Tag: Ofcom

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Legal ofcom Regs voip

Emergency Calls and VoIP

999

Emergency Calls and VoIP have always been a contentious issue, but the need for ever increasingly innovative and cheaper ways of communicating means the tensions are getting worse than ever.

Despite what many of you may think, Regulatory Affairs is fun. Bear with me for a second. This isn’t quite like a train spotter defending a book of carriage numbers as fun (though for them I am sure it is). Regulatory Affairs is a truly multi-disciplinary job. Each day, I have to be a little bit telecoms engineer, lawyer, accountant, economist, lobbyist, salesman, compliance officer, and more. My work this year has taken me to documents in the British Library regarding the 1984 privatisation of BT that were pertinent in a dispute being argued at Ofcom, and I am currently working and planning on charge control periods for 2016-2019 and beyond. Every day you get to be at the leading edge of technological environments, helping businesses understand the regulatory environment and coming across some wonderful problems and innovations.

That fun gets drained, though, when it comes to 999 (or 112 for our European brethren…and I think we can all safely say we know 911 is America). Lives are at stake, and it is rightly a very important topic, however much I despise having to deal with issues arising from it.

There are two pieces of history that tie on to why we have the 999 environment we have today. The first one, serious and sombre, is that the foundations of the regime today came about following the 1986 Hungerford Massacre where the local exchange couldn’t handle the volume of calls as Michael Ryan perpetrated his horrific crimes. There were only two lines into the 1986 equivalent of a call handling authority for Newbury at the time. The second is more interesting than serious, that being that the design of pay phones in 1925 was such that the dial was fixed but the number 9 and 0 could be used — the former thrice for emergency services and the latter for the operator — without having to put money in to release the dial. The urban myth is that it was chosen in the pulse dialing days because overhead wires could touch in high wind and send a 1 pulse … if done three times in a certain period would make a false call. The avoidance of this was simply a fortunate consequence of the pay phones.

More recently, in the late nineties, we have had significant improvements to location information databases, we’ve had the rise of mobile phones and the location information therein, and we’ve also had the ability to text 999 (pre registered users with special needs as I recall). In amongst all of this we have VoIP, one of the most important innovations in telephony for a generation. Today I can sit in a hotel in Brazil and make calls presenting my UK 0208 number. More importantly, I can make such calls from an app via a smartphone connected to a switch/PBX/platform in the UK that doesn’t even know I am abroad.

So what on earth happens when I dial 999?

That instance is simple; apps should probably just let the handset deal with it natively so as to pass on all the relevant information….. but what if I sign into a hosted PBX in my colleague’s home office and something goes wrong? I’ve been a good boy as a homeworker and the call handling authority would see the address of where I am most often – my own home office. Thankfully, Emergency Calls are presented to the call handler in two ways, based on a prefix the originating network places on the call — there’s one for old school legacy TDM fixed network that says “reliable address” and there’s a second one that says “unreliable address” used for roaming VoIP. Cutting a very complex story short, that triggers a different script for the operator to follow. The mobile world is somewhat different and their location information plans regarding GPS chips etc. will undoubtedly save lives. We’ve managed like this for coming up to a decade, since Ofcom made its last pronouncements on VoIP and Emergency Calls. All well and good.

The legacy broadband superimposed over narrowband copper voice world has a short shelf life now, though. Various government bodies and Ofcom are consulting and whatnot on how to deal with Emergency Calls when we can’t rely on the BT Exchange to power the line (the narrowband voice at least) should the wider electricity supply be compromised. Right now if there’s a power cut at home I will lose broadband and my phone. I can, however, go to the garage, dig out an old phone and plug it into the master socket and knock myself out. The current regulatory/government consensus is that data-only/wires-only/naked services should have at least one hour battery backup to remove this potential problem.

Wow. 1 hour.

Essentially then, in a VoIP only world (or strictly VoIP or other technology over naked DSL or somesuch), if someone wants to axe-murder me during a power cut I am in deep trouble if nPower cannot get their ducks back in a row within 59 minutes and 59 seconds.

According to Ofcom’s own research, 26% of socio-economic group DE households are now mobile only (16% in other groups if you are interested). They are relying today purely on whether they’ve remembered to charge their phone and/or Apple have invented a hydrogen cell, as opposed to the usual offering making you reminisce for an old Nokia and that the local masts have sufficient backup power in a prolonged outage too. I suppose, in my alluded to axe-murdering power-cutting thunderstorm I would also have my mobile, but everyone knows I have to carry around a 14000mAH battery pack because I always forget to charge my phone! This situation in itself is why I am surprised that the fixed requirement is just one hour…… after all, we are familiar with the snowmageddonwe endure each winter, with communities sometimes cut off for days.

At times I get the impression (and I have some sympathy with this position) that some VoIP companies would like to be able to just have a disclaimer that says “This device/service cannot be guaranteed to be able to make Emergency Calls” or somesuch. With the growth of VoIP and our need to have this technology widely accepted and embraced by the populace — and our desire to not pay for the line card and metallic path to the voice processor in the exchange — I don’t think that just making it someone else’s problem will wash….. you can just see the Daily Mail headlines now.

