The First Anniversary Of 0k Has Passed !

spongebob

In 1999 we acquired the legal right to have Data pass over our phone lines at 2.4k and Fax at 9.6k . It was part of a bundle of measures called a Universal Service Obligation and covered every non ISDN line in the country.

On the 25th of July 2003 Comreg removed our right to the stonking 2.4k Full duplex data speed (with a 56k modem) and replaced it with Nothing , the by now notorious 0k Universal Service Obligation. On the same day, lest one has forgotten, the UK went from 2.4k up to 28.8k . The current USO is the Irish end of an EU directive from 2002 which should have been law by the 25th of July 2003.....and just about made it in once it had been stripped of its overall usefulness by Comreg .

Comreg were allegedly to consult with Eircom and to get some stuff back from Eircom on the 24th of OCTOBER from which they could define something where something != Nothing which is what Comreg was minded to do anyway because the Irish consumer (quite evidently)=Nothing in their eyes.

One quite rightly thought that something might be 28.8k like in the UK . One had the temerity to possibly believe that Comreg could have this sorted by Christmas 2003 as some were promised ......instead we got a massive Line Rental increase in January as a Universal Service obligation to the customers. As for the phone lines themselves Anybody who has complained to €ircon in the interim about their crap overpriced phone line ....only to be told that your line is voice only......should send some Hugz and Kissez and Greetz to mike.byrne@comreg.ie as it was HIS brillliant idea to allow Eircom to have a Universal Service Obligation without telling €ircon WHAT THE OBLIGATION ACTUALLY IS !!!!!!!!!!! not even a year later for Gods sake.

M

LoBo

What's the difference between ComReg and the UK's Ofcom? I don't mean in results or lack thereof, I mean in who appoints their fearless leaders, pays for everyones jobs, decides their focus.. etc etc.

Interested to know why we can fail so consistently on matters that should be easy - we can just play catch up with how the UK/ofcom do things and we'd be doing alright.

bealtine

//

---

What's the difference between ComReg and the UK's Ofcom?
//

---

One is a cosy talking shop that does sfa except defend the dark forces
of thievery. Pretty much like all the regulators in that country.

The other has some teeth and has a consumer focused brief...
pretty much like all the regulators in that country.

It is an utter amazement to me how one regulator can read the SAME
document and come up with a definition of "Functional Internet Access" and
then decide that this means "what it says on the tin" aka 28k is the minimum
standard. The other shower of useless tossers come up with NOTHING...
nothing at all after 18 months of consultations (over lunch)

Thanks guys its good to see uselessness being honed to such a fine art...

Da Man

I was actually onto Comreg about some other issues related to this, which was to do with service quality or some such. I can't remember the details now, but Eircom was supposed to deliver information on the state of their network which they apparently have. I asked Comreg for this information but they refused to give it to me and said that they were negotiating with Eircom. Maybe it's time to hassle them again.

Maybe it's time for a freedom of information request.

Champ

to allow Eircom to have a Universal Service Obligation without telling €ircon WHAT THE OBLIGATION ACTUALLY IS !!!!!!!!!!! not even a year later for Gods sake.

That really puts things into perspective regarding the competency of our beloved and highly valued ComReg:D

spongebob

Originally posted by Da Man
I was actually onto Comreg about some other issues related to this, which was to do with service quality or some such. I can't remember the details now, but Eircom was supposed to deliver information on the state of their network which they apparently have.

Was it you who was assured by Comreg that the 0k matter (of their own creation) would be dealt with by Christmas ..... 2003 . Someone posted in here late last year after an exchange of emails with Comreg. I'd love to find it for historical reasons .

How anybody could take an EU directive mandating "Functional Internet Access" and proceed to the conclusion that "Functional Internet Access"= 0k is well beyond me and everyone else in here. It is still worthy of an anniversary celebration ...... as are many disasters .

M

LFCFan

Eircon have Comreg in their back pockets and should be disbanded, with a totally independant body set up that has no affiliation with the Government or anyone else for that matter and they should be give the power to do what's needed. It's quite clear that Comreg have no interest in defending the consumer or making Eircom comply. It's a sick joke that they are allowed to continue.

