DCMNR Public Consultation: Broadband Demand

damien

http://www.dcmnr.gov.ie/Communications/Communications+Development/Broadband+demand+report.htm

They have suggested 33 discussion points.

They also say:

Your submissions should be marked ‘Broadband Demand’ and emailed to the Department of Communications, Marine and Natural Resources at information@broadband.gov.ie by 15 February 2006.

damien

Now taking submissions til March 1st

damien

The following are the 33 questions and suggested discussion points from the DCMNR. Yes, they help you answer the questions. IOFFL will have their submission ready by end of week.



Overall Approach

(1) Is there a fundamental problem with the level of demand for broadband?

The current take-up rate for broadband in Ireland is lower than many other countries. This mainly reflects the Irish market being at an earlier stage of development than others. It is normal that customer numbers increase gradually over time, rather than all at once. However, if there is a fundament issue that deters households and enterprises from purchasing broadband even where it is available, thereby reducing consumer and SME demand, it would be an appropriate public policy response to address it. The same question could be posed in relation to a specific group of potential users, e.g. users in a particular region or a particular type of SME, rather than the market in general.

(2) How should the Department prioritise broadband demand-side issues, relative to supply-side issues?

In light of both demand and supply side issues being important, on which issues should public policy focus? This is largely determined by where you believe the more serious issues lie in the broadband market. Supply-side or industry issues include service coverage, infrastructure roll-out, effective competition, pricing, while demand-side or user issues include consumer awareness of broadband, understanding of different broadband providers, technical capability to use broadband.

(3) What sectors should the Department prioritise as part of a broadband demand initiative?

Public policy could address demand at a general level, such as awareness raising. An alternative approach could be focus on specific segments of the market such as a specific user group. An additional matter to be considered is whether the Department should prioritise a cross-departmental approach or focus on immediate actions for which it has direct responsibility.

Examples of General Measures

(4) ‘Broadband service providers could continue to reduce the total cost of broadband to customers.’

This would improve the cost-benefit balance of broadband and thereby increase broadband take-up. While this would increase the attractiveness of broadband to consumers, it could also affect the revenues of service providers. However, the growth in the number of paying subscribers could offset the effect of the reduction in prices on vendors’ revenues. Notwithstanding, it should be recognised that increased competition is the single strongest incentive for a seller to reduce price.

(5) ‘Broadband service providers could improve the quality of broadband products without increasing prices’.

Examples of improved service quality include increasing the downloading and uploading speeds of broadband, reducing the standard contention ratio, improving/removing any time limits on the service, and improving/removing download limits. This would improve the value for money of broadband from the consumer’s perspective. However, it would have cost implications for the service providers. Again, increased competition and scope for product innovation is likely to lead to improved broadband offerings.

(6) ‘Broadband service providers could publish more transparent and comparable pricing of broadband services in a standard format.’

This initiative would clarify the cost of the different services for potential customers. This would make costs easier to understand and to compare for consumers but would increase competitive pressure on service providers.

(7) ‘Broadband service providers could provide pricing and availability information to the Department’s www.broadband.gov.ie.’

This would increase the amount of impartial information available to consumers but would involve additional work by service providers.

(8) ‘Broadband service providers could include a link or reference to the Department’s www.broadband.gov.ie

This would improve consumers’ understanding of broadband pricing and competition but would require main service providers to agree to include a link/reference.

(9) ‘Broadband service providers could improve the flexibility for customers to switch between service providers, including a Code of Practice for switching provider.’

A code for switching between providers would make it a hassle-free process for the consumer and minimise any break in broadband service. This would reassure consumers by preventing ‘lock-in’ but would require agreement and cooperation between main service providers as well as possibly increasing competitive pressure/customer churn.

(10) ‘Broadband service providers could introduce special ISDN-to-Broadband switching promotions.’

Pricing discounts or special offers could target existing Basic Rate ISDN users. ISDN subscribers demonstrate a clear demand for faster internet access. A special ISDN switching promotion would target the existing 100,000 Basic Rate ISDN subscribers. The ISDN subscribers would benefit from a faster broadband service and reduced costs. However, this would also impact on revenues of existing ISDN service providers.

(11) ‘Broadband service providers could introduce special Dial Up-to-Broadband switching promotions.’