That all said, the solution isn’t a room UPS for every household, nor is it a hot-standby generator for every street. We also cannot avoid much longer the roaming VoIP location information issue; a return to the pre 1998(ish) situation of the caller having to give their address would be retrograde. That will make it interesting, and for once, I may not actually hate dealing with Emergency Calls in Regulatory Affairs either.

This is a VoIP week post on trefor.net. Check out other VoIP themed posts this week:

Why are major telcos afraid of encrypted VoIP? by Peter Cox
Emergency calls and VoIP by Peter Farmer
VoIP, the Bible and own brand chips by Simon Woodhead
Why the desktop VoIP telephone isn’t going away by Jeff Rodman
Small business VoIP setup by Trefor Davies
VoIP fraud-technological-conventionality-achieved  by Colin Duffy

Categories
Business End User ofcom Regs voip

A VoIP Spring

A regular trefor.net contributor, Peter Farmer is the Commercial and Regulatory Manager at Gamma, as well as an ITSPA Council member and Chair of ITSPA Regulatory Committee.  We are pleased to present his “VoIP Week” post.

So, Trefor asked me to approach an article for “VoIP Week” from a commercial perspective as opposed to regulatory…. took me a while, but sunstroked approaching Havant cycling from Esher to Portsmouth, it dawned on me.

We’ve had our VoIP Spring. We just don’t realise it yet.

Last year, there was much furore around Ofcom’s decision (enacting an EC Recommendation) to reduce geographic termination rates to the Long Run Incremental Cost (“LRIC”). These rates were previously calculated using Fully Allocated Cost (“FAC”). Very roughly, FAC is 5x LRIC in this market, so 0.3 became 0.06 pence per minute.

All the views espoused on that subject were valid, especially as we have a diverse industry with many niche interests and many unbalanced portfolios of net termination and origination. In the same market review, however, Ofcom transferred — for BT at least — the foregone common cost (the difference between LRIC and FAC, attributable to costs such as your CEO and Finance and HR teams, etc., and not directly to each incremental unit of what you are selling) in the termination market to the origination market. Granted, this had the perverse effect of reducing the cost (through the Significant Market Power Condition that governs non-geographic out-payments), but what it did to was virtually double the per-minute cost of the origination leg of Carrier Pre-Select and Indirect Access. Granted, again, this nets off against calls to UK geographic and non BT terminating non-geographic (why BT itself is exempt is a very long story that I will tell another day), but means that calls on legacy ISDN30 estates to mobiles and international numbers increased. Markedly. We are now in a situation where the direct cost of getting a call from the Network Terminating Equipment (“NTE”) over the Local Loop to the Digital Local Exchange (“DLE”) is five times that of getting it from the DLE to a mobile in the US of A. Seriously.

If you’re an over-the-top provider, your cost base just went down. You don’t have to worry about that leg from the NTE to the DLE. Your voice traffic is ones and zeroes encoded in packets of data over broadband frequencies, not analogue on narrowband frequencies. The per minute cost of providing the service to any caller has plummeted, relative to an ISDN2 or 30 or even a single WLR line.

And that right there, Ladies and Gentlemen, was our VoIP Spring. Let’s make the most of it.

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VoIP Week Posts:

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Business ofcom Regs

Mid Term Price Rises

The implementation date of Ofcom’s recent foray into mid-term price rises has now been and gone.

If you were the recently discovered Pacific castaway, then, briefly, Ofcom were concerned that Communications Providers were advertising fixed term contracts at a price and then increasing that price during the contract

This went through one stage of Ofcom intervention, when they introduced (via General Condition of Entitlement 9) the “materially detrimental” test. Which was to say that if an Communications Provider during a fixed term, to a domestic consumer or a small business (the usual sub-10 employee rule) made materially detrimental changes to the terms, the contracted party could have a penalty free exit from the contract.

Don’t ask me what materially detrimental meant. I once spent

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Engineer internet ofcom

Ofcom slow news – 98% of tablet owners use them to connect to the internet

August is normally a deadly quiet month. Almost to the extent that it would be very easy to say I might as well take the whole month off. This year seems to be different. We are rushed off our feet. It’s all good stuff. I’m not complaining. Just saying that we are very busy.

August is also normally a very quiet news month. The media resorts to headlines such as “Boy’s ice cream melts before he could finish it” and other riveting slow news day reports. The one bit of news that you could set your watch by every year in August is the Ofcom Communications Market Report. This year it came out when I was on holiday in North Wales and observing radio silence so I’ve only just noticed it. On that basis whatever I might say on the subject has possibly already been said.

Notwithstanding that the Ofcom CMR usually has some nuggets worth looking at. The first that stands out is the headline saying:

“Total UK revenues from telecoms, TV, radio, and post fell for the fourth successive year in 2012.  These services generated £59.5bn in revenues during the year, a £0.1bn (0.2%) fall compared to 2011 as a £0.7bn fall in telecoms revenues was offset by increasing TV, radio and post revenues.”

