ComReg: FIA is 28.8k

damien

http://www.comreg.ie/whats_new/default.asp?ctype=5&nid=101969

On functional Internet access, ComReg is proposing guidelines for meeting a required minimum data rate of 28.8 kbit/s for functional narrowband Internet access. It is expected that the telephone lines for all end users who wish to have internet access will meet this minimum standard. Where this is not the case, ComReg will expect that eircom will use all reasonable efforts to rectify the situation.

Sponge Bob

Well Holy God Miley. !

That IS such an improvement .

damien

The IOFFL Committee are going to examine the 24 page consultation in a lot of detail before we make any formal comment on this. We'd welcome everyone else's opinion on this though.

damien

Functional Internet Access

• Requirement for eircom to adopt 28.8kbit/s as a reasonable minimum data rate for functional Internet access;

• eircom will be required to take full account of ComReg guidelines when planning network build, providing individual connections to the network and when responding to requests to address service quality including:

(i) meeting targets for the minimum number of telephone lines capable of meeting or exceeding the reasonable minimum data rate of 28.8kbits/s;
(ii) facilitating users who have legitimate doubts about the data capability of their telephone line and to establish procedures to diagnose individual lines, and
(iii) Where a user’s telephone line is not capable of achieving the specified data rate, eircom to use all reasonable endeavours to ensure compliance.

Request for connections:

• eircom will be required to consider all requests for connections as “reasonable” if the expenditure involved in meeting the request is less than a certain threshold. ComReg proposes that this threshold be €7,000;

• All such requests should be met within defined timescales and involve no more than a standard connection charge (currently €121.93 VAT inclusive);

• Requests for connections which involve expenditure by eircom in excess of €7,000 to be considered reasonable if applicant agrees to pay standard connection charge plus incremental costs above €7,000;

• eircom will be required to take full account of ComReg guidelines when dealing with requests for connections including:
(i) provision of information to applicants in respect of requests for connection, and
(ii)the publication of supply times and the setting of performance targets
for meeting reasonable requests.

• eircom will also be required, under Regulation 10 of the Universal Service Regulations, to publish information on its performance in meeting requests for connection.

Sponge Bob

I'm somewhat concerned at the bit where Comreg reckon that 93% of ALL Lines in Ireland can currently support 28.8k minimum . Even if that were a % of all analogue lines, 1.6 Million, Comreg are in effect saying that only 112,000 lines are so substandard that they even cannot support a continous 28.8k connection with no drops .

Comreg are then allowing Eircom to stretch the improvement progam for those 112,000 lines out so that 8000 get done every half year and 16000 a year , meaning that getting the whole network up to FIA 28.8k speed minimum will take until 2012 , this in a USO !

I tend to the opinion that 30% of lines nationally are either substandard or grossly substandard . That would be in around 480,000 lines nationally and it will take until 2034 to bring them up to a standard, v34 , formulated in 1994 if the 'upgrade ' program follows Comregs leisurely path.

Nevertheless it is nice to see Comreg address many of the issues put to them exactly 2 years ago by IoffL, however belatedly, and the FIA consultation is indeed worthy of very careful consideration before any submissions go in.

damien

4.5 Impact of proposals on applicants

Based on information provided by eircom on the cost range of applications for 2003, ComReg estimates that somewhere in the region of 0.13% of the total number of applications received for service, would exceed the proposed threshold of €7,000.

4.6 Impact of proposals on eircom

Based on information provided by eircom, ComReg does not believe that the proposed threshold of €7,000 would have a significant effect on the net cost to eircom of meeting the USO requirements. A regulatory impact assessment will be conducted as part of the final decision making process. Please refer to Section 10.

dahamsta

Should be 36.6, and I'm guessing IrelandOffline will suggest that if not higher, but 28.8 is an improvement on... what is it Muck?

However I can't see Eircom taking it lying down, I think they'll battle it with more vigour than the LLU stuff. Not least because a concentrated campaign by an evil lobby group that may or may not exist could cost them serious wodges of dough. Not that I'm trying to put ideas in people's heads or anything, I'm just not that kind of person.

adam

cgarvey

This is indeed good news.. I know there are a lot of people who feel 28K8 isn't enough, but if you can get on and stay on at that speed, I do think it's functional.. you can barely SSH and you can send/receive email (that doesn't have 13MB pr0n attachments). We'd all like BB as a minimum, but we do have to be realistic.. and I know a hell of a lot of people who can only get ~12K, so 28K8 is a big improvement.

That's the theory.

In practice, I think eircom are just going to turn around to those people, who must be rural in the majority, and say sorry, but we'd have to replace the entire line back to the exchange, or have to replace the exchange loop, which will cost more than 7K, so therefore we're not going to do it. "We're not required to do it".. but at least it should force them to look at the individual lines, rather than a blanket "no can do, we're not required to".

So, in theory, I think this is great news, but I'm sceptical on the practical implementation of the theory, and how well (if at all) it's going to be enforced.

.cg

damien

Hmmm

However, ComReg believes that eircom should publicly report on the numbers of lines which do not support the target data rate. As with the data rate itself, ComReg considers that there should be a general target set which eircom should strive to meet.

End June 2005 93.0%
End Dec 2005 93.5%
End June 2006 94.0%

ComReg believes that where carrier systems are inhibiting line capabilities, such devices should be removed. While eircom has indicated that 64 Kb Carriers can support a reasonable minimum data rate of 28.8kbit/s, ComReg believes that the continued use of carrier systems should be avoided in order to avoid potential problems in the roll out of broadband. Their future use should only be contemplated in a limited number of cases and only after a full evaluation of the future potential of the line capability.

Where the capability of the line at the network connection point is found to be below the FIA target rate, ComReg considers that it is reasonable to expect eircom to use all reasonable endeavours to remedy the situation including the removal of carrier systems equipment. ComReg would expect that such a scenario would arise in only a small number of cases as requests in respect of lines which do not meet the target data speed would be low, and a commitment by eircom to address requests would remedy the capability of the line except where there are technical or economic
constraints.

Sponge Bob

It was a stonking 2.4k from March 1999 until July 2003 .

Comreg reduced that speed from 2.4k to 0k from July 2003 until (probably) July 2005 , eg by the time this consultation process is finished.

