"Regulating Better"

vinnyfitz

This Government White Paper published earlier in the week should be of interest to anyone here who is not satisfied with ComReg's activities to date.

http://193.178.1.125/upload/Regulating_Better_html/index.html

I've not read it yet but am about to have a look.

It strikes me that despite our best efforts we seem not to be realising the significance of certain consultations ComReg has been involved in. Query has pointed out at least two such cases in the last few days.

I wonder what does this imply?

1. That we are lazy gits?
2. That the consultations are incomprehensible to consumers?
3. That we are disorganised and could do better?
4. That ComReg needs to find a new way of working if user interests are to be reflected in consultations?
5. Err...?

Ripwave

Originally posted by vinnyfitz
This Government White Paper published earlier in the week should be of interest to anyone here who is not satisfied with ComReg's activities to date.

http://193.178.1.125/upload/Regulating_Better_html/index.html

I've not read it yet but am about to have a look.

Sounds like it could have been written by oreillycom. Lots of excuses to get rid of regulation, nothing about using regulation to improve consumer welfare.

dahamsta

I'll put my hand up and say that I'm entirely hypocritical when it comes to consultations, I'm not sure I've ever responded to one individually even though I egg people on here to do it. My excuses, weak as they are:

- When I was with IrelandOffline, their responses represented me.
- When I left IrelandOffline, I was too busy to respond.
- For the last few months I haven't received notices about them.

On top of that, any time I have sat down to respond, I get myself in a twist trying to phrase things correctly. The latter above has apparently been rectified now though, so in future I'll try to respond whether I'm busy or not. I guess if I can find the time to type up angry letters to John Doherty and Phil Nolan (and post here), I can find the time to respond to the consultations.

They mightn't be entirely coherent, but I guess the best I can do is try?

adam

vinnyfitz

Within 30 seconds I found the following text for example:

t is important to recognise the danger of over-representation of one particular viewpoint during consultations. Consideration will be given to encouraging not-for-profit groups to engage with the consultation process. Greater engagement will help consumer organisations, for instance, to become self-sustaining through demonstrated success in achieving policy influence.

Not sure what it means but its evidence this doc requires a look - even if only 'cos your assessment turns out to be correct Rip.

Ripwave

Originally posted by vinnyfitz
Not sure what it means but its evidence this doc requires a look - even if only 'cos your assessment turns out to be correct Rip.

Part of my cynicism stems from the fact that, as a society, we aren't over burdened with regulation as it is. (When was the last time you encountered a health and safety inspector, nobody seems to bother fixing headings or broken indicator housings until the day before the NCT, fire-safety "licenses" don't seem to be enforced, etc, etc, etc). So most of the regulation that does exist in Ireland is in areas that are meant to protect us as individuals and consumers. And we've seen in the case of telecoms generally, just how ineffective tht has been. (And for those of you who do feel that we're over-regulated, you might try comparing our situation to the British, the Americans or the Germans).

So while I'm all in favour of "better regulation", I'm sceptical that we need a white paper and public consultation exercise to get it. The people who actually grease the wheels of our political system have a very singular view of regulation - as little as possible, as quickly as possible. The Principles outlined in the document all sound very well, but they are all expressed in terms of minimising regulation as though it's an absolute given that less regulation is better than more regulation.

theking

I think it would be more reflective of the process to say that the idea is to provide the minimum regulation required to have a job well done.

This is obviously a good thing- if it does the job why have more. If there is more regulation than is needed to have the job done, then we should have less. But the policy isn't that there should be no regulation, or that regulation should be reduced until it is ineffective- hence the title Regulating Better, which is derived from the government' Better Regulation programme. (Run from the Strategic Manegment Initiative unit in the Department of the Taoiseach, in case anyone is wondering)

vinnyfitz

Yes King - the idea behind it is understandable but the issue is whether the idea is right?

the idea is to provide the minimum regulation required to have a job well done

I think it would be fair to summarise the mood of the board that the regulatory job wrt telecoms is not being well done and, further, that even less regulation would definitely not be the best solution!

Members and officers of IOFFL have devoted a huge amount of voluntary time over nearly three years to make a consumers contribution to the telecoms regulation process and yet we still have a very unsatisfactory system.

Why is this? I get the sense that there are several problems and a very un-even playing field. For example:

1. the telcos have much better access to comreg than consumer interests do
2. the complexity of the consultation documents is such that one needs employed staff resources to stay on top of them
3. most consultations are not summarised in plain English
4. there is no pro-active outreach by comreg to stimulate consumer interests
5. comreg probably believes it is consulting on a level playing field and has not stopped to wonder why consumer interests are less visible - in other words the problem is not even recognised
6. etc....

So - is there anything in the Taoiseach's White Paper which gives us leverage to press for a different relationship between IOFFL and ComReg?

I think that, maybe, there is.

