{"id":19230,"date":"2019-09-16T00:01:39","date_gmt":"2019-09-15T23:01:39","guid":{"rendered":"https:\/\/www.ispreview.co.uk\/?p=19230"},"modified":"2024-02-23T15:27:35","modified_gmt":"2024-02-23T15:27:35","slug":"isp-association-on-the-risks-of-brexit-doh-and-uk-full-fibre-targets","status":"publish","type":"post","link":"https:\/\/www.ispreview.co.uk\/index.php\/2019\/09\/isp-association-on-the-risks-of-brexit-doh-and-uk-full-fibre-targets.html","title":{"rendered":"ISP Association on the Risks of Brexit, DoH and UK Full Fibre Targets"},"content":{"rendered":"

Andrew Glover, Chair of the UK ISPA<\/a>, has told ISPreview in a new interview that a no-deal Brexit could harm both the industry’s supply chain and access to a skilled workforce. Glover also warns that DNS over HTTPS (DoH) raises a “host of security concerns<\/em>” and says “considerable regulatory change<\/em>” is needed to hit full fibre targets.<\/p>\n

The Internet Service Providers Association (ISPA<\/a>), which was first formed all the way back in 1994, is the industry’s main trade association for providers of broadband, mobile, web hosting and other internet services in the United Kingdom. As part of that it not only promotes constructive collaboration between some 200+ members but also holds them to a code of practice and engages with Government and Ofcom<\/a> to help shape future policy.<\/p>\n

Andrew Glover is the current Chair of the ISPA<\/a> and was also instrumental in founding both the EuroISPA<\/strong> and the Internet Watch Foundation<\/a><\/strong> (IWF). On top of that he runs three smaller ISPs – Bridge Fibre<\/a>, Air Broadband<\/a> and Connect Fibre<\/a> – so has plenty of hands-on experience of both business and residential delivery, as well as infrastructure building.<\/p>\n

Suffice to say that we were keen to get Andrew’s opinions on some of the industry’s most pressing challenges and right at the top of our list was everybody’s favourite topic – Brexit<\/strong>. On this Andrew doesn’t mince his words and warns that a no-deal outcome would be a problem for the industry, not least in terms of “maintaining access to a skilled workforce and the impact on supply chains<\/em>.”<\/p>\n

“If Boris Johnson wants to live up to his commitment of rolling out full-fibre broadband nationwide by 2025, then a no-deal Brexit will inevitably make this harder<\/em>,” said Andrew. Speaking of full fibre (FTTP<\/a>), Andrew added that the current targets cannot be delivered by the industry alone and require the Government’s “full commitment … [and] considerable regulatory change, to wayleave legislation, fibre taxes and planning laws<\/em>” etc.<\/p>\n

However Brexit isn’t the only contentious area for the ISPA to be dealing with and lately one of their most controversial stances has been toward the rising adoption of DNS-over-HTTPS<\/strong> (DoH), which is a technology that encrypts DNS requests (i.e. turning IP addresses into human readable domain names like ISPreview.co.uk and back again).<\/p>\n

Many people across the internet see DoH as a way of reducing their ISPs (and Governments) ability to snoop on and censor (filter) their online activity. On the flip side third-party DoH solutions can also break other systems deployed by ISPs. Suffice to say that the ISPA’s initial decision to label Mozilla an “Internet Villain<\/em>” for their pro-DoH stance was negatively received by all except a fair few ISPs and politicians (here<\/a>).<\/p>\n

Nevertheless Andrew remains unapologetic. “[The] privacy improvements offered by DoH are often overstated and the protocol presents a whole host of security concerns<\/em>,” said Andrew. “The UK Internet industry upholds high standards of safety and security and DoH must not subvert this … ISPA are adamant that DoH must not be introduced by default<\/em>.”<\/p>\n

The full interview covers various other subjects and adds more detail to the above topics. See below.<\/p>\n

