Ofcom Sets Guidance to Improve Resilience of UK Broadband and Mobile Networks UPDATE

The UK telecoms and media regulator, Ofcom, has today set out how they intend to update their guidance on network resilience in order to give broadband ISPs, mobile operators and other digital network providers greater clarity on how they can “reduce the risk of network outages“. But proposals to improve battery backup on mobile networks will come later.

Communications providers in the UK currently have a legal obligation to identify, prepare for and reduce the risk of anything that compromises the availability, performance or functionality of their networks. But such networks are highly complex and outages can still occur, with Ofcom warning that the consequences of these are “likely to become more severe as society becomes increasingly dependent on them to function.”

In response, the regulator plans to update their existing resilience guidance to provide greater clarity on how providers of public electronic communications networks and services (PECN and PECS) can comply with their security duties under a new framework for security and resilience, which originally came into force in October 2022.

Network providers are now expected to have regard to the New Network and Service Resilience Guidance when considering their resilience-related security duties. The hope is that this may reduce the chances of serious and protracted network outages occurring (e.g. last year’s BT outage of 999 services) or make them quicker to resolve. But modern networks are complex beasts that can fail due to all sorts of reasons (it’s often the ones you don’t foresee or expect that bite the hardest).

What Ofcom have decided – in brief

We are introducing an updated version of our resilience guidance for providers of PECN/S, which sets out measures we expect them to take in relation to the resilience of their networks and services as part of their security duties imposed by and under s105A-D of the Communications Act 2003.

These measures include:

• ensuring that networks are designed to avoid or reduce single points of failure;

• ensuring that key infrastructure points have automatic failover functionality built in so that when equipment fails, network traffic is immediately diverted to another device or site that can maintain end user connectivity;

• setting out the processes, tools, and training that should be considered to support the requirements on resilience.

The issue of power backup was also considered, although for now Ofcom has only chosen to recommend that electrical power provision at each “core site” should include the following: “Battery backup and fuel-powered electricity generators. These sites are expected to be able to survive power loss for a minimum of 5 days, with permanent electricity generators on site which can be refuelled while in operation.”

The regulator had also considered the potential for requiring a 4-hour power backup in active cabinets on fixed line broadband networks (some operators already target 3-4 hours), but the final guidance noted significant concerns over the “nature and scale of costs needed to retrospectively upgrade active street cabinets.”

Ofcom Statement on Power Backup (Active Cabinets)

Assessing the capability of existing networks to meet the proposed 4-hour minimum requirement may be challenging and may vary significantly between providers. This uncertainty extends to the potential cost implications for providers of retrospectively upgrading their active cabinets to achieve this specific target. Based on the evidence now available, we cannot be confident that including such a specific measure, a minimum 4-hour backup power supply that extends to all existing powered active components in street cabinets, would be a proportionate measure within the guidance.

However, the final guidance does still include a soft recommendation, rather than a hard requirement: “Based on the factors above, we would consider power backup of approximately four hours to be good practice for active fixed access equipment in cabinets at the point of installation. In areas that suffer longer power outages more frequently, we would expect CPs to increase the duration of power backup as appropriate.”

The original consultation on all of this was also accompanied by a separate Call for Input (CFI) on the potential for improving power backup for mobile radio access networks (RAN), such as at the mast sites operated by Three UK, EE, Vodafone and O2. But we recently reported on how many mobile operators had balked at the costs of deploying national battery backup (here).

For example, their CFI asked questions about the feasibility of mobile operators installing a minimum 1 hour of battery backup on RAN sites. But Ofcom’s own illustrative example suggested that to install this on RAN sites, where power backup is likely to be feasible, could cost in the region of £0.9 – £1.8bn (this would end up being passed on to consumers as higher prices). Due to this, the regulator didn’t consider it “proportionate” to include such a measure in their future guidance “at this stage“, but they did seem to be hinting at a move in that direction.

Ofcom’s Response to the CFI (Battery Backup)

While the feedback showed strong interest in mobile resilience, some highlighted the need for a broader approach to power backup beyond the telecoms sector. Additionally, responses offered valuable insights into potential harms from power outages, such as the effect on emergency services and communication difficulties, particularly in rural areas where communities could be more vulnerable to the impacts of outages.

Over the coming months, we will further analyse the information gathered to determine if additional resilience measures are needed for the mobile RAN. This analysis will consider a range of solutions, rather than a one-size-fits-all approach, and we plan to work with government and industry to identify the most suitable way forward.

Suffice to say that we’ll have to wait a bit longer before Ofcom decides on its position with respect to battery backup at mobile sites, although they’ve already largely ruled out imposing a strict time requirement. The expectation we have is that the regulator will end up taking a more targeted and mixed-solutions approach (e.g. a focus on rural sites), which may also need support from other sectors (e.g. energy) in order to be effective.

UPDATE 9th Sept 2024

We’ve had a comment from fibre network operator Zayo Europe.

Michael Katz, VP for Product & Technology at Zayo Europe, said:

“Network resiliency has become mandatory rather than a luxury, and Ofcom’s updated guidance is welcome. But building resilient networks is vastly easier said than done. Accurate network records are a major impediment to this, and many network operators still don’t have a good understanding of their network assets. This lack of transparency causes delays in network planning and delivery as well as increased cost and uncertainty. It also makes it near impossible for alternative telecom service providers to accurately plan network resiliency.

At Zayo Europe, we share network KMZ files with our telecom service provider customers, so they know precisely where their fibre runs. We offer multiple exit points from the UK to both Europe and the US, including direct, long haul and deep subsea routes that, together, provide the diversity our customers need. As a result of this culture of excellence, our network availability is at 99.992%.”