Intelligent Solutions

Thanks for another interesting year!

Simon Woodhead

Simon Woodhead

24th December 2021

By Simon Woodhead

Wow, it felt odd writing ‘interesting year’ for the first time a few weeks ago, or at least as it seems. Actually a year on, a year further towards our self-inflicted dystopian nightmare, I hope you’ve kept safe and well, and moreover kept ‘self’. Who’d have thought (beyond Orwell in ‘1984’) that we’d be even contemplating mandatory vaccinations and carrying around zee papers. My Grandad was an engineer on Ark Royal when it was sunk, fighting to prevent today; he’d be ashamed.

Alas, I truly hope you and yours have had a good one. Like last year, we’re lucky and I’m grateful to be in this sector, and I hope life and business has been kind to you.

At Simwood we’ve had a busy year although not in the usual way, and you’d be forgiven for thinking things have been quiet, as we’ve been far more internally facing in our progress than previously.

January got off with a bang across the pond as Simwood Inc was approved as a CLEC in California. No mean feat that, especially with a fraction of the team normally required and in record time despite a pandemic. Tom, Cathy and their army of lawyers smashed it. I’m still blown away by the fact that the GDP of California alone exceeds ours here in the UK. 

February saw the early results of huge efforts by Charles and his awesome team behind the scenes on the Simwood Partner ‘Sipcentric’ platform. Call recording, a feature we give away for free on the platform, had shown growing pains after we more than doubled the user-base in the preceding year, and our rich API on that platform was seeing insane levels of usage. Massive work went on behind the scenes, not simply progressing the migration of Sipcentric to the Simwood network, but also re-architecting a few things ready for significant scaling. They also enabled third party payments, such that the platform will not only do your end-user billing for you (another free feature) but can now process the payments for you – in your name against your own Stripe account. Lastly, we went live with Simwood Residential which several of our alt net customers have been pushing very hard since. In fact, adding those to the many alt nets using us in more of a carrier services capacity and nobody is doing more than Simwood in delivering voice to those end-users who have truly stepped into the light! 

2021 was a big year for Regulation. Pete and I were rather busy articulating our vision of a fair and transparent marketplace to the champion of such a cause. No, not our team, we have the passion but not the power; rather, one who has the power but seemingly not the passion: Ofcom! We chalked up a win for the old people regarding BT land-line pricing (even though Ofcom said we were wrong but proceeded to address our concern specifically) and we fed some contentious views (amongst our ISP friends at least) into the consultation on the video sign-language service. Most significantly though, we saw how much we’d been listened to with our feedback into the WVMR – Ofcom’s policy setting for our industry for the proceeding 5 years. There were some wins even though ‘we do not agree with Simwood’ seems an essential part of any Ofcom statement nowadays. I’m good with that as long as, whilst they feel they have to disagree, we’re shaping the outcome positively!

Another huge part of 2021 for us was the BTZero and the Secret Club. Gaining admittance to the latter was a win in late 2020 but 2021 was about execution. We’re probably the second or close third largest host of number ranges for other Communications Providers in the UK by my figures, and migrating them from TDM to IP was no small or quick undertaking. It involved a myriad of BT portals and excel spreadsheets and even dusting off the legacy Windows VM we have to keep for running IE4 and ActiveX! I genuinely fear for those smaller operators, and moreover their hosted customers, who don’t know what the future holds and will be migrating to IP with BT (be it Secret Club or as a reseller) in the ever increasing mad rush of the next 5 years. But we’ve done it and, although we didn’t make a fuss, since November 100% of the traffic entering the Simwood network for 100% of hosted customers (and our own number ranges of course) has been over IP. This gives so many benefits and is great to get behind us! Of course, BT is just one operator, and all the others were already IP under BTZero and carrying an ever increasing proportion of our traffic. But we’ve been 100% IP (well, ignoring Virgin who haven’t got round to IP yet but are optional for us) since the Autumn. That is a monumental step forward.

