Broadband - Business, Innovation and Skills Committee Contents

Memorandum submitted by Thinkbroadband


  1.  We would like to thank the Committee for giving us the opportunity to present a written submission to its inquiry. We are very pleased to note that both the Government and the Committee consider broadband access very important in today's society.


  2.  Thinkbroadband is an independent broadband information resource for consumers to read about broadband related developments, obtain advice about broadband services, identify and resolve problems relating to their broadband connections and help other users in an online forum community. It was set up in 2000 under the name when the initial ADSL broadband trials were under way and was re-named thinkbroadband in 2006 to encompass other broadband technologies such as cable and mobile broadband.

  3.  We operate one of the most popular free web-based "speed test" tools and have handled over 27 million speed tests.

  4.  In May 2009, we launched, a website to track the UK notspots (areas of no broadband service) and slow-spots (areas where only broadband services running at less than 2Mbps downstream are available). We have had over 8,000 reports from users around the country. The data is publicly available on the site for users, policy makers and service providers to use to help improve broadband coverage.

Response To Issues Raised By The Committee

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

  5.  BT started trialling ADSL services on a wide scale in 2000 offering services at 0.5Mbps (for consumers and businesses) as well as 1Mbps and 2Mbps (for businesses only). In 2006, they launched the rate adaptive service that could allow many lines to receive faster service, in some cases up to 8Mbps. In autumn 2005, several "local loop unbundled" operators (competitors to BT) launched ADSL2+ services with speed of up to 24Mbps with BT following suit with a large scale rollout in 2009. In the first half of 2009, Virgin Media rolled out its "up to 50Mbps" service. Today, we are seeing small-scale trials of services up to 100Mbps. 80%[166] of households in the country is now covered by ADSL2+ services.

  6. Both our own research and Ofcom's broadband survey have found download speeds across the UK averaged at between 3.2 and 3.6Mbps in 2009.

  7.  The current high definition stream on BBC iPlayer consumes up to 3.5 Mbps.

  8.  The Digital Britain Report proposes a Universal Service Commitment (USC) of 2Mbps by 2012.

  9.  Whilst we appreciate that delivering 2Mbps to those currently unable to receive any broadband service is a huge step, we feel that the level at which this commitment was set is too low, taking into consideration it will only become effective in 2012. As broadband speeds increase we will see new services develop and those with slow connections will become more and more disconnected from the digital society as they cannot access the same range of interactive services. We must not allow the slowest parts of the country, the digitally disadvantaged, to fall so far behind.

  10.  We do note the Digital Britain Report suggests that "next generation-compatible solutions" will be considered where possible, however we are concerned that funding limitations and the separation of the projects relating to the Universal Service Commitment and delivering next generation access for the "final third" may discourage a long term strategy. Our overriding concern with setting a 2Mbps rate without firm commitments beyond 2012 is that the technology used may not be future proof, and thus may not be an efficient use of taxpayers' money in the longer-term.

  11.  We are also concerned that the USC does not address metrics other than download speed. In particular, we would suggest that upload speeds are likely to become increasingly important given the way in which the web is changing to be more interactive. Other metrics including latency, packet loss and jitter should also be taken into consideration as these may affect the experience of users of some real-time applications.

  12.  The USC does not specify whether a user should be able to receive a 2Mbps service throughput the day, or simply at off peak times.

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

  13.  It is a matter for policy makers to determine whether general taxation or a specific levy similar to the TV licence (as effectively proposed) is most suitable to fund the development of next generation broadband. We would point out however, that the benefits of universal broadband reach the UK economy as a whole, and focusing the funding on those who have copper phone lines might unfairly impact those with no interest in next generation broadband services who simply want a phone line for security and as a lifeline.

  14.  We have some concerns that the levy applying to copper telephone lines may have the following unintended side effects:

    (a) Giving a competitive advantage to mobile operators over fixed line networks in providing of low cost telephony and/or broadband services.

    (b) Giving a competitive advantage to cable operators to provide broadband services (possibly with a VoIP service over the Internet as a replacement of a fixed telephone line) and thus not providing a copper phone line liable to the levy.

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

  15.  We are pleased to note the Government's intervention to deliver next generation access to the "final third". We do not have the expertise to comment on the financial aspects of the arrangements in any detail.

  16.  We would refer you to our comments below regarding non-domestic rates applicable to fibre, which we believe still discourage adoption of the underlying technology which can deliver next generation networks and beyond.

