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Thanks for your Directive stabilisers.
Dermot,
Thanks for your Directive stabilisers. They arrived in the post the other day including the illustrated manual.
We understand your reaction after our embarrassing accident with the line rental and have already mounted your directives.
We look a bit awkward now all right.
We are glad you took us out of the A or OECD class. We would not have had a snowball's chance in hell anyway to reach your government's previously proclaimed goal of making it to one of the first three places in that league by 2005.
In the B or expanded EU class, we will have a fair chance. We only have to beat newcomers Lithuania, Latvia, Poland, the Czech Republic, Hungary, Slovakia and Greece to make it to the middle as you asked us.
Thanks for your ongoing support.
John
P.S.: Your spokesperson managed to justify your u-turn on the governments broadband goals so eloquently: “Instead of setting a goal that we might not have be able to achieve, we’re setting a goal that we can achieve. The timeframe has changed but the goal is the same: we want to be among the top ten OECD countries.” I just like it how he misleads the public about the initial goal: Ireland claimed to be within the top 10 percent of OECD countries by 2005, not within the top 10 countries! But even to reach a place within the top ten is now buried anyway. To beat Poland will do fine. (Full silicon republic article in the resources below.)
resources:
Revealed: Government moves broadband goalposts (From silicon republic)
12.02.2004 - In an apparent admission of failure, the Government has dramatically rowed back on its own broadband targets, siliconrepublic.com has learned.
In his recent Policy Directions to ComReg, Communications Minister Dermot Ahern defined the Government’s main broadband goal as “to be at, or better than, the EU average for end-user access to and usage of broadband by mid 2005.” Previously, however, the Government’s primary broadband target has been that Ireland be ‘within the top decile [ie, 10pc] of OECD countries for broadband connectivity by 2005’ (Information Society Commission: Ireland’s Broadband Future, Dec 2003).
This would put it on a par with countries like Korea (21.3pc broadband penetration), Canada (11.2pc), Sweden (7.8pc) and the US (6.9pc) (International Telecommmunication Union, Birth of Broadband report, Sept 2003). In fact, broadband penetration in Ireland stands at just 0.25pc.
A spokesperson for the Department for Communications said the Government stood by its objective of putting Ireland among the top ten OECD countries for broadband penetration but conceded that the timeframe had proven “unrealistic”. He commented: “Instead of setting a goal that we might not have be able to achieve, we’re setting a goal that we can achieve. The timeframe has changed but the goal is the same: we want to be among the top ten OECD countries.”
The discrepancy between the old and new Government positions is highlighted by Eircomtribunal, the vociferous lobby group, on its latest web blog (www.comwreck.com/blog_9_feb10.html). The blog claims that the new target for broadband is not a target at all because by mid 2005 – the objective’s set deadline – nine new Eastern European countries will have joined the EU, dragging the EU average way down. Were EU enlargement not to happen, this objective would have been much more taxing, the group claims.
For example, in July 2003, the EU average broadband penetration (broadband connections per 100 people) was 4.65pc. If Ireland were to achieve the equivalent level of penetration – even assuming that the average did not rise further in the meantime – it would need to install 186,000 DSL lines or equivalent, such as wireless or satellite. As of last July, however, fewer than 10,000 broadband connections had been made in the Irish Republic – 5,370 DSL lines and 4,100 other broadband systems (EU Commission: Broadband Access in the EU, July 2003).
The Department of Communications spokesperson denied that the Government was using enlargement to lower its broadband targets. “The objective would have stood if even there was no enlargement,” he said. “And I wouldn’t characterise all accession countires as [backward] – some of them are more advanced than us,” he said.
The spokesperson reiterated the Government’s commitment to broadband. “[Minister Ahern] has driven the broadband agenda non-stop. We are running to catch up but we’ve made massive strides in the last six months. There were a lot of logjams in the system – such as pricing – but these are being removed.”
