Just FYI I was at the meetings in question, it's perhaps a little presumptuous to assume what my source indicates.
I know your credentials in the area, so I'm not trying to be presumptuous, but I certainly am puzzled. Extremely puzzled.
Think about why the Urban Broadband Fund has ended up being a voucher system. EU state aid rules.
The exact same issues prevent use of the other BDUK money in these areas. The main BDUK fund is for 'rural' broadband only and while that definition has been stretched out of all recognition it still stands,
This, I think, is getting two separate issues seriously muddled.
The state-aid rules only dictate that public funds cannot be used in areas where competition is present, or has been "announced" to be present (to the councils, under NDA, as part of the "open market review" phase) within 3 years - a so-called "market failure". This results in the common "NGA white", "NGA grey" and "NGA black" zone maps.
The councils must then perform a public consultation based on this competitive picture - showing their rules, their intentions and the maps.
Every public consultation I have read, including West Yorkshire's, has specified the state-aid rules to restrict intervention to "NGA white" zones. There are no rules about not intervening within cities, nor within urban areas, nor within certain population densities, nor enforcement of rural areas only, nor the addition of any "wealth" demographics.
The
only rule is that competition must not exist.
Here, therefore, is the source of my puzzlement:
On one hand, the West Yorkshire public consultation document makes the following statements:
- �White� areas are those served by no NGA broadband network
- These White areas indicate there is a market failure to provide NGA
- The broadband project will only tackle these White areas
- These maps shows the potential �white� intervention areas for both basic and NGA
broadband
- Maps [and the maps show "white" intervention areas in Leeds city centre]
But it makes no statement about why any of the "NGA white" areas would be considered ineligible for other reasons.
On the other, you are saying that, from your contacts, some of those "white" intervention areas depicted in the public consultation are actually ineligible.
If you are correct, then the West Yorkshire public consultation is a sham. It isn't telling the public the truth - it is misstating the state aid rules, and misrepresenting the areas that are to be included for consideration.
Hence my puzzlement.
The main BDUK fund is for 'rural' broadband only and while that definition has been stretched out of all recognition it still stands,
I agree that it has been touted as a "rural" project, but it is actually run as a "final-third, anything-commercially-unviable considered" project - and the 'optimal deployment' that you mention has a tendency to promote in-fill of unviable cabinets on viable exchanges.
In part, I'm sure this is because Ofcom's definition of "rural" happens to amount to
a final-third of the country too, and back in 2011 all we knew of BT's commercial project was that it would target two-thirds. It was reasonable, in many spectator's minds, to believe that the
viable two-thirds was the
urban two-thirds.
We didn't know for fact, back then, how much rural would be included and how much urban would be excluded. Now we know that a reasonable proportion of urban properties are deemed unviable - and the knock-on effect is that a matching portion of rural properties therefore made it into the commercial project.
With this knowledge, it seems the actual BDUK projects are responding in the best way possible - they are including urban unviable properties as within-scope.
hence why London has no BDUK programme to plug gaps and you aren't seeing BDUK funding infill in major city centres.
Back in 2011, when the funding allocations were made, the government allocated London no funds - justified by the statement "presumed covered by private sector".
It turns out, 3 years later, to have been the wrong presumption. Obviously it is too late to now start a BDUK project in London, given that the money has already been allocated. Who knows - perhaps London will choose to use their UBF money to run a BDUK-equivalent project.
I think the other major city centres haven't been seen yet because they are all late within the BDUK process, and have relatively little funding. But it isn't zero, unlike London (or Hull).
UBF certainly complicates the issue for the few major cities that got money, but again, this may not prevent a BDUK-like project to provide SFBB capablities (not UFBB). Bristol, for one, was aiming to use a portion for exactly that - but who knows whether that will have survived.