Hello everyone,
This (rather long) note is my tentative contribution to the Parliamentary Committee.
I'd be interested in the views of others on these topics which are coloured red below.
Kind regards,
Walter
The following link provides access to the appropriate enquiry scope. The lines in Red are the topics listed at present.
http://www.parliament.uk/parliamentary_committees/berr/becpn47_0809.cfmWhether the target for universal access to broadband at a speed of 2Mb/s by 2012 is ambitious enough?No it certainly isn’t. In order to ensure a reasonable minimum speed at the extremities it is important to specify much faster speeds closer in. Were fibre being deployed there would be no need to consider speed in as much detail as it is so much faster and importantly provides similar upload and download speeds that Asymetric DSL doesn’t.
Is the Government right to propose a levy on copper lines to fund next generation access?No, it is wasteful of resources and would require yet another Government administrative body; The Telcos would also have to set up otherwise useless administrative systems. The proposed levy isn’t nearly big enough to have a major impact. It also seems unfair that the poorest people would be penalised when it’s most unlikely they would ever use broadband.
Will the Government's plans for next generation access work?No, this type of intervention will seriously distort broadband design and implementation plans. All of the stop-gap designs to meet this very low standard have limited or non-existent upgrade paths to reasonable speeds. There can be little doubt that we need to catch up with under-developed countries such as Slovakia who have already implemented phase one of a national Fibre To The Home scheme.
If companies are providing the speed of access which they promise to consumers?Yes in most cases they are, as they have to include caveats to cover the copper line distance and quality limitations as well as their capacity costs.
The extent to which current regulation strikes the right balance between ensuring fair competition and encouraging investment in next generation networks?Current legislation has allowed Virgin Media (via NTL and Telewest etc.) to provide fast FTTC solutions and has also provided a platform to allow many ISPs to provide ADSL broadband over the existing BT copper infrastructure but the whole process is flawed as there is no obligation for BT Openreach to maintain the local loops in an adequate condition for optimum broadband performance. They only have to provide a 3 kHz audio capability and this can be satisfied even with crossed pairs of wires which are disastrous for an ADSL specification which relies on balanced twisted pairs. Furthermore business pressures are forcing BT, who are at a serious technical disadvantage, to concentrate on the more economically attractive areas of the country that already have mainly Virgin Media services at the expense of ignoring sparser areas completely. Likewise Virgin are also not interested in the sparser areas. There is a strong case that sparser areas are much more in need of fast broadband in order to compete with urban facilities enjoyed by other more fortunate users.
and
Any other views stakeholders think the Committee should be aware of.The BT Group are not funding BT Openreach sufficiently to maintain or improve the copper network. In some areas there is a significant shortage of copper pairs as evidenced by the number of DACS line-sharing units deployed. DACS circuits are totally incompatible with ADSL broadband signals. Furthemore BT are being evasive and deliberately obstructive - see Appendix A. They also have not set up a channel to allow local groups to contribute financially to improve their networks and currently have refused such contributions!
It is clear that the BT Group, who have announced some financial difficulties in their oversea operations, are attempting to invest in areas they hope will be more profitable.
This produces two undesirable consequences, viz.
Maintenance is kept at minimum levels to support their obligation to provide voice-only services.
BT are investing heavily in Next Generation Access exchange equipment and FTTC mainly for the most profitable areas only.
Unless BT is to be re-nationalised they cannot be expected to deploy their Fibre capital in areas of poor return which is generally where the worst broadband areas are. Nor can they be expected to invest in upgrading the copper network in bad areas. It follows that one of the few ways of resolving these fundamental difficulties is to segregate BT Openreach completely from its parent and provide it with significant Government funding to refurbish the copper network, as well as install new FTTC cabinets in sparsely populated or very long line areas. However the true costs of copper refurbishment and maintenance should be carefully compared with the cost of installing and maintaining FTTH; if they are similar FTTH is to be strongly favoured.
Appendix A
Hambleden (Near Henly where protracted negotiations to install a trial FTTH scheme have achieved absolutely nothing, despite a small enabling subsidy)
Peaslake Road (BT's refusal to accept a contribution from local residents to install a 0.4 Km overhead line to replace a 1.2 km loop of poorly-performing cable.)
Appendix B
The following is provided as a typical approach to assist in solving the national crisis we face. It is offered as a simplistic solution which, if the appropriate people were persuaded to negotiate fairly, could produce a viable mechanism to overcome the national emergency. An alternative is to re-nationalise the entire communications industry.
Given:-
1.1 Virgin media have a fully working fast FTTC solution running reasonably well and they are planning network upgrades and expansion of the areas they cover. They have also obtained backbone internet infrastructure. However they do not want to invest in areas which are unlikely to provide sufficient Return On Investment from FTTC.
1.2 BT at Hambleden have shown they are an unreliable fibre negotiator. However they have a major investment in the backbone internet infrastructure, but which will probably need reinforcement in the short to medium term. BT have announced an outline plan to provide FTTC over poor unshielded twisted pair copper in some instances, often in competition with Virgin Media with a superior co-axial copper implementation.
2.1 The UK has a national communications investment emergency. (As a low-level example I know of 3 services in Ewhurst which are no longer adequate, even though they had been in the past. Currently BT Openreach are not obliged to invest the required capital to remedy the situation.)
2.2 It follows that Virgin Media should offer a wholesale arrangement to allow others to provide high speed broadband using Virgin’s infrastructure.
2.3 In exchange for wholesale access to Virgin’s network BT should be prohibited from installing competing network equipment in areas already covered by Virgin.
2.4 BT should then be expected to install FTTC systems in the next lower-cost areas.
2.5 The remaining areas with PSP green street cabinets should be provided with FTTC by an entirely segregated UK Openreach group with government funds. In addition “UK Openreach” must be tasked with refurbishment of the D side copper loop and the elimination of all DACS units. This will require significant investment in larger local cables.
Where thought economic FTTH solutions should be installed instead of copper upgrades, most especially on "D side" lines of over say 3 km.
2.6 Only those areas with very long lines, either direct from rural exchanges or from very remote PSPs should be considered for alternative limited broadband solutions such as satellite or wireless in the immediate future and to be given top priority for FTTH investment. Any solutions proposed without a viable expansion route just to obtain the proposed phone line tax money should be prohibited.
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