ComReg Forward-looking Strategic Review Consultation

damien

As per a previous thread...

ComReg has released a consultation about how it will plan out the next 5 years in a document called "ComReg Forward-looking Strategic Review of the Irish Telecoms Sector Consultation"

The full text of the consultation (150 pages or so) can be found here:

http://www.comreg.ie/whats_new/default.asp?ctype=5&nid=102001

We would like if everyone on this forum replied as best they can to this consultation. I posted the most important questions from the consultation in other threads which are linked to below.

The closing date for submissions is Friday May 27th at 5pm. Please send you thoughts and opinions to marketdevelopmentconsult@comreg.ie , send a copy to info@irelandOffline.org too.


Below are the questions asked in the document. The links will bring you to the text that inspired the questions.

* How can ComReg best incentivise infrastructure-based competition?

The full text leading to this question can be found here:
http://www.boards.ie/vbulletin/showthread.php?t=256608

(This part discusses splitting eircom up)
* Do you agree with ComReg analysis that further improvement is necessary at the wholesale level to facilitate the development of a fully competitive market place here in the interests of Irish consumers? If so, what would be the best way to ensure equal treatment between OAOs and eircom’s own downstream retail arm

The full text leading to these questions can be found here:
http://www.boards.ie/vbulletin/showthread.php?t=256621


*Q.5 How can ComReg achieve the right balance, at the retail level, between light-handed regulation and the prevention of abuses of dominance? Can the availability of wholesale inputs on a nondiscriminatory basis allow the relaxation of retail regulation?

*Q.6 Will substitution and convergence between fixed and mobile services reduce or eliminate the need for retail controls on a dominant operator?

*Q.7 What, if any, retail controls should be applied to all operators providing voice services to consumers?

The full text leading to these questions can be found here:
http://www.boards.ie/vbulletin/showthread.php?t=256625


* Q.2 Do you agree that these represent developments that will impact on the telecommunications sector in the period under review? Are there others? If so, what will they be and what would you expect to be their impacts?

The full text leading to these questions can be found here:
http://www.boards.ie/vbulletin/showthread.php?t=256651


*Q.21 Do you have any comments on these developments considered by ComReg on universal service obligations (USO)?

*Q.22 Do you expect these developments to lead to an increase or a decrease in retail obligations on operators with SMP in retail markets? How do you expect them to affect the level of retail obligations on all operators, including those without SMP?

The full text leading to these questions can be found here:
http://www.boards.ie/vbulletin/showthread.php?t=256656

Sponge Bob

In my heart I know I should engage with Comreg but my experience of them, and of other consultations where I strongly encouraged the readership of this forum to engage and reply to the consultations is that the responses were ignored by Comreg .

Sometimes Comreg handled this in a cack handed manner, eg.

1. Narrowband Analysis as part of the Framework series last year. Comreg themselves led us to believe that FIA would be part of the matrix of elements to which they would give due consideration .

2. A lot of responses come in on the subject , amongst others. Comreg kicks them all off to touch in a manner best described as arbitrary .

3. Comreg then kicks off an unexpected secondary consultation where they revisit the USO (also about Narrowband or POTS ) with a view to cleaning up the unholy mess they made of it in 2003 , defining the Internet as functional at 0k .

While I am minded to say that we should engage with Comreg on this meta consultation I fear that the responses to consultation will be ingored if they do not fit into a plan that Comreg themselves already have. I fear that Comreg will cherry pick parts that underpin their own internal thinking. Sometimes they will pick a small clause from a carefully structured paragraph and will ignore the rest of it and its overall intent and will not give a reason why .

Its almost like every answer to every question in their consultations must finish with the following catch all :

"and Comreg should show cause clearly as to why all of the aforementioned does not apply as a whole , and if some of it applies then what rationale was used by Comreg to justify the elimination of the remainder ."

Its too much like eating jelly with a fork when we should all be engaging in an honest discourse . Then we have to read a spin in the next days papers which glosses over the all too obvious failings and causes this poor Sponge to angrily squirt in every direction at the same time .

It takes ages for the sediment to settle on the sea bed , and then i can see again

eircomtribunal

Sponge Bob wrote:

I fear that the responses to consultation will be ingored

Are you saying you do not believe our regulator? On page six ComReg clearly says: "These responses will be considered when drafting the Strategy Statement due for publication in the Summer 2005."

This time around ComReg will not even go to the trouble of publicly dealing with any (possibly) unpleasant consultation resonses: "A dedicated published response to this consultation is not planned." (ComReg doc, page 6)


I've made some observations on the misleading presentation of the current state of affairs in the ComReg document under "resources" of the latest ComWreck blog:

(Isolde's briefing to the authors of the document) "==FOR YOUR EYES ONLY=="

P.

damien

*bump*