Consultation Title: Broadband deployment and sharing other utilities infrastructure. 1. Introduction 3

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1 Consultation Title: Broadband deployment and sharing other utilities infrastructure Name of organisation consulting: BIS Water UK response Date of submission: 16 th September 2010 Contents 1. Introduction 3 2. Responses to consultation questions Question i) Do you agree that the ability to share other utilities infrastructure would reduce the costs of rolling out superfast broadband and facilitate investment? Question ii) We think that encouraging infrastructure sharing might help companies extend the reach of their networks further into harder to reach rural and remote areas. What infrastructures would be most useful in achieving this objective? How much difference do you think that more infrastructure sharing would make to the ability to reach these areas? Question iii) What do you see as the main barriers to infrastructure sharing? Question iv) What benefits are there for utility infrastructure owners in making their infrastructure available for sharing? Question v) What additional incentives would infrastructure owners like to see in place to encourage more sharing? th September

2 Question vi) What government action would be most likely to ensure the quickest and most effective deployment of broadband through infrastructure sharing? Is legislation likely to be required or would industry co-operation be quicker and more effective? 9 3. Other comments 9 16 th September

3 Introduction Water UK is the industry association that represents UK statutory water supply and wastewater companies at national and European level. We are funded by our members to influence public policy and opinion to ensure a strong water industry in the interests of all stakeholders. The focus on policy means: identifying gaps or inadequacies; working with members and stakeholders to develop alternatives; and helping deliver the benefits as new approaches are implemented. Our core objective is sustainable water policy actions and solutions that create lasting benefit by integrating economic, environmental and social objectives. The water industry in the UK owns and operates extensive water and sewerage networks. There are companies within the industry that have already entered into commercial contracts with telecommunications companies, sharing their infrastructure to facilitate broadband roll-out. Others are currently exploring this area of operation. There is therefore scope, which in some cases is already being exploited, for commercial collaboration. However, as we will explain, water mains are unsuitable for technical and health and safety grounds, and in many areas, sewage networks are fragmented and technically unsuitable for the installation of cables. Experience within the industry has shown that installing cables in sewers with internal diameters of less than 225mm (9 ) increases operational problems beyond acceptable levels. Sewers of this diameter, as the maps accompanying this response show, are rarely found outside urban and suburban areas, and so it will be unfeasible to use the sewage network alone to roll out high speed broadband quickly to rural and semi-rural areas. There are also other technical issues that we detail below that would need to be addressed or investigated more fully. We recognize that sewer networks could offer an opportunity for broadband roll-out in partnership with other utilities equipment, and feel it would be constructive to explore this as part of the consultation. We would welcome government intervention, if that would lead to a more flexible and sensible regulatory structure for those companies that wish to develop commercial relationships with telecoms companies. We would be very concerned, however, if there was any element of compulsion involved in infrastructure sharing, not least because of the legal responsibilities sewerage companies have. 16 th September

4 We welcome the opportunity to comment on this consultation and look forward to the renewed dialogue that will inevitably be generated between industries as a result of this exercise. Responses to Consultation Questions i) Do you agree that the ability to share other utilities infrastructure would reduce the costs of rolling out superfast broadband and facilitate investment? In suitable locations the installation of broadband in sewers could enable development of quick cable infrastructure and, as a short term measure, could connect people speedily to broadband. However, as we explain below, given the fragmented nature of the sewage system it could be problematic to use this method to get broadband into semi-and deep rural areas - the areas that the Commission for Rural Communities has identified as most likely to lose out as the UK connects to broadband. There are also other technical issues, which we explain in other sections of this response. The water industry already has experience of sharing infrastructure with other industries in this way. Companies have worked in the past with telecommunications firms on the placement of mobile transmitters on water towers and other infrastructure. The technical and health and safety issues involved were significant; however, they were overcome, and many companies have developed positive working relationships in this area. ii) We think that encouraging infrastructure sharing might help companies extend the reach of their networks further into harder to reach rural and remote areas. What infrastructures would be most useful in achieving this objective? How much difference do you think that more infrastructure sharing would make to the ability to reach these areas? It is our current view that the water supply network is not suitable for the installation of internal cables due to its pressurised nature, and because of the potential health and safety issues involved. Similarly the use of pressurised sewers is unlikely to be a suitable option for broadband providers due to technical issues. However, the gravity sewer networks do, in some instances, provide opportunities for the insertion of fibre optic cabling. There may also be small 16 th September

