USO Comreg Finally Respond to Consultation

spongebob

Its 77 pages long. Most of the interesting stuff is between pages 20 and 30 TBH

Full Response to Consultation Here

While a document like this was always going to be a curates egg. Here are a few snippets and please note (page 9)

Comreg would welcome comments on the impact of the proposals set out in this paper.

By 04 July to carol.donohue@comreg.ie

1. Pairgains and proper internet speeds. Comreg have dropped the ball on this. They will require Eircom to notify Comreg of where they are. They seem to think that the consumer need not know they are paying extra for a crap service.

This is on pages 28/29

However, it is also clear from consultation responses and from the consumer
complaints received by ComReg that certain issues in relation to internet service
provision should be tackled. One key issue relates to the provision of service over
carrier access systems/pairgain devices. ComReg recognises that where there is no
other commercially/cost-effective or technically viable alternatives, the use of these
devices may be required. Depending on the systems employed it may affect the data
rate experienced by the user. However, some pairgain systems support 56Kbit/s
modems.
ComReg is of the view that data speeds of 14.4 to 19.2 kbps (note that these speeds
may not reflect actual modem speeds as experienced by users via their Internet Service
Provider) may not constitute satisfactory internet access. While ComReg does not
intend to specify a specific bit rate, there is a need to reduce the number of carrier
access systems in use and/or allocate the resource to those users who have no
requirement for internet access. ComReg will therefore engage with the USP to assess
the level of use of carrier access systems and may require the USP to develop a detailed
plan on how to address this issue moving forward.

They go on to fumble the ball a bit more

It is considered that the issue can be addressed in a managed fashion through its
incorporation into the USP’s network development plans which, while subject to
normal commercial criteria, must also consider regulatory obligations.
Therefore, ComReg’s approach in relation to functional internet access can be
summarised as follows.
• Connections to the public telephone network at a fixed location should be
sufficient to support satisfactory internet access equivalent to that enjoyed by the
majority of users, having regard to the prevailing technologies used by the majority
of subscribers and to technological feasibility.
• The USP should publish a statement which sets out the range of factors which can
affect its network performance (and are within its control) and therefore the data
speeds experienced by internet users.
The Future Framework for the Regulation of Universal
Service in the Irish Telecommunications Market
28 ComReg 03/68
• The USP should quantify the proportion of users whose internet speeds may be
affected through the use of carrier systems/pairgain devices in its network.
ComReg’s discussions with the USP will focus on how these issues can be addressed
and further public consultation may be appropriate. This will be included as part of a
wider policy statement to by published by the USP regarding the delivery of universal
services.
With regard to the establishment of a flat rate internet product for secondary schools,
there is no provision for this under the USO Directive. Nonetheless since the
publication of this consultation on universal service, ComReg has required that a flat
rate internet product is to be made available for Irish consumers. This will be available
as a wholesale product to other licensed operators and should ensure affordable internet
access at competitive prices is available to Irish consumers in the future.
Commission’s Position
On the matter of functional internet access, the USP will be required to
(a) develop a public statement which sets out the range of factors which can affect its
network performance (and are within its control) and therefore the speeds enjoyed
by internet users.
(b) inform ComReg of the number and location of connections to the public telephone
network that employ carrier systems/pairgain devices
(c) subject to further discussions with ComReg, develop a plan for addressing network
performance issues that affect the speeds enjoyed by internet users.
The USP will be required to publish the information in paragraphs (a) and (b) as part of
its wider policy statement regarding the delivery of universal services.

I am glad that Comreg took the IoffL position on the right to select the range of diallable number from a landline. The IoffL submission was that a user could opt in or out as they saw fit.

Page 60 notes

It is ComReg’s intention to require the Universal Service Provider (USP) to provide
selective call barring facilities for outgoing calls to National, Mobile, Premium Rate
and International Calls. The premium rate call barring facility shall be free of charge
for users.
The USP will be required to submit a detailed proposal to ComReg within three
months following designation as to how the issue of an unbundled mobile call barring
facility can be dealt with.