The 56k modem standard, v90, was finalised in 1996 or 1997 while the 28k modem standard, v34, was finalised in 1994. Comreg intend to ensure that everyone can benefit from early 1990s technology, standardised over 10 years ago, by 2012 .

Progress, Irish style.

cgarvey

Does any country have a 56K USO ?
Could any company viably upgrade the entire (Irish) network in a couple of years to support 56K?

28K sounds like a small number, and it is old technology, but it's a hell of a lot better than what a lot of people I know have (as in 2-3 times better!!). I still say one-step-at-a-time, and set realistic targets, but aggressive ones.

I had hoped that the target percentage would be a lot higher by June '06 though, and I still think eircom are just going to reasonbly point-blank say "no can do, it'll cost too much"
.cg

damien

Anyone think there'll be another trip to the high court ?

cgarvey

Ahh jaysus , surely not!!? They knew it was coming, they don't have to do a whole lot to improve the situation (1% of bad lines over 2 years?), especially with the help of new lines coming on stream.

Yeah, I know what was I thinking .. "yes, I do think there'll be another trip to the High Court", I wonder do they have an eircom bench in the halls?
.cg

Sponge Bob

Nowhere outside a Lab supports 56k, I have seen 53k in the wild though.

28k and the later v34bis 33.6k standards are demonstrably attainable though.

The IoffL USO submission asked for target speeds according to line length, 50k at 1 mile and 40k at 5 miles kinda stuff.

The same submission also asked for impact statements from Eircom if they proposed to mess with your Copper Loop .

Blaster99

Dialup... dialup... dialup... It rings a bell. I can't even remember what kind of speeds I used to get.

I can't imagine dial-up speeds will be worth anyone's while fighting about. The world has kind of moved on. But eircom obviously thinks dial-up is still useful considering they think installing "carrier systems" is alright because it meets the USO. Why Eircom would be so stupid as to install an infrastructure that patently cannot deliver broadband is beyond belief. They should simply be told that all new lines have to be BB capable otherwise the country will just continue on its slippery slope in the BB league tables. Enough of this short-sighted bollocks.

jwt

BB and Dial up are not mutually exclusive. If your line will carry at least 28.8K analogue then its odds-on to carry BB (at least in other countries where the telco adopts a suck it and see approach s opposed to ours where an arbitrary limit is imposed)

So adopting a 28.8 limit enables a lot more people to gain access to BB whereas before they wouldn't.

Also, a lot of people will first dabble with the internet and email using dial up, and if there first experience is made more positive because they are able to download at least at 4k a sec then surely they are more likey to appreciate the benefits of being online.

Lastly, it forces the owner of the copper to maintain it to a reasonable standard, remove old splitters, fix noisy lines (important even for voice calls )and generally provide a better quality service.

John

bminish

Sponge Bob wrote:

I tend to the opinion that 30% of lines nationally are either substandard or grossly substandard . That would be in around 480,000 lines nationally and it will take until 2034 to bring them up to a standard, v34 , formulated in 1994 if the 'upgrade ' program follows Comregs leisurely path.

In cases where customers have Lines that do not meet the new USO of 28k8 perhaps they should be entitled to a 50% reduction on line rental until such time as the line is improved.

Perhaps pairgained customers should also be entitled to a similar rental discount?

google dug this link up.
http://whirlpool.net.au/article.cfm?id=989&show=replies

.Brendan

SkepticOne

damien.m wrote:

Anyone think there'll be another trip to the high court ?

No. They would only do that if the 28.8 recommendation was binding. As it stands, there's plenty of ways around it. Almost everything in the document allows Eircom to continue exactly as they are. I don't see anywhere where it is stated that the consumer has a right to 28.8 low as it is and that Eircom are obliged to provide it.

Capt'n Midnight

cgarvey wrote:

Does any country have a 56K USO ?
Could any company viably upgrade the entire (Irish) network in a couple of years to support 56K? ...
28K sounds like a small number, and it is old technology,

56K is produced by a 64K digital line , you always loose something in the digital to analog conversion and noise on the line.
Next 56K is the download speed, upload is only about half of this because you are going in the opposite direction analog to digital.

28K is symmetrical - up or down is the same and less fancy tricks are needed than for 33.6 or 56K. Rock Solid 28.8K with no upstream bottlenecks or overcontention would be ok in remote areas if it were truly flat rate. ( 70 users on a 128Kb Leased line with large attachments )

ISDN is an alternative that dates back to the 70's
ISDN means most people could already have had 128Kb with the always on of about 9KB on the 16KB back channel.. http://www.calcuttatelephones.com/isdnfaq.shtml

Q 1 : Does ISDN connection require any special cable to be laid ?
Ans : No. ISDN line works on the same copper cable up to a distance of 5 Km (approx.) from the
Exchange/RSU. However, ISDN lines cannot be extended over longer distances as of now.

http://www.jet.net/isdn/isdnintro.html

. But even if ISDN achieves its goal of 95% deployment by the end of 1995,

- this is where we should have been a decade ago.

eircomtribunal

We now know that ComReg asked Eircom to write the (scam called) vulnerable user scheme, which enabled the company to hike the line rental. This USO is co-written by Eircom. No need to go to court over this.
It has get out clauses all over.
The target dates are ridiculous.
The language alone is telling: carrier systems should be "avoided".
"Their future use should only be contemplated in a limited number of cases and only after a full evaluation of the future potential of the line capability."
"...except where there are technical or economic
constraints."

And don't think the €7000 thresh-hold is as reasonable a it sounds at first glance. My neighbouring farmer wanted Eircom to slightly reposition three telephone poles (on a real old and vertically challenged rural make-shifty line), to the side of a field: he got a quotation for several thousand euros (I've seen it myself).
P.

damien

SkepticOne wrote:

Almost everything in the document allows Eircom to continue exactly as they are. I don't see anywhere where it is stated that the consumer has a right to 28.8 low as it is and that Eircom are obliged to provide it.

This is where the alarm bells start going off:

http://www.rte.ie/business/2005/0304/comreg.html

Speaking tonight on RTE radio Eircom's commercial director David McRedmond welcomed ComReg's consultation as he thinks it is the correct way to do regulation, with everyone contributing to the debate.

