Dermot Ahern Is Blatantly Lying Again .....jeez!

spongebob

The country has good international ports, we paid Global crossing to build one such

The Country has loads of Fibre motorways. The telcos took grants to build them.

Now we are getting ring roads, the local authorities are taking grants to build them

Now all we need is the SLIP ROADS from each to t'other.

M

Hornet

Originally posted by Muck
My precise point is this.

19% of the population can get ISDN or ADSL @ 384k from a FWPMA Base Station. Thats because they have line of sight to an EXISTING basestation. 31% of the population will have this alternative by June 2005

I have to admit that my day job is suffering a bit at the moment due to this interesting discussion, but I can't resist...

ADSL @ 384k? Is that in Eircom's product portfolio? If not, you have to wait until it is! Silly rules? Maybe, but as in Eircom the left hand doesn't know what the right hand does, there could be a credible justification for it.

The customers are entitled to the SAME LEVELS of customer care from Eircom over wirelsss that they are over wired, its in the licence.

Logically this means that where Eircom cannot supply ISDN over Wired ...distance and crap lines are the usual suspects, AND THEY HAVE WIRELESS AVAILABLE , they should immediately offer it over Wireless.

I agree with the first part.
Second part: Yes, they SHOULD, but there is NO obligation. There is no USO for ISDN or ADSL, therefore they can choose if or if not they want to provide it and what method they want to use to provide it.

Eircom make sure that their staff are blissfully ignorant of where the Wireless alternative is currently available....hardly consistent with their licencing obligation to be platform agnostic where they have coverage.

I had some dealings with Eircom on Wireless issues around the time of the licence issue and I was surprised how the left REALLY didn't know what the right hand did. (And I experienced that when during the ADSL trial I rang Eircom because of a fault and it seemed that the whole "service" call centre staff had no idea what ADSL was and that Eircom was providing it.)

But I have to repeat the point, that Eircom has no obligation to provide the service. Platform agnostic only applies when it comes to service guarantees and pricing!

Regarding your example:
Yes, there is FWPMA capability in Cork. Yes they COULD offer you services using it. But they don't HAVE to. No, ADSL @ 384k is not available.

I don't disagree with you, but the small print is against you! "Should" and "Have to" are far apart. Product portfolio decisions are totally up to the relecant telco if non-USO services.

The current system is like pulling hens teeth.

a) Nobody knows where the Antennae are.
b) Nobody in Eircom is allowed to admit to knowing where they are.
c) Eircom customer care is not offering the service...you must hound them
d) Comreg are not even at the starting gate, they make Vodafone, Metoeor and O2 publish the location of THEIR antennae ...on a map on the Comreg site, while Eircom don't have to at all despite the fact the Cells and Eircoms FWPMA antennae are all Omni Microwave devices.

I like the metaphor! :-)

a) True
b) Not many in Eircom DO know.
c) They don't have to, but full marks to you if you don't give up and are successful in the end. (Customer "Care" ???)
d) Different licencing conditions and different type of service. Mobile service without signal coverage is no service. ISDN service doesn't necessarily need wireless signal coverage.

--Hornet

Hornet

Originally posted by Muck
The country has good international ports, we paid Global crossing to build one such
The Country has loads of Fibre motorways. The telcos took grants to build them.
Now we are getting ring roads, the local authorities are taking grants to build them
Now all we need is the SLIP ROADS from each to t'other.

The motorway analogy devloped even further! I like it! :-)

Hmmmm...

After all that there is still no guarantee of low priced competitive services. I used the Dunnes vs Tesco analogy to point out that Ireland is a high-price low-competition country. Don't expect the current players in the market to upset the pricing models.

The global crossing investment was much too high and most of the links are not used. But the intention was good and had some positive effects.

All of the fibre motorways are heavily protected if they are owned by Telcos and some of them are not even used. The only breath of fresh air is coming from ESB and Bord Gais (Aurora).

The Ring Roads are overpriced (I mean the total investment in comparison to the expected benefit) and not where the cars are. ("Build it and they will come"-Syndrome from bygone years!)

Motorways without slip roads are useless! So planing one without the other is a big mistake (Local Authorities!!!!)

Only when smaller Telcos work TOGETHER (while competing) they will have a chance against the two (!!) incumbents Eircom and BT (all decisions seemed to be made in BT, not in EsatBT).

-Hornet

SkepticOne

Originally posted by Hornet
I have to admit that my day job is suffering a bit at the moment due to this interesting discussion, but I can't resist...

