IOFFL - Proposed Questions For Eircom

LegacyUser

Based on contributions on various threads on this board and in ie.comp, I have prepared following draft set of questions to send to Eircom before Thursday’s meeting. Thanks to all who did contribute already, especially Dahamsta with his invaluable list of questions in the regulatory area.

As I am away on Monday and Tuesday, I would like to get it off to them Sunday night so please make your comments ASAP.
Sory about lack of formatting but I am rushing off to a wedding

1. UNMETERED ACCESS
1.1. Why has Eircom to date not made any attempt to introduce an unmetered package similar to SurfNoLimits as introduced by ESAT two years ago?
1.2. Does Eircom have any intention to introduce such a package, and if so, when?
1.3. What is Eircom doing to facilitate the achievement of FRIACO and what is the timescale for doing so?

2. LOCAL LOOP UNBUNDLING
2.1. Does the Director of Regulatory Affairs (DRA) believe that Eircom is co-operating to the fullest extent with the ODTR and the Other Licensed Operators (OLO's) to facilitate LLU and fair competition in the telecommunications marketplace?
2.2. Please explain in detail, from a regulatory perspective, what Eircom are doing to facilitate the issues mentioned above.
2.3. The LLU process is over six months behind schedule, in contravention of a European Commission Directive, and this can be attributed almost entirely to the pricing issue. Eircom has still not agreed some of the pricing structures for LLU, which is seen by many as a stalling tactic on the part of Eircom. Will the DRA concede that this demonstrates, or has demonstrated, Eircom's lack of commitment to their regulatory responsibilities?
(a) If the DRA concedes to the above, what is the DRA doing to correct this problem?

(b) If the DRA does not concede to the above, who does the DRA hold responsible for the problem? There are three primary parties involved here, the ODTR, the OLO's, and Eircom. Which does the DRA feel is most responsible?
2.4. From a regulatory perspective:
(a) Are Eircom prepared for LLU?
(b) Do Eircom have comprehensive plans in place to facilitate access to exchanges and the local loop, as required by the Regulator?
(c) Do Eircom have a timetable in place for LLU?
(d) Please give an overview of the above-mentioned timetable.
2.5. Eircom has stated publicly that it is not content with the wholesale pricing guidelines the ODTR has released with regard to LLU. What pricing would Eircom be content with?
2.6. The ODTR’s pricing was based on the European average for "efficient operators". If the Eircom will only be content with a higher price, please outline the factors that raise this price above the European average.
2.7. Will the DRA give a guarantee to Ireland Offline and the consumers and businesses it represents that the DRA and Eircom will assist the ODTR and OLO's in every way possible to facilitate LLU quickly and efficiently?


3. BROADBAND
3.1. What is Eircom’s schedule for rolling out broadband beyond the trial exchanges earmarked for trials in September?
3.2. What price range will Eircom be targeting for broadband and will there be tiered packages on offer?
3.3. There has been widespread speculation that broadband will be capped – what are Eircom’s plans in this regard?
3.4. What does Eircom intend to do about the problems created by many DACS boxes around the country which slow down modem access and prohibit broadband access?
3.5. Do Eircom believe that the standard of copper wiring in the country at large is good enough for broadband access? If not, what are their plans to deal with this?
3.6. It has been suggested that Eircom are having difficulty finding sufficient technical staff with the skills for installing broadband equipment – if this is so, how do they see this problem being overcome and what impact will it have on the rollout programme?

4. OTHER ISSUES
4.1. A comparatively large number of complaints have been filed against Eircom with the ODTR, not just with regard to local loop unbundling, but also other issues that come under the brief of the Regulator, including, but not limited to: pricing, interconnects, SLA[1] breaches, and general co-operation issues. A large majority of the Notices issued by the ODTR on these matters have been decided against Eircom. Does Eircom believe they have been unfairly treated by the Regulator, or do they concede that the Regulator was correct and that Eircom have been mishandling some or all regulatory issues?
4.2. Have Eircom brought any legal proceedings against the OTDR, or are Eircom preparing to bring legal proceedings against the ODTR?
4.3. Does the DRA believe that Eircom has a monopoly on fixed lines in Ireland?
(a) If the answer to the above is yes, please explain why Eircom is allowed to continue in its dominant position. Is the monopoly sanctioned by the Irish government or legal system in some way?

(b) If the answer to the above is no, according to competition law, Eircom is by definition a monopoly in this particular sector. Please explain how you have come to this conclusion.
4.4. The telecommunications infrastructure in Ireland was developed using taxpayers’ money before the company was privatised. Does Eircom believe it has an exclusive right to that infrastructure now that the company has been privatised?
(a) If Eircom believes the above is true, please explain the reasoning behind that belief.

(b) If Eircom does not believe the above, please explain why Eircom has not facilitated fast-track access to that infrastructure?