This is interesting because our use of the internet is growing massively. This might lead you to naturally conclude that the revenues for businesses operating in that market are growing. Certainly this is true for Timico.

It is clear though that for the industry as a whole the model is changing. Old fashioned lines of business are changing. ISDN is being replaced by SIP trunks – telephony by VoIP. The cost of minutes has plummeted largely to a fixed monthly fee per subscriber. Broadband prices are also at rock bottom, particularly for consumers. The government is right when it says we have one of the most competitive markets in the world.

This is also true for mobile and whilst people might whinge about mobile prices the mobile operators are struggling with their gross margins. These large telcos are still seen as fat organisations paying fat salaries and there is probably some way to go on the cost cutting side before mobile markets reach the bottom.

Everyone in the game is trying to modernise their business model. The money must still be there. It is just going elsewhere. One clue is in the growth in TV, radio and post revenues. People must be using their internet connection to spend money. In our house we probably watch more TV over the internet that on the actual TV itself. Including the advertising. We also buy a lot more stuff over the internet than we used to, hence the rise in postal revenues. It’s mostly not downloaded. It comes in a van.

As the world moves more “onto the internet” the one thing that is becoming more and more important is the integrity and the quality of the internet connection. This is particularly true for businesses who are increasingly growing to depend on revenues that rely in one way or another on connectivity to make them happen. For example if you own an ecommerce site then every minute of downtime means lost revenues. Similarly in the physical retail world, most payments are processed using broadband connections. Lose the connection and lose the lolly.

However people might be spending their cash this represents a huge opportunity for the telco that can respond to change. They just have to look up and look forward and not dwell on what was.

One final note. Ofcom bless em do have a way of stating the bleedin obvious. They tell us that nearly all (98%) tablet owners say they use their tablets to connect to the internet. One wonders what the other 2% use their tablets for?!

Gotta go. Busy busy busy.

Categories
Business fun stuff ofcom

Smart SEO makes a difference – NewNet wholesale comms provider

Web presence makes a huge difference to your business these days. You need to be on the front page of Google search rankings or you ain’t on the web.

I’m not saying we are up there for every search term we would like – that’s work in progress. However NewNet, our wholesale business is very much getting it right.

Check out the two screenshots below. The first is the top of the page showing the results for the “wholesale comms provider” search term. NewNet comes top for both paid for and organic. The other organic results on that page are mostly BT and then Ofcom. The second just shows you the rest of the screen. Nice.

google rankings wholesale comms provider

wholesale2

 

Categories
Engineer fun stuff ofcom

And the hot news is…

Normally I’m fending off ideas for blog posts. This last couple of weeks I’ve been wading through a soup of Awards Entries which take yonks to write, especially when they limit you to writing your life story in 250 words. Bit of an  exaggeration but those of you who have to do that sort of thing will know what I mean.

So I’ve looked up, drawn breath and thought what do I want to write about. There’s the massive DDoS attack against CloudFlare that was in all the news earlier in the week. “Internet grinds to a halt” – that kind of thing. It didn’t affect us.

Then there was the cable cutting by Egyptian insurgents, demonstrators, rebels, whatever they were. Didn’t affect us though I know one or two people with operations in the Middle East and lots of traffic to Pakistan that were affected. Not us though like I said.

I note today the Register talking about how capital expenditure by network operators is very rarely recovered. I guess that doesn’t apply in our case as we are not just a bits shifter. We are into added value services that generate good gross margin. We are in this game to make money.

If you’re not in the trade you might not have noticed the Ofcom consultation on Narrowband Markets which closed on Tuesday. Amongst it’s various nuggets the Ofcom proposals contain suggestions like “if you get your line rental from BT then they would also be able to compel you to get your minutes from them as well”.  Not good really and I’m to sure that is what Ofcom wanted to say but that is how it came out on paper. Timico responded through ITSPA, that fine Trade Association that looks after everyone’s interests in the Internet Telephony space – that’s yours and mine if you but knew it. I thought about a specific blog post on the subject but no, too tedious! Yawn…

Yesterday’s news was the 40th anniversary of the mobile phone. In those days it was the size of a phone box but, hey, you could stick it in your boot (trunk) and drive it around. That was yesterday’s news. This blog ain’t a retrospective. It’s progressive and funky. Move on.

Today all the broadsheet tech pages, at least the currently free to access ones such as the Grauniad and Torygraph, are talking about the leaks of info about the forthcoming Facebook phone – poetic license intended – more here. It might interest some people but not me. I don’t trust Facebook though I do use it to keep in touch with the kids and have to admit to having two Facebook Pages of my own (here and here). One assumes btw that with modern spellcheckers they never get the Guardian spelling wrong these days, unless they use an American dictionary maybe. Whilst claiming immunity to nostalgia there are still some things worth gazing back wistfully over your shoulders. The Grauniad spelling is one.

