Eircom wants fixed mobile convergence so Comreg hop to it with consultation

Sponge Bob

Details

http://www.comreg.ie/_fileupload/publications/ComReg0633.pdf

A good idea in principle but the LLU / Number Portability issue comes first and foremost in my mind.

damien

I'm sure the ultra secret Forward Looking Steering Panel suggested this to ComReg. It probably just happens that one of the 12 members is from eircom, though the details of this panel are not in the public domain.

Sponge Bob

a master from O2 had an input into this consulation too or so a lil birdie tells me but Buttsys press release makes no mention of eircom at all ....whats new

were a landline operator to ask for a chunk of these numbers and then try some MVNO activity Comreg would run them out the door.

were a VoIp operator to ask for a chunk of these numbers they would be treated like something the cat dragged in

were the Sponge to PM buttsy for a block of 10000 for <ahem>< location sensitive mpron activities not entirely unlike catting > I'm sure ole Buttsy would oblige ....obviously with the numbers I asked for and nothing else

otherwise they are for the cartel !

Blaster99

ComReg are a laugh. I like the "These are broadly similar to services that have already started to appear in other countries...". Yeah, started to appear. They've been available for years in other countries.

I wonder if the regulators in those other countries spent two pages on Geographic Number Porting or if it was just assumed that it would work. An Irish consultation document for an Irish problem.

Urban Weigl

This has been available in Germany for years. Even Vodafone offer it there. I think o2 were one of the first, under the o2 "Genion" brand. You get a landline number (even keep your existing landline number if you wish) + a mobile number + unlimited calls to all German landlines and o2 customers for €15 a month. When you take the phone out of your house (it's sensitive to a radius of ~2km), you pay normal mobile rates.

Edit: Check out http://www.vodafoneshop.de/shop/talk24/index.cfm
What you see here is a GSM phone that looks and works like an ordinary PSTN telephone. If there's a power outage, it will even continue to work for 48 hours, giving the ESB plenty of time to fix your line...

leoc

They what now? :eek: This is a new low.

(As you read the next paragraph, be warned that I'm not a telecoms engineer. But I doubt I'm far wrong.)

Back in the day when calls from one exchange to another were connected by operators plugging cables into switchboards, handling a national call cost the phone company quite a bit more than handling a local one. But in this day and age of digital exchanges etc. the extra cost to Eircom is close to nothing.

(Now be warned that I'm not an economist. But I doubt I'm far wrong.)

So why do we still pay different rates for local calls? Price discrimination.

In each category, Eircom's profits roughly = the profit they make on each call * the number of calls people make at that price. Now, if you dropped national call rates to what local calls cost, people would make a few more national calls. But people make many more local calls than they would if they cost what national calls cost. So Eircom keeps the two prices different because their sweet spot of maximum profit is different in each category. Having to charge the same price for both would be very upsetting, because wherever they set it they wouldn't be able to make as much money overall.

In a highly competitive market it wouldn't matter; in a highly competitive market, any time you set the price of a product significantly above the cost of providing it, someone undercuts you and takes all your business. So Eircom would end up charging roughly the same for both local and national calls, because they cost roughly the same. But when you have Significant Market Power ('monopoly' is such a strong word) things are different.

In fact the whole fun of being a monopolist or a cartel member (or something approaching one) is that you can charge customers what they're willing to pay for the product (or something approaching that price); none of that sliver above cost price rubbish. But just charging one inflated price isn't too cute, because different people are willing to pay different prices at different times and so on. Dividing up the market into different chunks which you can price differently is how you make 'em. So if you were Eircom, you'd want lots of different ways to charge people significantly different prices for things that cost basically the same. Charge more for longer calls. Charge more for calls during business hours. Charge by the call for a service that's almost 100% fixed costs. Generously volunteer to provide special light-use rates for the blind and the handicapped and the elderly.

