Ewhurst Broadbanders

contribution to the Business and Enterprise Committee for their Broadband Speed Enquiry Reference becpn47 0809

Synopsis

This paper offers the practical experiences of a Surrey village of 1000 properties in attempting to improve broadband performance where the present telephone exchange is too far away at over 3 km. It provides comments on the B & E C questions and additional information including an outline National remedy. It appears that a nation-wide communications “rail crash” is upon us which requires similar remedies and which will not be rectified by commercially competing interests nor miniscule phone line taxes.

Ewhurst Broadbanders re becpn 47 0809 Iss. 1.9 8th June 2010 - Page 1 of 17 pages Contents

Responses to the five questions the B & E Committee asked Page 3 Other views Page 4-5 Appendix A - Slovakia Fibre To The Home announcement Page 6 Appendix B - Broadband speed statements Page 7 Appendix C - U K Internet capacity Page 8 Appendix D - AAISP comments Page 9 Appendix E - ’s capacity load example Page 10 Appendix F - BT ’s Limited Maintenance Pages 11-12 Appendix G - A Milton MP & Ewhurst / meeting Page 13-14 Appendix H - BT Attitude Page 15-16 Appendix I - Conceptual Re-organisation Page 17

Revision history 1.7 Initial issue 1.8 copyright data added & typing corrections

Preface

This paper has been produced by Ewhurst Broadbanders, a group dedicated to the improvement of Telecommunications and Internet services in the area. The information provided are the observations from end-users’ viewpoints - i.e. external to any Internet Service Provider’s (ISP) organisation using information in the public domain. Photographs illustrate the plant condition mainly over the Summer of 2009 so the current plant could differ as BT continue to change their infrastructure.

Please note:-

As we are mainly end users relying on (Un-moderated) internet research and observing the difficulties of our Internet Service Providers (ISPs), it is possible that some of our topics are incomplete; it is also probable that there are omissions. However there can be little doubt that the subject matters raised are a significant cause for concern for both telephone and broadband.

Copyright:-

Some of the data included contain copyright material as well as the intellectual property of others. In these circumstances we must retain their rights so the document as a whole cannot become copyright of Parliament or any Government Agency. Permission has been granted for the use of the copyright material in this document. Furthermore the topics have been widely discussed with interested parties via the internet and thus should not be considered confidential.

Ewhurst Broadbanders re becpn 47 0809 Iss. 1.9 8th June 2010 - Page 2 of 17 pages 1.0 Whether the target for universal access to use the term unlimited (when there are many traffic broadband at a speed of 2Mb/s by 2012 is ambitious contention points) and up to (when line distance enough? calculations can provide reasonable speed estimates, particularly when it is probable that longer‑line users 1.1 No it certainly isn’t; it’s well below the speeds {including most of Ewhurst} will achieve virtually many internet users already have and which is being nothing from NGA and similar technologies). These increased substantially for them in the short term. practices are continuing with BT offering speeds In order to ensure a reasonable minimum speed at of up to 20 mbps for their NGA product and Zen the extremities it is important to specify much faster Internet stating the same but also stating “average speeds closer in if Next Generation Access (NGA) download speeds will be between 9 mbps and 13 facilities are to be of any use. Were fibre being mbps”.) See Appendix‑B. The speeds obtained will deployed there would be no need to consider speed in also be seriously affected by poor cabling including as much detail as it is so much faster and importantly aluminium cables. provides similar upload and download speeds that Asymmetric technology doesn’t. 5.0 The extent to which current regulation strikes the right balance between ensuring fair competition 2.0 Is the Government right to propose a levy on and encouraging investment in next generation copper lines to fund next generation access? networks?