I’m a bit of a mixed up kid when it comes to these social media platforms and online privacy. On the one hand I complain about it and say I don’t trust any of them. On the other hand I still carry on using them all in one form or another. It’s unavoidable unless I just take an allotment and spend all my time growing carrots (or peas, beans and spuds – that kind of stuff anyway. Not sprouts as I’m not very fond of them and as for broccoli!!!). #isnotgonnahappen!

Anyway I can’t think of anything to write about today so I’m going to give it a miss. Feel free to post some ideas as comments. If nobody does I’ll take it as an endorsement of my own inactivity and assume that you are either still in Tenerife catching some rays, or skiing in Bognor Regis, WL.

Catch ya later 🙂

Categories
4g Business mobile connectivity ofcom

Everything Everywhere LTE Launch

The Ofcom decision to allow Everything Everywhere to launch an LTE (4G) service on its existing 1,800MHz spectrum has resulted in lots of press coverage this week (here’s me in the the Telegraph) and complaints from the other operators who have to wait for the auctions in the new year.

I can see both sides of the argument and like it or not I agree with the Ofcom decision to let them get on with the launch. We have to get these services out there so we can all start using them. I expect there to be no further delays in the auction process after this.

The big question in my mind is what the LTE packages are going to look like. I could be wrong but I sense that EE is not going to launch very fast services because speed uses up more of the spectrum. My bet is that the services will be perhaps 10 or 15Mbps using smaller chunks of spectrum and not the whizz bang speeds the technoogy can actually achieve.

10 – 15Mbps is still a lot faster than what we have already and allows the operator to offer faster services downstream without having to change its infrastructure. EE could alternatively offer the faster services at launch but at a premium. When it comes to it we don’t actually need 40Mbps (say) on our phones. What we will notice is the faster response rate at 10 – 15Mbps than we currently get.

Offering a speed that is not orders of magnitude faster than the existing services will also help prevent network congestion although the EE infrastructure has had a huge capacity upgrade in readiness for the launch.

The other interesting thing to look out for will be the pricing or more specifically how much data usage you will get for your money. Also which handsets will be supported?

Not long to wait now. Although Timico is an O2 and Vodafone house I will be getting myself an EE 4G SIM to play with.

That’s all folks…

Categories
Business ofcom Regs

So much to do so little time…

Not sure whether I mentioned it but I’m off on holiday after this week – going to see the London2012  Olympics.

You would think that the world would drop everything and focus on the biggest sporting event to hit the UK (ok mostly London) since ever. I’m amazed at how much is still going on in the world of internet legislation. So much so that most of it will have to be left to others for comment.

We have consultations over the Draft Communications Data Bill. Then the Interception of Communications Commissioner has published his annual report – interesting reading I’m sure.

Oh and did you know that the Welsh Government (iechyd da)  announced that it has selected BT to implement the Next Generation Broadband Project for Wales. BT was also the successful bidder in North Yorkshire which has become first county to deploy BDUK broadband (if I can call it that). Note the Welsh Government is also launching a Business Crime Unit.

Next up is EU Commissioner Neelie Kroes who has outlined the European Commission’s general conclusions following on from last year’s consultation on wholesale access to telecoms networks – good stuff.

You don’t need me to tell you that Ofcom has published its Communications Market Report for 2012 – I’ll definitely be reading that but not whilst I am on holiday.

You may not have noticed that the IP Crime Group, which was formed in 2004 by the Intellectual Property Office (IPO) to bring together experts from industry, enforcement agencies and Government to work together on piracy and counterfeiting issues, has published its latest annual report.

The Department for Business, Innovation and Skills launched a consultation on enhancing consumer confidence by clarifying consumer law. In addition to goods, the consultation also looks at services and digital content.

Finally uSwitch has published a report on broadband billing.

All exciting stuff eh? Unfortunately you will have to gen up on all this yourselves as I won’t have time to do it. All good reading for when you’re on the beach.

Ciao.

PS Lists and links have very kindly been provided by ISPA.

Categories
Business ofcom piracy Regs surveillance & privacy

Ofcom update on Digital Economy Act implementation timescales – slipped to Q1 2014 #DEAct

It seems a long time ago now, the passing of the Digital Economy Act. It’s easy to remember how long because it was rushed through just before the last general election and I’m sure that global historical events such as the re-emergence of a Liberal government (only joking) are amongst the list of dates you remember exactly what you were doing when “it” happened.

The assassination of JFK and 9/11 are the other two that spring to mind although others may well have other memorable dates – outbreak of WW2 etc. Note I don’t actually remember the JFK assassination, I was too young, but it is always one of the ones quoted.

Ofcom has updated ISPA and have said that the code of practice still has to go through various stages:

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Business ofcom Regs

Ofcom International Communications Market Report 2011 – the unscientific analysis

It’s always exciting when Ofcom brings out a new report. No, no I really mean that:) There is so much going on in the communications world and fair play to it Ofcom has the resources to produce some really interesting stats.

This time it’s the International Communications Market Report 2011. I’ve only just noticed that its out so haven’t had time to distill its 363 tightly packed pages into five paragraphs as is my usual wont. Don’t worry – that’ll be something to do another day.