So much for landlines. On mobile networks, I would guess there are still genuine cost reasons to encourage people to keep their calls shorter and spread out over the day, though I'd also guess that they don't nearly account for the differences in price. (Again, I Am Not A Telecoms Guy.) But as far as I can see no-one is even trying to pretend that a mobile operator's costs will be lower for a call made to or from a customer's "local zone" rather than elsewhere. In fact, all they're going to do is increase overall operator prices. So they're a price-discrimination mechanism, pure and simple.

The primary attractions of home-zone services for end-users are likely to be the
application of lower rates for outgoing calls made from within the home-zone area.

...

For incoming calls, home-zone services allow other users calling the home-zone
subscriber to benefit from fixed-line rates by calling the user’s geographic number.

...

Thus ... employees – while in the home-zone - could also be reachable (typically for free) through a short internal extension number.

Yes, darlings. Exactly. Condemned out of your own mouths. Actually, I can think of another use for geographic numbers; they'll make pricing even more complex. This will make it even harder for customers to weigh off the different tariffs and special offers to find the cheapest one for them. So less price competition and more profit for the operators. Strangely the consultation paper neglects to mention this advantage of the scheme.

So why would we want extra costs, hassle, and pricing opacity in order to deliberately introduce a new means for telephone companies to abuse their market power?

Under sub-section 12(6) of the Act, ComReg is required to take utmost account of the desirability that the exercise of its functions related to
subsection (1)(a) does not result in discrimination in favour of or against
particular types of technology

What this means in the present context is that it's wrong to let Eircom have its geographic price-discrimination scam on landlines without allowing the mobile networks (including Eircom's) to run the same scam too. Now of course the sane solution would be to abolish the local/national pricing distinction on landlines rather than extending it to mobiles! This would solve two problems at once rather than solving one problem (no number portability from landlines to mobiles) by creating another (a new pricing scam in the mobile market). Still economics is a strange old thing, so it actually is conceivable that extending the geographic-pricing scam to mobiles as well might be better than the status quo. So assuming that the sane solution is too much to hope for, why doesn't Comreg justify its proposal by claiming that the new problem will be smaller than the old one? Is it that:

1. Comreg is completely ignorant of the basic economics it needs to do its job: Eircom said "sure we can offer customers lower rates for local calls on the mobile" and Comreg said "Oh great!" There's no mention of 'third-degree pricing discrimination' in the consultation because Comreg has never heard of it.
   
   or
   
   
2. Comreg is deviously pretending to be: Saying something like "At present we don't dare to solve this problem properly by abolishing geographic price discrimination altogether, so here's why we think that extending this anti-consumer market distortion into a new sector is a lesser evil than the present arrangement" would be very embarrassing, maybe even a legal risk. So Comreg, not known for its fearless candour, decided to say nothing and brazen it out.

I really couldn't say. What do you think?

Sponge Bob

The bit that struck me was that there is an opportunity to take a cool look at VoIP / Mobile convergence too , not least by leaning on the cartel to facilitate national roaming (as in Italy) and MVNO and or roaming (as in O2 for Meteor to plug the gaps) and to re-energise the overall MVNO proposition in ireland which has been dead in the water since 3 got their licence.

A great opportunity has been lost in the cloud of dithering vacuity that passes for vision over in Comreg but thats nothing new is it ?? The home area will probably be a single sector off a mast with some doppler fuzz so it wont work in the back garden .

Seeing as the cartel are telling Comreg what questions they want asked this will not happen, of course it won't. Comreg know the answers too, the cartel have written them the crib sheet and will supervise the filling in of the answer sheet most closely.

You wonder what the forward looking yoke they set such store by does in these circumstances because this is only a bad version of what the Germans did years ago. Forward Looking like me hole I suppose !

leoc

Sponge Bob wrote:

The home area will probably be a single sector off a mast with some doppler fuzz so it wont work in the back garden .

