Responses to the DCMS Digital Communications Infrastructure Strategy Consultation

INCA submitted a response to the recent DCMS Digital Communications Infrastructure Strategy Consultation:

We’re Only Going to Do This Once

INCA’s response to the Government’s consultation exercise on Digital Communications Infrastructure Strategy is unashamedly forward looking and positive. Reflecting the fact that none of INCA’s members own an old phone network, we say:

"Many INCA members view their activities as building the digital communications networks of the future: high capacity, symmetric and affordable. We term these ‘Transformational Digital Networks’. As yet no significant limitations to bandwidth have been found for fibre networks. Capacity on wireless networks is growing all the time (with some caveats on available spectrum and other factors). Fibre networks being built by companies like CityFibre, Hyperoptic, Gigaclear and B4RN can deliver gigabit services as easily as they can deliver 1mbps. Gigabit cities and gigabit villages are becoming a reality in the UK, built by the independent sector. Their operational costs are significantly lower than hybrid FTTC networks, they are more resilient and they deliver what they promise rather than ‘up to’ speeds. Customers get what they pay for, service providers have more reliable networks, the country gets the modern, up to date infrastructure it needs. Win, win, win.

When Joseph Bazalgette was planning the London sewer system he came up with the dimensions of the pipes required and then decided to double them. At the time he explained, ‘Well we're only going to do this once and there's always the unforeseen'. His foresight allowed for the huge expansion in London’s population with a sewerage system that continues to work today. We need that sort of Bazalgette vision for our digital communications infrastructure. The transition from the old phone network to the new fibre and wireless networks will only happen once in our lifetimes. The new networks will provide the capability for dealing with the unforeseen.

Government policy needs to take account of the massive increase in demand for bandwidth that has occurred over the past 20 years since access to the Internet became widespread, alongside the huge growth in mobile communications that also started in the early 90s. The belief that demand will continue to increase drives investments being made by INCA members, often with 10-20 year time horizons. Government policy should support those making investments in networks which will accommodate the unforeseen - and not simply back those arguing for continued investment in the 20th century copper network."

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Also posted here at the request of the response authors are two other responses to the same consultation:

Philip Virgo, chair of the Conservative Technology Forum, responded in a personal capacity. Philip argues that DCMS’s vision has shrunk in the past few years and that:

"We need to move from reliance on “a handful of semi-incompatible, pre-internet, national networks, to a world class, high resilience, secure and ubiquitous, any-to-any mesh. We need a communications infrastructure that is fit for purpose as a critical utility, on which lives and businesses depend. It should be no more subject to outages or traffic rationing at times of peak load than the power supply."


Stefan Stanislawski of Ventura Next submitted this response. Stefan argues that:

"It is now simple common-sense to set a policy goal of a fibre switchover and to start driving the changes in regulation and incentives needed to accomplish this, without major cost to the taxpayer, to the benefit of citizens and businesses both as a result of lower than otherwise bills and also much, much better broadband."

He makes the point that the line rental component of our monthly bills should have been used for some years to achieve this - an issue he terms the ‘replacement anomaly’. He goes on to argue in favour of modifying the USO to provide some of the funding and for the creation of regional fibre development corporations to help effect the change.


Michael Armitage of Broadway Partners submitted this response. Michael, Co-founder of Broadway Partners and formerly an investment analyst of many years standing, Michael argues that the 2010 government intervention in superfast broadband was premature and that 

"when the technical and economic limits of the copper network have become all too clear as BT pushes its upgrade programme to the final 20% of the population, and when long-term interest rates are at an all-time low and pension liabilities of an ageing population are at an all-time high, there has never been a better time than the present to launch a major long-term infrastructure programme, where the expected returns extend many decades into the future – to say nothing of the immediate and direct contribution of an extensive civils programme to employment, to the economy and to tax receipts."
He makes the case that public intervention should operate at multiple levels with government acting as an aggregator, anchor tenant, coordinator, co-investor and pro-competitive watchdog. He also makes a clear distinction between corporate financing that judges competing projects on the basis of maximising shareholder return, compared to project financing that can attract different types of investor at different stages of a project. It is worth noting that INCA members tend to fall clearly into the latter camp.

​Further responses are also attached below.

INCA Response1.23 MB
Philip Virgo Response246 KB
Stefan Stanislawski Response600.21 KB
Michael Armitage Response178.19 KB
Federation of Communication Services Response149.16 KB
UK Broadband Response338.77 KB
Bit Commons Response159.69 KB
ITSPA Response121.56 KB
LEP Network Response496.92 KB
Program Planning Professionals Ltd Response242.72 KB