The privatization of censorship (an Irish SOPA)

Ireland has in its past, had a time of censorship which was rightfully overturned by right thinking politicians. In those more enlightened times certain politicians eventually saw the ultimate futility of censoring James Joyce and hacking feature films to death..

Eamonn Wallace, Chairman of IrelandOffline said : “under the bullying of the Content Oligopoly we propose to hand over censorship and public policy to private companies. The probable outcome to this is that the likes of IRMA will now be given control over the websites that Irish people can visit and view.”

Wallace continued : “Those videos of your two year old singing “Happy Birthday” will now be targeted as copyright infringement because Happy Birthday is still in copyright and ditty sung by a 2 year old can grossly infringe that copyright in the eyes of a Content Oligopolist.”

Wallace added “All of this is to be sneaked through, without debate, by Ministerial Order to appease the content companies and their supposed fight against piracy. No discussion in the Dail, no interaction with consumer groups, nothing; just a stroke of a Ministerial pen. This is the low level that our democracy has sunk to. This is redolent of dictatorships of the past.
The exact wording of the legislation hasn’t been shared with us and is being produced in secret, and with the probable helpful assistance of the Content Oligopoly, in the hope that the Irish people will neither understand nor care until it is too late. Even then all considerations of Public Policy making will be kicked to touch, into the courts where instead judges will decide on Public Policy. We could then compare ourselves to the extreme situation that pertains in Belarus where browsing all foreign websites is illegal. This is the slippery slope to corporate censorship. There are no rights of appeal conferred on websites that are to be blocked expect an extremely expensive visit to the High Court with all its attendant exorbitant costs. Innovation on the Internet must be allowed to flourish without hindrance, for the good of the country”

Wallace went on to say “Irish politicians seem to misunderstand the basic concepts of the Internet. The Minister responsible for this can of technical worms is Sean Sherlock TD Minister of State in the Department Of Enterprise, Jobs & Innovation. Blocking sites on the Internet is hardly an innovative step.
Politicians just hear “our business is suffering” from entertainment industry lobbyists so “something has to be done” no matter what the damage to the sensitive digital economy is. It’s the law of unintended consequences at work. We risk destroying our freedoms and our healthy digital environment, possibly jeopardising the investment from companies like Google, Facebook  Amazon, Ebay, Paypal and Twitter, just to keep some dying business that is trying to lash out at what it perceives as doing damage to it’s interests. These Internet  companies will be expected to police postings on their websites in case of some alleged “copyright” infringement otherwise they may find their websites blocked by Irish courts and Irish consumers locked out of the Digital world. Risking inward investment should be a red-line issue just like our corporation tax.

Copyright industries are demanding, through the courts, compensation and a bailout from the government and the citizens of Ireland for the failure of their historical monopoly.This is a bizarre situation“

This regressive legislation will damage current efforts to implement a secure Domain Name Service and damage confidence in the security of the Internet leading to damage to consumers computers due to malware and viruses.
As a measure, it is flawed, as any non technical people do not understand the complexity of the Internet and how any possible enacted measures can be trivially evaded.

This, in all likelihood, is illegal and beyond the Minister’s powers, as it doesn’t seem to take into account the Sabam v. Scarlet jugement which clearly states:
“[filtering] could potentially undermine freedom of information since that system might not distinguish adequately between unlawful content and lawful content, with the result that its introduction could lead to the blocking of lawful communications. Indeed, it is not contested that the reply to the question whether a transmission is lawful also depends on the application of statutory exceptions to copyright which vary from one Member State to another. Moreover, in some Member States certain works fall within the public domain or can be posted online free of charge by the authors concerned. “

Wallace went on to say “The Internet is our digital highway and represents the single most important economic, social, and cultural communications tool available to us, we don’t put blocks on the roads to different cities because crime might happen there, indeed not we address the real issue that of crime itself. We accept that artists need to be compensated for their works but the Internet is not the plaything of the Content Oligarchy.
This is a most undemocratic and regressive step, endangering Ireland’s healthy digital economy, jeopardizing inward investment all to prop up a dying business model. It has nothing to do with what consumers want and everything to do with protecting a business based on album sales, vinyl and CDs. Welcome to the 21st century.”

