57 plus question for the DECNR and no answers

57 plus questions; not one answer

The mapping process for the The National Broadband Plan is underway. Its stated purpose is to map areas of the country that either currently have, or will have by July 2016, alternatively Next Generation Access (NGA) or ‘basic broadband’. The process then should, in theory, reveal those areas without NGA or indeed basic broadband (of which there are many).

While the ten month delay in getting started is inexplicable, the most urgent issue now is to ensure that proper standards are applied to each service. Some of these services will be of unknown quality and some might be (mis) represented as NGA, but it is vital to get as candid (if embarrassing) as possible a picture of the state of our broadband infrastructure throughout the country. The standards that will apply to the mapped services will set the benchmark for what follows by way of intervention in the areas of deficit.

IrelandOffline has profound doubts about the intentions of the Department in the entire National Broadband Plan, but the mapping process, needs to be carried out regardless of what follows. We believe the probable outcome has already been decided and it’s likely the whole exercise is being done to bolster this predetermined view.

The mapping process must be carried out with absolute transparency and integrity. With that in mind IrelandOffline has registered as an interested party in this process and has (as we are entitled to do under EU guidelines) submitted questions relating to the qualifying standards of each of the technologies that DCENR intends to accept as NGA. We also asked some questions about the criteria  that the Department will apply in querying the plausibility of ‘planned’ deployments; because by accepting ‘planned’ deployments the department will be putting some areas, perhaps very large areas, at the mercy of commercial entities that have no particular interest in this country.

We reproduce below the questions that we have put to the Department (with some additional explanations in parentheses). The department has to date not answered any of them.

FWA (Fixed wireless access)

  1. Which FWA technologies does DCENR intend to accept, in principle, as NGA technologies.

  2. What nominal maximum service radius will DCENR attribute to each qualifying FWA technology.

  3. What contention rates will apply. ?

  4. Will these contention rates be hard set.?

  5. How does DCENR plan to verify coverage and delivered speeds.

MOBILE (Mobile access using LTE or Wimax)

(IrelandOffline notes that, under EU Guidelines, these technologies may be considered only ‘under certain circumstances’. We have attempted to find out what those circumstances might be on numerous occasions.)

  1. Which mobile technologies does DCENR intend to accept, in principle, as NGA technologies.

  2. In the case of LTE ‘advanced’ (if included), which specific elements of the draft 3GPP standard will be required to qualify.

  3. What provisioning requirements will be required in the case of each mobile technology to qualify as NGA, including:-

  1. The maximum number of residences and businesses to be provisioned by a sector.

  2. The required amount of spectrum to be available per sector per provider in the relevant spectrum band.

  1. What other requirements will DCENR deem necessary to “ensure the required quality of service level to users at a fixed locations while serving other nomadic subscribers in the area of interest”

  2. What nominal data service radius does DCENR intend to attribute to each qualifying mobile technology at 800Mhz, 900Mhz, 1800Mhz, 2100 Mhz etc.

  3. Does DCENR intend to carry out coverage modelling in respect of all qualifying mobile cell sectors.

  4. How does DCENR plan to verify mobile coverage.

  5. How does DCENR intend to ensure that qualifying  mobile services remain properly provisioned through continuing time.


FTTC (Fibre to the Cabinet – aka VDSL)


(FTTC speeds are a function of the cable length between the customer and the cabinet. Lengths greater than 300M would not theoretically deliver more than 30Mb/s using a standard VDSL technology)


  1. Will VDSL and variants qualify in principle or qualify subject to individual line speed test.

  2. Which VDSL variants will be accepted as NGA.

  3. Does the mapping include tested “eligibility” or “submitted coverage” or “service areas based on radius”.

  4. What  nominal speed will be attributed to each VDSL variant  at 100M, 200M 300M, 400M, 500M…….etc. (Indicate if these are straight line distances or cable lengths.)

  5. In the case of “eligibility” from Q3 above, what is the qualifying line test speed for NGA.

  6. What factor is used to convert straight line distance to cable length. for the purposes of mapping qualifying VDSL areas.

  7. What is the nominal service radius beyond which each VDSL variant will no longer be accepted as sufficiently fast.

Planned Investments (see also State Aid below)

  1. Is vectoring a qualifying planned investment.

  2. What assumptions will be used regarding speed uplift to each VDSL variant, at each distance, as above, due to vectoring.

