Ofcom consultation on the USO

OFCOM have issued a new consultation on the Broadband USO.

This one is all about how they designate the operator(s) across the country. The consultation on the actual designations will occur later in the year


There are a couple of interesting points in Section 2.18 point 2.
"No provider (other than BT) has indicated that it would be prepared to be designated on a national basis"

And

"if we were to conduct an auction on a sub-national basis, there is only one Local Authority in which we have received more than two expressions of interest, while large areas of the country have attracted no expressions of interest."

Rest is fairly dry with only one question.
"Do you agree with our proposed approach to designating a Universal Service Provider? "

Also see this article & discussion on ISP Review: https://www.ispreview.co.uk/index.php/2018/09/five-i...

Some people in the comments section of that article brought my attention to the responses from potential USO providers, which can be found here: https://www.ofcom.org.uk/consultations-and-statement...

Note that in BT's response (BT's Response - PDF File), 4G LTE plays the prominent role for their USO proposal.

How would the USO of 10 Mbps work in Scotland since the Scot Gov't has its own 'Reach 100%' programme (R100) with min speeds of 30 Mbps planned for all?

Edited by deleted (Sat 15-Sep-18 12:11:55)

Given launch date of USO in 2020 and the if there is a plan to bring something USO capable within 12 months, then you cannot demand via USO is how it will work.

Given the speed at which it can be deployed, then yes 4G is probably going to be a big part, did not write it up on our news feed as seems not worth it until we have a better idea of what will actually happen and be made available.

I agree that 4G is the most likely technology for BT to use to fulfil most of the USO requests, I've thought that for a while. They already have the packages in place, basically these:

BT / EE's "4GEE Home Router / Mobile Broadband" packages

An external LTE antenna can be installed for an extra £100, which seems like a good idea.

I myself use a 4G router (TP-Link Archer MR200), with an EE Data SIM (albeit only 32Gb per month at the moment), and Load Balance it with my slower (2-2.5Mbps) ADSL connection (using a DrayTek Vigor 2860Vac router), and it does give me a nice "superfast boost" when needed (although these days I usually run out of 4G data before the month is up!). So, it's certainly a viable solution for many areas, in theory. The speed and latency of 4G in general are good.

I keep mentioning EE, and realise that others use Three, O2 or Vodafone (or MVNO's [Mobile Virtual Network Operators] based on these) - but I'm keeping my comments to EE for the purpose of this posting, as EE is part of BT and will be used for USO delivery - plus many of us out "in the sticks" on our long EO (Exchange Only) lines, can only get service from EE (if we're lucky enough to have 4G at all - I was chatting to somebody a few days ago not too far away who can't get any fixed line broadband at all, not even 0.5Mbps, and no proper mobile signal, so has to use Satellite for internet), and we aren't often covered by the other 3 mobile networks, at least not for 4G.

However, there are 2 areas that I believe need solving before 4G can be a full USO option, at least in my opinion:

1. The CGNAT issue - if using a pure 4G connection, it's very difficult to use systems (e.g. if hosting a service from home, utilising home automation etc) that may need Static IP addresses. This especially can affect people (like myself) trying to work or run a business from home. I know some 4G SIM contracts allow Static IPs, but they usually seem extremely expensive.

2. Data Caps - the current EE plans allow 50 to 300Gb limits (at a hefty price - I was tempted at one point by the 200Gb option, but the prices of all their packages have actually *increased* by £10 per month recently, which goes against what BT say in their response document about driving prices down - maybe it's a case of them "making hay while the sun shines"?!). The problem with the data caps is that they are a "hard stop" when you reach the limit, like hitting a brick wall! Although, at least with EE, this means you don't accidentally rack up huge extra costs by going over your limit, which is excellent. You can buy more data to last you until the next billing month starts (when your data allowance is reset), however extra data is at massively inflated prices.

