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Comreg consultation on 2.6GHz + other spectrum rights

Comments

  • #2
    watty
    Registered Users Posts: 32,417 ✭✭✭✭watty


    They almost certainly have already decided


  • #3
    clohamon
    Registered Users Posts: 1,762 ✭✭✭clohamon


    Apogee wrote: »
    "Is there anything to be said for launching another consultation?"

    They are potentially looking at the 700MHz, 1.4GHz, 2.3GHz and 3.6GHz bands as well.

    It looks like a re-run of the MBSA (Dec '12). Same consultants and same arguments.

    You should make a submission anyway.


  • #4
    watty
    Registered Users Posts: 32,417 ✭✭✭✭watty


    I'd rather campaign to abolish National Regulators and have an EU one answerable to European Parliament with charter of best Infrastructure and Citizens first. With planning, management, efficiency and performance a higher priority than Competition.
    NO licence fees at all for ANY spectrum, but instead Service Obligation based licences, "policed" monitoring of use, charges, performance and coverage (95% to 99% geographic depending on service) for all kinds of spectrum usage. No priority to any one kind of service but BALANCED and sensible allocation of Fixed Data, Broadcast (AM, DRM, DAB, FM, Digital TV etc), User licence free (Wifi etc), Mobile, Satellite (Broadcast, Data, navigation), telemetry, Military etc.
    The spectrum usage is being hopelessly damaged for generations to come due to over emphasis on Mobile and revenue from Licence.
    No sharing of spectrum between different kinds of services or "White space, licence free or licensed), that is political and stupidity. Greed of Corporations like Google, Apple and Microsoft.
    A revised CE scheme for all electronics that has approved 3rd party testing and in market policing and improved standards of longlivity, repairability, reuse, recycle, immunity to interference, quality ratings, reduced and properly measured generation of interference.
    In 1970s there was DIN for HiFi. Now we have a CE mark that means nothing. We have meaningless A to F energy ratings on electrical stuff. We have misleading specs on lamps in terms of brightness vs life vs energy that are tantamount to lies.
    We have things marketed as Broadband that can't ever be. Digital Radios that are poorer than 1965 AM/FM sets with x6 power consumption.
    Stuff for sale (Phones, Radios, Chromecast, Tablets, screens etc) with no real spec on the box at all. How do you know if a phone is GSM only? Or if a Smart Phone does EDGE, or which 3G and/or 4G it supports? Or what WiFi speeds and encryption a gadget supports?

    Comreg is a waste of space. So is Ofcom. They have narrow agendas. They are not accountable and are driven by licence revenue. They want to abolish Terrestrial Broadcast. Broadband, Mobile and Terrestrial Broadcast are complementary technologies. Satellite Broadcast and Fibre/Coax can't replace Terrestrial Broadcast ever.


  • #5
    clohamon
    Registered Users Posts: 1,762 ✭✭✭clohamon


    watty wrote: »
    I'd rather campaign to abolish National Regulators and have an EU one answerable to European Parliament with charter of best Infrastructure and Citizens first. With planning, management, efficiency and performance a higher priority than Competition.

    There's hope. Article 13 (page 43) of Connected Continent provides for European oversight of ...
    (a) the type of authorisation process;
    (b) the timing of the authorisation process;
    (c) the duration of the rights of use;
    (d) the type and amount of radio spectrum available, as a whole or to any given undertaking;
    (e) the amount and structure of any fees to be paid;
    (f) compensation or incentives regarding the vacation or sharing of radio spectrum by existing users;
    (g) coverage obligations;
    (h) wholesale access, national or regional roaming requirements;
    (i) the reservation of radio spectrum for certain types of operators, or the exclusion of certain types of operators;
    (j) conditions related to the assignment, transfer or accumulation of rights of use;
    (k) the possibility to use radio spectrum on a shared basis;
    (l) infrastructure sharing;
    (m) minimum technology performance levels;
    (n) restrictions applied in accordance with Articles 9(3) and 9(4) of Directive 2002/21/EC;
    (o) a revocation or withdrawal of one or several rights of use or an amendment of rights or conditions attached to such rights which cannot be considered as minor within the meaning of Article 14(1) of Directive 2002/20/EC.

    But as it's now proposed as a Directive rather than a Regulation it may take some time to implement.


  • #6
    Apogee
    Registered Users Posts: 3,769 ✭✭✭Apogee


    They have also released an accompanying consultant's report.
    http://www.comreg.ie/_fileupload/publications/ComReg14102.pdf


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  • #7
    clohamon
    Registered Users Posts: 1,762 ✭✭✭clohamon


    The Oireachtas Joint Committee on Transport and Communications recently met representatives from DCENR and ComReg. During the meeting Deputy Timmy Dooley enquired about the relationship between revenue raised and the coverage conditions in the spectrum auctions of 2012, and compared it to the sale of Telecom Eireann.
    “With regard to mobile broadband, does ComReg think the way the State sold access to the radio frequency spectrum acted as a disincentive to companies to achieve the broadest geographical cover? Deputy O'Donovan was very quick to try to suggest that in a previous era the then Government's sale of Eircom had an impact on the roll-out of broadband and the fixed-line business. I would accept that because of the large price paid by the company which bought it. Have we learned nothing from the decisions taken then? We are still selling spectrum for 4G, tempting and all as it might be to take in close to €800 million, but is that effectively spancelling the people who purchase these licences in any attempt to give the greatest geographical spread? Would we be better, in selling spectrum, to demand 100% geographical cover in return for the licence to operate rather than eliminating a portion of the geographical area, concentrating on population and taking a once-off windfall payment which, sadly, will get spent? We will then have large tracts of rural Ireland with no access to mobile broadband and poor mobile phone coverage.”


