Ireland Is Bottom of the Global Pile in Telecommunications.

Ireland Is Bottom of the Global Pile in Telecommunications.

Comreg have asserted recently that “broadband is working” in Ireland which demonstrates how far removed our regulator (Comreg) is from reality. The reality is that vast swathes of the country still cannot get decent broadband or are relegated to mobile midband products.
This is a Map showing where DSL is currently available in Ireland. DSL1 is up to 8mbits and DSL2 up to 24mbits. Most eircom exchanges use the older technology.
Clearly, the problems are attributable to a failure in decisive regulation. The endless rounds of consultations, without ever reaching a decision, lead to uncertainty and reinforce monopolistic behaviour
The worst example of this uncertainty is the National Investment Spend in Telecommunications.
In Late July The EU Commission published the detailed(1) breakdown of where EU Countries are at in Telecommunications. Ireland generally either tops the wrong tables or comes up last in all the wrong tables.
The Scariest Figure of all is the Overall Investment number. Ireland invests less than any developed country in Telecommunications as a % of GDP. Many of our developed peers invest twice what we do. Many of our less developed competitors spend even more as they progressively catch up on us.
Telecommunications are the plumbing on which a knowledge economy relies. We simply cannot work smarter with sub-saharan telecommunications networks. Comreg did not deem it necessary to trouble the EU with this particular investment data the previous year(2)(Page 8 ) and now we seemingly know why.
Our higher charges for these services, not least the worlds highest line rental, ensure that we are not bottom of the pile for revenues all the same.(1)(Page9)
Ireland continues to suffer a chronic ongoing lack of investment and this can be laid firmly at the door of Comreg. Comreg have singularly failed to deliver simple clear principled decisions leading to functioning competition and a diversity of services for all stakeholders. Comreg have not stood over the decisions they did make and most importantly Comreg have NEVER fined any Telecommunications company  in Ireland for breach of Competition Regulations.
Comreg make no apology, as ever, for failing to deliver local loop unbundling (LLU) and sub loop unbundling (SLU) after over 10 years of interminable consultations on the subject. Comreg, in fact, have written 3.9 words in a consultation document for every single line unbundled in Ireland.
These two regulatory building blocks, namely simple and fast regulatory decision making, are key to removing uncertainty and delivering  Next Generation Networks (NGN). Yet we do not have any real idea of what the regulatory environment shall be. Comreg are off on a multi-year round of permaconsulting again on this subject.

Our Broadband penetration rate currently stands at approximately 20%, when using the correct and EU mandated metrics.(1)(Page 111)

(In other words when mobile midband is removed from the figures)
Mobile midband is not broadband

Comreg assert that mobile broadband, more appropriately known as midband, is working perfectly and delivering headline speeds of 7.2Mbps.
This clearly demonstrates that the regulator simply does not understand the fundamental workings of mobile midband.
The headline speeds, often quoted, simply refer to the total sector capacity, this capacity is shared among all users of a sector often leading to speeds of less than 1Mbps.
Other technical aspects of mobile midband, known as CDMA cell breathing, lead to situations where users who previously could connect can no longer do so. They are disconnected as other consumers nearer the mast connect to it. This leads to a very “hit and miss” type solution and consumers can sometimes wait for many days just to get a connection, especially in the evenings.
Furthermore the UK has 52929 Base stations(3) or one for every circa 1134 persons where Ireland only has around 3200 base stations or one for every circa 1393 persons. A recent study in UK showed that typically 20% of the “headline” speed, or  about 1Mbps is delivered(4). With about 20% less Masts per population, 120% Mobile voice penetration (voice traffic has priority over Data) and nearly 25% of Regular Internet use via Mobile Modems we can expect any similar survey here to give average speeds in the 0.15Mbps to 0.7Mbps range. Of course some users may see greater than 2Mbps speeds, but these are in the minority.
Mobile midband is a perfectly acceptable solution, when used in the way it was designed: a few emails and some light surfing. Comreg have already previously acknowledged this. However, attempting to substitute mobile midband for fixed line broadband is disingenuous in the extreme and is severely straining mobile networks that are markedly less robust than those in the UK and in other countries. Many Business people need a Mobile solution and ironically these “must be mobile”, users suffer up to 1/4 speed and disconnections due to the number of “Fixed” users on Mobile due to its artificially lower cost than Dialup, Cable, Fixed Wireless and DSL.
The EU have summarily dismissed mobile midband as a solution to the digital divide by explicitly excluding 3g products from their NGN consultations with the proviso that LTE (the next iteration of mobile broadband) may in the future provide acceptable broadband and that they are likely to revisit the matter post 2012.(5)(Page 17 Note 60)
Mathematical Models show that about 10,000 base stations are needed in a country that now has around 3200 for complete coverage at reasonable contention. At the current number of bases even 100Mbps LTE or Mobile WiMax will struggle to achieve consistent basic DSL speeds.
At best LTE will provide current entry level Broadband by 2012 or 2013. By then almost all of UPC’s cable network will offer 120Mbps. UPC can deliver a consistent actual speed of 15Mbps today and Digiweb Fixed Wireless a consistent actual speed of 7MBps today on most of their Networks. On average DSL delivers half this and Mobile less than 1/10th of that again.
Smart economy
On this issue everybody is in agreement, fibre is essential to the future of the Irish economy, to the future of our “smart economy”.  Clearly, Ireland is falling behind our neighbours while Comreg and government dither along publishing yet more consultations. We need action now, the time for endless consultations has long passed.
Lord Stephen Carter, the author of Digital Britain a plan for Universal Broadband Access in the UK complete with 70 Actions to be taken(6) was at at yet another of our interminable conferences in Dublin this week where he said.(7)
“there’s a multiplicity of approaches to the smart economy being taken by governments around the world.But the most common theme is infrastructure, infrastructure and infrastructure. It’s about the infrastructure, stupid!”
The Minister of Communications has only announced one fibre installation project during all of 2009 (8)(“Action 6”)  This fibre will serve no businesses and will serve no residential customers and that is because the Minister of Communications plans to run  it along  the bed of Galway Bay and that the stakeholders involved will take great care to route it away from the shoreline at all times.  If there is a single metaphor for the real future of the Smart Economy in Ireland  then this is it. (9)
The fibre that avoids everybody
Ireland simply does not spend enough on Infrastructure and when it does it is too little and too late and too far out to sea.  Having spent these dribs of cash the tendency is to spend the next 6 months issuing glib self reinforcing Political and Regulatory PR on these band aid programmes rather than to address the fundamental structural weaknesses that beset the Irish Telecommunications Landscape.
For as long as the Minister and Comreg constantly reinforce each others inaction and ineptness we lose. The Investment numbers are the clearest possible proof of this.
One day very soon we shall find that other countries like Portugal, Slovenia, Australia, Finland, New Zealand and Sweden and even Greece have stopped the consultations and set about installing that fibre.
Then it will be too late for us, the knowledge economy will have gone to where the technology supports it requires may be found.
(4) Mobile “Broadband” too Slow?
(5) (Community Guidelines for the application of State aid rules in relationto rapid deployment of broadband networks 17 Sept 2009)

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