Responses to the EU public consultation on the scope of Universal Service.

damien

The European Commission has made available 75 of the responses it received to the public consultation it launched in relation to its Communication "On the Review of the Scope of Universal Service in accordance with Article 16 of Directive 2002/22/EC". None from ComReg but one from eircom.

zuma

After reading this statement I couldnt stomach reading the rest of it:

eircom wrote:

Broadband
The inclusion of broadband access and services in the scope of Universal Service at this stage would be
wholly unjustified as established by the Commission itself using its own criteria. While broadband
penetration rates are rapidly rising in all EU Member States, the service does not yet meet the criteria
of being used by a majority of customers.

viking

More from eircom:

Furthermore, mandating broadband as a Universal Service would assume that broadband take-up is primarily a matter of supply and price. Full adoption of broadband throughout the EU is a challenge that will be met by competing platforms, attractive content for end-users, innovative services and in certain cases public policy intervention to ensure that infrastructure is available in very peripheral areas where private capital may not be attracted. Above all, it will be facilitated by less regulation particularly at the retail end of the market.

BT (UK) also don't want broadband to be included in the USO even though they have ~99% availability:

While we agree that the time is not right to bring broadband services within the scope of the USO, the EU should encourage wider availability of such services by, for example, support for network provision in commercially unattractive areas.

Seems as though take-up is the reason that incumbents are giving for not incuding broadband in the USO, ie. its not a service enjoyed by a majority of users.

However, BT do at least contemplate a time when broadband might be included in the USO and consider some (incumbent-biased) factors:

• What is the definition of Broadband? The market has moved rapidly to a state where there are many different offerings, distinguished by bandwidth, quality of service, and quantity of data that may be downloaded. This is not an exhaustive list. Fixing a standard, especially as the market is changing rapidly, will be difficult [eh, no it won't. 'Always-on' and a minimum bit-rate would be a start]– and the choice will have major implications for the cost of provision.
• In most European countries Broadband access is not a vertically integrated service– one or more operators, including LLU operators, provide the connectivity while ISPs provide the retail service. While incumbents usually have an ISP, most have a market share below 50%. It may be necessary to distinguish between obligations for connectivity and services and it is not axiomatic that one provider should be responsible for both.
• Current USO providers face increasing localised competition from alternative operators, LLU providers and Cable operators who do not have to bear the costs of providing service to rural areas and citizens with affordability difficulties. The addition of a broadband element would increase the burden of USO provision.
• This observation is reinforced by current regulatory arrangements. In the UK, and some other Member States, LLU and DSL access prices are subject to regulatory control and no “excess” profit exists to fund USO provision.
• A distinction should be drawn between revenues from access and the provision of services. Offsetting revenues to the provision of Broadband access are limited and usually accrue to t to ISPs and other edge of network service providers. The scope for internal cross subsidies to meet USO costs is severely limited.

Essentially, the incumbents want the mobile operators to share the burden of providing the USO. Eircom argue that because we all live in the "schticks" and not living in super-high tower blocks in Dublin, that ComReg should pass some of the burden for availability onto mobile operators where fixed line access is not available.

Settlement patterns in Ireland are unusually dispersed. The low overall population density is not due to large tracts of largely uninhabited land, but to small low-density urban areas combined with a large proportion of the population living scattered around the open countryside.

viking

The Communication Workers Union in the UK hold some interesting views:

There are two main barriers to the use of mobile telephony, those of cost and availability. Despite the fact that mobile telephony has come down in price in recent years, there are still some sections of society who cannot afford the cost of a mobile phone (their emphasis)..... Our view is that there is a case for including mobile communications within the scope of universal services, and that the USO should be extended to require mobile phone coverage everywhere now reached by the fixed network. We also believe the USO should require the introduction of at least one low cost, basic mobile phone and mobile tariffs that are more accessible to low income users.

[The CWU] believes there is a compelling rationale for implementing a USO for broadband... At a time when BT is very near to being able to provide around 512 kbps DSL service to 99.4% of the population, it is wrong to stay with a functional Internet access speed of a mere 28.8 kbps.

We disagree with the Commission’s view that broadband has not yet become part of the fabric of society such that a lack of access implies social exclusion. On the contrary we would argue that we live increasingly in an information society where, to ensure full participation in the electronic marketplace and full rights as a citizen, one needs Internet access at greater and greater speeds. We believe that lack of access to broadband services does create social and economic exclusion. For example people running businesses in remote areas often completely rely on having a fast internet connection to survive in a competitive market place. Furthermore, people who wish to participate in the growing availability of online education, often retired people who lack mobility, cannot effectively do so without a broadband connection.

And interestingly,

We are also concerned that the Commission is being contradictory in its reasons for the exclusion of mobile and broadband from the USO. The Commission’s conclusion on mobile is that there is no justification for its inclusion in the scope of the USO because it has reached the majority of people. However, the Commission also concludes that there is no justification for the inclusion of broadband in the scope of the USO because it has not reached the majority of people. We are therefore faced with a ‘Chicken and egg’ or ‘Catch 22’ situation, in that if a service reaches nearly everyone there is no point in applying a USO, but if it does not reach everyone there is no point in applying a USO either. According to this logic there will never be a USO for mobile or broadband.

I wonder did the CWU in the UK contact their Irish counterparts for assistance in putting this submission together........