2.1 No, it is wasteful of resources and would 5.1 We are living with the lamentable decision, require yet another Government administrative probably made by Ofcom, to prohibit BT originally body to collect the tax and then to oversee the from installing Fibre but then allowing others to do procurements which all too often seem to fail. so only in profitable areas. Current legislation has The Telcos would also have to set up otherwise therefore allowed Virgin Media (via CableTel, NTL useless administrative systems. The proposed levy and Telewest etc.) to provide increasingly faster isn’t nearly big enough to have a major impact. It Fibre‑To‑The‑Cabinet (FTTC) solutions with new also seems unfair that the poorest people would be higher‑performance co‑axial cables to each property. penalised when it’s most unlikely they would ever The legislation has also provided a platform to use broadband. Furthermore the fibre property tax allow many ISPs to provide ADSL broadband over illustrates disjointed planning particularly where the inferior and degrading BT twisted pair copper there is a strong case for encouraging Fibre. and aluminium network. However the whole BT Wholesale arrangement is flawed as there is no 3.0 Will the Government’s plans for next obligation (No USO) for BT Openreach to maintain generation access work? the local loops in an adequate condition for optimum broadband performance, nor even to provide a 3.1 No, this type of intervention will seriously broadband speed line. They only have to provide distort broadband and telephone design and a 3 kHz audio capability and this can be satisfied implementation plans. All of the stop-gap designs with DACS line‑sharing units or even with crossed to meet this very low standard have limited or non- pairs of wires (which are disastrous for ADSL existent upgrade paths to reasonable speeds; the entire which relies on balanced twisted pairs). Furthermore operationmust then be repeated probably before 2012. business pressures are forcing BT, who are at a The UK must catch up with developing countries serious technical disadvantage, to concentrate on the such as Slovakia who have already implemented more economically attractive areas of the country phase one of a national Fibre‑To‑The‑Home (FTTH) that already have mainly Virgin Media services, scheme. See Appendix A. at the expense of ignoring sparser and aluminium equipped areas completely. Likewise Virgin are also 4.0 If companies are providing the speed of not interested in the sparser areas. There is a strong access which they promise to consumers? case that sparser areas are much more in need of fast broadband in order to compete with better urban 4.1 Yes in most cases they are, as they have to facilities enjoyed by some, but certainly not all, those include caveats to cover the actual line distance and BT Openreach users. quality limitations as well as their capacity costs. However it is highly misleading for all suppliers to Ewhurst Broadbanders re becpn 47 0809 Iss. 1.9 8th June 2010 - Page 3 of 17 pages 6.0 Any other views stakeholders think the and reliability viewpoints, is a vital national asset Committee should be aware of. and must be maintained so must be included in a Governement funded National Fibre network. 6.1 There are (at least) five additional major ** It seems important that the aluminium cable topics which the Committee could consider, viz. inventory is researched to establish the magnitude of A) The capacity of the national networks. the problem. B) The replacement of the aluminium and copper network with fibre. 6.2.3 Network resilience also requires ongoing C) The resilience of all networks to accidental review. The Internet could be disrupted by activating or deliberate damage. Denial-Of-Service attacks or possibly an overload D) The current commercial and technical condition as in Appendix E. Recently a problem conditions. was caused in an exchange when equipment was E) A realistic approach to communications stolen. Essex also had difficulties when a fibre cable systems development. under the Thames was damaged whilst new cabling 6.2.1 The capacity of the National Broadband operations were underway. In current conditions Network is a complex subject; it is provided by BT major incidents such as fires and hostile acts should and Virgin Media together with other “backbone” also be considered together with contingency suppliers; all have a number of limiting capacities. plans for replacement equipment and duplicated The example at Appendix C provides outline details locations. Appendix D contains some very worrying of the current (20CenturyNetwork) BT arrangements comments upon a single point of failure. It seems that of their Remote Access Servers in 12 locations dual‑redundant designs for all critical components across the UK. Appendix E describes a worrying must be a mandatory requirement. It is suggested recent incident where very significant loading was that GCHQ and / or the military are tasked with a caused by the population using BBC iPlayer to watch confidential failure-mode investigation of the entire Wimbledon. UK communications networks to cover technical and associated commercial limitations. 6.2.2 Whilst broadband speeds are a major item of debate, the copper and aluminium telephone 6.2.4 In the current financial conditions the BT network is still a vital National Asset and must Group cannot be expected to fund BT Openreach not be overlooked. The photographs illustate sufficiently to maintain the whole “middle and last there are insufficient telephone lines and some mile” network adequately or to improve it. Pictures components are definitely in need of replacement are provided at Appendix F include fault tags at a much faster rate than BT Openreach is allowed dating back at least to 2003. Some plant still has to achieve. In addition there is a significant quantity GPO markings and dates from 1945. In Ewhurst for of aluminium cable,** often not in ducts. It is instance, there is a significant shortage of copper pairs notoriously unreliable and, at a higher resistance, as evidenced by the number of Digital Access Carrier degrades broadband performance. Again, as there System (DACS) line-sharing units