Ireland’s broadband performance slumps
In light of Ireland’s continued decline in the world rankings we in IrelandOffline are calling on the Minister of Communications to put away the continual departmental excuse book and take immediate action to address this dismal performance measurement.

This performance plunge puts us below such Internet luminaries as Moldova,Vietnam, Mongolia since 2010(1) ,Papua New Guinea, Ghana(2) and Kyrgyzstan.

Eamonn Wallace, Chairman of IrelandOffline said : “These are countries in transition or developing economies, unlike Ireland which aspires to be in the top tier of countries for Internet access. Patently this will not be the case as our performance is falling quarter by quarter. The Department of Excuses (DECNR) does not seem unduly worried about this disastrous showing, preferring to ‘spin’ and cling to outdated ideologies. Most of the advances in recent reports have been down to work done by UPC in Cities and Large Towns, however the majority of the country suffers from dismal download speeds and this needs to be addressed urgently if we are to have any hope of matching the EU 2020 Vision ‘knowledge economy’ goals”.

Wallace continued: “The digital divide is widening as as shown by the speeds provided by UPC in mostly urban areas compared to the speeds offered by eircom in the rest of the country. The average eircom speed is now only 4.67 Mbps which demonstrates the pitiful and ongoing lack of investment by eircom in the network.”

Outlook for 2012
Below are the issues most likely to be important and affect consumers/businesses in 2012.

Rabbit, Rabbit Rabbit
For nine months now Minister Rabbitte has been involved in “talks” with a carefully selected and limited number of stakeholders, each with their own self-serving agendas to pursue, on how to rollout Next Generation Broadband in the country. These talks are supposed to be in-line with the Digital Agenda for Europe.The Digital Agenda outlines the following:

• Access to basic broadband should be available to all citizens by 2013:
• Access to broadband with speeds of 30 Mbps or above should be available to all

citizens by 2020

Neither of these two goals will be met. 3G is not Broadband, nor will it ever be whatever the promises of LTE. The most common cause of disconnection in 3G is when the cell shrinks under load in the evenings leaving customers with NO signal for hours.

However many of the most important stakeholders have been openly excluded while useless 3G operators are inexplicably included. 3G providers can never deliver anything like 30Mbs no matter what green field produces this week’s thinking in the DCENR. Where are the Fixed Wireless ISPs and the dark fibre providers in these discussions? These infrastructure providers are the operators that will more likely deliver the necessary infrastructure required to satisfy the Digital Agenda for Europe. Fixed wireless uses available spectrum up to eight times more efficiently than 3G mobile midband does. Where are the representatives of consumers/businesses? Nowhere to be seen.

The imminent collapse of eircom

The destruction of eircom is nearly completed, insanely high line rental charges have led to a decline in lines in use. Greedy venture capitalists and bankers have serially destroyed the company. So much for the much trumpeted “fully liberalised market” that was supposed to deliver improvements to the network for the benefit of Ireland.

The looming disaster at eircom as reported in many news reports seems likely in the near future.
The decision by Singapore-based majority shareholder ST Telemedia (STT) not to meet the extended deadline for submitting a modest proposal on the restructuring the company’s €3.7 billion net debt, citing Euro zone instability, has thrown all existing plans into chaos. All that is left are proposals from the various lenders on how to restructure the company. This will likely lead to examinership of the company and ongoing turmoil into 2014.

(1) http://irelandoffline.org/2010/05/what-are-the-mongolians-doing-right/
(2) http://irelandoffline.org/2011/10/what-the-ghanaians-can-teach-the-irish/

IrelandOffline Quarterly Report Q4 2011

The latest Irelandoffline Quarterly report, based as always on Ookla Netindex Data shows Broadband Speeds in Ireland are worse than ever. Ireland has dropped to 53rd place with an average download speed of 7.86 Mbps. Ireland has plunged a catastrophic eight places in the download world rankings in this quarter alone.

This dismal performance rating leaves us behind many Internet luminaries such as Moldova,Vietnam, Mongolia ,Papua New Guinea, Ghana and Kyrgyzstan.

Poor performance is disappointingly accompanied by misleading advertising and high prices.

Ireland is the 5th worst in Europe for under-performance against service promise and the 3rd most expensive in Europe in the service cost per Megabit per second.

