Mr. Marcus Matthews:

Before I begin, I note an error on page 4 of my submission, where it is stated that it took Eircom five years to pass 300,000 properties. The statement is incorrect because it took Eircom two years to pass the said properties. The Regional Internet Service Providers Association, RISPA, apologises to the committee and Eircom for the error and asks that it be corrected for the record.

I will take the opening statement as read and highlight certain aspects, including the background, for the information of the committee because I wish to ensure that the committee receives answers to its advance questions.

On behalf of the Regional Internet Service Providers Association, RISPA, I thank the committee for the invitation to appear before it and for the opportunity to contribute to its current examination of the NBP. RISPA recognises the important role that the committee serves in scrutinising all matters pertaining to public expenditure and appreciates the privileged opportunity to contribute to the committee’s work regarding the NBP. It is the intent of RISPA to present information on selected aspects of the NBP, which collectively should offer the committee new insights with respect to the plans economic cost-effectiveness and general value for money.

RISPA is a trade protection association comprised of 13 Irish owned and operated internet service providers, ISPs, each of which provide reliable high-speed Internet connectivity to predominately rural premises throughout the regions of Ireland. Collectively, these companies provide a personalised customer service experience and are committed to expanding their network coverage and adding additional services like television, enhanced telephony and broadband at speeds of 100 Mbps and faster. RISPA aims to raise awareness of small Irish owned and operated ISPs and to address the issues they face in delivering high-speed reliable broadband to rural Ireland.

I will now refer to the briefing on the purpose of RISPA's submission and appearance before the committee. In the eight years since the NBP began, network technology has developed significantly. This technology has been successfully deployed in other jurisdictions to address connectivity gaps similar to that faced by Ireland. Given the much faster deployment timescales and better return on investment opportunity to Ireland that these technologies represent when compared to rolling out fibre in the same context, RISPA feels that it is in the best interests of Ireland and its economy that an up-to-date alternative to the fibre optic-centric, single wholesale operator model of the NBP be explored.

This concludes the introduction to, and brief background on, RISPA. I will now move to answer the questions the committee specifically asked all delegations to answer in their opening statements. On the question regarding RISPA's involvement with the NBP, we have not been involved with the plan because we are a newly formed trade protection association. Over the years, our members have attempted to engage in the consultation processes surrounding the NBP but have only ever received token responses to their submissions. Accordingly, no RISPA member is involved with the NBP.

On the question of RISPA's involvement or discontinued involvement in the plan, our position is that the fundamental design parameters of the NBP preclude fixed wireless solutions that utilise license-exempt radio spectrum and, because the procurement process did not identify any suitable spectrum to be set aside for bidders wishing to submit a proposal which utilised fixed wireless technology, no RISPA member nor any other small ISP was able to partake in the process.

Regarding the committee's questions about challenges to the NBP, it is RISPA's position that there are numerous administrative, bureaucratic, financial and operational challenges with the NBP in its currently proposed format, a number of which RISPA will examine during its presentation. In brief, the association's view is that the NBP's procurement process has failed to meet the standards required of such processes as set by the public spending code and that the NBP is a fundamentally out-of-date proposal due to more cost-effective technologies that have come to market over the past three years. It is, therefore, the association's opinion that, based upon the project management principle of continued business justification, which is a rudimentary risk control concept designed to prevent the funding of projects with poor prospects for return on investment, the NBP tender be cancelled and that a new 12-month evaluation on how to solve Ireland’s connectivity gap, which incorporates both the lessons learned from the NBP and genuine effort to engage with ISPs via a public private partnership consultative approach, be started.

On communications with the Department in respect of the operation of the MANs, neither RISPA nor its members have had any such communications, not least because these networks are under a contract that renders any discussion mute.

Regarding the question of broadband provision and new technologies such as 5G, RISPA's position is that such provisioning efforts are progressing at an unacceptably slow pace compared to the needs of Irish citizens and the wider economy. It is the association’s opinion that the approach being taken by the Government, the Department and ComReg is ill-advised and could be greatly improved by borrowing lessons learned from other jurisdictions with similar connectivity gaps. RISPA's position regarding 5G technology specifically is that its inherent design makes it fundamentally unsuited to the needs of rural Ireland. The association will give precise details during its presentation to factually explain why 5G technology cannot be a cost-effective solution for Ireland. RISPA's position on new technologies generally, when these technologies are applied correctly, is positive. However, it is RISPA’s general assessment that 5G only offers benefits in high-density urban environments. In contrast, the advancements that have been made with fixed wireless technologies and their application to similar connectivity gaps makes them worthy of consideration as a possible solution for Ireland. In particular, the association believes that the latest generation of fixed wireless technologies, which came to market approximately three years ago, have the capability to deliver speeds of 100 Mbps or faster per subscriber connection. Given the low cost of these technologies and their potential to rapidly solve Ireland's connectivity gap in an economically sustainable way, the association will examine them in further detailed during its presentation.

With respect to the potential use of MANs in respect of the NBP roll-out, RISPA has no direct comment since the contract governing the MANs would preclude them from being utilised in such a way. Nonetheless, RISPA does believe that the MANs could play a vital role in addressing Ireland's connectivity gap if they were subject to competitive wholesale pricing. In this regard, it is the association's opinion that the Department's decision not to run a tender process for the MANs, after BT Ireland gave the Department more than six months notification regarding its keen interest in competitively bidding for the contracts, was a grave misjudgement that has set Ireland’s economy back 15 years. RISPA will offer information during its presentation to support this opinion regarding the decision not to tender the MANs contracts.

Finally, I refer to the committee's questions about the mapping of the MANs, private fibre networks, and mobile black spots. On the mapping of MANs, we believe that they have been sufficiently mapped and that there is little to be gained by remapping them.

Regarding the mapping of private fibre networks, it is our opinion that it is an important exercise because it could help the Government to make informed funding decisions that can avoid situations where such networks are overbuilt, that is to say, avoiding the occurrence of double spending where no additional benefit results from the taxpayer’s perspective. Consequently, RISPA believes that all private communications network operators, not just fibre operators, should be afforded a reasonable opportunity to respond to the mapping exercise and, in turn, that network operators should have an obligation to ensure that the data they supply is accurate so as to minimise the cost to the State. Interlinked with this viewpoint, RISPA believes any decision to provide funding for a network operator should not wrongly disadvantage an ISP who is delivering quality services in their locality.

RISPA's opinion regarding the mapping of mobile black spots is that the exercise is of limited value with respect to addressing Ireland’s connectivity gap. Our position on this matter is due to the nature of mobile communications technologies being unsuitable for the provision of high-speed broadband in rural environments.

This concludes our opening statements and our answers to the questions which we were asked to address in advance. I yield to the Chairman to decide whether the committee would like me to present RISPA's submission or to move directly to questions on it, if all members have read it.