Comreg – terminate this Secretive auction process now!

Comreg – terminate this Secretive auction process now!

Comreg have run a veritable cornucopia of consultations, even by their tortuous standards, on how to conduct the largest spectrum auction (the 4G auction) in Irish history during 2012. In between strange micro-eruptions of “Fantasy Cricket” leagues in Comreg and consultations that were strangely detached from the answers they received in immediately preceding consultations, they eventually finalised the process in June and launched their spectrum auction in July.

But by the time Comreg started the auction a fatal flaw was evident. They were not auctioning spectrum in a competitive environment, they were auctioning to a cartel. O2 and eircom formed an Active RAN Sharing entity named Mosaic in 2011 and Three and Vodafone formed an unnamed ‘Sharing’ entity in July 2012. IrelandOffline support such initiatives and do not feel that they are, in essence, anti competitive. In fact such a twinpack arrangement works very well in rural Sweden for 3g networks and with the blessing of the regulator there in 1999.

Abolish Comreg

When a regulator is no longer relevant, is utterly ignored by the industry it regulates and no longer represents the consumer interest, it should then be abolished. Who, after all, needs a “sclerotic hunting dog” who won’t leave his bed by the fire and hires consultants to do the job. We need a regulator that serves the country whose laws it should, primarily, implement.

Comreg found themselves with 2 bidders they already knew about presenting at their auction, 2 bidders pretending not very hard to be 4 bidders, if they even bothered with the pretence. We don’t know precisely what happened but we do know that a simple auction process that should take 4 weeks is now 10 weeks in train and with no end in sight. The blame for this fiasco lies firmly at Comreg’s door.

Minister Rabbitte’s promise

Minister Rabbitte was assured by Comreg that the auction/award process would be complete over a month ago. On the 30th of August, when unveiling his National Broadband plan, he personally assured his audience that the process of awarding the spectrum would be complete by the end of the following week, ie by the 07th September 2012. Here we are 5 weeks later and nothing has issued from the Comreg auction fortress, not even an explanatory note or an inane excuse. The auction has frozen because Comreg simply cannot award the spectrum given the evidence of conspicuous collusion presented to them.

IrelandOffline have a simple and concise position

In 80% of Ireland by area there is, effectively NO COMPETITION and the only time there was any such evident competition was when Esat Digifone bid for a licence in 1996 leading to an aggressive infrastructure rollout by Digifone and Eircell. Today rural Ireland has 90% GSM coverage.

In 20% of Ireland by area there SHOULD BE FULL COMPETITION. This is the area where most of the population live and where 100% coverage should be mandatory. Full competition means each licensee must build a full network in 20% of the state.

Furthermore these 20% and 80% ‘zones’ should be pre-agreed and mapped.so everyone knows exactly what is meant.

IrelandOffline repeat their call to Comreg to:

1. Terminate the auction now. The taxpayer is ill served by continuing with it and continuing with it is highly damaging to Ireland’s reputation and to its shrunken regulatory capital.

2. Introduce Mandatory Active RAN sharing across 80-85% of Ireland. That means 1 Physical network only with no coverage rollback allowed from current 2g coverage in the most rural 80% of Ireland. All 4G licensees must buy into and use this single network with costs shared pro rata spectrum held.

3. Introduce full infrastructure competition ( ie 6 licensees = 6 physical networks competing on coverage and quality across the remaining urbanised 15-20% of Ireland.which is where 80% of our population live)

4. Launch the entire process again. There is a much greater chance of there being a new market entrant if such a certainty is built into the process.
Finally we call upon Minister Rabbitte to deliver from his side and ensure that the Active RAN Sharing network will benefit from Life of Licence infrastructure planning permissions, not rolling temporary permits.