People paying for motor tax by post or over the counter are to face penalties as part of a bid to drive more business online proposes the Local Government Efficiency Review Group (LGERG).

Online services would cut costs to the taxpayer and increase efficiency, according to the recent LGERG report. Among the chief targets for these further cost-savings were motor tax, advertisements and planning applications.This simply demonstrates how arrogant and out of touch the government and its bewildering array of quangos and agencies such as the LGERG is with the reality of the broadband situation throughout the state.

The proposal seems grossly unfair where 10s if not 100s thousands, of people throughout the country still do not have access to good quality and afordable broadband facilities and therefore cannot go online to avail of these services. It is a tax on Minister Ryans failure to deliver affordable universal high quality broadband.

We in IrelandOffline do not feel that the citizenry should be directly taxed for Minister Ryans continual failure to address the substandard telecommunications market in Ireland.

The hardest hit are likely to be the elderly and those in disadvantaged areas and in more rural areas where telecommunications networks are consistently substandard. The Local Government Efficiency Review Group group insists that this is not a revenue generating scheme but aimed at encouraging use of the online system.

To a reasonable and right minded person it is evidently an ill-advised and badly thought out proposal when vast swathes of the population of the country cannot use it in the first place as they lack the basic facilities.

To this end we propose a smart simple and dare we say ‘green’ solution.

We propose that the government mandates the LGESB to first set up a Citizen speedtest.net server using the software provided at a low cost by the speedtest.net network. We ask for one small modification, the ability to link a PPS number to the speedtest result.

Where the citizen cannot achieve a stable, low latency, minimum 256k connection over which to do their business with the state and its service providers they are to be credited all of their online taxes,in full, by all government service providers for a full year. Thereafter they may try the test again to see whether matters have improved.

The Local Government Computer Services Board is the central IT procurement arm of local government. IrelandOffline shall be seeking a meeting with them as a matter of urgency to discuss the mechanics of this speed testing network.

We expect that Minister Gormley, who is the Green Party leader, will instruct his staff to co operate in a meaningful way with this testing initiative.

When is unlimited not unlimited? When it is offered by an Irish Telco.

IrelandOffline are today calling for an end to the misleading practice of describing telecommunications packages as unlimited.

We now have a plethora of “unlimited” offerings by various telcos yet they all have limits. They are now hidden behind a “Fair Use Policy”. These supposedly “unlimited” offerings stretch the use of the English language to the extreme.
Unlimited by definition means exactly that: unlimited not some falsely crippled offering.

For instance, Imagine’s Wimax offering is advertised as unlimited yet has a cleverly hidden 30Gbyte cap.
Then we have Vodafone also advertising an “unlimited” Mobile package. This package does not even offer full access to the internet. Skype and VOIP are not “supported”. While this may mean that Skype and VoIP are not known to work very well on any mobile broadband it may also mean that they are actively blocked which is a completely different situation and most certainly not what is reasonably understood to be “Unlimited”. These are only two examples of this practice.

Comreg and the ASAI were supposed to address these issues a number of years ago. Why has this not been done? What does the Comreg Consumer Panel actually do?

This is in clear breach of European Consumer guidelines:

http://ec.europa.eu/information_society/eyouguide/fiches/4-i-a/index_en.htm

Here is the text of the directive itself

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2005:149:0022:0039:EN:PDF

whose enforcement is supposed to be monitored by the European Consumer Centre

http://www.eccireland.ie/

Today IrelandOffline are calling on Minister Eamon Ryan to deliver concrete actions to get Irish Internet Speed and Quality up to that of Mongolia.

Commenting on the results of this global survey Eamonn Wallace Chairman of IrelandOffline said: “He cannot do this from the RTÉ studios. We want him back working at his desk and dealing effectively with this Mongolian problem. First Soweto outpaced Dublin and now Mongolia has overtaken Ireland. Urgent action is required of you Minister. ”

Test Metric company Ookla released their six monthly speedtest.net results. Ookla have carried out no less than 1.5 BILLION INDIVIDUAL broadband speed tests globally. Of the 1.5bn 800,000 were carried out from Ireland. These tests are conducted by the end user from their own computer or smartphone. They give a very accurate and wide ranging snapshot of real broadband delivery conditions to real people in Ireland.

Wallace continued: “Importantly these results INCLUDE recent market developments.The speeds shown are ONLY those collated from tests conducted between April and May 2010. They account for 233,000 IPs of the 800,000 Irish IP addresses tested by Irish Internet users over the years. Therefore these results include widely trumpeted ‘upgrades’ such as eircoms relaunch of 8mbit ADSL (a standard dating from 2001) as “next generation”.

The results additionally include the UPC package upgrades between January and March 2010 which brought their basic package to 5mbits nominal. They also include some developments on 3g mobile networks over the past month. Almost 10,000 tests are carried out every day from Ireland alone.

