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13-09-2006, 10:28   #1
bealtine
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Comreg looks for excuses to jack up the line rental (again)

I think we should probably respond to this and be utterly ignored yet again...

Even so I urge you to respond to this nonsense.

http://www.comreg.ie/_fileupload/pub...ComReg0641.pdf

"Consultation on a Retail Price Cap as a Potential Remedy on Fixed Narrowband Access Markets - Part 1."
Responses to arrive on or before 5:30pm on Friday 29 September 2006,

Our current line rental pricing is the highest in the EU and now they want to put it up again...It is not our problem (mine and yours) that eircom is encumbered with massive debt. This is not a valid excuse to jack up the prices.

Please respond to Comreg and let them know what you think:-)

I shall copy 'n' paste the questions here later.
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13-09-2006, 10:36   #2
bealtine
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Questions...

Q. 1. Do respondents have any observations in relation to ComReg’s assessment of the statutory basis for the imposition of any new price cap and the procedures that must be adhered to in that regard? Please provide detailed reasons in support of your response.

Q. 2. Do respondents agree with the objectives of ComReg with respect to its current review of the price cap? Which objectives should have priority, if any? Does the respondent feel that this list excludes other important objectives that need to be considered? If yes, please list.

Q. 3. In the event that there is no effective competition in the access market(s) defined, what other factors should ComReg consider before deciding to impose a retail price cap remedy? Do respondents agree with the factors listed above

Q. 4. Do respondents consider that any of the factors listed above preclude the imposition of a retail price cap on any of the specific markets identified? Please give reasons for views expressed and supporting analysis and/or data if possible

Q. 5. Do respondents agree that, in addition to wholesale measures, some form of a retail price cap remedy is an appropriate and proportionate form of regulation in light of changing market circumstances for retail SMP access services? Please give reasons for views expressed and supporting analysis and/or data if possible

Q. 6. In the event of eircom’s having SMP in the lower level access market, does the respondent believe that some form of price cap should be applied to this relevant market? Please give reasons for views expressed and supporting analysis and/or data if possible

Q. 7. In the event of eircom having SMP in the higher level access market, does the respondent believe that some form of retail price cap should be applied to this relevant market? Please give reasons for views expressed and supporting analysis and/or data if possible

Q. 8. In the event that a price cap remedy is deemed necessary, which form of price cap do you consider would be the most appropriate and proportionate remedy, a global basket cap (lower and higher level access considered together) or separate individual cap(s) on each identified SMP market and/or services? Please explain your reasons with supporting analysis and data if possible

Q. 9. In the event that an individual cap either on an SMP market or service is deemed necessary, in relation to lower level SMP markets/services should this be a narrow cap on PSTN line rental only, or should it be expanded to include other lower level access services (e.g., connections)? If so, which ones? Which combinations

Q. 10. In the event that an individual cap either on an SMP market or service is deemed necessary, in relation to higher level SMP markets/services should this be a narrow cap on ISDN rental only or be expanded to include other higher
Retail Price Cap as a Potential Remedy on Fixed Narrowband Access Markets
33 ComReg 06/41 level access services (e.g., connections)? If so, which ones? Which combinations

Q. 11. Are there any access services, or access products for particular groups of customers, which should be price capped separately on the basis that competition may soon develop to the point where controls can be dropped? If so, please state which services and your reasons why.

Q. 12. In the event of eircom having SMP in the lower and/or higher level access market, does the respondent believe that a cost orientation obligation can be an effective upper limit control in the alternative to a price cap measure? Please state your reasons why/why not

Q. 13. In respect of the options analysed above, is there additional analysis that in your opinion should be carried out? If so please specify

Q. 14. Are there additional factors that in your opinion require analysis by ComReg? If yes, please indicate precisely what they are. In respect of the factors analysed, is there additional analysis that in your opinion should be carried out. If yes please indicate precisely what this is?
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13-09-2006, 10:40   #3
bealtine
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Some choice quotations from the document.

“ComReg has recently assessed the level of competition in the retail markets for lower and higher level narrowband access. Competition in these relevant markets does not yet appear effective. As there will be no significant challenge to eircom’s dominance in narrowband access markets within the lifetime of this review there may be a case for continued regulatory intervention to ensure that eircom does not exploit its market position unfairly in the retail access market and disadvantage consumers.”

Lets state the obvious...

"3.10 The prices that eircom charge end users for line rental and calls have been
controlled since 1996. This approach has been successful in reducing
communication prices overall in contrast to the general rise in other consumer
prices. The following chart compares changes in the communications index
relative to the overall Consumer Price Index:- "

What planet have you been living on?

“3.12 However, concerns remain. eircom has increased PSTN line rental appreciably between 1998 and 2004, albeit within the confines of the existing price cap limit.
From above, the CPI-0% cap, in line with European legislation, recognised the principle of rebalancing to ensure that efficient cost is recovered in an appropriate way. In ComReg’s view, PSTN increases have succeeded in aligning those access prices with cost. In any case, ComReg would not wish to see a significant increase in monthly PSTN line rental charges which are currently the highest in the EU. “


Uhuh so the decision has already been made...
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13-09-2006, 11:04   #4
Sponge Bob
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email retailconsult@comreg.ie with the answer.

you may write whatever you wish in answer to question 14 so if the rest of it gives you a headache or arseache or both just email an answer to question 14

subject

"Consultation on a Retail Price Cap as a Potential Remedy on Fixed Narrowband Access Markets - Part 1."

tell them that we should have EU average line rental of €14 a month, same as our peers in other 'developed' countries and not a penny more
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13-09-2006, 14:30   #5
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Have you a link handy to quote that €14 average back at them? Always looks better with a bit of backing material.
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13-09-2006, 16:09   #6
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Good point its here in section 7.2 (and the link on the IoffL website is wrong) and bugger me but the EU average is 14:80 (EU 25 is €15.30 but would drop below €14.50 and €15 respectively if we dropped TO €15

http://europa.eu.int/information_soc...93_vol2bis.pdf

page with incorrect link to line rental figures

http://www.irelandoffline.org/2006/0...-for-telecoms/

Make it a demand for no more than €15 a month in the interests of EU competitiveness so .
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25-09-2006, 13:37   #7
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*bump*
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26-09-2006, 09:35   #8
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I'm just about to reply to this, but could I get some pointers to data to support our case. That EU report from last year seems a little out of date (or is it the best we have?).

Somehow, simply stating that we pay the highest line rental rate in Europe doesn't feel like a strong enough arguement.
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26-09-2006, 09:39   #9
bealtine
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Quote:
Originally Posted by tom dunne

Somehow, simply stating that we pay the highest line rental rate in Europe doesn't feel like a strong enough arguement.

Not to worry, no matter what beautifully constructed argument you make, they'll just ignore you anyway and grant the increase.
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27-09-2006, 17:22   #10
bealtine
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*bump* *bump*

Get your speak in now!!!!!Tell them you really really want to pay E30 a month for line rental to those nice people that always rush out to fix your line when required.


Only 2 shopping days left...to answer just point 14 in the list above.
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27-09-2006, 18:33   #11
watty
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I told them I'm not playing anymore. Getting rid of phone line due to high rental and poor service.
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27-09-2006, 23:32   #12
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I enjoyed that, I got some anger out haha.
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