5 opportunities available within abandoned sewers and water mains, wherever these remain intact. It is a common misconception that the sewerage of rural communities is linked to major urban conurbations. If this were the case, there would be unique opportunities to expand broadband services from our towns and cities. However, the reality is that rural communities are largely served by small diameter sewers, draining to local treatment facilities. In some cases these communities are not sewered at all, and properties have privately owned treatment facilities serving single or small numbers of homes. The experience from pilot studies carried out by water and sewerage companies, and from commercial collaborations that are already taking place across the country, is that to carry single fibre optic cables of between 14 and 22 mm (carrying up to 300 fibres), sewers have to be at least 225mm (9 ) in diameter. On smaller diameter sewers trials have shown that ragging, where detritus in the sewers catches on the cable or its fixings, becomes an issue with a potential increase in blockages and other negative impacts on customer service. While urban and suburban areas have sewers of this size, most rural areas do not. We have attached maps showing the distribution of 225mm sewers in Wales, and the South West region, and a sewer network map of the Anglian region, which may help to make this point. Ensuring that semi- and deep rural areas get broadband connection through the use of existing infrastructure could therefore mean the involvement of, and co-operation between, several utility companies with different interests and objectives. In some cases, these companies may have to share commercially sensitive information. The government may wish to consider how such co-ordination might work. iii) What do you see as the main barriers to infrastructure sharing? a) Pilot studies and the existing commercial collaborations between water companies and telecommunications firms, for example in Scotland, have shown that it is unfeasible to place more than one cable in any one sewer. At present, this means commercial contracts are being formed on a first come, first served basis. However, as broadband rollout becomes more 16 th September

6 widespread, there may be competition issues to consider, which itself may raise fresh issues as regards fibre leasing. b) In those sewers that are suitable for cabling, there is no consensus at present as to where the best place is to lay the cable. If it is at the bottom of the sewer - the cheaper option - there is a greater risk of ragging and kinking of the cable. If it is attached to the top, the drilling needed could affect the integrity of the sewer itself, and there is a greater chance of the cable being cut should work need to be carried out on the sewer. According to a recent trial carried out by one water and sewage company, the most suitable position in the pipe [for the cable] remains unclear. The view in Scottish Water, which has already negotiated several commercial contracts, is that the cable should be on the invert, fixed at each manhole and slightly tensioned between manholes. c) Given a 225mm pipe and a 14/22mm cable, the cable itself would take up about 1/100th the internal area of the sewage pipe. This in itself would not make a dramatic difference to the pipe s flow; however, as already mentioned, the chances of increased ragging, of solids catching on the cable and causing blockages, will inevitably be increased. Blocked sewers are a source of considerable and understandable distress to customers, and companies work hard to reduce the number of blockages. Many companies would be wary of commercial collaborations which could increase the chance of this happening. d) The methods of cleaning drains are quite brutal, aimed at restoring flow as quickly as possible; brutal enough to potentially damage communications cables. The Scottish Water experience is that cable used to date can withstand routine pressure jetting. Routine jetting for maintenance can take place, general high pressure jetting is around psi range {Cable tolerance is to a max of 5kg/mm Crush Strength} e) The water industry has an ongoing public education programme, aimed at reducing the amount of fats, oils, greases, rags and other debris that are poured or flushed down the drains. It may appear hypocritical of companies to, on the one hand, tell customers not to dispose of potentially drain blocking items through the sewerage system whilst the companies themselves 16 th September

7 are running cables down those same sewers for commercial benefit. f) Every pipeline is different. Different locations, sizes, gradients, connections and valves. It is difficult, therefore, from a technical point of view, to be able to say with certainty, even given a large enough diameter, which one would be appropriate for use with broadband cables and which would not until a site specific assessment has been undertaken on each section of pipe. Each company will need to draw up a technical specification and this will clearly slow down the speed of cable placement. g) There are no centrally held records of existing utilities apparatus that can be used to assess whether broadband services can be delivered to an area using more than one network. The Government might consider ways this could be facilitated. h) Water companies have legal responsibilities in relation to drains and sewers, together with obligations to the economic regulator and to the customers. In Scotland, where commercial arrangements are already in place for some placing of broadband cables in sewers, there are contractual clauses to ensure that the maintenance and free flowing of sewers has priority over broadband connections. i) If the sewer network is used extensively for broadband cable placement, the skills of those installing those cables will become germane. Some companies are developing a system of licensed accredited partner, ensuring a standard level of competence. iv) What benefits are there for utility infrastructure owners in making their infrastructure available for sharing? a) Additional maintenance will, by the very nature of the cable installation, be required. However, the industry is aware that there could be significant benefits. The assessment process used by water and sewerage companies (WASCs) for the installation of cables in sewers currently demands pre-installation surveys of the pipe condition. The use of CCTV when installing the cables could be beneficial, allowing companies to spot problems with sewers that may not otherwise come to light. In one 16 th September