I'm pretty sure that they want the 'home areas' to coincide with the current landline local-call areas. Which in fairness does serve the number-portability objective. They'll probably have to be a little more generous than the landline areas because of the fuzziness of Cell-ID as a location detector, at least until the promised new location-detecting technology in Appendix B comes.

probe

Sponge Bob wrote:

Details

http://www.comreg.ie/_fileupload/publications/ComReg0633.pdf

A good idea in principle but the LLU / Number Portability issue comes first and foremost in my mind.

A good deal... In return for nationwide LLU and real-time self-service numbering portability set-up eircom get FMC.

If eircom get away with giving less than that this, it will reflect negatively on the regulatory system (understatement).

probe

leoc

probe wrote:

A good deal... In return for nationwide LLU and real-time self-service numbering portability set-up eircom get FMC.

It would probably be a good outcome, but I don't think it would be a good deal to try to make with Eircom.

Firstly, how would you enforce it? You could hardly just give Eircom FMC and then hope that they'd be nice and voluntarily not cause any more problems with LLU.

Second, I think that Comreg deliberately introducing a new price-fixing wheeze into the telecoms market as a tradeoff for progress in other areas would be, um, a bit near the edge ethically.* It would be like the police department helping Al Capone to rob banks in exchange for his promise to leave the bootlegging trade. Simply paying Eircom money to go away would be shiningly noble and upright in comparison.


* Note that I don't believe that Comreg is actually trying to do such a deal! For one thing, it might be rather illegal. For another, I'm not convinced they have the brass or the independence of thought to come up with the idea.

leoc

damien.m wrote:

I'm sure the ultra secret Forward Looking Steering Panel suggested this to ComReg. It probably just happens that one of the 12 members is from eircom, though the details of this panel are not in the public domain.

As of 2003 it was Philip Donohoe (see slide 22). I don't know if it still is. Mr. Donohoe was (is?) Eircom's Head of Emerging Technologies and seems to have been its man on the telecoms conference scene 2001-3ish. His book report on Eircom for Eurescom has one or two quotable bits. (It's a fairly unremarkable name, so I don't know if he's the same guy who was technical director of streaming content startup NetTV in 2001, and I presume he's not the man who was in civil court versus Eircom in 2002!)

There's also Mike Carr, Director of Research and Venturing (sic) at BT. (Earlier he was Director of Enterprise Venturing (sic) at BT Exact (defunct).)

Frankly none of the other (2003) members seem all that scandalous or interesting, although as a Comp. Sci. student in the UK it amuses me to find two BCS worthies, Professor Jim Norton and Doctor Philip Hargrave, in there. Of the twelve, four are ComReg members plus chairperson Isolde makes thirteen. It seems the committee exists to allow Comreg people to chat about fun new technologies rather than attend to the real, ugly kicking-and-gouging work of regulating incumbents.

damien

Nicely researched!

Blaster99

Urban Weigl wrote:

When you take the phone out of your house (it's sensitive to a radius of ~2km), you pay normal mobile rates.

I assume they use LBS which has variable accuracy depending on the cell size. In rural areas I'd say you might be able to go 5km's from the house and still be in the home zone.

Urban Weigl

Blaster99 wrote:

I assume they use LBS which has variable accuracy depending on the cell size. In rural areas I'd say you might be able to go 5km's from the house and still be in the home zone.

All I know is that O2's marketing literature says that you can expect a radius of 2km around your house. This may very well be more in rural areas.

Of interest is the fact that O2 Germany lets you set the centre of your "home zone" wherever you want. So for example, if you lived on the outskirts of a city, you might set it near the city centre. That way, your house would still be covered, and you'll always be in your "home zone" no matter where you go. Vodafone Germany don't let you do that. With both providers, you can change your address -- for a nominal administrative fee -- up to once a month.

Blaster99

I'm fairly sure the accuracy of LBS is a lot better than 2km's in an urban area, otherwise it's a fairly pointless technology. Perhaps they use cell lock as opposed to LBS or something.