ADSL @ 384k? Is that in Eircom's product portfolio? If not, you have to wait until it is! Silly rules? Maybe, but as in Eircom the left hand doesn't know what the right hand does, there could be a credible justification for it.

Do you concede then that they must provide ISDN level services if they can't provide them over wired links and their licence obligation demands it?

Hornet

Originally posted by SkepticOne
I disagree with the motorway analogy. If alternatives to Eircom are going to be built and if currently there is no means of accessing Eircom's network, then new fibre will need to be laid.

Yes, but only where it makes business sense to do so! Not in Gweedore and Bandon!

If new fibre is to be laid then it makes sence to lay a lot of it to provide for future needs. The extra cost is far from linear. Most of the expense is in digging up the roads.

Where the road is opened up, you are absolutely right, lay as much as you can. But if I say put in less, I mean the number of locations, not the number of fibres.

I agree that it was a mistake to privatise Eircom's network in the way they did. But the country got 7 billion euros out of it. I have no problem with a tiny portion of this being used to facilitate regional development.

Do you remember where this money came from?? I am still licking my wounds from my short and unsuccessful venture into shareholding! The money was to a large extent taken from the same people that payed for P&T's and Telecom Eireann's infrastructure before!

But apart from that, I have no problem with using it for regional development, but I have a BIG problem with the money being wasted! Do I HAVE to mention Gweedore and Bandon again?????

If we are talking about large towns, we can stop the whole discussion right now! But for the majority of the locations fibre rings are just a waste of money.

-Hornet

spongebob

I gave my examples by referencee to Cork and not Ballydehob.

It is by NOT offering the services that Eircom are in breach of their licence.

Eircom ARE NOT ALLOWED to selectively deliver services on WIRELESS

The USO obliges them to guarantee 2400 Data over POTS

WHERE they deploy WIRELESS NARROWBAND FWPMA they MUST offer ALL the following services. Wireless , if installed , cannot be offered a la carte.

Here is the .Licence 03/19 I Refer to , see page 6 where it says.

"Required Services"

ISDN, POTS , 128k leased symmetric and 384k leased asymmetric

What bit of the word "Required" must I explain

What they are NOT obliged to do is to offer Wireless to 100% of the population, merely to 19-31% at present......

Wireless Availability Implies a Universal Service Basket Obligation.
Pots Must be Universally Available with a Minimum Service Basket Obligation

2 Different kinds of USO Hornet.

Floor is Yours

M

Hornet

Originally posted by SkepticOne
Do you concede then that they must provide ISDN level services if they can't provide them over wired links and their licence obligation demands it?

IF and only IF Eircom has an OBLIGATION to provide ISDN services to you, the requesting customer, for example as a Universal Service Obligation. Then they HAVE to provide it over wireless if they can't provide it over wired.

Yes, I totally agree on that.

...but unless the USO rules will be changed, there is currently NO obligation for them to provide anything else than basic telephony services. ISDN, ADSL, Leased Lines, even dial-up Internet services of more than 2400 (as I learned this week!) are all outside the USO.

Do you agree?

SkepticOne

Originally posted by Hornet
...but unless the USO rules will be changed, there is currently NO obligation for them to provide anything else than basic telephony services. ISDN, ADSL, Leased Lines, even dial-up Internet services of more than 2400 (as I learned this week!) are all outside the USO.

Do you agree?

Muck has already answered this question.

spongebob

Originally posted by Hornet
IF and only IF Eircom has an OBLIGATION to provide ISDN services to you, the requesting customer, for example as a Universal Service Obligation. Then they HAVE to provide it over wireless if they can't provide it over wired.

Yes, I totally agree on that.

...but unless the USO rules will be changed, there is currently NO obligation for them to provide anything else than basic telephony services. ISDN, ADSL, Leased Lines, even dial-up Internet services of more than 2400 (as I learned this week!) are all outside the USO.

Do you agree?

If I agreed I wouldn't have said otherwise.

The Existence of a Wireless Option in a given location puts Eircom under a different set of obligations to those extant where only Copper is available.

LOS to a FWPMA Antennae in Cork means you can SEE the feckin' thing from your premises, its that simple , if you can't see it you must fall back on the POTS USO .

Please read licence 03/19 , pages 3-6 as linked above.

M

Hornet

Originally posted by Muck
If I agreed I wouldn't have said otherwise

Apologies Muck, you were to fast for me. So my question (if you agree) was typed before I saw your other response.