He said that if is an universal service obligation then telecoms should be designated as an essential service.

mike65

from electric news

On the surface, lobby group IrelandOffline has welcomed the ComReg announcement. "IrelandOffline welcomes ComReg finally recognising the importance of a minimum data rate after the many years of our campaigning for one. We're still examining this current consultation but any directions which will improve the quality of a customers line and increase their chance of getting broadband will be met with positive feedback," Damien Mulley, chairman of IrelandOffline told ElectricNews.Net.

Mike.

De Rebel

Mediocrity
Mediocrity
Mediocrity
Mediocrity
Mediocrity
Mediocrity
Mediocrity
Mediocrity
Mediocrity
Mediocrity
Mediocrity
Mediocrity

eircomtribunal

"He said that if it is an universal service obligation then telecoms should be designated as an essential service."

Why is Eircom so keen for USO-Telcos to be designated as an essential service? McRedmond is on about it since a while. What is in it for the company?
P.

bminish

eircomtribunal wrote:

"He said that if it is an universal service obligation then telecoms should be designated as an essential service."

Why is Eircom so keen for USO-Telcos to be designated as an essential service? McRedmond is on about it since a while. What is in it for the company?
P.

Money (I.e Subsidy's & grant aid for infrastructural improvements / expansion) along with added political clout.

Perhaps they would also then push for onerous conditions that other telcos would have to meet to offer service.

.Brendan

d-j-k

In many other countries 9600bps is all that the telcos have to support as this is fast enough for group 3 fax. I've had plenty of problems getting phonelines in other countries to support 56K modems, and that includes downtown Boston, USA.

It must be remembered that the telephone network pre-dates high speed modems by quite a bit. Most of the digital technology that's in use was developed in the 1960s, 70s and early 80s and was designed to carry voice traffic only.

Pairgain devices that date from the 1980s (which are in use by eircom) basically multiplex a number of voice lines and send them down a single copper pair. They sound perfectly acceptable for voice calls but will mangle high speed modem data due to the way the pairgain device samples the signals on the line.

Unfortunately, it seems that eircom are using pairgain as part of normal practice rather than as a last resort.

BT had similar issues a few years back where loads of lines were being provided using a pairgain technology known as DACS, the older versions of which crippled modems.

28.8kbps is a pretty reasonable speed and should also mean that the line might have more chance of passing tests for ADSL.

Btw: 56K modems don't generally connect anywhere near 56K on any phoneline anywhere in the world connections in the 30-48K band are more likely.

Also it's worth noting that US specified modems will not perform as well on a European telephone line as they will in the states. This is not due to a poor quality line, it's due to a difference in the audio codec (coding/decoding) used by switches here. 56K modems are tweaked to deal with Mu-log (US codec) or A-Log (European codec). A European modem will work fine in the US and a US modem will work fine in Europe, but they won't be as efficient outside of their home market.

I suspect that quite a few modems that made it to the Irish market are actually US spec rather than European simply because we use the US RJ11 connector system.

One final tip regarding modem speed in Ireland:

If you have a relatively recent eircom line installation you should have a white network termination unit (NTU) box as the first socket. This is a white phone socket with an eircom / telecom eireann logo and 2 screws on the front (the old style one is beige and has a single screw at the centre). This system allows you to eliminate any internal wiring faults within your home when you're testing your line.

All of your internal wiring is connected to the front plate of the socket. To test the line itself, remove the two screws and the plate will slip out. You will find another RJ11 socket behind the plate. Plug your phone or modem in here and you will be directly testing the exchange line.

If you're waiting for an ADSL test / have failed an ADSL test it might be worth doing this and plugging your phone directly into this outlet for a while as it will eliminate any internal wiring faults.

(If you have the older style beige sockets you'll need to trace the wiring back to a small square or "soap bar" shaped junction box where it enters your home. This could be in the hallway, in the attic etc... Try disconnecting everything from this and running a clean new CAT5 cable from this point to your first phone socket it can produce dramatic improvements)

Finally, there was a spate of aluminum cable used in the irish telephone system. Apparently this wreaks havoc with DSL. Check your home for grey and white twisted pair telephone cable or old (1960s/70s) twisted pair cables that have been painted over.

Any old cabling like this should, ideally, be replaced with CAT5.

lucernarian

Would CW1311 cable not suffice for connecting phone sockets? Cat5 cable is a bit heavy handed isnt it? Anyway, CW1311 is the kind of cable that was used by TÉ and Eircom for the last 10 or so years and it's twisted pair.

Regarding the setting of FIA, I'm pretty happy but I'm worried about what Comreg had to say about pairgains. Economic and "technical" get-out clauses. There is no such thing as a technical issue when it comes to v34. Every single phone line can handle it with enough investment. Many of the areas that have pairgains in use are far from exchanges, where the cost of supplying more pairs, unfortunately, will be very high. This is probably because of the fact that its very hard to lay a few miles of cable through existing ducting.

d-j-k

Well, there's no harm in running CAT5 a few extra pairs won't hurt you can always ditch the phone connections and move to ethernet as time goes on. CAT5's also cheap and easy to pick up on the web.

MadsL

CAT5's also cheap and easy to pick up on the web.

Even cheaper and easier to pick up out of a skip, there must be several kms of CAT5/CAT6 cable thrown away in Dublin every week....

damien

So back on topic. Opinions on the USO and FIA.

AndrewMc

damien.m wrote:

So back on topic. Opinions on the USO and FIA.

Quick notes, that I hope to get time to flesh out and submit properly.

Q.1. Do you agree with the considerations which ComReg has outlined
regarding the setting of a threshold? Please state why. If you disagree please
give reasons. If there are any other considerations which should be taken into
account by ComReg in setting a threshold, please provide your reasoning.

Agree that "consumer interest" is far more important than Eircom's costs. However, are we the least-densely populated country, or so unique in our dispersal that this is justified?

(Note - anybody have details on how other countries charge for installation based on geographical remoteness? Or how the ESB charges?)

Q.2. Do you consider that in order to provision a connection to the eircom
network a €7,000 threshold is reasonable in the context of the Universal Service
Obligation regarding the provision of access at a fixed location? If you
disagree, please propose an alternative along with your reasoning.