In ‘Ireland’s Broadband Future’, the Information Society Commission draws attention to Ireland’s fanciful broadband objectives, saying that there would need to be a fiftyfold increase in the number of broadband connections in Ireland by March 2005 in order to reach the top-end forecast for the EU as a whole –12pc. The report further projects that, assuming that broadband is freely availably at an economic price, the proportion of Irish households to have high-speed internet access by 2007 would still be no more than 9pc.
By Brian Skelly
Draft
Policy Directions to ComReg (from the Department of Communications, Marine and Natural Resources)
Introduction
1. Section 13 of the Communications (Regulation) Act, 2002 empowers the Minister for Communications, Marine and Natural Resources to issue policy directions to the Commission for Communications Regulation (Comreg) to be followed by Comreg in the exercise of its functions. In February 2003 the Minister issued a series of policy directions to Comreg. In November 2003 Comreg reported to the Minister on its progress in implementing these policy directions. This document primarily focuses on suggesting new policy directions moving forward.
It is intended that new policy directions will be strategic, aimed at removing key constraints to competition, industry focussed, measurable and will complement the work programmes of the Department, Comreg and the new European regulatory framework.
2003 Market developments highlighted by Comreg
2. In its letter of 7/11/2003 reporting on progress in implementing the policy directions issued by the Minister in 2003, Comreg draws attention to developments in the Irish market since the publication of the last directions:
• New Regulatory Framework
• FRIACO which has now reached over 50,000 take up level
• Mobile number portability which was introduced on 25 July and over 65,000 numbers have been ported since then
• Market Analysis is well underway in connection with review of existing SMP obligations
• Continued increase in broadband availability through a variety of platforms – DSL, leased lines, cable modem, wireless and satellite. At the end of December 2003 there were over 31,000 installed broadband subscribers.
3. Key Government and private sector Initiatives on Broadband
• Connecting 88 towns of 1,500 population to broadband
• Proposals for a new group broadband scheme – similar to group water schemes – where smaller rural communities can pool their demands and secure high speed connectivity from a range of providers in the Irish market
• A guaranteed spend of €140 million from Government committed under Multi Annual Budget approval representing €35 million annually between now and 2007
• Tougher fines against those infringing telecommunications laws
• EsatBT/ESB initiative to improve national backhaul price competition
• Eircom initiative to rollout broadband
• Ongoing discussions between Government and the Telecommunications Internet Federation on the provision of broadband to schools
• Establishment of an operator neutral managed service entity (MSE) to facilitate operator access to the metropolitan area network (MAN) infrastructure.
4. General Policy Direction
i. Competition
a) Reason for the proposed direction: The creation of sustainable competition between other authorised operators (OAO) and incumbents across different technical platforms and markets will benefit the economic and social development of Ireland by increasing the choice and decreasing the price to consumers and businesses. There is a need to continue to increase competition in the Communications Sector. In the fixed market the OAOs’ market share has been in the 20-21% range for the last two years. In the mobile market Meteor now accounts for 5% of this market with Vodafone and 02 having 56% and 39% respectively (1). The fourth mobile network operator “3” launched its services on 30 September 2003.
b) Proposed policy direction.
Comreg shall focus on the promotion of competition as a key objective. Where necessary, Comreg shall implement remedies which counteract or remove barriers to market entry and shall support, in all ways possible, entry by new players to the market and entry into new sectors by existing players. Comreg shall have a particular focus on:
• market share of new entrants;
• price margins on offer to operators at the wholesale level with the goal to ensure that such price margins will incentivise and advance competition;
• price level to the end user;
• competition in the fixed and mobile markets;
• possibilities for incentivising alternative technology delivery platforms to support competition.
(1): Source Comreg quarterly key data December 2003
5. Fixed
i. Broadband
a) Reason for proposed direction: The development of broadband is a key enabler to enhance and maintain Ireland’s economic and social development. It is important that the regulatory environment underpins the development of available, affordable and competitive broadband services.
b) Proposed policy direction
Comreg shall use regulatory and enforcement tools, where necessary, to support Government initiatives and remove regulatory barriers, if any exist, to such initiatives to develop broadband. In encouraging the further rollout of broadband Comreg shall have a particular focus on:
• the residential and SME sectors;
• balanced regional development and;
• incentivising broadband provision on alternative platforms.
