Noel, Pull the Rug from Underneath the Impostors in ComReg.



Ref: Telephony tariffs in Ireland

Dear Minister Noel Dempsey,

ComReg continues to misinform the Irish public and the political decision makers about the fact that Irish telephone charges are the second highest in the whole EU (Finland beats us to second place).

1. Since 2001 the EC proposes to compare national telephone tariffs by means of the AVERAGE MONTHLY EXPENDITURE ("composite call basket"):

“The figures ... are intended to provide an estimate of the average monthly expenditure of a “standard” European consumer (business and residential).
The Basket Methodology for Telecommunications Cost Comparison has been devised by the OECD and accepted in most countries as the most stable and neutral method of comparison.”[European Commission document]

In each and every Quarterly Report and in its current consultation paper on the price cap ComReg deliberately misleads about Irish telephone pricing by not publishing the Irish telephone users “Average Monthly Expenditure”, as measured by the OECD’s “Composite call basket”, but instead cherry-picks and selectively publishes only those elements of the OECD’s composite call basket, where Irish pricing is favorable.

The latest EC/OECD "AVERAGE MONTHLY EXPENDITURE" chart shows in no uncertain terms, that the Irish telephone user pays the second highest price (Japan and USA are included in the chart for comparative purposes) of all European citizens.

[Note to journalists, who don’t want to fall for our regulator’s quarterly bluff: You can look up the EC source, from where ComReg selectively picks favorable data from the EC staff working documents section.
All resources can be parsed from the EC staff working documents section (11 = 2005; for previous years change number 11 to: 10 = 2004; 9 = 2003; 8 = 2002; 7 = 2001; etc.)]

Instead of publishing the EC's "most stable and neutral method of comparison", which shows Irish telephone prices being the second highest in the EU, ComReg takes the public for a ride. ComReg goes to surreal lengths with misleadingly publishing four (!) graphs of those parts of the EC measuring method, where Ireland happens to be relatively cheap. (See ComReg's latest Quarterly Report on pages 13, 14, 15)


2. ComReg’s latest trickery:
In various publications our regulatory impostors try to sell us the message, that thanks to their work we are blessed with sinking telecoms pricing, when all other prices are on the rise. Like here in ComReg's consultation document 5/30 (Forward-looking Stategic Review, page 35):



What they don’t say: This is a worldwide development, nothing to do with the Irish regulator.

When the average price development of the European “Average residential monthly expenditure” is compared with that of Ireland, it becomes even clearer why our Isolde, John and Co do not want us to see the only important OECD telecoms price comparison: The European consumer’s average monthly telephone bill is going down, the Irish consumer’s bill is going up.
The following graph compares the development from 2001 to 2005 of the EU and the Irish “Average monthly expenditure”, which measures the average monthly residential user’s phone bill by means of the OECD “composite basket” formula.

The average Irish monthly phony bill is going up – the average European monthly phone bill is going down.

Minister Dempsey,

in the last four years monthly Irish residential fixed line telephony costs have gone up to € 45, when in the same period the European monthly cost has gone down to € 37.40
How much longer will you allow our Communications Regulator to craftily misinform and mislead the public and the political decision makers about this (and not only this) fact on a regular basis in the Quarterly Reports?

Instead of aiming to reduce Irish telephone line rental from € 24.20 per month, the highest charge in all of Europe, towards the EU average of € 15 per month, ComReg suggests for Eircom another – moderate! – line rental price increase (in Comreg lingo, page 9 of consulation paper on price cap, it reads: " In any case, ComReg would not wish to see a significant increase in monthly PSTN line rental charges").

A look at the current position of Ireland's line rental in the European context, shows the madness of the regulator's position:



Noel, do as ComReg currently says with their postcards in pubs: Be a wise guy.

Regards
P.




Illustrations rendered from ComReg's current postcard blitz in pubs all over the country
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