Setting any such threshold immediately counteracts the whole point. Anybody remote who's not rich enough can't get a phone line, which is the opposite of "universal access".

Secondly, no monopolistic commercial entity should be trusted on setting price, ever. This is even more critical on a service people don't really think of as optional. Having no such cost threshold, but certain standards, encourages efficient, forward-looking, sensible implementation. If a company doesn't want to do something the easiest way to make the consumer go away is to set a price it knows the consumer cannot bear.

Q.3. Do you agree with measurement of the connection costs as proposed by
ComReg? Please specify any alternative measurement and outline your
reasoning.

I disagree with measurement of connection costs entirely. As well as the reasons in reply to Q3, it adds administrative overhead for everyone.

Q. 4. What are your views regarding the setting of performance targets for
meeting requests for connection.

Performance targets are crucial, especially in an essential service operated by a commercial monopoly. I believe the targets given are too light - the 52 week target, in particular, is far too long, and should be certainly no more than six months.

The force majeure criteria should be explicitly listed to be things such as planning difficulties (due to the council/authorities, not slow/late applications) and acts of God. It should, in particular, not include things such as Eircom claiming they can't get the contractors to do the job. I know from personal experience they can find them if they really want to.

Q. 5. What are your views on information to be provided to the customer;
should these issues be addressed in some other way? If so state what other
options you consider appropriate and your reasons and justifications for them.

• The customer must immediately, or within one working day, be notified if an installation is non-standard. Eircom should be able to make a genuine effort when an application is made to determine if this is the case, and not just guess.
• I agree that customers must be kept regularly informed. However I suggest a certain minimum amount of contact be specified, such as either (a) every four weeks, or (b) any time the delivery date changes. It should never be the case that the customer discovers the delivery date has changed due to a customer-initiated enquiry. Chasing up a company every few weeks for a year is ridiculous.
• Delivery dates should be realistic.

Basically, the customer should always know what's going on without having to chase up the company. Over-optimistic delivery dates can cost the customer dearly when they decide to forego interim measures (ah, sure, it's only two weeks), or make other decisions on the basis the line will be provided on time.

Q.6. What are your views on a reasonable minimum data rate of 28.8 kbit/s
being set as a minimum target speed?

In modern times such a data rate is very, very low and would be considered by few to be "functional" in terms of actual use. Although current USO requirements do not include broadband, the limit could be considered an opportunity to ensure that lines are kept to a quality that would have a better chance to provide broadband in the future. After all, investment in the network is why our line rental is astronomically high.

Q.7. What are your views regarding non-binding performance targets for the
overall network in respect of minimum data rates?

Non-binding targets are useless in a market operated by a commercial monopoly. If the network is in a poor state, that is as a result of low investment (less than depreciation) by the owner of the network. They should not be compensated by giving them extra leeway.

The target line improvement rate is very slow (at 1600000 lines, it's just 60 per working day), although I accept you don't want to give Eircom an excuse to pull back on DSL even more... More useful would be to give priority to customers who complain about line quality, since they obviously need it, with a maximum time for resolution of say 3 weeks.

I agree that Eircom should report, perhaps on a quarterly basis, the total number of lines upgrade, the number of lines about which complaints were received, and the time taken to resolve those complaints.

Q.8. What are your views on the use of Carrier Systems Equipment? Should
their future use be limited in the interest of DSL deployment? What should the
position be where limiting new deployment might result in an applicant for
service having to pay excess charges or in delaying the provision of a telephone line?

I agree carrier use should be discontinued for the good of broadband in the future. Carriers could be used only in extreme cases, and only with the consent of the customer on the understanding that it limits data throughput. If the customer does not agree, they should not be used, and the operator should be prepared to remove them if the customer subsequently requests broadband.

Q.9. What are your views on the guidelines to apply in connection with
functional Internet access? Are there other issues which should be specifically
addressed by the guidelines?

Partially answered before. Note that Eircom's system for testing line quality should allow for the fact that failures can be intermittent. Intermittent failure is not "functional". A phone line that gives poor quality on a breezy day might test as clear on a calm day.

damien

This is the IrelandOffline 2003 USO Submission. There's some good stuff about datarates in that if anyone wants to look at it.

Sponge Bob

AndrewMc wrote:

I agree that Eircom should report, perhaps on a quarterly basis, the total number of lines upgrade, the number of lines about which complaints were received, and the time taken to resolve those complaints.

Careful about the wording Andrew. A fault is NOT a fault until Eircom log it which they will refuse to do as long as you can ring them from that line .

Remember poor oul Kevin Myers and especially the Farming Independent story below.

http://www.boards.ie/vbulletin/showthread.php?t=210345

That guy only logged a fault on the 5th attempt . The other 4 fault reports were not logged as faults at all .

Then theres the issue of a fault near a depot with 20 engineers in it and a fault 30 miles away with one engineer covering the area and yer man maybe 50 and getting arthritic. Should we expect the same clearup rate ?

It is partially Because of unrealistic Comreg Install and Repair timing targets, easily achieved where the staff is available, that the copper in rural areas is so rank. Nothing excuses waiting a year for a line though, on that I agree with them. However In at least 100 exchange areas around the country the failure rate for DSL exceeds 75% of lines . In some 30 exchange areas 100% of lines fail .

I am old enought to remember the 6 and 7 year waits for a line . These disappeared by 1985 or 1986 but the 2 and 3 year wait have become quite the post millenial fashion accesory and dinner table topic .

shoegirl

Sponge Bob wrote:

I am old enought to remember the 6 and 7 year waits for a line . These disappeared by 1985 or 1986 but the 2 and 3 year wait have become quite the post millenial fashion accesory and dinner table topic .

I can beat that. I called CMI (now part of Chorus) to ask about their upcoming cable internet service in 1997. They said it wasn't ready yet, but gave me free dialup access for a year. A year later I called again and they said it was still in the pipeline.

8 years later I am still waiting . . .

viking

Found some interesting quotes in my regular read of parts of eircom's (28th July 2004) SEC filing... read it through:

"Under European Union directives that have been implemented into Irish law, ComReg is required to promote the availability of specified telephony services to all users in Ireland, regardless of their geographical position, at an affordable price. We are the only telecommunications provider in Ireland obligated to provide these services, known as universal service obligations ("USO"), and we are required to do so whether or not the price at which we must provide them generates profits for us. Our USO require us to provide basic voice services, standard fax and low-speed data services and reasonable access to public pay phones and directory enquiry services as well as services adapted for disabled users. In addition USO services are required to be provided at geographically averaged prices throughout Ireland.