It is by NOT offering the services that Eircom are in breach of their licence.

Eircom ARE NOT ALLOWED to selectively deliver services on WIRELESS

You are correct with the first statement. According to the licence, they have to provide the services in the Required Services list. BUT: They don't have to provide them to YOU!!

That is the big difference between the Required Services definition and the USO. The USO defines what YOU have to be able to get. It is your "basic right" to get the services listed in the USO. The Required Services in the licence only define what has to be available from the Base Station.

So we are not talking about two different types of USOs as you suggest. Instead one is from a customer's point of view (USO) and the other one is more a technological capability.

Eircom can pick and choose who they want to offer services (outside the USO) to and it is completely up to them to decide what services they do make available to a specific user and in what timeframes.

Is it fair? Commercially, Yes. Socially, Probably not.

BTW: I am happy to check with ComReg, if you have doubts about my definition.

spongebob

Page 2 explains where and when they dont have to offer it to me....assuming the Antennae is LOS

as I keep saying, the only problem is the gross neglilgence of Comreg in not publishing a list of the Antennae. They did publish them for Chorus who have the other Narrowband FWPMA licence.

If people knew what and where they were Eircom would not have such an easy time, 80-90% of them are stuck in a yard behind an ADSL enabled exchange.

M

oscarBravo

Gah! Two threads about my lil' ol' wireless problem. I'll post this here.

Act I, scene III: As predicted, ISDN is not available on FWA in Ballina. I got my order reference number from the (very helpful and friendly) Eircom engineer, and I'm writing (snailmail) to Eircom and ComReg as we speak.

Hornet, I'm with Muck. The license clearly states that where narrowband FWPMA is implemented, certain services are required. To say that they don't have to offer them to me is an insult to my intelligence (not by you, by Eircom!) and an abuse, IMHO, of the license.

I mean, dammit, it's I S D flippin' N we're talking about! The original 1980's vintage digital line!!

Hornet

Originally posted by oscarBravo
Hornet, I'm with Muck. The license clearly states that where narrowband FWPMA is implemented, certain services are required. To say that they don't have to offer them to me is an insult to my intelligence (not by you, by Eircom!) and an abuse, IMHO, of the license.

I fully understand your frustration! It is annyoing and depressing if you can't get what in other countries (e.g. Germany) is becoming the STANDARD phone line. After all you are _really_ not asking for too much!

Unfortunately, I don't think we are talking about an _opinion_ when we discuss the licence conditions, but a legal definition.

If certain services are required, the provider has to be technically able to provide these services. But if - for technical or commercial reasons - he decides not to provide these services in some area or to some customer group, the provider is NOT in breach of his license.

Lobbying and fighting for it might help you and I wish you good luck and hope you will be succesful. But the legal argument you use it in my opinion VERY shaky.

The intent of the USO is to guarantee availability of a (basic) service to the end user. Based on this you have a right. You, as an end user don't have a right coming from a license condition.

But, please, as it seriously affects you, do check with ComReg, don't just accept what I am saying (you aren't anyway! )

BTW: I checked in the license conditions on Page 2 as referred to by Muck if it explains where and when services have to be offered, but I couldn't see which section Muck was referring to.

BTW2: Interestingly, a large part of the license conditions was written by Eircom and suggested to the ODTR. Especially the part about the penalties! Surprising, but true! Why? Because they realised at the time, that they have to give more than the other applicants to get a license. ....and it worked....

-Hornet

spongebob

Originally posted by Hornet
I
BTW: I checked in the license conditions on Page 2 as referred to by Muck if it explains where and when services have to be offered, but I couldn't see which section Muck was referring to.

BTW2: Interestingly, a large part of the license conditions was written by Eircom and suggested to the ODTR. Especially the part about the penalties! Surprising, but true! Why? Because they realised at the time, that they have to give more than the other applicants to get a license. ....and it worked....

-Hornet

My apologies Hornet, the bit I referred to is the Second Paragraph on page 3 which states a Very Limited number of circumstances where Eircom can refuse to provide the service. Section 28.2

Essentially, if your application does not 'cause damage to the FWPMA network' ..probably because the engineer backed into the mast because the map was out of date then its game on if the mast is there.

There are a few twiddly bit on page 5 where Eircom can try to squirm out of a line test on the grounds of strom damage.....so be very wary of the definitions of "coverage" and "system availability". Check them with Comreg if you must before applying. Ask Comreg where the bloody map is while you are at it.......

