An Alternative National Broadband Plan

The Irish Government wishes to implement a plan to deliver fibre to the home (FttH) for every house in Ireland. This is a laudable objective for which it is easy to make the case. But, as a Nation, we must choose between many laudable objectives. We must therefore ask several questions before proceeding.

Should the state be involved, or to put it another way is there market failure?

When the plan was first discussed in 2012, it was to cost €500M and serve 1M homes. 50% of Ireland’s homes were not connected to Broadband. That situation has improved to where the private sector will deliver FttH to all but 0.5M homes. Other broadband delivery solutions such as wireless have delivered to 89% of the population but the capacity is not adequate for many emerging uses.

While the situation is improving, I think we can accept that there IS market failure and the Government do need to be involved. We have passed the ‘market failure’ test and so we move to the next question.

What should the State set as a connectivity baseline for every citizen and at what price?

Statutory Instrument No. 391/2016 - European Union (Reduction of Cost of Deploying High-Speed Public Communications Networks) Regulations 2016, contains the following definition “high-speed public communications network” means a public communication network which is capable of delivering broadband access services at speeds of at least 30 megabits per second. Let us adopt that legal definition.

I will include the phrase ‘contended but not congested’ in that definition. When testing you should measure 30Mbps 95% of the time, no matter what time you choose to test. I have a 30Mbps rural wireless radio link to my home our demand rarely exceeds 10Mbps. My wife and I work a lot from home, we have three kids and the service is fantastic. I certainly will not pay more for an FttH product. Typically 10% to 20% upload speed is adequate. If we can accept that 30Mbps download and 3 to 6 Mbps upload as an acceptable minimum standard, we can proceed.

While FttH is a gold standard objective, even the NBP agrees that a number of homes should be connected wirelessly because the cost is of FttH, for them, is prohibitive. In adopting a baseline, FttH cannot be the only option. Surely it makes sense to adopt the most cost effective solution provided the baseline service quality has been met.

If we accept that €50 plus VAT is a baseline consumer price, then the infrastructure provider might take €30 and the service provider might take €20.

If we are still in agreement, then a baseline to every home of 30/3Mbps at a wholesale cost of €30 is our target. Let us proceed further.

How should the State ensure that this minimum service is available to all?

Rather than address the NBP in isolation, there are two other issues that should be addressed in parallel.

1)     We need fibre for the rollout of 5G mobile services and we need the rollout of fibre for critical industrial/commercial/government infrastructure also.

2)     We have agreed above that wireless operators have a place to play in any solution. There is a widely held and totally incorrect belief that wireless cannot deliver the performance we have outlined in our baseline discussion above. Wireless operators need low cost fibre backhaul. Their technical issues are with backhaul, NOT will delivery at the customer end. They are congested at the point of aggregation, not the point of delivery. Put in more aggregation points and wireless congestion decreases.

eNet, Aurora, ESBT could be used as a vehicle to install key fibre connection nodes available to all Telcos. I understand that this was part of the early NBP proposals but has been abandoned. This fibre backhaul infrastructure should include key hilltop sites as well as central duct locations. Some of this investment might connect existing MANs. Current investment in eNet managed infrastructure is around €180M creating close to 100 MANs. I will assume that a further investment of €180M would create about 200 fibre aggregation points available to all carriers including the smallest WISPs. Aggregation points should be adjacent to communications towers if possible. It is incredible how few communications towers in Ireland are fibre connected. Fibre to the tower should be a high priority. Many aggregation points would be built on State property, so a cost of €1M8 per site seems very achievable. This could be planned and built within a year. A critical objective would be to drive down per metre backhaul costs in Ireland. Competition between carriers will deliver these savings to the end consumer. Despite state investment in backhaul fibre via the MANs, ESBT and Aurora as well as private operators such as Eir and BT, backhaul prices in Ireland remain stubbornly expensive.

Once the backhaul fibre is in place, we are ready to start the rollout. There are approximately 80 ISPs in Ireland ranging from a few multinationals to family run WISP businesses. These should be encouraged to compete. Broadband installers should;

• be certified by ComReg, just like RECI certifies electricians, to ensure they have insurance, training etc;
• contribute to the post code based database operated by ComReg so that correct planning can take place ;
• be subject to a complaints process which would include financial penalty for not achieving the baseline service;
• have an available panel of certified installers of mole plough contractors for cable installation;
• have a centrally agreed and regulated contract for access to existing Eir poles for fibre installation.

The best way to stimulate the market is to offer a voucher of say €400 to every home in the intervention area. Half would be payable to the installer on connection and verification to the baseline and the remaining would be payable after twelve months, again on verification of the baseline. It would be possible to offer a higher voucher for FttH (possibly €600) Assuming 500k homes take up this offer, then the cost to the state will be around €250M.

This plan will trigger a land grab by the 80 ISP companies. Some like Eir will roll out fibre. The WISPs will be pushed further into rural areas but they will have the backhaul from which to build out. WISPs will install fibre if it makes economic sense and some have started to do so (Rapid Broadband and WestNet for example).

How would a backstop service be delivered?

The world is entering a new era in Broadband communications. There are more than ten organisations implementing or planning low earth orbit (LEO) satellite constellations. This is a revolutionary technology. Entrepreneurs such as Elon Musk (SpaceX) , Jeff Bezos (Blue Origin / Kuiper) and Richard Branson (One Web) are investing billions to launch satellites that will zoom over Ireland, just above the atmosphere. They are being deployed to deliver broadband to every square inch of planet Earth, including rural Ireland. Ireland should negotiate a package for say 50,000 homes to take this service allowing them to sign up for an agreed price of say €50 per month. Their voucher of €400 can be used to close the deal. This will add no cost to the taxpayer. SpaceX or Kuiper will receive a €20,000,000 payment out of the voucher fund to guarantee the provision of the baseline service to homes that fail to secure a commercial agreement. There will be 40 LEO Satellites over Ireland’s skies by the end of 2020 and 1,000 by 2030. Be clear on this; LEO Satellite Broadband will exceed the baseline specification we have set.

As well as servicing single homes, LEO Satellites can also be used for service provider aggregation solutions.

Summary and Conclusions

The Government needs to invest approximately €400M and then stand back to allow the market perform. The plan will take one year to kick off and could be completed in two to three years. But most importantly, a plan like the one outlined above will initiate an incredible investment spree by ISPs, knowing that the market is open for them at last. In particular, it is my expectation that as Eir maintain their existing copper infrastructure, in order to keep collecting line rental, they will upgrade to FttH as quickly as possible.

Approximately 40 of the ISPs operating in Ireland are small (often family run) businesses, that have delivered an otherwise unobtainable service for more than a decade. I believe the Government has an obligation to support those businesses and should favour cost effective solutions that include them. It is also important to remember that investment by regional ISPs has been curtailed by the threat, since 2013, that ubiquitous FttH would destroy these small service businesses. In NBP had never been mentioned then rural broadband would be far better today than it is.

Ireland should focus on the space race that will be started by LEO Satellites. We have the National Space Centre in Midleton, County Cork, CloudCIX will build a small LEODeck on our roof to be able to talk with these satellites. Perhaps a major gateway could be built in Mayo to serve in flight entertainment to aircraft over the North Atlantic.

There is not enough focus on backhaul and c

I suggest that entering into a 1,500 page contract spanning 35 years and costing €2.75B in an area of incredible technological change is extremely risky.

Saving €2.2B on the NBP will allow us to build 10,000 affordable houses or a small Children’s hospital. We must choose wisely.