We are not reimbursed for any of the cost of providing these services. There is a statutory provision that permits ComReg to establish a fund that would allow us to recover part of the costs of meeting our USO if ComReg determines that the net cost of meeting our USO is an unfair burden on us. We intend to seek the establishment of such a fund in the current year. However, if such a fund is not established and if the losses we incur from satisfying our USO increase, our operating profit will be negatively impacted.

....

Our obligations have been extended to include service to people with disabilities and to provide geographically averaged prices throughout Ireland, which has always been the practice. Previously, we provided these services on a voluntary basis.

[and again they mention the "fund"]
There is a statutory provision that permits ComReg to establish a fund that would allow us to recover part of the costs of meeting our USO, if ComReg determines that the net cost of meeting our USO is an unfair burden on us. We intend to seek the establishment of such a fund in the current year on foot of a detailed and independent study of our net Universal Service Obligation costs."

Why has there been no mention of the fund from ComReg?
Who puts the money into this fund?
Why have ComReg proposed to allow eircom recoup the cost of basic service provision from the user when install costs go over 7k rather than using this "fund"?

Gareth

damien

I believe that other countries use this idea of a fund, so they're just copying that. I don't recall in any of the FOI docs we got on FIA any mention of a fund, but then ComReg pretty much send us blank sheets as everything was deemed commercially sensitive. *Reads more of his book on regulation*

damien

Ofcom had a recent USO consultation too. You can read it and all the replies here:

http://www.ofcom.org.uk/consult/condocs/uso/

The site is so easy to navigate and find the information you require.

The Wales Broadband Stakeholders Group sent in a one page submission. This is how they plainly put it:

Our submission is therefore very simple: put broadband and mobile access into the USO now, and move the Obligation back into HMG to support regulatory and selective measures to encourage competitive, Universal Broadband Access for all.

Mossy Monk

so should i expect to see double the speed then. currently it is 14.4k

w00t times a million :rolleyes:

damien

We're just polishing off our submission now. Deadline is tomorrow at 4pm. Meanwhile we sent this out to the members today to ecnourage more submissions to ComReg.

ComReg currently has a consultation in progress relating to the Universal Services Obligation (USO) document. The USO defines a bare minimum of services which eircom are required to provide to everyone across country.

The consultations generally get answered by large companies and ComReg rarely hear from the consumer, apart from the IrelandOffline submissions. We would greatly urge you to email in your thoughts about the USO to ComReg. The email address is: marketoperationsconsult@comreg.ie and comments must be in by Wednesday April 6th at 4pm.

Below is a detailed summary of what IrelandOffline is submitting, but a very very short summary of what we are submitting is that :

Universal is Universal and cannot be 93% or 94% of people getting Universal service and the rest going without. Everyone and not a chosen few should be entitled to a line capable of proper dialup speeds and being able to carry broadband too. Irish consumers pay the highest line rental in Europe, some €8 per month more than the EU average and paying this entitles everyone to having a proper universal service that will give them a line capable of carrying broadband.


USO Consultation Summary:

At the moment Universal Service basically consists of a phone line capable of providing a basic voice service for phone calls. There are a number of changes suggested in the current consultation which are of interest to both the general consumer and specifically internet users.

ComReg are proposing to introduce a "functional internet access" minimum data rate of 28.8kbit/sec for all telephone lines. As we are sure you will agree, this is a less than stellar minimum requirement for internet access. In our official submission, we will be suggesting a range of minimum requirements based on the length (and, therefore, the capability) of the telephone line starting at 48kbit for lines with a length of less than 1km, working down to a minimum of 33.6kbit for lines longer than 5km from the exchange. We realise that dialup internet itself seems like an outdated technology, but getting a decent minimum data rate defined will have benefits for broadband internet access as well. A "clean" telephone line which is maintained to meet basic dialup standards will be far more likely to be of sufficient quality to provide broadband services as and when they become available in your area.

ComReg further smudged the issue of functional internet access by not requiring that this be provided universally. They have instead set targets for eircom to reach, so that by June of next year only 94% of lines will even meet the paltry minimum data rate of 28.8kbit. This is unacceptable, as these should be minimum services that everyone in the country should be able to avail of.

ComReg have also brought up the use of the infamous "carrier systems", otherwise known as DACS boxes or line splitters. These are devices which are attached to lines by eircom which split one telephone line into two more separate lines, so that they don't have to bring a new line from the exchange to each customer. These work ok for voice traffic, but they seriously impact on analog modem connection rates and rule out ever being able to get broadband on your phone line. ComReg have rightfully decided that the use of these devices should be avoided.

IrelandOffline will be making their official submission to all of the issues raised in the consultation, but we would urge everyone to send in their own thoughts and comments on the above to ComReg as well. A five page detailed essay is by no means essential and all comments on the issues no matter how short will be important. To submit a comment, send an email to marketoperationsconsult@comreg.ie with it clearly marked as "Reference: Submission re ComReg 05/17" no later than 4pm tomorrow (Wednesday April 6th).

damien

and of course the email address is busted.

Lots of people getting bounces.

damien

Email address is now working again. It was allegedly working before lunch.

Sponge Bob

Hear No Evil :eek: !!

damien

Final few hours now folks.

AndrewMc

Quick query about the "threshold" before I send mine off. Personally I think the threshold idea is a disaster (and I'm saying so, too), but I found what seems to be a contradiction in the ComReg document between point 4.4:

"the proposed threshold would apply only to the costs associated with connecting an individual customer to the eircom network using infrastructure that is not used, now or in the future, for the provision of service to other customers."

and point 4.7:

"Where agreement is reached between eircom and the customer on the total cost to eircom for the provision of access, installation should be provided at the standard connection charge, plus the incremental amount over and above the defined threshold figure. Where the consumer agrees to meet such charges, a timeframe for installation should be agreed with the consumer. Alternatively, if the consumer wishes to wait until network expansion occurs in their area he or she should be provided with a record/reference number for their order and an indication as to when service will be provided in the future."