In Quarter 4 2011 Ireland’s Position is as follows:

Ireland is  53rd in the World  for Download Speeds and 24th out of 27 in the EU (45th/24th Q3 2011)
Ireland is  71st in the World for Upload Speed  and 24th out of 27 in the EU (72nd/24th Q3 2011)
Ireland is  23rd in the World up for Quality and 18th of *25* in the EU (24th/18th Q3 2011
Ireland is  53rd in the World for  Promise and 23 out of 27 in the EU (45th/24th Q3 2011)
Ireland is  43rd in the World  in cost per Mbps and 25 out of 27 in the EU (New)

IrelandOffline notes that since  our new  Minister for Communications Pat Rabbitte assumed office in late Q1 2011 the improvements to Ireland’s Broadband Performance rapidly levelled off and our performance has now gone into full reverse with a drop of eight places in download speeds during the past quarter. We feel that Minister Rabbitte has had quite long enough,  nine months in fact, to learn his Departmental ‘Excuse Book’ off by heart and now the necessity for strong action is required to stem our inevitable slide.

In our Q3 Report, Irelandoffline observed that ”This improvement in cable broadband speeds keeps Ireland largely static in the international tables instead of falling back as expected.”

These improvements have largely tailed off, the limited launch of eircom Fibre to the Home and to the Kerb Products during the past quarter had no measurable effect on eircom performance   and we are  falling down the rankings again simply because competitor nations continue to systematically invest and improve as compared to the mess Minister Rabbitte presides over.

The Urban Rural divide as implied by the gap between UPC and eircom continues to grow. The average UPC customer enjoyed three times the speed of the average eircom customer in Q4 2010 and the performance gap in Q4 2011 now shows UPC is on average over four times faster than eircom.. This improvement in cable broadband speeds kept Ireland largely static in the international tables over much of the year but can no longer deliver a sufficient performance to keep us static in International Comparison tables.

Table of Download Speeds ( in Mbits) UPC vs Eircom

UPC       Eircom      UPC/Eircom Ratio
Dec 2010     12.21       4.01                     3.04
Mar   2011    14.4         4.4                       3.27
June 2011    17.62       4.59                     3.84
Sept 2011    18.11        4.57                     3.96
Dec  2011    18.84       4.66                     4.04

Recently cabled towns, typically towns with populations between 10,000 and 30,000 are now vastly outperforming  our main cities which are the main employment centres. UPC cable is largely confined to residential areas rather than core employment centres in the cities.

The fastest speeds in Ireland are in Dungarvan County Waterford where the local cable ISP, Casey Cablevision (not measured), now deliver average speeds of 23.09mbits. In second place nationally is Athlone  on 17.48 mbits and Swords Co. Dublin  has dropped to from second place in Q3 to  third in Q4 on 15.12 mbits.

The top 10 Towns have an average speed of 13.16mbits in Q4 up from 12.64mbits in Q3 2011

Ireland’s top ten cities/towns and download speeds
1 Athlone        17.48 Mbps
2 Swords         15.12 Mbps
3 Celbridge         14.12 Mbps
4 Waterford         13.60 Mbps
5 Clonmel        12.35 Mbps
6 Lucan         12.24 Mbps
7 Greystones         11.89 Mbps
8 Maynooth         11.78 Mbps
9 Tallaght         11.62 Mbps
10 Mullingar         11.11 Mbps

As ever none of the big Cities are in the top 10. Dublin is in 13th place on 9.54mbits and Cork is in  20th place on 8.33mbits in Q4. Dublin has nevertheless dropped to 13th fastest overall in Q4 from 12th fastest in Q3.

Average eircom speeds in Dublin and Cork  all increased but average UPC speeds increased by a notably greater amount.

Table Showing Operator Speeds In The Main Cities, Q4 2011.

EU Download Speeds Q4 2011.

EU Upload Speeds Q4 2011
EU Download Speed Performance Gap
Google Netindex Visualisation (Select Download Speeds) January 2008 (Source)

Google Netindex Visualisation (Select Download Speeds) November 2011 (Source)

UPC Speed Comparison.

While UPC speeds continue to rise in Ireland they are also rising in other UPC Territories in the EU. UPC Ireland is much slower than UPC in Holland Germany and Austria.

