Bundle Bungle

Random Bundle

OFCOM recently announced a fast-track consultation as regards K-C, the incumbent telecoms operator in Hull and parts of East Yorkshire, being able to bundle together lines, call and fixed access broadband.

If other interested parties wish to make their views know, please be aware the consultation closes this Sunday 5th September 2010.

There follows the NextGenUs response.

“NextGenUs UK CIC would genuinely welcome the introduction of bunding of retail telecommunications services in the Hull SMP area as soon as there is equivalence of wholesale access and pricing as available from BT Openreach in the rest of the UK.

If K-C wishes to offer better value to its customer immediately then it is entirely at liberty to reduce the costs of the individual calls, lines and fixed broadband components, without seeking to limit competition by tieing customers into long term bundled contracts.

NextGenUs would like to engage in a dialogue with the appropriate staff at OFCOM to expand upon this initial objection to the proposed Retail bundling in Hull and this online submission is put forward in a briefing format in view of the very limited time available until the consultation closes on September 5th.

OFCOM have recently relaxed the reigns on BT Retail in the rest of the UK in permitting BT to offer more aggressively priced service through bundling lines, calls and broadband services to residential customers. The customer has the freedom to select a bundled option (the more you buy the less you pay) and is not “forced bundling” (tying) that forces KC customers to pay for local calls from KC at an additional £3.50 per line per month whether they make a call or not and removing all competition in market for local calls.

If OFCOM were to allow KC to offer similar “bundled” packages, whilst initially being good for the consumer, would have a considerable long term negative effect on consumer choice since by reducing charges without the presence of any existing competition in an existing Monopoly where Significant Market Power (SMP) already exists would further minimise any possibility of any other Commuications Provider seeking to enter the Hull market in direct competition to KC and harm whatever limited competition already exists.

If OFCOM are considering permitting KC to bundle services,Ofcom MUST conduct a new investigation into the individual markets for telephone calls, lines and broadband markets in the Hull area. If KC still are still considered to have SMP (Significant Market Power) in any of these markets bundling cannot be permitted.

NextGenUs wishes to make its position abundantly clear that the removal on the existing conditions on KC will be fully objected to and vehemently opposed on the grounds that KC continue to possess SMP in all 3 markets and Communication Providers (CP’s) do not have access to the KC telephone line at the wholesale level.

NextGenUs would only ever agree to the removal of the existing conditions placed on KC unless the equivalent of Openreach’s WLR3 services were made available from KC in the Hull area whereby CP’s were able to compete directly with KC for the provision of fixed telephony service having obtained “Equivalence” with all providers that wish to compete in the Hull market.

If OFCOM were to orchestrate this would fully benefit consumers in terms of not just providing consumers with competitively priced services but would also provide consumers with a number of alternative choice’s with a selection of providers whereby endusers can choose their supplier based on price and service.

OFCOM should write to all CP’s to solicit their views about the Hull Market.”

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Question 1: Do you agree that is it appropriate to make an exception with respect to our interpretation of the no undue discrimination remedy in these circumstances in order to further the interests of consumers in Hull? If not please give your reasons.?

“Disagree.

K-C the incumbent operator has a de-facto monopoly on lines calls and broadband services and the action by OFCOM to allow bundling of services would clearly have the effect of preventing effective competition emerging in the Hull SMP area.

NextGenUs is putting forward a formal and reasonable request to K-C to provide full automated equivalence to the BT Openreach WLR3 product set and also SMPF/MPF wholesale access to allow the full range of CPs in the UK to be able to offer competitive retail services based on a credible wholesale offering.

Once that process is completed satisfactorily then NextGenUs would naturally be supportive of the same range of bundled retail services”

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Question 2: Do you agree that the proposed approach to the setting of the retail prices for bundles including SMP and non-SMP products offers sufficient safeguards to prevent foreclosure of future competition in Hull? If not please give your reasons.?

“No there are insufficient (if any?) safeguards as once K-C are able to offer enticing bundles to customers in the Hull SMP area in exchange for long term contractual lock-in then that will prevent the emergence of effective wholesale competition which in turn will be a poor regulatory outcome for the consumer.”