Anyhow, it's a service I've considered obvious in an Irish context for a long time. The mobile companies could, if they had any inclination to innovate, make life really difficult for eircom by making land lines largely obsolete.

watty

Given the cost of line rental and lack of takup on young folk moving to their own accomadtion isn't Eircom making life hard for themselves?

I spend less than 25 Euro a month on my Mobile. I can't think why I still have an Eircom line...

Yes I can, I'm waiting since 2nd NOVEMBER 2005 for porting of the number to my Broadband VOIP supplier.......... I think I'll give up soon.

Urban Weigl

Indeed. For instance, Vodafone could soon leverage their existing network to offer Landline, Mobile and 1.8mbps broadband, all in one package. It could do wonders to their ARPU.

And perhaps they will be shortly. My source in Vodafone tells me that they're already testing a landline-like service with some of their own employees, and that I might want to keep my eyes on vodafone.ie for an announcement in the coming months. I suppose number portability needs to get sorted first, though, so I wouldn't hold my breath just yet.

Sponge Bob

thats a clear breach of the USO Watty, a tart email to Brussels is in order !

probe

Sponge Bob wrote:

thats a clear breach of the USO Watty, a tart email to Brussels is in order !

I don’t believe that the bastard Brussels lot know what an e-mail is.

Best to use a lettre recommandée (registered letter) with “un accus de réception” (proof of delivery letter which comes back from the Belgian postal service (www.post.be) that certifies that they delivered it to the bastard) when communicating with these bureaucrats addressed to the Competition Commissioner at B-1049 Brussels. Be sure to get your “tampon” out (rubber stamp) and stamp it over your signature (signatures without a valid rubber stamp are often considered invalid in the bureaucratic EU and your letter is liable to be shredded without reading). Best to include a copy of your passport too, stamped, signed and dated by your local notaire (notary) to certify that it is a true copy which should be issued within seven days prior to posting.

Don’t forget to get out the sealing wax in front of the notaire to put your seal on the envelope (obtaining a written certificate of sealing) so the recipient will have difficulty claiming that the envelope was empty when he opened it!

probe

Sponge Bob

Un Notaire ????, le salop coute trop

probe

Sponge Bob wrote:

Un Notaire ????, le salop coute trop

Send the notaire's bill to Smart Telecom - I'm sure they'll be happy to pay!

probe

gerryo

watty wrote:

...I'm waiting since 2nd NOVEMBER 2005 for porting of the number to my Broadband VOIP supplier.......... I think I'll give up soon.

I was considering this step also, I assume you can't stop paying line rental while the port is in progress. Will I be wasting my time + € waiting for the number to be "released" to the new provider?

Am I being cynical in thinking applications to have numbers ported are being routinely stalled, the longer the process drags out the more € the existing supplier gets, & maybe (just maybe) customers will give up & keep on paying the rental (because that's the real € spinner).

Sounds like it might be cheaper to cancel the rental & get a new number.

probe

gerryo wrote:

Am I being cynical in thinking applications to have numbers ported are being routinely stalled, the longer the process drags out the more € the existing supplier gets, & maybe (just maybe) customers will give up & keep on paying the rental (because that's the real € spinner).

No (you are not being cynical). Porting should happen instantly and should ideally be a self-service web based option for the consumer to do whenever they want to move their business. Porting is little more than updating some tables in a database - i.e. similar to a call diversion which one can do from virtually any telephone in real time.

Sounds like it might be cheaper to cancel the rental & get a new number.

Then they will grab some more money from you under Section 1 Part 1 of their government approved money making racket
http://www.eircom.ie/About/Activities/sn1_pt1.pdf

probe

gerryo

probe wrote:

...Porting should happen instantly and should ideally be a self-service web based option for the consumer to do whenever they want to move their business. Porting is little more than updating some tables in a database - i.e. similar to a call diversion which one can do from virtually any telephone in real time.

probe

I know how easy it is to do, in real terms, it's probably all in SW.
However, routing to another suppliers gateway should be just as easy.

probe wrote:

...
Then they will grab some more money from you under Section 1 Part 1 of their government approved money making racket
http://www.eircom.ie/About/Activities/sn1_pt1.pdf

probe

That is a very unclear document.