The Interview<\/span><\/strong><\/h3>\n

1. I\u2019m just going to jump right in at the deep end here and ask, in your understanding, what sort of measures or changes have ISPs had to make as part of preparations for an as yet uncertain agreement around Brexit? In keeping with that, would \u201cno deal\u201d be a bad outcome from the perspective of ISPs?<\/strong><\/p>\n

ANSWER:<\/u><\/p>\n

Our biggest concerns regarding a no-deal Brexit have always been about maintaining access to a skilled workforce and the impact on supply chains. The Government\u2019s commitment to maintain the rights of EU nationals in the UK even in the event of no-deal are welcomed. But in reality no one really knows what a no-deal Brexit will look like, and it could potentially disrupt this agreement and cause a huge amount of uncertainty.<\/p>\n

We want to make sure that there is clarity from Government that our members will continue to have access to high-skilled workers from the EU, and that the rights of existing EU workers in the UK are protected. In addition, there is the potential that a no-deal Brexit which is damaging to the UK economy means that there will be less public funding to commit to big technological infrastructure projects.<\/p>\n

If Boris Johnson wants to live up to his commitment of rolling out full-fibre broadband nationwide by 2025, then a no-deal Brexit will inevitably make this harder.<\/p><\/blockquote>\n

2. Consumer internet provision is a very low margins business and lately we\u2019ve been getting the impression that smaller ISPs are finding it increasingly difficult (i.e. cost and technical challenge) to adapt to some of Ofcom<\/a>\u2019s new regulations (e.g. the new system of automatic compensation for broadband faults\/delays and the latest broadband speed code of practice).<\/strong><\/p>\n

As a result very few smaller providers have joined the regulator\u2019s voluntary schemes. Are you aware of any concerns around those systems from smaller providers and, if so, what do you think needs to change in order to bring them on-board?<\/strong><\/p>\n

ANSWER:<\/u><\/p>\n

ISPA has a large and broad membership and we see ourselves as having an important role in representing the interests of smaller ISPs when talking to policymakers and regulators. We help smaller members understand compliance requirements by providing initial information and guidance on certain areas but keeping abreast of the increasing demands from Government and regulators is a challenge.<\/p>\n

We have long called for a proportionate approach to enforcement and this has led us to the situation today where some rules and regulations tend not to fall on smaller ISPs, this includes data retention obligations and age verification blocking.<\/p>\n

Smaller ISPs can struggle to adopt some voluntary or regulatory initiatives as you highlight, with some of the biggest challenges being cost (such as speeds code of practice) and resources. We are working on \u201cbest practice\u201d guides in a number of areas that should enable our members to aspire to join these voluntary schemes.<\/p><\/blockquote>\n

3. At present it\u2019s often still a slow and tricky process for people to switch their telephone number away from a fixed line phone service and on to a VoIP \/ SIP platform. Indeed sometimes doing this can even result in an active broadband line being ceased.<\/strong><\/p>\n

Going forward the rise in full fibre and broadband-only services is likely to drive a more aggressive shift away from traditional phone services. We\u2019ve heard that Ofcom<\/a>, the OTA and ISPs are working to come up with a better solution.<\/strong><\/p>\n

Can you tell us how much progress has been made on this and how long we might have to wait before it\u2019s ready?<\/strong><\/p>\n

ANSWER:<\/u><\/p>\n

We are still in the early stages of this process. People from across the industry have recognised that it will be important to solve this now as we need to make switching across infrastructure as easy possible. The upcoming European Electronic Communications somewhat sets a deadline for this but the complexities of getting switching right shouldn\u2019t be underestimated.<\/p><\/blockquote>\n

4. The recently approved and highly controversial new EU Copyright Directive, which was supported by the UK Government, looks set to bring about a worrying culture of automated internet content filtering and restrictions upon the sharing of news.<\/strong><\/p>\n

Despite Brexit it looks likely that this or a similar form of the same policy may eventually find its way into UK law. If that happens then what position will the ISPA be taking and how should the UK Gov approach adoption of the arguably more controversial elements?<\/strong><\/p>\n