In my opinion, for USO purposes, these issues could be mitigated or solved by offering, ***in USO-eligible Post Codes only*** packages that either:

1. Use a "tapered" data limit, combined with speed throttling when the data cap is exceeded. I'm aware of the issues with offering unlimited data on 4G packages, I've heard it's not sustainable due to congestion / backhaul / spectrum capacity + bandwidth problems, etc - however, just for those of us in USO areas, maybe the downstream & upstream speeds could be throttled back to, for example, 3Mbps down / 0.5 Mbps up, if/when the data cap is exceeded - that way, at least we wouldn't lose our important connection.

And / or:

2. Use a true "bonded connection", to combine our existing sub-10Mbps fixed line link, with a 4G link. This would required special hardware both at the user's end and ISP-end. But, that would mean that when the 4G data cap was exceeded, we could still use our slow fixed-line link, without being cut off. Also, it would potentially solve the CGNAT issue, by using the slow fixed-line link for all such traffic requiring it. I guess Load Balancing is a 2nd option, but true Line Bonding would be better. Again, special packages just for USO usage, in order to prevent capacity issues on 4G.

I still also think that maybe traditional point-to-point (line-of-sight) FWA (Fixed Wireless Access) links, and maybe also TV Whitespace, can also play a part in providing USO connections to some of the harder to reach areas. With Satellite only as an option of real last resort.

Of course, I'm still hoping that some USO can be fulfilled by FTTC / FTTP, although this is looking less likely.

From a purely selfish perspective, I'm also still hoping that some of us in Wales will be included in the next BDUK phase (still waiting to hear news on that) - and the same goes of course for BDUK areas in Scotland, England & N.I. too.

Anyway, those are my (probably un-informed!) thoughts on the matter. If anyone thinks they are viable, I may be minded to provide feedback both to Ofcom and BT - we have until 15th October to submit responses - see: https://www.ofcom.org.uk/consultations-and-statement...

Kind regards,

Adam.

Trouble is, I don�t know how EE�s LTE spectrum would fit in to Openreach. As really it is Openreach that would have to fulfil any USO, rather than individual CPs such as BT Consumer or TalkTalk.

Can Openreach use EE�s spectrum? I don�t know the answer to that at all, does anyone else?

Does it even have to be done by Openreach and wholesaled?

So if BT Group is designated a USO for broadband would it satisfy Ofcom if they merely say �Well we can provide EE Home 4G Broadband to all of those properties�? Not wholesale it to other providers, just retailed by EE and presumably by BT Mobile too?

Edited by deleted (Sun 16-Sep-18 14:46:20)

The USO obligation will probably fall on BT Group, rather than Openreach specifically, and don't recall seeing any requirements for USO service to be made available on the same basis as Openreach services are currently.

Icarus

You need to read the BT response to see what they are suggesting. I think a summary would be.

Out of the 600k sub USO lines suggested at 2020, 450k would be already provided with (4G) wireless ability so reducing the USO to only 150k. ( Some with outside aerials.)

So only 150k would be looked at, either by
1. Proactive build starting ASAP (2019) if OFCOM designates BT quickly, target to cover ALL by end of 2021 (price dependant on take-up demand density).
2. Reactive build starting with requests ( building demand up until under £3400/ connection) in 2020 likely to be longer waits and unlikely to cover all until post 2023 due to slow ramp up.

If BT are going to cover an area (others may cover some areas) I prefer 1 on economic and efficiency grounds, as I can foresee that there will be one off demands everywhere and it is not possible to do all the work at once on a demand led basis. Therefore proactive build will enable quicker rollout to more people but some people who want it at the start date may have to wait until the end of the programme which will be more than 12 months.

Several industry respondents have noted the same issue as BT in that building everywhere within 12 months for odd connections is not possible with the available resource.

kitkat: I did read BT Group�s response. My question was how Openreach fits into this. Which you haven�t addressed at all.

Andrew: Your response in interesting. So if it�s BT Group as a whole that�s being targeted, and they aren�t required to wholesale then as long as EE can serve most of the properties with 4G then the remainder can be done via Openreach?

Edited by deleted (Mon 17-Sep-18 16:21:58)

It appears that if they have access to 4G at speeds of 10Mbps or above then they aren't a USO target in the first place - doesn't matter who the provider is. If they can't get 4G then one potential solution may be to install 4G masts.

