LLU "paper" from comwreck

bealtine

http://www.comreg.ie/_fileupload/publications/ComReg0421.pdf

Now where did I put that handy buzzword generator decryption
program?

Econometrics wtf is that? <-Rhetorical question

spongebob

Here are the questions they 'want' answers to, Muck has helpfully provided a few of them in case you want to respond to the consultation.

I find that the more responses they get, then the more convoluted and incoherent their response to consultation becomes. Their understanding of functional internet access as a "right" in the reply to the USO consultation last June was a model of babbling moronic ****e. I expect more of same from Comwreck .

Muck also predicst that Comwreck will set a price of €15.28 anyway......even AFTER you send these specimen answers in. (margin of error + or - 2%) .

Q. 1. Are there any other variables that might make operating costs of the
local loop network materially different in Ireland from those costs in other
countries with which comparisons might reasonably be made and that are not
discussed above? If so, what are they and what effects would you expect them
to have?

The enormous amount of money that Eircom gouges from its customer base because an incompetent regulator thinks that leading Europe means MOST EXPENSIVE.

They should give one local loop free for every 3 paid loops, we would still average out higher than the rest of the EU but its a start in the right direction.

Q. 2. Do you believe that eircom’s actual operating costs of its local loop
network cannot be used alongside the capital costs on a new network, as
estimated under the LRIC approach? Please provide detailed reasons for your
views.

**** your LRIC, They are a predatory monopoly that margin squeezes all the REAL competition you ****wits.

Q. 3. Are there grounds for believing that any of the operating costs forming
part of an efficient entrant’s LRIC local loop network would be higher than
eircom’s actual operating costs? If so, what might they be?

Eircom have taken over lots of ducting that belongs to local authorities when they take estates in charge. Tell them to go **** themselves the thieving bastards.

Q. 4. Does the above discussion explain fairly the strengths and limitations of the different ways of estimating efficient operating costs for the LRIC unbundled
local loop network? If not, in what ways is it incomplete or deficient? Please
provide detailed reasoning.

Nobody has done an Anal-ysis on the benefit of removing Comwrecks head from its arse, what a glaring omission.

Q. 5. Do you agree that it is appropriate for ComReg to use evidence from US data in determining the efficient level of operating costs for the local loop
network in Ireland? If not, please indicate what you think would be a superior
approach and why.

No doubt they will reach the wrong conclusion from that data anyway. Make tits of yeerselves again , why dont ye.

Q. 6. Do you agree that the explanatory model for differences in LECs’ direct
network operating costs set out in Appendix C has been selected using
appropriate criteria and that it captures the important influences from plant,
demographic and meteorological variables in a satisfactory way? If not, how
should the modelling strategy be improved?

You forgot the ozone hole lads. Apart from that ye could make pissing sound complicated (and important too). Finland has far worse weather and can supply DSL through Permafrost. We can do the same, its hardly like we have locusts attacking Biddies twin set in the hairdresser or Termites eating the poles ....but I am working on the latter . Use WIRELESS FFS .

Q. 7. Do you agree with the allocation criteria set out above for allocating a
portion of direct non-network and indirect costs to the unbundled local loop
should be based on eircom’s Separated Accounts? If not, please indicate what
you think would be a superior approach and why.

Hand the job over to the Competition Authority and to Monti in Europe and then jump in a lake.

M

BigEejit

he's snapped .... he's finally lost it;)

Moriarty

Do I sense some hostility?

spongebob

How did we get a Functional Internet Access Rate of 0k when we had a whopping 2.4k until July.

1. Comreg Consult on USO (Feb 03)

Q From Comreg

Q.4 Do you agree that the specification of requirements setting a specific bit
rate and the publication of a network performance statement by the
universal service provider? What bit rates might be appropriate?

2. Ioffl Submit an answer to the Questions in the Consultation Document.

A From IoffL

We note that the current requirement of voice band communication standard of
2,400 bit/second is grossly out of date and in no way conforms to the
requirement of "functional internet access" by today's standards. 2,400 bps
corresponds to the ITU's (International Telecommunications Union) V.22bis
standard that was codified in an ITU recommendation in 1988, many years
before access to the Internet became available to residential customers over
dial up lines.

AND

The 1999 USO has had no effect on the quality of the network for data
communication, serving only to compound its degradation by the installation,
up until April of last year, of Pairgain devices to minimize the cost of Copper
Line provision.
This lack of a realistic USO requirements bringing tangible benefits to citizens
over a 4 year period mean that the forthcoming USO must set out clearly the
entitlements to a bit rate that permits functional internet access on the following
basis:
Distance from Exchange: minimum bit rate(kbits/sec)
1 Mile 48
2 Miles 42
3 Miles 40
4 Miles 36
5+ Miles 33.6
It should additionally specify that this be communicated at all levels within
Eircom and, via the customer charter, to the end user.

3. Comreg Reply to the IoffL Reply to Consultation . Page 27 of 77.

ComReg is of the view that data speeds of 14.4 to 19.2 kbps (note that these speeds (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 therefore reduced the minimum data speeds from 2.4k to 0k .

Then they said on page 28

ComReg is also of the view that the current requirement (under Annex 1 of Directive that a connection must be capable of transmitting data via modems at
2,400bps is an inappropriate benchmark considering the purposes for which consumers are now using their telephone lines.

They told €ircon to send them a report by the 25th of October 2003 and then they forgot all about the **** that passes for copper in most of Rural Ireland and have done nothing since, the useless tossers.

Now they want us to engage them in this farce about Cost Modelling and Econometric Issues when everyone knows that ****e comes out of yer arse and that you need not actualy bother looking up there for it to prove that it does........

My response will be simple . It will say.

"Comreg, we simply want the same Network quality and services at the same price as the rest of the EU. If you cannot deliver that by the end of March 2004 then **** off and let someone else do the job ......because you are a failed institution . "

M

eircomtribunal

Originally posted by Muck

Muck also predicst that Comwreck will set a price of €15.28 anyway......even AFTER you send these specimen answers in. (margin of error + or - 2%) .
M

John Doherty said it himself: "The last time we went to court it was €14.67 we were looking for. We will be working up from the price we want and something that suits Eircom. We want to introduce a reasonable valuation. We originally went to court for €14.67, I don’t think we will be very far away from that figure in April when we go back again."

From the February_12_blog_on_Comwreck


BTW there's a brand new_John_Doherty_blog_on comwreck.

Peter