TOTSCO (One Touch Switching) Live

We're live for One Touch Switching, well, with a dozen (well, 13) other CPs, for on-ramp testing. Live use of OTS. This is public knowledge as we are listed by other CPs as available for OTS.

Updated:

There are, of course, issues being worked out, and daily calls to resolve them - and we are all working to try and ensure everything is sorted by the launch date (12th Sep).

I'd love to explain more, but at the risk of invoking the Streisand effect, I have now been told I cannot go in to any details on progress, even without naming the CPs that are having issues. Sorry.

Obviously customers can see the issues if using our order page to try and progress an order, and seeing the errors. It is just that I am not able to tell you about it.

Power on the line

Who ensures you can call 999 in a power cut?

This blog does not have all the answers, it has a lot of questions, opinion, and some history. I am trying to address the issue and explain some of the technical, financial, and regulatory challenges. It is not simple, and some will undoubtably have a different opinion. I hope it helps address the very understandable knee jerk responses though.

I also have personal views on 999 service moving to the 21st century, but this blog covers just power for 999 calls.

A bit of history

Telephones have been around well over 100 years now. Surprisingly the basic working of the old fashioned analogue phone still works today, but that is changing.

They way an analogue phone works happens to need a small amount of power. There needs to be a voltage (no power really) to detect you lift the receiver. There needs to be enough power to allow the microphone and earpiece to work. There needs to be a bit more power to make a bell ring. This was done using batteries at the telephone exchange.

This meant a telephone would work without the home having power. Indeed, mains power was less common and less reliable over a century ago when phones started. It is also worth remembering that consumer electronics did not exist either - these days we see DC USB power on wall sockets and are used to a small switch mode power supply working some electronic gadget - the idea of a telephone handset being powered from you home is not daft. But a century ago the very power supply itself would be complicated, to say the least, and the phone handset had no electronics anyway - it would not make any sense for a telephone handset to be power from your home mains electricity. So they were line powered, simple as that.

The telephone handset was also part of the service, even wired in, for a very long time.

Catch up to today

Today, analogue telephone lines do the same. Yes we have DTMF now, and the handset itself has electronics that do that, but a simple handset is powered by the line still. Of course we have also moved to the telephone being the customer's responsibility and not part of the service itself, something you can choose, and plug in.

It is an issue for the telcos as the electronics in a handset could expect more power than the original telephone lines were every designed to deliver and there are current limits defined as a result.

But also we have a lot more complex telephones now, even simple cordless phones, DECT base stations. phone with answering machine, PABX, and so on. These work using local mains power, and in some cases DO NOT work when no local mains power. In a lot of cases there are special work arounds - a phone system in an office will typically have at least one old school phone, and maybe a relay that switches that directly to the line when power fails. But not all consumer equipment has any means to work in a power failure.

But also, mains power is way more reliable in almost all places.

However, if you have a simple old school telephone handset somewhere in the house, you can still use it during a power cut - yay!

20th Century

For a long time it was expected that ISDN was the future. Indeed, in some countries it really did take off, and a basic ISDN2 telephone could plug in to a socket and work. My understanding is that ISDN2 was design to power a basic ISDN telephone.

I am not sure if BT did power ISDN2 sockets - I have a feeling they did not. They did a consumer ISDN2 (Home Highway) which did have an analogue phone fallback, which was good. But for anyone using ISDN2, an actual ISDN2 handset was unheard of - people used and ISDN2 card in a computer (mainly for data) or a small ISDN2 PABX which needed power to work.

ISDN30 is a large scale service, and that definitely did not power a handset. It was often using fibre. It did not have power fail working, even though 999 should work just as much for such cases as a home phone line.

Somehow BT were legally able to provide a proper telephone service on a line in such cases with no power fail backup! (Do correct me if I have that wrong).

21st Century

The problem is that times are changing, the old school telephone service (landlines) are going away. These days telephony is an over the top service, working over IP, VoIP, that is Internet Protocol. This changes things.

So how does this work in a power cut and who is responsible for it?