deployed. DACS is no Universal Service Obligation for Broadband, circuits are totally incompatible with DSL broadband BT typically refuse to replace the aluminium cable signals. if it does not cause service interruptions. E.g. http:// winterbournestoke-thedigitaldivide.blogspot.com/ 6.2.5 Furthermore BT have been evasive and “We have not yet been able to find the cause of deliberately obstructive - see Appendix H. There the REIN, {i.e. interference} but it is worsened by is no standard mechanism to allow local groups to having a ‘middle-mile’ {not in ducts} underground contribute financially to improve the BT copper cable made of aluminium - notorious for this type of networks and currently BT have refused such problem and the responsibility of BT Openreach. The contributions! For this third attempt we have had solution would be to replace this old and decaying unproductive conversations from mid July to infrastructure with copper, or more logically fibre, to September 2009 on one Ewhurst problem area. future proof the connection. Openreach won’t pay for this, as they say the cost (£180,000) is too high for 6.3 It is clear that the BT Group, who have them to recoup from a small customer base, so we are announced some financial difficulties in their oversea stuck.” operations are attempting to invest in areas they An adequate telephone network, from both capacity hope will be more profitable. This produces two Ewhurst Broadbanders re becpn 47 0809 Iss. 1.9 8th June 2010 - Page 4 of 17 pages undesirable consequences, viz. solution which would out-perform Virgin’s FTTC A) Maintenance is often kept at minimum levels offerings. to support their obligation to provide voice-only services. 6.6 Anne Milton MP asked a Parliamentary Question B) BT are investing heavily in Next Generation re Broadband Availability which received the Access exchange equipment and FTTC trials mainly expected response from the then BERR - see 6.7 for the most profitable areas only, often in direct below. It did produce a meeting with Ofcom which competition with Virgin Media’s superior technology. we attended at Portcullis House on 9 June 2009 where Furthermore all non-cable ISPs rely on BT Wholesale questions were raised and the map of the Peaslake offerings and are thus excluded for Virgin’s superior Road problem was also tabled. Sadly the meeting networks. It seems a national unified FTTH solution produced little result. See Appendix G. is urgently required to restore this imbalance. 6.7 Anne Milton: To ask the Minister of State, 6.4 Unless BT is to be re-nationalised they cannot Department for Business, Enterprise and Regulatory be expected to deploy their Fibre capital investment Reform what plans he has to improve the in areas of poorer return which is generally where the telecommunications infrastructure in rural areas worst broadband areas are. Nor can they be expected to extend the provision of high speed broadband. to invest in aluminium replacement and upgrading the [270209] copper network in bad areas. It follows that one of the Mr. McFadden: The Budget confirmed the few ways of resolving these fundamental difficulties Government’s plans to deliver a Universal Service is to segregate BT Openreach completely from for broadband up to 2 Mbps by 2012. This will allow its parent. Significant Government funding seems virtually everyone to benefit from broadband services. necessary to refurbish the copper / aluminium network The Budget also underlines the Government’s and install new FTTC cabinets in sparsely populated commitment to helping business take full advantage areas. However the true costs of refurbishment and of the opportunities offered in this area by announcing maintenance should be carefully compared with the a review of Ofcom’s powers and duties to ensure cost of installing and maintaining Fibre To The Home; it can strike the right balance between supporting if they are similar FTTH is to be strongly favoured. competition and encouraging investment. As you Were fibre deployed it would overcome the serious are aware, Universal Service and Next Generation shortage of phone lines probably at far less cost than Access are also key aspects of the Digital Britain installng new copper cables from the exchanges. report, which will be published shortly. Fibre links also avoid Radio Frequency Interference The Government will also be carrying out research on problems that plague parts of the existing networks. broadband ‘Not spots’ under the cross-Government See Appendix I for a conceptual reorganisation of the paper “Delivering Digital Inclusion—An Action UK Communications industry. Plan for Consultation” with the objective of putting information into the hands of local communities 6.5 BT are trialling a FTTC solution and Rutland to enable them to manage the risks, and realise the Telecom are commissioning their production cabinet opportunities of Next Generation Access locally and in Lyddington - See http://www.rutlandtelecom. regionally, where they identify a need and want to co.uk/lyddington/. FTTC replacess the exchange activate their own solutions. This will also cover equipment locally thus reducing line lengths the devolved Administrations of Scotland, Northern substantially, but requires BT Openreach to accept the Ireland and Wales. Universal Service Obligation for Distribution‑side lines. It is very unfortunaste that BT chose to 6.8 It seems a rather reckless approach to expect all install their Muswell Hill FTTC cabinets without Local Communities to obtain and manage their own planning permission in a conservation area. There broadband facilities securely and in conjunction with, is real concern over un‑necessary street furniture or even competing with, the existing Communications so production cabinets should replace existing PCP Providers. Green Cabinets. It appears that there is no financial or practical possibilityfor more than one FTTC solution at any one PCP so the construction and regulation implications of this situation should be addressed. Again a complete FTTH solution is a better technical Ewhurst Broadbanders re becpn 47 0809 Iss. 1.9 8th June 2010 - Page 5 of 17 pages Appendix A - Slovakia Fibre deployment (© Technologies Co. Ltd.)

