Last chance to get a Decent Phone Line line Installed Until 2007

spongebob

If you think that Comreg should do something about the crap that Eircom put on peoples lines and charge full whack for then you must make your point to Comreg by close of bizniss today.

Comreg have stated their (muddled to say the least) position between pages 15 and 30 of this document Here on their website (500k PDF)

They do not consider that we have the right to decent data speeds on our expensive phone lines that cost more per month than any other phone lines in the EU

On the 25th of July 2003 the Law in Ireland will change once this Statutory Instrument Here (Word Doc) is transposed (made law). Comreg seem to be wilfully ignoring section 3(2)(c) and section 3(4)(a) which sets out the following legal requirements FOR ALL ANALOGUE PHONE LINES from that date

(2) Any connection provided by <EIRCOM> shall be capable of allowing end-users to make and receive:

(a)local, national and international telephone calls,
(b)facsimile communications, and
(c)data communications at data rates that are sufficient to permit functional Internet access.

(4) ComReg may, with the consent of the Minister, for the purposes of the services referred to in this Regulation, specify requirements to be complied with by an undertaking designated as aforesaid in relation to -

(a)functional Internet access, having regard to prevailing technologies used by the majority of subscribers and to technological feasibility,

"Prevailing Technologies" in this case is the 56K modem.

The current ( 1999 ) USO states that all lines must support 2.4k data speeds but Comreg in its new USO does not wish to set a minimum bit rate for the next 3 or more years..

The position therefore is that Comreg wish to move the goalposts from a guaranteed 2.4k to a guaranteed 0k despite the fact that the 56k modem is the 'prevailing technology' mentioned in the Statutory Instrument. You could ask them how something less than 2.4k constitutes "functional Internet access" because I cannot see how anything less than 28k can be described as "functional Internet access."

Page 9 or 10 of the original linked PDF tells you how to make the submissions by email.

Closing date is today.

M

maxheadroom

Thanks for the heads up - I'd planned to send something in and then completely forgot...

Urban Weigl

(c)data communications at data rates that are sufficient to permit functional Internet access.

We should be the first country in Europe to define this as at least 512kbps downstream and at least 256kbps upstream.

Alternatives could be 384kbps downstream and 64kbps upstream, or 512kbps downstream and 128kbps upstream. And fast, before someone else beats us to it (many countries already have broadband availability of over 95%).

spongebob

Comreg have oficially anounced they intend to drop below their current minimum of 2.4K Guaranteed . They have said that they will not set a minimum this time. We are the only country in Europe (I should think) who have allowed a depreciation in line quality (for data) of 100% to precisely nothing. Other countries are no doubt struggling with the 33.6-40k range, as intended by the Commission.

This final consultation period may get them to change their mind on 'functional' . I totally fail to see how less than 2.4k is functional. I fail to see how 2.4k is functional either. 28.8k or 33.6k is a start IMO

M

fabien

Just sent an email using some of the point made above - Thanks.

For those of you who don't have time to look it up, here's the procedure for sending your comments:

All responses to this call for comments on the regulatory impact of the positions set out
herein be clearly marked:-
“Reference: Submission re ComReg Universal Service RIA” as indicated above, and
sent by post, facsimile or e-mail, to arrive on or before 5pm on, 4th July 2003, to:
FREEPOST
Ms. Carol Donohue
Commission for Communications Regulation
Irish Life Centre
Abbey Street
Dublin 1
Ireland
Ph: +353-1-8049600 Fax: +353-1-804 9680
Email: carol.donohue@comreg.ie

fabien

...and Carol even acknowledged my comments...although I'd rather she did something about them ! (I basically asked for 28K USO for data)

Dear Fabien,

I would like to thank-you for your comments on our consultation 03/68.

Kind Regards

Carol Donohue

Gavin

I don't quite get it. What is Comregs' reasoning behind not setting a minimum ?

Gav

Nitrox

I am sure the next big tribunal in Ireland will be about how Eircon managed to fool all and "fund" COMREG without anyone but "a few" techies found out.
What COMREG is doing is exactly what Eircon want them to do, aint that strange....

spongebob

Originally posted by Verb
I don't quite get it. What is Comregs' reasoning behind not setting a minimum ?

Gav

They didnt provide a "reasoning" , the rationale they attempted to provide is between pages 20 and 30 of the doc and makes no sense

M

LFCFan

Originally posted by fabien
...and Carol even acknowledged my comments...although I'd rather she did something about them ! (I basically asked for 28K USO for data)

Got the same reply as I'm sure everyone will. Whether they give a sh1t or even bother to take it into consideration is another matter.

zz03

The blind leading the blind.

ComReg in typical Irish fashion appear to be rubber stamping EU blind cluelessness without questioning the issue. Or are they in the same boat?