Pricing discounts or special offers could target existing dial-up users (both standard and flat rate dial-up subscribers). A special dial-up switching promotion would target the estimated 640,000 dial-up subscribers. All dial-up subscribers would benefit from a faster broadband service and many would also benefit from reduced costs. However, this could also impact on revenues of existing dial-up service providers but could be more marginal than an ISDN switching initiative.


(12) ‘Broadband service providers could continue to improve their customer support arrangements.’

Service providers should recognise that most consumers are not technophiles and find any technical problems particularly difficult and irritating. This improvement would enhance the quality and experience of a broadband service for consumers and would have cost implications for service providers. Negative ‘word of mouth’ experiences can deter many people getting broadband.

(13) ‘The Department could develop a more informative, image-based map of broadband service availability than is already available on the www.broadband.gov.ie

This would provide more information for consumers but would also require detailed information to be provided by the service providers.

(14) ‘The Department of Communications, Marine and Natural Resources could publish regular “best broadband buys” on the basis of a typical user and the services currently available.’

These could be recommendations by consumer/user bodies. The ‘best broadband buys’ could be integrated into the Department’s www.broadband.gov.ie This would increase the amount of information available to consumers but could alienate service providers.

(15) ‘The Department of Communications, Marine and Natural Resources could publish public information leaflets/booklets for SME and residential broadband consumers.’

This could demystify the range of broadband options, which can be confusing for potential customers as differences between broadband services may not be impartially explained by vendors seeking to sell their own broadband offering. It could address issues such as what is broadband; explanation of technology options; reasons to upgrade; comparison of services; basic requirements to be able to get broadband; questions to ask a service provider; buying tips; and PC security recommendations.

(16) ‘The Department of Communications, Marine and Natural Resources, in conjunction with service providers and other partners, could increase the number of public free broadband access points to enable people to try broadband for free in convenient locations.’

Current Government initiatives have focused on providing free internet access in libraries, and on rolling broadband out to schools. Consideration should be given to extending, possibly temporarily, free access points to locations that people frequently visit by competitive tender. This would increase the opportunities for consumers to ‘test’ broadband without having to purchase a broadband service but may compete directly with existing internet cafes.

damien

(17) ‘The Government could continue to rollout online Government services, such as tax payments, licensing, etc.’

The expansion of eGovernment services will provide useful applications for residential and business users. However, as many Government services are irregular, information-provision or intermittent, simple transactions, eGovernment may encourage more use of the internet but may not be sufficiently important or regular to encourage people to purchase broadband access.

(18) ‘The Government could continue to support the development of online information/content by local community/voluntary organisations.’

This will provide more relevant online information for local people. However, by its nature, this information may not be broadband dependent and is likely to be accessible by dial-up services.

(19) ‘The Government, in conjunction with industry, could continue initiatives to raise awareness of PC security and protection against computer viruses.’

This will reassure business and residential users that its is possible to use broadband and to effectively protect a PC.

(20) ‘The Government could develop educational content that is linked to the curriculum and provide support training to teachers to use it.’

This would provide useful source of material that schoolchildren could use in school and at home. However, it would need to avoid disadvantaging socially excluded groups.

(21) ‘The Government, in partnership with industry, could introduce a PC & broadband subsidy/voucher scheme for schoolteachers.’

This would enable teachers to become familiarly with computers, broadband, and online content resources at home so that they would encourage its use as a classroom/learning tool for their schoolchildren.

(22) ‘The Government and service providers could provide a fund to support individual schools developing their own websites for information, scheduling activities, school-parent communications, study information, and locally produced student & teacher content.’

This would provide relevant online information for households with schoolchildren. However, it may result in relatively uneven benefits between different schools.

(23) ‘The Government could support the provision of more downloadable TV and radio programming by RTE.’

This would be a useful application of broadband by providing interesting content that is best viewed/listened to over a broadband connection. However, establishing a digital archive could be costly and involve digital rights issues.

(24) ‘The Government could digitise Irish cultural material from the National Gallery, Library and Museum.’

This would provide a source of content that could be of interest to many people, particularly schoolchildren, that would be best accessed over a broadband connection. Issues of cost of development and digital rights management would need to be address.

(25) ‘The Government and service providers could promote the use of cheaper VoIP telephone services by SMEs and households.’

This would promote a broadband application that is immediately useful for consumers and provides financial savings. However, it could be considered unusual for a Government department to promote a particular application.