Notes:

Click on an INDIVIDUAL country inside a listing for City and ISP Statistical Drilldowns.

Download Index http://www.netindex.com/download/
World (All Countries) http://www.netindex.com/download/allcountries/
EU http://www.netindex.com/download/1,7/EU/
Town and City Speeds http://www.netindex.com/download/2,49/Ireland/
Upload Index http://www.netindex.com/upload/allcountries/
Quality Index http://www.netindex.com/quality/allcountries/
Promise Index  http://www.netindex.com/promise/allcountries/
Click HERE To get a Visualisation (press play button to see the last 3 years)

IrelandOffline, a leading consumer advocacy group in telecommunications warmly welcomes the announcement that a major transatlantic fibre will be landing at Belmullet in County Mayo. The cable is low latency (sub 60ms) and is a huge increase in the inter-connectivity into Ireland. The route this cable takes is only 5200Kms which is the shortest route across the Atlantic. The fibre consists of 100 x 100 Gbps per Fiber Pair (60Tbit Total Design Capacity and is Future Proofed)
Eamonn Wallace, Chairman of IrelandOffline said : “This is a great day for Ireland as this fibre cable will bring much needed international transatlantic traffic to Ireland. The cable will be a low latency cable and follows the “Great Circle route” which is the shortest transatlantic route by far. This is the optimal route across the Atlantic and cables should follow this route in future. Low latency is a key driver in international e-commerce and financial trading between major financial centres. This shows the importance of the west coast of Ireland as a landing point for trans-Atlantic fibre transit. We in IrelandOffline look forward to more fibres making landfall in this region and to the region becoming a hotspot for international connectivity”
Wallace continued : “The landing of this fibre outlines how Ireland is now well served for  international traffic, we now have two new cables between Dublin and Wales coming online which will allows for cheap and rapid transit across the Irish Sea. The Welsh regional authorities have installed a fibre to connect these  to the UK core fibre network. This will allow very fast transit across the UK to London and Europe”

Wallace went on to say : “Now all we need to do to utilize this fantastic interconnectivity available to us is to improve the dark fibre provision throughout the State. Building a National Dark Fibre network  will help access in the local access network (the network that connects homes to local POPs and the MANs). This is now an urgent priority for Ireland Inc if we want to advance into the digital age and to benefit all the hard-pressed consumers of Ireland. Limited fibre rollouts (to a few isolated towns) and building stranded MAN networks with no backhaul is not a proper solution.  How is Ireland to benefit from this new digital age if the New Era (and Labours equivalent) are to be left on the shelf and ignored? If we do not do this we risk falling behind,  the likes of China(1) and Brazil(2) are building Next Generation Networks so should we.”

Minister Rabbitte is to present the results of his ‘New Era’ discussions with a very small list of stakeholders in the Irish Telecommunications sphere this December. Levelling out access between regions and to Dublin through the removal of barriers to market entry must be the starting point otherwise this latest talking shop in the DCENR will go the way of most of its predecessor deliberations, i.e. into oblivion and sit on a shelf somewhere.

(1) http://www.telecoms.com/30287/alcatel-lucent-selected-for-broadband-china-fibre-cities-project/
(2) http://itdecs.com/2011/07/brazil-tech-the-national-broadband-plan/

IrelandOffline, a leading consumer advocacy group for telecommunications, have to question the commitment of our new Minister to his brief in telecommunications. We looked forward to a notably intelligent Minister engaging with and changing the  “do nothing” culture that has ruined  his Department and his Country, however we just see a continuation of the old tired nonsense coming out of his Department. Recycling may be good but the continual recycling of tired old excuses is wearing very thin after 6 months..

Eamonn Wallace,chairman of IrelandOffline, stated “Thus far the new Minister has been parroting word for word the same old excuses that his predecessor Eamon Ryan used to use to justify doing nothing in particular except of course to make vacuous speeches on finance issues.
First we had the exact same answers to questions as Ryan used to use and now the same old excuse that mobile midband is delivering broadband to rural areas and somehow this meets the requirements of the Digital Agenda for Europe, obviously this is patent nonsense. The Digital Agenda for Europe is about providing 100% coverage of 30mbits for all by 2020, something that is technically impossible on 2x5mhz slices of mobile spectrum.

