FCS response to DTIS call for input on Private Telecommunications Networks.

The FCS represents companies which provide professional communications solutions to business users. Our members deliver telecommunications services via mobile and fixed line telephony networks, broadband, satellite, wi-fi and business radio. Our members’ customers range from SMEs, home-workers and micro-businesses up to the very largest private enterprises and public sector users. FCS is the largest trade organisation in the professional communications arena, representing the interests of circa 350 businesses which supply B2B services nationwide.

The FCS has promoted the DTIS call for input on Private Telecommunications Networks to our members and encouraged them to reply individually.  Our members are diverse and provide private networks to a wide range of customers, including Government departments, emergency services, utilities and a wide range of private companies. The private telecommunications and

radiocommunications networks they provide are equally diverse, so it is not appropriate for the FCS to reply to the detailed questions in this Call for Input. However, the FCS does have a number of general points that it would like to make and we would be very happy to discuss any of our points further with the DTIS, if that would be helpful.

1. The market for Private Telecommunications Network is vibrant. Over the past years the FCS has seen many new entrants in the market, providing innovation and competition which is so important to drive a high-tech growth economy.  It is incredibly important that competition is allowed to flourish, and any Government intervention needs to ensure that it facilitates rather than hinders such competition. 

2. The marketplace is seeing increasing convergence and this means that traditional lines between telecommunications networks and radio networks can be blurred. It is very important to understand the marketplace and as the FCS represent members across the industry, we are in a good position to provide insight, if this would be useful to the DTIS.

3. The development of open, standards-based security requirements, is to be encouraged. It is important that Communications Providers (CPs) are able to put together the building blocks of private networks, whether it be handsets, spectrum or ethernet/IP services, confident in the knowledge that they conform to the required rigorous standards. Please note that private systems are often used to support critical infrastructure, having operations that are ‘Mission-Critical’ and even ‘Safety-Related’.  In consequence, the desired level of resilience of the overall system is a matter of priority to the operators.  As a result, the entire design and implementation ethos may well be completely different from that of a more typical network.

4. Additionally, there must be fair access to network building blocks. The success of open equivalent access to the fixed line products and services provided by Openreach has been shown to have stimulated the marketplace and led to innovation and growth.  Such access to other elements of Private Networks, such as 5G technology, will be equally important to FCS members and must be addressed.

5. The impact on competition, and therefore the development of vibrant markets, can be seen in the recent Government policy position on radio spectrum. We note that a radio spectrum policy solution which passed the control of significant amounts of radio spectrum, to a single commercial organisation by government action and at the same time removed all possibility of achieving any form of competition, creating a coercive monopoly, to be an unusual step in the UK.

6. It is very important that Government action in this area is joined up. The DCMS recently published a Code of Practice for Public Telecommunications Networks, Ofcom is active in this space, and now the DTIS is also involved.  The FCS welcomes the focus given to network security and believes it is important that all Government Departments are involved and a single, cohesive policy is produced.

7. Whilst rigorous security standards are to be encouraged it is important that this does not unnecessarily put-up barriers to entry that would disproportionately affect smaller, niche providers. Ensuring that standards are focused on wholesale providers, would help to ensure that the market continues to develop positively.

8. Security is increasingly important to customers and our members have reported that security requirements feature significantly in bids and tenders for Private Networks. It is therefore an important area for Government to review.

9. Our members have also emphasised that good security usually comes down to human beings and it is important the human element is not lost in any review of technology standards. The FCS would encourage the DTIS to consider how it can promote good data and network security behaviours. 

The FCS would be very happy to facilitate sessions with some of our knowledgeable members if it would help the DTIS to develop its thinking. It will be particularly important for the DTIS to consider the needs and views of smaller Communication Providers who often provide bespoke, innovative solutions and whose requirements can often be overlooked. 

The FCS are holding an industry event, FCS COMEX 2023, on the 16 and 17 October in the Telford International Centre, which would be a very good opportunity for the DTIS to speak to our members in an informal setting and a chance to understand some of the key issues facing both them and the industry. The event is free, so please let me know if you or any of your colleagues would like to attend and I will arrange passes.  

13 September 2023