Huawei - Print http://www.huawei.com/news/view.do?id=10781&cid=42&print=true

Huawei deploys GPON FTTH network for T-COM

[3 March 2009, Shenzhen, China] Huawei Technologies Co Ltd. ("Huawei"), a leading provider of next generation telecommunication solutions for operators around the world, has announced it has successfully completed the first phase of its Fiber to the Home (FTTH) network deployment project for Slovak Telekom and its business brand T-COM , a subsidiary of Deutsche Telekom.

Comprising 34 sites and 90,000 FTTH subscriber lines, the first phase of the nationwide commercial project was completed in just 5 months and represented one of the largest Gigabit-capable (GPON) deployments across Eastern Europe. This new FTTH network enables T-COM to deliver a broader range of high-quality ultra broadband services to Slovakian subscribers.

Slovak Telekom' s Senior Director for Prod.&Services Mr. Bogdain said: "The construction of a nationwide FTTH network forms an important part of T-COM' s broadband strategy. The deployment enables us to reduce network costs and simplify network structure, greatly enhancing the subscriber experience. Huawei' s leading solution and rich experience in FTTH commercialisation has helped us deploy the network and deliver FTTH services swiftly, assisting T-COM to realise its strategic objectives."

"We are delighted to cooperate with Slovak Telekom in its GPON FTTH project. The rapid deployment could not have been achieved without our good cooperation. Huawei is committed to leveraging its proven optical access expertise and extensive global application experiences to provide tailored services to operators worldwide." said Yang Zhirong, President of Huawei Product Line.

Based on a terabit access platform, Huawei' s innovative FTTH solution provides unified access to data, voice, and video services. Underpinned by the large-capacity platform with an ultrahigh optical branching ratio, it provides robust broadband capabilities, flattens the network structure, reduces individual subscriber fees and protects investment by supporting smooth evolution to 10Gbit/s PON.

As an IP and optical access leader, Huawei has already engaged in more than 100 FTTx projects worldwide for almost 50 telecommunications operators.

About Slovak Telekom / T-Com

Slovak Telekom, a. s., is a multimedia operator belonging to the international group of Deutsche Telekom AG. The Company owns and operates a telecommunications network which covers the entire territory of the Slovak Republic, providing national and international voice services and a wide portfolio of modern data services under T-Com brand. It is also the largest provider of high speed broadband internet and offers the triple play service called Magio, combining digital television, internet and telephony. In order to be able to provide Slovakia' s citizens with new and more convenient services, the Company has made huge investments in extension of its optical infrastructure. TRI*M index score of Slovak Telekom, a.s. positions the Company among the top of European operators. Slovak Telekom, a.s. holds the certificate of quality management system as per EN ISO 9001:2000 and the certificate of environmental management system as per EN ISO 14001:2004. For more information, please visit http://www.t-com.sk/

Copyright © Huawei Technologies Co., Ltd. 1998-2009. All rights reserved.