Lobby Bobbins

Taken from Wikipedia:

The term “bobbins” appears in northern English slang, meaning “rubbish”, i.e. something worthless or incorrect. Taken from the cockney “bobbins of cotton”, meaning “rotten”. This may be related to the contemporary British slang usage, where “bobbins” can be used to denote something negative, particularly in theatrical circles.

Not so long ago, I was having a Chatham House chat with a certain Political Advisor when the subject of Final Third Lobbying came up.

The point was made that “if you spent as much time at Portcullis House as XYZ, then you would understand why XYZ gets such a hearing”.

Now, many and varied interest groups naturally seek to get their messages across to Government and, in that context, Lobbying is a useful part of the Political Discourse in Westminster.

Where Lobby becomes Bobbins however is in situations where folks who don’t actually have a legitimate voice to speak on behalf of particular interest groups, nonetheless claim to so do.

So long as Government recognises the above and therefore treats such Lobby Bobbins speak as anyone would the sound of empty barrels then no harm is done and that realisation seems to be emerging where Final Third NGA is concerned, which is a Good Thing.

The real action and delivery in the Final Third comes from those who get on with the job, particularly at a local level, community by community, Building the Big Society.

Least Cost per Exabyte = FttH

There are many proposed definitions of NGA, Next Generation Access:

Ranging from an uninspiring 5Mbps asymmetric through 20Mbps to 100Mbps symmetric and beyond (the latter being the NextGenUs NGA 2010 benchmark, i.e. real-time world-class, itself increasing to 1000Mbps symmetric in 2012 inline with the current world leaders, our cousins in Japan and South Korea).

In order to deliver the 4th Utility the UK needs, we must look beyond the pseudo-equality of so-called technology-neutrality and recognise that the only infrastructure capable of upscaling to meet any bandwidth demand scenario that local communities can call for, is Fibre to the Home.

Just as services such as social networking, and real-time streaming were unimaginable 10 years ago, the innovative applications that super-fast broadband could support are only to be guessed at.

What we can say categorically is that no NGA infrastructure other than FttH can guarantee to deliver at a reasonable on-going cost (and therefore as a non-discriminatory service of General Public Good) a 4th Utility service that is genuinely future-proof regardless of what we, the customer, may choose to demand it supports.

As bandwidth demand goes up, only FttH can keep up, at least cost per exabyte exchanged.

Anything less from NGA and the UK is being short-changed – something that can ill be afforded in a global economy where telecommunications is already demonstrating its astonishing transformatory capability to transfer work and wealth-creation at the speed of light.

FttH is not a luxury, it is an imminent National necessity.

The Danger of Fluffy Definitions

Fluffy Definitions

Disturbing reading re Broadband Britain, definitions of NGA and concerns over the use of Taxpayers Money to undermine the Open Market are emerging from the South West:

NGA – Next Generation Access – all very fluffy and singularly lacking in any quantitative or qualitative definitions of service delivery on offer.

Now, VOA amongst others have clearly defined NGA as being a service that exceeds 20Mbps.

To quote from the above blog post:

The bid was about delivering a number of NGA pilots – which simply put, means you have to deliver broadband speeds of 20 Mbps into a number of areas. The Council officers explained, their NGA pilots would be to supply an NGA compliant 5 Mbps. Again the County bid has failed to meet the requirements of the bid, but this time they had changed the requirements to map onto – what appears to be a specific vendors solution. The only vendor we are aware of, that fits this, is BT.

If NGA Compliant = 5Mbps then who exactly made this determination and on what authority?

The residents and businesses of Devon and Somerset are at very real risk of being short-changed for NGA – the simple reality is that each community will have one bite at the cherry for any Public Funding Assistance in the current economic climate.

It is hard to find fault with SWI’s analysis of the situation and it is imperative that there is an urgent review of deliverables against best value for Taxpayers Money before there can be any thought of the project proceeding in its present form if at all.

Where is the Incentive?

Another insightful post over at 5ttH and followed up here

What is perfectly clear from the waste described in the above blog post is that not a penny of public subsidy must be allowed to go to BT unless and until there is transparency that best value for Taxpayers Money is being achieved.

No more repetitions of Iwade in other words!