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

  17.  The problem of understanding how broadband speeds are affected by various technical conditions is quite complex and users are often confused as marketing material does not, and generally cannot, give them a realistic indication of the speed they can achieve on a particular line at a particular time and to a particular destination.

  18.  ADSL broadband, delivered over telephone lines is available to over 99% of the country, and is in many cases, the only viable option. BT Wholesale and Openreach provide wholesale services to service providers, so a consumer can purchase a service from one of hundreds of companies. With ADSL, an estimate can be made when the service provider has the line details of the user and the approximate length of the line can be compared against data to give an indication of the likely speeds the household should be able to get.

  19.  Broadband services are generally marketed using headline speeds, such as up to 8 meg This is the maximum achievable line speed in optimum conditions. In ADSL broadband, the speed of the service is primarily dependent on the distance of the premises from the telephone exchange; the further away you live, the slower the speed you will be able to achieve. This is because the ADSL signal weakens over distance. Other electrical interference can also slow the connection, including faulty household appliances such as boilers, incorrect wiring of home telephone extensions, missing microfilters on Sky satellite receivers or alarm systems and even some Christmas tree lights.

  20.  Cable broadband services are not affected by line distance in the same way as it uses a different technology, although cable broadband users are nevertheless still affected by many other factors both within a user's control and on the service provider's network. Cable broadband is available to around 40-50% of households, and not generally in less densely populated areas which suffer most from next generation coverage issues.

  21.  The speeds achieved by a user at a particular time will depend on the following:

    (a) Matters under the user's control or influence:

(i)The user's choice of broadband package (or awareness of faster services);

(ii)The specification of and current activity on their computer. Older computers can slow down when busy. Computers with unnecessary software installed over years can also begin to struggle;

(iii)The activity of any other members of the household who may be sharing the same Internet connection;

(iv)The speed and stability of the connection from the computer to a wireless access point/router. Interference from other wireless networks can slow down connections. Also, the speeds advertised for wireless routers are optimum speeds; most users won't get the maximum speed. The user may be able to change settings to optimise this;

(v)The speed and capabilities of the router itself. Compatibility issues between ADSL equipment in an exchange and the consumer's choice of router. [This may be under the service provider's influence if they supply the router];

(vi)Quality/wiring of any telephone extension wiring inside the house/flat;

(vii)Electromagnetic interference caused by faulty household appliances;

    (b) Technical limitations (some under control of wholesale operator)

(i)The length and quality of the telephone line itself (ADSL);

(ii)Any electromagnetic interference outside the house or neighbourhood; including some weather conditions (ADSL);

(iii)The congestion on the trunk links between the aggregation point (eg telephone exchange) and the core telecommunications networks (and depending on technology, how much bandwidth your neighbours, village or town are using) [in some cases Service Providers may have some control over this];

(iv)Compatibility issues between ADSL equipment in an exchange and the consumer's choice of router;

    (c) Matters under service providers' control

(i)Congestion between the core network nodes (wholesalers) and the service providers;

(ii)Congestion inside a service provider's network and their various "Internet" links. It is worth noting that this effect can mean that traffic to one website will be fine, whilst another website may be slow if one part of the service provider's network is congested;

    (d) Matters out of the control of anyone involved in providing the broadband service

(i)Problems of various kinds "on the Internet" outside the control of the broadband service provider or at the destination web server.

  22.  Whilst many of the above factors affecting speeds are not under the Broadband Service Providers' direct control, they can for example help users identify what is possibly causing speed problems. For example, if home wiring is the likely cause, there is a small device costing less than £15 which can be fitted in some cases, which can double the speed by filtering some of the interference.

  23.  Advertising—It is inevitable that service providers will seek to use the fastest possible headline speed in advertising. If you consider two providers using the same underlying network, but one offered a speed of "up to 7Mbps" (which is closer to the actual maximum possible IP throughput a user would see on an "up to 8Mbps" ADSL line) and another offered "up to 8Mbps", it is likely that more users would be drawn to the "faster" service even though in practice both may be exactly the same. This is complicated by the fact that some service providers will contend their networks more, ie they have less capacity per user than other networks, so traffic jams can occur, particularly a peak times. This is no different to having difficulty finding a seat on a peak time train. The key here is user education and informed choice. Some may prefer a reserved seat (ie guaranteed connectivity) whilst others are more price sensitive.