"Eircom state that if a bit rate of 56kbits were set this would require the reduction of the maximum distance from subscribers to an exchange from 9 to 4.5kms..."

So lets go for 0 bps?

No PSTN line will function at 56k - it is a theoretical data rate that can't be achieved over an analog modem dial-up connection. Eircom know this and appear to be leveraging the regulatory stupidity for their own ends.

Who'd blame them? Eircom state that it would cost EUR 2bn to get PSTN data rates up to 56k. What total rubbish! What non comatose state would spend EUR 2bn to get internet access rates up from say 45k to 56kbits/sec to comply with some EU directive? Even if you reduced loop lengths to a max of 4.5kms you wouldn't get 56k on analog. (You wouldn't have to reduce loops to 4.5k to get 56k via ISDN).

It is alarming to read such rubbish. It displays gross pulling the wool. Why did ComReg fall for it?

In the real world, any phone line that won't support say 42k analog from the eircom point of connection with no other devices connected in the customer's premises is surely unacceptable? A loop that can't do that is suffering from water ingress or some other defect that can and should be repaired.

The monthly line subscriptions payable to eircom have gone up and up and are now far higher than anywhere else I can think of. eircom can't have their cake and eat it.

There is something rotten in the state of denmark if eircom get off the hook for line quality on these grounds, having had so many price increases of late?

Aside from the fact that even 512k broadband is only bordering on functional. If you bought a new TV and the pictures from RTE could only be viewed in a 10 cm "window" on the big screen, I don't think you would feel that RTE were providing a functional TV service. That's all 512k will give one in multi-media terms.

Perhaps someone has hacked into comreg.ie and posted this? A precursor to Microsoft's hacker attack on July 6!

zz..

Capt'n Midnight

Then drop the speed to 28.8 for those who live more than 4.5Km of coper from the exchange but no further. (For those closer in of course 44K would be nice.)

Remember the main reason you can't get beyond 56K is not because of background noise or bandwidth or filters but soley because of the decision to use a 64k digital channel per analog line in the exchange.

It's a bit like a pub trying to pass off a cup full of beer as a pint - on the basis that you can never fit a full pint in a pint glass because of the room taken by the head.....

(twice the distance means twice the noise - and hence half the maximum number of quantitization levels - you don't even need to use dB's on this one )

And the moral of the story - drink cider - preferrably bought up North.

Calibos

I maybe completely missing the point and I appologise in advance cause I haven't read the comreg document but maybe comreg don't want to set a level now when the '............prevailing technologies used by the majority of subscribers and to technological feasibility' is 56k. Maybe they are waiting for a few years till more people have some form of broadband and can then claim that BB is 'the prevailing tech.......' and codify it into a new USO safe in the knowledge that the courts will back them against any action by Eircom to have the 'new' USO rejected.

andrew163

is this new USO a joke? Were going backwards!!!!

I smell brown paper envelopes.....

zz03

Originally posted by Capt'n Midnight
Then drop the speed to 28.8 for those who live more than 4.5Km of coper from the exchange but no further. (For those closer in of course 44K would be nice.)

That would formally let eircom off the hook for v.90 speeds for all subscribers > 4.5kms.

v.90 will work fine over far longer distances than 4.5km at speeds up to 56k. It won't work at 56k however, any more than it will work AT 56k if the exchange is 200 metres from the users house.

Home wiring and / or water ingress on the eircom loop could bring a 56k modem down to the low 20s even for someone 200 metres away. Repairable faults such as these have far more impact on v.90 modem speeds than loop length.

While I am totally against ComReg having no minimum connect speed (because eircom will take advantage of it to get away with not having to roll a truck to repair very defective loops) leaving the internet customer totally offline, I do feel we are discussing something akin to which side of the road the horse and car should be driven.

Having allowed eircom to increase its loop subscription fees three times in the recent past, one would instead expect ComReg to be discussing performance requirements and targets for the rollout of DSL availability across the fixed network. And an educational advertising and field demonstration program to show non geeks the benefits that DSL can bring them. Not to mention sorting out the price. (If the TV license cost €654.48 per annum, how many households would buy a TV or more to the point a TV license?)

ComReg, please stop wasting time on side-shows!


zz..

zz03

Originally posted by andrew163
Were going backwards!!!!

Down a hill and the brakes seem to have failed!

zz..

BoneCollector

I dont see how comreg can justify this and neither can i see how eircom can either, since they are selling whole sale bandwith for the clear and specific functionality of data and internet access not telephony.. I say "bandwidth"..

therefore i would assume eircom are under every obligtation to insure that the product can deliver the service it is being sold to provide.!?

This is nearly a kin to dsl..
eircom are advertising/selling a product/service they cant deliver!??