In reply to a post by ian72:

It appears that if they have access to 4G at speeds of 10Mbps or above then they aren't a USO target in the first place - doesn't matter who the provider is. If they can't get 4G then one potential solution may be to install 4G masts.

Understood. But my question was: If they can�t get 4G at the moment, and masts need to be installed then does that need to be wholesaled by Openreach? But it appears not.

Icaras

Openreach dont own the network assets BT Group do. So BT Group would become the USO designated provider (if Ofcom agree). BT Group's response states they would instruct openreach to proactively build out to all USO properties under the £3400 cost threshold. Although the numbers are redacted you can approx around 70k-80k properties would get new infrastructure.

The controversial aspect of BT Groups response is removing the 450k properties with 4G cover from the USO - how that plays out in other areas where other designated USO providers may be available... For example Hyperoptic and Quickline both suggest they would seek designation in specific areas, but you could hazard a guess that the vast majority of properties in those areas would also have 4G coverage so would they be excluded from USO?

In reply to a post by Icaras:

Understood. But my question was: If they can�t get 4G at the moment, and masts need to be installed then does that need to be wholesaled by Openreach? But it appears not.

The key aspect is that 4G wouldn't be the USO delivery, but having 4G Coverage (at acceptable RSRP of -105db @ 1800MHz) would exclude you from USO inclusion.

There's no suggestion of using USO funding to build more 4G coverage - so no requirement to Wholesale or Mast sharing.

Edited by TechServ (Mon 17-Sep-18 17:39:37)

If an existing service meets the USO metrics then no matter who is USO operator in an area, the USO becomes irrelevant

Now with 4G it is possible that house A will get 25 Mbps down and 2 Mbps up, but house B 40 metres way will be below 1 Mbps on the upload side, but you would usually only know that once someone has tried to install the service.

Which raises questions around how you determine if a service is USO compliant.

In reply to a post by MrSaffron:

If an existing service meets the USO metrics then no matter who is USO operator in an area, the USO becomes irrelevant

Now with 4G it is possible that house A will get 25 Mbps down and 2 Mbps up, but house B 40 metres way will be below 1 Mbps on the upload side, but you would usually only know that once someone has tried to install the service.

Which raises questions around how you determine if a service is USO compliant.

Currently 4G / LTE is not compliant as an NGA technology, so it depends if Ofcom accept 4G as a valid broadband service - hard to argue when 17000 currently use EE's 4G Home Router, but still to be answered.

With regard to house A and house B, by only using 1800MHz spectrum you can determine quite accurately the RSRP and SINR at any given pin location - that will determine the speed achievable. By not using 800MHz spectrum there is no danger of upload falling below 1Mbps. The -105dB RSRP limit will also remove marginal coverage properties and seasonal variations.

NGA? You mean superfast?

If Ofcom was to rule 4G as non USO compliant full stop, irrespective of speeds of service, then ADSL2+ would have to be and a lot of the fixed wireless services too.

Ofcom is likely to accept 4G as a USO capable service, but will vary for individuals as to whether it qualifies based on the connection speed that a 4G modem will connect at.

4G ticks the latency parameters, for lots of areas ticks the download and upload, and usage allowance of 100GB can be done. The downside being the cost of the 100GB allowance and that is where things may change, hint look at the rise of higher usage allowance packages especially BT with a data SIM only service now.

Yep, I did already know that BT Group own the network assets and that hasn�t and won�t be transferred to Openreach Ltd.

Mobile technology is a tricky one. In some ways we rely on the network�s coverage maps. Which in my experience are often wrong. As Andrew said you can move 40m and have no useable signal. Maybe even in an area that the network says you should have a signal.

I�m outside now and have 1 bar of 3G on EE. It�s excrutiatingly slow, but the network map says I should have great outdoor coverage.

The advantage with the EE 4G Home solution is that if you order and then cannot get signal with the outdoor antenna then that should trigger you as being non USO, how this will all work i.e. maps say yes but reality says no are what is going to cause all the shouting when the USO starts actually working.