The above data can be viewed directly from Huawei’s web site at:- http://www.huawei.com/news/view.do?id=10781&cid=42

(This web link is included to conform to Huawei’s use of their copyright material regulations.)

1 of 1 3/4/09 07:06 Ewhurst Broadbanders re becpn 47 0809 Iss. 1.9 8th June 2010 - Page 6 of 17 pages Appendix B - Zen’s statements re their NGA offering using BT’s 21CN service

The following text is quoted in full from Zen’s web link - the bold itallic colour is our change:- http://www.zen.co.uk/about/zen-introduce-new-20mbps-broadband-services.aspx

Zen Internet introduces new “up to 20Mbps” broadband services 08 June 2009: Zen Internet, one of the UK’s leading Internet Service Providers (ISP), announced today that it is introducing faster broadband services with download speeds of up to 20Mbps and upload speeds of up to 1Mbps at no extra cost for customers this summer.

Zen will start moving existing residential and business customers over to the new services later this summer, as long as they are available in their area. The new services, which will be on a “like for like” basis with current products, will not change in price but customers can, in most cases, expect to receive a higher speed. Zen has already started communicating the planned move to its customers.

“We have been working on this upgrade since late 2008. The final phase of tests and trials for these new faster services is due for completion this summer. We therefore fully expect to start moving existing customers over from late summer onwards and this will be done at no extra cost”, said Andrew Saunders, Head of Product Management and Marketing, Zen Internet.

New customers will also be provided with the faster services from late summer onwards, as long as they are available in their area. Any new customers joining Zen where the faster services are not yet available will be moved across as and when they are introduced. The faster services will be provided at the same price as Zen’s current services. Even though Zen will be providing these new faster services it will not be introducing a traffic shaping policy.

“Zen has always had a very clear proposition around our services. We are retaining our current monthly contracts and just want customers to enjoy the benefits of our new faster services at any time of the day, with no gimmicks or restrictions hidden in a fair use policy.” added Saunders.

The speed customers can expect to receive will depend on how far they are from their local BT exchange. Based on the results of Zen’s current trials, it is estimated that the average download speeds will be between 9Mbps and 13Mbps, but some trial users are already achieving over 20Mbps.

Zen has upgraded its own network and is using elements of BT’s new 21st Century Network (21CN) project to bring customers these faster broadband services. 21CN is a UK wide communication network upgrade project currently being rolled out by BT. This will involve enabling all BT exchanges for 21CN including the faster ADSL2+ broadband technology. BT plan to cover 55% of homes and businesses by March 2010, depending on demand. Investments in Zen’s network include upgrades of the connections from its network to the BT local exchanges, the significant increase in the capacity of its core network and the interconnections from Zen’s network into the rest of the Internet which have been expanded and optimised for resiliency.

“Zen Internet was one of the first ISPs to embrace broadband technology in the UK and connected some of the earliest broadband circuits back in the summer of 2000. We have a mission to provide the best ISP service in the UK and so, over this summer, we are completing a major technology upgrade to our broadband services that will enable the introduction of faster 20Mbps services and bring the most significant changes for our customers since those pioneering days of 2000” said Saunders.

Ewhurst Broadbanders re becpn 47 0809 Iss. 1.9 8th June 2010 - Page 7 of 17 pages Appendix C - UK Internet capacity limits Data here reproduced by kind permission of http://www.kitz.co.uk.

The following block diagram provides an outline of a typical part of the 20CN network starting on the left with the customers equipment and progressing through both BT’s and the Internet Service Providers equipment. Note that the 21CN is different and will probably have different limitations. For a fuller explanation please visit:- http://www.kitz.co.uk/adsl/equip2.htm

The backhaul link from the exchange to the Remote Access Servers (RAS) has a maximum capacity of 155Mbps. It doesn’t take too many people using their connection to the full before speeds will start to drop. Unfortunately adsl and the Asynchronous Transfer Mode (ATM) network wasn’t really designed to cope with todays demands for bandwidth. Although higher speeds appear to offer the user significant advantages, the benefits will be limited if the ATM back-link can’t cope then everything will slow down.