In the interest of taking a break from work before going home I do, however, herewith provide you with a few choice morsels to keep you going until those five paragraphs are crafted.

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4g Engineer mobile connectivity ofcom Regs

complexities under the mobile data bonnet and Ofcom delay to #LTE auction #4G #digitalbritain

Everyone Everywhere (pun intended) will have heard of Ofcom’s decision to re-enter consultation over the LTE or 4G mobile spectrum allocation. Issued late on Friday afternoon the statement regarding the delay caused by reopening the consultation has already attracted comments re “hiding bad news over the weekend”.

There were 64 responses that included the  A to W of stakeholders in the UK (nothing from  X, Y or Z). The  Association of Train Operating Companies was mainly concerned to ensure that good coverage at high, sustained download speeds is ensured along the whole of the GB mainline rail network. At the other end of the alphabet both the Welsh government and Wiltshire Council wanted better coverage in rural areas with the latter quoting a target figure of 99% of the population.

Straightforward right?

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4g Business mobile connectivity ofcom Regs

Ofcom delay in holding 4G spectrum auction will cost UK £100s millions report says

More pressure has been piled on Ofcom and the government by the publication of a report by the Open Digital Policy organisation suggesting that delays to the UK 4 G license auctions will cost the country dear. The delay to the auction has been caused by apparent threat of legal action by a number of carriers including O2.

ODP looked at the speed, capacity and coverage improvements next generation mobile broadband (known as 4G or LTE) is likely to bring, and estimated that over 37 million business hours per year could be saved from faster mobile data downloads if 4G mobile technology was to be deployed sooner than is currently planned.

Earlier this year I chaired a debate on mobile spectrum allocation at Portcullis House in Westminster. The issue of 4G spectrum allocation is a hot potato. The three largest mobile carriers O2, Vodafone and Everything Manyplaces, have existing voice bandwidth that they are being allowed to reuse for data. 3 does not so this delay will not only cost UK business but will likely have a deleterious effect on the number 4 operator (this is clearly a numbers game).

Ofcom, the UK regulatory authority tasked with

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Engineer ofcom Regs voip

Ofcom study into location determining of VoIP callers to emergency Services

Consultants Analysys Mason are conducting a study on behals of Ofcom into determining the location of Voice over IP callers making calls to emergency services. It is is easy to determine the location of a caller is in the old fixed line world because a phone number is recorded based on the location of a piece of copper “plugged” into the local telephone exchange.

This is not the case with VoIP.  A VoIP number could be anywhere on the planet. Anywhere there is a connection to the IP network/internet that is.  Ofcom recognises this and wants to understand whether there is a practical solution.

UK technical standards organisation NICC has published (Jan 2010) a potential solution to the problem though this is complex and also limited to VoIP users using UK ADSL connectivity.

This solution stems really from network architectures familiar to large telcos and my first reaction is that it is very expensive. One might ask what price a life? This is a reasonable question. We all have grannies and nobody wants ours to

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Business ofcom Regs

Ofcom and the Typical Speeds Range for broadband

There was a lot of talk this morning about Ofcom ‘s research announcement that

“Average download speeds remain less than half of ‘up to’ speeds advertised by some Internet Service Providers (ISPs), particularly for broadband delivered via a phone line. “

Ofcom is recommending that if speeds are used in broadband advertising they should be based on a Typical Speeds Range (TSR), so consumers have a clearer idea of what speeds to expect.

The stock response from ISPs is that every line is different and by announcing an “up to “ speed they cover all the bases and customers are appraised of the actual expected speed of their line before they sign up.

This is an interesting one. I work for an ISP but I am also a consumer. I see no reason why ISPs should not be able to give greater prominence to typical speeds rather than the “best you can possible expect”. We should being straight and honest with our customers – not hyping things up and raising expectations that can’t be met (you can tell I’m not a marketing person here 🙂 ).

ISPS have made some concession to the fact that if a technology (eg ADSL2+) can theoretically do 24Mbps most people are not going to get that speed. A 24Meg line is therefore often described as an “up to 20Meg” line (not universally as the Ofcom data in the table inset shows). My “up to 20Meg line only does 11Meg. It is disappointing but I understand the game. Not everybody does, though you do wonder whether most people care.

Most people do care about the quality of their experience though and in the absence of any other suitable metric typical speeds are a good enough representation of this.

The survey results do make interesting reading. Firstly the Virgin results which are based on cable modem technology and not ADSL are consistently better – their typical numbers are consistently close to the “up to” numbers. That’s a technology thing.

If you look at the ADSL providers with similar technologies I’m not sure that there is much to differentiate them. The thing that is holding back these ISPs from quoting typical speeds is that these speeds would be significantly slower than those of Virgin. Not good for a marketing director’s pulse.

I sympathize with these ISPs but at the end of the day my consumer head still thinks it would be right to quote the typical speeds and not the “up to”. Or at least both sets of numbers.

I can’t see this happening voluntarily. It would only take one ISP to break ranks for all the others to have to follow.

