Cityfibre on the Challenges of Copper to Full Fibre Migration

Cityfibre has provided ISPreview with an update on their on-going ‘Copper to fibre switchover‘ consultation, which considers the question of retiring Openreach’s (BT) old copper telephone lines in favour of “full fibre” (FTTP) broadband, albeit from the perspective of an alternative network provider.

At present most of the focus in the planning for copper switch-off and migration has tended to centre around Openreach’s national network, which is hardly surprising because they control most of the UK’s legacy copper infrastructure and are expected to have the single largest Fibre-to-the-Premises (FTTP) network by around 2025 (15 million premises). Related trials are already underway (here and here), such as in Salisbury.

However alternative network (AltNet) providers like Cityfibre (aiming to cover 8 million premises) are keen to remind the Government and Ofcom, as well as perhaps consumers too, that Openreach is not the only full fibre game in town. Indeed in some parts of the country there will be locations where Cityfibre is the only choice for FTTP, while in others it could be the case that several FTTP providers may operate in the same area (overbuild).

Suffice to say that Cityfibre’s consultation, which began last November (here), is centred around engaging the wider industry over this issue and ensuring that any future switch-over is pro-competitive, “so processes are in place to support easy switching between networks.” Ofcom’s on-going work to integrate the new European Electronic Communications Code (EECC) also touches on this area (here).

Cityfibre thus aims to give ISPs of all sizes an opportunity to stipulate what provisions would be required to support all legacy services on the new network(s), what the process should be for mass migration of customers, and what steps are needed to ensure easy and hassle-free switching for consumers.

Full fibre or nothing?

As part of this consultation ISPreview has engaged with Cityfibre’s Director of Regulatory Affairs, Alex Blowers, to query the operator’s approach and some of the more challenging aspects of its consultation. For example, the Government’s recent switch to adopt “gigabit-capable” language has opened this debate up because we now have to look at more than just full fibre networks, with Virgin Media’s cable (HFC) and possibly even fixed wireless or 5G networks having a role to play too.

“As for HFC upgrades, these may be good news for Virgin Media’s existing customers, but as Virgin Media operates a closed network, they are not relevant to the central challenge of migrating the existing copper customers of ISPs onto a ‘gigabit capable’ network,” said Alex.

We suspect that Virgin may choose to disagree with the above statement, not least since they’ll be bringing 1Gbps+ speeds across their entire network by late 2021 (15 million premises). Likewise their network may not remain closed for long, particularly if the predicted Liberty Networks change goes ahead and opens it up to wholesale (here and here).

Separately Cityfibre suggests “there is no reason why, in the context of legal separation of BT Group and Openreach, BT itself should not set up to consume other full fibre networks,” which is an interesting viewpoint. BT Group ultimately still funds Openreach and their roll-out of FTTP, thus the idea that BT’s consumer ISP would hop on to harness Cityfibre’s platform seems flaky but not impossible (they never did that with copper LLU either).

However, despite a few unusual viewpoints, Cityfibre’s consultation is important and asks some of the right questions. Indeed these are questions that other altnets should also be considering. Clearly, city-wide full fibre rollouts are not yet reaching completion at scale but it won’t be far off at the rate the industry is now moving.

The operator’s consultation is due to end on 6th March 2020, although it may yet be extended and after that a final report is expected to follow within another couple of months. In the meantime you can read our brief Q&A with Alex below, which touches on just a few of the often tricky issues that have been raised.

Q&A with Alex Blowers (Cityfibre’s copper switchover)

1. The consultation talks a lot about the Government’s plans to achieve UK-wide full fibre coverage by 2025, but sadly this changed last year and over a month before the consultation itself was published.

The Government now talks about ensuring that every home can access “gigabit-capable” broadband by 2025, which they suggest includes full fibre, hybrid fibre coax and 5G / fixed wireless etc. As a result quite a few points in the consultation now give and exist in the wrong context.

Why wasn’t this change included into the consultation before publication and what impact does it have on Cityfibre now that the focus is not purely on full fibre (e.g. Virgin Media, mobile operators and others all have a role)?

ANSWER:

Our focus is clearly on the full fibre network that we are building. We think this is the superior, future-proofed technology to HFC and FWA (see the study we commissioned from Plum recently). We understand the Government has softened the target language to provide more flexibility in delivering an ambitious target by 2025.

FWA may have a role to play in rural, but cost-effective technology solutions are currently unproven. As for HFC upgrades, these may be good news for Virgin Media’s existing customers, but as Virgin Media operates a closed network, they are not relevant to the central challenge of migrating the existing copper customers of ISPs onto a ‘gigabit capable’ network. As far as we are aware, no-one is suggesting that customers will migrate from copper to anything other than full fibre where it exists.

We also know, because it has already been discussed at the regular DCMS CEO roundtable, that a plan for copper to fibre switchover is seen by the Government as an important part of the overall plan.

So, our view is that the core challenge is unchanged – how to plan and manage the migration of existing copper customers onto full fibre networks, in line with a challenging 2025 target. The focus to date has been unduly oriented towards Openreach’s own business decision-making. Self-evidently, with CF now planning to build up to 8 million FTTP connections, we are necessarily a part of this debate.

2. The consultation warns that, in areas where two full fibre networks are present, it could undermine competition because “Openreach would be free to define the process as entirely a matter of switching from copper to its own full fibre, at a time of its choosing.”

