Broadband - Business, Innovation and Skills Committee Contents

Memorandum submitted by BBBritain

  BBBritain represents a group of avid Broadband users keen to get the most from our connectivity and keen to assist our neighbours and friends to do the same.

  Several submissions were made to the Digital Britain team, including the design of a Universal Broadband service, one of whose components was a 50p levy on all existing Broadband users.

  The following comments arise from watching the video link of the event and are given as an answer to the questions and a reaction to the evidence presented.

Whether the target for universal access to broadband at a speed of 2Mb/s by 2012 is ambitious enough?

  Best effort 2Mbps is a start and it is important to treat the commitment as such. In the context of moving from a best effort commitment to an obligation to deliver a specific minimum service with a specific minimum quality, then such a move would need to be driven by the need to achieve specific outcomes.

  The hearing did not reference the transformation of the delivery of key government services, be it education, healthcare, or care of the elderly or support for people who are deaf, or blind. This debate is much needed and key to driving cost savings in government budgets. In any debate on carbon reduction then the suitability of out networks to support quality video telephony and video conferencing and quality home working ought to be discussed.

  It is quite possible that a 2Mbps service appropriately defined as symmetrical with the minimum quality values for loss and delay characteristics could support all the outcomes we would need.

  Equally we could have a 2Mbps ADSL from one of today's operators which would prove incapable of supporting any critical service.

  One of the challenges we have on our existing competitive offers is that the services are engineered for best effort browsing and downloading. They are not today engineered for key service delivery making task substitution sometimes difficult to achieve. This is complicated further by existing incumbents need to protect existing legacy voice revenues. Relying on the competition as a force of change is not enough when the level of disruptive change demands incumbents including new operators like Carphone Warehouse to re-write their business models.

  In my opinion the move to a Universal Service Obligation should be underwritten with targets for journey reduction and targets in delivering education, health care, and the support of quality home and flexi-working. The latter sends a clear message to industry that best effort Broadband with no assured outcomes will be of limited value going forward. It would also make clear that government and its contractors will be using and paying for services to transform front line service delivery.

  When Andrew Heaney of Talk Talk, states folk are unwilling to pay for more services, he should have made it clear that no ISP guarantees any outcome at present. In the quest to create the lowest common denominator service, expectations of what is possible drop. The recent case of the Ukraine vs England world cup qualifier was a good example of the catch 22 we face. People are unwilling to pay because the networks are not configured to deliver a good user experience.

  The debate on a Universal Service Obligation is important, but to be meaningful the debate must be reinforced by some hefty policy objectives in terms of how public services are delivered and consumed in future. It is our view that the a move to an "obligation" is needed if the Government service transformation objectives intend to use high speed networking as a way to deliver services.

Is the Government right to propose a levy on copper lines to fund next generation access?

  Public investment is needed. The levy on fixed lines is peculiar. BBBritain suggested a tax of 50p a month on all broadband connections plus the re-investment of spectrum fees collected by Ofcom.

  However odd, we remain supportive of the investment. We also believe that Carphone Warehouses opposition to the 50p is related to the long term impact of NGA on the valuation and sale of Talk Talk Broadband. NGA bypasses LLU exchanges reducing the value of these assets they plan to sell.

Will the Government's plans for next generation access work?

  The upgrades announced by BT and Virgin Media and the use of the levy to extend NGA access further are good building blocks.

  The clearance and re-farming of radio spectrum for Mobile Broadband services is also a good structural move.

  The above steps keep the UK in the middle ranks in terms of the nations connectivity. The term "fit for purpose" has been used but not defined.

  The plan could be enhanced further if they a vision for future public service delivery was outlined and support by a visible implementation programme.

  This could put in context the USC of 2Mbps service, the need to convert that to a USO to support critical service delivery and onward development to NGA roll out. The debate has been hampered and somewhat misinformed by a singular focus on speed, where speed on its own does not create or enable a service.

  The following steps could be included in a more comprehensive Digital Britain plan.

