Convergence Conversation

To recap the consultation dealt with the big change in BTs focus from replicating its PSTN service with a all new but similar IP based or emulated PSTN service to a focus on delivering higher speed connectivity using fibre to the curb.  The shock for Ofcom was the possible impact on ISPs investing in kit in BT exchanges,  when the pinch point would no longer be the exchange,  but the kerbside cabinets. Ofcom also took time out to express that IP was unproven for voice (unbelievable!), it was minded to continue interconnect based on call conveyance charges for another 4 years,  (not even run a bits interconnect regime in parallel),  and was generally unsure what to do about competition in the new local loop apart from ensuring a re-sale of BT components based on a BT design.

From an end users perspective the shift in focus on an all controlling next generation network to delivering more bandwidth has to be welcomed.  It was disappointing that Ofcom did not seize this opportunity to announce the need to review its market definitions and do some early direction setting in advance of its new responsibilities to secure more investment in the sector.  

Having had a quick trawl through the responses, there is a distinct lack of vision for the delivery of services.

BT did not state why the original 21C plan failed so badly.  Instead it states in no uncertain terms,  that the new focus on delivering high speed access demands that Ofcom let the market decide whats best,  which is; if you want next generation access we do it our way under our terms!  Touch it,  introduce any new rules and it will slow down investment.  Ofcom,  having joined and partaken fully in the politics of speed, speed, speed is being told with some glee to stay in its box or the planned upgrades will be at risk.  

Talk Talk spend a long time complaining about xMPF, something that means little to end users but would permit Talk Talk to collect more of the call origination charges and xMPF might have arrived if a mass migration to the new PSTN was in play.  No mass migration,  no xMPF,  no real loss to end users.  Talk Talk believe IP is proven and its time to change the interconnect regime, and question whether BT costs are any  longer representative of being efficient. The latter is a bit more like it.

C&W are equally put out on xMPF and make their annoyance clear.  They even suggest that it is time to look at the separation of transport from services.  They also believe IP is proven.  They also make the case for new interconnect product to offers something other than BT defined services in the local loop. Duct sharing at a £1m a metre just has to be part of the picture.

Sky is equally bemused.  BT delivery of voice over Next Generation Access ties operators to use BT's design as opposed to providing an opportunity to create something a bit different. This means the Voice over Next generation access preserves the PSTN and all that comes with it.  You also get a pre-configured notion of how quality of service is to work. To be fair our antiquated regulation,  and the soon to approved EU Telecoms package demands the PSTNs existence and BT can use this pre-condition to hard bake the design for all operators.  In so doing it creates immediate costs and limitations on the CPE being specified.  It also put design limits on how the available bandwidth can be used.

Vodaphone say little apart from how hard it is just to run a voice service and would you please leave us alone. Many alarm companies want addtional time and effort to convert existing customers.  Ericsson believe Ofcoms stance will cause operators to stall investments not increase them.

The really disappointing part of the consultation is that none of the major Government departments (Environment, Health or Education) made a contribution as to what their networking needs will be if they are to transform the delivery of their services.  It shows the shallowness of the digital inclusion activity and just how much work Martha Lane Fox has on her plate.  The requirements for better networking and monies to be expended to support the goals of these departments should be spelt out to warm the hearts of long suffering telecom investors.  The future needs and quantified objectives for home working,  assisted care delivery and additional educational services must be as important as a phone company or alarm companies pitching to protect legacy revenues.  No operator mentioned the convergence of fixed and mobile voice services delivered on a common data transport fabric.  No mention of multi-media communication services.  These are big omissions from a discussion on next generation networking. There was no mention of how spectrum policy is to be changed to support the delivery of Universal Broadband services.

Having spent 20 years making room for other operators, carefully defining markets to do so,  Ofcom will never admit to the need for a national champion(s).   But the silence on so many points is as good as a confession.  As this consultation shows Ofcom seems somewhat resigned to being dictated too on this matter.  Is there an alternative?  Is there a win win for Digital Britain and make UK investors?

Investing in VDSL by pushing Fibre and Cabinets to the curb, will not of itself change much.  We get more of the same services,  and just pay a £3-£5 a month to do more of what we are doing now.  We continue paying for two voice (fixed and mobile) services separately. More speed is always welcome, but does not change the nature of the services supported.

The strangeness appears when you say;  there is no plan to converge services.  There is no plan for a national fixed and mobile data transport fabric,  there is no plan to change our interconnect from call conveyance to bits transferred.  Our reference point for efficient costs is BT's TDM network. There is no plan to use our Broadband access points as Mobile network end points.  We are still planning to auction the digital dividend spectrum to the highest bidder!  There is no clear message that the more bits you carry the greater your reward.  A so called Digital economy needs such a focus.  Cost recovery based on keeping legacy voice services in place must be the wrong message.

We do need something to further change the landscape.  It is apparent that we have too many networks of limited dimensions - engineered scarcity.  If fiber is being pushed further out,  then it seems ludicrous not to make full use of it. It would seem sensible to plan and construct a fixed and mobile data transport layer across the UK.  Mobile companies are already sharing facilities, the bigger the volume the more efficient the data transport.  If we are serious about Universal Broadband access to support key services,  then most of the same service needs to be accessible whether at home or on the move.  Connectivity is not two markets, it is just one. 

To achieve what I am suggesting may require a clear split between those deciding to become access and bit transport carriers and those choosing to run services over those transport facilities.  It may require parts of BT and C&W and a Mobile network operator who likes' building networks,  to be entrusted with the spectrum from the Digital Dividend, and get on and build the UK Data transport fabric. Rather than extending spectrum holdings indefinitely it would be better to agree a guaranteed future price for bits carried and lose the liability of maintaining duplicate masts.  Bit transporters  get awarded for one measure only,  bits carried.  The service provider and retail arms of operators trade on an equivalent basis with the bit transport carriers, on an open and transparent basis.  It would lead to some M&A chaos,  but that looks to be needed anyway.

We should at least discuss this before the Government/Ofcom organises another spectrum heist.

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