On Legal Grounds alone

1. This is an agreement entered into voluntarily by Eircom some 15 months after the current copper USO became binding.

2. Eircom knowingly accepted these onerous extra service requirements......

3. The technology is new and unencumbered by the shoddy workmanship that characterises the copper plant. It is not surprising that more was expected of it and asked of it in the licence conditions. Nor it it surprising that Eircom agreed.

4. In short, you cannot compare the Copper USO....a set of services which will work in 100% of the state, with the Wireless USO which is intended to provide a Larger feature set but only over 43% of the state by Land area by June 2003 (thats end year 3 I was wrong about the coverage ) Pages 11 and 15 are slightly contradictory the Target is June 2003 and the fines kick in in August 2003

5. 66% of the population are entitled to these services within this 43% of the land area of the state. If the service is supposed to be available to 66% then Comreg should force Eircom to inform us, the taxpayers, of where this 43% of the state is (or isn't) and damn the property crash.

Put this in perspective.....the ADSL rollout promised by Eircom recently will allegedly enable 150 exchanges ..... out of 1100 in the state. This is 16% of exchanges by end September 2004.

As each exchange covers the same geographical area, broadly speaking, I am going to generously concede that 20% of the land area of the state will have wired ADSL Broadband by 30/09/04

Wireless must cover 43% of the land area of the state by 16/06/03.

I live in the countryside, Wireless sound like a much better bet for me , I cannot be the only one who wants Eircom to be held to the terms of their licences.

M

ednwireland

This seems to be another problem here, one of eircom not investing in the basic infrastructure now i don't know if the ballina issue is a lack of lines in the exchanges (eircom not doing ANY capital spend in putting extra equipment in exchanges) or a distance issue. but i do know donegal town has not had any new isdn capability for about 6 months due to eircom refusing to upgrade the exchange. unless youre a minster moving her office and a line appears magically.
this raises a point i would be interested in how many small-ish towns in ireland are suffering from the same problem, now i know hornet will say this is a commercial issue BUT we get politicians saying how they must give the west more jobs without this basic infrastructure not even sme's can open up beleive me i see enough people not bothering due to lack of basic infrastructure.

also no motorways in donegal 20-30 mins have been knocked off the journey time from Donegal town to letterkenny in the last 5 years (i have lived here) IS this commercially viable infrastructure I doubt it. IT is a gov. decision to build the only infrastructure that they can SO why is broadband any different.

It is down to political will which is there for a low tax low service economy - and the people voted for it

[end rant]

bk

Well there is nothing wrong with oscarBravo sending a letter to Eircom and ComReg. If we are wrong about Eircoms license requirements, then I'm sure they will set us straight.

Best case scenario is oscarBravo gets what he is looking for and IOFFL gets yet another bat to beat Eircom with.

Worst case scenario Eircom and ComReg discover that we are very aware of this issue and are watching them very closely now. This should help with any future license agreements, ComReg will have they include much stricter license requirements and punishments, or feel our anger.

BTW as soon as we get FRIACO and the new ADSL products, I believe IOFFL membership and committee should put greater focus on wireless technology (or any other alternative to Eircom) and campaign for the development of real competition in the market

Hornet

Originally posted by bk
Well there is nothing wrong with oscarBravo sending a letter to Eircom and ComReg. If we are wrong about Eircoms license requirements, then I'm sure they will set us straight.

As offered in some of my recent postings, I have asked ComReg for clarification as well and will post the response here as soon as it arrives. (BTW: I have asked a question about maps as well!)

As I am not directly affected, I would strongly suggest that oscarBravo and others will send their own letters. even if the response would be the same.

BTW as soon as we get FRIACO and the new ADSL products, I believe IOFFL membership and committee should put greater focus on wireless technology (or any other alternative to Eircom) and campaign for the development of real competition in the market

Good point - and something I realised at the First Tuesday meeting, where David Long was on the panel: IOFFL will have to re-invent itself as soon as possible. With ADSL and FRIACO soon beeing there, IOFFL will loose its main purpose of existence. So the goal has to be adjusted to the new situation. My strong recommendation would be not to wait to long!!

-Hornet

spongebob

How about The

Irish - Telecommunications Home Users Group

aka

i-THUG

has a ring to it if ye'll pardon the pun.

