text:
151. Broadband and its infrastructure inevitably
represent a highly technical field; and the regulatory arrangements
which structure and govern the territory are no less complex.
One can be forgiven, therefore, for finding a journey into the
detail of policy implementation in this area forbidding. However,
it has been our discovery that many of its smaller, more intricate
features are responsible for the contours of the wider landscape.
As a result, it is important, for the proper scrutiny of the area,
not to be deterred by its jargon or detail.
152. It is for this reason that we have taken
a substantial amount of evidence on the implementation of the
current policy, as well as the regulatory arrangements that surround
it. Having considered this, we make a number of observations and
recommendations, some of which are inevitably expressed in more
technical language. As much as possible, however, we will try
to explain the terms used, occasionally by placing background
information in boxes, and certainly, we have sought throughout
to spell out the important implications of our proposals in the
most straightforward terms. Broadly, the observations and recommendations
which we now make fall into three groups:
· Those which assume no change in the Government's
overall approach;
· Those which call on the Government to
change its approach, effectively bringing it closer to our alternative
· Those which call on the regulator, Ofcom,
to change its approach, with the same effect;
We will take these in turn.
Recommendations assuming no change
in the Government's overall approach
153. Our focus up until this point has been on
a reorientation of Government broadband strategy away from the
edges and towards a reorganisation and enlargement of the middle
mile of the network, and in particular to the introduction of
open access fibre-optic hubs. However, to a large extent, the
Government have set the direction for broadband policy to 2015,
and clearly much of the work this has set in train is already
underway through four strands of activity:
· Three of which are under the auspices
of BDUK:
BDUK management and allocation of £530
million for the 'final third';
The Mobile Infrastructure Project (MIP);
Superconnected Cities.
· One further strand of which is a responsibility
of Defra:
Rural Community Broadband Fund (RCBF).
154. Problems with the last of these, the RCBF,
are particularly startling. Fortunately, the solutions should
be equally straightforward for the Government to develop. By design,
the RCBF is intended to subsidise enhanced broadband infrastructure
to those areas of the UK considered to be, not only in the final
third, but also in the final 10%, which will almost certainly
be rural. The reason they need special attention is that communities
and properties in these areas are generally acknowledged to present
the most severely challenging investment case; even with BDUK
subsidy, it is considered to be too weak.
155. Accordingly, the RCBF is only available
"if your community is in a rural location identified as being
in the 10% hard to reach area covered by your Local Authority's
Local Broadband Plan."[84]
In other words, it is only available if you are excluded from
your Local Authority's Local Broadband Plan.
156. Miles Mandelson, Chairman, Great Asby Broadband,
explained that when local authorities are asked whether they can
guarantee that a specific community falls outside the boundaries
of its roll-out, the answer is:
"'No, we cannot. We have not finished our procurement.
We do not know what the boundaries are going to be and the situation
keeps changing. But, if you like, you can exclude yourself from
the county council roll-out and we will not come anywhere near
As there is equally no guarantee of inclusion within
the RCBF scheme, communities are naturally wary. After all, as
Miles Mandelson put to us, if: "their application [to the
RCBF also] fails
they are then left with nothing more than
the 2Mbps universal service commitment (USC)."[86]
157. As a result, remote communitiesparticularly
those engaged as part of BDUK's pilot schemeare being forced
to take on a considerable amount of work and responsibility, with
the entirely likely result that they will ultimately be told they
fall outside the boundary of the roll-out.
158. A further failure of the RCBF arises from
its specific stipulation that communities in the final 10% fund
the construction of their access networks with no guarantee of
grant payment from Defra; they will only be able to recover the
expenditure once they have provided evidence that they have paid
for itand even then there is no guarantee. According to
Defra's RCBF Handbook:
"In simple terms, you will need to spend firstand
then claim later."[87]
159. In our view, it is ludicrous to expect all
remote communities to be able to provide the levels of funding
required to build broadband access networks in their areas. While
there may be some which can, inevitably others will not be able
to do so. The RCBF process, therefore, will present a number of
communities, whom it is intended to assist, with a Catch 22. It
must be said that there is a lack of clarity over the origin of
this stipulation. The RCBF funds derive from a wider Defra programme
called the Rural Development Programme for England, which in turn
draws its funds from both the UK Government and from the European
Agricultural Fund for Rural Development. Whether the stipulation
derives from a Europe-wide policy or is one of the Government's
own making, however, does not alter the absurdity of its assumptions,
which must be resolved.
160. We urge the Government to provide a more
coherent mechanism for the provision of enhanced broadband infrastructure
in the final 10% than currently is the case with the Rural Community
Broadband Fund. In particular, a new mechanism for distributing
funds must meet the criticism that its predecessor was flawed
in assuming all communities have the capital required, up front,
to invest in their own access network.
161. We also wish to highlight a number of other
ways in which the Government could usefully intervene without
fundamentally having to change their current approach. The most
obvious examples relate to the planning system, street works permissions
and the Electronic Communications Code; aspects of all of these,
as they stand, can cause delays to the roll-out of broadband infrastructure.