Broadband/Internet

A broadband/internet service never had any requirement to be 24/7 100% reliable, or to work in a power failure. OFCOM are pushing more and more for this, and even talking of power failure requirements (for at risk customers, at least). This is a change, and has a cost.

The internet itself is a large interconnected network - an ISP cannot guarantee that even Google works 24/7, that is down to Google, and even they had an outage the other day. An ISP cannot guarantee they have connectivity to some VoIP telephone service provider 100% of the time, as a lot of that connectivity is outside the ISPs control, as is the operation of the VoIP provider themselves. Yes, an ISP may also be a VoIP provider, but there is not reason to make more onerous obligations in such a case, especially as such a company could simply split its operations in two if that was the case, so assume they are separate.

The elephant in the room here is actually where and what a broadband/internet service is - it is provided at the Network Termination Point. For DSL this is the master socket. It is a clear demarkation for where service is provider.

If OFCOM insist that an ISP has to have a broadband service that works during a power failure (even if only for an hour), that is the point at which it has to work. That is no different to the landline provider providing service at the master socket.

The problem is, unlike a landline, having a service working at a master socket is not a lot of help to a consumer in a power cut. Unlike a landline telephone service, broadband service never provided power (for a router). It provides connectivity - the ability to DSL sync on the line using a modem. You need a modem, and that needs power.

Interestingly, BT are talking of battery backup for optical network termination points (ONTs), where the network termination point is an Ethernet socket. That could be useful to a customer if they have a laptop with an Ethernet port and a PPPoE stack. That would allow them internet access in a power cut. But that is an edge case. In almost all cases the consumer has a modem/router/switch/access point, and they have to power that to make it work. Just as they would have to power a DECT base station if they had one plugged in to a landline master socket.

From a regulatory point of view the whole concept of a network termination point is important, it defines where the service is provide and who is responsible each side. The ISP is simply not responsible for what is plugged in.

From a technical point of view the ISP could not sensibly power arbitrary customer equipment. Here, for my laptop to work, I have a router, and modem, and large PoE switch, and 6 access points. Powering all of those for an hour is a big undersaking, but not doing that means I don't have internet at all. I don't have a system to fall back to just a modem and one access point, but powering even one AP is a lot.

Should companies making and selling network routers, switches, and access points, have to ensure battery back up, just because they could be used to carry VoIP traffic for a 999 calls?

So yes, I suspect a service still working at the network termination point, and hence powered ONT, might happen. It happens for DSL lines, we think (BT have batteries in street cabinets, but not sure if all, or for how long). But it will be not help for 999 calls.

VoIP provider

The other side of the coin is a telephone service provider using VoIP.

The very nature of the service is that it is oIP, i.e. over IP. It depends on working internet access.

Does it make sense to expect the VoIP provider to somehow make it work when no internet access, well no, it does not.

Does it make sense for the VoIP provider to provide battery backup? Well, for what? If the provider rented a SIP handset, maybe they could power that for you, but that does not help in a power cut if nobody is powering your modem, router, and network switch, all of which are very much out of the scope of the VoIP provider. And if they are not renting a SIP handset, or providing as part of the service, even that handset is out of scope.

I VoIP provider should ensure their equipment has power backup and redundancy to allow 999 calls, but that is actually pretty easy in a data centre. Data centres have lots of power backup and redundancies.

The key issue here is that making the broadband work at home is down to a lot of equipment for which the consumer is totally responsible, and not the broadband provider, and not the VoIP provider.

Should companies making/selling SIP handset have to ensure battery backup? And would it help? Maybe if modem and switch manufactures had to do the same. But none of that sounds sensible.

Landline replacement

There is a middle ground here, a landline replacement service. This is something we see, and likely to be something BT has to do as the incumbent operator with a Universal Service Obligation.

Being a replacement it IS REASONABLE for the customer to expect it to work like the service it replaces. This means a provide providing not just internet access to a network termination point, but modem and router with an old school analogue telephone socket. The termination point for that overall service is the analogue phone socket on the router, and so it is reasonable to expect that to work in a power cut, with an old school analogue phone. So likely that will have battery backup as an option.

