The quarterly speed survey released today by Akamai1, the company that actually delivers windows patches to your computer every month, has found that Ireland has:

1. The Highest percentage of SLOW connections in Europe at 3.4%2.
2. The 4th lowest percentage of FAST connections over 5mbits in Europe at 9.4%3

Commenting on the results IrelandOffline Chairman Eamonn Wallace said:

“This is utterly unsurprising to us given the sheer number of Dialup and Midband 3G mobile connections in Ireland.
The leading countries in this survey all have wide scale fibre deployed to the home, today.
Irish people are more likely to be looking for that mystical Blue Light on their 3G dongles while up in the attic getting that urgent email out before they go to bed.

The second tier countries with 20% of their population already on fast 5mbit+ connections all have plans to install fibre.
Ireland cannot be accused of Policy Failure because we simply do not have a policy. It would be fairer to say we have a Policy Vacuum.

Furthermore there has been no improvement in our relative and absolute connection speeds since the previous quarterly survey were released.

While we welcome the recent announcements of faster products from UPC and Eircom these will have no effect on the speeds experienced across 80% of the state where ADSL2 and Fast Cable Broadband are simply not available and shall not be available. Sadly there are no major plans to improve the deployment of fast 5mbit+ products beyond a few selected urban areas during 2010″

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Notes

1) http://www.akamai.com/dl/whitepapers/Akamai_State_Internet_Q3_2009.pdf?campaign_id=AANA-6M2S4U&curl=/dl/whitepapers/Akamai_State_Internet_Q3_2009.pdf&solcheck=1& See page 29 of 32
2) http://www.akamai.com/dl/whitepapers/Akamai_State_Internet_Q3_2009.pdf?campaign_id=AANA-6M2S4U&curl=/dl/whitepapers/Akamai_State_Internet_Q3_2009.pdf&solcheck=1& page 29 of 32 At 3.4% even Greece is better at 3% and the AVERAGE is 1.6%
3) http://www.akamai.com/dl/whitepapers/Akamai_State_Internet_Q3_2009.pdf?campaign_id=AANA-6M2S4U&curl=/dl/whitepapers/Akamai_State_Internet_Q3_2009.pdf&solcheck=1& page 29 of 32 At 9.4% we are ahead of only 3 countries in Europe where the average is 19%

IrelandOffline recently did some research on the Irish governments website http://www.broadband.gov.ie and particularly on the supplier list.(1)

We ask Minister Ryan to explain the grossly inaccurate and out of date website his department runs. This shows how low Broadband Provision to Irish People is on the Minister’s priority list. This shoddy and grossly out of date website is beyond a joke in 2010.

75% of the listed suppliers no longer exist. Many went out of business before the end of 2008. About 1/4 of the suppliers actually exist, many by another name or via takeover. 87% of the listed packages are no longer on offer. Who gets 512k Broadband nowadays? Only about 1/10th of packages are valid and available today.

Nor are any Bundle deals shown on the site despite the fact that most new product launches in the past 2 years have been bundles.
One listed supplier, Mediasat, went out of business in March 2008 and nobody in Minister Ryan’s department even noticed, much less the Minister himself. Minister Ryan’s staff can hardly pretend not to know of Mediasat given that many of them were present when his predecessor, Minister Ahern, launched the service in 2004.(2)

This site is the much trumpeted “one stop” shop for people throughout the country in their search for broadband suppliers. It was launched as a “Comparison” site by Minister Dempsey.

Minister Ryan was referring enquiries from T.D.’s about non existent Broadband services on the ground to this shoddy site of his only two days ago, As he glibly told Frank Feighan T.D. on the 20th of January 2010 (3)

“Details of the availability of broadband services in County Roscommon, are available at www.broadband.gov.ie. I would add that the information contained in this website is provided by service providers.”