NOTE: Mounting an external antenna on the roofline of a home is very different to standing outside with a mobile phone in terms of signal reception

Icarus

I think other have now covered this. The response suggests that BT Group commission OR to provide FTTP ( or possibly FTTC) where there is no supplier able to offer a USO service.

section 3.16 states "Where the number of customer orders to BT in an area reached a level that allowed the deployment to be undertaken within the threshold, BT would commission Openreach to build. "

Likewise,for those customers above the £3400 section 4.2 states
" Where a consumer requests service, we would request a cost quote from Openreach. If the consumer was prepared to pay the excess, we would commission the build from Openreach as appropriate."

No not superfast - just that LTE has not been judged as approved for State Aid funding which the USO could be classed as (next march who knows)

The trouble is that currently Ofcom do not consider coverage from 4G Broadband in their analysis of broadband availability, just because EE / BT say they can cover 450k properties with a compliant service, why is it not validated the same as DSL? What about Three, they also offer a USO compliant service, surely there would be overlap with EE but also unique properties covered as well. VF could in a heart beat offer a compliant service etc etc.

A 4G service is compliant with the USO specification, but Ofcom have to make their position clear - at the moment its cowboy territory - you have suppliers in wales charging £800 on a voucher for a 4G Antenna install, suppliers in England charging £300-600 often with voucher and EE themselves charging £99 for the only MNO approved solution, that's insane & bad value for government to allow that to continue.

USO is unlikely to be state funding classified, hence the on demand and levy to fund it rather than BDUK money etc

The issues around silly pricing to exploit vouchers is something I have mentioned in face to face meetings

An important point, the 10 and 1 figures are sync/connection speeds, and not sure what a 4G modem connecting at 11 Mbps down and 1.2 Mbps up actually produces in terms of TCP/IP throughput

The throughput of a 4G Modem is dictated by the RSRP and SINR (& RSRQ but less relevant)

The point is that you wouldn't see throughput of 11Mbps and 1.2Mbps if the parameter threshold is -105dBm using 1800MHz, you'll be seeing closer to 25-30Mbps D/L and 10-15Mbps U/L

Its only when you get to fringe cell edge that you'll see the SINR deteriorate (& the upload will disappear) then as you approach -115 -120dBm RSRP the D/L will tail away.

If you were on 800MHz you'd be lucky to see 12-15Mbps D/L & 1-2Mbps U/L - at least on EE's limited 800MHz spectrum

In reply to a post by TechServ:

The point is that you wouldn't see throughput of 11Mbps and 1.2Mbps if the parameter threshold is -105dBm using 1800MHz, you'll be seeing closer to 25-30Mbps D/L and 10-15Mbps U/L

But if there are 10 similar active users on the same cell and frequency, presumably they'll get <3Mbps usable throughput each?

Hence I don't think the concept of "sync speed" is particularly useful in the context of wireless delivery of USO. With FTTC or ADSL, even if you get only 10M sync speed, at least it's a dedicated point-to-point link to the DSLAM.

Aside: I'm old enough to have worked with 10baseT ethernet hubs (and 10base2). An ethernet hub is like wireless: only one device can talk at a time. Out of your 10M raw bit rate, the effective usable throughput was about 4M once overhead like collision detection was taken into account. And that 4M was shared between all the devices on the LAN.

I still have a couple of 3com hubs in the garage if anyone wants them

I agree that 4G is the most likely technology for BT to use to fulfil most of the USO requests,

This may work in some rural areas, but quite a many USO lines are and will be in city centres (the urban EO line problem). 4G fails to deliver in these areas because of population density. This has already been demonstrated in London with Relish. They are unable to provide anything resembling USO quality at evening peak times. There are just too many users within the cell tower area competing for the same bandwidth.

And of course as you mention, the proposed USO data cap (100G?) is borderline ridiculous and this would most likely be the woe in any mobile networks. Download a couple of games, OS updates to your ipads, iphones and computers and watch an episode or two of something on Netflix and you are done for that month.

Many urban/city centre lines already get over 10Mb on ADSL.
The fact they are EO and FTTC hasn't come won't matter if they are above the USO.