Ewhurst Broadbanders re becpn 47 0809 Iss. 1.9 8th June 2010 - Page 8 of 17 pages Appendix D -AAISP re BT Single box design

The following data was extracted from AAISP’s fault status reporting site. http://aaisp.blogspot.com/

There are sometimes rather blunt comments on the site, but this particular one could illustrate that insufficient thought over dual-redundant systems etc. has been considered currently for BT’s Wholesale Broadband Managed Connect services. It appears that there are both technical design and commercial issues to resolve. If this design concept is replicated elsewhere within BT, then system resiliency is probably compromised. It might also be prudent to ask similar questions of Virgin Media. http://aaisp.blogspot.com/2009/09/info-bt-single-box-design-still.html

Tuesday, September 08, 2009 [info] BT single box design, still

We were shocked to learn that BT had a “single box design” for WMBC links to us, whereby they have, in each metro node, only one (albeit very large) router. The consequence is that planned maintenance causes 3 to 4 hour outages for customers even if they have multiple (BT) lines. It also makes them vulnerable to vendor specific bugs and issues.

We have been pursuing this with BT for some time. It is unbelievable that anyone running an IP network would not use dual routers and router redundancy.

We were, today, shocked to hear that senior people within BT did not appear to actually understand the issue. Questions raised at the BT ISP forum at BT tower today show that they actually thought that there was a way we could connect on WBMC that would avoid these outages.

The whole point of WBMC is that it replaces BT Central links (where BT come to us) but even with multiple connection points it would not avoid this serious issue. BT still do not have a commercial model for us to connect to two nodes even. We do have dual fibres and routers our end, obviously. We now have dual providers because of this and hope to launch our BE products properly next month.

To be fair, the technical people we deal with in BT fully understand the issues, especially as they have to maintain the network and address the consequences of this design.

We hope BT can come back with a response on this and a clear indication when they will be providing a network that is (in our opinion) fit for purpose. We are happy to post BT’s response, and if we are in any way wrong, an apology - this is not a BT hate site after all.

Ewhurst Broadbanders re becpn 47 0809 Iss. 1.9 8th June 2010 - Page 9 of 17 pages Appendix E - PlusNet’s increasing capacity load

Data here reproduced from an article on the BT subsidiary Plusnet’s forum illustrating a major system-wide degredation of the whole UK Internet caused by BBC iPlayer activity during Wimbledon. Such events will increasingly affect the Internet’s throughput indicating that this matter is becoming urgent.

Murray Mania Marches On! | Community Site News http://community.plus.net/blog/2009/07/01/murray- mania-marches-on/

Andy Murray today beat Juan Carlos Ferrero in straight sets to reach the Wimbledon semi-finals. And in what is now becoming the norm the British public went straight to the Internet to watch the live coverage. At the peak we saw 1.81Gbps (making up over 25% of our network capacity) of iPlayer traffic this afternoon beating the previous high set on Monday for Andy’s fourth round game of 1.66Gbps (which we also assume will include quite a few people catching up on Top Gear and Glastonbury). Only just over 2 weeks ago our previous high was 953Mbps which was set back during the Olympics but we’ve seen that figure beaten by Top Gear, the breaking of the Michael Jackson news and several times now by the tennis.

The data below is from Plusnet’s site but many Internet Service Providers reported traffic difficulties.

Ewhurst Broadbanders re becpn 47 0809 Iss. 1.9 8th June 2010 - Page 10 of 17 pages Appendix F - BT Openreach’s limited maintenance These pictures are of DP1097 in Somersbury Lane, Ewhurst in July 2009. A subscriber beyond this pole had a broadband service which was lost for 5 weeks and eventually restored at minimum speed. The pole has 414 / 230 Volt power lines at the top. It also has at least 3 DACS line splitting units making 6 lines useless for broadband. Fault tags recorded in 2004, 2003 and possibly earlier are still outstanding and the BT 66 junction box at the bottom has been left open. Proud guardians - No comment!