Eamonn Wallace , IrelandOffline Chairperson said:

“It is somehow apt that the “smart” and “green” policies espoused by Minister Ryan are represented by a website that directly compares nothing to absolutely nothing.
These companies and their packages generally no longer exist just like broadband policy in his own department no longer exists. His www.broadband.gov.ie website has not been touched since 2007.”
IrelandOffline is today offering to take this site over, FREE OF CHARGE, and to bring it completely up to date by the end of February 2010 .

We feel that it is both “smart” and “green” to let the experts deal with the matter and at absolutely no cost to the taxpayer. We guarantee we will have it halfway up to date by the end of January when we delete all the dead companies and their packages.

We await the Ministers assent if he truly wants Irish people to get TIMELY and above all ACCURATE information from his department.”

Notes and References

___________
(1) http://www.broadband.gov.ie/List+all++Services/
(2) http://www.enn.ie/story/show/9396634
(3) http://www.kildarestreet.com/wrans/?id=2010-01-20.1493.0&s=www.broadband.gov.ie#g1495.0.r

We hear a lot of advertising for mobile “broadband” in the media these days, so with that in mind we in IrelandOffline did some research into this new and wondrous type of internet access.
Frankly we were shocked by what we found out…

It’s patently obvious that this method of internet access is really only “dialup with better advertising“.

For the reasons outlined below we have christened this type of mobile internet access as “midband“.

Some facts on mobile midband

* Broadband is Always on. Mobile attempts to connect on demand and may or may not connect at depending on who got there first.
* Broadband is 0.512Mbps, 0.768Mbps, 1.5Mbps minimum depending on country. Mobile can easily be 0.05kbps and on a loaded sector with 10 simultaneous connections is < 250Kbps
* Broadband is low latency, typically less than 50ms, Cable < 20ms and rarely ever more than 70ms. Mobile is 100ms to 2000ms, typically 170ms.
* Contention is strictly controlled on Broadband. Mobile can only control contention by refusing new connections.
* Broadband works irrespective and is unaffected by voice Traffic. Mobile shares bandwidth with voice traffic which has priority and subsidises data by 100:1 to 500:1
* The OECD does not count Mobile as Broadband.
* The FCC does not count Mobile as Broadband.
* Mobile is not Broadband and is typically 16 times less efficient than Fixed Wireless in the same Spectrum.

Mobile midband is well designed for what it is meant to be: a mobile internet access solution, however using it as a replacement for fixed broadband is disingenuous in the extreme.
Using the system as designed in most other countries is not really a problem as these countries have well developed fixed broadband systems in place. If you need broadband then you really need fixed broadband as a mobile systems degrades substantially when a number of users connect to the system.

LTE

LTE is the often touted solution, sadly this is not exactly correct either. Even LTE, if implemented in FOUR times the spectrum that UMTS/3G/HSPA is using today it will only just manage entry level DSL performance. Then, and only if the cells are very lightly loaded, at peak times it would be 5 times poorer. Entry level DSL (1Mbps down /128k up) is no longer regarded as valid target for Broadband rollouts.
Targets now are 2Mbps rural and 10Mbps Urban, sadly LTE can’t do that. Its 100Mbps is peak speed in less than 1% of cell area with one connection only in use.

Backhaul

In the real world, outside of the Mobile Phone companies, most Europeans expect more speed and performance on their Home or Business Broadband connection than an Irish Node-B (3G Cell)  has as back-haul for the entire mast!

In reponse to http://www.comreg.ie/_fileupload/publications/ComReg0986.pdf

(Non Confidential)

Introduction

We would like to take this opportunity to thank Comreg, in advance, for allowing us to respond to this consultation. We hope that this document will allow for proper discussion and release of the relevant
details and documentation into the public domain so that a thorough examination of all the details can be undertaken.

Competition issues

We, in IrelandOffline, are of the opinion that this consultation is a window-dressing exercise and that the market is clearly not as competitive as Comreg wishes to claim.
We do not believe that the market is fully competitive, as we are being led to believe. This is a core issue that needs to be addressed and tackled urgently.