  3. Have separate assumptions been programmed for Card Level and for System Level Vectoring

  4. Is bonding a qualifying planned investment.

  5. What assumptions will be used regarding speed uplift to each VDSL variant, at each distance, as above, due to bonding.

FTTB/FTTK (Fibre to the Building/Kerb)

  1. Which FTTB/FTTK technologies will be mapped

  2. What is the definition of deployment in relation to these technologies: e.g. does in-building or kerb to building cabling count as additional infrastructure.

  3. Do unlit deployments qualify.


FTTH (Fibre to the Home)

(Universal ‘Fibre to the Home’ is the logical conclusion of broadband development for now and for the foreseeable future. Point to Point or individual fibre connections are seen as being more amenable to retail competition than PON (Passive Optical Networks) which could be constrained)

  1. Which FTTH technologies will be mapped.

  2. What requirements will be in place regarding wholesale access in respect of planned investments.

  3. Do unlit deployments qualify.

  4. Given that a single FTTH infrastructure is more likely in rural areas, will DCENR require multi-fibre P2P architectures in planned investments as recommended by the State Aid guidelines in the case of interventions.

“For instance, network topologies allowing full and effective unbundling could receive more points. It should be noted that at this stage of market development, a point-to-point topology are more conducive for long-term competition in comparison with point-to-multi-point topology, while the deployment costs are comparable especially in urban areas. Point-to-multi-point networks will be able to provide full and effective unbundling only once wavelength-division-multiplexed passive optical network (WDM-PON) access is standardised and requested under the applicable regulatory frameworks.” Para 78(d) Footnote 103, State Aid Guidelines.


  1. Which Cable technologies will be mapped.

  2. What requirements will be put in place in respect of planned investments.

Mapping Process

  1. What mapping application software is being used?

  2. What radio wave propagation software is being used?

  3. What is the source reference of the elevation data being used?

  4. Does the elevation data include structures?

  5. Does the elevation data include vegetation?

  6. Will providers who do not supply coverage data be estimated or excluded?


  1. What action will DCENR take in respect of a credible information from a member of the public regarding the non-availability or ‘not-spot’ of an indicated current service at a specific location.

  2. Does DCENR intend to register, retain and publish such information from the public.

  3. Does DCENR intend to carry out field tests to verify the map? What methodology will be employed in carrying out field tests.

  4. What other means does DCENR intend to employ to verify the map

State Aid

Plausibility of Planned investments

  1. What is the format of the business case analysis that needs to be provided for planned investments.

  2. What business case plausibility criteria will be used.

  3. What financial data will need to be supplied.

  4. Is 01/07/2016 the final date for completion of planned investments, to qualify for inclusion.

  5. If not, what is the final date and what percentage of area of the planned investment must be complete by 01/07/2016.

  6. Will a financial bond be required?

  7. How will the bond be calculated?

  8. Will a grid will be used to delineate the boundaries of the identified intervention area.?

  9. If so, what grid will be used, e.g.  CSO small areas, Electoral Divisions , square blocks (size?), etc.


  1. What remedies will be in place for those who are excluded because of the vagaries of a grid system or mapping errors. i.e. false exclusions.

  2. Will the NBP contractor(s) be contractually and financially enabled to step in to extend intervention coverage where planned private investments fail to materialise, or are below the forecast quality in terms of performance or provisioning, or are behind schedule.

  3. In the absence of a bond (6 above),what is the value of contingency funds that will be available for this purpose.

  4. What are the progress review intervals for planned investments.

  5. Who will carry out the reviews.

  6. Will timely progress reports be published regarding planned investments.

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3 Responses

  1. Tommy says:

    Hello, is there any update on this? I’m very interested in the DCENR’s reply.

  2. This funding decision, affecting the states of Alaska and Hawaii, and the territory of Puerto Rico, is the first the FCC has taken as part of the Connect America Fund Phase 1 program this year. Decisions for funding across all other jurisdictions are pending a challenge process regarding eligibility of areas for funding. The goal of this challenge process is simply to ensure that subsidies are not authorized in areas where broadband service already exists. This quick and decisive decision in Puerto Rico, therefore, is directly linked to the reliability of the underlying broadband maps.

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