Minster Rabbitte loves to say and does so at every opportunity:
“In cases of market failure the Government will intervene, where it is appropriate and possible to do so. The National Broadband Scheme (NBS) represents such an intervention. Broadband services are now available throughout the entire NBS area.”

Then the same old nonsense of Ireland having a “fully liberalised” market when there is only one supplier of telecommunications in the vast bulk of the country”

The provision of the “last mile” is an urgent issue and successive Ministers have ignored the issue for many years, the only Minister to achieve anything in this area was Dermot Ahern in his time in the Department of Communication but that was a long time ago now. Since then nothing has happened except for more platitudes and excuses.The only solution to our problem is proper fixed broadband in areas not currently served.

Wallace continued “Thus far the Minister has said absolutely nothing new, has not done anything of value for hapless Irish consumers. We have the highest telecommunications costs in Europe and all we hear is that “everything is fine” and we are doing just great so nothing will be done. This is most unsatisfactory. Minister Rabbitte has gathered the CEOs of the larger telcos and ISPs into a Task Force of some sort and  they have met periodically since his ministry started. The Minister has eschewed informing any of his parliamentary colleagues of any of the deliberations of this particular group save to say that they are finalising something shortly.”

What The Ghanaians Can Teach The Irish!

Eamonn Wallace Chairman of IrelandOffline wishes to remind Pat Rabbitte that under Section 13 of the Communications Regulation Act 2002(1)  it is possible for a minister to give a policy direction to Comreg. No other Minister since Dermot Ahern has given such a statutory direction. We sincerely hope that Minister Rabbitte will prove to be a different and decisive Minister? One  that looks after the interests of Irish consumers, the forgotten voice in the NewERA planning.

Information recently received by IrelandOffline suggests that eircom is finally switching all its Fixed Wireless Access (FWA) customers to cellular technology leaving the spectrum clear and free for other uses and other suppliers.

According to Wallace, Pat should ring up his counterpart in Ghana for a few tips first.
eircom have been squatting on huge blocks of spectrum, for a long time now, particularly in the 3.5Ghz and 2.3Ghz bands. Much of the 2.6Ghz band that UPC was issued with is rarely used.
These blocks of spectrum could be used to provide urgently needed rural broadband options.
Spectrum squatting is grossly anti-competitive and should not be permitted when blatantly used  to block other operators from providing badly needed services.

According to an Oireachtas report from March 2006 , eircom has used its FWA licence in only 80 locations and supplies broadband using FWA to just 250 customers, whereas the spectrum could have been used to offer broadband to the whole country. The same Oireachtas report suggested eircom may have been “sitting on this licence”.(2)

Wallace added : “These key spectrum blocks should be removed from their current squatters and reallocated to other users/companies that are sorely in need of the required spectrum. All it takes is political will and principle-based clarity of thought.”

Wallace suggests that Pat pick up the phone and speak to the Hon. Haruna Iddrisu in Accra who will give him some excellent advice on how to handle spectrum squatters here in Ireland.
His Ghanaian counterpart simply directed the regulator to take spectrum back once any operator has evidently squatted it for 3 years.

“To that end the ministry has given the National Communications Authority (NCA) a policy directive to revoke any assigned frequencies that have lain dormant for the last three years and reallocate them”

“Swift, clear and eminently just. Over to you Minister” concluded Wallace.

—————————
Notes.

(1) Section 13

“13.—(1) In the interests of the proper and effective regulation of the electronic communications and postal markets, the management of the radio frequency spectrum in the State and the formulation of policy applicable to such proper and effective regulation and management, the Minister may give such policy directions to the Commission as he or she considers appropriate to be followed by the Commission in the exercise of its functions. The Commission shall comply with any such direction.

(2) Page 12 of report here: http://url.ie/24y

IrelandOffline Quarterly Report Q3 2011

The latest Irelandoffline Quarterly report, based as always on Ookla Netindex Data shows Broadband Speeds in Ireland are improving but only at a glacial rate in the last quarter and with a marginal relative drop in download speeds against our EU competitor countries.

In Q3 2011 Ireland’s Position is as follows.

