[Release] ComReg LLU Report shows LLU in Ireland is failing

Damien Mulley - IrelandOffline Info at Irelandoffline.org
Thu Dec 21 18:08:34 GMT 2006

The following is an IrelandOffline briefing document on the ComReg
Report on local loop unbundling. Should you need clarification on any
information in this briefinf document or in the ComReg report then
please contact Damien Mulley on 086 825 8586

ComReg report:

Local Loop unbundling is the process of an alternative provider
connecting a consumers phone line to their equipment in a phone
exchange allowing for greater choice of products and value for
products. LLu has been a key driver of broadband growth in most EU
countries and has brought down telecoms prices in all the countries
where LLU is working.

Analysis of Report:

Page 4: "Eircom's contention remains that there is no need to move to
Phase 2 in the immediate future as Phase 1a will cope with any volumes
deriving from consumer marketing of the product.

ComReg and operators are considering this position but given the long timelines
suggested by eircom to implement Phase 2 (12 months) the operators
have expressed a desire for the development to begin immediately in
case the Phase 1a processes result in operators experiencing
difficulties as order volumes increase."

Explanation: The current ordering system for a local loop unbundled
powered product is a manual system, meaning that a person from an
alternative operator takes a customers details, sends them over to
eircom, where someone from eircom then takes this information and
inputs it into an eircom system. This system cannot work for bulk
orders as it depends on the number of people processing data that a
machine should be doing.

Eircom are refusing to develop an ordering system telling operators
there is no need, despite the 50% fault rate with the current system
(see below). Even if an automated system were developed, eircom are
telling ComReg it will take them 12 months to develop such a system.
With current negotiations, an automated ordering system is years away.
An automated system would speed up the delivery of broadband to a
customer but would also allow mass transfer of customers from a a
resold eircom product to an in-house developed product by Smart, BT or

Page 5: "The data provided would indicate that more than 50% of
orders, at various stages of processing, in any one month are being
rejected or result in non-delivery of service."

Explanation: This Menas that with the current manual process 1 out of
every 2 orders are not going through as they should and a consumer is
further delayed from getting broadband. Generally this results in
downtime of phone and broadband service, which many businesses cannot
afford and as a result the attrition rate from bitstream products to
LLU products will remain low. Seamless movement from one service to
another is what has allowed the mobile industry to thrive in Ireland
and why usage in Ireland stands at 102% for mobiles. The stats in this
report show that it is a matter of luck that someone has a smooth
transition from an eircom or eircom resold broadband product to an LLU

A graph on page 7 shows the significant percentage of orders delayed
by the ordering system.

This has been an IrelandOffline briefing document.

Should you need clarification on any information please contact Damien
Mulley on 086 825 8586

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