Nothing universal about service from Eircom

The number of households in Ireland which do not have a land line telephone is among the highest in Europe, writes Dr Roddy Flynn…

The number of households in Ireland which do not have a land line telephone is among the highest in Europe, writes Dr Roddy Flynn

One in six Irish households does not have a home phone. Given a decade's worth of political rhetoric about Ireland as an information society, one would expect that universal access to this most basic means of communications would be a major political and social issue.

However, the substantial framework document on regulating universal service in the telecommunications market published last week by the Commission for Communications Regulation (ComReg) will disappoint those who consider the telephone essential for meaningful participation in modern Irish life.

That the telephone is essential is pretty much a given in contemporary societies. Face-to-face meetings now constitute a minority of daily communicative interactions in the Western world. Politically, economically and socially, the western world is organised around the assumption of universal access to the phone.

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However, according to ComReg, between 207,300 and 248,760 Irish households do not have land line telephones. Ireland's residential telephony penetration rate of between 82 per cent and 85 per cent is one of the lowest in the EU and has remained largely static since the mid-1990s. That the issue hasn't received more attention owes much to the assumption that mobile phones have picked up the slack. Common sense suggests that people moving into new homes in the last decade haven't had the same incentive to acquire a land line. Seventy-seven per cent of the population (3.1 million people) now own a mobile. The trouble is, there's no statistical evidence to support the substitution effect implied here.

We have no idea whether even a minority of those homes without land lines have access to mobile phones. Indeed, since there is a historically strong correlation between low household income and low levels of residential land line, there's little reason to think that those hitherto unable to afford a land line went for the considerably more expensive mobile option.

Universal service, the policy concept at the heart of the ComReg document, is the arena where lack of telephone access is nominally addressed. Yet as a general concept, universal service is a moveable feast. Although a public policy goal in every virtually developed country, there are a multitude of operational definitions. A minimalist definition is limited to guaranteeing access to telecommunications facilities on an equal basis.

A maximalist definition, however, encompasses the requirement to provide an affordable (possibly subsidised), continuous telecommunications service of an agreed minimum level of quality to all citizens regardless of their geographical location. In Ireland, ComReg's document describes universal service as seeking "to ensure that users can have reasonable requests for basic services at an affordable standard prices". In short, we lean towards the minimalist version.

That minimalist tendency is accounted for by Irish universal service policy's being framed in an EU context. Despite occasional nods to the social role of telecoms, the European Commission has mainly focused on liberalising telecoms markets. "Equal access" in this policy context means levelling the playing field for new market entrants seeking access to subscribers, not to facilitating universal access to services for citizens.

Indeed universal service was only brought into the EU equation by public telecoms operators defending their monopoly status by arguing that their unprofitable customers were cross-subsidised with the profits from their low-cost subscribers.Competition, they argued, would erode those profits. Ironically these same - now largely privatised - operators now bridle at the thought of facing any obligation other than those demanded by the market.

This is evident if one considers Eircom's comments within the ComReg framework document. For Eircom, universal service obligations means meeting minimum standards on the geographical reach of the network, on pay-phone availability and on offering directory inquiry services.

Indeed Eircom announced itself bewildered by the notion that telephone penetration of households could be in any way relevant to assessing the extent to which universal service obligations were being met. Similarly the company's understanding of a "reasonable" request for service appears very restrictive:

"Eircom considered in situations where the capital cost of providing the line is unlikely to be recovered from the customer that such cases should not be deemed reasonable."

In short, Eircom's working definition of universal service - and it worth noting that for the foreseeable future they are the designated Universal Service Provider in Ireland - falls well short of operatively expanding the current subscriber base. To its credit ComReg rejects much of the Eircom perspective. Nonetheless, it largely shares Eircom's assumption that lack of access is a market issue. The furthest ComReg will go on allowing the possibility that some people genuinely can't afford a phone is to acknowledge that the existence of those without a telephone connection "may reflect the position that consumers' payment options are limited, particularly where payment difficulties are experienced".

Given all this the most interesting contribution to the framework document comes from an unnamed respondent who argues that, in setting SO requirements, the perspective of the citizen - i.e. someone who needs telephone access to operate in society - rather than consumers should be considered. And this is the crux of the matter.

Universal service - access to basic communications services - is not only a competition issue: it is also a social one, a point implicitly acknowledged by the fact that the Department of Social Welfare has funded free telephone rental for pensioners since 1977. Indeed Eircom, despite its comments to ComReg, has made at least one positive move in this respect, with the vulnerable user scheme introduced earlier this month whereby low-use customers were offered a flat €22.50 rate a month for rental and €5 worth of free calls. But even that scheme does nothing for those hundreds of thousands of homes not already on the network.

If we are serious about creating a wired society, then it is essential that a pro-active policy on promoting telephone access must be drawn up and driven forward by the Departments of Social Welfare and of Communications.

Dr Roddy Flynn is a lecturer in the school of communication at Dublin City University