Ireland is 72nd in the World for Upload Speeds and 24th out of 27 in the EU (79th in Q2 2011)
Ireland is 45th in the World for Download Speeds and 23rd out of 27 in the EU (49th in Q2 2011)
Ireland is 34th in the World for Quality and 18th out of *25* in the EU (38th in Q2 2011)
Ireland is 52nd in the World for ‘Promise’ and 23rd out of 27 in the EU (52nd in Q2 2011)

The large speed increases during Q2 by both eircom and UPC restored our relative position in the EU back to where it was in May 2010 but these speed increases tapered out of the statistics during Q3 2011 with eircom showing a drop in download speed and with the improvement against our EU Competitors largely stalling. Upload speeds have improved, largely driven by cable.

The gap between UPC and eircom continues to grow. The average UPC customer enjoyed three times the speed of the average eircom customer in Q4 2010 and the performance gap in Q3 2011 is now nearly four times more. This improvement in cable broadband speeds keeps Ireland largely static in the international tables instead of falling back as expected.

Average eircom speeds dropped nationally from 4.59mbits in June to 4.57mbits in September as the rollout of their ‘next generation’ broadband slowed down dramatically. eircom did improve their speed performance in Galway Limerick and Waterford but were only up a meagre 0.01 Mbits in Dublin and dropped slightly in Cork City.

.
The notable trend continues whereby recently cabled towns, typically towns with populations between 10,000 and 30,000 are now enjoying significantly faster speeds than any our main cities and employment centres nowadays.

The fastest speeds in Ireland are in Dungarvan County Waterford where the local cable ISP, Casey Cablevision, now deliver average speeds of 24.3mbits. In second place nationally is Swords Co. Dublin on 16.35mbits and Athlone has dropped to third on 14.58 mbits up from 13.08mbits in Q2.

The 10 Fastest Towns in Q3 2011 average 12.64 mbits up from 11.24Mbits in Q2 2011 and again up from 10.5mbits in Q1.

None of the 5 biggest cities are among the 10 Fastest Towns in Ireland.Dublin in 12th place is the top City with speeds of 10.57mbits on average.

Average UPC Speeds in Cork are over four times higher than average eircom speeds and are 4.7 times faster in Limerick.

This gap has developed significantly over the course of 2011 .

Download Speeds EU

Upload Speeds EU

In January 2008 Our Relative Position Looked like so.

In September 2011 it is starker.

Notes:

Click on an INDIVIDUAL country inside a listing for City and ISP Statistics.

Click HERE To get a Visualisation ( press play button to see the last 3 years)

Download Index http://www.netindex.com/download/
World (All Countries) http://www.netindex.com/download/allcountries/
EU http://www.netindex.com/download/1,7/EU/
Town and City Speeds http://www.netindex.com/download/2,49/Ireland/

Upload Index http://www.netindex.com/upload/allcountries/

Quality Index http://www.netindex.com/quality/allcountries/

Promise Index  http://www.netindex.com/promise/allcountries/

IrelandOffline has performed a technical capacity analysis on total satellite broadband throughput metrics in recent weeks. This analysis was conducted once Hylas-1 and Ka-Sat went live. Hylas-1 and Ka-Sat between them more than quadrupled satellite “broadband” capacity in Ireland.

IrelandOffline has come to the inescapable conclusion that the total capacity of all satellite broadband providers operating in Ireland is less than the backhaul available to the rather small Roscahill exchange in County Galway and indeed that of many small rural exchanges.

Satellite is an ideal broadcast mechanism for television but owing to natural constraints it is not suitable for large scale broadband deployment owing to the speed with which it gets naturally saturated by over-subscription and overselling. The country is littered with victims of this chicanery, many of whom paid enormous sums to get their satellite broadband installed.

Current Irish public policy towards satellite is misguided and wrong, akin to incentivising 4 wheel drive purchases and sending them all down a narrow country boreen….and then wondering why everybody is complaining about the service. ALL Irish satellite capacity together, Ka-Sat, Hylas-1 and older “birds” is much less than 1 Gbps. Probably less than 300Mbps total download speed. Likely less 150Mbps total in moderate rain.  Astra2connect drops to 10kbps in upstream in ordinary rain! This bandwidth is shared amongst all users.