Traffic volumes surged in 2021 as well. I think we long passed one of our closest peers and have 1 billion minutes a year in sight now, with our next competitor quite a long way above that. I’m pretty chuffed with that!

July was a depressing low-point that offended me to the core with the introduction of origin surcharging by BT, EE and Three. The WVMR provided for post-Brexit Britain with protections that should the French (let’s be honest!) have a tantrum and decide to jack up the termination rate on a bilateral interconnect if they don’t get all our fish, a UK operator wasn’t obliged to give them the price-capped domestic rate for calls the other way. This was dangerous, and we warned Ofcom, but in the context they intended it had logic. As an operator with bilateral interconnects in other parts of the world, it made some sense. However, at an uncharacteristic speed after applauding Ofcom’s genius in the consultation the said operators implemented surcharging, not just internationally based on a specific bilateral agreement, but domestically on everybody based on where the call appears to come from. These same operators who for years have been unable to implement General Condition C6 and filter erroneous CLI, were suddenly able to bill for it and at egregious rates. Never slow to sniff a dirty buck, most of the industry followed suit, blending these charges or making up their own to pass on to their customers. Some who couldn’t update Bind for 15 years, managed to overhaul their billing seemingly overnight to get in on the filth. We stood by our morals and refused to pass these dirty charges on, and we maintain that position. We’re alone of course but as more and more operators get shafted, we’re seeing ever more of them move over to Simwood. I’m amazed we haven’t seen a large insolvency though, and the financial reporting season will be revealing! I had the pleasure of speaking about this in Westminster late in the year, Chairing a session which enabled me to question BT’s regulatory director on why they couldn’t implement GC C6 but could implement origin surcharging (which unexpectedly made headlines), and to pass a question to Ofcom about the whole thing. Their summary view: “if the CLI is invalid I don’t know where the call came from”. Er, how about the damn interconnect it came over? And if the CLI is invalid, you have a rule about that (GC C6) from years ago! Grr.

Autumn was bittersweet. On the one hand our Code Powers were announced which got lots of people excited. Sadly, they were pointless before they’d even been announced. We’d spent much of the year planning a full fibre rollout in a connectivity starved part of the country (that didn’t overbuild any of our alt net customers). Those plans were scrapped when BT put away the begging bowl (for now) and asked Ofcom if they could instead introduce a loyalty scheme discounting fibre by up to 30% to its most loyal resellers. This tipped the risk reward equation unpalatably for us. Ofcom’s response:

In October we announced I was stepping back from the CEO role, after 25 years. That was, and remains, a very sad day for me as any of you who have done the same will relate to. I described intensely personal reasons, which will have been news to many I expect because I’m generally a private person, although that didn’t stop some making up their own on FaceBag. Grahame stepped up to the plate and his team have done a distressingly good job of forgetting about me and taking things forward! I’m still here of course and, intentionally, involved asynchronously and behind the scenes where I think I’m needed. Personal reasons and sadness aside, given my increasing loathing for the darker side of this industry, stepping away is probably a good thing.

DDoS of course has been a theme for this Autumn and for some ‘networks’ this was the first time they’d thought about responding to one. I don’t wish that on anybody but this is a scenario that has scared me for much of the last decade. Two whole network refreshes ago we implemented on-net DDoS scrubbing as a service for ITSPs and last network refresh we migrated this to huge off-net scrubbing as standard on all our IP Transit and of course our own network traffic. Nevertheless, we had to respond and that was mostly taken well and our customers stayed safe. I’m told we got positive mention at NANOG but didn’t see anything myself. That whole experience shone a light in areas others would sooner it didn’t and I welcome more of that, not that I condone DDoS or wish it on anyone.

Don’t forget, Ofcom has given you some homework for the festive season. That aside, I genuinely wish you and yours a safe and restful break and hope 2022 is going to mark a turning of the tide in many respects. Look after yourselves and each other, and thank you for putting your trust in us.

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