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Dear Dermot,
as usual we released our quarterly success story,aka Quarterly Report with a big hype. While most of the media again simply reprinted our storyline of a massive rise in home Internet connections to 50%, there were a few nasty questions raised for the first time.
But this letter of yours, dated 22. March 2004, is somewhat disturbing is it genuine or did somebody play a trick on me?
Please confirm.
Yours
John
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Dear John Doherty,
When laughing about tomorrow’s Dilbert cartoon on my desktop calendar, I just could not help thinking about your latest Quarterly Report:
You are the pointy-headed boss, your pressman Tom Butler is Dilbert and you think I am the naïve VicePresident. That’s where you are wrong.
What’s the point of ComReg’s Quarterly Reports?
When your survey makers Amarach conclude : “..there has been a small amount of growth in home internet access. Overall use of the Internet has remained mostly unchanged” (Amarach page 28) ComReg sells its Report with the headline: massive 5% rise.
When your survey finds that 38% of all households are connected to the Internet, ComReg come out and misleadingly claim, by some figure trickery “fantastic rise: now every second household is connected to the Internet!”.
When the press questions this figure trickery (using a statistical subgroup), ComReg publicly claim to do as the OECD wants it done, when in reality the OECD unambiguously asks for the figures to be given as the percentage of all households.
When the survey results show that Internet usage, shockingly going down since a year, is recovering, but has not yet reached even the level of one year ago, ComReg are bragging about a 7% rise.
When an amazing 1 in 6 customers complain about their operator, why should ComReg report this as “Only one in six are complaining…?
When line rental has risen by an extraordinary 25% in the last year, solely due to ComReg’s failure to understand how competition works, why should this fact appear in the Report in this term: “…the decline [10% less people think they get value for money from their fixed line telephony] may be due to consumer perceptions of the recent increase in line rental.” Does ComReg suggest there was no line rental increase? Or what?
Your claim “We now have one of the most competitive markets for DSL in Europe” is simply preposterous.
Your call for yet more costly demand stimulation: “We would like to see the continued marketing of DSL coupled with critically important demand initiatives throughout 2004 and beyond”, shows that you of all people have still not understood that broadband is a supply led issue.
Too many important things are left out from your report, simply because of the fact, that they would show ComReg to be the losers they are:
Percentage of people left with no functional Internet access at all, because ComReg has lowered the USO specs for normal phone line connections from 2.4 KB to 0 KB?
Percentage of Broadband availability?
Comparison of Broadband coverage with our European counterparts.
Comparison of Broadband take-up with our European counterparts.
Local Loop Unbundling. How many are unbundled?
Why is Eircom's line rental fault repair situation so abysmal, compared with the ESB and with other European Telcos. Which changes are proposed?
How much profits does Eircom make from its Porn Band 13?
Why can't consumers get Band 13 numbers barred?
Why is Eircom allowed to make huge profits, by-passing premium service number regulation's consumer protection with its de facto PSN11811 service?
Your Quarterly Report, a costly thing to produce, probably somewhere in the hundred thousands of euros, is mostly a worthless piece of rose-tinting PR, trying to create the perception of successful activity by the Regulator.
Instead of critical analysis as the basis for successful and intelligent planning of the future it delivers mostly useless self-praising propaganda.
That is not ComReg's task, my party political PR people can do that more efficiently.
I expect ComReg to produce their next Quarterly Report in an objective, analytical and critical manner, so that it is a useful basis for the future. I am tired of having to direct ComReg for each and every important task but I will not hesitate to do so, if radical improvements are not made with regards to the Reports.
Yours sincerely,

Dermot Ahern
Minister for Eircon and Haddock.
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resources:
ComReg's four Quarterly Report documents and the Media Release can be downloaded from ComReg's website or here:
PR160304.PDF Media Release
04/30a - Irish Communications Market - Quarterly Market Commentary
04/30b - Irish Communications Market - Quarterly Key Data
04/30c - Irish Communications Market - Residential Telecommunications Survey
04/30d - Quarterly Market Report - Internet Survey
Excerpts from the Quarterly Review documents, with comments in red.