Ewhurst Broadbanders re becpn 47 0809 Iss. 1.9 8th June 2010 - Page 11 of 17 pages Fault tags dated in 2003 and 2004 on DP 1097 in Sommersbury Road Ewhurst July 2009

Ewhurst Broadbanders re becpn 47 0809 Iss. 1.9 8th June 2010 - Page 12 of 17 pages Appendix G - Extracts from Ewhurst / OFCOM meeting at Portcullis House

1.0 Addendum for Ofcom nationally

This note comments more generally on aspects applicable to many locations suffering with inadequate speeds and those without any service.

1.1 Ewhurst is just one example of a predominantly English national problem (as Scotland, Wales and Northern Ireland appear to have some schemes underway).

1.2 No mechanism exists to enable locally generated funding to be utilised by BT Openreach.

1.3 If a mechanism for 1.2 did exist, BT has a history of massively overpriced cost estimates so some form of independent cost assessment would be needed.

1.4 The alternative of a third party (Rutland Telecom model) undertaking the work still requires BT Openreach’s active co-operation both for access to the sub-loop copper and to some backhaul bandwidth solutions.

1.5 If FTTC over the BT network is to be sustained for many years, both BT and third party users will need at least the BT street cabinets and D side plant adequately maintained for broadband use; whereas currently with no BT USO for broadband it seems there is no contractual need for BT Openreach to maintain or improve higher frequency throughput.

1.6 We have already seen the demise of a few CPs and current circumstances might suggest others could follow. Providing alternative solutions for BT wholesale CP clients seems to have been handled efficiently with the “walled garden” approach to obtain a MAC. However there would appear to be a greater risk of significant service disruption should LLU CPs fail, especially those providing phone and broadband.

We would be grateful for replies to the following:-

1 Does Ofcom agree with points 1 to 6 above?

2 Does Ofcom consider it is within their remit to deal with these issues, or if not who should be addressing them?

3 What does Ofcom intend to do about these issues, both immediately (in regard to Ewhurst) and longer term (in regard to the wider situation).

2.0 Communications Consumer Panel Research Report of 1 June 2009

2.1 It is noted that the report covers many aspects of broadband development. However if Lord Carter recommends a 2 mbps download speed only to be implemented by 2012, additional speed demands are highly likely; it suggests a safer route would be to invest the resources in national FTTC as a minimum, if not FTTH now rather than duplicating the effort later to catch up internationally.

2.2 The report deals quite comprehensively with many aspects of broadband development for the domestic not-spot population. However a fundamental aspect, but possibly not strictly within the report’s remit, is that it fails to consider that many homes and farms etc. accommodate small businesses and these require faster services and much more upload capacity.

Ewhurst Broadbanders re becpn 47 0809 Iss. 1.9 8th June 2010 - Page 13 of 17 pages Ofcom’s reply to Ewhurst Broadbanders:-

On 14 Jul 2009, at 14:21, Richard Moore wrote:

Dear Mr Wilcox,

Sorry for the delayed response, but I wanted to wait until we had updated Ann Milton on the scope of the Digital Britain proposals on access to broadband before I replied. As you may have read in the Digital Britain report, it is estimated that there are around 2.75m households in the UK currently unable to receive broadband at 2Mbps. It is therefore important that Ofcom uses its limited resources to facilitate the increased availability of broadband throughout the UK, rather than focussing on individual cases. Consequently, I am sorry to say that I do not intend to engage with BT directly in relation to the issues in Ewhurst.

The questions you raised when we met touch on a number of policy areas, some within Ofcom’s remit and some outside. I am not able to provide answers to them at the moment, but I will ensure that the points that you have identified are passed onto the relevant policy teams in Ofcom.

Kind regards Richard Moore

______

Ewhurst broadbanders’ comments:-

From the above it seems as if Ofcom (and the Communications Consumer Panel) are accepting the Digital Britain report that a 2 mbps speed limitation is adequate when there is substantial evidence that it is not.

We have not been informed of any further actions from OFCOM’s policy teams.