LegacyUser

Small error on my part:

"2.6. The ODTR?s pricing was based on the European average for "efficient operators". If the Eircom will only be content with a higher price, please outline the factors that raise this price above the European average."

Please replace "the Eircom" with just "Eircom".

LegacyUser

lets hope we get some answers and not rubbish
pld i.offline

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routine? expectations? competition? happiness? commitment? infatuation? virginity?
respect? marriage? adultery? money? carnal knowledge? love?...
... blah, blah, blah

p.s i want dsl

LegacyUser

Just a few comments:

"
3.1. What is Eircom?s schedule for rolling out broadband beyond the trial exchanges earmarked for trials in September?"

The trials are now. The actual launch is in September. Suggested question:

3.1. What is Eircom?s schedule for rolling out broadband beyond the trial exchanges after the launch of commercial services in September?

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Broadband.

"3.2. What price range will Eircom be targeting for broadband and will there be tiered packages on offer?"

This suggests that we might be in favour of a tiered capped system. I would suggest we put a slightly different question to them:

[/i]3.2. What price range will Eircom be targeting for fully flat-rate broadband ADSL?

This will force them into providing prices for services that can be compared internationally. Don't accept answers where they talk about a "flat-rate portion" followed by a per-megabyte fee thereafter. This is not flat-rate. This is a pre-paid service. Whatever they want for this service, it will allow us to compare it with other countries. This will add to the case for LLU.

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One other question (I don't know where it fits):

There are many variants of xDSL. For example IDSL allows the range to be extended up to 8Km from the exchange. This would allow rural dwellers to have a always-on flat-rate connection.

Will Eircom be installing this equipment in exchanges? Will Eircom allow OLOs to install IDSL and other xDSL variants in exchanges under LLU?

Again, non-answers here are a further case for LLU.


[This message has been edited by Skeptic1 (edited 14-07-2001).]

sceptre

Think the IDSL question is one that should be asked.

LegacyUser

oh ye' and tell the fockers to roll out dsl to deh northside or i'll be fockin round unbundling their focking local loop.

LegacyUser

Seems to me to be very comprehensive and covers everything.. A lot of hard work going into all this.Well done, and good luck. Not only from me, but everybody in Ireland with needs such as ours. Waiting with great interest for the results of the meeting. I am trying my best to be at the meeting. If I fail will only be for reasons outside my control.

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LegacyUser

<font face="Verdana, Arial" size="2">Originally posted by sceptre:
Think the IDSL question is one that should be asked.</font>

Added

Martin

LegacyUser

A number of people have expressed the view that the list of questions posted yesterday was too wide and going into areas that are not our concern e.g. legal action between Eircom and ODTR.

I have pruned the list as below to make it more targeted. That is not to say that the other questions/issues cannot be raised in discussion – the ones below are those that we want to submit in advance.

Opinions and comments?

Martin Harran
IrelandOffline


1. UNMETERED ACCESS
1.1. Why has Eircom to date not made any attempt to introduce an unmetered package similar to SurfNoLimits as introduced by ESAT two years ago?

1.2. Does Eircom have any intention to introduce such a package, and if so, when?

1.3. What is Eircom doing to facilitate the achievement of FRIACO and what is the timescale for doing so?

2. LOCAL LOOP UNBUNDLING
2.1. From a regulatory perspective:
(a) Are Eircom prepared for LLU?
(b) Do Eircom have comprehensive plans in place to facilitate access to exchanges and the local loop, as required by the Regulator?
(c) Do Eircom have a timetable in place for LLU?
(d) Please give an overview of the above-mentioned timetable.

2.2. The LLU process is over six months behind schedule, in contravention of a European Commission Directive. What is the DRA doing to correct this problem?

2.3. The ODTR’s pricing was based on the European average for "efficient operators". If Eircom will only be content with a higher price, please outline the factors that raise this price above the European average.

2.4. Will the DRA give a guarantee to Ireland Offline and the consumers and businesses it represents that the DRA and Eircom will assist the ODTR and OLO's in every way possible to facilitate LLU quickly and efficiently?


3. BROADBAND
3.1. What is Eircom’s schedule for rolling out broadband beyond the initial exchanges planned for September?

3.2. What price range will Eircom be targeting for broadband and will there be tiered packages on offer?

3.3. There has been widespread speculation that broadband will be capped – what are Eircom’s plans in this regard?

3.4. There are many variants of xDSL. For example IDSL allows the range to be extended up to 8Km from the exchange. This would allow rural dwellers to have a always-on flat-rate connection. Will Eircom be installing this equipment in exchanges? Will Eircom allow OLO’s to install IDSL and other xDSL variants in exchanges under LLU?

3.5. What does Eircom intend to do about the problems created by many DACS boxes around the country which slow down modem access and prohibit broadband access?

3.6. Do Eircom believe that the standard of copper wiring in the country at large is good enough for broadband access? If not, what are their plans to deal with this?

