Damien Mulley

33 candles are lighting for Michele Neylon as he celebrates his birthday today. Everyone wish him a happy birthday and sing him out of tune copyrighted songs!

Forfas asked IrelandOffline to give our views on their recent Broadband Benchmarking Report. They asked a few specific questions and we gave quite a lot of detailed replies.

Increasing Broadband Availability

Given Ireland’s spatial patterns, what are the most effective ways to accelerate the rollout of broadband services to all?

Spatial Pattern Excuse/Myth
Just to be clear – Ireland’s spatial patterns are not unique in the developed world. Northern Ireland has 100% broadband availability and a much better penetration rate than the Republic and all with the same spatial pattern. Apart from the very large cities in Sweden, Norway and Denmark, the spatial patterns of these countries are also akin to Ireland and these are some of the leading broadband countries in the world. Spatial patterns are a minor obstacle when phonelines are going
into almost every home in the country already and so therefore can avail of a DSL service if it was provided.

Previous Reports
We believe the best way to accelerate rollout of broadband is for the Government to read previous reports created by Forfas, the Information Society Commission, the Oireachtas Report on broadband and so many more. They have all suggested methods on how to roll out broadband but their recommendations remain unexecuted. This is probably the biggest obstacle for broadband roll out.

Regulation
Additionally the quality of regulation in Ireland is not on-par with other EU countries such as the UK and Denmark. A strong regulator not afraid to take on telecom giants and who does not capitulate during court actions would create a better environment to provide broadband for all.

C/GBS
We believe that the Group and County Broadband schemes created by the DCMNR are a great way of providing broadband to towns and villages who cannot get broadband through any other means but these projects ideally should only be addressing “blackspots” where there is patchy coverage. Instead it appears that 30% of the country would need to set up GBSs if they want to get broadband.

National Wireless Broadband License
We believe that the National Wireless Broadband license that eircom owns should be taken from them and reauctioned to local ISPs who can use the spectrum to provide wireless broadband to rural areas. This 3.5ghz license that eircom owns remains largely unused and is unadvertised and if you try and enquire how to avail of it, you will be told it is not available in your area. We have highlighted this repeatedly to the National Regulatory Authority and we have brought it to the attention of the DCMNR.

Flatrate Internet
We believe that per minute dialup Internet access should be banned and replaced with flatrate bands of dialup. Circa 80% of people still go online using dialup and according to ComReg the average monthly bill for Internet access is around €36. Given that many broadband products are now €20-€30 a month, it means dialup users are paying more for a far inferior product. eircom noted in their SEC filings in 2005 that they sell billions of minutes of dialup Internet. This is a cash cow and an incentive to only rollout broadband at a leisurely pace. The incentive for massive profits from dialup needs to be removed.

Additionally those who cannot get broadband over their phoneline or through wireless should be given the option to be provided with true flatrate broadband where for a price of €30 a month they can avail of 24/7 flatrate.

To implement flatrate bands, the wholesale cost of flatrate needs to be reduced drastically. IrelandOffline has requested that the National Regulatory Authority reexamine the wholesale costs of this service but as per our requests about the National Wireless Broadband license, they have not looked into it, to the best of our knowledge. IrelandOffline question how 180 hours of dialup Internet costs €26.99 when a 1mb always on dsl connection now costs €20. Those suffering on slow dialup should not also have to suffer extortionate costs.

Line Failure Rate
The failure rate of lines connected to broadband exchanges is atrociously high in Ireland with rates of 20-25%. The current enabled exchanges are in mainly urban areas and we believe that as more rural exchanges come online, the line failure rate will increase.

We believe that a mandatory directive should be put in place so that if a line fails the broadband test then it will have to be
investigated by an engineer and replaced if necessary so that it does pass the broadband test. If doing this costs an unreasonable amount then the customer should be provided with a subsidised full flatrate dialup product.

