Please send a submission to ComReg by 5pm, this Wednesday, 11th May 2022

In March 2021, Openeir (Eir) issued a White Paper called Copper Switch-Off – Leaving a Legacy for the Future, detailing the plan to migrate from the traditional copper landline network to internet based digital telecommunications, which will mean switching off and decommissioning all our landlines and eventually removing the copper network altogether https://www.openeir.ie/wp-content/uploads/2022/01/White-paper_Leaving-a-Legacy.pdf

On 28th March 2022, ComReg published a 69 page document, Framework for the Migration from Legacy Infrastructure to Modern Infrastructure, https://www.comreg.ie/media/2022/04/ComReg-2213R.pdf calling for input and responses from stakeholders. There was no publicity about this, no information on any Govt websites or in the media.

Please take part in this consultation and tell ComReg why traditional copper landlines must not be removed and that there should be a choice to use either the copper landline network or digital networks.  INFORMATION HERE https://www.comreg.ie/framework-for-the-migration-from-legacy-infrastructure-to-modern-infrastructure/

Responses should be clearly marked with subject Reference: Submission re ComReg 22/13

Responses by: 5pm on 11 May 2022

Email responses to: products@comreg.ie or by post

_____________________________________________________________________

WHAT IS THE COPPER SWITCH-OFF?

The plan is that all telephone landlines will be utilised through the fibre network only, using data over the internet or Voice over the Internet Protocol (VoIP).

Over the last few years, some people have already chosen to give up their landlines in favour of mobiles, or use VoIP connected to their broadband. However, there will be negative consequences to getting rid of existing copper landlines altogether and having only digital telecommunications.

People should have the choice.

· If the internet goes down, for whatever reason; a power outage caused by storms, maintenance work, cut off by electricity suppliers, sabotage, hackers etc, digital VoIP landlines will not work – unless you have your own back-up power.

Copper landlines have, more often than not, stayed working during power outages as they are independent of home electrical power and the main electricity grid and have their own exchange and power generators. This has been the case for decades.

In fact, in a Consumer Survey carried out by ComReg in 2021 they found that: 41% of those with a traditional fixed landline with no power cable have a misperception that their service will not work in a power outage https://www.comreg.ie/media/2021/12/ComReg-21143a.pdf

· If there is no power or internet connection for a few hours or longer, the alternatives are having a power supply back up or a charged up mobile phone (that’s assuming nearby mobile phone masts still get power in a power cut). Everyone, especially those who are vulnerable, should have immediate access to emergency services. Lives will be put at risk if the more reliable landlines are removed.

· Having to use or have a mobile or smart phone instead of a copper landline is not a viable option for some people, including:

• Those of us who do not have or want a mobile phone due to adverse effects on our health and being unable to tolerate using them or being near any wireless/smart devices.

• Others who have made the choice not to have smart phones.

• Elderly people who are not able to use a mobile or smart device, and more comfortable with traditional landlines.

• Not everyone wants, needs or is able to use a mobile phone and no should have to get one, and pay a monthly contract, when we have a safer and more reliable existing network.

There are some people who do not want, or need, broadband installations at their homes either which would be necessary to facilitate VoIP landlines. Current traditional fixed telephone landlines are what most of us have, are used to and they are the most reliable telecommunications technology.

· It is very important to have the option of turning off our routers (and wifi) at night or when out or not in use, as a safety measure and to avoid wastage of energy. The new system would mean either that when people turn off their routers, they would also be turning off their home phone system, or there would be no option to turn it off at all, neither of which is acceptable.

· Many older and vulnerable people rely on Emergency Response wearable alarms which need to be connected to their home landlines, in case of an emergency and to feel more secure in their own homes. It is not known if all these systems will still work on VoIP when installed, but they definitely will not work if there is a power cut or the internet goes down. How will a vulnerable person call for help if they don’t have power, a working landline or a mobile phone? And what if they don’t have a charged mobile phone or mobile coverage? All this will cause considerable anxiety to many. It could also be used as an excuse to install even more mobile phone masts and base stations.

· As well as Emergency Response systems, the changeover may also impact burglar alarms and other systems connected to landlines. There is uncertainty around this and it seems from Openeir’s White Paper that customers and the providers of these systems will have to work this out for themselves. (p 14)

· The copper landline network is already fully in place and has worked successfully for decades. It doesn’t make economic or environmental sense to remove it and it would be extremely wasteful to discontinue and rip out this national, efficient, safe and important service. Maintaining the existing network would be more beneficial for the environment, our security, safety and health, than a network that needs to be plugged in and requires more data and energy consumption.

· VOIP lines are less secure than traditional landlines and can be hacked more easily.

‘It is easier for hackers and eavesdroppers to intercept VoIP data, thereby breaching your privacy. The packets are disseminated over the internet through unsecured channels and are easily intercepted at any node. Moreover, since the data is digital, it can be stored and manipulated in ways that PSTN data cannot.’ https://www.lifewire.com/are-you-calls-secure-on-landline…

· Traditional landlines provide clearer, cleaner reception and sound quality than mobile calls or VoIP digital calls which generally have interference and poorer sound. There will be a lot of data traffic on VoIP internet lines, competing with internet usage, streaming, downloading, uploading, online meetings etc, etc

______________________________________________________________________

The following are from UK where the changeover is already in progress and copper landlines decommissioned in some areas, but due to public concerns and pressure it has been temporarily halted by BT.

Is the proposed axing of landlines by 2025 a betrayal of the most vulnerable? https://www.mailplus.co.uk/…/is-the-proposed-axing-of…

BT to end landline phones sparking fears for millions of vulnerable and elderly people https://www.mirror.co.uk/…/bt-end-landline-phones…

Why axing landlines is a betrayal of the most vulnerable: The brave new world of digital phone lines means many could be cut off https://www.msn.com/…/dame-esther-rantzen…/ar-AAVnSUj

House of Commons Digital Telephone Switchover https://researchbriefings.files.parliament.uk/…/CBP…

UK Petition to Save Landlines https://www.ipetitions.com/…/save-our-landlines-help-us…

____________________________________________________________________

COMREG’S CONSULTATION IS OPEN until Wednesday 11th May 5pm. PLEASE SEND THEM A MESSAGE : KEEP OUR COPPER LANDLINES https://www.comreg.ie/framework-for-the-migration-from…/–