All I can say is bring on Fibre ToThe Premises where 100Meg will be 100Meg, give or take a wavelength. I really hope that my home town of Lincoln skips Fibre to the Cabinet and goes straight to FTTP.

Categories
Business ofcom Regs voip

New EU rules on number porting has get out clause for fixed line providers

Ofcom is currently consulting on changes to EU law applicable to Communications Providers that in theory will force providers to port numbers within 24 hours of being asked.

Sounds great but fixed line providers have been chucked a get out clause that adds that a subscriber line has to be ‘ready for service’ before being appropriate to port.

This means business as usual for the likes of BT whose archaic manual porting system requires a complete overhaul anjd which often leaves business custoemrs in the lurch.

Coincidentally the Internet Telephony Service Providers’ Association, ITSPA has recently commissioned an independent report outlining the options for the UK Communications industry in respect of number porting. It isn’t just a technical issue. There are contractual bottlenecks as well with each CP having to independently negotiate separate porting contracts with every other CP.

I will share the output when I get is sometime in March. In the meantime Ofcom seems content to let sleeping dogs lie and accept that as long as the letter of the EU law is met, (but not the spirit) then that is all fine and handy. This might make Ofcom’s life easier but is a disservice to UK business that has to put up with lengthy delays with porting their telephone numbers.

Details of the Ofcom consultation, scheduled to last 6 weeks, are available here. Interestingly CPs are also required to offered disabled access to Emergency Services via sms text service. I will need to investigate this further but if applicable to ITSPS this is certainly something very new for them to get to grips with.

The new laws have to be in place by 25th May 2011.

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Business ofcom Regs

Ofcom hits BT Wholesale in the rurals #DEAPPG #FinalThirdFirst

Ofcom yesterday proposed significant reductions in the prices that BT Wholesale can charge internet service providers (ISPs) in parts of the country where it is the sole provider of wholesale broadband services – mainly in rural areas.

The proposed price reductions are between 10.75% and 14.75% below inflation.

As an ISP and BT Wholesale customer I say good oh! I’m not quite sure that it will achieve the effect Ofcom think it will achieve though. Yes we might find retail ISPs lowering their prices marginally for customers in these areas. Consumer ISPs already charge rock bottom prices so a cut of 15% off a low number won’t make much difference.

Also ISPs buy bulk backhaul bandwidth from BTW. This is not specific to particular exchanges or locales. For example Timico’s bandwidth comes into two docklands locations from all our customers all over the country. We would not be able to say “this customer gets more bandwidth because he is one of the lucky ones living in an area with reduced costs.

A big chunk of the cost is in the bandwidth used so whilst a reduction in line rental is good a reduction in bandwidth costs would be better. We may find that competition does drive down the cost to the end user a little in these cost reduced areas but there is also a fair chance that ISPs will just pocket the additional margin thanks very much and maintain homogenous pricing policy across the whole country. More packages means more complexity and ultimately more cost.

This many not necessarily be a company line here but it’s what I think will be the overall outcome. I might be completely wrong.

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Business net neutrality ofcom Regs surveillance & privacy

Net Neutrality debate in Westminster – surprise vote turnaround

portcullisIn Westminster yesterday BBC technology correspondent Rory Cellan-Jones chaired a Net Neutrality debate on a motion entitled:

“That this House agrees that traffic management is essential for the running of modern networks and that improved and enforceable transparency and market competition will ensure that consumers are protected from potentially negative effects.”

In an initial vote 50% of those present were in favour of the motion with perhaps 10 – 15% against but there was a twist.

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Categories
Business ofcom Regs surveillance & privacy

Ofcom to get another 3 months to finish #DEAct Code of Practice

At the DEAct conference in London today Rachel Clark, Deputy Director, Communications and Content Industries Dept for Business Innovation and Skills, told us that the deadline for Ofcom to complete its work on the Code of Practice has been put back 3 months to the end of March 2011.

She considered that this was still a difficult deadline to meet but at least it is an admission of the fact that Ofcom has been struggling with the enormity of the task in hand.

Interestingly the meeting comprised around 70 – 80% Rights Holders representatives. I thought this seemed disproportinate but actually only 6 ISPs are seriously being affected in the initial phase. More concerningly is the fact

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broadband Business internet ofcom

Ofcom – Increased Broadband Speeds and ISP Voluntary Code of Practice

Big headliner from Ofcom this morning is that average broadband speeds in the UK have increased by over 25% in the past year. Research, conducted in partnership with broadband monitoring specialists SamKnows, has found that speeds have increased from 4.1Mbit/s to 5.2Mbit/s.

This is no surprise really as ISPs move their base from ADSLMax (“up to 8Meg”) over to ADSL2+ (“up to 24Meg”). It’s a shame that the average is not higher but that’s copper for you. The research showed that cable customers fare significantly better than ADSL.

The Ofcom data also reveals some very interesting stats about performance during peak times that don’t do some ISPs any favours.