ANSWER:<\/u><\/p>\n

Ultimately, UK providers need to comply with UK laws. That doesn\u2019t mean that ISPA is in favour of extending blocking and filtering regimes, but we do need to recognise that the UK Parliament and Government have set the UK on a path that is somewhat different to some other Western Democracies.<\/p>\n

We are not the only country going down that route and Germany, for example, has a similar discussion, and we are actively trying to make any attempts to block or filter the internet as proportionate as possible, not just for our members but crucially internet users.<\/p>\n

As a minimum, we believe that any such process should be standardised and be founded on Parliamentary approval or a court order. Our members don\u2019t want to be judge and jury and having an independent authority would help to ensure new blocking regimes would be proportionate, subject to legal requirements, follow due process and would avoid situations where ISPs are asked to block websites on a voluntary basis.<\/p><\/blockquote>\n

Flick over to page 2 for more..<\/p>\n

<\/p>\n

5. Increasingly politicians appear to be introducing measures that aren\u2019t particularly workable and may potentially even be damaging to how people normally use or interact with the internet \/ online content (e.g. the often technically unworkable aspects of GDPR\u2019s cookie policy, Article 13 [now 17] in the EU Copyright Directive and Age Verification \/ blocking for adult websites).<\/strong><\/p>\n

We get the sense from these that politicians often don\u2019t understand how such networks and technologies work, thus failing to comprehend the full ramifications of their changes. We similarly get the sense that they aren\u2019t listening or adapting enough to what the industry has to say on such issues.<\/strong><\/p>\n

Does the ISPA feel as if they\u2019re being heard and concerns acted upon when raised, or do you think there is indeed a growing culture of wilful ignorance?<\/strong><\/p>\n

ANSWER:<\/u><\/p>\n

In some ways there is a slight inevitably about this \u2013 as the Internet and technology became mainstream, politicians and others will look to regulate in what they see is in the interests of the public. Every few years witnesses a new approach to internet regulation and the most recent is the Online Harms White Paper that is set to establish a regulator for online harms.<\/p>\n

The White Paper touches on a number of the challenges around internet regulation, such as the limitations on blocking and filtering, enforcement and jurisdiction and what constitutes a harm. Any changes to policy in this area should be targeted and specific to address a clear problem. The delay in implementing age verification shows the challenges in introducing new policy.<\/p>\n

Politicians are only likely to continue to seek to regulate more so it\u2019s important for industry and others to actively engage in these discussions to make for more informed and realistic policy. This is something ISPA regularly does and will continue to do.<\/p>\n

It would be great to see politicians improve their understanding of the Internet and technology, but equally it needs industry and the technical community to improve how it understands policymakers\u2019 concerns and intentions. As such we offer to meet with MPs, government and regulators on a regular basis and as early in the process as possible such that we can provide background information to help inform their thoughts before it gets to policy \u2013 however, the culture of sound bites and knee-jerk reactions are not a new phenomenon in politics.<\/p><\/blockquote>\n

6. You touched above on the new Online Harms White Paper, which appears to mark a significant shift toward a much more censored internet, where everything from fake news to hate speech and conspiracy theories could, at an extreme, end up being either removed at source or blocked by a broadband ISP.<\/strong><\/p>\n

The rules will focus upon major social networks (Facebook, Twitter etc.) but could also target smaller file-hosting sites, online forums, messaging services and even internet search engines. Smaller sites may struggle to implement effective filtering due to cost and limited human moderation resources (e.g. individual blogs are run by people who simply aren\u2019t awake 24\/7 to monitor such things).<\/strong><\/p>\n

One difficulty here is that there can be different interpretations of what is or is not \u201cfake news\u201d and some of the other content category definitions are similarly ambiguous. Suffice to say, many fear that in the race to protect internet users and children from harm we might ultimately sacrifice freedom of speech and expression. What are your thoughts on the recent proposals?<\/strong><\/p>\n

ANSWER:<\/u><\/p>\n

UK ISPs have played a prominent role in supporting the online safety agenda for many years and acknowledge the importance of the Government\u2019s ambition to make the UK the safest place to be online which underpins the Online Harms White Paper. There are, however, some areas of the White Paper that we have concerns about as they are currently expressed.<\/p>\n

