that the people we are dealing with (such as Eircom) take us seriously, it gives a better public image of IrelandOffline, and - well... it's a mixture of common decency, common sense and respect to be professional in all such dealings.

We know what we want, we know what we're talking about, we've got people behind us, and we're not going away

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Bard

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I've got a plan... and it's as HOT... AS MY PANTS!!!" - Lord Flashheart.

[This message has been edited by Bard (edited 14-07-2001).]

LegacyUser

Please see new topic "IOFFL - Proposed questions for Eircom"

Martin