3.7. It has been suggested that Eircom are having difficulty finding sufficient technical staff with the skills for installing broadband equipment – if this is so, how do they see this problem being overcome and what impact will it have on the rollout programme?

Bard

There's no real reason why Eircom should be 'let off the hook' and allowed to be completely at ease having had all their answers pre-prepared. Maybe some questions should be pre-prepared and presented to Eircom... And maybe some should be set aside as "SURPRISE!!!" questions to be asked by us in the Q&A session after their "presentation" ?

Even if they refuse to answer some, we'll be better able to gauge how they feel on some issues by their reaction than we would be by a response they've had time to 'manufacture' and shine up.

(This is my 2 cents... speaking here on my own behalf, not necessarily the committee's - obviously)

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Bard

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I've got a plan... and it's as HOT... AS MY PANTS!!!" - Lord Flashheart.

LegacyUser

I think it's good to have at least some questions pre-submitted. That way, evasion and non-answers can be interpreted much more seriously. Eircom needs to be made more accountable.

For most of the country, there is no choice but to use their local loop services. This is unlikely to change in the future. In my opinion, refusal to answer (in full) questions about LLU timescales and the pricing and roll-out of flat-rate and broadband services is unacceptable.

We have a right to know these things. The local loop is often considered a minor part of a country's telecomms infrastructure but for me it is the most important part. It is through the local loop that most people (and indeed companies) access these broadband networks that have been subsidised by the tax-payer. It is the bottleneck. Evasion and non-answers, if given, mean that this vital part of the infrastructure is run by a non-accountable body.

We have to wait and see what answers Eircom will give.

[This message has been edited by Skeptic1 (edited 15-07-2001).]

dahamsta

My only worry is that Eircom will either throw out or answer politically anything not covered by the DRA's job description, using an excuse like "he wouldn't be able to follow up on them in the meeting if asked for clarification". That's half your questions gone right there. I have no objection to Eircom being supplied with a rundown beforehand though.

adam

LegacyUser

As far as I'm concerned, the meeting is with Eircom. They have decided to use their DRA as the spokesman. Three days should be sufficient to gather the information from other sections of Eircom. IrelandOffline is doing them the courtasy of submitting the questions in advance in order to allow this to happen. This should be made clear in the email to Eircom with the questions.

All the above is IMHO as a supporter of IrelandOffline.

LegacyUser

Very well worded and i agree with Skeptic, they have more than enough time to answer all questions.

Where excactly is the meeting going to be tho?...I know central Dubla but where bouts in it

Farls

LegacyUser

<font face="Verdana, Arial" size="2">Originally posted by Farls:
Where excactly is the meeting going to be tho?...I know central Dubla but where bouts in it</font>

Presume you mean the public meeting - the meeting with Eircom is Thursday morning with representatives of IrelandOffline.

Venue for public meeting will be finalised tomorrow and posted here.

Martin

LegacyUser

Whew! Nice catalogue of questions!
My compliments.

Now hopefully Eircom will take at least the same effort to answer those questions.
I am convinced that some representatives from Eircom do read the postings here, so they definitely have time enough to come up with some meaningful answers.

So, let's hope for the OIFFL delegation (and for all of us) that those Eircom representatives will not just waste the time of 'our' delegation...

Wishing you 200% success ;-)

disConnected

LegacyUser

To Martin:
There may be some q's arising from my experience today on the phone to eircom
re: "i-stream" dsl. You can read about it on the "i-stream delay" post here....

http://www.boards.ie/community/Forum18/HTML/000218.html

80p.

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www.80project.com

[This message has been edited by 80project.com (edited 16-07-2001).]

LegacyUser

In relation to the DSL capping..

If a capped service is being introduced, can Eircom explain why they believe this is necessary (technical reasons and/or otherwise), and how there are telcos in other regions that do not operate such limitations.

LegacyUser

old news, but a previous article to give you a flavour of Pat Galvin:

"Eircom says EU regulation discriminatory"
http://www.ireland.com/newspaper/finance/2000/1116/fin4.htm


Pat Galvin et al seem to be part of this:

http://www.ibec.ie/Sectors/TIFF/TIFFdoclib3.nsf/6a004bbd02034a5480256845006de153/524f1082db2c8ad4802569ed0051051c

LegacyUser

Eircom keep missing the point ... they have an asset (all that installed copper wire) which was financed by the tax payer and we the tax payer have the right to insist that this asset is made available to other parties who are willing to offer the services that we require.

jd

<font face="Verdana, Arial" size="2">Originally posted by infomat:
Eircom keep missing the point ... they have an asset (all that installed copper wire) which was financed by the tax payer and we the tax payer have the right to insist that this asset is made available to other parties who are willing to offer the services that we require.</font>

One argument would say the state sold off the copper infrastructure with Eircom ie we (the taxpayers)got paid for it by those who bought Eircom shares
jd