Short Comreg response

ComReg dodges the question(s) on spectrum auctions and 4G rollout

We read with much mirth and bemusement Comreg’s “answers” to simple questions posed by SiliconRepublic. (1) The so-called answers are worthy of an episode of “Yes Minister”. Not a single simple question was, in fact, actually answered. What is most telling from their copy and pasted response is what was actually left out.

In a copy and pasted and overly long and verbose response to what are perfectly reasonable questions they cannot say:

  • whether the auction and bidding has started yet
  • what they are doing to expedite the delay in the process
  • when the process will be completed
  • how they propose to handle the fact that there are now, effectively, only 2 networks competing for 4 spectrum blocks.

Their answer is “no comment” seemingly they are in no way accountable to anybody especially not the government.

The Comreg position on spectrum sharing was stated in November 2011(2) where they clearly indicated that the Department of Communications, Energy and Natural Resources (DCENR) was the responsible body and should therefore formulate a position: quote – “ComReg would firstly state that it is clearly a matter for the DCENR to set out its position on spectrum sharing” Have the DCENR or the Minister responsible formulated such a position and if so what is the position? This should be a simple enough question for Comreg to answer.(4)

Q : When do you envisage 4G services will be made available?
The answer is “next year”. Are they suggesting that a relatively simple auction process will stretch out for over a year. This is an entirely unsatisfactory response and only serves to bring up more questions about the suitability of the auction process.

The imagined ideology of competition

It is seemingly not on for a regulator to note there is abject market failure in the greater part of the territory it regulates, not when you are Comreg.

Comreg has clearly failed to promote competition in the greater portion of the State, essentially there has only ever been one and a half mobile networks available in the more “rural” areas.. Comreg should recognize this reality and should encourage all the licenced operators to invest and participate in one single network in the so-called “un-competitive” areas ( that is 80% of the entire State) pro rata their overall spectrum holdings..

Had Comreg been perfectly clear about RAN sharing in the 80% of the State where there is no market competition they would have:

  • Attracted far more bidders for the spectrum
  • Earned far more money for the exchequer at auction.
  • Been in a position to enforce anti ‘coverage rollback’ clauses in those rural areas where coverage could go from around 90% currently to 0% over the next 16 years.
  • Aimed for 100% Voice and Text coverage by 2017 at 800mhz, which is a simple and attainable objective when you start at 90% today.

No developed country has ever allowed it’s networks to roll back from 90% Geographic coverage to 13% Geographic Coverage as Comreg propose to do with 4G/LTE.(3)
Their proposed coverage obligations will send most of Ireland back to the stone age.


A regulator that cannot answer simple questions with a clarity that demonstrates some apparent purpose and which therefore serves neither the consumers of Ireland or the communications industry, has no place in a modern economy. This fiasco is just the latest in a long line of an utter failure to regulate.

Comreg should be replaced by a body that knows what is is talking about. As one telecommunications CEO recently put it : “the abject failure of the Regulator to enforce the laws of Ireland….” is sufficient commentary from someone who should be receiving service – this is criminal, of itself.

(2) Review of the Period 2008 – 2010 & Proposed  Strategy for Managing the Radio Spectrum

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