If the threshold doesn't apply to infrastructure to be used "now or in the future" for other customers, why would they want to "wait until network expansion occurs in their area"? Shouldn't the costs be the same in either case?

damien

This is IrelandOffline's reply. We are very grateful to Mike Meegan and SpongeBob for helping out on this.

Q.1. Do you agree with the considerations which ComReg has outlined regarding the setting of a threshold? Please state why. If you disagree please give reasons. If there are any other considerations which should be taken into account by ComReg in setting a threshold, please provide your reasoning.

Since we don't have access to the "confidential" information provided to ComReg by Eircom we are not in a position to determine whether the setting of a threshold is reasonable. ComReg says that the threshold amount should be set to impact on relatively few cases. This figure is estimated at 0.13% of applications.

Our concern is that what is "relatively few" in theory will turn into quite a large number in practice as it something that can be easily exploited by the USP.

We do not agree with a threshold when eircom makes so much from installations of land lines and the income from the ComReg sanctioned highest line rental in the EU. A threshold is not necessary. All installations should have the same basic charge.

Q.2. Do you consider that in order to provision a connection to the eircom network a €7,000 threshold is reasonable in the context of the Universal Service Obligation regarding the provision of access at a fixed location? If you disagree, please propose an alternative along with your reasoning.

Again without access to the costing model that eircom has created, a proper answer cannot be given. It is a disservice for respondents to have to make guesses instead of informed opinions. The individual consumer is in no position to argue with the USP when the regulator will allow it to keep its costing model secret under the "confidential" excuse. A customer has the right to know how they are charged.

As we stated in answer to Question 1: We do not agree with a threshold when eircom makes so much from installations of landlines and the income from the ComReg sanctioned highest line rental in the EU. A threshold is not necessary. All installations should have the same basic charge.

Q.3. Do you agree with measurement of the connection costs as proposed by ComReg? Please specify any alternative measurement and outline your reasoning.

Yes, costs taken into consideration should only be those associated with the individual customer and costs associated with the USP's normal network build out should not be taken into consideration. We would question whether this is possible in practice however.

We agree that costs should be based on the the least cost technology regardless of what the USP uses in practice.

We note, however, that if a fixed connection fee were to apply to all customers, it would be in the interest of the USP to build out the network in an efficient manner and use the best technology available to do the job.

Considerations of thresholds, varying connection fees, technologies and networks put the consumer at a disadvantage since the consumer does not have access to the appropriate information. Only the provider has this. The consumer is now totally dependent on the regulator who is in turn dependent on the provider for the information. This is not a desirable position for the consumer.

A Universal Service Obligation should mean that the customer should not need to know these things but rather that the burden is placed on the provider. A certain level of provision for a particular price should be available to everyone.

What appears to be proposed is that if the USP's estimate of costs exceed the threshold of 7,000 euros, that the consumer either pays the amount over this threshold or has the option to wait for network expansion. We believe this is likely to be exploited by the USP who may hold back on network expansion in order to maximize individual fees. What constitutes network expansion is not properly defined and this too may be exploited. Overall, we believe that the measures being proposed here represent a strong disincentive for the USP to build out its network in an efficient way.

Q. 4. What are your views regarding the setting of performance targets for meeting requests for connection.

A maximum time frame for meeting connection orders should be set for the USP. That 5% according to the table supplied are met after a wait between 26 weeks and 1 year is unacceptable. There will always be circumstances where the USP wishes to delay a particular order but this is precisely why specific time frames need to be applied and these need to be mandatory. Failure to make such a timescale mandatory opens the door to exploitation and discourages the building of a network from which orders can be met in a timely manner.

To encourage meeting timescales, the USP should be subject to fines if they do not meet the timescales.

Q. 5. What are your views on information to be provided to the customer; should these issues be addressed in some other way? If so state what other options you consider appropriate and your reasons and justifications for them.

Customers need to be informed in writing of the progress of their installation. This means monthly updates if necessary. The USP should also make available on its website on a quarterly basis the number of orders fulfilled within 2 weeks, 1 month, 3 months and 6 months.

Q.6. What are your views on a reasonable minimum data rate of 28.8 kbit/s being set as a minimum target speed?

IrelandOffline welcomes the fact that ComReg have finally decided to tackle the issue of Functional Internet Access which IrelandOffline has been pushing since ComReg failed to define it in the previous 2003 USO. We wish to make it clear that as a result of this lack of foresight, a large number of consumers are being told they are not entitled to data connections on their line. IrelandOffline wants this current USO to make up for lost time and give hope to the 1000s of disappointed consumers that are still suffering.

28.8k is not good enough anymore. IrelandOffline would like to see the quality of lines measured using Signal to Noise ratios. IrelandOffline believes all lines must be above 30db SNR. This should be verifiable with a proof of performance test. IrelandOffline also believe that this minimum measurement be mandatory and not a "suggested" minimum. Proper cabling must be run to consumers and ancient cabling must be replaced, without a cost to the consumer, to bring the SNR to the correct levels for the distances involved.

If the SNR for a consumer's line is below the minimum as suggested by IrelandOffline we believe that a consumer should be compensated by having to only pay 50% of the standard line rental price until the issues with their line is resolved.

Q.7. What are your views regarding non-binding performance targets for the overall network in respect of minimum data rates?

Non-binding performance targets will be abused just like the lack of definition for FIA was abused for the past 2 years when ComReg made FIA non-existent/ non-binding. Targets need to be clearly defined and need to be binding and need to be enforced with the use of fines.

To facilitate ease of administration, and to ensure the Universal aspect of the Universal Service Obligation is clearly understood by all stakeholders, eircom should have geographic USO completion targets thus:

30/06/06 All Of Dublin and Cork.
30/06/07 All Cities over 30,000 population and all of Leinster.
28/02/08 All of Munster Ulster and Connaught in addition to the above.

The above is in the interests of clarity to all stakeholders and to facilitate ease of administration and regulatory enforcement.

It is spread across 5 financial years and is fully funded by the ComReg sanctioned highest line rental in the EU.

