Forfas Benchmarking Consultation 2006

damien

In a previous thread the Forfas Broadband Benchmarking Report was mentioned. They have invited IrelandOffline to give our feedback on the report and are asking a few specific questions which we'd like to hear your views on:

(Please note that this is not an invite to debate blah versus blah with another poster or to find fault with the questions themselves. Constructive feedback is welcome.)

Increasing Broadband Availability
Given Ireland's spatial patterns, what are the most effective ways to accelerate the rollout of broadband services to all?

Increasing Competition in the Market Place
How can Ireland accelerate the effective implementation of local loop unbundling to provide competition in the DSL market?

How can Ireland optimise the use of state-owned infrastructure to increase availability and choice of broadband services?

Creating Awareness to Increase Demand
How can Ireland best use experiences/initiatives in leading countries to create awareness and drive demand?

Are there local initiatives that have been successful in some regions in Ireland that can be used as a template for other parts of the country?

watty

Increasing Broadband Availability
Given Ireland's spatial patterns, what are the most effective ways to accelerate the rollout of broadband services to all?

Decrease Line rental to 15 Euro a month. Then Eircom would find LLU and Broadband more attractive.


Insist that if BB is unavailable or line fails then one of the following should apply:
ISDN always on internet dedicated on one channel no charge.
OR
Dialup internet unlimited duration for 10 Euro per month.
OR
Second line rented at 15 Euro a month dedicated as always on "dialup" internet.

ALSO. Where a customer already has ISDN, install ISDN compatible aDSL as in Germany such as NEC vDSL


Increasing Competition in the Market Place
How can Ireland accelerate the effective implementation of local loop unbundling to provide competition in the DSL market?
Set realistic cap to charges by incumbent.
Set penalties if a certain percent are not unbundelled in an initial period


How can Ireland optimise the use of state-owned infrastructure to increase availability and choice of broadband services?
Subiside all ISPs equally for connections to MANs and ESB fibre etc. Set realistic CAP on Eircom charges to connect MANs to Internet backbone.

Creating Awareness to Increase Demand
How can Ireland best use experiences/initiatives in leading countries to create awareness and drive demand?

The problem is percieved high cost of connection or lack of connection.
The schools Broadband inititive should have a part II: Use of Broadband

Reduce cost of .ie Domains

I'm renting 10Mbits/s bothway bandwidth and fault tolerant hosting with scripting and mailserver and personal Domain name (.net) for $92 A YEAR.

How much per month would that cost here (after buying a real fault tolerant server for €4500) just for the bandwidth?

What % of population (not by exchange) would that be available?

cgarvey

watty wrote:

Insist that if BB is unavailable or line fails then one of the following should apply:

Bingo .. nail .. head

uncle_sam_ie

The government should give tax breaks to broadband internet provider's who invest in rural Ireland. We need to give them a good financial reason to look outside Dublin,Cork, and Limerick.
My two cents

oscarBravo

I agree.

Sponge Bob

The government should provide a tax incentive based simply on the DSL BB line test, if you fail the DSL test you get a €1000 allowance per year, every year till you pass, to susidise the alternative option which will always have more expensive CPE

One database, one standard , simple to administer and <cough> transferable like <cough>

damien

One more day left to get opinions.

damien

Increasing Broadband Availability
Given Ireland's spatial patterns, what are the most effective ways to accelerate the rollout of broadband services to all?

Spatial Pattern Excuse/Myth
Just to be clear - Ireland's spatial patterns are not unique in the developed world. Northern Ireland has 100% broadband availability and a much better penetration rate than the Republic and all with the same spatial pattern. Apart from the very large cities in Sweden, Norway and Denmark, the spatial patterns of these countries are also akin to Ireland and these are some of the leading broadband countries in the world. Spatial patterns are a minor obstacle when phonelines are going into almost every home in the country already and so therefore can avail of a DSL service if it was provided.

Previous Reports
We believe the best way to accelerate rollout of broadband is for the Government to read previous reports created by Forfas, the Information Society Commission, the Oireachtas Report on broadband and so many more. They have all suggested methods on how to roll out broadband but their recommendations remain unexecuted. This is probably the biggest obstacle for broadband roll out.

Regulation
Additionally the quality of regulation in Ireland is not on-par with other EU countries such as the UK and Denmark. A strong regulator not afraid to take on telecom giants and who does not capitulate during court actions would create a better environment to provide broadband for all.

C/GBS
We believe that the Group and County Broadband schemes created by the DCMNR are a great way of providing broadband to towns and villages who cannot get broadband through any other means but these projects ideally should only be addressing "blackspots" where there is patchy coverage. Instead it appears that 30% of the country would need to set up GBSs if they want to get broadband.