Absolutely it’s right that Ofcom should consider alternative full fibre networks in any related regulation, although there is a danger here that we end up focusing too much on the network supplier and forget about the end ISP (consumer contracts are with the ISP, not the wholesale network supplier). Long contract terms can also restrict switching away from ISPs.

Ultimately consumers take their service from an ISP and that ISP chooses what networks to use or not, which will of course govern how they respond to the migration challenge. In that sense don’t Cityfibre and other alternative networks have to play their part by ensuring and helping more ISPs to support their network? It seems like this, more than anything else (except availability), may impact network choice. The choice of network cannot realistically be forced on to ISPs.

ANSWER:

We don’t disagree: the purpose of our consultation is to begin a conversation with both ISPs and consumer groups. As an open access network, we want as many ISPs and their consumers on our network as possible. This includes BT’s downstream business as well. There is no reason why, in the context of legal separation of BT Group and Openreach, BT itself should not set up to consume other full fibre networks and indeed we have sent the consultation to them and encouraged them to respond.

The consultation is specifically asking:

• What products do ISPs require us to provide to replicate current service offerings on copper?
• What migration processes do you require CF to provide to switch customers to our platform? And:
• What do you need from us in terms of an ordering and provisioning process?

3. Following on from no.2 above, do you think Cityfibre could be doing more to provide support and services that might help ISPs to adopt their network, especially smaller residential players? Some ISPs tell us that it can be a prohibitively complex and costly development process to adopt a new network.

ANSWER:

We are a wholesale only open access network. We want to have as many ISPs on our network as possible. We are building a platform of sufficient scale that it is worthwhile for major ISPs to set up to consume it. Our latest plan is to build a network connecting up to 8 million premises which addresses this point.

Second, consuming our platform needs to be as easy as possible for operators already set up to consume Openreach. For that reason, we have developed an offering that makes the switch from Openreach to CityFibre as seamless as possible whilst also seeking to deliver substantial operational improvements over those available via Openreach.

We want to be easy to use for existing ISPs and for new entrants. We want this consultation to open up a dialogue with a broad range of ISPs to make sure we are doing everything we can to accommodate their requirements.

4. Following on from no.2 again, most full fibre alternative network-based ISPs have chosen not to sign-up to some of Ofcom’s voluntary codes of practice (e.g. broadband speeds, automatic compensation code etc.). Would you agree that there is an argument that says this needs to change so consumers receive the best possible protection during any switch-over, particularly if we reach the latter stage of enforced migrations further down the road?

ANSWER:

As a wholesale only operator, we don’t really have a view on how ISPs should manage their retail regulatory obligations.

5. At what point do you think a specific location / area should start the switchover process from copper and how long should it take (what sort of process do you envisage)? Openreach proposed a process for moving from copper to FTTP lines once 75% of premises in a related exchange are able to receive an “ultrafast” 100Mbps+ broadband service (target for this is 24 months after roll-out starts and copper switch-off might then occur c.3 years after / on top of that).

ANSWER:

We think the focus right now should be on making voluntary migration from copper to fibre as attractive as possible. The copper to fibre transition is at a very early stage both in terms of rollout and adoption where available. Our consultation is an attempt to drive voluntary migration in scale now, rather than design a compulsory migration scheme.

Analogous forced migrations from a legacy infrastructure (e.g. analogue to digital satellite) has generally only been implemented once the majority of the consumer base has already voluntarily migrated. This approach has two advantages: there is already widespread consumer acceptance of the need to change, and any practical or technical problems have generally been ironed out by the time there is a compulsory migration of the remainder. In the light of that previous experience, we are surprised that Openreach is proposing to begin a compulsory transfer process when it hits a build target, rather than a voluntary adoption target.

This also increases the urgency of opening up the dialogue to consider the scenario where alternative full fibre providers have hit the same indicative rollout threshold in a given area. We expect to hit the 75% rollout target which triggers Openreach’s ‘stop sell’ on copper products in at least two locations within this calendar year.

6. Openreach are expected to offer both a voice-only (VoIP) and entry-level (e.g. 40Mbps) broadband product via FTTP as part of their process. Does Cityfibre intend to do something similar with their ISP partners (can you give examples / ideas?), which may be particularly important if you intend to target the same customer base as Openreach facilitate via copper (includes vulnerable consumers with voice-only needs etc.)?

ANSWER:

Yes, this is one of the key issues on which we are looking for feedback. We are very conscious that within ISPs’ existing customer bases there will be many consumers who are currently consuming either voice only or entry-level broadband products, and we want to understand what products ISPs want in order to match their customers’ requirements.

7. Ofcom are currently looking to include FTTP services into their future all-IP migration rules / process, which may require alternative networks to adopt an agreed industry process (possibly Gaining Provider Led) like currently exists on Openreach based ISPs, as well as to also factor in how phone numbers are ported for VoIP etc.

Have you engaged or do you intend to engage much with the regulator’s / OTA’s work (AIP-MTP) on this front and what recommendations do you have for that process?

ANSWER:

We are participating directly in the GPL Switching process and observing the All-IP work.

We think that GPL should be a standard process for all intra and inter-platform switches and welcome the plan to implement the new requirements of the EECC. Our recommendations are that a ‘true GPL’ approach is adopted, rather than a hybrid, code-based approach. This will deliver the best consumer experience and a competitive level playing field.

We’d just like to thank Alex Blowers for giving us the opportunity to query some of the challenges raised by their consultation.