Response to 'Access to Bandwidth - Proposals for Action' The following is our response to OFTEL's second paper on the regulation of broadband Internet access and local loop unbundling, Access to Bandwidth - Proposals for Action © September 1999 Campaign for Unmetered Telecommunications

1. The Campaign for Unmetered Telecommunications welcomes the broad thrust of 'Access to Bandwidth: Proposals for Action' [1], in particular its emphasis on unmetering and 'always-on' Internet connections. However, we have some reservations about detail.

2. The principle of Option 4 followed by Option 2 (5.9) is sound but the proposed timescales are much too slack. xDSL was available well before the publication of 'Bringing Higher Bandwidth Services to the Consumer' [2]; those implementing xDSL will have worked on the technical and commercial implications for several years by now.

3. We suggest that production of a spectral management plan and other procedural and managerial directives is compressed into a shorter timescale than up to fifteen months (1.9), thus bringing forward the start date for Option 2.

4. The proposals almost exclusively mention ADSL. Some people have suggested to us that ADSL is 'already obsolete', which we think is an overstatement, but there are both lower-bandwidth (IDSL) and higher-bandwidth (HDSL, VDSL) flavours of xDSL available now.

5. We suggest that OFTEL investigates the feasibility of IDSL [3],[4] as an adjunct to ADSL, providing very cheap 'always-on' Internet connections at ISDN speeds.

6. We suggest that a consultation process is immediately implemented by OFTEL to explore the issues involved in deploying copper-based broadband techniques faster than ADSL and also 'fibre to the door'; the gap between deployment of ISDN and deployment of ADSL has proved unacceptably long and viable technologies must not be allowed to slip out of view.

7. There is insufficient emphasis on ADSL Lite (6.5). A crucial feature of ADSL Lite not mentioned in the consultation paper is that it can be integrated with PCs and Internet appliances at a low level (for example, on motherboards), thus making it cheaper and easier to configure than ADSL per se. It has also recently been standardised by the International Telecommunications Union [5], lack of standardisation presumably being part, if not all, of the 'technical issues to be resolved'.

8. We suggest that OFTEL puts pressure on BT for early availability of ADSL Lite, particularly for consumer use.

9. We are concerned at the high trial wholesale prices for ADSL for SMEs announced by BT [6] (consumer trial wholesale prices had not been announced at the time of writing) which, if the proposed timescales remain, BT will probably be able to maintain for over a year under Option 4.

References

[1] Access to Bandwidth: Proposals for Action
http://www.oftel.gov.uk/publications/1999/competition/llu0799.htm

[2] Bringing Higher Bandwidth Services to the Consumer
http://www.oftel.gov.uk/publications/1995_98/competition/llu1298.htm

[3] ISDL: ISDN Digital Subscriber Line
http://www.ascend.com/docs/techdocs/idslto.pdf

[4] ISDL: Deploying High-Speed Data Access Services Today
http://www.ascend.com/docs/techdocs/idslegwp.pdf

[5] Affordable Multi-Megabit/s Network Access to Internet via Telephone Lines to be fostered by single transmission standard
http://www.itu.int/newsroom/press/releases/1999/99-10.html

[6] Broadband Portfolio
http://www.isn.bt.com/SP/broadband/index.htm