Media Release- 16 March 2004
ComReg Quaterly Report survey shows home Internet penetration at almost 50%
A well planned outright misinformation of the public, contravening decency and OECD recommendations on publishing Home Internet usage figures. Irish Home Internet penetration rose by 1% to 38%, according to the ComReg/Amarach survey. The CSO survey even states a lower figure of 35 % Internet Penetration..
The Commission for Communications Regulation (ComReg) today published its latest quarterly report the last quarter of 2003 - which highlights a number of important developments in the communications sector.
These include:
• Home internet penetration has reached almost 50%, an increase of 5% from the previous quarter.
Same lie as in the headline, Mr Doherty. And the media start to question your tricks.
• Of those who use the internet at home, 1 in 5 said they used it daily, while almost 40% said they used it several times per week.
Isn’t that impressive? No, it ain’t. It is “lying with the truth” (Mark Twain): While usage figures have gone up since the last three month, they have not yet again reached the usage level of one year ago (page 18 of the ComReg/Amarach Internet survey). Irish usage figures are absolutely dismal in International comparison. For example: 45% of Swiss people use the Internet at least several times a week, it is 22% in Ireland.
The internet survey findings are supported by the continued strong uptake in FRIACO and DSL lines which are detailed in ComReg’s quarterly report. FRIACO subscribers have increased from 30,000 last quarter to 40,000 at the end of December 2003, with indications that current take-up levels exceed 1,600 per week. DSL has also increased significantly from approx 13,000 to almost 26,000 at the end of December 2003. Take-up levels for DSL lines currently exceed 1,400 per week.
Unfortunately there is nothing to be that jubilant with these figures in 2004.
Tariff comparison data published as part of the quarterly report shows that Ireland has improved to 5 th cheapest in the EU for residential fixed telephony services.
The comparison takes into account recent line rental increases from eircom.
A look at the chart shows two important things (the fact that Ireland "has improved to 5 th cheapest" is irrelevant, as there is not much difference between the bulk of the countries):
1. John Doherty lied to the public when he granted and defended Eircom's recent third line rental hike, saying that this was in the context of lower overall phone prices here compared to the UK.
2. The unique percentage and absolute height of the blue (fixed line price) column in the Irish telephone cost column shows in clearest terms, how ComReg allowed monopoly Eircom to squeeze out any meaningful competition.

Although, the ranking for business fixed telephony has fallen by one place.
Commenting on the latest Quarterly Report, ComReg Chairperson, John Doherty said: “The higher levels of internet take-up and usage are encouraging for continued flat rate and DSL adoption. ComReg welcomes the recent further reductions in DSL prices that has moved Ireland from one of the most expensive locations for DSL to one where some service providers are offering packages with DSL at a price of €30 per month.
We now have one of the most competitive markets for DSL in Europe.
John Doherty, go to Europe before you claim such unsupported nonsense! Ireland still has the highest dsl wholesale pricing in Europe, dismal dsl coverage and uptake. ComReg has allowed Eircom to stunt the Irish broadband market for years. Even with similarly low priced and widely available broadband as in Europe, and we don't have that yet, it will take a long time for Ireland to recover somewhat.
We would like to see the continued marketing of DSL coupled with critically important demand initiatives throughout 2004 and beyond”.
As long as Doherty does not understand that broadband is a mainly supply led issue, more millions will be senselessly wasted with useless demand initiatives and useless regulation based on wrong assumptions.
Comreg March 2004 Quarterly Market Commentary
2 Market Overview
The OAO (Other Authorised Operator) market share remains stable at 20%. It has been in the 20-21% range for the last two years.
All the regulatory “efforts” have failed to open the market and give competition a chance for the last 2 years.
Over the last year Internet minutes caught up and now slightly exceed domestic minutes as a proportion of overall fixed retail traffic, reflecting increased internet usage by SMEs and Residential customers. Internet minutes account for 40% of all fixed retail traffic.
A bad indicator: dial up Internet connection (92% of Internet connections in Ireland) is still the cash cow for eircom.
ISDN lines increased by 6.5% since last quarter to 355,000.
Another bad indicator, especially as Eircom does not provide dsl vial ISDN lines.
DSL take-up has increased rapidly over the last quarter to 25,300 up from 13,350.
Rapidly? Our figures are laughable in the international context.
FRIACO wholesale flat rate services - were launched at the end of June 2003 and there are now approximately 40,000 FRIACO subscribers.