Ripwave

Originally posted by theking
I think it would be more reflective of the process to say that the idea is to provide the minimum regulation required to have a job well done.

No regulation is the minimum regulation. And there are those in government who are generally of the view that No regulation is a "good thing" in principle. There is plenty of evidence to support your contention that the idea is to provide the minimum regulation - there is a lot less evidence to support the notion that the idea is to have a job well done.

Taxi deregulation has certainly led to more taxis on the road. But taxis now cost a lot more, even though we're no longer supporting "plate rental", and there are claims that taxis aren't as safe anymore - because there is almost no regulation of who can become a taxi driver, and no training is required to become a taxi driver. (I haven't had any negative experiences since deregulation, exccept when it came to paying the bill, but I have heard numerous reports on the radio, etc).

I'm all for "better regulation". But I don't buy the argument that "less regulation" is better regulation. And the language of that white paper suggests to me that it was written from the point of view that "less regulation" is better regulation.

Can you give me an example of an area in Irish life that you think could benefit significantly from "less regulation"?

Capt'n Midnight

Comparing Irish prices to other EU prices - can anyone show any evidence that there is any realistic competition here ? It seems to be a case that the other Telco's under cut Eircom by a little (fair enough a lot of it is due to interconnect / wholesale charges) but not by a huge margin - it seems like the grocey trade - no one is going to rock the boat too much.

So far regulation has only delayed calls for proper regulation. We can't get a regulator - 'cos we already have one. At this stage if we didn't have any regulation then there is a small chance (this is Ireland of the brown envelopes) that an effective regulator would have to be set up.

Personnel Telco anyone ?

SkepticOne

Originally posted by Capt'n Midnight
Comparing Irish prices to other EU prices - can anyone show any evidence that there is any realistic competition here ? It seems to be a case that the other Telco's under cut Eircom by a little (fair enough a lot of it is due to interconnect / wholesale charges) but not by a huge margin - it seems like the grocey trade - no one is going to rock the boat too much.

What goes on in the Irish market is not competition, it is simply a number of companies taking their cut of a monopoly. The OAOs compete with each other to a certain extent but none of them compete with Eircom in any meaningful way.

Is the Irish Farmers Association competing with Eircom with their telco or are they acting as a sales and billing organisation on behalf of Eircom?

It is far worse than a simple cartel. The analogy with the grocery trade would work if it were the case that all the grocers got all their produce from a single monopoly wholesale supplier.

As far as solutions are concerned, people have suggested that Eircom be prevented from offering retail products. The OAOs would certainly love this as all margin squeeze would be eliminated. However the wholesale monopoly would still remain and this is the real problem. Prices would still be high.

It also means that wholesale line rental is no solution to the problem of high line rental.

What we think of as competitors are not competitors in the ordinary sense of the word. When line rental was jacked up by Eircom, Esat weighed in saying they should bring in WLR. All they want is a cut of Eircom's monopoly profits. Unfortunately there is a widespread view that if these monopoly profits are spread around among a number of companies, the consumer somehow benefits from this "competition".

theking

Originally posted by Ripwave
No regulation is the minimum regulation. And there are those in government who are generally of the view that No regulation is a "good thing" in principle. There is plenty of evidence to support your contention that the idea is to provide the minimum regulation - there is a lot less evidence to support the notion that the idea is to have a job well done.

Minimum is taken to mean effective minimum. Not physically minimum- which would be nothing, as you point out.

I'm all for "better regulation". But I don't buy the argument that "less regulation" is better regulation. And the language of that white paper suggests to me that it was written from the point of view that "less regulation" is better regulation.

I think it would be fair to say that if you were swiming in a public sector environment, as the authors of this document are, you would feel that there is no shortage of unneeded regulation.

Can you give me an example of an area in Irish life that you think could benefit significantly from "less regulation"?

Just to taken an example you may be familiar with, the registration of .ie domain names is riddled with irritating hoops to be jumped through. It is also expensive and restrictive. And none of these regulations acutually serve to meet the purpose for which they were created- namely to make the .ie domain a widely used and trusted domain.

Ripwave

Originally posted by theking
Just to taken an example you may be familiar with, the registration of .ie domain names is riddled with irritating hoops to be jumped through. It is also expensive and restrictive.

The IEDR is a completely private company, and it's rules don't have the slightest effect on the public at large (because it's rules says it won't deal with the public at large). Government White Papers (or even Bills and Acts) on "better regulation" won't have the slightest effect on the rules of private companies. (While ComReg regulates private companies, the regulations are "public" regulations, not "private" regulations).

Give me an example of "public regulations" that need to be "improved" by decreasing the amount of regulation.

And none of these regulations acutually serve to meet the purpose for which they were created- namely to make the .ie domain a widely used and trusted domain.

Those rules were not implemented to make the .ie domain widely used. They were implemented to make it "trusted", by eliminating the abuses of cyber-squatting in other domains. There's no question that they worked extremely well in that regard, if in no other.