So, at least for now, due to jet more legacy it is likely BT will still provide this, at least for at risk customers.

Should someone else do this anyway

The big issue at hand is power cut. Would it not simply be sensible to regulate that power companies have to do something.

They already have a priority service register and already roll out generators to vulnerable users (e.g. those with powered medical equipment at home). I'm on the register as I have insulin in the fridge, which was one of the criteria - I also (now) have Tesla batteries so won't need a generator for even a very long power cut.

Having to provide a small USP enough to cover a broadband modem, and router, and SIP ATA to work a handset, is not a big step, and not a huge cost if only for at risk customers.

It makes a lot more sense that insisting telcos provide power. Just like it makes sense that power companies are not expected to provide telephony.

Maybe this is the real way forward here?

Cool feature on VoLTE

Our SIP2SIM SIMs run through ONSIM/Tango, and uses VoLTE normally. OK a lot of acronyms, I know.

The key point is we feed the call to the mobile network using SIP.

SIP allows the calling number to be set with a number (well, technically anything in the local part of the sip address) and a name.

Eg. I could have From: "Adrian" <sip:401@whatever>

On my SIP phone on my desk it shows both Adrian and 401, which is great. It has options to show one or the other or both.

I use this feature in our call routing, so, for example, if someone calls my 02000 number, I prefix the name part with a 2, and then the calling number. Similarly if someone calls my 0800 number I prefix it with 080. That way, even if all I can see is the name part, I get to see the calling number and a prefix indicating which of my numbers was originally called. In hindsight I may make the 0800 just have 8 as 080 then 0 looks even more confusing at first.

For example, this call:

As you see, the name part is 0800759...

What I have noticed is that the name part gets all the way to my mobile (iPhone).

I know this because of the missed call list.

Sadly when the call comes in, the main phone screen only shows the CLI, not the name part, which is a shame. Though on my Mac (which also shows the incoming call) it shows both.

It would be nice to have an option to show name, or both.

P.S. I cannot tinker with the actual CLI due to OFCOM rules - it has to be a plausible number. The fact the name gets through gives some hope of handling better local / internal CLI using Name field.

Broadband slamming

With One Touch Switching (OTS) only a month away, it seems a good time to talk about how it changes broadband slamming.

Summary: I believe slamming, and particularly malicious slamming, will be a lot easier.

I believe the details are correct, but will update if necessary.

What is slamming and why does it happen?

Slamming is simply changing provider on a service without the customer's permission. It dates back to US phone systems and long distance carriers being changed to get the new provider the business. For broadband, in the UK, it is changing the communications provider (CP) on a service without permission, and we see it for a few possible reasons:-

1. Traditional slamming: Basically a CP getting business. Surprisingly we do see this, mainly with door to door salesmen.
2. Mistake: This is where someone orders a service but gets their address wrong, which is easier than you might realise. We have one example of a customer who has had someone try to migrate his line four times!
3. IT consultant: Changing a clients broadband to his preferred supplier (maybe to get a kick back).
4. Accounts department: Thinking it is like gas/electric and just changing to a cheaper supplier without asking IT (not actually slamming but same problems).
5. Fraud: mainly for telephone to allow calls to be made and received on someone else's number.
6. Malicious slamming: Changing provider to cause a victim problems. 

Existing safeguards

Slamming to a new technology is not that helpful - it means a new service installed, but they can't cease the old service - so you end up with two services, and can tell the new provider to piss off if it was not you that ordered it.

For the same technology, and in this case I mean a BT circuit, it can be migrated from one CP to another CP. This is where the problems lie, but there are safeguards:

• 14 day lead time.
• BT tells existing CP.
• Existing CP has to tell customer (OFCOM rules).
• Customer can cancel by telling existing CP (who tells BT).

This works well, and there are even anti slamming services to automatically cancel a migrate (useful for that customer that has had it tried 4 times already!).