Examples of Measures for the SME User

(26) ‘The Department could conduct a broadband awareness campaign for particular sets of consumers.’

For example, the Department could target SMEs to identify and clarify the benefits and issues related to broadband for SMEs. As early adopters, SMEs could act as broadband champions spreading word of the benefits that they got from a broadband service. Consideration could be given to working with some of the larger ICT companies to promote SME broadband take-up.

(27) ‘The Department, in conjunction with industry, could organise regional roadshows/seminars with business groups to provide information to SMEs about getting broadband and profitably exploiting broadband.’

This could provide relevant and impartial information to business groups at a local level.

(28) ‘The Government could establish a fund to support the development of innovative services/applications for SMEs that use broadband.’

This fund could provide a dedicated source of funding for the development of new commercial applications that bring broadband-related benefits to SMEs. On the other hand, it could displace new applications that are being developed by the market (via start-up companies and venture capital, as well as R&D by large established companies).

(29) ‘The Government could provide a subsidy/tax credit to SMEs to get a broadband connection.’

This could incentivise SMEs to get broadband, however, the deadweight effect of a subsidy/credit would also need to be considered.

Examples of Measures for the Residential User

(30) ‘The Government, in conjunction with industry, could introduce a residential customer subsidy/voucher scheme for new broadband connections, which is targeted at low-income or e-excluded groups.’

This proposal has a direct link with broadband take-up and targeting it at particular income groups could make it more cost-effective.

(31) ‘The Government, in conjunction with industry, could introduce a incentive schemes (e.g. vouchers, subsidy or tax credit) to promote PC purchases by residential consumers.’

This would encourage more households to purchase a PC but other issues would need to be considered, such as the effectiveness of such a scheme in increasing broadband take-up, the deadweight effect of the scheme, and social inclusion.

(32) ‘The Government, in conjunction with industry, could implement a scheme to provide low-cost PCs to low-income families.’

This would have similar issues to a PC purchase incentive scheme but it would also focus enabling low-income schoolchildren to get broadband access.

(33) ‘The Governments could provide IT awareness/training courses to particular e-excluded groups, such as elderly, homemakers and disabled.’

This would encourage these groups to experience broadband and ICT and increase the likelihood of getting broadband. However, given that these groups are least likely to use ICT/broadband, the initiative’s impact may be limited.

lucernarian

I take it that is IOFFL's submission?? It's quite impressive! Many points and aspects covered - good job guys.

damien

NOOOOOO

That's the DCMNR's suggestions where everything is already good in lollipop land and they're going to make it even more special. We'll have a reality based submission.

damien

I fully encourage people to do a before and after for each of those model answers and see the difference between fiction and reality,

We'd like our next consultation to be a bit more collaborative with the people who come on here and interact with everyone and so I've created a Wiki here: http://irelandoffline.pbwiki.com but it is password protected. If anyone wants to give input on the above questions then PM me and I'll send you the password. I'd like to keep our reply private for a while so the usual suspects won't come up with counters to what we say. We have a few surprises too and we hate to spoil surprises. Thus the wiki.

lucernarian

I didnt read the "suggested discussion points from the DCMNR" bit of the post:o

watty

Not a lot of people have done this

damien

*BUMP*

20 people have submitted their views and sent copies to IrelandOffline. Two days to go folks. Lets make it to 50 at least.

paulm17781

I sent one in. I can't remember if I cc'd IoffL.

damien

30 people or so now. Make it 50 by 5pm. Sorry for spamming but come on folks!! There's way more than 50 people that read this forum daily. I'll make Spongebob get into a cheerleaders outfit if you don't!

Sponge Bob

damien.m wrote:

I'll make Spongebob get into a cheerleaders outfit if you don't!

phuck

I have a spectacularly rude submission to send in to them on my own bat. I may share it with yiz post facto ! Ultimately this survey strikes me as being analagous to an exercise in lifeboat provisioning conducted on the Carpathia .

bealtine

Sponge Bob wrote:

phuck

Ultimately this survey strikes me as being analagous to an exercise in lifeboat provisioning conducted on the Carpathia .

THis survey is being conducted underwater too...and in 1920 or so.

damien

We sent in a 13 page submission to this, too long to include on a thread here but I'll include the first few paragraphs. We'll stick the document we sent in on our website soon enough.

On behalf of our members, IrelandOffline would like to express our gratitude for being asked to contribute to this consultation. We greatly encourage more public consultations.