M

SkepticOne

Originally posted by Hornet
With ADSL and FRIACO soon beeing there, IOFFL will loose its main purpose of existence. So the goal has to be adjusted to the new situation. My strong recommendation would be not to wait to long!!

There needs to be a swing towards wireless and other technologies. However, FRIACO as it stands will be limited and Eircom's suggested ADSL (if it actually goes ahead) will take a long time to reach most lines in the country.

Unfortunately, flat rate 56K and ADSL will need to be on the agenda for quite some time, imho.

BoneCollector

Seems to me that the closer we get the slower progress becomes...
its like time is slowing down

In fact to the rest of the world, where probably already standing still. :eek:

oscarBravo

Act II, Scene I:

Mr Pat Galvin
Director of Regulatory Affairs
Eircom plc
St Stephens Green
Dublin 2

Dear Mr Galvin

On Monday February 10, I placed an order (no. 2304317CH) with Eircom for a "Hi-Speed" (ISDN Basic Rate) line to be installed as an upgrade to the existing lines in my premises. The following day I was contacted by an engineer to arrange a date for the installation.

• I explained to the engineer that one of my existing lines is provided over the copper local loop, while the other is provided using narrowband Fixed Wireless Point-to-Multipoint Access (FWPMA).
• He told me that the plan was to upgrade the copper line to ISDN, and to discontinue the FWPMA line.
• I informed him that the copper line has been found on a number of occasions to be inadequate for ISDN, and that the service would have to be provided over the FWPMA connection.
• He seemed doubtful as to whether this was possible, but agreed to check into it and call me back.
• He called me several hours later to confirm that it would not be possible to provide ISDN on a FWPMA connection.

I would like to draw your attention to the enclosed excerpts from Eircom's narrowband FWPMA license agreement (ComReg document 03/19). Section 28.1 and Part I of the Second Schedule of this document clearly state that ISDN Basic Rate is a required service under the terms of the license.

I would appreciate it if you could explain why Eircom is unwilling or unable to provide a service, as required under the terms of the license, to a location which has been demonstrated to be within line-of-sight range of an operational FWPMA base station. I expect to receive your reply, in writing, by February 20.

Yours Sincerely,
Paul Cunnane

cc: Commission for Communications Regulation
Block DEF, Abbey Court
Irish Life Centre
Lower Abbey Street
Dublin 1

I attached pages 3 and 6 of ComReg10319.pdf, and a copy is on its way to ComReg as well.

bk

Just to remind people the stated goal of IOFFL can be found here

* Universal flat rate (unmetered) access to the internet for all users.
* Complete Local Loop Unbundling (LLU) by Eircom.
* Universal access to broadband services for all users.

I do believe we will have objective one complete in the next few months, but we still have to be vigilant until it is launched and even after that, to ensure we don't slip backwards when we have our backs turned (i.e. Nolimits)

Objective 2 I believe may be a dead duck

Objective 3 is still a very long way off, the introduction EUR54 DSL product is only the beginning of the end. It will take many years before bb is available to all.

Also there is nothing in this objective to say that BB needs to be DSL, DSL is only the most obvious form of BB and the most achievable in the short term, but we need to support other tech if we are to achieve the "universal" part of the objective, DSL will never be suitable for the majority of rural users due to its limitations, alternatives will be required.

Personally I will not consider Objective 3 achieved until the following two conditions are met:

1) At least two (preferably 3) competing BB platforms in all major population areas (Cork, Dublin, etc.).

When I say platforms, I mean completely seperate tech and companies.

For instance I would consider bitwise DSL to be only one platform, it doesn't matter if others (UTV, Esat, etc.) buy it wholesale, they are will restrained by Eircoms spec and wholesale price of the product, therefore there would never be true competition and innovation, just slight product variations.

I would consider other platforms to be LLU, various wireless tech, cable and perhaps low altitude systems and BB over power lines. (Did I miss anything?)

Only with this sort of platform mix will we see true competition and innovation, like we are starting to see develop in the UK (see Bulldog intros 4Mbps DSL - TheReg )

2) At least one BB platform in all other areas.

Only with these goals achieved will we truly have completed objective 3.

BTW this is in no way meant to cast a shadow over the absolutely brilliant work everyone invloved in IOFFL has done so far, I jsut wanted to remind people that there is a great deal of work to be done yet and the potential directions IOFFL might focus on once we have FRIACO and at least the start of the roll out of the residential DSL products.

OT - Cool I'm a Crazy Poster now