Another Fine Mess You Made Of Things Comreg
Shortly, possibly even as soon as September 2011, IrelandOffline expect to see another fine Comreg mess, possibly the finest mess of all. It will be in the form of the fifth public mobile licensing round(1)
Despite their having presided over three of these public licensing rounds themselves it seems that Comreg essentially know nothing about mobile technology and couldn’t care less about the end user. But this time it really matters.
The reason it really matters is because Comreg propose to turn off the most successful and widely available mobile service in early 2013 and have evidently not thought through how to replace it. By this we mean the 900MHz GSM service which provides the most widely available voice and text service in Ireland and with at least 99% population coverage today.
There is no reason, short of gross regulatory ineptitude, why there should not be 100% coverage in a small country such as Ireland by now. 100% coverage was understandably not a condition of the original GSM licences owing to cost at the time of issue and no operator today is obliged to cover more than 85% of the population…except that we all know they do. Nor were the original GSM licences amended to require 100% coverage at any stage despite such an objective being a reasonable and proportionate one for any Telecommunications Regulator in a developed economy.
We do not intend to go back to 85% population coverage again because of some regulatory foul up by Comreg. 85% population coverage in Ireland is circa 60% Geographic coverage.
Here is what Irelandoffline propose.
1. Voice and Text should be 100% available on day one of the new regime, whatever about data. This could be done between now and early 2013 (licence expiry) with 100% 1800MHz spectrum coverage as distinct from 70-80% 1800MHz coverage nowadays. Getting up to 100% 1800MHz coverage will itself ensure adequate masts are available to provide very high quality coverage at lower frequencies
2. Universal Data service at minimum 128k should be 100% available after 1 year of the new regime. (in addition to 1)
3. Universal Data service at 1mbit should be 100% available after 2 years of the new regime (in addition to 1 and 2)
To do so will require a completely shared Radio Access Network, (a RAN or shared RAN) owned by one company (RANCO) and this means:
a) 1 set of masts in rural areas and small towns where operators often do not want to provide a service. Operators may pledge their existing masts to this effort in return for equity.
b) All licenced operators are required to share these masts, in fact they do not own the masts or the equipment merely the valuable spectrum attached to the masts. In essence they become virtual operators on these masts or MVNOs
c) RANCO, the operating entity, is to be owned by all the licensed mobile operators but run by Comreg or some other entity to ensure full equality of access.
d) It will be much cheaper to supply 100% national coverage with one radio network.(2)
e) This network will require 4000 cells on day one and up to 10,000 cells within 2 years.
f) Operators can compete with their own network in cities and large towns, which is where they want to compete. Geographically 80% of Ireland is a burden for any mobile operator and they make their money in the remaining 20%
g) It is desirable that RANCO are to be given the Universal Service Obligation in areas where ADSL is not available or programmed to be delivered and also in SAC/SPA and National Parks where population is low and where planning constraints are onerous. RANCO is to provide low latency (eg not mobile) services in these area in addition to mobile based (3GPP standard) technologies.
h) Other virtual network operators such as Tesco Mobile or An Post may choose to contract to the entire RAN spectrum pool or to an individual operator assignment. This determines whether they can offer data or not, in essence.
h) Finally. Comreg and NOT the operators are to be responsible for the production of all coverage maps at all frequencies in future.
As it stands the existing proposal from Comreg is to close down a working network with near 100% population coverage and another with near 98% and to replace it with one or two networks that initially only provides 85% population coverage. This is unacceptable if not indeed criminal. People will literally die as a consequence of this idiocy.
Naturally the loss of service will be more profoundly felt in rural areas and cannot be substituted for with either:
a) The 1800MHz 2G service that continues in operation off current masts as of now (it has inadequate range) and is poorly rolled out. A minimum audited coverage should 98% population for this service, with a defined time period for upgrade and severe penalties for missing target. This band is very much under utilised.
b) The 2100MHz 3G service that continues in operation (even more inadequate range and cell breathing issues leaving customers out of coverage for hours on end)
However this all means that Comreg should concede that:
1. Competition does not work in most of Ireland contrary to their own delusions over the years.
2. That the RANCO consultation and creation must PREDATE any spectrum auctions.
3. That the New Era NGN plan must have a single network design to plug their fibre backhaul into. Most sites will require fibre from inception or equivalent speed microwave links.
We need the regulatory certainty that all of these concessions will bring.
We in Irelandoffline are not of the opinion that mandatory RAN sharing is a requisite in urban areas but we have no issues with RAN sharing anywhere. We do recognise that very high speed mobile broadband is only possible when operators can pool spectrum to create large blocks on a single mast and so do the operators. Our problem is that Comreg neither recognise or understand that fact. Nor will they set a minimum air interface quality of service at the spectral level, eg QAM16 (we do not expect QAM64 so don’t worry). Yet these should be specified as part of any licensing because the limitations of mobile technology, especially for data, are known.
Time is running short. Hop to it Comreg before you destroy the 2 most valuable networks in Ireland come 2013.
In genuinely advanced countries none of this matters, they have already licenced their new Mobile Spectrum and rolled out their networks. We have not even started the regulatory process.
1. The first two mobile spectrum licensing rounds were not public and were for the original Telecom Éireann 088 and 087 spectrum.
The first public licencing round was the notorious ESAT Digifone licence pre ODTR/Comreg.
Comreg carried out the 1800MHz licencing (Meteor won) and the 2 3G licence rounds
One 3g round for Vodafone Three and O2 and the second for the spare licence won by Smart then eircom.
We will not mention tetra licences and the 3 stillborn National Mobile Data licences from 2005 .
2. RAN sharing can reduce network build costs by 30%
3. RAN Sharing is not new. Sweden did it 10 years ago
4. Speeds and prices post 4g rollout. Source Three Ireland now averages less than 1.8Mbits.