Not all urban/city centres struggle with the very low 4G speeds you describe either.
I get over 100Mb down at peak in Edinburgh City Centre.

I don't know how that would work anyway.
Does the guy on the thread before this who has 330/50Mb FTTP qualify for the USO? His peak time speeds are below 5Mb.

Your last paragraph Andrew has become even more true today, with EE launching a 500Gb per month package - see this thread for cross-reference: http://forums.thinkbroadband.com/mobilebroadband/t/4...

Of course, it's still a hefty price tag for the data (500Gb is £100 per month) - but the price of 4G data in terms of "pence per gigabyte" is gradually coming down (that 500Gb package is cheapest, at 20p per 1Gb, so best value if you know you're going to need it) - hopefully that trend continues, if it does then 4G could become a more viable alternative (if the cells aren't oversubscribed of course, which would diminish speeds).

In reply to a post by candlerb:

In reply to a post by TechServ:

The point is that you wouldn't see throughput of 11Mbps and 1.2Mbps if the parameter threshold is -105dBm using 1800MHz, you'll be seeing closer to 25-30Mbps D/L and 10-15Mbps U/L

But if there are 10 similar active users on the same cell and frequency, presumably they'll get <3Mbps usable throughput each?

No that is not the case , the backhaul is contested, just as the backhaul of a FTTC cab is shared between active users, but the EE 4G Broadband Service is (as BT Group have stated) using additional spectrum capacity not used by Mobile UE Devices.

Individual 4G Broadband connections vary between 20 & 120Mbps DL but their average peak time throughput is around 33Mbps DL (previously sold as upto 60Mbps).

LTE its not single talker like an 10BaseT Hub - EE use Frequency Division Duplex on their LTE Spectrum - same as VDSL - the maximum possible throughput is down to Spectral Efficiency, sharing the available resource between UE Devices - With MiMo and MuMiMo even greater efficient use of spectrum is possible, maximising throughput.

Many urban/city centre lines already get over 10Mb on ADSL.
The fact they are EO and FTTC hasn't come won't matter if they are above the USO.

Not all urban/city centres struggle with the very low 4G speeds you describe either.
I get over 100Mb down at peak in Edinburgh City Centre.

Does any EO line (= ADSL) actually go over the 1Mbps upload requirement? I guess it would be theoretically possible, but this would require some tinkering and also an optimal and very short connection?

The problem with low 4G speeds is not everywhere but it seems to concentrate in areas with low ADSL speeds and no fibre services. My particular area in London is one of these (slowly improving, though). ADSL speeds are in the range of 2-3 Mbps. Relish offers an unlimited 4G service and speed drops to 2-8Mbps at evening peaks.

My mobile operator of course does not offer unlimited service and I can get 50Mbps using that, but my allowance would be used in about 20 minutes of 4K streaming, which does not make it fit for purpose as ADSL replacement. A major OSX update would already be over the limit.

In reply to a post by hvis42:

Does any EO line (= ADSL) actually go over the 1Mbps upload requirement? I guess it would be theoretically possible, but this would require some tinkering and also an optimal and very short connection?

Tens of thousands. Being EO on ADSL2/2+ is no different from going via a cabinet (PCP). It's simply a question of the distance to the premises.


I'm 2.1 miles by the connection route from my exchange and got 5Mbps/1,100kbps.

Edited by RobertoS (Thu 20-Sep-18 10:54:22)

And while this is the case in terms of sync, as the ADSL2+ is nearing end of life using it to tick USO boxes is not a great idea.

Have said that ADSL2+ should NOT be considered USO capable to Ofcom. You could perhaps exempt it it was Annex M e.g. 15 Mbps down sync and 1.8 Mbps upload sync, but standard mode ADSL2+ will be seen as fudging things.

If there is a need to ration things, then yes those with over 10 Mbps sync on ADSL2+ I would consider less urgent than those below 10 Mbps sync.

I completely agree. I was simply pointing out to the poster that an EO line on ADSL2/2+ can easily attain over 1Mbps upstream sync at considerable distance . Despite being well below 10Mbps downstream.

Edited by RobertoS (Fri 21-Sep-18 00:09:16)