Y 'all should have a few words with Comreg at the email address above. Comreg appear to have completely ignored the vast number of Wireless licences they granted to Eircom for the purpose of service provisioning "AT A FIXED LOCATION". They muttered about a review at some stage but that clause is horrendously vague.

July the 4th is the last date that they will listen. Then it will not change for 3 Years or more.

M

SkepticOne

I've just read through the document and I'm very disappointed. By being vague on the important issue of bitrate, they have given Eircom licence to abuse the consumer once again.

spongebob

they have an ambitious 20k in mind, along with Consultations with Eircom that will no doubt last 3 years....same as the USO

There IS time for another forceful submission by July 4th ...thank God. What did ye think of Eircom stating it would cost €2Billion to rewire the network to guarantee 56k (or 48k which is technically feasible except that nobody asked for it)....its only worth €1.5 Billion in its entirety .More cuckoo bookeeping.

IoffL proposed a stepped approach to no lower than 33.6k at 5 miles (48k at 1 mile). It did not ask for ANY new exchanges at all but that Eircom should clean up its wiring and provide a universal standard.

Comreg also dropped the ball on informing the AFFECTED CONSUMER who has a pairgain. How does that fit in with the principle of transparency and universality ?

M

Mossy Monk

14.4 to 19.2 kbps may not constitute satisfactory internet access.

that is disappointing. i'll take it that those at Comreg have never had to endure really poor dial up connection speeds. it takes me an hour to download 4 MB at 16.8 kbps. all the houses down my road have the same speed. everyone in the country should have at least 33.6k

pepsiman

Maybe not relevant here, but at work today I read some of the Comreg documents, and were literally shocked to see they talk about ISDN as being broadband. Anyone know if this is an official Comreg point of view or just convenience. I'll provide links tomorrow (when at work) if anyone wants. It takes bleeding ages to download over my poxy 40kbit connection...

/T

spongebob

Originally posted by Mossy Monk
that is disappointing. i'll take it that those at Comreg have never had to endure really poor dial up connection speeds. it takes me an hour to download 4 MB at 16.8 kbps. all the houses down my road have the same speed. everyone in the country should have at least 33.6k

I lived somewhere like that. Always connected at 16.8k and so did me neighbours, 3.2 miles from the exchange. We all should have had wireless.

Xian

Originally posted by Muck
What did ye think of Eircom stating it would cost €2Billion to rewire the network to guarantee 56k (or 48k which is technically feasible except that nobody asked for it)

This was their response to the setting of a bit rate of 56kb/s, something we explicitly did not ask for. What we asked for was for a bit rate to be set such that pairgain systems are removed. The telling response, therefore, followed:

5.1.2.2...the cost of replacing all existing carrier systems would be at least €90 to €100m.

This is the first indication we've had of the extent of the problem. As the document says:

10.3...A [...] respondent felt that services which fell within the bounds of a reasonably maintained network should be outside the definition of an unfair burden

The decision of the cost to the USP in relation to "unfair burden" remained undecided. The possibility remains, therefore, to call on ComReg to include the request for a full copper pair in the "reasonable request" criteria based on the fact that the cost to Eircom will be a percentage of the full stated cost to remove all splitters from the network, and therefore fulfill the "fair burden" requirement, given the fact that

5.1.2.4...there is a need to reduce the number of carrier access systems in use

and

5.1.1.4...reasonable endeavours should be made by the USP to provide users with 'full' connections

also taking into account the fact that

5.1.2.4...some pairgain systems support 56Kbit/s

viz. http://www.inoviatele.com/Products_PtP/PtP_PentaGain.asp [thanks Ray]

Dawg

Maybe not relevant here, but at work today I read some of the Comreg documents, and were literally shocked to see they talk about ISDN as being broadband