  The most important step Government could take is have a plan to transforms its own costs by transforming the ways keys services are delivered. Government is proving more than capable of collecting taxes on line but is less focused in transforming the delivery of front line services. A commitment with visible targets to do so, particularly the delivery of health, education and care would drive next generation network services and would force operators to improve the quality of Broadband services. The vision for transforming Government services and the vision for a better connected society are tightly intertwined.

  The proposal to auction and re-farm radio spectrum for next generation Mobile Broadband services should have some additional conditions attached, including the need to enable the convergence of mobile and fixed data transport fabrics. Users are accessing the same set of services from our computing (Mobiles, laptops, set top boxes), using the same protocols so why use regulation (market definitions) and a auction process (designed to ration bandwidth) to keep our fixed and mobile connectivity separate.

  It would be sensible that the laying of fiber to cabinets at a street level be coordinated with the upgrades to mobile base stations, particularly in area 3. The convergence of the data transport fabrics should allow a multi-media communications service to emerge to replace the legacy PSTN and Mobile voice services.

  The need for five separate and incomplete mobile networks offering indifferent and incomplete coverage should be reviewed. Capacity and coverage could be increased if two network providers were tasked with delivering wholesale high speed access to all service providers. It would reduce the yield in the proposed auction but the network upgrades could be delivered earlier, with significant improvements in coverage and a reduced carbon footprint in powering five overlapping and bandwidth constrained networks. It would also allow all spectrum to be used to boost coverage and speed rather than rationed on a per operator basis.

  It should also specify that each of the Mobile Base station upgrades include the use of fiber. The use of the spectrum auction to create bandwidth scarcity has to be avoided. Separating the network upgrade function from the selling of services would assist this process. Thus not just the sharing of networks need to be encouraged but the sharing of spectrum. This includes the use of mobile access points at the end of our fixed broadband connections so coverage and service could be improved.

  The rates issue on new fiber builds need resolving. Apart from Ireland no other country in Europe is charging rates on new fiber builds in this way. In addition BT should be where possible be encouraged to rent its duct space where possible a £1 pa per metre.

  Parliament should also push Ofcom to deliver a interconnect regime based on bits transferred as opposed to the proposal to allow call conveyance based interconnect and cost recovery to continue for another four years. At the very least an interconnect regime based on bits transferred should be run in parallel with the call conveyance proposal.

  Commitments to improve the UK data transport infrastructure to aid road traffic congestion ought to be a specific joint Government and industry programme. MPs have every right to be question each time they make a needless journey or overpay for a rail fare. This is a cost of failure of the UKs data infrastructure and an everyday example of being unfit for purpose.

If companies are providing the speed of access which they promise to consumers?

  The promise of "up to" speeds have little meaning, Up to represents a potential, not an actual. The Ofcom and industry guidelines are an effort to reduce mis-selling but do not inform customers as to the true nature of their connectivity.

  At a minimum operators should publish their planning rules to highlight what resources they are building to facilitate the service we purchase. Operators should also publish the emergent operational properties of their networks so application builders can engineer services to work. This would translate into a commitment to deliver a very minimum peak time throughput as little 30Kbps per second with an ability to download as much as up to 24 Mbps when nobody else is using the service.

  Speed on its own means very little, and average speed as published by Ofcom contributes little to the debate. Customers need clear labelling as to the nature of their connectivity and what services will work and will not work.

  The extra payments ISPs wish to charge will not materialise unless they move from the one dimensional mis-measure of speed only. The focus must be on service delivery, which is a function speed, quality of the bandwidth and the resources in place to service the busy period.

  In the context of Digital Britain, the up to speed assertions both mis-sell and undermine for the medium the true potential of our connectivity.

The extent to which current regulation strikes the right balance between ensuring fair competition and encouraging investment in next generation networks?