Functional Internet Access
Currently lines in this country must be able to carry a dialup speed of 28.8k. However the regulations for this allow multiple loopholes so many will not even gets 28.8k. We believe that FIA should be once again reexamined so that a line should be able to carry a speed of 42k. This will result in a faster dialup experience for those on dialup but it will also ensure that the quality of the line will also allow it to carry a broadband signal, so that if the exchange the line is on is enabled, then it is guaranteed to pass the broadband line test.

This FIA speed would also mean line splitters would need to be abolished or upgraded to line splitters that can carry a DSL signal. Currently as previously stated, a low speed FIA means the quality of phonelines can be substandard so that they cannot carry carry broadband signals and the dialup signals it does carry are slow enough that it could take twice as long to download something compared to another dialup user on a better line. This means that a telco will make more money from a dialup user on an inferior line. This incentive to profit by not investing in a high quality network must be removed.

National Broadband Authority
Much like the National Roads Authority has helped bring Ireland into the modern era with our road network, we would like to see a body charged with working on bringing about broadband for all. A body that is in charge of linking all the broadband assets together. Additionally the body could link with smaller ISPS and GBSs to provide Government assets for them to use to put up antennae and masts and possible space for data centres.

Planning/Ducting
We believe that the planning regulations for ducting differs from council to council. A standard regulation for ducting is needed and one that provides a cheaper and transparent rate than is available currently. To aid competition, providers should have the means to rollout alternative infrastructure like fibre at a cost that is reasonable.

Internet Usage
Internet usage in Ireland remains unchanged for the past 2-3 years with a usage rate of 37%. This seems to say that those online are moving from dialup to broadband. If this rate of transfer continues it will mean we will get more people on broadband but our overall Internet usage will not increase. The only way to match the rest of the EU and the developed world is to get more people online and bring the 37% figure up to 60% or more. It needs to be researched if those using broadband are just moving from dialup and see are there new Internet users who start off with broadband.

Increasing Competition in the Market Place

How can Ireland accelerate the effective implementation of local loop unbundling to provide competition in the DSL market?

LLU is a failure in Ireland through major incompetence by the NRA. LLU was directed by the EU over 4 years ago and is still not correctly implemented in Ireland. In Feb 2005 the NRA after months of discussions with the OLO sent directives to the incumbent which would have created an environment where LLU would have worked and thrived. After a court case over a point of law and NOT the directives themselves the NRA withdrew all these directives and agreed with the incumbent that the incumbent would created a Market Requirements Document. This was released in October and basically stated that it did not like the idea of LLU and would not make LLU provision an easy task.

It is now 12 months later and none of the issues which the OLOs have been complaining about for the past 4 years have been addressed. We would like to see the National Regulatory Authority reissue these directives.

Additionally we would like to see the DCMNR direct ComReg to bring the LLU rate on a par with the EU Average and to transparently report on Ireland’s ranking compared to the EU on a 3 monthly basis.

Further to that we would like to see an independent LLU adjudicator created, as OfCom did in the UK.

How can Ireland optimise the use of state-owned infrastructure to increase availability and choice of broadband services?

There have been numerous reports suggesting how to link up state-owned fibre and using it to link up MANs and fibre corridors. We’d support previous suggestions on this initiative.

We understand that a private company has been tasked by the Office of Public Works to engage with telcos to rent them roof space and property space. However it seems they will only work with large players like Meteor, o2 and Vodafone. We would like to see Government assets used so that Group Broadband Schemes and smaller ISPs providing broadband to those in less urban areas can use these resources to bring broadband to those that still cannot get it.

Creating Awareness to Increase Demand

How can Ireland best use experiences/initiatives in leading countries to create awareness and drive demand?

We should be looking at the regulatory model of the UK and of Denmark. The majority of countries in the EU have shown how to address the issues of broadband by regulating properly. Ireland needs to do the same. We should bring over the leading people from Estonia who made the country a success in terms of Internet usage.

Are there local initiatives that have been successful in some regions in Ireland that can be used as a template for other parts of the country?

Casey Cable in Dungarvan, Community broadband schemes done by the likes of WestNet. Look at the model in Northern Ireland. 100% broadband availability in a few short years.