Irish Phone line Rental (ripoff of the century?)

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IrelandOffline today expressed concern over the continued delay in the ComReg reporting of the quality of Ireland’s telephone network, for which its users continue to pay the highest line rental charge in the EU.

ComReg, on a quarterly basis, report on the status of Universal Service Obligation (USO) performance. This report examines how well eircom, the designated USO provider, are delivering on their obligation to provide a good quality telephone service, including voice, internet access and payphone services. The reports are considered important metrics in evaluating the state of the Irish phone network, and the value for money Irish consumers are receiving for paying the highest line rental in the EU.

IrelandOffline Spokesperson, Eamonn Wallace, explained “ComReg have failed to publish these reports for over 2 quarters now. Although, these statistics are meant to be published every quarter, the last published statistics were for Q1 2008, with yet an other deadline missed in the last week of February. These guidelines have have only been published once since Comreg set targets for line faults and increasing performance levels on Repair.”

ComReg, themselves, note the importance of these reports when they describe that the reports “will provide increased transparency regarding the fulfilment of the USO and will help to inform debate regarding related matters”, in an earlier USO Performance Review they carried out. Wallace expressed the concern “we still have the highest line rental in the EU. The minimum we can expect for this exorbitant charge is a decent phone line. We also expect the regulator to answer Irish businesses and consumers, by reporting that the phone network is consistently performing to a high standard, in return for this high line rental. Furthermore this data is part of Ireland’s USO obligations to both Irish consumers and to the EU.”

Wallace also expressed concern at the proposed loss of staff in eircom, in the guise of cost cutting measures. “It looks as though many engineers will be made redundant, as reported in the media. With the most recent data available, trends indicate that these engineers are needed now, more than ever, to cope with the higher fault rates, longer repair delays, and longer installation delays”.


Chart showing line rental charges across the EU taken from the EU’s “13th Report on the Implementation of the Telecommunications Regulatory Package – 2007” report.

Given the importance of these reports, ComReg’s own admittance of their significance, and the fact that they are now considered mandatory, IrelandOffline is now calling on ComReg and Minister Eamon Ryan to rectify this delay, immediately.

Glossary
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+ USO – The Universal Service Obligation is a set of conditions, enforced by ComReg, which seek to ensure that everyone has equal access to some basic telephone services, regardless of their location. The USO sets various criteria around phone line install times, repair times, public payphone provision, functional Internet access (dial-up modem access, not broadband, unfortunately), and phone tariffs for vulnerable users.

Supporting Notes

Line Faults and Regulatory Capture

Regulatory Capture is described as “Regulatory capture is a term used to refer to situations in which a government regulatory agency created to act in the public interest instead acts in favor of the commercial or special interests that dominate in the industry or the sector that it is charged with regulating.” (WikiPedia article).
While theory would suggest that this should not happen, Patrick Neary demonstrated it has been going on for years. ComReg (and their predecessors, the Office of the Director of Telecommunications Regulation) are the longest serving regulator in Ireland and, in our opinion, have long been “captured” by eircom and the big two mobile operators.

The Importance of the Fault Reporting

During the 1990s, the World Bank standardised the statistics it collects, and a key statistic they collect is “Faults Per 100 Main Lines”. This figure is a good measure of the quality of a telephone network. The World Bank, describes this figure as “The number of faults per main line per year defines the frequency of breakdown of the telephone lines. For a well constructed and well maintained network, the average number of faults per main line per year should be 0.2 or less; that is the telephone line should not be out of order more than once in five years. Because the figure is normally small in industrialized countries, this indicator is often expressed in faults per 100 main lines. The actual situation in developing countries is much worse, with the average number of faults in some countries exceeding three faults per main line per year.” (Source: World Bank)

eircom’s figure, a quarterly figure, has risen to a record high of 7.8 faults per 100 residential lines and 3.1 faults per 100 business lines, as per the last USO Performance Quarterly Review report (PDF of ComReg report). Comreg is the collection agency in Ireland. They report to the ITU in Geneva and the ITU reports its collated data to the World Bank. The last report ComReg released was for Q1 2008, meaning ComReg have fallen behind on the delivery of this important quarterly report.

IrelandOffline estimates we have 1.1 million residential lines and 600,000 business lines giving us a blended average fault rate of 104,400 faults per 100 lines per quarter, or 6.1 faults per 100 lines per quarter in Q1 2008. As there are 4 quarters in a year this equates to 24.4 faults per 100 lines. Therefore we no longer have a “well constructed and well maintained network” by World Bank standards
The World Bank estimated that we only had 3.2 faults per 100 lines in 2006 and that the average for a High Income country was 5.8 per 100 lines in 2006 (source: World Bank PDF report). Q1 2008 was over 4 times higher than it should have been for a high income country.

Please note that this data series is not the same as the ComReg Quarterly Reports, where Mobile Internet is constantly and incorrectly described as broadband. It is in fact a midband technology. The latest report in that particular series is for Quarter 3 2008 (PDF Report). The line fault metric is abstracted from a different quarterly series, the USO Performance Review quarterly reports, which intermittently covered from Q1 2006, to Q1 2008. Those reports can be downloaded from the following pages: Q1-Q3 2006 , Q3 2007, Q4 2007, and the last available report, Q1 2008.

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