ComReg definition of broadband can be found here
3.1 Definition of Broadband

The concept of broadband is normally defined in terms of capacity6 (or speed of data transfer) provided on a telecommunications network. A relatively high level of telecommunication capacity is generally referred to as ‘broadband’7. However, this definition can create confusion as it raises the question as to what constitutes a ‘relatively high level of telecommunications capacity’. In 1997, the ITU issued a recommendation that transmission rates greater than Primary Rate ISDN (i.e. approx. 2Mbit/s or above) be considered to be ‘broadband’8. However in its studies, the OECD defined broadband as providing downstream access of 256kbit/s and upstream access of 128kbit/s. Elsewhere, in a study of 14 countries by the Canadian National Broadband Task Force, broadband definitions ranging from 200kbit/s to 30Mbit/s were reported9. The extent of the disparity reflects ‘forward-proofing’ by some countries10. Given this emergence of multiple definitions, there have been some suggestions recently towards defining broadband in terms of functionality rather than a specific minimum capacity. In 2001 the ITU suggested that any network capable of carrying full motion video could be considered broadband11. Such an approach would counter the problem of evolving end-users’ expectations of broadband, but would exclude most of today’s ‘broadband’ connections via cable modem and DSL technologies. In May 2002, in their most recent report, the OECD stated that “it may be better to think of broadband as a wide set of technologies that generate some minimum level of high speed bandwidth interconnection”12. By including the words ‘high-speed’, but not specifying a minimum capacity this definition brings us back to the earlier definition of “a relatively high level of capacity”. Furthermore, the always-on or packet-based (e.g. IP based) characteristics of some broadband technologies (e.g. DSL, Cable) are becoming generally accepted as part of the broadband definition. For the purposes of this report, we have decided to define ‘broadband’ as capacities of 512kbit/s13 and above in the portion of a network that a customer uses to connect to a service provider – i.e. the access network14. However, we regard this as a somewhat arbitrary working definition, and we recognise that technological and market developments may require us to revisit this definition in the future. It should be noted that the definition excludes Basic ISDN connections (max. speed of 128kbit/s) of which there has been strong growth over the past 18 months.


So, according to this (and the extremely helpful person who directed me to the link) 128k ISDN figures are not included in any of their broadband reports. Only connection speeds above 512k are considered broadband.

[edit]
wtf 2 billion euro!!! muppets

ednwireland

funny cos up until a couple of months ago i was getting 22-24k on dialup they have since taken me off a splitter and now i get 42-44k although a few months before that someone took the line down with a digger. two years ago i was told by an engineer we were on the list for our lines to be upgraded. funny how they've stopped calling me now to get my lines upgraded to isdn.
19.2k is a joke the only reason is so eircom can leave line splitters in place and not provide a proper phone service

SkepticOne

Originally posted by Dawg
ComReg definition of broadband can be found here
So, according to this (and the extremely helpful person who directed me to the link) 128k ISDN figures are not included in any of their broadband reports. Only connection speeds above 512k are considered broadband.

Yes well, since they wrote that they have forgotten their own definition. If you look at their latest quarterly report, section 3.2 there's a table of broadband take up.

Table 3.1 Types of broadband access companies have at present

ISDN 55%
National Leased Lines 29%
DSL 14%
International Leased Lines 7%
WLAN’s 3%

ISDN obviously should not be included here. Also, the WLANs mentioned are most likely suplements to internal local area networks and may be used to share out a broadband link but should not be considered broadband in themselves.

Still, what do you expect?

pepsiman

Originally posted by pepsiman
at work today I read some of the Comreg documents

Originally posted by SkepticOne
If you look at their latest quarterly report

Ah -- that's where I read it... :-)

/T

SkepticOne

Originally posted by pepsiman
Ah -- that's where I read it... :-)

/T

That's even worse.

spongebob

Originally posted by Xian
Originally posted by Muck
What did ye think of Eircom stating it would cost €2Billion to rewire the network to guarantee 56k (or 48k which is technically feasible except that nobody asked for it)

This was their response to the setting of a bit rate of 56kb/s, something we explicitly did not ask for. What we asked for was for a bit rate to be set such that pairgain systems are removed. The telling response, therefore, followed:

5.1.2.2...the cost of replacing all existing carrier systems would be at least €90 to €100m.