We shall start our reply by giving our overall view of the broadband market in Ireland and areas Ireland is failing in. After this we shall answer the questions suggested discussion points in the consultation.

Current state of telecoms and broadband in Ireland

Ireland is not doing well when it comes to telecoms. We have the highest landline rental prices in the EU which is 8 Euros per month more expensive than the EU average. Ireland has the 4th most expensive landline bills in the EU when using a genuine composite basket. Mobile Average Revenue Per User (ARPU) is the highest in the EU according to ComReg figures for the past two years.

In the EU 15 we are second last for broadband penetration and we are consistently at the bottom and stay there in every single international broadband survey. A recent Forfas report showed we actually have dropped a place in OECD rankings.

A worrying aspect of this is that there is a constant denial from some Government circles on how bad the situation is. The PR machine of ComReg is doing Ireland more harm than good. A culture of secrecy and denial goes against the very core of open governing and effective regulation. The failure to admit to past mistakes and current ongoing problems in other institutions in Ireland has been shown to be detrimental. This inability to grasp the nettled reality is damaging us. We cannot get out of the broadband gutter if we delude ourselves that we are in the stars.


Facts, figures and PR machines spinning overtime.

One of the reasons we believe we are in such a dire situation in Ireland when it comes to broadband is the insistence by so many groups that there is nothing wrong with the broadband market in Ireland. Problems cannot be addressed if they are not given recognition. Forfas have reported how bad we are, they gave solutions. The Information Society Commission issued reports and suggestions as did the Oireachtas report on broadband. Many reports and many valid suggestions have been made but the majority of the recommendations have never been carried out.

Growth Rates
Claiming to have one of the highest growth rates in the EU to make it appear we are doing well is disingenuous. If the penetration rate of Ireland is 5% and we have a growth rate of 100% it means we are going to go up to 10%. A country with a penetration rate of 25% and a growth rate of 60% will boost the penetration rate to 40%. Ireland is being lapped and lapped again by every developed country in the world. Patting ourselves on the back for a high growth rate is deceptive and dishonest.

The fungible excuses of no cable competition, starting late, telecoms bubble bursting, population density, pc penetration and lack of demand need to cease. These excuses are listed here along with their counter-arguments.

Cable Competition
The excuse of not having cable competition as a reason for Ireland doing so badly in broadband penetration does not hold weight. Cable is not the cause of worldwide broadband penetration increases. Many countries have aspired to high penetration rates without cable.

Telecoms Bubble Bursting
The technology and telecoms “bubble” “bursting” is used to explain why we were a late starter in the area of broadband. The telecoms market and the bubble bursting were not localized to Ireland. Every country suffered from the crash, some even more so than Ireland and they are currently prospering in the broadband environment.

Population Density
Population density is another favoured excuse for rollout issues and as a result low broadband adoption in Ireland. Many of the Scandinavian populations are less dense than Ireland and have much better broadband penetration rates. Northern Ireland has 100% availability and a penetration rate far better than the Republic. Same geography, same population density.

PC Penetration
PC Penetration is fast becoming the favoured excuse for lack of broadband penetration. The excuse runs that since we have low PC usage we have low broadband usage. PCs are now primarily network access devices. Why buy an expensive device if you cannot use it for what you want it? Consumers are being blamed for lack of broadband penetration because they are not buying PCs. Have consumers ever been blamed for poor mobile network coverage because they are not buying enough handsets? Meteor built out their network and generated almost 100% coverage and as latest figures showed their customer base jumped a large amount.

Irish consumers use Playstations and X-Boxes more than any other nation in the world apart from Japan. We adore technology but we are not stupid. We would not buy something that we could not use. We will not buy a PC if we cannot get it high speed Internet.

Staying with the X-box theme - you cannot blame the lack of X-Boxes for lack of games being sold if it transpires that the number of games out there were severely limited and only a certain percentage of the population could access the shops where the games were sold. Yet this backwards excuse is used about PCs and broadband. Build a broadband network that reaches all and PC usage will jump. The corollary is not true.

Lack of Demand
A very hostile and insulting excuse for low penetration rates is lack of demand. We do not for one single second believe this to be true. We instead believe it to be convenient for avoiding the hard work of getting Ireland from bottom to near the top of all the broadband league tables.