IrelandOffline calls on Minister Rabbitte to recognise this reality, that there is and will continue to be insufficient satellite capacity to adequately service more than a few 100 users nationally in geographically extreme locations where wireless connections are difficult and expensive. ”

Even then in most cases Fixed wireless would be cheaper in long term and in short term deliver real broadband compared with Satellite. Even apart from Capacity issues, the latency (delay due to 152,000 km which even at speed of light is more than 500ms, half a second, more than 10 to 50 times worse than broadband) is never going to be reduced to broadband speeds.
Also due to capacity issues the satellite providers enforce severe Fair Use Policies with rolling caps of maybe 2Gb per month, most now enforce minuscule caps by the hour with download data rates reduced for the remainder of the month if the limit is exceeded. This makes satellite unsuitable for all but the most trivial tasks, so no general Youtube or movie watching.

There is no case for any Satellite so called “broadband” at all in an Advanced country like Ireland. It should be used only for emergency communications. The Majority subsidize, to an extent, phone lines and for all the ESB connections. Anywhere that gets ESB can get Fibre or Fixed Wireless more economically than Satellite and with real net benefit to the economy. All Satellite Service providers are outside of Ireland. The people here are no more than shop keepers and installers reducing the value to the economy. Fibre and Fixed wireless roll outs save money, provide real broadband and create real secure local jobs.

Ireland’s best kept secret

The Rural broadband Scheme was sneaked out in a Press Release and an announcement on the Department’s website on the 9th of May. We have to wonder at the absurdity of this step…surely the people without broadband will not be able to read the website in the first place as the scheme is supposedly designed to deliver a basic broadband service to those people. As it stands now they do not have broadband and therefore cannot access the website. Sir Humphrey (Yes Minister) himself would be proud of the administrative elegance displayed by the announcement.

The Department has been accepting applications from 9 May 2011 and will continue to do so until Friday 29 July 2011. Those with dialup will have to struggle through their graphics heavy website to make an application for the service. There seems to be no other way to apply for the service except through the website.

There will be a number of phases in the Scheme.
The first phase involves inviting and processing applications from potential end customers. The second Phase of the Scheme is supposed be completed by January 2012 by that stage most applicants will be offered an existing services and services under the scheme.

Users that are expecting a decent broadband service from this scheme will be sorely disappointed to find out this scheme is yet another stopgap measure and an excuse to rollout inferior and mostly useless satellite service to areas that currently cannot receive any form of service. Some, as we know, are within 10 miles of cities like Dublin Galway and Limerick

A scheme that delivers before it’s tendered
This is a scheme, although not even out to tender yet, is currently delivering according to the Minister in written statements and speeches. Again more absurdity. How can something be delivering broadband BEFORE people have a chance to apply and most especially where it is generally delivered by third world satellite technology located some 30,000 kilometers away from the Ministers office.

Shortly, possibly even as soon as September 2011, IrelandOffline expect to see another fine Comreg mess, possibly the finest mess of all. It will be in the form of the fifth public mobile licensing round(1)

Despite their having presided over three of these public licensing rounds themselves it seems that Comreg essentially know nothing about mobile technology and couldn’t care less about the end user. But this time it really matters.

The reason it really matters is because Comreg propose to turn off the most successful and widely available mobile service in early 2013 and have evidently not thought through how to replace it. By this we mean the 900MHz GSM service which provides the most widely available voice and text service in Ireland and with at least 99% population coverage today.

There is no reason, short of gross regulatory ineptitude, why there should not be 100% coverage in a small country such as Ireland by now. 100% coverage was understandably not a condition of the original GSM licences owing to cost at the time of issue and no operator today is obliged to cover more than 85% of the population…except that we all know they do. Nor were the original GSM licences amended to require 100% coverage at any stage despite such an objective  being a reasonable and proportionate one for any Telecommunications Regulator in a developed economy.

We do not intend to go back to 85% population coverage again because of some regulatory foul up  by Comreg. 85% population coverage in Ireland is circa 60% Geographic coverage.

Here is what Irelandoffline propose.