  24.  The Advertising Standards Authority must be clear on what is acceptable when it comes to advertising of headline speeds, and over the years, we feel they have not provided a clear enough signal to service providers.

  25.  We are concerned by the use of the term "fibre-optic broadband" in advertising for services which are based on fibre-coax or fibre-twisted pair hybrid fibre-to-the-cabinet solutions. It is important that this marketing activity does not detract from the need to expand fibre optic coverage and in particular eventual "fibre-to-the-home" (FTTH) rollout. We would stress this point to ensure that FTTH remains firmly on the agenda rather than as a criticism of the companies using this terminology.

  26.  Consumer expectations of speed—Broadband is still often sold on an "all you can eat" basis quite similar to how water is charged for to households without a water meter. Some people believe that they "pay for 8 meg" (or whatever headline speed they purchase) and thus should be able to use this full capacity 24x7x365 without hindrance. This type of use is quite similar to leaving all the taps running on an unmetered water supply. In order to be able to receive faster "on demand" speeds, consumers will need to accept that they cannot have an uncontrolled, "unlimited" package with no constraints at all.

  27.  In summary, ADSL service providers who supply consumers with broadband services will find that the costs of delivering a 7Mbps and 3Mbps service is more or less the same (assuming the usage profiles are identical) as the line rental fees charged by Openreach are not dependent on the quality of the phone line and thus the maximum speed they can achieve. This can make it difficult for a consumer to understand why they have to pay the same charge for a slower service.

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

  28.  "The Internet" is a virtual environment which is only possible due to the interconnection of all the tens of thousands of network operators around the world. The degree of interconnection will vary by network with some being connected to only one "upstream" network, and others being connected to thousands of other networks.

  29.  In the UK, the network operators have congregated around London's Docklands area, where most public interchange of UK Internet traffic happens, traversing from one network operator to another.

  30.  Fibre optic cables are capable of delivering multiple 10Gbps (10,000Mbps) connections and the 100Gbps standard has just been ratified. In the longer term, it is likely that fibre optic cables will become the most efficient way to deliver high speed telecommunications services to homes and businesses.

  31.  We take the view that it is in the UK national interest, for the benefit of the economy, redundancy to cope with unforeseen localised events and in the interests of promoting competition, that better interconnection should be achieved between data centres, the large scale computer rooms hosting websites, around the country. We also believe that fibre optic cables are going to be key in long-term broadband solutions.

  33.  To this end, we believe the non-domestic rates applicable to fibre optic cabling are a tax on efficient interconnectivity, and should be abolished to encourage faster and more reliable connectivity. There is a case for government considering further ways to encourage building of next generation networks.

Any other views stakeholders think the Committee should be aware of.

  33.  The Internet operates using the Internet Protocol (or "IP" for short), which identifies each computer uniquely using a number sequence, a bit like a phone number. We currently use IPv4 (IP version 4) which has approximately 4,300,000,000 addresses and which is projected to run out in 2012. A new version, IPv6 has been in existence since 1998[167] but only a few niche service providers have adopted IPv6 and whilst the main operating systems now support it quite well, consumer broadband routers do not. This should be a matter of concern to government when developing strategy for next generation broadband and in particular a universal service commitment.


  34. Universal Service Commitment—The Government should require solutions funded by the Network Design and Procurement Group to be future proof where possible. It should also set targets going beyond 2012 and consider funding projects to deliver beyond 2Mbps in areas where this is economically efficient in the longer-term.

  35. Public Funding—We would suggest that where public funding is provided to assist in broadband projects, these are provided either to co-operatives or not-for-profit organisations working for the benefit of communities, or to a company willing to provide its services on a wholesale basis to other service providers (in addition to any retail operations it wishes to offer itself).

  36. Public Funding—We would recommend that publicly-funded projects should be required to support IPv6.

  37. Fibre Future—The Government should focus incentives to encourage building of fibre optic networks which can be used to deliver next generation broadband services. Where significant government support is provided (in the form of subsidies, direct funding or tax benefits), these networks should be open on wholesale terms for other ISPs to use in delivering services to end users. The Government should exclude fibre optic cabling from nom-domestic rates to remove a tax barrier to encourage better interconnectivity.

September 2009

166   Based on ADSL2+ coverage by TalkTalk's LLU network; BT currently have 40% coverage and expect to increase this to 55% by spring 2010 and 75% by spring 2011. Back

167 Back

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