Q.8. What are your views on the use of Carrier Systems Equipment? Should their future use be limited in the interest of DSL deployment? What should the position be where limiting new deployment might result in an applicant for service having to pay excess charges or in delaying the provision of a telephone line?

Modern carrier systems can support DSL. Ancient carrier systems must be retired and quickly. Carrier systems should only be used in emergency cases and when done so, the customer must be informed in writing and supplied with a guaranteed time-frame when this system will be removed. Carrier systems have been used to cut corners and cut costs which is a great disservice to consumers who have no choice but to pay the ComReg sanctioned highest line rental in the EU.

ComReg needs to direct eircom to publicly disclose the number of carriers used on their network. This information is not commercially sensitive and using the "commercially sensitive" excuse is not to be tolerated.

Q.9. What are your views on the guidelines to apply in connection with functional Internet access? Are there other issues which should be specifically addressed by the guidelines?

It must be mandatory that a consumer can request in an easy manner the capability of their line and an escalation process should be in place for the consumers line to be upgraded if it does not meet the minimum standards. The consumer should also be informed when the line will guaranteed to be upgraded. ComReg need to have a procedure in place also in case that the consumer and eircom are in dispute.

damien

This was our introductory text too:

IrelandOffline wishes ComReg to acknowledge that we have serious concerns, on the behalf of Irish consumers, that Comreg are now degrading the concept and value of "Universal Service" by inserting loopholes so that the USP is not obligated to provide basic services to the whole population

by not installing lines at a standard universal price
by not providing lines capable of taking modern dial-up speeds with a universal minimum speed.
by not providing lines that meet verifiable and measurable line characteristics

Based on the USO document, as presented, consumers have no recourse when their lines fail to meet minimum specifications.

It can be interpreted that ComReg has already redefined what Universal is by adding in get-out clauses, loop holes, non-committal and non-enforceable language thus allowing for the USP to choose its own interpretations of the USO.

We also would like to take this opportunity to remind Comreg that this is exactly what occurred with the last USO when the USP was able to tell consumers they " were not entitled to a dialup connection" on their phone lines. We would also like to remind Comreg that the concept of service, i.e. the provision of a service, is what this is all about and minimum and enforceable standards are required for the provisioning of any service.

SkepticOne

A very clear concise subission from IOFFL that is firmly on the consumer's side.

Here's my submission. My appologies to Damien and IOFFL that I didn't collaborate properly with IOFFL on the full submission. Unfortunatly the last month has been very busy for me.

Q.1. DO YOU AGREE WITH THE CONSIDERATIONS WHICH COMREG HAS OUTLINED REGARDING THE SETTING OF A THRESHOLD? PLEASE STATE WHY. IF YOU DISAGREE PLEASE GIVE REASONS. IF THERE ARE ANY OTHER CONSIDERATIONS WHICH SHOULD BE TAKEN INTO ACCOUNT BY COMREG IN SETTING A THRESHOLD, PLEASE PROVIDE YOUR REASONING.

In its introduction, ComReg state that Eircom, the Universal Service Provider is required to satisfy any reasonable request to provide a connection capable of allowing telephones, fax and functional Internet access. The two issues under discussion are what is meant by reasobable in relation to a request for connection and what is meant by functional in relation to Internet access.

ComReg state that, in response to decision notice D17/03, Eircom proposed that reasonable in relation to requests for access should relate to Eircom s own costs in supplying that connection. If the costs estimated by Eircom were above a certain threshold then, in Eircom s opinion, the costs above that threshold should be bourn by the customer making that request. If the costs are below that threshold then, Eircom proposed, that the standard fee of EUR 121.93 would apply.

What is not clear from Eircom s proposals (as reported by ComReg) is whether those requests with costs above the threshold should be considered unreasonable. Under Eircom s Universal Service obligation, Eircom as Universal Service Provider, are required to satisfy any reasonable request to provide at a fixed location connections to the public telephone network.

If the threshold proposal is to be regarded as the determinant of whether or not a request is reasonable , then this means that, based on Eircom s costs, a request is reasonable if it falls below a certain threshold for the cost of provision. If it is reasonable , it is covered by the Eircom s Universal Service obligation as a Universal Service Provider. If, on the other hand, according to this interpretation, Eircom s estimated costs for providing the connection are above this connection, then the request, presumably, is considered by Eircom to be unreasonable and, as such, it would not be covered by Eircom s Universal Service Obligation.

In commenting on this, ComReg states that they believe that in addition to Eircom s threshold proposal consumer interest should also be accorded a high degree of importance. From this, and other unstated factors, ComReg say that they believe, therefore, that the the number of cases where a higher connection charge is payable should be relatively limited although the reasoning is not given. ComReg s comments do not clarify the question of whether the threshold proposals constitute reasonable in relation to requests from users for connection. Do requests whose costs as estimated by Eircom exceed a particular threshold mean that the request is unreasonable?

The setting of such a proposed threshold puts the consumer at risk and goes against the idea of a Universal Service Obligation for the following reasons:

1. The definition of reasonable is not clear. Are connection requests that are estimated to be above the threshold considered unreasonable for the purposes of the USO or are they not?

2. If request above the proposed threshold are to be considered reasonable then some upper limit on how much the customer is going to be charged needs to be set. A Universal Service Obligation should set minimum or worst case standards below which the USP is in breach of its obligations. There is little point in such obligations otherwise.

3. If, on the other hand, requests whose estimated costs for connection are above the threshold are to be deamed unreasonable , then this definition of reasonableness is circular and unacceptable. It is a circular definition because the the estimated cost of connection is related to the USPs current investment in network buildout. Yet, in the normal understanding of a service obligation, meeting such an obligation may require a certain level of investment, hence the circularity.

Q.2. DO YOU CONSIDER THAT IN ORDER TO PROVISION A CONNECTION TO THE EIRCOM NETWORK A EUR 7,000 THRESHOLD IS REASONABLE IN THE CONTEXT OF THE UNIVERSAL SERVICE OBLIGATION REGARDING THE PROVISION OF ACCESS AT A FIXED LOCATION? IF YOU DISAGREE, PLEASE PROPOSE AN ALTERNATIVE ALONG WITH YOUR REASONING.