1. Voice and Text should be 100% available on day one of the new regime, whatever about data.  This could be done between now and early 2013 (licence expiry) with 100% 1800MHz spectrum coverage as distinct from 70-80% 1800MHz coverage nowadays. Getting up to 100% 1800MHz coverage will itself ensure adequate masts are available to provide very high quality coverage at lower frequencies
2. Universal Data service at minimum 128k should be 100% available after 1 year of the new regime. (in addition to 1)
3. Universal Data service at 1mbit should be 100% available after 2 years of the new regime (in addition to 1 and 2)

To do so will require a completely shared Radio Access Network, (a RAN or shared RAN) owned by one company (RANCO) and  this means:

a) 1 set of masts in rural areas and small towns where operators often do not want to provide a service. Operators may pledge their existing masts to this effort in return for equity.
b)  All licenced operators are required to share these masts, in fact they do not own the masts or the equipment merely the valuable spectrum attached to the masts. In essence they become virtual operators on these masts or MVNOs
c) RANCO, the operating entity, is to be owned by all the licensed mobile operators but run by Comreg or some other entity to ensure full equality of access.
d) It will be much cheaper to supply 100% national coverage with one radio network.(2)
e) This network will require 4000 cells on day one and up to 10,000 cells within 2 years.
f)  Operators can compete with their own network in cities and large towns, which is where they want to compete. Geographically 80% of Ireland is a burden for any mobile operator and they make their money in the remaining 20%
g) It is desirable that RANCO are to be given the Universal Service Obligation in areas where ADSL is not available or programmed to be delivered and also in SAC/SPA and National Parks where population is low and where planning constraints are onerous.  RANCO is to provide low latency (eg not mobile) services in these area in addition to mobile based (3GPP standard) technologies.
h) Other virtual network operators such as Tesco Mobile or An Post may choose to contract to the entire RAN spectrum pool or to an individual operator assignment. This determines whether they can offer data or not, in essence.
h) Finally. Comreg and NOT the operators are to be responsible for the production of all coverage maps at all frequencies in future.

As it stands the existing proposal from Comreg is to close down a working network with near 100% population coverage and another with near 98%  and to replace it with one or two  networks that initially only provides 85% population coverage. This is unacceptable if not indeed criminal. People will literally die as a consequence of this idiocy.

Naturally the loss of service will be more profoundly felt in rural areas and cannot be substituted for with either:

a) The 1800MHz 2G service that continues in operation off current masts as of now (it has inadequate range) and is poorly rolled out. A minimum audited coverage should 98% population for this service, with a defined time period for upgrade and severe penalties for missing target. This band is very much under utilised.
b) The 2100MHz 3G service that continues in operation (even more  inadequate range and cell breathing issues leaving customers out of coverage for hours on end)

However this all means that Comreg should concede that:

1. Competition does not work in most of Ireland contrary to their own delusions over the years.
2. That the RANCO consultation and creation must PREDATE any spectrum auctions.
3. That the New Era NGN plan must have a single network design to plug their fibre backhaul into. Most sites will require fibre from inception or equivalent speed microwave links.
We need the regulatory certainty that all of these concessions will bring.

We in Irelandoffline are not of the opinion that mandatory RAN sharing is a requisite in urban areas but we have no issues with RAN sharing anywhere. We do recognise that very high speed mobile broadband is only possible when operators can pool spectrum to create large blocks on a single mast and so do the operators.  Our problem is that Comreg neither recognise or understand that fact.  Nor will they set a minimum air interface quality of  service at the spectral level, eg QAM16 (we do not expect QAM64 so don’t worry). Yet these should be specified as part of any licensing because the limitations of mobile technology, especially for data, are known.

Time is running short. Hop to it Comreg before you destroy the 2 most valuable networks in Ireland come 2013.

In genuinely advanced countries none of this matters, they have already licenced their new Mobile Spectrum and rolled out their networks. We have not even started the regulatory process.

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Notes

1. The first two mobile spectrum licensing rounds were not public and were for the original Telecom Éireann  088 and 087 spectrum.
The first public licencing round was the notorious ESAT Digifone licence pre ODTR/Comreg.
Comreg carried out the 1800MHz licencing (Meteor won) and the 2 3G licence rounds
One 3g round for Vodafone Three  and O2 and the second for the spare licence won by Smart then eircom.
We will not mention tetra licences and the 3 stillborn National Mobile Data licences from 2005 .

2. RAN sharing can reduce network build costs by 30%
3. RAN Sharing is not new. Sweden did it 10 years ago
4. Speeds and prices post 4g rollout. Source Three Ireland now averages less than 1.8Mbits.