We can see why Comreg would like to claim that the Irish telecommunications landscape or indeed any aspect of the Irish market is a wholly, or largely, functional market and that no undertaking operating within it has significant market power.

Sadly we would observe that in order to do so, any analysis supporting such a position would trend towards a lack of rigour in order to achieve the desired result.

Our view is that a reasonably competitive market exists when certain conditions are satisfied and where this is the case, Comreg is correct in granting specific geographic reliefs from an SMP designation.

National Spatial Strategy

We are most concerned that Comreg have self-admittedly taken no account of the National Spatial Strategy and have not tiered their market analysis, if any, to the different requirements of different towns as outlined in that strategy.

At the most basic level, and following rather than ignoring the National Spatial Strategy:

1. There is a requirement for a hub and spoke analysis to ensure that not all traffic is needlessly back boned and routed to Dublin; and priced as 2 full national traversals in many cases.
2. There should be a demonstrably higher threshold for a declaration of competitiveness in a gateway such as Galway, Cork and Dundalk, as against a hub town such as Ennis.
3. Gateway to Gateway paths, and not via Dublin, should be examined in detail. It is essential that this be done for each set of contiguous gateways towns.

IrelandOffline Analysis

On a National Scale there are only 4 networks in Ireland. Unlike Comreg we are happy to name them:

1. eircom
2. ESB
3. BT
4. UPC

These are the only carriers with sufficient fibre either owned, or leased, by IRU to offer competitive pricing and a number of them are present some semblance of a market (other than a basic cartel) may be inferred to exist.

There are two significant national wireless networks but as they are frequently dimensioned at 155Mbits maximum as they evidently do not have the capacity to lease all of that out in a given locus and cannot be seen as having significant market power in the provision of circuits above 155Mbits.

These currently are:
1. Digiweb
2. Airspeed.

Our contention is that a competitive market exists where 3 of the named fibre carriers have:
A) Lit capacity of 1 x 2.5Gbit wavelength or higher in a town and
B) Where a MAN is functional in a town along with
C) A contiguous mast and a co-location to Tier1, or Tier2, data centre standards where route redundancy may be implemented.

In that case, Comreg should forbear where eircom conclusively demonstrate, additionally, that they have presented capacity to that co-location and have a Wholesale product available in a given town, scheduled in an annex to this document allowing a cost effective route redundancy implementation, via the co-location, to a secondary carrier. This would suffice even if that secondary carrier does not guarantee 155Mbits but a significant fraction of that bandwidth of not less than 30% of the dimension of the primary port.

Further analysis required

IrelandOffline urge Comreg to go back and do this analysis properly, on these stated grounds:

1. Comreg must comply with the National Spatial Strategy and must show such compliance.
2. Availability of Tier 1 or Tier 2 co-location has not been examined by locus.
3. Route Redundancy to that co-location has not been examined.
4. Verification of the minima of lit wavelengths in a given town has not been carried out.
5. Confirmation of completion of Wholesale Route Redundancy circuits to the co-location or openly accessible mast is required together with a Published Product Offer at the Wholesale Level.

The apparent presence of an alternative network on the alleged say-so of eircom is insufficient grounds for conducting this consultation, due to the absence of a proper and due diligence examination of the facts on the ground. Abstract desktop surveys from an office block in Abbey street is not an adequate form of regulation and especially not so in Ireland.

We do not believe that any purpose is served by not stating currently available bandwidth minima and maxima by town, e.g. 2.5Gbits, on commercial or any other grounds that we can think of.

Disappointment

We are disappointed that Comreg have chosen not to examine the provisioning of masts and co-locations in any of these towns. However we have examined them ourselves. Absent the Wholesale Route Redundancy to a co-location we must find most of the initial list to be partially competitive (PC), rather than competitive (C) or not competitive (NC) unless we are certain that a wireless option greater than STM1 (typically STM4) is also available. We apply the same qualifiers to the new list.