The Goal is to be at or better than the EU average for end-user access to and usage of broadband by mid 2005.
ii. Proposed policy direction on wholesale and retail telephone line rental
a) Reason for proposed direction: The number of local access lines supplied on a wholesale basis by the incumbent to OAOs is quite low (2). The direction recognises the importance of single billing wholesale telephone line rental to advancing competition.
b) Proposed policy direction:
The Minister directs that Comreg will introduce by 31 March 2004 a single billing wholesale line rental product for voice and data services. Comreg will ensure that the margin between wholesale and retail is wide enough to drive competition, that the product is accessible, affordable, available for telecommunications operators, and contains any other conditions required that will incentivise and drive competition in this market. Comreg will report to the Minister no later than 30 June 2004 on the effect that the single billing product has had on competition in this market and whether it is delivering lower prices. If this product is not in place by 31 March 2004 and if it is not delivering verifiable competition and lower prices by the 30 June 2004 the Minister will direct Comreg to take line rental out of the present price cap, and to set a specific rental cap no greater than CPI plus zero.
(2): Source Commission working paper:- Ninth Report on the Implementation of the Telecommunications Regulatory Package – Annex 1; 19/11/2003 doc SEC(2003)1342
iii. Interconnection/Leased lines
a) Reason for the proposed direction: The pricing structure of interconnection and leased lines is an important element of promoting competition in the telecommunications market.
b) Proposed policy direction: Comreg will review the pricing structure for interconnection and leased lines having regard to developments at EU level. Comreg will report to the Minister within six months of the date of issue of this policy direction on the areas of the interconnection and leased line sector that are not competitive and identify what additional legislative, regulatory or enforcement measures, if any, are required.
The goal is to ensure that pricing structure for interconnection and leased lines advances competition in the telecommunications sector.
6. Mobile
i. National and cross border roaming
a) Reason for proposed direction: National roaming is seen as a means of increasing competition in the mobile telephony market. The ability to roam nationally on GSM networks would ensure that all three licensed GSM operators could provide countrywide coverage. It is also proposed to cover cross border roaming in this direction. Minimising cross border roaming costs on the island of Ireland would be beneficial for Irish mobile phone users, particularly those who live close to the border.
b) Proposed policy direction
National Roaming
Comreg shall make use of its powers under existing legislation to mandate national roaming on existing GSM networks of incumbent mobile network operators in favour of other Irish mobile network operators on fair commercial terms subject to relevant requirements under European law.
The goal is that agreement is reached between relevant parties, and that such agreement is commercially and technically implemented by the end of 2004.
Cross Border Roaming:
Comreg shall identify barriers, work closely with Irish Operators, the Northern Ireland Regulator and operators, and use regulatory and enforcement tools to encourage and support initiatives that would: reduce the costs for people on the island making and receiving calls on their mobile phones to numbers within Northern Ireland; reduce or eliminate roaming and other charges on the island between Ireland and Northern Ireland; encourage national call charging on an all-island basis.
The goal is to minimise cross border roaming and other charges on the island of Ireland for Irish mobile phone users, particularly those who live close to the border.
7. Postal
i. Quality of Service Standards
a) Reason for proposed direction:
An Post has obtained significant price increases in the area in which it is a monopoly provider and has imposed significant price increases in the competitive parts of the postal market. In light of these increases, An Post customers are entitled to expect a high quality of service, and, under the European Communities (Postal Services) Regulations 2002, Comreg is obliged to impose and monitor quality of service standards in the universal service area of the postal sector.
b) Proposed policy direction:
In order to ensure that An Post focuses on the delivery of quality service to customers, I am directing Comreg to report to me quarterly on quality service standards being achieved by An Post and, where remedial measures are required to make recommendations in this regard.
8. Reporting
Comreg shall report on its implementation on these directions at the end of June 2004, at the end of September 2004, at the end of December 2004 and at the end of March 2005.
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