Investment By The Telecommunications Industry in Ireland

Dear Pat,

IrelandOffline has studied data on Investment By The Telecommunications Industry in Ireland as supplied by Comreg/DCENR to the OECD and as separately supplied to The EU Commission. We have found some glaring discrepancies and most particularly in the data supplied by Comreg/DCENR to the OECD over the past decade.

These discrepancies deliberately overstate Investment in Telecommunications in Ireland by around $1bn or near enough 2 average years of real investment by the Irish Telecommunications industry over the period in question to 2007.

It is a gross overstatement. NOW is the time to:

a) Correct the dataset for the period 2002 – 2007
b) Furnish accurate 2008 and 2009 data with 2010 to follow later this year.
c) Identify the culprits who dragged our name through the mud for furnishing false and misleading data to the OECD over the years….whether by deliberate commission or by equally deliberate omission.

Our analysis of the data indicates that Comreg/DCENR have cumulatively misrepresented real investment in Telecommunications Networks in Ireland by Up To $1Bn dollars. This was apparently done simply by not providing any data at all to the OECD since 2003 thereby leading the OECD to ‘extrapolate’ figures in their absence. Comreg/DCENR were quite happy to let the OECD do this;

This is an outrageous and deliberate misrepresentation by the Comreg/DCENR and one that is every bit as significant as any of the antics of our Financial Regulators of yesteryear.

The misrepresentation leaves the entire Irish Telecommunications Industry open to to a similar wholesale destruction of Reputational Capital on the scale of that undergone by our banking system. And yet this destruction of reputational capital was itself perpetrated by the Regulator and by the Civil Servants who work for you and who are supposed to oversee this Regulator.

The OECD, furthermore, publishes their authoritative Communications Outlook every 2 years and the Biennial refresh is due to be published in Summer 2011 which is also when they are likely to update their published Telecommunications Investment statistics for 2008 and 2009. You do not have very much time to ensure that the correct data is published in that publication.

Sadly the proposed New ERA investment policy will only replace these funds which were never invested during that time.

This shows how vitally important the implicit ‘catchup’ element of the New ERA investment proposal is no matter how hostile your Department of Communications proves to be, as always. While their OECD scam was underway the International Metrics very conveniently ‘proved’ that your Civil Servants didn’t have to do anything.

Now we all know the real facts this must change, forever!

We in IrelandOffline believe that you now have a salient opportunity to show the leadership of which we all know you are capable. We urge you to take this singular opportunity to rescue your country and your department from the mire.

Warm regards



We start examined three key tables in the OECD Central Statistics database. The italicised comment was made by the OECD themselves as follows:

“ Data in italics indicate unofficial estimates derived from historic ratios of incumbent investment to total investment.”

and said note is to be found in the _footnotes_ to the following OECD Table .

Table 1

OECD Communications Outlook 2009 – OECD © 2009 Table 4.17. Public telecommunication investment in the OECD area
( all figure in USD millions)

2003 2004 2005 2006 2007
575.28 638.20 766.76 899.71 1101.18

Table 2

OECD Communications Outlook 2009 – OECD © 2009 Table 4.2. Total communication access paths in the OECD area ( Millions)

2003 2004 2005 2006 2007
5.15 5.64 6.24 7.00 7.48

Table 3 is a division of the revenue in table 1 by the access channels in table 2

Table 3

OECD Communications Outlook 2009 – OECD © 2009 Figure 4.20. Public telecommunications investment per access path, USDollars

2005 2007
Iceland 169.5 230.6
Australia 141.2 171.6
Canada 108.7 160.3
Denmark 119.9 158.1
Norway 310.0 154.5
United States 135.4 153.7
Ireland 122.8 147.3
United Kingdom 98.0 79.7
Switzerland 130.2 140.2
New Zealand 89.3 114.8
OECD 96.5 100.0
Spain 102.6 102.8
Luxembourg 54.2 102.7
Japan 106.5 98.7
Netherlands 82.1 95.8
Korea 77.3 95.7
Belgium 84.8 94.3
Portugal 56.9 90.1
Sweden 72.7 88.4
Austria 75.5 84.6
France 92.7 83.9
Italy 84.1 78.6
Greece 49.7 78.2
Slovak Republic 71.6 69.5
Finland 51.3 54.2
Poland 37.5 54.1
Czech Republic 37.2 49.1
Germany 56.2 49.1
Hungary 49.3 42.6
Mexico 50.4 34.6
Turkey 21.7 22.5

Finally we check the currency rates the OECD uses for their annual calculations .

(One modifies Time and Frequency on top in this table to get all the years in question ..selecting the last 8 years ) We use the correct annual rate in any year to convert or to reverse convert. The results of the reverse conversion are ( table 1 by effective OECD rate in that year)

Investment in Euros OECD Actual Figures
2003 0.8850 €509m
2004 0.8048 €513m
2005 0.8046 €617m
2006 0.7967 €717m €431m ( diff €286m)
2007 0.7305 €804m €458m ( diff €346m)

( compound difference 2006 and 2007 = €632m or $832m dollars in those two years alone)

It is safe to assume that $200m of false data was interpolated by the OECD in 2004 and 2005 together bringing the cumulative investment misrepresentatio to $1bn by the end of 2007.

People may ask where Ireland Offline got the Actual figures, Comreg/DCENR indirectly gave them to us but they did not give them to the OECD.

We expect the 2008 OECD figures to be announced very shortly and for the OECD to further compound the error. But it is not too late for Comreg to fess up.

The actual Irish Telecommmunications Sector Investment figure for 2008 is €516m which should translate at the known OECD $ € exchange rate of 0.720 for 2008 to a total of $717m in that year. We will get the actual 2009 figure when the 16th “Implementation” report is published by the EU during the next 2 months. This being a year when GDP and GNP fell precipitously.

But will Comreg/DCENR tell the OECD what these numbers are and will they correct the $1Bn of cumulative false investment data still shown on the OECD database between 2004 and 2007 inclusive ???

We would like you to investigate this matter and to assure all stakeholders that the data will be correctly furnished to the OECD for the years 2003 – 2007 and that subsequent 2008 onwards data … yet unpublished by the OECD…is entirely correct.

You know it is the right thing to do Pat. There is no better time to do it.

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