New safeguards

One Touch Switching changing things, but is not without safeguards:

• The old CP has to match, which means address and surname and possibly more details like account number. However, an exact correct address and correct surname are good enough.
• The old CP tells the customer on match, and when it starts. 

But there are other changes:

• No 14 day delay, it could be next day even, so customer has to on the ball.
• Customer can only cancel by talking to new CP. But if not them, the customer will not know account, login, password, email, or even first name used, so may have a challenge getting new CP to even talk to them.

So yes, there are some safeguards, and the most benefit I can see is handling the mistake type slamming, as the surname match should solve wrong addresses in most cases. It is also possible for a customer to tell their CP they have a new surname, which then needs to match, though can mean an engineer asking for Mr Antislamming when there is a fault :-) 

But it is worse!

One Touch Switching only applies to consumer switching. For business, a simple BT circuit migrate happens as before. But that is OK, surely? That is how it has always worked.

Well, no...

• BT are removing the 14 day lead time, so customer has to be on the ball.
• There may be little, or no, advance notice any more (not entirely clear).
• It will no longer be possible for the old CP to cancel the order.

It is not even clear if the old CP will know who the new CP is. If slamming, the customer might not know until they get a letter in the post asking for money.

No, worse than that!

You might be thinking that, at least, consumers are protected by some safeguards (One Touch Switching)?

Well,  no...

BT don't know if the end customer is a consumer, and neither does a new CP. You can order a business service on a circuit, and migrate it next day with no One Touch Switching, even if the victim is a consumer. They will just have broken internet (no idea of new router login). So consumers are not protected at all from malicious slamming - the slammer only needs the address, not even surname, as no match is done on a business order.

No, worse even than that!

Yep, it is worse. If the victim had an old fashioned landline still, broadband migration will kill the phone line. And whilst getting the broadband back may be possible, and maybe even quick, the landline won't come back. The victim has to sort a right to port on the ceased number, finding a suitable provider, and getting suitable VoIP equipment all set up.

Example

DON'T DO THIS, IT IS ILLEGAL IN MANY WAYS!

Imagine you have an annoying neighbour. If you know address and surname you can do a proper One Touch Switching migrate to a new service. It means lying to the new CP, obviously. Yes, if they are quick, they can contact new provider, and maybe get it stopped, but may be tricky if next day switching. This could kill their internet.

But you don't need to do One Touch Switching, just order a business service. Maybe from a business only provider that is not even part of One Touch Switching. You can lie to them, and provide real business details, so passing credit checks and so on, and give phoney bank details for direct debit. But the migrate could be next day, with no notice, and the victim not even knowing who the new CP is. And, as I say, losing a landline number in the process.

Now imagine it is not a neighbour, but a celebrity you don't like, or a politician. All you need is the address!

What about a restaurant that gave you bad service. Slam them, and suddenly no internet; no credit card machine; no online orders; no VoIP phones. Chaos, even if only for a day whilst they get it back.

And not so nice on the victim for costs - the old CP may be chasing early termination charges. Getting service back may also have a cost, and minimum term.

And not so nice on the CPs - who have a customer who (rightly) says it was not their fault, so won't be paying early termination charges, etc, and if the CP argues the customer goes to ADR (Alternate Dispute Resolution) which costs the CP as well.

Once again, DON'T DO THIS! I am not trying to incite anything, just giving some examples of the risks.

Trying out a service

I am posting this because there seems to be some confusion...

Consumer protection laws try to help consumers and help them avoid making silly mistakes. It is good. And one of the concerns is that, unlike a "real shop", buying on-line can be misleading, and confusing, and can even lead to regrettable impulse purchases which would not have happened in a "real shop".

So originally the Distance Selling Directive, and now The Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013, provide some protections.

Goods

For goods the idea is to try and provide something of the same level of assurance as buying in a "real shop". In a shop you can see the item, pick it up, inspect it, maybe even have a demo from the salesman. Consider it carefully and make an informed choice.