ISDN usage has increased not decreased. It should be obvious why this is. People want broadband and cannot get it and resort to expensive ISDN. Satellite usage is increasing not decreasing again because people need something like broadband and resort to a inferior and horribly expensive system to get them close to what they need. Why would people pay €1000 install fee and minimum €70 a month for such a service if it wasn’t because they need broadband type speeds?

The IrelandOffline survey we presented to the DCMNR showed the majority we surveyed who were on dialup (circa 400 people) wanted broadband but could not get it because it was not available. The Chamber of Commerce of Ireland recently showed that 30% of businesses who wanted to upgrade to broadband could not do so because of the lack of availability of broadband. Anytime there is a radio piece on broadband the switchboards are bombarded by people who cannot get broadband because it is not available.

There is not a lack of demand, there is the insistence to not accept failure and blame it on lack of demand.

Unless the energy put into creatively coming up with excuses for the current situation is channeled into something more constructive, we will be held back from moving forward.

jwt

Less than an hour left folks

It doesn't need to be a monster submission.

One paragraph stating that you think x because y will do.

You don't want the Dept. telling you they didn't do something because of lack of interest do you?

John

Sponge Bob

Very good submission, I will put my rude one on hold so

eircomtribunal

damien.m wrote:

We sent in a 13 page submission to this, too long to include on a thread here but I'll include the first few paragraphs.

Can we have more here?
I like the diplomatic irony in sending this:

A worrying aspect of this is that there is a constant denial from some Government circles on how bad the situation is.

to the DCMNR.

I was wrong to be afraid you might succumb to the leer of getting lost in the complexity of the DCMNR list of 33 questions.

Great document.

You'll send it to Pat Kenny? Who had David McRedmond lying on public radio unquestioned about the fact that Irish broadband availability is also on second last place in the EU. McRedmond had the neck to repeatedly tell the listerners that dsl availability in Ireland was en par with the other EU countries, "absolutely".

You'll sure send it to the Oireachtas Committee on Communications members? It is about time they emerged from the deep sea for a while and really took on their function of reigning in a regulator gone astray.

P.

damien

We had an 8 page introduction before we answered a single question. I'll have the document on our website later tonight.

cgarvey

damien.m wrote:

I'll have the document on our website later tonight.

He's had his wicked way .. IrelandOffline DCMNR submission

eircomtribunal

ComReg's response is here. It's basically the same cack they sent to an earlier consultation – think it was the FORFAS.
ComReg tell us that because broadband is now freely available (you can choose between the dsl, the LLU (!) or a € 9.99 Bitstream (Timed) 1MB, cable and wireless) they are disappointed with our up-take levels.

They say that despite the strong growth the EU says that on a per capita level Ireland's broadband penetration is still "below the EU average"(nice way of putting it – I thought the graph showing this, on page 4, funny for another reason: I gives averages for the EU-10 = the new entrants, the EU-16 = the old countries and the EU-26 = all countries – did I miss a new country entering the EU?

But all is not lost.

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.

and

In tandem with this, ComReg anticipates that the addition of ‘Home Phone’ and ‘Broadband’ calculators to ComReg’s www.callcosts.ie website in May, will further enhance pricing transparency for consumers and assist them in choosing which broadband and fixed line packages available in the market can meet their pricing and usage requirements.

ComReg conclude that demand stimulation is the thing to do.

I wonder will they again get the same media attention as they got when they published this self-protecting propaganda piece earlier?

P.

eircomtribunal

eircomtribunal wrote:

I wonder will they again get the same media attention as they got when they published this self-protecting propaganda piece earlier?
P.

No they did not. IOFFL's submission was more interesting: See article on siliconrepublic here

Lack of LLU is damaging Irish economy

07.03.2006 - Local loop unbundling (LLU) has been an absolute failure in Ireland, a lobby group focused on promoting broadband has warned in a submission to the Department of Communications, Marine and Natural Resources. The group has called for a Government directive to resolve the issue.
In a response to a public consultation by the department regarding the broadband demand issue, IrelandOffline highlighted the number of lines unbundled in Ireland are low compared to the European average. It said that Ireland is second last for broadband penetration in the EU15 and a recent Forfás report showed that Ireland actually dropped a place in the OECD rankings for broadband.
According to the Ireland Offline submission: “The regulator’s attitude towards LLU needs to be seriously questioned. It has failed year on year to make anything that could be considered progress.
“Its decisions on processes....

P.