National Wireless Broadband License
We believe that the National Wireless Broadband license that eircom owns should be taken from them and reauctioned to local ISPs who can use the spectrum to provide wireless broadband to rural areas. This 3.5ghz license that eircom owns remains largely unused and is unadvertised and if you try and enquire how to avail of it, you will be told it is not available in your area. We have highlighted this repeatedly to the National Regulatory Authority and we have brought it to the attention of the DCMNR.

Flatrate Internet
We believe that per minute dialup Internet access should be banned and replaced with flatrate bands of dialup. Circa 80% of people still go online using dialup and according to ComReg the average monthly bill for Internet access is around €36. Given that many broadband products are now €20-€30 a month, it means dialup users are paying more for a far inferior product. eircom noted in their SEC filings in 2005 that they sell billions of minutes of dialup Internet. This is a cash cow and an incentive to only rollout broadband at a leisurely pace. The incentive for massive profits from dialup needs to be removed.

Additionally those who cannot get broadband over their phoneline or through wireless should be given the option to be provided with true flatrate broadband where for a price of €30 a month they can avail of 24/7 flatrate.

To implement flatrate bands, the wholesale cost of flatrate needs to be reduced drastically. IrelandOffline has requested that the National Regulatory Authority reexamine the wholesale costs of this service but as per our requests about the National Wireless Broadband license, they have not looked into it, to the best of our knowledge. IrelandOffline question how 180 hours of dialup Internet costs €26.99 when a 1mb always on dsl connection now costs €20. Those suffering on slow dialup should not also have to suffer extortionate costs.


Line Failure Rate
The failure rate of lines connected to broadband exchanges is atrociously high in Ireland with rates of 20-25%. The current enabled exchanges are in mainly urban areas and we believe that as more rural exchanges come online, the line failure rate will increase.

We believe that a mandatory directive should be put in place so that if a line fails the broadband test then it will have to be
investigated by an engineer and replaced if necessary so that it does pass the broadband test. If doing this costs an unreasonable amount then the customer should be provided with a subsidised full flatrate dialup product.

Functional Internet Access
Currently lines in this country must be able to carry a dialup speed of 28.8k. However the regulations for this allow multiple loopholes so many will not even gets 28.8k. We believe that FIA should be once again reexamined so that a line should be able to carry a speed of 42k. This will result in a faster dialup experience for those on dialup but it will also ensure that the quality of the line will also allow it to carry a broadband signal, so that if the exchange the line is on is enabled, then it is guaranteed to pass the broadband line test.

This FIA speed would also mean line splitters would need to be abolished or upgraded to line splitters that can carry a DSL signal. Currently as previously stated, a low speed FIA means the quality of phonelines can be substandard so that they cannot carry carry broadband signals and the dialup signals it does carry are slow enough that it could take twice as long to download something compared to another dialup user on a better line. This means that a telco will make more money from a dialup user on an inferior line. This incentive to profit by not investing in a high quality network must be removed.

National Broadband Authority
Much like the National Roads Authority has helped bring Ireland into the modern era with our road network, we would like to see a body charged with working on bringing about broadband for all. A body that is in charge of linking all the broadband assets together. Additionally the body could link with smaller ISPS and GBSs to provide Government assets for them to use to put up antennae and masts and possible space for data centres.

Planning/Ducting
We believe that the planning regulations for ducting differs from council to council. A standard regulation for ducting is needed and one that provides a cheaper and transparent rate than is available currently. To aid competition, providers should have the means to rollout alternative infrastructure like fibre at a cost that is reasonable.

Internet Usage
Internet usage in Ireland remains unchanged for the past 2-3 years with a usage rate of 37%. This seems to say that those online are moving from dialup to broadband. If this rate of transfer continues it will mean we will get more people on broadband but our overall Internet usage will not increase. The only way to match the rest of the EU and the developed world is to get more people online and bring the 37% figure up to 60% or more. It needs to be researched if those using broadband are just moving from dialup and see are there new Internet users who start off with broadband.


Increasing Competition in the Market Place
How can Ireland accelerate the effective implementation of local loop unbundling to provide competition in the DSL market?

LLU is a failure in Ireland through major incompetence by the NRA. LLU was directed by the EU over 4 years ago and is still not correctly implemented in Ireland. In Feb 2005 the NRA after months of discussions with the OLO sent directives to the incumbent which would have created an environment where LLU would have worked and thrived. After a court case over a point of law and NOT the directives themselves the NRA withdrew all these directives and agreed with the incumbent that the incumbent would created a Market Requirements Document. This was released in October and basically stated that it did not like the idea of LLU and would not make LLU provision an easy task.