Ewhurst Broadbanders re becpn 47 0809 Iss. 1.9 8th June 2010 - Page 14 of 17 pages Appendix H - BT attitude

H1 Hambleden (Near Henley-on-Thames where protracted negotiations to install a pilot FTTH scheme have achieved absolutely nothing, despite being given an enabling subsidy of over £5,000.) More information on the negotiations is probably available from South East England Development Agency.

H2 Peaslake Road Ewhurst - BT’s refusal since 2007 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, using an excuse - repeated to Lord Carter - of an Area of Outstanding Natural Beauty. This ostensibly requires very expensive underground cabling but BT already have 30 poles in the immediate area - see annotated map overleaf. In practice only 4 or 5 well hidden new poles are necessary in a road containing much utilities’ plant. Our formal complaint to Ofcom and the Ofcom discussions we had in Portcullis House, were both unsuccessful and possibly indicate collusion with BT. On the third time of asking in July 2009, BT have yet to address the matter.

Ewhurst Broadbanders re becpn 47 0809 Iss. 1.9 8th June 2010 - Page 15 of 17 pages This page contained a SCC copyright map of Ride Way, Moon Hall Road and Peaslake Road illustrating the pole positions and details, the list of addresses beyond Woolpit Farm without broadband and inset pictures of the Gas and Water installations in Peaslake Road. It has been romoved as our licence to publish the map has expired.

Ewhurst Broadbanders re becpn 47 0809 Iss. 1.9 8th June 2010 - Page 16 of 17 pages Appendix I - Conceptual re-organisation

I1 The following notes are provided as an I2.6 BT should then be expected to install FTTC outline approach to assist in solving the national systems in the next most profitable and lower-cost communications crisis we face. It is offered as a areas. simplistic solution which, if the appropriate people were persuaded to negotiate fairly, could produce a I2.7 The remaining areas with Primary Connection viable mechanism to overcome the national emergency. Points (PCPs) green street cabinets should be An alternative is to re-nationalise or otherwise merge provided with FTTC by an entirely segregated the entire communications industry. UK Openreach group with government funds. In addition “UK Openreach” must be tasked either with I2.1 Virgin media have a fully working faster refurbishment of the Distribution D side cables and FTTC solution running reasonably well and they are the elimination of all DACS units, or replacement planning network equipment upgrades and expansion of the entire network with individual fibres. This of the areas they cover. They have also obtained will require significant investment in larger local backbone internet infrastructure. However they do copper or fibre cables. Where thought economic not want to invest in areas which are unlikely to FTTH solutions should be installed instead of copper provide sufficient Return On Investment from FTTC upgrades, most especially on “D side” customer lines such as Ewhurst. of over say 2 km from the PSPs.

I2.2 BT at Hambleden have shown they are an I2.8 Only those areas with very long lines, either unreliable fibre negotiator even for a small pilot direct from rural exchanges or from very remote scheme. However they have a major investment in green cabinet Primary and Secondary Connection the backbone internet infrastructure, but which will Points should be considered for alternative limited need reinforcement in the short to medium term. (E.g. broadband solutions such as satellite or wireless in Wimbledon this year caused significant bottlenecks.) the immediate future and to be given top priority for BT have announced an outline plan for 2012 to FTTH investment. provide partial (60%) Fibre To The Cabinet and continuing over poor unshielded twisted pair copper I2.9 Any solutions proposed without a viable and possibly aluminium, often in competition with speed‑upgrade route, just to obtain the proposed Virgin Media with a superior fibre / co-axial cable phone line tax money, should be prohibited. implementation.

I2.3 The UK has a national communications investment emergency. (As a low-level example there are 3 Ewhurst services which are no longer adequate, even though they had been in the past. Currently BT Openreach are not obliged nor funded to invest the required capital to remedy the situation.)

I2.4 It follows that Virgin Media should offer a wholesale arrangement to allow others to provide high speed broadband using Virgin’s infrastructure where available.

I2.5 In exchange for wholesale access to Virgin’s network BT and others should be prohibited from installing competing but inferior network equipment in areas already covered by Virgin. BT’s resources are desparately needed elsewhere.

Ewhurst Broadbanders re becpn 47 0809 Iss. 1.9 8th June 2010 - Page 17 of 17 pages