Wednesday, 1 July 2015

OFCOMs latest folly

Some phone numbers have had "special" charges for some time.

0845 was "local" and 0870 was "national" and this dates back to the times that local and national call charges made sense. The problem is that over time these have stayed expensive as inclusive packages and lower costs have meant that "normal" calls (01, 02, 03 numbers) are lower.

There have also been various "Premium rate" services, which OFCOM can regulate (as Communications Act says they can). These are now generally in 09 numbering.

The problem is that it is a mess. Some numbers cost as much as £6 a call, some are free, and it is not clear. Mostly 09 is expensive and 08 is not so much. People using 0845 and 0870 are being encouraged to move to 0345 and 0370 at "normal" rates.

So OFCOM have made some rules and said that the new system applicable to 084, 087, 09 (and 118) calls is that they have a service charge and an access charge. The service charge is set by the range holder, and the access charge by the telco you use to make the call.

The idea is that instead of saying "Calls charged at 50p/min from a BT landline but may be more from other operators and much more from mobile" you now get "Calls charged at 50p/min plus your telcos access charge".

Sounds sensible, until you realise many retail telcos, even BT, have an access charge of 10p/min and one charges as much as 44p/min. This access charge has to be the same over all codes (except those "inclusive" in bundles) which makes a mockery of those that are 1p/min or 5p/min, etc.

It will confuse people that services advertised as "1p/min plus your telco's access charge" are costing them 45p/min from some telcos!!!

But it is worse - how does a telco know what the service charge is. After all, no telco has contracts with every service provider (range holder) directly. So they have a contract with some carrier (maybe even BT directly) to route the calls. As a telco, how do I know what to charge for a number.

Well, OFCOM have distanced themselves from any responsibility saying we have to look at the contract we have with our carrier to find the cost of the service charge. However, they have only made this new system apply at retail to consumers, and not to our carriers. It seems our carrier does not have to do anything. To be fair, they are, mostly, doing something sensible, but OFCOM are not insisting that they do. They don't have to tell use the service charge for each number.

OFCOM suggested the BT Carrier Price List as a reference, but if I was BT I would expect OFCOM to pay me to run that database! OFCOM won't actually tell me what the service charge is for each number even though they REQUIRE that I charge calls to that number based on the service charge (and my access charge). That is MADNESS!!!

Seriously, WTF are OFCOM on?

1. No definitive list of service charges. BT CPL is already wrong and out of date.
2. Access charge means calls cost massively more than they used to for many numbers.

If, as OFCOM have said, telcos should use the contracts with their suppliers as the reference for service charges - what is to stop a telco selling all 084/087/09 at £10/min, and its customer using that as the reference for all such numbers? Not OFCOM rules for a start - heck! these rules do not apply to "business tariffs" let alone CP to CP tariffs...

We already have issues that OFCOMs right to regulate Premium Rate numbers comes from the definition in the Communications Act. We have a few 0871 numbers that were never "Premium rate" and we still provide no "service" via these, only communications (fax to email) as per their original numbering plan allocation. As such OFCOM have no legal right to regulate our use of these numbers as "Premium rate". Thankfully it is mostly academic but they really lack clue some times.

NoT - the quiet week

The new OFCOM Notice of Transfer system for broadband migrations has been going for over a week now.

This means that this week is quiet - migrations have been changed from 5 working days to 10 working days (by the regulator acting in interests of the customer, of course?!). As most migrates are on this minimum lead time, this means no migrates (in or out) completing this week.

We think it is going well from our point of view. It is a little hard to tell yet but I think we are gaining on average. This makes some sense as we were always easy to get a MAC from (and it was on-line and automated) but people dreaded calling other ISPs to get a MAC to move to us. So maybe that is good for us.

We have not yet seen a slamming on broadband - either from us, or an accusation of us slamming (e.g. one of our new customers mistyping details on our order form). I wonder when the first will be.

We have managed to make our internal systems much more orthogonal and allow nice PGP signed emails to customers for key events (the OFCOM required ones, and some not strictly required such as when migrates complete). The changes to our terms and billing system seem to have worked, with only minor transitional issues. The new early termination charges system is working as planned and saving customers money. Overall I am quite pleased with how it is going. Not that OFCOM pay us for all this work we have to do...

We have seen one person who is moving to us who has not received any notice from existing provider, and indeed, the existing provider (when questioned) says there is no migrate happening. That will be a fun one to watch.

We had a surprise - BT used to have a real issue with "pending orders" stopping any other order and importantly stopping any faults being reported. After decades of this being a pain, it seems the new NoT process has prompted BT to fix this - allowing a fault to be reported whilst a migrate is pending. The other surprise is BT stating that cancelling orders has no cost - solving the moral issue of who pays for a "Cancel Other" order as both ISPs have good reason for it not being them!