It is now 12 months later and none of the issues which the OLOs have been complaining about for the past 4 years have been addressed. We would like to see the National Regulatory Authority reissue these directives.

Additionally we would like to see the DCMNR direct ComReg to bring the LLU rate on a par with the EU Average and to transparently report on Ireland's ranking compared to the EU on a 3 monthly basis.

Further to that we would like to see an independent LLU adjudicator created, as OfCom did in the UK.


How can Ireland optimise the use of state-owned infrastructure to increase availability and choice of broadband services?

There have been numerous reports suggesting how to link up state-owned fibre and using it to link up MANs and fibre corridors. We'd support previous suggestions on this initiative.

We understand that a private company has been tasked by the Office of Public Works to engage with telcos to rent them roof space and property space. However it seems they will only work with large players like Meteor, o2 and Vodafone. We would like to see Government assets used so that Group Broadband Schemes and smaller ISPs providing broadband to those in less urban areas can use these resources to bring broadband to those that still cannot get it.

damien

Creating Awareness to Increase Demand
How can Ireland best use experiences/initiatives in leading countries to create awareness and drive demand?

We should be looking at the regulatory model of the UK and of Denmark. The majority of countries in the EU have shown how to address the issues of broadband by regulating properly. Ireland needs to do the same. We should bring over the leading people from Estonia who made the country a success in terms of Internet usage.

Are there local initiatives that have been successful in some regions in Ireland that can be used as a template for other parts of the country?

Casey Cable in Dungarvan, Community broadband schemes done by the likes of WestNet. Look at the model in Northern Ireland. 100% broadband availability in a few short years.

eircomtribunal

That's an excellent submission by IOFFL.
ComReg's submission is pathetic, to say it in one word. Kind of We are doing great, if only end-users could be pushed a bit more to do their bit.

"ComReg considers the stimulation of end-user demand for Broadband as the key challenge both for operators and other stakeholders in 2006.

P.

eircomtribunal

The 2 cent I sent to Forfas:

As somebody who since 2002 has put a lot of effort into alerting government ministers, TDs, the regulator and the Irish Media about the devastating development of Irish Internet and Broadband availability and take-up, with far-reaching negative impact on the nation's future, I'd like to make a few comments on your report.

1. While it is a good thing that Forfas makes a clear statement about the dire situation we are in (in stark contrast to regulator ComReg and the DCMNR, whose continuous rose-tinting of the situation has seriously undermined any decent effort to look for timely remedies and in even starker contrast to the misinformation the incumbent has been able to put out to the public), I would like to constructively correct some wishy-washy thinking that seems to be behind the Forfas consultation questions.

(Allow me to simplify somewhat in order to emphasise the priorities)

You write under the heading "Creating awareness to increase demand: A lack of awareness among both residential users and SMEs of the benefit is regarded as the single biggest barrier to broadband take-up in Ireland." and ask "How can Ireland best use experiences/initiatives in leading countries to create awareness and drive demand?"

This is in my opinion missing the point:

The single most important, the pivotal point, why Ireland's Internet penetration, and consequently the Broadband take-up is trailing so far behind most other EU countries is this:
Incumbent Eircom was and still is allowed to price the ordinary user out of using the Internet. Eircom makes a "killing" out of 3 euros per hour metered dial-up access.
This is still by far the most common means of accessing the Internet in Ireland. At this price you cannot "convince" the ordinary consumer to go online.
The experience in all the successful Internet nations was/is based on making access to the Internet easy and very affordable.
The World Wide Web did/does the rest – not government incentives.

Low Irish computer usage is mainly due to the Irish "Internet failure". Internationally computer usage and Internet usage went up simultaneously. They depend on each other.

When Minister Ahern in the beginning of 2003 (belatedly) tried to take the clock out of the Internet experience of the Irish user by directing ComReg to introduce "affordable retail flat-rate dial-up Internet access", this directive was not implemented by the regulator. Instead the regulator cunningly/stupidly hailed the introduction of FRIACO, which did not bring about "retail flat-rate dial-up access", as the Minister had demanded, as fulfilling the DCMNR directive.
All that was introduced were some bundled hours packages with punitive overreach charges, that were a failure with only some 100 000 bundles sold. No change in our Internet usage could or did happen.

Today the incumbent can offer real flat-rate talk service for 15 euros per month, and has the audacity to ask an inhibitive 30 euros for a 150 hours dial-up package with 3 euro per hour overreach charge. All happening under the "watchful" eyes of ComReg, who are too busy loosing ecap and judicial appeals, as to concentrate on fixing the basic hindrances of Internet success in Ireland.

As long as this situation is not changed, there is no incentive for the Irish consumer to try the Internet and there is also no incentive for the incumbent to roll out broadband to the 40 percent of population that can be milked for pay per minute dial-up.