ComReg say that the since inflation and other factors may influence the amount of infrastructure that can be supplied for a given amount of money that other factors should be taken into account to ensure that the proportion of customers impacting the threshold does not increase. ComReg estimate 0.13% of applications would exceed a threshold if it were set to EUR 7,000.

My objections to the principle of a threshold in answer to Q.1 apply also to the question of the specific figure of EUR 7,000. The definition of reasonable should be unambiguous and not based on the USPs current network.

Q.4. WHAT ARE YOUR VIEWS REGARDING THE SETTING OF PERFORMANCE TARGETS FOR MEETING REQUESTS FOR CONNECTION.

ComReg proposes the following performance targets to be met following receipt by eircom of a request:

60% of requests for service to be met within 4 weeks
80% of requests for service to be met within 8 weeks
90% of requests for service to be met within 13 weeks
95% of requests for service to be met within 26 weeks
100% of requests for service to be met within 52 weeks

The purpose of a Universal Service Obligation should be to specify the worst case that a consumer will have to suffer. From these targets, it would appear that 5% of requests might take up to one year to be met. However, even more worryingly, the 5% figure could potentially apply to any request. From a consumer point of view, the USP is fully within its rights under these proposals to delay the installation of a connection for up to a year. The individual consumer has no rights until this year has passed.

I would also note that the proposed for connection falling within the first eight weeks would appear to be no better than the current situation that the USO should be attempting to remedy.

In discussing reasonable requests for connection, ComReg state in their introduction that a recurring issue of complaint relates to requests for connection that that 18% of requests take over two months to be met. Under the new proposals, 20% of connections can go unmet in the first 8 weeks.

If the idea of a Universal Service Obligation means the USP is required to deliver a basic minimum or worst case standard of service to all consumers, then an upper limit should be placed on the length of time a consumer should have to wait for a request to be met. This should be a lot less than one year as businesses and private consumers cannot be expected to wait this long.

Q.5. WHAT ARE YOUR VIEWS ON INFORMATION TO BE PROVIDED TO THE CUSTOMER; SHOULD THESE ISSUES BE ADDRESSED IN SOME OTHER WAY? IF SO STATE WHAT OTHER OPTIONS YOU CONSIDER APPROPRIATE AND YOUR REASONS AND JUSTIFICATIONS FOR THEM.

The consumer has no interest in Eircom s current network. What the consumer needs to know is how long a connection request is going to take to be met and how much it is going to cost. The consumer is in a very weak bargaining position with the USP and therefore needs to be informed of rights and minimum service levels/maximum costs allowable under the USO. These rights should state clearly:

1. What constitutes a reasonable request under the USO. This definition should not rely on current levels of investment since the consumer has no control over this.
2. The maximum length of time that the USP can spend meeting the request.
3. The maximum amount of money that can be charged.
4. That the line be capable of sustaining Functional Internet Access.

Q.6. WHAT ARE YOUR VIEWS ON A REASONABLE MINIMUM DATA RATE OF 28.8 KBIT/S BEING SET AS A MINIMUM TARGET SPEED?

28.8 kbit/sec was a standard speed in the mid-nineties for dial-up access. It should be set higher than this to account for the richer content on the Internet in 2005 and should be revised annually to take into account international developments in access technology as well as content.

Furthermore, the speed should not be a target but a binding obligation. If it is not, then the consumer has is deprived of a right to a minimum service level in the spirit of a Universal Service Obligation.

Setting the speed higher will encourage more investment in the network and thereby facilitate the rollout of broadband.

SkepticOne

Q.7. WHAT ARE YOUR VIEWS REGARDING NON-BINDING PERFORMANCE TARGETS FOR THE OVERALL NETWORK IN RESPECT OF MINIMUM DATA RATES?

As mentioned in answer to Q.6, non-binding targets are not what the consumer needs. In cases where the speed obtained is below the threshold speed (which should be higher than 28.8kbit/sec), the user should be made aware of their right to have the situation rectified and an upper limit on the time taken to bring the user up to speeds allowing Functional Internet Access should be placed as an obligation on the USP.

Again, this will encourage the USP to invest in the network and thereby facilitate the rollout of broadband.

Q.8. WHAT ARE YOUR VIEWS ON THE USE OF CARRIER SYSTEMS EQUIPMENT? SHOULD THEIR FUTURE USE BE LIMITED IN THE INTEREST OF DSL DEPLOYMENT? WHAT SHOULD THE POSITION BE WHERE LIMITING NEW DEPLOYMENT MIGHT RESULT IN AN APPLICANT FOR SERVICE HAVING TO PAY EXCESS CHARGES OR IN DELAYING THE PROVISION OF A TELEPHONE LINE?

The applicant should not have to pay to recieve something that the consumer is entitled to recieve. As mentioned in the answer to Q.5. Upper limits should be placed as obligations on the USP on the maximum time and the maximum charges meeting requests for lines and these lines should be capable of functional internet access. In Q.7 it is suggested that the minimum line data rate be set at higher than 28.8k. Above this rate a carrier system cannot be used.



Q.9. WHAT ARE YOUR VIEWS ON THE GUIDELINES TO APPLY IN CONNECTION WITH FUNCTIONAL INTERNET ACCESS? ARE THERE OTHER ISSUES WHICH SHOULD BE SPECIFICALLY ADDRESSED BY THE GUIDELINES?

If a user is getting less than a particular data rate over the USP s network then a self-test is reasonable. ComReg should define more clearly what reasonable endeavours means in the context of the steps Eircom should take in meeting its obligations to provide connections capable of sustaining Functional Internet Access.

It has been suggested that upper limits to the time spent rectifying data rate problems should be placed on the USP.

Q.10. WHAT ARE YOUR VIEWS ON THE TEXT OF THE DRAFT REQUIREMENTS AND THE DRAFT GUIDELINES. ARE THERE OTHER ISSUES WHICH SHOULD BE SPECIFICALLY ADDRESSED OR ISSUES WHICH SHOULD BE EXPANDED UPON? PLEASE PROVIDE SUGGESTED ALTERNATIVE TEXT?

The right of a user to certain worst-case or minimum levels of service should be made clear. Upper limits should be placed on how long an individual user should expect to wait for a connection request and how much they should pay. This connection should be capable of sustaining Functional Internet Access and the rate should be set higher than 28.8k to take into account technological developments in the last ten years.