The Federation of Communication Services (FCS) response to the BIST consultation Digital

Connectivity: Consultation on Improving Broadband for Very Hard to Reach Properties

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 supports the Government’s aim to provide good connectivity everywhere in the UK, including Very Hard to Reach Properties (VHTRPs).  Digital connectivity is a key building block of economic growth, particularly in rural areas which often have poor connectivity. Access to connectivity which allows businesses to flourish, can help to transform rural economies, delivering a growth economy and contributing to the Government’s levelling-up agenda.  It is important that VHTRPs have access to connectivity at similar standards to the rest of the country.

The FCS also agrees that there will need to be additional specific Government intervention to reach VHTRPs. The roll-out of fibre broadband has been a UK success story driven by a combination of government and commercial funding, but without additional Government help VHTRP will remain without the Broadband they need.   

The FCS believes that it is important that any additional Government funding is focussed at the infrastructure level, with regulatory safeguards providing equality of access, encouraging retail competition.  All Communications Providers (CPs) should be made aware of VHTRP locations and be able to access funds to service them.  To ensure ongoing competition and give consumers and businesses choice, we believe that any connections provided under the VHTRP regulation should be available for switching to another provider at the end of the initial minimum contract period, where the customer wishes to do so. This should be the case irrespective of the technology. For example, if EE provides a Fixed Wireless connectivity solution it, or Openreach as its agent, should be obliged to grant wholesale access to other downstream suppliers. This will ensure that resellers and smaller providers are not prevented from competing for these customers. Access to mobile networks should be a right rather than a gift as it is today.  

The regulations should also ensure that future technologies/solutions are covered. For example, satellite technology is being developed and, if used to support VHTRPs, regulation is needed to ensure that there is fair and equal access to ensure effective competition.   

The FCS has not responded to individual questions, however, would like to make a specific comment on question 4.4 “Should the Govt set different quality parameters for residential and business consumers reliant on very hard to reach interventions.”   

The FCS believes that good broadband connectivity is vital to businesses. Small businesses are likely to be particularly hard hit in VHTR locations and appropriate interventions could have a significant economic impact. To answer this question, the FCS suggests that the Government should look at what connectivity businesses need to be able to operate effectively. As an example, Openreach provides a breakdown of the business services its current portfolio supports, and the speeds required^[1]. The FCS believes that 330 Mbps download and 50 Mbps upload is a good starting point and may provide a large proportion of business customers with the connectivity they require but this is a minimum business requirement, and the assumptions need to be constantly checked and evaluated.  This is particularly important given the PSTN switch off in 2025 and it is expected that businesses will need additional bandwidth to provide the new products that will be required.   

In practice it is hard to differentiate consumer and business lines and currently there is no standard industry definition of a business line. Industry systems and processes are not set up to differentiate lines and the FCS believes that Ofcom should be required to introduce a definition of a business line and require industry systems and processes to recognise these. Indeed, the FCS believes that Ofcom should have a duty to promote the interests of business customers in the same way it does currently for consumer customers.

FCS November 2023

[1] Broadband for business | Openreach