This is not a figment of my imagination but a simple economic fact that can be read for example in the latest CitiGroup report on Eircom.

No incentive initiative or similar can come up against such fundamental economic facts.

The demand stimulation argument is an already overused fog grenade, most prominently brought forward by the incumbent. It should not be entertained by Forfas.

The regulator could introduce a mandatory obligation on the incumbent to offer dial-up Internet access for a nominal fee or free of charge (as compensation for people paying the highest EU line rental and not having broadband access) on all lines that cannot avail of broadband. Such a measure would soon put an end to the incumbent's foot-dragging on broadband roll-out. Under the USO rules it is in ComReg's power to enforce such or similar measures.


2. The LLU situation:

This is only showing the general mismanagement of the Telecoms situation by the government: A government cannot allow to have one of the single most important industry incumbents consistently act against the State interest, using its enormous financial resources to fight all regulatory attempts, as for example the attempt to un-bundle the local loop .

The gov has to invite the management of the incumbent and make them aware in no unclear terms that the cat-and-mouse-game has to end. This is in the end the way it is done in other countries, like the UK. If the government does not have enough leverage, and I think they would have considerable leaverage, than the gov should provide this leverage by strengthening its competition tools.


3. Using infrastructure in State ownership

The further roll-out of the so-called Metropolitan Area Networks (now referred to as Municipal Area Network!) needs to be looked at again:
It is and cannot deliver what it is "advertised" by gov.
The loops of fibre-optic cable underneath the footpaths of the likes of Kiltimagh do not serve a purpose, they are a waste of EU and gov funding. All not yet finished projects should be stopped and redesigned to offer fibre to the home or curb, if they are to serve a purpose. To have these projects finished "in time" and "within budget" as the DCMNR claims, is not good enough. The gov claim that those smaller MAN's could support wireless providers is absurd nonsense.
Failure to open up the incumbent's copper infrastructure is not "made good" by this independent fibre provision.
Can I encourage Forfas to ask the DCMNR how those smaller fibre MAN's are meant to serve a purpose and what purpose?

P.

eircomtribunal

Some gems from the ComReg submission to Forfas:

In the main Irish consumers do enjoy a high level of disposable income but are not as likely to consume high levels of Internet access and services.(page10)

In addition ComReg would once again highlight the fact that although public funding has ensured universal broadband coverage in Northern Ireland, this has not as yet resulted in high take-up of Broadband.(page 7)

Once again? They must be reading to much Adrian Weckler, or the other way round.

And on LLU

Progress albeit slower than we would like is being made on elements of local loop unbundling including an initial geographical number porting solution. The processes needed to deliver fully unbundled loops to customers are complex and considerable care has to be taken to ensure that customers get the quality and level of services they require in any processes we would seek to put in place. (page 8)

Isn't it great to hear that the slow progress is due to ComReg taking extra care ensuring the customer gets the quality they require?

P.

Sponge Bob

....that Comreg ONLY replied to the Forfás survey at all because they know that IoffL would . Otherwise they would have ignored it.

Now about this bit on page 7 of the Comreg submission !

"Comreg is working to encourage innovation in the use of wireless broadband "

That is a barefaced lie. Any operator that has so far come up with an 'innovative' plan has found that Comreg is extremely slow to process and release necessary spectrum licences for those innovative services or to protect the spectrum in order to guarantee continuity of service . If they were O2 or one of the other kiddie robbers Comreg would fall over themselves to help out I am sure

The submission is delusional , I hope soemone in Forfás delves forensically into the Comreg claims and deconstructs them with the contempt that their lying self serving submission richly deserves. A call for abolition would be nice too of course

eircomtribunal

It's just fabulous how they start the chapter on "Residential Use of the Internet" (page 3):

1.1 Residential use of the Internet
ComReg’s most recent residential survey found that 99% of Irish consumers were familiar with the term “Broadband”, indicating that there is an opportunity for Broadband providers to convince Irish consumers of the benefits it can bring.

Next sentence shows how unhappy ComReg is with using internationally comparable figures for broadband penetration.

Although many comparative measurements of Broadband take-up internationally use a per capita metric (i.e. connections per head of population), ComReg considers it more appropriate to measure Broadband take-up per household.

Much nicer to throw about the Irish broadband household penetration, which at around 10% looks not that bad compared to the 10% – 20% per capita broadband penetration of our comparator countries.
P.

damien

Want to have some fun? Why not put together a prediction document for ComReg's submission to the DCMNR consultation. We can start a new thread for it.

bealtine

damien.m wrote:

Want to have some fun? Why not put together a prediction document for ComReg's submission to the DCMNR consultation. We can start a new thread for it.

I predict Comreg will ummm make up stufff...