Are you saying I have to pay to have my line removed?
Suppose I just terminate the rental agreement, leaving the wires in place, do I still have to pay?

This seems to fly in the face of portability, how come it's so easy (relatively) for mobile switching, yet so awkward & costly, I hear it costs €50 to have your number ported to non Eircom suppliers.

Some might waive the fee if they really want your business, however, €50 to transfer a phone number is a bit much just for some admin + routing changes.

Blaster99

Because eircom likes to make things unnecessarily complicated. The porting process is apparently a complete bitch to deal with so €50 is probably a fair charge. Some charge nothing, though.

probe

gerryo wrote:

That is a very unclear document.

Are you saying I have to pay to have my line removed?
Suppose I just terminate the rental agreement, leaving the wires in place, do I still have to pay?
.......

Some might waive the fee if they really want your business, however, €50 to transfer a phone number is a bit much just for some admin + routing changes.

I agree – it is as unclear. Unclear and confusing as your average Irish road signpost.

If one undergoes “Removal of Exchange Lines” one would assume that the lines are removed (as in any bit of wire running from the eircom system into your premises is removed – ie physically taken away). Sounds like an exercise for a dentist and probably just as painful… (eg you have a nice new house and you don’t want an ugly eircom cable running across the garden into it – you dump eircom and they charge you a removal fee to take it away).

But then one reads three lines down under the “removal” heading “(where linework is completely in-situ after ceasing)”. How can one have “linework … completely in-situ” when it has been “removed” I ask myself?

Then we go to the notes to maxxxxx up the confusion…:

(5) What is the relevance of a “spread payment facility” for “PSTN connection fees” in the context of a removal of the line in the context they present same?

(7) Surely if you are having a line “removed” from a premises matters relating to installation fees is irrelevant.

Where did these idiots go to school please? Not dissimilar to the pending price list which has references to legislation which was repealed by Le Dáil several years ago! Why does ComReg permit such rubbish to be published to get eircom out of the obligation to publish a price list?

Is it too much to expect clear English and clear logic in these pricing documents?

The main reason I pointed out this sick document to you was the issue of installation charges if you planned to cancel your existing subscription and get a new line. And if they decide to use the same pair you may find yourself disconnected for an unknown period after they “cancel” line A and prior to installing line B. So you should not dump the old line until you have a new line working with a dial tone and BB running on it. During which you will be paying a double subscription for the two lines. But eircom is a good, well run, charitable cause so you probably won’t be worried about this.

The opportunities for screwing your life up if you even smell as if you are defecting to a “competitor” are many.

You are better off staying with eircom and paying their monopoly prices to ensure continuity of service and avoiding all these porting anxieties in my view.

probe

lucernarian

probe wrote:

You are better off staying with eircom and paying their monopoly prices to ensure continuity of service and avoiding all these porting anxieties in my view.

And that's why eircom do it all, or not do, as the case may be...

gerryo

probe wrote:

..The opportunities for screwing your life up if you even smell as if you are defecting to a “competitor” are many.

You are better off staying with eircom and paying their monopoly prices to ensure continuity of service and avoiding all these porting anxieties in my view.

probe

Well, If I go, I go for good, I really don't see the point of paying rental anymore for a line that's sub standard, I doubt I'll be looking for another just like it.

I only really use it for Internet access, Eircom never made much money on it, the rental was all they had, really.

If I got VoIP working, I'd be happy with that. besides, I lived with a mobile for long enough before they connected me up, It's not really a hardship thesedays.

Getting a new landline number would not be a big deal either, I'm not particularly attached to the one I have right now.