This is the first indication we've had of the extent of the problem.

The IoffL submission gave Comreg a reasonable plan of action which was NOT an unfair burden. Without reading it again it was

48k at 1mile
44k at 2 miles
40k at 3 miles
36k at 4 miles
33.6k at 5 miles

I believe that the number of lines that are over 5 miles from the exchange is 2% nationally (figures submitted to cabinet by Eircom but not published).

So 98% of Irish Homes and Businesses are within 5 miles of an exchange. A line is Designed by international standards to work at up to 5 miles from the exchange. 1% of lines is 14,000. The maximum number of lines outside the limit is 28,000 .

These international standards have been around for 20-25 years. Precisely how the fúkc is it an 'Unfair Burden' on Eircom to enforce a standard they have known about for years. A standard is a standard is a standard The ESB does not widdle around splitting 220v lines and complaining that a standard 220v connection is an Unfair Burden on them, here ya go, have 136v coz yer off up a boreen.

Remember that Eircom have squatted on a large chunk of National Airwave to provide them with alternatives to a wired solution.....for the other 2% of the population or even for some of those within 5 miles. Eircom have frequencies around 2.1Ghz 2.3Ghz(Rurtel) and 3.5Ghz(FWA) with which they can provide POTS ISDN and DSL type connections at up to 384k . Comreg issued these licences to Eircom. Why?, what have we got from Eircom (or Comreg for that matter) in return for these licences. Nothing.

Let us also look at why this is being discussed. In Early 2002, the EU published This directive. It is part of Irish Law from next month. Comreg are cleaning up their own rules in order to comply with it after it becomes law. On page 2 of the directive we see, stated in the CLEAREST POSSIBLE TERMS for the likes of Comreg to follow.

(8) A fundamental requirement of universal service is to
provide users on request with a connection to the
public telephone network at a fixed location, at an
affordable price. The requirement is limited to a single
narrowband network connection.

<snip>

There should be no
constraints on the technical means by which the
connection is provided, allowing for wired or wireless
technologies, nor any constraints on which operators
provide part or all of universal service obligations.
Connections to the public telephone network at a fixed
location should be capable of supporting speech and
data communications at rates sufficient for access to
online services such as those provided via the public
Internet.

<snip>

For this reason it
is not appropriate to mandate a specific data or bit rate
at Community level.

<snip>

Flexibility is
required on the one hand to allow Member States to
take measures where necessary to ensure that
connections are capable of supporting such a data rate,
and on the other hand to allow Member States where
relevant to permit data rates below this upper limit of
56 kbits/s in order, for example, to exploit the
capabilities of wireless technologies (including cellular
wireless networks) to deliver universal service to a
higher proportion of the population.

<snip>

Member States should be
able to require the connection to be brought up to the
level enjoyed by the majority of subscribers so that it
supports data rates sufficient for access to the Internet.

Now I did snip it a bit but it sez use wireless if the cost of wired is too much. It also sez that the INTERNET is PUBLIC while the Comreg waffle seems to imply that the INTERNET is not part of the PUBLIC NETWORK. This is important becuase the Public Network is what the USO covers.

Finally I looked again at some of the convoluted waffle between pages 12-25 where Comreg turned themselves inside out trying to remove Wireless from the USO and NOT at the same time. The Directive is pretty straight. Use wireless if wired solutions are too expensive. ABOVE ALL get the speeds up to "to the
level enjoyed by the majority of subscribers" . That was why the IoffL submission REQUIRED at least 33.6k speed at 5 miles. IoffL had READ the directive properly not least because I made them

The Comreg definition of the carrier activity that comes under the USO is essentially:

A Connection to the Public Network which is AT a fixed location .