Gadgie

I got the following reply from ComReg on the 18th May (2004, obviously):

I wish to advise you that discussions with eircom on [functional internet access] are still ongoing and we are currently not in a position to advise you when these will be concluded. However, please note that any statement ComReg will have will be announced through our PR office and on our website.

I replied to say that this response was unsatisfactory, as under Directive 2002/22/EC of the European Parliament all EU citizens are entitled to a telephone line capable of supporting functional internet access, and was told:

I wish to advise you that ComReg has taken note of your comments.

I replied again to ask what this meant (was someone in ComReg going to contact me further about this?), but as of yet have received no reply.

Later that same week I sent another e-mail to ComReg (infact I sent several copies as they weren't replying to them) asking them to confirm that there was currently no obligation for eircom to provide a line capable of supporting FIA, as I wanted it in writing. What I got back was a copy and paste job from the USO stating that

eircom as the designated Universal Service Provider (USP), shall satisfy any reasonable request to provide access to the public telephone network and access to publicly available telephone services. The connection shall, taking into account the prevailing technologies user by the majority of subscribers, be capable of allowing end-users to make and receive data communications at data rates that are sufficient to permit functional Internet Access.

The problem being just how do you define functional internet access without a data rate being set? Duh.

I was also told in the same e-mail that

ComReg is in discussions with eircom in relation to its responsibility, under the Universal Service Obligation to provide satisfy reasonable requests for access and an update has recently been published in this regard http://www.comreg.ie/publications/default.asp?nid=101522&ctype=5
. The discussions are also focussing on issues around the capability of the line. Once these discussions are complete and an approach that provides increased clarity around the USP's obligation has been resolved then these details will be published on the ComReg website.

This email was sent on the 24th of May.

bealtine

Here is a reply I got from ComReg on this matter 2/07/2003.

Dear YYYYYY,

Thank you for your comments which have been noted internally.

ComReg has set out its approach in relation to functional internet
access in Document 03/68 (Section 5.1.2.3) and in the subsequent
Decision Notice (Document 03/87). A specific functional internet access
requirement is not specified at this time. ComReg has directed that
eircom

(1) develop a 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
(2) inform ComReg of the number and location of connections to the
public telephone network that employ carrier systems/pairgain devices.

Following further discussions with ComReg, eircom are to develop a plan
for addressing network performance issues that affect the speeds enjoyed
by internet users. ComReg has reserved the right to specify any further
actions that may follow, including further specific measures regarding
functional internet access.

I trust this clarifies the matter,

Best Regards,

XXXXX XXXXX

Consumer Management
Commission for Communications Regulation

Abbey Court Irish Life Centre Lower Abbey Street

Dublin 1 Ireland

Telephone +353 1 804 xxxx
Fax +353 1 804 9680

bealtine

here is my reply

have read the ComReg document "Document 03/68".
After reading this document I then wrote my email

This is a bizarre document coming from a "regulatory authority"
of any description.
I point out the absurdity of the position laid out in the document,
which you have alluded to below:

I quote:
"The respondent expressed difficulty with the specification of a bit
rate
and the publication of a network performance statement by the USP.
While they felt that this was a commendable aim, other factors need
to be considered that may influence the customer's internet experience
such as the customers equipment, bottlenecks in the internet backbone
and download speeds at the far-end server.
As the customer's experience is dependent on the slowest link in the
internet chain, the setting of a minimum bit rate may not significantly
impact on the actual customer experience. In addition, the costs
involved in network upgrades in order to ensure any
minimum bit rate make this an unrealistic option."


This is utter nonsense. I fail to see what some server in the USA has to
do
with connection speeds between the user and the local exchange, these
factors may affect the user's perceptions, but they in no way affect the

speed of the link to the exchange.
(In fact this sounds like the total rubbish that eircom normally use.)

I am familiar with what the regulatory authorities in at least two
other jurisdictions publish. They have both managed to impose
a realistic and modern "line speed requirement" on their telecom
providers.
Yet again I reiterate our line speed requirement has managed to go from
a
paltry 24k to 0k. How on earth can this be considered progress?



//

---

to which I got this (bit of double speak)

Thank you for your comments and concerns which we have taken note of
here.

However, Comreg's reasons for its approach have already been set out in
03/68 and confirmed by Decision Notice 03/87.

I trust this clarifies the matter,