Our analysis of the initial list:
Arklow, PC
Carrick-on-Shannon, PC to C
Cork C,
Drogheda, NC to PC
Dublin, C ( in parts, mainly around the M50)
Dundalk, C
Ennis, PC
Galway, C
Letterkenny C (assuming Kelvin is lit, not right now)
Limerick, PC
Mullingar, PC to C
Shannon, PC
Sligo, PC
Waterford PC
Wexford. PC

Our analysis of the supplementary list:
Athlone PC to C
Swords PC to C
Bray NC
Clonmel NC
Naas PC
Carlow C
Portlaoise C

Northern Ireland To Get over 20 Times More Fibre Than The South by 2011.⁽¹⁾

Inward investment is a hot topic in these stressful times and any direct
challenge to our ability to attract this valuable inward investment needs to
be addressed as a matter of utmost urgency.

In early 2007 eircom, announced an unambitious and limited project where they
committed to installing 240 fibre nodes across the state over 3 years, largely
as they were enabling further exchanges for DSL.⁽²⁾

In comparison this week, Northern Ireland announced 1150 new BT fibre nodes⁽³⁾
by May 2011 all to be completed within 18 months.⁽⁴⁾ This investment will  ensure a
MINIMUM GUARANTEED speed of 2mbits for all employers in Northern Ireland by mid 2011.

BT, after winning a competitive tender, is investing more than half the money
with the rest coming from various public funds, including some from  EU funds .

Commenting on the Contract the IrelandOffline Future Technologies Working
Group Chairperson Michael Watterson said:

” ‘Smart’ and ‘Green’ are but an illusion that fools nobody any more.
We need positive and realistic action on these issues immediately
and that requires that fibre be in the ground and fully lit.

The price of failure to compete with our peers in the Global Knowledge economy
is economic oblivion. As our developed peers all move smartly towards the high
speed ‘cloud computing’ future  we in Ireland are left peering through a dark dank
drizzle of failed green policies”

IrelandOffline believe that a concerted and joint effort from all telecommunications
providers is required to address this vast gulf that is now opening up between
the Republic and the North. We, as a nation, need action not more meaningless
platitudes and soundbites about the “Knowledge Economy”.

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NOTES

Northern Ireland is 1/5th the size of the Republic and therefore on a pro rata basis
this investment would, if replicated here, correspond to over 5500 fibre nodes in
the republic and not a mere 240 nodes. Over 20 times more.

It would increase normal broadband speeds for everybody not just businesses and
we in Ireland Offline estimate that 5500 fibre nodes would deliver the same minimum
speeds as Northern Ireland. Currently there are 1200 exchanges in Ireland and a
fibre node is a mini telephone  exchange in a box on  a street corner…but nearer
the customer and faster. We would have nearly 7000 fast broadband
service points in that scenario.

Eircom , at their fastest, enable maybe 150 exchanges a year for broadband, some
with fibre and some without.

BT Propose to enable at a rate of 800 a YEAR which is as many as we installed in
all of our history.

Underlining the importance of fast broadband for a modern economy, Arlene Foster,
NI Minister for Enterprise, Trade and Investment, said: “Broadband is an enabler-use
of these new services will enable our businesses to increase
their productivity, improving the competitiveness of the economy as a whole.

References

(1)http://en.wikipedia.org/wiki/Fiber_to_the_x
(2)http://www.comreg.ie/_fileupload/publications/PDanon.pdf Page 10.
(3)http://www.openreach.co.uk/orpg/products/nga/downloads/Super_fast_fibre_access.pdf BT Fibre to the Cabinet ( Fibre to the neighbourhood not just to the exchange)
(4)http://news.bbc.co.uk/2/hi/uk_news/northern_ireland/8393117.stm

A survey released today by Tariff Consultancy¹ has revealed that Ireland is now the most expensive country in Europe in which to lease Data Centre capacity.

After getting a broadband connection the first reaction of most people and companies is to establish a presence on the internet, usually a web site. However the cost of renting space in a datacentre is prohibitive.