Source - NewsArse.com : Nation overwhelmingly votes for tragic fireball end for BT ad couple thumbnail

The UK’s copper wire network grew in what is euphemistically referred to as an “organic” fashion without sufficient attention paid to least cost operations/maintenance.

This was largely a legacy of the Nationalised GPO years and seems to have persisted since Privatisation some quarter a century ago.

The fundamental problem with either state-monopoly or commercial monopoly is the same.

It is a problem of lack of incentive.

In other words, why care about constant gradual improvement in productivity when the costs of inefficiency can be passed onto the customer?

There is a better way to be found and that is the Community Interest monopoly.

Customer Service

Both the market-testing FttH networks in the audio segment below involve not a penny of Taxpayers Money and started out with a round table discussion, just as the recent gathering below in Cumbria, where NextGenUs, AFL Telecoms and CLEO Instigator Barry Forde (pictured left) collaborate with local community representatives to find better ways of delivering Community Interest future-proof FttH across the Eden District of Cumbria and beyond:

NextGenUs Final Third First Approach to the 4th Utility

NextGenUs Final Third First Approach to the 4th Utility - Together We Are The Network

For all the talk about broadband, shiny superfast NGA or otherwise, what matters most is to remember the old maxim:

The customer comes first.


That’s why the 4th Utility, FttH, Fibre to the Home, is called the First Mile in contrast with the outdated copper wire telephone system with its last mile mentality, spruced up with FttC, Fibre to the Copper or otherwise.

Here is a 5 minute interview from BBC Radio Lincs on 16 August 2010 that says more about why the 4th Utility is worth having than any powerpoint presentation or keynote speech ever could.

Starring William Wright, Val C Smith and Dave “Spanish” Steenvoorden

Digging Lincs

Final Third First underway

Helping the High Hanging Fruit

Inspired by 5ttH and Lord Kelvin’s maxim (supposedly:

Can ye make a model of it?

If ye can, ye understands it,

and if ye canna, ye dinna!

Once the Low Hanging Fruit are proverbially picked, what then of the remainder?

The High Hanging Fruit?

A statistically significant sample of the Final Third (quarter, fifth, tenth?) would be good…

The three Theoretical Exercises currently being open source supplied by some of the Industry Day attendees to BDUK and in between each other cover areas that are each and all challenging – high hanging fruit

Consider this:

1000 logging routers to capture SamKnows info across each of the 3 localities – do this for a month, for 90 days and onwards.

Result:

Instead of theoretical mapping exercises, invest in actual rural customer broadband performance data by lending out 1000ish logging routers to capture standardised SamKnows datasets across each of the 3 localities

- do this for a month, for 90 days and onwards…

Then use that growing body real-world evidence to inform future practical improvements to broadband service delivery.

Our friends at DABS will do 1000 of WRT54GL routers for
Delivery (764.000kg) £273.54
Total (inc VAT) £45,945.79

Exceptional value for Taxpayers Money – For, say,  for an outlay of less than £50k the result is a detailed and valid analysis of the high hanging fruit,

In the very garden of Eden even… ?

Now that would be a huge value add for Rory Stewart’s Rural Broadband Conference – 10 routers per Parish perhaps?

Tasty Spam

The most useful unsolicited email received in a long while.

Captures in a simple highly visual form the key facts about present day broadband in the UK.

Well done Mobilebroadband.net and thanks for the tasty spam Claire!

Broadband Internet In The UK

Infographic by MobileBroadband.net

Big Society – the North Folk View

Excellent blog post from Rick Waghorn in Nor(th)Folk and interesting how folks the length and breadth of the land are awakening to the increasing importance of connectivity to enrich people lives by its availability – and likewise the impoverishment that comes with lack of broadband – the dreaded NotSpot situation.

As Cyberdoyle noted in the blog comments, the initiative being championed by Rory Stewart in Cumbria is both welcome locally and promising nationally.

What is worth considering is what happens after the building is over, how is this new 4th Utility to be operated, in whose interests and for whose benefit?

Telecommunications decisions that we make over the course of the next 1-2 years will set the terms of trade for the next century ahead.

Big Society, if it is allowed to deliver, offers a golden opportunity for local communities to make informed choices for themselves.