So for on-line sales you get the chance to do the same - a 14 day trial period. If you don't like it, you can send back for a refund. You don't even have to pay postage. (yes, if faulty, or not as described, you can send back anyway, and have more protections, we are talking changing your mind here).

The regulations are not quite so absolute, you get postage covered, unless you opted for a more expensive than default postage, for example. Also, if the goods are diminished in value by handling other than, well, basically, what you might expect in a shop (not quite the wording, but you get the idea), then you have to cover that.

But the idea is simple, same deal as a "real shop".

Services

This is more difficult as you cannot "send back" a service for a refund.

So, once again, the regulations try to be fair to customer and the seller.

The 14 day cooling off period is a chance to CHANGE YOUR MIND only. To address the "impulse purchase" and "buyers regret", even the "Amazon whilst drunk" syndrome. And to do so before the service is provided.

It is not a chance to try out the service and then decide you don't like it. This is important. IT IS NOT A FREE TRIAL!

There are allowances for asking for the service quickly, i.e. within the 14 days, and still changing your mind. But if the service has started to be provided, you have to pay for what has been done. When fully performed, you lose the right to cancel at all. You don't get a free trial.

A lot of people seem to think the 14 days is a free trial, or at least a cheap trial, of a service. It is not.

A good example was a comment on a recent ispreview article, here:

"It’s good for the customers…. Why give us 14 days to cancel without even trying your service, i think the OTS 1 day service will allow customers to test the network and if its bad, they can leave within 14 days:)"

This very much highlights the problem as people really think the 14 day period is to "allow customers to test the network", which is very much is not.

Ongoing services

This is the grey area. A service that is "one year of broadband" cannot be fully performed within the 14 days, but at the same time the "provision" of that service can be. Saying "fully performed" makes no sense for an ongoing service, and arguably the ongoing part is not relevant to the regulations at all - it is "performing" the service, the service of "providing the ongoing service" that has been done, and as such stops the right to cancel. That is one view, anyway.

The problem is the regulations do not use wording clearly enough to say for sure, and (as far as I know) it is not tested in court.

This means some people think the 14 days ends up being a means to "try out" a new "ongoing service" and cancel within 14 days. This is clearly not the intention of the legislation and may not be what a judge sides with. But it is a risk for a seller, because of the bad wording.

OFCOM

What is worrying is that people see OFCOMs new rules on fast service migrations as specifically allowing cancellation within the 14 days, AFTER the service has been provided (well, provisioned), because it was quick and within the 14 day period. They see it as allowing someone to try the service and then change their mind.

Given that the supplier may have costs to install and even commitments to 12 month terms for underlying circuits, it makes no sense that they only get to charge the customer for a day or two of service. That is what some customers think is fair, somehow.

That is why it needs to be crystal clear, in law, and on sign up, what exactly the customer is getting.

• A 14 day chance to change your mind BEFORE service starts.
• An option to have service sooner, LOSING the right to change your mind once provisioned.

This is what the regulations do for any other service, so should be the same for an ongoing service like broadband. They may do, depending on how a judge reads it, but it should be clearer for suppliers and consumers what it means exactly.

The Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013

Time to write to my MP...

I am hoping you can address a concern I have regarding these regulations. This letter should hopefully explain my concerns, and why I feel a small amendment to the regulations would be in order, particularly now.

Who am I?

I am the director of an Internet Service provider (Andrews & Arnold Ltd) providing internet and telephone services throughout the whole of the UK, and with most staff based in Berkshire, and several staff based in Wales.

Background

One of the key features of these regulations is a 14 day cooling off period for distance sales, for goods and services, to consumers. This is an important safeguard.

However, section 36 provides a facility for consumers that do not wish to wait 14 days for a service to be performed. It specifically allows a consumer to make an express request, in a durable medium, for a service to be performed within the 14 days, and waive their right to cancel within 14 days if the service is performed.

It then provides the protection that if the service is not performed yet, the consumer can still cancel within 14 days, only paying for the part of the service that has been performed, in proportion. However, once the service is performed, the right to cancel is lost.