    In response, the Commissioner asserted that auctions and high coverage obligations were mutually exclusive.
    “Pricing was, in some ways, a mechanism to sort out who felt they would most use the spectrum in providing a service to consumers. I suppose the Deputy contrasted that with other countries which have very significant or onerous coverage obligations rather than running an auction.”

    The Commissioner then asserted that competition and coverage were mutually exclusive.
    “There are different choices here in terms of State intervention and whether one wants to pay for coverage levels versus allowing for a competitive marketplace.”

    Who knows what the Commissioner was thinking when he made those assertions, but the meeting ended before Deputy Dooley had a chance to enquire any further.


  • #8
    watty
    Registered Users Posts: 32,417 ✭✭✭✭watty


    So they don't care about the consumer, only raising revenue. We knew that.


  • #9
    clohamon
    Registered Users Posts: 1,762 ✭✭✭clohamon


    watty wrote: »
    So they don't care about the consumer, only raising revenue. We knew that.

    Yes we knew that, but coverage is not the enemy of auctions or competitive markets. If Commissioner Kevin O'Brien didn't mean that, then he should have corrected it.


  • #10
    watty
    Registered Users Posts: 32,417 ✭✭✭✭watty


    clohamon wrote: »
    but coverage is not the enemy of auctions or competitive markets.

    Unfortunately it is. The less coverage rules the more they can cherry pick where to put infrastructure, maximise profit vs Investment. Then people may pay more for licence.

    Also a competitive market is the enemy of capacity & efficiency. The mathematically provable (x4 better typically) best capacity & efficiency solution is to have only one physical network operator and very strong sensible regulation. Getting rid of incumbents wasn't the solution, but proper regulation was.

    Telecoms (copper, cable, fibre or Wireless) isn't like making & selling nail varnish or baked beans. Telecoms infrastructure is a limited resource it makes sense to have only one of at the physical level. By all means have retailers and MVNOs that try to add value and compete marketing. The public shouldn't have to deal with the Network Infrastructure people. The MVNOs of the Coax cable or Copper (both of which adding fibre and Cable folk best suited to do FTTH/FTTP in Urban and Copper folk best suited to do FTTC/FTTK etc elsewhere) and regulator would be the logical people to put pressure to deliver coverage, speed, capacity.

    If the network owners are competing for public in absence of strong regulation, then the Public is ignored and the Operators Cherry Pick to maximise ROI and also minimise investment. Consolidation of operators such as O2 and Three in current climate will result in removal of bases and reduction of capacity (and slightly less coverage) where it makes more profit after costs, overall.


  • #11
    bk
    Moderators, Motoring & Transport Moderators, Technology & Internet Moderators Posts: 22,457 Mod ✭✭✭✭bk


    I have to disagree with you Watty. I'd rather there be two network operators (two physical copper/coax/FTTH networks and two wireless networks) in urban areas, with MVNOs operating on both networks.

    This would ensure a level of competition at both the operator level and the MVNO level. The operators would compete with one another to attract MVNO's who would in turn compete with one another to attract customers.

    In low density (rural) areas then one well regulated network operator with multiple MVNO's on it would make more sense.


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  • #12
    watty
    Registered Users Posts: 32,417 ✭✭✭✭watty


    I don't think we are saying anything different. I expressed myself poorly. One Urban operator would be formerly coax and other copper, but both migrating to hybrid fibre or fibre to premises. Cable should have MVNO for data. TV on Coax/Fibre is more more complex, but first Sat operators Pay TV operators would need to banned Europe wide from having any share in Channel ownership.

    I'd like to see TV packages banned and channels selling direct (but able to sell a group of channels if they own 51% and also offer the channels individually at no more than 15% expensive per channel. Unlike the Analogue Cable/Satellite Era the conditional access mechanisms now support this.


  • #13
    clohamon
    Registered Users Posts: 1,762 ✭✭✭clohamon


    watty wrote: »
    Unfortunately it is. The less coverage rules the more they can cherry pick where to put infrastructure, maximise profit vs Investment. Then people may pay more for licence.

    The point was that auctions can be positive or negative. Its the licence conditions that make the difference.
    watty wrote: »
    Also a competitive market is the enemy of capacity & efficiency. The mathematically provable (x4 better typically) best capacity & efficiency solution is to have only one physical network operator and very strong sensible regulation. Getting rid of incumbents wasn't the solution, but proper regulation was.

    The point has been made here many times that competition can happen without infrastructure duplication, triplication, quadruplication.


  • #14
    Apogee
    Registered Users Posts: 3,769 ✭✭✭Apogee


    Non-confidential submissions, including one from IrelandOffline.
    http://www.comreg.ie/_fileupload/publications/ComReg1515.pdf

    Information notice following submissions - 3.6GHz will be dealt with separately.
    http://www.comreg.ie/_fileupload/publications/ComReg1514.pdf


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