After all those ‘upgrades’ are fully taken into account Ireland has nevertheless fallen behind Latvia, Lithuania, Romania ,Bulgaria, Moldova, Greece …..and Mongolia in these rankings. In fact Mongolia TROUNCED us.”

Download Speeds: Mongolia 38th Ireland 41st
Upload Speeds: Mongolia 16th Ireland 63rd

The average Irish download speed is 6mbits. Most EU countries are averaging well over 10mbits nowadays with the EU27 average download speed at 10mbits. Ireland only manages 60% of this EU average download speed performance. In the EU27 only Spain Italy Malta and Cyprus now lag Ireland for download speeds.(1)

The Upload Speed figure is even worse. We do not manage 60% of the EU average there. In fact we only manage 40% of the EU average (1mbit upload vs 2.5mbits EU wide) and within the EU27 only Greece, Spain, Italy, UK and Cyprus performed worse than we did.(2)

In the QUALITY stakes we are critically lagging in 65th place. Only 7 countries in the global rankings scored lower than Ireland, they include Egypt, Kenya, Iran and Lebanon.(3)

Countries with better QUALITY broadband than Ireland include EVERY OTHER EU MEMBER and a few interesting surprises like Serbia, Albania and Moldova (the 3 poorest countries in Europe). Quality is a measure of smooth and consistent transmission of individual pieces of data such as gaming packets and voice over ip packets. A good quality score means one can hear the person one Skypeing with no delays or dropouts for example.

Importantly the quality index is on a continual and worrisome downward trajectory across the test period that ended on the 25th of May 2010. The nearest EU country to us,Greece in 63rd place just above us, is meanwhile improving its performance as too is Uruguay just below us, the only second world country to score lower than Ireland. (3)(4)

Notes and References.

Download Index.Ireland 43d

1. http://www.netindex.com/download/allcountries/

The Irish Download Speed Entry

http://www.netindex.com/download/2,49/Ireland/

Upload Index. Ireland 61st

2. http://www.netindex.com/upload/allcountries/

The Irish Upload Speed Entry

http://www.netindex.com/upload/2,49/Ireland/

Ennis , the Information age town, is the slowest.

Quality Index.Ireland 65th

3. http://www.netindex.com/quality/allcountries/

The Irish Quality Entry.

http://www.netindex.com/quality/2,49/Ireland/

Ookla Press release 25th May 2010

http://www.ookla.com/press-room.php

Soweto ahead of Dublin in International Survey

http://irelandoffline.org/2009/10/international-broadband-quality-survey-blasts-dublin/

3 Ireland have silently announced that they are unilaterally changing the terms of
the NBS contract. They will be dropping the data allowance for customers from
15GB a month of data down to 10GB of data.

This clearly demonstrates that the 3 Ireland network is not capable of handling
the data throughput required for the NBS and highlights in general the unsuitability
of any 3G network to handle the large volumes of data required for such a
network to be considered as real broadband.

In our opinion this is clearly a breach of contract and the NBS should be scrapped
with the €80m of public and EU spent on something more suitable to the goal of
delivering broadband to those that are currently not served by broadband.

Other key contracted road map events such as an increase in MINIMUM data
speeds for NBS users to 1.6mbits on the 1st of July 2010 and completion of
the entire roll out to the intended 388 masts (or their replacements)
by the end of September 2010 will not be met.

While there have been issues with planning authorities with regard to the
proposed 160 entirely new masts planned for this scheme (for which one
feels some sympathy for three) the fact is that fewer than half of the
160 new masts have been installed to date. In Kerry only 2 masts have
eceived permission out of the 10 applied for. This scheme is to be
installed and fully commissioned in less than 5 months. 3 are showing
no sense of urgency.

Contract changes are flagged here, please note that NBS customers are
considered to be “pay monthly”

http://www.three.ie/terms/customer_notification.htm

For the record here are the original terms as originally announced:

http://www.dcenr.gov.ie/Communications/Communications+Development/National+Broadband+Scheme/NBS+FAQs.htm#Limits

Will there be download and upload limits and what will they be?

An uncharged monthly data cap of 15GB (12GB download and 3GB upload)
will apply for the wireless product while 11GB (10GB download and 1GB
upload) will be available for satellite users.

Are there plans to upgrade speeds?
Two upgrades of the wireless product are planned by 3 in the coming
years without any increase in the monthly recurring charge:

July 2010 Min (at cell edge) Max (at cell centre)

Download Speed 1.6Mbps 6.8Mbps
Upload Speed 1.2Mbps 4Mbps

Maximum contention ratio of 22:1
Round-trip latency: 100ms

October 2012 Min (at cell edge) Max (at cell centre)

Download Speed 2.3Mbps 10.4Mbps
Upload Speed 1.4Mbps 4.8Mbps

Maximum contention ratio of 18:1
Round-trip latency: 100ms

Furthermore, since the inception of this scheme they have been
unable to maintain the initial minimum contracted download of
1.2Mbps (in common with all Mobile operators), 100ms Latency,
always on or always connected.

