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Consultation Response to:

To date, ComReg has issued Quarterly Report data directions to authorised operators who are considered to be actively offering electronic communications services to consumers. This decision is based on monitoring of ComReg’s Electronic Register of Authorised Undertakings (ERAU)  and monitoring of operator websites. Such data directions are issued to around 90 such operators each quarter.

ComReg is now proposing to apply a minimum threshold of €800,000 in gross revenues per annum, to capture data from the most significant operators in the Irish market. This proposal is being made to ensure that the burden of data collection on very small operators is reduced, and also to reduce the administrative burden and costs incurred by ComReg and by smaller operators.

If a materiality threshold based on turnover is implemented, ComReg will need some method of monitoring authorisations to ensure that new companies added to the general register are sent data directions once their turnover is above the threshold. Information on company turnover is available through the Telecoms Levy which is imposed on all companies above a specific turnover threshold. Information is also supplied to ComReg when an operator applies for a General Authorisation. In addition, financial information on companies registered in Ireland is available from the Companies Registration Office (CRO).

Q. 1.    Do you agree or disagree with ComReg’s proposed approach to data collection? Please detail your response and, where possible, support your response with evidence.

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The consultation period will run from September 2008 until October 22nd during which the Commission welcomes comments on any of the issues raised in this consultation.

Having analysed and considered the comments received, ComReg will review the use of the proposed materiality threshold and publish a report in Novermber 2008 on the consultation which will, inter alia summarise the responses to the consultation.

In order to promote further openness and transparency ComReg will publish all respondents’ submissions to this consultation, subject to the provisions of ComReg's guidelines on the treatment of confidential information – ComReg 05/24.

Please note
ComReg appreciates that some of the issues raised in this consultation may require respondents to provide confidential information if their comments are to be meaningful.

As it is ComReg's policy to make all responses available on its web-site and for inspection generally, respondents to consultations are requested to clearly identify confidential material and place confidential material in a separate annex to their response. Such Information will be treated subject to the provisions of ComReg's guidelines on the treatment of confidential information – ComReg 05/24

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