This also makes some scenarios simpler - people moving in to a new house. It was always best if they can migrate the existing service, but that meant getting the previous occupant to get a MAC and hand it over. Now, the new occupant can simply order service for the date they move in.

Saturday, 27 June 2015

Binfield Engineering Centre

At last the man-cave, or as we like to call it now: "Binfield Engineering Centre", is finally going to happen. I have quotes, at last, from a local builder, and the electrician and plumbing & heating engineer. There is a good chance we can actually get started in a couple of weeks.

I have been waiting nearly a year for this... And, of course, it comes at just the right time to clash with our tax bill, but it is going to happen!

The builder said a "change of use" needs approval from the council. They had a pre-planning application thing on their web site, which seemed quite efficient allowing uploads of drawings and pictures and so on. We'll see what happens with that.

I'll take pictures once the work actually gets started. I am actually looking forward to it.

P.S. Why "Binfield Engineering Centre"? It is apparently a thing to give your garage some grandiose title:

Friday, 26 June 2015

Do they not teach decimal numbers in school any more?

The ARIN IPv4 depletion web site shows how much IPv4 space is left for allocation in the American region.

It is a number of "/8s" left. For those that do not know, a /8 is 16,777,216 IPv4 addresses, and is the size of block allocated to each region at a time. The top level /8s ran out ages ago, and 4 of the 5 registries are no longer allocating IPv4 normally (most have policies on final allocations from remaining space). ARIN is down to the wire and shit will finally hit the fan any day now.

What I find most amusing is the explanation on that page, to explain a simple number, like 5.22 as apparently the meaning of "5.22" is not clear, well, not to Americans?

Of course, this explanation is fine, to explain a number like "5.22", and you can probably guess what the counter was when someone wrote that explanation. But reading it now, does that mean we have 0 /8s and 978% of another /8 left?

It is reminiscent of the 0.002 cent argument someone had with Verizon...


The counter shows the number of /8s remaining. The numbers after the decimal point are equivalent to a percentage (so 5.22 /8s is 5 /8s + 22% of a 6th /8).

Thursday, 25 June 2015


We have had many years now with very much the same prices for back-haul.

It is worth trying to explain to my less technical readers... One of the key things with the services we sell is connecting things. This means that you get data from one place to another. This is the crux of the whole telecommunications industry. Ultimately the costs of connecting stuff is the cost of digging up the ground and putting things in ducts. This is what allows the monopolies and major carries in countries to sell their communications services.

There are many ways the make this work, and there are some shortcuts by way of radio microwave links, and even people considering balloons and satellites. But for a long time the underlying issue is stuff in the ground.

Now, the copper in the ground is one of the key issues with broadband. There is copper from exchange to home and office and that is used for broadband (ADSL). Getting closer to the home or office by running fibre to a cabinet and then using the copper from there with VDSL (FTTC) is faster. Ultimately there are moves to get new connectivity to people's homes and offices using fibre.

But whatever the "last mile" is, whether coax, copper pairs, fibre, hybrid, radio, or what, there is also the issue of "back-haul". This is where the data goes from exchanges and similar concentration points locally to ISPs connection points and on to the Internet.

As an ISP we are in the middle - on one side we connect to peering points and transit providers that connect to "the rest of the world", and on the other we use carriers like BT and Talk Talk to connect via "back-haul" to the various local exchanges and "last mile" connections such as broadband. We join the two together.

There are costs on both sides.

When connecting to the "world", there are transit providers that buy capacity on (or run their own) transatlantic fibre links, and national fibre links in many countries. For as little as £1/Mb/s/month (that is £1 per month for a megabit per second) I can buy transit that connects to thousands of connection points around the world using national and international fibre links.

When connecting to the "UK", I am using back-haul carriers. Now, these have a simpler job in many ways, they are all on land and connecting to several hundred telephone exchanges. The "last mile" from the exchange to homes and offices I pay for separately. So this back-haul is simpler and smaller than the challenges of "transit" to the world, but the cost is anything up to 50 times that of transit! And for no good reason than "It has always been so".

The good news is that there is competition. The good thing about fibre back-haul is that you can simply change the transceivers on the end of the fibre and go from a gigabit to 10 gigabit to a terabit. It is a cost for the technology on the fibres, but the real cost is digging up the road, and that is not needed to make more and more use of the fibre links.

The good news is OFCOM are trying to get BT to open up "dark fibre" links to other operators. This is a big step as the existing way to buy from BT is by link speed. If you buy dark fibre you can choose to invest in later transceivers and get more out of it. If you buy by the gigabit than you are stuck with that.

