Memorandum submitted by Thinkbroadband
INTRODUCTION
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.
ABOUT THINKBROADBAND
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 ADSLguide.org.uk 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 broadband-notspot.org.uk,
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.
RECOMMENDATIONS
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
http://www.ietf.org/rfc/rfc2460.txt Back
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