8 example of a current commercial contract, the telecommunication company was willing to cover the cost of some repairs in order to make the sewer suitable for cable installation. b) Water and sewerage companies support the potential societal benefits of rolling out broadband access through current utility infrastructure. They are keen to help bring about the wider community benefits of broadband access for all, in terms of employment, education, and allowing communities to fully participate in the Big Society. Potentially, water companies could themselves also benefit, for example, by using the cable network at minimal cost to get real time data from water and sewerage networks, to link company telephony and data services, and share information with customers. c) The key benefit is the opportunity to earn non-regulated revenue. This provides the primary incentive to sewerage companies to take on the additional costs and risks associated with hosting cables at a time when companies are striving to reduce the risk of customer impacts from the sewer network through the sewers for sewage stance. v) What additional incentives would infrastructure owners like to see in place to encourage more sharing? a) OFWAT has stated that it considers the granting of access to, and use of, the sewerage network for the laying of fibre optic cables a disposal of protected land. OFWAT has a duty under s2(3)(c) of the Water Industry Act to secure that consumers are protected as respects benefits that could be secured for them by the application in a particular manner of any of the proceeds of any disposal (whenever made) of any such a company s protected land or of an interest or right in or over any of that land:.... As the regulator itself points out, the Act does not prescribe how it should protect consumers, but its policy is to remove for customers 50% of the proceeds from the disposal of protected land. OFWAT believes that this gives consumers some benefit while retaining commercial incentives Given Ofwat s remit, it is understandable that it should seek to take a narrow view of how water customers should benefit from returns from providing access to sewers. However this approach 16 th September

9 does not take into account the non-financial benefits that would accrue to water customers following a successful broadband investment namely, that they would have access to an enhanced broadband product supplied partly through water infrastructure. We consider that the best arrangements to facilitate duct sharing arrangements between sewer owners and broadband providers would be a moratorium on the 50% reduction mechanism, so deployments in sewers within a specified timeframe would be exempt. This would increase the number of commercial agreements which would be viable, and provide strong incentives for all operators to accelerate deployment. b) We believe consideration should be given to capital delivery on new schemes. There may be opportunities within new capital projects being undertaken by the WASCs to incorporate broadband technologies, or even cable ducting alongside new assets. Such installations would need to be considered on a case-by-case basis to ensure that new cabling did not present operational issues. Similarly, on new housebuilding developments, it may be possible to provide appropriate ducting for cable companies to use, perhaps in the future. At present there are no incentives to do this. vi) What government action would be most likely to ensure the quickest and most effective deployment of broadband through infrastructure sharing? Is legislation likely to be required or would industry co-operation be quicker and more effective? Many water and sewerage companies are keen explore the possibilities of utility sharing, and the industry feels that government action would be welcome if provides a more flexible and attractive framework within which water and sewage companies who want to and telecommunications companies can work together. Water and sewerage companies have an encyclopedic knowledge of their own assets; they are aware of the balance between risk and reward, and are working hard and sharing knowledge to ensure that this relatively new area of operation progresses as effectively as possible, providing benefits for water and broadband customers, and wider benefits for society. The companies themselves are best placed to know what would and would not work within their own sewerage system. As we have 16 th September

10 pointed out, no sewer is the same, and often expertise, not paper calculation, will show what is feasible. The water industry is opposed to the introduction of legislation, or indeed any element of compulsion, to drive the sharing of utility apparatus, and believes that co-operation, though the introduction of appropriate financial incentives, would provide the right drivers for those who wish to develop this area of their operations. Another issue Scottish Water are experiencing, is that land owners are challenging the installation on cable in sewers from the perspective that, in their view, the wayleave grants the water company the right to transport sewage, not broadband. It would help to get a resolution to this. For further queries, please contact Sarah Mukherjee, Director of Environment or th September

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