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Business mobile connectivity ofcom

Ofcom sets April 2011 deadline for faster mobile number porting

Ofcom has set a deadline of April 2011 for mobile network operators to speed up the process for their customers to port their numbers to competitors.  Customers will be able to change suppliers within 24 hours.  Believe it or not as a Service Provider I like this idea because it is good for our customers. It means that we either do a good job of servicing customers or they leave (subject to contract of course J ).

Companies offering good service will prevail.  Grauniad article here.

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Business internet ofcom piracy Regs surveillance & privacy

Mandelson’s Uncertainty Principle – evil genius at work or just plain incompetent? #DEAct

Mandelson’s Uncertainty Principle states that the costs to an ISP of processing a Copyright Infringement Report can only be known when that ISP knows how many CIRs it is going to have to process and that Rights Holders will not disclose this number until they know the costs.

If it was as simple as that we might be able to come to some arrangement but of course it isn’t.

The BIS consultation on Costs under the Digital Economy Act is not scheduled until October 2010. Work is going on now to prepare for this and yesterday Ofcom held a meeting with ISPs to take on board their views on the subject.

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Business internet ofcom piracy Regs surveillance & privacy

Ofcom Draft Code of Practice for the Digital Economy Act #DEAct

Just ploughing through the 73 pages of the Ofcom Draft Code of Practice for the Digital Economy Act.

There isn’t much time for the industry to respond here and I’m certainly not in a position to give it a comprehensive review after 10 minutes of scan-through reading.

A few points do immediately jump out of the page at me though.

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Business internet ofcom piracy Regs surveillance & privacy

#DEAct costs should be borne by rights holders – Ofcom meeting 1st June

The next Ofcom stakeholder meeting on the Digital Economy Act (DEAct) is taking place next Tuesday June 1 at 3pm at Ofcom. The meeting will be looking at Ofcom’s work in relation to cost sharing under the statutory instrument, on which BIS is currently consulting.

The DEAct was heavily weighted in favour of rights holders and we should be seriously concerned that the Code of Practice does not adopt a similar bias.

ISPs are intermediaries that pass packets of information over their networks. ISPs neither benefit from, nor

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Business internet ofcom piracy Regs surveillance & privacy

ofcom #deact market benchmarking

Section 8 of the Digital Economy Act requires Ofcom to report on the provision of lawful services, education and information campaigns, levels of copyright infringement and legal proceedings against infringers.

By January of 2011 the regulator must have set up an independent monitoring system so that there is data available to measure the success or otherwise of the Act.

Ofcom is proposing that monitoring should consist of three types of input: collation of existing data (eg existing industry reports, ISP traffic data and existing consumer research), consumer research and direct measurement of activity on file sharing networks.

Independant partners will be commissioned for the consumer market research and the direct measurement work with the tendering process beginning in June.

The market research will be conducted 4 times a year on samples of 5,000 persons each time. It will be interesting to see how accurate this research is. Will people tell the truth? I guess it will just be a contribution to the overall dataset.

The baseline data needs to be in place for the start of next year.

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Business ofcom Regs surveillance & privacy

Ofcom #DEAct Code of Practice limited to ISPs with 400,000 subs & excludes mobile broadband

ISPA Secretariat met with Campbell Cowie and Chris Rowsell from Ofcom this afternoon to discuss the ongoing work surrounding the DE Act.

Ofcom explained that the Code will look at four areas: process – how a Copyright Infringement Report (CIR) is generated and sent and the notification process; appeals for consumers; dispute resolution between ISPs and RHs; and costs, which BIS will be focusing on.

The Code is due to be published within the next ‘couple of weeks’, though no date has been set. As Ofcom did not anticipate industry to come together and produce an effective code as per the DE Bill/Act, it had been planning what a Code may look like for some time and had not relied on one side of the debate to influence the content.

Due to the short timescales Ofcom has been working to, the Code will be instructional rather than setting out line-by-line what is required. For example, instead of dictating a standard approach for a CIR, those affected will have to tell Ofcom how they will go about it and Ofcom will then approve it or recommend changes.

The Code will initially be limited to ISPs with around 400,000 subscribers – currently 7 ISPs – and not including mobile broadband, but the long-term ambition is to target those ISPs with copyright infringing consumers. So downloaders who migrate to an ISP not included in the soft launch of the Code will eventually be covered as Ofcom follows the traffic. Ofcom has also been tasked with analysing the level of copyright infringement and barriers to innovative and emerging business models and report back to the Secretary of State, and would be actively seeking views on this.

My thanks to the ISPA Secretariat for this feedback.

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Business ofcom Regs surveillance & privacy

Ofcom #DEAct Code of Practice limited to ISPs with 400,000 subs & excludes mobile broadband

ISPA Secretariat met with Campbell Cowie and Chris Rowsell from Ofcom this afternoon to discuss the ongoing work surrounding the DE Act.

Ofcom explained that the Code will look at four areas: process – how a Copyright Infringement Report (CIR) is generated and sent and the notification process; appeals for consumers; dispute resolution between ISPs and RHs; and costs, which BIS will be focusing on.