This is a benefit to consumers that do not wish to be forced to wait 14 days for a service, and addresses the inherent nature that a service, unlike goods, cannot simple be sent back.

The problem

The problem is the wording of 36(2), and specifically the phrase “if the service has been fully performed”.

This makes perfect sense for a service like installing a dishwasher. I.e. if the installation has started, but not finished, the consumer can cancel, paying only proportionately for what has been done so far.

However, this wording does not fit well with a service such as broadband/internet. The problem is that such a service is installed and then ongoing, possibly even with a minimum term. The supplier has costs for arranging the installation, and may well have commitments with circuit providers for a minimum term.

If a customer cancelled after the installation was complete and the service is working, but within 14 days, the supplier has to charge in proportion. For a 12 month term, that is a fraction of the costs to the supplier. Indeed, with services on 12 month term it is common for a free installation to be offered, which is another cost for the supplier if cancelled within 14 days.

As such broadband service provision invariably has a 14 day cooling off period, denying the consumer the option to have an installation done sooner.

Why now?

Until now, for most broadband/internet installations, either a new circuit had to be installed (which takes time), or a migration is done with a carrier such as BT Wholesale. BT Wholesale have, to date, enforced a 14 day delay in migrations. So 14 day cooling off period is effectively enforced.

However, a new initiative by OFCOM has changed things. This takes effect 12th Sep 2024. As a result, BT Wholesale are dropping the 14 day minimum lead time on migrations. OFCOM are trying to encourage switching of broadband to be easy for consumers, indeed, the wording of the OFCOM general conditions means a provider has to provide a service as soon as technically possible if the customer expressly requests it, which may be within that 14 day cooling off period.

The fact OFCOM are, in effect, insisting operators allow customers to request services sooner creates a serious problem for providers. If nothing else, a free installation type service would not be sensible (again, to the detriment of the consumer). Even if a provider chose not to fully adhere to OFCOM GC, and insisting on a 14 day cooling off time, this effectively denies the consumer an option. But the wording of 36(2) of the regulations means an Internet provider will not be willing to offer quicker broadband switches without significant risk.

I stress that a consumer has to make an express request for a faster install, in a durable medium.

Suggested change

I would suggest the drafting of the regulations simply did not consider this type of service provision, and the current wording is an oversight.

I’d like to see working more along the lines of…

… if the service has been fully performed, or, for an ongoing service, the ongoing service has been made available, …

This could allow an ongoing service to commence within 14 days, losing the right to cancel, at that point, which is only fair given the costs for the supplier. I.e. supplier has done the work necessary now and so deserves to be paid.

How does this help your constituents?

The clash between OFCOMs new rules and the regulations is already causing concern for small Internet Providers like us, and leading to reduced choice for consumers, your constituents. We’d love to offer the full range of options, including cheap or free install on a 12 month term, along with service provided even next day when possible. But at this point, such options are a risk for small providers and ultimately will reduce consumer choice.

I feel having this option of faster broadband switching will benefit consumers, and would support OFCOMs aims of better and simpler broadband switching. It remains entirely optional for consumers, obviously. But being unable to cancel once the “ongoing” service “starts” seems fair, and seems to be what the regulations clearly intended as an option.

Is this something you can raise in parliament?

TOTSCO load

OK, UK has 66 million people, assumed EVERY SINGLE ONE, man, women, child, has a separate broadband link, wow!

Assume every single one wants to switch broadband every single year.

So 66 million broadband switches a year.

1. That is 180000 a day
2. 7500 an hour
3. 2 a second.

So TOTSCO would handle, on that massively exploded logic, 2 a second.

FFS a single Raspberry Pi could do that.

Even "office hours only" pushes to like 6 or 7 a second maybe.

Why is this a whole company, and AWS servers and whatever?

Update: To be clear this is very flippant and verging on a joke. Yes, the load will be very little, and yes, the peak may be more, but not hugely, and yes, you need redundant servers and so on. But the whole thing feels like massive overkill the way it has been done, that is all.