Third parties can do this themselves if they have the fibre and can upgrade, so we really hope back-haul will finally start to come down in price.

I really hope that it will get cheaper. We are starting to see some clues to this with some carriers. We may even be able to offer new services soon. But what we really need is the major carriers like BT lowering the back-haul pricing to something a tad closer to transit. After all, transit providers link to the world, and BT link to the UK - surely BT should be cheaper!!!

NoT and 12 months term

I seriously think BT have got this wrong and it needs fixing.

BT plc t/a Openreach provide GEA links (basically what most ISPs use to provide FTTC) on a 12 month minimum term.

Firstly, this is a problem anyway - most other services whether broadband or phone line - do not have a minimum term. This may have made more sense in the start and when there was an engineer visit and modem supplier, but really starts to make no sense for wires only FTTC, and now that FTTC is the norm. So ideally BT need to drop the minimum term. However, for now we have it.

When migration of FTTC services came in there was a problem - BT would charge the old ISP for the end of the term whilst charging the new ISP for the same period of time and holding the new ISP to a new 12 month term. What was even worse is that this was done by BT plc t/a BT Wholesale. Their excuse was that BT plc t/a Openreach had this 12 month term. However a migrate from one BTW customer to another BTW customer did not involve BT plc t/a BT Wholesale restarting the term with BT plc t/a Openreach - they literally were charging two ISPs for the same service for the same time!

The eventual fix was to make a migrate not have a min term for the new ISP but the old ISP pays to end of term. It addresses one issue, but has some serious problems.

The issue here is that when two parties agree a contract and dictate something like a minimum term, it make sense for the party that breaks that term and ceases before the end of the minimum term to compensate the other party.

So, if an ISP buys a service with a 12 month term and ceases after 6 months, it makes sense to pay the supplier / carrier something, perhaps even the whole of the remaining 6 months of service.

But what if the supplier (carrier) breaks the term - and ceases the service within the 12 months. Then surely the supplier needs to compensate the ISP for that breach, at the very least not expecting the ISP to pay to term for a service that is not being provided.

Sadly BT plc t/a BT Wholesale do not agree - they think that even when they break the 12 month minimum term the ISP has to pay them for the remainder of the term!

Now, this only really happens if the service is transferred to a new ISP. But even so, it is the carrier breaking the term with the ISP and not the other way around.

Now, if BT plc t/a Openreach insist on a 12 month term, what would make sense in the case of a transfer is for the new customer to be starting a new 12 month term, and the old customer to be let off. That would mean that the carrier would not have to pay BT plc t/a Openreach when it is BT plc t/a Openreach that breaks the term, and similarly BT plc t/a BT Wholesale would not have to charge the ISP for the rest of the term when it is BT plc t/a BT Wholesale that broke the term, and ultimately the ISP would not need to charge their customer an early termination fee.

Even better would be for a migrate to carry over the remaining term and not restart the 12 months. This would ensure BT plc t/a Openreach always got 12 months rent for a VDSL port that they have installed, which is what they want.

But ultimately the best would be for BT plc t/a Openreach to just drop the minimum term on the wires only FTTC installs and then it would avoid a lot of unfair contract terms and arguments.

P.S. One carrier is being very very special, suggesting early termination means not only paying to term but also paying an extra early termination fee. That is crazy - why would you cease the service early rather than just leave it in place to end of term in that case.

Business Names Act

The Business Names Act 1985 was repealed and the various requirements included in to The Companies Act 2006. This is a tad confusing as it does not just apply to companies, but also individual sole traders and partnerships.

Basically the idea is that if someone is trading, acting as a business, then they have to actually identify themselves. It is why many shops will have a small plaque that states the company name and registered office, and why web sites and letterheads state company name and number and registered office. It applies to individuals and partners in that they have to state the name and address of the people involved on business letters and order forms and so on.

The principle is that you have to be able to identify the party with whom you are dealing relatively easily.

Unfortunately I am having trouble working out who enforces these rules!

Trading Standards said Companies House.

Companies House said yes, for rules relating to registered businesses (82-84), but not the section on individuals (1202), try the police.

Now I have had a nice chat with a Scottish policeman, who has paid a visit to Mr McGhie after I made a complaint, but who is unsure what to do. He says he has checked all the details he has, his manuals on such things, and cannot find anything that covers this. He thinks it is not a police matter, even though it is a clear criminal offence. He suggested Companies House!

In the end we have left it that he is going to ask Companies House for advice, but ultimately, surely, if there is a crime, then someone should be responsible for enforcement.

We'll see how it goes.