They went through linguistic hoops in their trying to exclude the INTERNET (or Online Services) from the PUBLIC NETWORK. By induction, they decided that a mobile phone was not at a fixed location, even if it was !!!! (Don't try Jesuitical logic on me lads) and excluded Vodafone from the USO as a consequence. In excluding Vodafdone and O2 they neatly encapsulated all non wired technology into the exclusion, or so they thought! I think that their painful definition of what is to be provided AT a fixed location by Eircom can be cleaned up into a logical and consistent policy in plain english.

Comreg really dropped the ball in the following excerpt from page 15. They Confused Fixed Carrier with Wired Carrier and then developed the analogy down the cul de sac where it belongs.. They never acknowledged that Fixed Wireless (or Nomadic Wireless solutions) existed that would deliver the Universal Service Required in the Directive but FROM the Fixed Carrier , the USP.

Page 15

At present, universal service obligations only apply to fixed carriers. Mobile operators’
statutory ‘public service requirements’ tend to be included in the tender documents and
licence provisions of mobile operators which require them to guarantee extensive
geographic coverage. Under current and the new EU framework, they may also be
required to contribute to any universal service funds. The use of mobiles to deliver the
services falling under the USO would give rise to considerations regarding
affordability (i.e. the retail cost of the universal services via mobile may be more
expensive than via traditional fixed means). Furthermore, one of the key differences
between fixed and mobile services is that mobile service normally connects individuals
irrespective of their location. On the other hand, a fixed service normally connects
households/businesses. The Directive also requires that access is capable, amongst
other things, of supporting functional internet access. Mobile services may not
currently satisfactorily supported these requirements.

But this following bit is what the directive said (quoted above too) !

There should be no
constraints on the technical means by which the
connection is provided, allowing for wired or wireless
technologies,

Eircom have delivery options including wireless where they can deliver 56k POTS over 2.1Ghz 2.3Ghz 3.5Ghz and Copper. Comreg seem to state that only MOBILE operators have Wireless options, this is not the case at all.

Fortunately there is a further consultation period during the next fortnight....up to 04/07/03. I advise anyone reading this to concentrate on pages 12-30 of the Doc linked in the first post and to deconvolute them and to submit to Comreg. Remember that you should Submit Early and Submit often, once this is put to bed there will be no change to the policy for 3 years from October or so. That means Late 2006 at the earliest. There will be no rural economy by 2006 if this ain't sorted NOW!

M

jd

Originally posted by Muck
The IoffL submission gave Comreg a reasonable plan of action which was NOT an unfair burden. Without reading it again it was

48k at 1mile
44k at 2 miles
40k at 3 miles
36k at 4 miles
33.6k at 5 miles


M

Just wondering what test would you use to verify the above bit rates - is there a standard test that can be used?

dahamsta

Originally posted by jd
Just wondering what test would you use to verify the above bit rates - is there a standard test that can be used?

As far as I'm aware, analog line tests currently check for levels of resistance between the exchange and the premises, and I'm not sure this would be good enough to gauge line speeds accurately. It's likely Eircom engineers would need to be provided with new equipment burst data down the line over a period of time (much like ISDN line tests) and average the results, but this wouldn't be a substantial investment for an ogre of Eircom's size. Company, sorry, company.

Someone will no doubt correct me if I'm wrong.

adam

*To actually get ISDN, your installation has to pass a test whereby they pump a large block of data down the line. If you don't pass, you don't get ISDN.

PiE

Can I just copy & paste that "Vaugue? Its watered down p1ss at times TBH" post and send it off to Comreg Muck? It makes a lot more sense than I ever could

spongebob

Plagiarise away No copyright reserved in you case .

I am now minded to say to them that they have

"Unilaterally, and without showing good cause, constrained the technical means of delivery contrary to section 1(8) of the USO Directive which states that there should be no technical constraint."

Which could make the Proposed USO Ultra Vires of course.

M