A Broadband Code of Conduct for Ireland

IrelandOffline have been informed that Comreg and the National Consumer Agency are now actively supporting the efforts of the Advertising Standards Authority to accurately inform the Irish consumer of the standards that ISPs should adhere too when advertising broadband to consumers. This is in response to a profusion of ‘up to ‘ offers in the ISP market and the misleading nature of many of these offerings. This is where products are advertised with enormous headline speeds or as ‘up to’ a certain speed but where the consumer has almost no chance of reaching these speeds or anything near those speeds in reality.

Eamonn Wallace, Chairperson of Ireland Offline commented “We welcome these long overdue measures and would like to point out these standards have long been available throughout other EU countries. These measures are vitally important for the protection of consumers. The tendency in Ireland is to mis-sell products, until you read the terms and conditions. We wholeheartedly support the efforts of the various agencies to bring clarity to the selling of Broadband”

IrelandOffline has therefore examined the technical issues involved and is releasing this document to inform the debate.
Commenting on the document Wallace said “IrelandOffline believes that the consumer in Ireland is at a grave disadvantage when it comes to Wireless products.”

ADSL Broadband

ADSL is the main Broadband product in Ireland .The market in Ireland has developed differently to the UK. In Ireland most products are sold as 1mbit or 3mbits etc. The majority of ADSL users have purchased a 1mbit product. Broadband is often misleadingly advertised as “super fast”. The limiting factor for these headline speeds are generally the quality of the line.

In the UK one product is very widely available, this is an ‘up to’ 8mbit product. The second largest group of ADSL products in the UK are ‘up to’ 24mbits products.
The average speed in the UK today is actually 3.6mbits [1].

Contention is not major issues at present but certain operators are better than other, see Contention explained below.
3G Internet

3G Internet is widely termed “midband” because of the extreme variability of speed.  It can range from dialup speed to broadband speed depending on cell conditions and the number of users. It would be exceptional were speeds to exceed 1mbit at any stage during peak usage hours , e.g. 7-11pm, no matter what the headline speeds are quoted.

“midband” products are the second largest category of products currently sold in Ireland as Broadband after ADSL. Together they account for the vast majority of broadband subscriptions.

Wallace continued “ComReg, Ireland’s telecommunications regulator is one of very few regulators that include “midband” subscribers in their broadband subscriber reports. The term “midband” is also used in the Oireachtas Joint Committee on Communications report of 2004.

With the 3G technologies the speeds quoted are generally best-case scenarios and the majority of users can not get anywhere like these speeds. E.g. enormous speeds like 14.4mbits and 7.2mbits are always best case figures, not an average. They only apply to one subscriber in a cell and that person being the only person using that cell. The quoted speeds can not possibly be achieved by many users”. [2]


Contention is a technical name for sharing.
Wallace explained “Contention is a particular issue with “midband” products. Users cannot be stopped from moving around (roaming), this is an essential design feature of mobile systems. As a simple explanation of contention, this is the sum of all connection speeds provisioned, divided by the system, in the case of 3g, sector capacity or backhaul capacity (whichever is smaller).”

Cell Breathing

This is an important phenomenon to understand and explains the variability of speeds on 3g “midband”; it is not the only factor though.
Wallace went on to say “Cell breathing is the dynamic expansion and contraction of the coverage of a CDMA cell, which is based on the number of users connected at any given time.
Cell breathing is the constant change of the range of the geographical area covered by a cellular telephone transmitter based on the amount of traffic currently using that transmitter. When a cell becomes heavily loaded, it shrinks. Subscriber traffic is then redirected to a neighbouring cell that is more lightly loaded, which is called load balancing. Cell breathing is a common phenomena on all CDMA based cellular systems such as 3G based I-HSPA”.

Please note that these circular cell graphs in fact represent one pie shaped sector of a cell and are drawn as complete circles for clarity. Cells typically have three sectors.

Standard Layout

Standard loaded Layout demonstrating cell breathing

Typical user speeds for a 2km cell

Chart from Nokia

Please refer to this website for a typical user experience, while admittedly this is not with the 3 service. It does however represent the experience that is common to all mobile carriers and this users experience is typical of the expected performance of any 3g midband system. It should be noted that the opinions expressed are strictly personal.





Ofcom UK Broadband Advertising Code of Practice 2008


Ofcom published this for Fixed Line ISPs and is developing the Mobile Broadband version at this time.

“17. Whilst the current code is focused on fixed line broadband access, consumers of mobile broadband may equally benefit from similar measures since they too may not, in practice, be able to achieve headline or advertised speeds. Ofcom will be urgently seeking to engage with the mobile operators to consider whether to include mobile broadband in the code or alternatively to develop a separate code, or if other measures are needed.”

Ofcom Monitoring of Average DSL Speeds in the UK show AVERAGE speed as 3.6mbits in January 2009.



From ComReg


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2 Responses

  1. g mcguinness says:


    I think you need another name for MIDBAND. I have O2 in galwat city, and i would call it SNAILBAND, as I get slower speeds than dial-up,and no help from O2

  2. robert says:

    hi i live in the country outside loughrea galway what should i do fixed line or mobile it seems cheaper im confused having read ur stuff help thanks

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