  The current regulation has supported the roll-out of first generation best effort broadband services, using existing copper infrastructure. Given the mission, regulation has succeeded in the fixed line ADSL services. The roll out of Mobile Broadband is less successful given the distortionary effects of the £22.4 billion spectrum auction heist in 2000. Given the debt individual companies operators carry and the fact BT has no Mobile interests does mean customers have several discrete contracts for accessing what are the same information, communication and entertainment services.

  Ofcom to date has done little to encourage investment, but focused on creating opportunities for new providers to gain a foothold in the market. Ofcom rather than taking a self critical approach to its role has instead played a full part in the propagandising of speed only, and has made little contribution to outlining the true nature of the UK data transport infrastructure today and what its needs to be.

  The very success and popularity of first generation broadband services has created an expectation gap between users who were promised a great deal and have a thirst for more connectivity and industry who have delivered cheap services which are limited by the need to ensure our high speed connectivity is not used to undermine legacy voice revenue streams. Although IPTV is being portrayed as the application to drive NGA subscriptions, this is a big assumption and a certain amount of wishful thinking. Consumers are already paying for a TV licence and many are paying for Sky and Cable packages. Paying a third time for the same content is peculiar.

  During the course of the hearing we heard repeatedly that Video is driving usage and volume of usage is doubling but people are not willing to pay for it. If people are already paying two TV subscriptions then any new payments may be substitutional in nature. The unwillingness to pay more is a reflection on the current lack of quality connectivity. Consumers cannot be expected to pay more if no assurances can be given that an application will work, or where a customer has not been allowed access to prioritise their traffic so the application can be made to work.

Any other views stakeholders think the Committee should be aware of

  The internet did not arise as a result of competitive forces but came from collaboration across a great many publicly funded institutions.

  Internet technologies represent a huge threat and opportunity to re-invent existing services. The advent of email, instant messaging, twitter, webcasting to name just a few are all enabled by these internet technologies. Phone companies like BT and Talk Talk, while making money from Broadband subscriptions are all hugely threatened by the possible impact of the these same technologies on their legacy services.

  Thus, the investment question is difficult and complex. The investments in Korea and Japan are not just about speed but the re-invention and replacement of legacy voice services, the convergence of fixed and mobile networks, all underwritten by the need to fundamentally re-examine how services are delivered in the future.

  It is in this context that the Digital Britain report is very much a first draft and very welcome one as to what a UK Information society might look like.

  The gap between what the market is delivering, and users expectations is growing as the amount of processing power we possess is growing. Laptops, smartphones, games machines, set-top boxes are all providing a standard means of accessing information, communication and education services.

  Our homes, libraries, schools, workplaces are all connected in what is in effect a 24x7 UK bit commons. There is a revolution taking place in how we learn, work and communicate. The declaration that our connectivity is "fit for purpose" displays a very complacent mindset. Each time you are irritated by an inability to connect with what or who you need, is an example of the UK data transport infrastructure failing you, or somebody failing to use the connectivity available.

  The 2Mbps USC is a first step and this Parliamentary group need to demand steps two to five to be outlined. This will include targets for transforming Government service delivery through to the high speed networking needed to support such services. The latter demands we move to a USO, a drive to converge fixed and mobile networks, and a need to replace legacy fixed and mobile voice services with multi-media communications.

  This is disruptive to industry, to regulation and the tax system. As a country, a vision and a plan to fulfill that vision need to be articulated. Todays "fit for purpose" connectivity should not be accepted as anything other than a starting point. It is a mere appetiser as to what is possible and what we know is possible through utilising first generation best effort connectivity to the internet.

  Finally, the Digital Britain forensic investments are just that, a deposit. The need to accelerate investment in this sector to realise earlier the benefits of a "bit" based economy should not be ignored. Industry should be asked what is needed to achieve more, faster. The re-investment of spectrum fees, the re-definition of markets, the change in USO from telephony to data transport, the merging of fixed and mobile networks to create a UK data transport fabric should be addressed with determination. None were during this review.

November 2009

previous page contents next page

House of Commons home page Parliament home page House of Lords home page search page enquiries index

© Parliamentary copyright 2010
Prepared 23 February 2010