The Code is due to be published within the next ‘couple of weeks’, though no date has been set. As Ofcom did not anticipate industry to come together and produce an effective code as per the DE Bill/Act, it had been planning what a Code may look like for some time and had not relied on one side of the debate to influence the content.

Due to the short timescales Ofcom has been working to, the Code will be instructional rather than setting out line-by-line what is required. For example, instead of dictating a standard approach for a CIR, those affected will have to tell Ofcom how they will go about it and Ofcom will then approve it or recommend changes.

The Code will initially be limited to ISPs with around 400,000 subscribers – currently 7 ISPs – and not including mobile broadband, but the long-term ambition is to target those ISPs with copyright infringing consumers. So downloaders who migrate to an ISP not included in the soft launch of the Code will eventually be covered as Ofcom follows the traffic. Ofcom has also been tasked with analysing the level of copyright infringement and barriers to innovative and emerging business models and report back to the Secretary of State, and would be actively seeking views on this.

My thanks to the ISPA Secretariat for this feedback.

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Business internet ofcom piracy Regs surveillance & privacy

Ofcom goes quiet on #DEAct Code of Practice

Ofcom seems to have gone very quiet since the initial flurry of consultation meetings following the passing of the Digital Economy Act. This is somewhat concerning in my mind.  Ofcom has to produce a draft Code of Practice by the end of May.

The DEAct is such a contentious subject that the last thing we want is to find  that this CoP is not objective and is bisassed towards one set of stakeholders over another. It is a lot easier to get changes made before the initial draft than afterwards.

It is also hugely important for Ofcom to remain transparent here and it would make sense to me for the regulator to be asked to identify how many contacts and inputs have been had with each set of stakeholders during the compilation of the draft CoP.

Ofcom responsibilites in respect of the DEAct can be found here. There is one meeting planned for 20th May to present these duties. Doesn’t seem to be to do with the CoP subject matter.

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Business ofcom Regs voip

Ofcom’s unwillingness to enforce porting regulations – guest blog post

Louise Lancaster is a communications lawyer specialising in interconnect, regulation and public affairs. Having qualified as a solicitor in 1994, Louise held a variety of legal, regulatory and public policy roles in the telecoms industry before forming Ayres End Consulting in 2003. She now provides commercial, strategic and compliance advice to communications providers and trade associations. Her website is at http://www.ayres-end.com/.

It is widely accepted that the routing of calls to ported numbers in the UK is based on an antiquated process. Calls to ported numbers are required to route via the original Range Holder, and then onward to the current service provider (rather than being directly routed to the current SP). To achieve this, the Range Holder and the new service provider must engage in drawn out negotiations to agree conveyance charges and routing plans. These typically take six months to a year, but can take longer.

If I wish to change my service provider I will not want the move to be delayed by an inability to port my number. But

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Business internet ofcom piracy Regs surveillance & privacy

Ofcom #DEAct definitions meeting – more work needs doing

Ofcom held a DEAct definitions meeting with ISPs yesterday afternoon.  Although I couldn’t make this one I have discussed the progress made with some of the attendees.

My view is that Ofcom has been given a task, the generation of the draft  Digital Economy Act Code of Practice, that is impossible to fulfil to everyone’s satisfaction in the three weeks that the regulator has left to complete it.

The meeting did not nail the major issues in terms of definition of who is and isn’t an ISP or Subscriber. Some of the definitions are highly complex and subject to different interpretations. The natural order of these things, believe it or not, is to brush the problem areas under the carpet and assume that this will be ok.

However in this case using the “carpet technique” potentially leaves huge holes in the legislation that will make it completely ineffective. 

For example nobody believes that the intention of the Act is to kill off the  WiFi hotspot market.  Is a WiFi hostpot operator a subscriber or a Communications Provider? The latter potentially as it is selling/providing services to custmers.  It is impossible in a many cases to be able to identify the subscriber on these hotspots so infringement notices go to who? 

So whilst it isn’t Parliament’s intention to kill off WiFi hotspots if they don’t do so then these connections will become defacto standard targets for those wanting to continue to download copyrighted material.

Marry in haste and repent at leisure (or words to that effect).

Also good luck to the people at Ofcom because they are, in my experience, by and large intelligent and able folk. We only have to wait 3 weeks to see what they come up with.

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Business internet ofcom piracy Regs surveillance & privacy

Digital Economy Act appeals meeting at Ofcom – notes #DEAct #debill

I went along to the Digital Economy Act appeals meeting at Ofcom today. I did so partly out of concern that smaller ISPs were not being given a voice at this important stage of the post DEAct game.

The Ofcom Boardroom (R11.01) was hardly big enough for the 35 or so people there. Organisations represented included ISPA, Timico, Which, Consumer Focus, Ofcom, AAISP, DCMS, Alliance Against IP Theft, UK Music (Feargal), BPI, BT, Mobile Broadband Group, Sky, Premier League, Orange, HSBC, Post Office, Virgin Media, TalkTalk, T Mobile, Communications Consumer Panel, Open Rights Group, Nintendo.

The scope of the meeting was to discuss the Appeals Process for subscribers accused of unlawful copyright

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