You mention the gulf in the resources of large social networks and small websites \u2013 this reality must inform the online harms regime. In our response to the consultation, we consistently emphasised the importance of proportionality, both in terms of scope and enforcement requests.<\/p>\n

The UK Internet industry has great breadth and diversity and we suggested that services and business models where there is no, or very limited, associated harm to users should not be included in the scope. Furthermore, the size of companies must be taken into consideration to ensure that the regulatory burden is not too great for smaller businesses and start-ups. It is vital that this regulation does not undermine the UK\u2019s position as a world leading digital economy and does not deter innovation and investment.<\/p>\n

You are right to highlight the ambiguity of language used to describe harms in the White Paper and the dangers this poses to freedom of speech. The Government must clearly define the concept of \u2018harm\u2019 used in the regime and it should be founded on clear, transparent and evidence-based principles.<\/p>\n

Similar transparency must be applied to the process for deciding which harms are in scope and such decisions should be subject to consultation. Here the importance of proportionality comes to the fore again \u2013 it is vital that the response to different kinds of harm is proportionate, consistent and targeted. The whole regime must be underpinned by a robust system of checks and balances, including a mechanism for appeals against the regulator, to uphold freedom of speech and expression.<\/p><\/blockquote>\n

7. In keeping with the above, Government politicians are known to be concerned about the future adoption of DNS over HTTPs (DoH) technology. At present ISPs usually control their own Domain Name Systems (DNS), but the new encrypted DoH solution can be managed by a third-party (e.g. Google\u2019s Chrome website browser) and they may in the future enable it by default.<\/strong><\/p>\n

Politicians are concerned that DoH may hamper their censorship plans and some ISPs are also worried that it could create more problems for their service, such as by hindering the operation of certain features. On the other hand DoH is fundamentally a security and privacy improvement for consumers. What is your perspective on this debate?<\/strong><\/p>\n

ANSWER:<\/u><\/p>\n

ISPA are widely supportive of measures to improve privacy and security; however, we would caution that the privacy improvements offered by DoH are often overstated and the protocol presents a whole host of security concerns. Beyond this, and the negative impact on user experience that you mention, the introduction of DoH raises concerns about data protection, user choice and consent, online safety and competition.<\/p>\n

ISPA are adamant that DoH must not be introduced by default. We welcome recent indications from the major browsers that they do not plan to introduce the protocol by default in the UK; however, we would like to see this commitment formally expressed to UK stakeholders. Furthermore, any future implementation of DoH in the UK must be carried out in a responsible manner, being mindful of UK Internet norms and the complexities of user relationship and trust models that are in play.<\/p>\n

The UK Internet industry upholds high standards of safety and security and DoH must not subvert this. Going forward, collaboration and consultation with the UK internet industry, third sector groups and policymakers will be vital.<\/p><\/blockquote>\n

NOTE:<\/strong> Since conducting this interview Mozilla has confirmed they will adopt DoH by default in Firefox (here<\/a>).<\/div>\n

8. The Government wants to see nationwide coverage of \u201cfull fibre\u201d (FTTP<\/a>) broadband ISP networks by 2033 and in order to do that they\u2019ve committed nearly \u00a31bn to help foster such networks, such as through targeted investment schemes and vouchers. Do you think this is the right approach to achieve such an aim and, if not, what should they be doing differently?<\/strong><\/p>\n

NOTE:<\/strong> This interview was conducted before Boris Johnson became Prime Minister, which means it uses the 2033 full fibre for all target instead of the new 2025 one.<\/div>\n

ANSWER:<\/u><\/p>\n

We are keen to deliver on the Government\u2019s ambitions for full fibre coverage, but these targets cannot be delivered overnight by the industry alone. The Government\u2019s full commitment is needed to oversee considerable regulatory change, to wayleave legislation, fibre taxes and planning laws to name but a few.<\/p>\n