With W-CDMA/3G/UMTS/HSPA it’s not even possible to have a
guaranteed minimum connect speed at the cell edge.

This “distance” will vary depending on the number of simultaneous
connected users.

The maximum contention isn’t possible to achieve with mobile
subscribers. The industry standard is that contention
is the sum of package speed per user divided by the system
speed, as if all users connected. It’s not the real time
number of users per mast. The actual reality is that only a
certain percentage of customers connect at once,
thus on a real broadband system you might only see a real
time reduction of package speed from 8Mbps to
7.5Mbps due to real time contention. The 12:1, 24:1 or 48:1
contention rates quoted refer to the bandwidth
needed by total number of customers, not actual connections.

Three Themselves maintain that the commonly accepted distances
for 3g cell sites in varying environments are:

150m – 350m in urban areas

800m – 1000m in suburban areas

2km – 5km in rural areas

That shows clearly the density of cells required for adequate service
levels and also why the NBS can never possibly achieve its stated aims.

If there was a true representative and unbiased audit comparing 3G
system in areas where the customer sign-ups have reached a mature
stage, we suggest that the system would not ever have met either
the NBS specification or met the commonly accepted standards of Broadband.

The announcement
Let us be clear on this announcement, this is neither Next Generation anything nor will 8 MB be delivered to the vast majority of hapless consumers. While IrelandOffline welcome the attention to the important issue of contention we feel this announcement is nothing more than “window dressing”.

The phrase “Next Generation” alludes to the next generation of broadband products usually delivered by Fibre, this most certainly is not anything like that. This is purely “marketing speak” as almost everything else remains exactly the same.

The only thing “Next Generation about this product is the charging policy. This is a 200% increase on the average user’s bill for those who can least afford it. This product is only Dublin based for the moment.

Usage based charging
This is yet another attack on the hard pressed telecommunications consumers of Ireland. Not only do they have to endure the highest line-rental on the planet they now have to endure a €2 charge for each Gigabyte they go over their paltry caps. For instance the “Broadband Basic” has a minuscule 10GB cap barely enough for the average “tech savy” family.

In reality this package will cost €50 for all but the lightest users. That’s €50 + line rental making the total €75.36 per month. This is hardly a giant leap forward it’s more like a gigantic leap into the dark past and into your wallet.

IrelandOffline has been campaigning for many years for improved broadband services and has welcomed the suggestions made by the high-level group. Amongst the suggestions that IrelandOffline considers essential is that all public infrastructure include provision for shared ducting for communications services. The Innovation Taskforce includes the following recommendation “provision of access to public ducting infrastructure by establishing the planned “one stop shop” This idea has already been put forward by IrelandOffline and we are presently examining regional development plans to ensure they include open access ducting in their infrastructure actions.

IrelandOffline spokesman Eamonn Wallace said “basic facilities such as water and electricity are included in development plans without question, the Innovation Group has now created a requirement that communications facilities be treated in the same way. IrelandOffline continues to research the options for building in to new developments the required telecommunications infrastructure. However these recommendations are the same as in previous reports, we hope the opportunity now is taken to turn the recommendations into concrete proposals”

In addition to longer term planning IrelandOffline insists that ComReg, the communication regulator and the Department of Communications must supervise the roll-out of high speed reliable broadband more closely. IrelandOffline has repeatedly taken the regulator to task for allowing less than optimal services such as 3G be called broadband. The Innovation Report has endorsed this by pointing out that “uncontended access” (user does not have to share bandwidth with other users due to network constraints) is an absolute requirement for proper broadband facilities.2

The Innovation Report quoted a Forfas survey which identifies the Irish broadband situation in the following terms “In Ireland, 5 percent of broadband connections are above 10Mb/s. The EU-24 average is 15.5 percent of connections above 10 Mb/s” IrelandOffline has used similar data to identify the ground that Ireland has to make up if it is serious about being a major player in the so-called smart economy.

Notes and References
___________
1 http://www.taoiseach.gov.ie/eng/Innovation_Taskforce/Report_of_the_Innovation_Taskforce.pdf
2 “Uncontended Access” means that the last mile to your home is managed in a way that GUARANTEES you the bandwidth you pay for. With ADSL you have an exclusive copper line and with fibre or copper or fixed wireless there are effective sharing techniques that guarantee you your share. With 3G mobile this is technically impossible as everybody shares a sector.

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″

——————

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