This shocking report is a result of a myriad of policy failings over the medium term since around 2001, not only in the lack of an overall balanced National Broadband policy but also because our only energy policy is to have the most expensive electricity in Europe, by design.

Data Centres are the very heart of any functioning knowledge economy, they are where knowledge and data is stored and distributed. Pricing Irish business out of these Datacentres may seem smart and green to some but this smart green policy will have disastrous consequences over the medium term out to 2015, not least to our GDP.

Ireland Offline calls on Minister Ryan to address these deficiencies as a matter of extreme urgency. Only 2 data centres have opened in Ireland in the past 8 years, one in Cork and one in Dublin. No more are planned.

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1) Tariff Consultancy Website http://www.telecomspricing.com/

2) http://www.telecomspricing.com/news_detail.cfm?item=2592 “The most expensive average Data Centre countries in our survey are Denmark, Switzerland & Ireland (with rates per rack from 1,300 Euro to 1,050 Euro per month), with cage and 50 KVA pricing being significantly less (in Euro per square metre terms).”

Ireland led Europe in the quality price and availability of its Data Centres in 2001. We have built only 2 since, one in Cork and one in Dublin. Data centres are huge computer warehouses where ones data is stored, even though we are supposedly a “leader” in the knowledge economy stakes.

This is a very thorough report. We in Ireland Offline are particularly agitated by the table on page 58 and titled Table 3.4. Country rankings on various speed measures ³ and based on real life user speed. Measurements in those countries excluding Mobile, as this is excluded by the OECD. The data in this table focuses entirely on measuring the performance of technologies that are capable of delivering a consistent and fast user experience, such as ADSL and Cable Broadband and of course Fibre.

_{Of the 30 OECD countries}⁴ _{Ireland came 27th out of 30. This time Greece came out ahead of us and only Poland Turkey and Mexico, among the “developed” nations, came out behind us.}

Were the Berkman centre to include the sub standard Midband Mobile technologies that so obsess our policy makers in its overall speed measurements we could well have come in the bottom two. Thankfully the OECD standard excludes Mobile.

On the 13th of October, Minister Eamon Ryan stood over his lack of policy in the Dáil. Answering questions arising from a recent Ireland Offline press release^5, Minister Ryan glibly told us that⁶

“Dublin is ranked at 87, from a Broadband Quality Score perspective, of more than 240 cities surveyed bringing it within the top 100 cities in the 66 countries surveyed and is classified as meeting the needs of today’s applications.”

Sadly Minister Ryan has deliberately missed the point as he seems to so often do. We pay lip-service to the knowledge economy, however without some positive action on the subject we will never achieve anything more than just another glib “sound bite”.

Dublin is behind almost every capital city in the EU at this point and is rapidly heading for last spot next year, all on Minister Ryan’s watch. All those other capital cities are installing super fast fibre right now. Nothing constructive is being done in Ireland to address these access deficits. Finland have made broadband a basic right to all it’s citizens, it is incumbent on all those that espouse the knowledge economy to implement similar policies in this country. There is nothing green or smart about a communications policy mix that can barely keep us ahead of Turkey or Mexico and that only when your favourite technology, mobile, is excluded.

Please stop consulting and start laying the fibre in the state now Minister!

1) http://cyber.law.harvard.edu/
2) http://www.fcc.gov/stage/pdf/Berkman_Center_Broadband_Study_13Oct09.pdf
3) http://www.fcc.gov/stage/pdf/Berkman_Center_Broadband_Study_13Oct09.pdf page 58 of 232.
4) http://www.oecd.org/countrieslist/0,3351,en_33873108_33844430_1_1_1_1_1,00.html
5) http://irelandoffline.org/2009/10/international-broadband-quality-survey-blasts-dublin/
6) http://www.kildarestreet.com/wrans/?id=2009-10-13.241.0&s=Broadband+Quality+Score#g243.0.r