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
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