Without the crucial removal of these barriers to sit alongside the very welcome funding commitments, the UK will not be able to reach full fibre coverage by 2033. It is really encouraging to see the growth in new network builders and ISPs building and rolling out full fibre services, this shows there is a healthy market delivering for consumers and businesses, although everyone recognises that further funding was also be required if we are to reach the whole of the country.<\/p><\/blockquote>\n

9. As part of the aforementioned effort the UK Government has already introduced a 5 year holiday on business rates for new fibre optic lines (effective since April 2017), although Scotland has just introduced a 10 years relief for the same purpose.<\/strong><\/p>\n

At the same time we note that the payback period for FTTP<\/a> networks can be extremely lengthy, often extending to 10-15 years. Do you think the UK Government should also extend their relief from 5 years to 10 or possibly more?<\/strong><\/p>\n

ANSWER:<\/u><\/p>\n

The business rates relief on fibre infrastructure has been welcomed by the industry, but it is well established that these infrastructure projects are planned with timelines of 15-20 years to recoup the investment made. This means that a five year relief window can only have a very limited effect, and we have been pushing for clarity well ahead of the 2022 ending date for relief.<\/p>\n

The FTIR made the Government\u2019s fibre ambitions clear, and a true sign of their commitment to the \u2018full-fibre future\u2019 would be to remove business rates from fibre infrastructure indefinitely. This would give the industry the certainty they need to build effective business cases and roll out fibre faster and further to the communities that desperately need it. The whole area of business rates needs to be reviewed as they are no longer fit for purpose in the digital age.<\/p><\/blockquote>\n

10. Openreach<\/a> and Ofcom have both recently launched consultations on their future approach to switching off old copper networks as part of a phased move toward full fibre FTTP infrastructure. What sort of challenges do you see this as creating in the future and how do you think it should be handled?<\/strong><\/p>\n

ANSWER:<\/u><\/p>\n

The switch off of legacy infrastructure will always be an important and nuanced issue as the UK moves away from copper infrastructure to higher capacity networks. There will undoubtedly be challenges given the number and range of consumers impacted, many of whom may be vulnerable, and it is particularly crucial that all parties can work together constructively to bring this about in the smoothest possible manner.<\/p><\/blockquote>\n

We’d just like to take a moment to thank Andrew for engaging with us over these topics. Earlier this year he also wrote a Guest Editorial for ISPreview.co.uk, which our visitors might also like to read (here<\/a>).<\/p>\n","protected":false},"excerpt":{"rendered":"

Andrew Glover, Chair of the UK ISPA, has told ISPreview in a new interview that a no-deal Brexit could harm both the industry’s supply chain and access to a skilled workforce. Glover also warns that DNS over HTTPS (DoH) raises a “host of security concerns” and says “considerable regulatory change” is needed to hit full […]<\/p>\n","protected":false},"author":1,"featured_media":21950,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"ngg_post_thumbnail":0,"footnotes":""},"categories":[2716],"tags":[473,65,56,109,58,38,479],"class_list":["post-19230","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-interviews","tag-censorship","tag-ftth","tag-fttp","tag-internet-privacy","tag-ispa","tag-politics","tag-security"],"share_on_mastodon":{"url":"","error":""},"yoast_head":"\nISP Association on the Risks of Brexit, DoH and UK Full Fibre Targets - ISPreview UK<\/title>\n<meta name=\"description\" content=\"Andrew Glover, Chair of the UK ISPA, has told ISPreview in a new interview that a no-deal Brexit could harm both the industry's supply chain and access to\" \/>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.ispreview.co.uk\/index.php\/2019\/09\/isp-association-on-the-risks-of-brexit-doh-and-uk-full-fibre-targets.html\" \/>\n<link rel=\"next\" href=\"https:\/\/www.ispreview.co.uk\/index.php\/2019\/09\/isp-association-on-the-risks-of-brexit-doh-and-uk-full-fibre-targets.html\/2\" \/>\n<meta property=\"og:locale\" content=\"en_GB\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"ISP Association on the Risks of Brexit, DoH and UK Full Fibre Targets - 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