There is a silver bullet, but…


“There is no silver bullet to resolving the broadband problems of this country,” Isolde Goggin, 20/1/2005

Dear Noel,

Unlike to what we say publicly, there is a single silver bullet to solve Ireland’s Internet and Broadband woes...
but it would require to shoot it right through the 2002 communications act which established this monster of a regulatory body.


Failed regulation is the main cause for Ireland's Internet misery. We are the three heads of the stupendous monster ComReg. The genie is out of the bottle. In this case ComReg sprung from the 2002 Communications Act (everlasting revenge of Mary O’Rourke!). Nobody can control us, certainly not you in the Department of Communications.

As you’ve noticed we treat DCMNR policy directions with arrogant disregard:
• You wanted “cheap, always on dial-up Internet access to radically improve Irish home Internet penetration”, we gave you expensive prepaid Internet hours (FRIACO) that naturally were a flop. With only 6% of Internet dial up share FRIACO kept Eircom’s profits high, but our home Internet penetration stagnant at a dismal 36%.
• You wanted Whole Sale Line Rental (specifically not merely single billing) to bring the cost of Irish line rental down – we gave you single billing, keeping Irish line rental at the highest in the EU.
• You asked us to bring "Irish enduser broadband take-up and enduser availability to at least the average EU-15 level by mid 2005" – thanks to our monstrous regulatory failure Ireland is still at second last place with broadband take-up. With a broadband availability of currently 60%, we are probably as well on second or third last place in the EU-15 in this regard.
Isn't it truly awesome to achieve this with an English speaking, young and educated country?
• And we misinform you and the public about our failure; we lie about the 60 percent broadband availability, about our dismal stagnant 36% home Internet penetration, about having the fourth highest fixed line telephony prices in the EU-25.

And here comes the nicest thing: You can do nothing about it. We are accountable to nobody. The Oireachtas Committee members, whom we have to tell once a year what we are up to, well, they are just like putty in our hands. And isn’t it only natural that the Ombudsman has no remit over us?

Good look with your sticky plasters, the MANs and Group broadband schemes...


Yours
John D.


PS.:
We published two documents to further mislead the public about our regulatory failure.
• I've enclosed a commentary to our "Trendwatch" (part of the Quarterly Report) to keep you in the picture, what's really going on.
Download the pdf file here.
View the official Comreg document here.

• Our "Forward-looking Strategic Review of the Irish Telecoms Sector", a 133 pages 'bluff' pulp fiction, where we blather at length about the future, but only after misrepresenting the present, should not be read without seeing the briefing Isolde gave to the authors of the report.
See resources.
Download the official ComReg document here.

resources:

==FOR YOUR EYES ONLY==
Brief for the latest ComReg document “Forward-looking Strategic Review of the Irish Telecoms Sector”:

The Communications Act of 2002 obliges us to show that we have some sort of strategy. Please prepare a document that will give this impression.
I know it ain’t easy, here are some suggestions:
Firstly and most importantly: Make sure very few will read the document. Remember the Churchill quote: “This report, by its very length, defends itself against the risk of being read." So make it at least 130 pages plus.
Secondly: We are clueless and have not much to say about our future strategy, so just waffle in the most complicated form of words about the rather straightforward developments to come: VOIP and the transformation from a switched system to an IP based system. Throw in some stuff about Convergence and Spectrum. Write all in long-winded dissertation style – that will make readers believe we had something important and sophisticated to say.

Important:
Use every trick in the trade to give the impression that we have successfully regulated so far, as people and ministers (!) are starting to point with fingers at us for the cause of the failed Internet and Broadband development in Ireland. The threat of the gov capping our budget by 10% each successive year for the next five years is real!

Some examples how to do this:
1. Irish fixed line telephony prices are now the fourth highest in the EU-25, both for residential and business users, according to the latest OECD composite baskets, which measure and compare the average fixed line customers monthly bills.
This must not become known! So just publish all the sectorial OECD baskets where Ireland is in a more favourable position, but not the conclusive “composite baskets”. Ignore the existence of the “composite basket” and simply lie by saying that “in all PSTN baskets” “Ireland compares reasonable well with...other European countries.” (page 34, Pricing 3.2.1.)

2. To further impress the readers of our success, publish a chart which shows how Irish Telecoms prices have decreased against the general price index. I know this is a worldwide phenomena and has nothing to do with our work, but our Irish journalists and politicians will not notice! (page 35)

3. When we cannot avoid to publish unfavourable tables or charts, always counter their relevance with claims; they can be spurious, nobody will notice: for example:
We cannot possibly avoid to show the OECD ADSL price comparison chart where we are in a very unfavourable position. Simply claim: “It is envisaged that there will be an improvement in this statistic based upon the recent announcement that ...eircom will be increasing the headline speed of its DSL products for the same price.” We know that is nonsense, as the other countries will as well offering higher speeds and lower prices, but our politicians will fall for it. (page 46)

4. We were under the obligation from Dermot Aherns policy Direction of April 2004 and should have achieved for Ireland at least the enduser broadband usage and availability of the EU-15 average.
As we are still on second last place (Greece is our saviour!), we simply make a lot of noise about our huge growth!
And as our broadband coverage is still at a dismal 60% of population, simply mirror eircom’s lies about a current 80% coverage: “DSL coverage in Ireland is currently around 80%.” (page 47) Mention that there are “issues with line failure and distance” (page 48) but write that “alternative technologies such as wireless and satellite can fill this broadband gap.” (page 48)

5. The fact that Ireland is 2 to 3 years behind the development with Internet and Broadband is disastrous. But you can successfully hide even the most alarming facts in sentences like this: “Broadband penetration is accelerating, and following similar trends in other peer countries despite a lag of up to two years.” (page 14)

6. Specifically about this lag: As we have done in a previous presentation to the Dail Committee on Communications, we’ll get a special chart prepared, which will give the impression that we are not lagging, but even doing better than others: by arranging the countries Broadband take-up to a fictive starting point. Nobody questioned this cheap trick chart the last time, so we should come away again. (chart especially fabricated for ComReg by “Analysys” on page 15)

7. Have “Analysys” prepare a list of “milestones”, which can include any bullshit they can come across:
Even something like the cynical PR exercise of Eircom’s “broadband trigger” programme (you know the one where eircom offered to broadband enable smaller towns if demand was shown, but had set triggers of up to 500% of the population and did not even bother to have their demand-website register the demand!) can be included: “Milestone February 2004: Launch of broadband trigger scheme by eircom for 150 communities of less than 1500 population.” (page 124)

This is our 40th blog. Reason to send our Congratulations to ComReg.
Here's the front and back of the card dedicated to the Commissioners and staff:

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