FRIACO was a long overdue lifeline for many overcharged dial-up Internet users. It was introduced years too late and only after the direct intervention of Comms Minister Dermot Ahern. But these figures are nothing to boast about. Many subscribers are on the 10 hours a month level. FRIACO based Internet access is by now a heavily overcharged relic. Slow modem connection, disabling the telephone line, time restricted and the same price as dsl. Uniquely possible in the only West European country where in 2004 broadband coverage is at a mere theoretical 60% of lines (probably much lower in praxis)
Internet
The results of the Amárach residential Internet research show that 49% of adults have Internet access at home, (miniscule footnote: Adults ages 15 74 with a fixed line phone. ) a 5% increase on the previous quarter.
An intentional risible misinformation of the public. Irish Home Internet Penetration has risen by 1% to 38%. (And even this figure is questionable. The CSO survey arrives at a lower figure.) The claimed 5% rise is in the statistical subgroup of fixed line holders and here the rise is due to a very worrying decline of fixed line household (down to 83%) and has nothing to do with growth of Internet connectivity.
When questioned by the press (in this case by “silconrepublic”) about the credibility of using the fixed line figures a ComReg spokesman referred to the OECD praxis of using these figures. When I asked the OECD about their definition of Internet Penetration they informed me of the opposite:
OECD document 22453185.pdf “A proposal for a core list of indicators for ICT measurement, Martin Schaaper, OECD” states unambiguously on page 6 under the heading
“Households’ and individuals’ readiness and use of ICT Indicators:
• Proportion of households with access to a home computer (% of total)
• Proportion of households with access to the Internet (% of total)”
PC ownership at home has also increased with 51% now having a home PC.
Thank God ComReg have no direct influence on that figure. So we are quite normal on that. Of course we would be higher had ComReg not watched on the sideline when Eircom sabotaged the Internet development in Ireland.
PSTN remains the predominant access technology for residential users followed by ISDN.
Dismal as its written here, but much worse when one compares the shocking figures (PTSN 83%; ISDN 9%) with our European neighbours..
There were encouraging signs in this quarter of increased consumer usage of the Internet, almost 1 in 5 (19%, representing an increase of 4% since the previous quarter) use it daily or almost every day; while more than 1 in 3 use it several times a week (39%, representing an increase of 7% since the previous quarter).
Usage figures have increased indeed in the last Quarter; but not to tell the reader that this increase has not even recovered the slide to the level of usage which we had a year ago is telling lies (by telling unimportant parts of the truth).
3.2 Overview
In terms of value for money provided by different telecommunications services, home telephony is still considered to provide excellent/good value for money by the majority (61%). However, this is 10% lower than in previous years (71% in 2003 and 72% in 2002) and the decline may be due to consumer perceptions of the recent increase in line rental.
Only 61%, down 10%, think home telephony is good value for money! ..After granting a 25% price hike to the monopoly, ComReg have the cheek to write this sentence: ”..the decline may be due to consumer perceptions of the recent increase in line rental.”
Almost two thirds of those surveyed (61%) believe that the Irish telecoms market is more competitive than it was in 2003, although this is a slight decrease on the 2003 survey (63%). Almost half of the respondents believe that their bill has increased in the past 2 years.
61% is not "almost two third". Why not write it down as it is: Less people think the Irish telecoms market is more competetive than in 2003.
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Down the Bunny Hole
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Ecapped and Stymied at Every Turn
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The Big Lie: Broadband Availability
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Kathryn Thomas in compromising position
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There is a silver bullet
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Eircom customers' telephone bills
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Isolde Tries to Stitch up Minister
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Welcome to Room 101
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It's the Regulator, Stupid!
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Three Blind Mice
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Too little too late
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Prime Time Transcript Stockholm Syndrome
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Dsl Broadband Coverage Map
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Sec, Lies and Videotape
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ComReg wins B.O.B.
26 September 2004
Part 2: Farewell, Dermot
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ComWreck Consumer Guide.
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Eircon Broadband Trickster Programme.
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How we tricked Bertie and the Committee.
24 January 2004
For heavens sake, is everybody ganging up on me now?
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Not an Idiots Guide, but a Guide made by Idiots
14 January 2004
Dermot, I really had a bad dream tonight.
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Single billing on the horizon.
4 January 2004
New Year cards
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