162. The planning system can cause delays because
of the length and cost of consultation processes. As Antony Walker,
CEO of the Broadband Stakeholder Group, told us:
"One of the biggest barriers to the use of poles
is the planning system. The consultation processes that are required
if you want to utilise poles or put up new ones are pretty onerous
and off putting to investors."[88]
Similar points were made by Vodafone:
"Many delays during the planning process are
caused by tokenistic opposition which is more often than not overturned
on appeal. Delays add significant actual costs, as well as the
opportunity costs for the local economy."[89]
163. Street works permissions can equally add
serious delay. Sean Williams, Group Strategy Director, BT, told
"The street work guidance for permit schemes
can result in councils designating the putting up of the street
cabinet as a major work, and if it does that then it causes all
sorts of costs and delays."[90]
164. Finally, delays can also arise from the
process for gaining wayleave permissionsa licence granted
by the owner and occupier of land giving a third party the right
to install, use and maintain its equipment on that landprovided
for in the Electronic Communications Code. Vodafone argued that:
"The current system of high annual ground rents for the lifetime
of the site imposed by the code is one of the greatest disincentives
to the roll-out of mobile coverage and should be reviewed."[91]
165. Sean Williams, Group Strategy Director,
BT, argued that a better mechanism for dispute resolution with
regard to wayleave permissions was required. Wayleaves, he argued,
"particularly important for multi-occupancy
dwellings, whether they are blocks of flats or retail centres
with businesses in them, where it is very often difficult and
costly to negotiate wayleaves, and indeed there is no effective
mechanism for resolving wayleave disputes. We could very readily
do with some support in that area, to get a dispute mechanism,
and also to put some obligations on landlords to make this possible,
as I think they do in other countries."[92]
166. As part of its wider communications review,
the DCMS has asked the Law Commission to conduct an independent
review of the Electronic Communications Code. This project began
in September 2011 with a consultation paper being published on
28 June 2012. The Commission expects to publish its report in
spring 2013 and for any reforms to be implemented through legislation,
anticipated in 2015.
167. In their deliberations over the potential
reform of the Electronic Communications Code, we encourage the
Law Commission to consider the impact of the Code on the roll-out
and availability of broadband infrastructure throughout the UK.
168. We urge the Government to consider reform
of street works permissions and the current planning system, given
their wider impact on the pace and sheer viability of the roll-out
of broadband infrastructure throughout the UK.
169. Finally, we note that new build sites can
easily have ducting for fibre installed. It is, therefore, our
view that for new developments, the provision of fibre connectivity
should be as automatic as the provision of mains electricity.
170. We recommend that the Government require
that all new building developments be ducted for fibre, with appropriate
provision for an internet connection, and that building regulations
for this be developed perhaps analogous to those which already
require adequate provision, for example, for the delivery of mains
electricity and sewage connections.
A change of approach in Government
171. Up to this point in the chapter, we have
made recommendations which the Government are able to act on now,
without rethinking the broader strategy they have set for 2015.
However, in exploring its detail and implementation, we have also
encountered a number of features which reinforce the case for
considering an alternative strategy altogether.
We will pick up three particular points:
· The impact of inflexibility in the current
policy targets;
· The wider potential of the Mobile Infrastructure
Project (MIP);
· The importance of monitoring infrastructure
providers in relatively non-competitive markets
The impact of inflexibility in
the current policy targets
172. In its original strategy document, the Government
maintained that: "our approach to delivery... [is] technology-neutral."[93]
However, it is widely acknowledged that the significance of the
original 24Mbps target lies in the fact that it specifically aimed
to exclude as an eligible technology any copper between the exchange
and the cabinet; as noted in Chapter 2, 24Mbps relates towhat
was at the timethe highest headline speed achievable over
copper lines from the exchange.
173. In line with the alternative strategy sketched
in Chapter 3, we endorse the replacement of copper by fibre deeper
into the network. However, there are indications that mandating
this shift by means of a speed target has built inflexibility
into the implementation of the current policy, with a number of
undesirable consequences.
174. One of these was described by Rory Stewart MP,
in reference to Northern Fells, an area in his constituency. Having
formed plans to bring fibre within reach of its village, the community
considered the use of the wireless technology, 'white space',
as a way of reaching its outlying properties. The problem that
arose was that white space spectrum is technically limited to
delivering a maximum of roughly 15Mbps, and as this falls short
of the Government's targets, it is ineligible for public money,
stranding the outliers with a lower level of service. As Rory
Stewart MP put it:
"I think it is about flexibility. I think it
is about loosening the reins a little, loosening the criteria
and being prepared to look at each case on its merits."
175. Curiously, by mandating a specific speed
target, with the intention of pushing fibreand by extension,
enhanced capacitydeeper into the network, the Government
have in some cases ensured that communities reliant on more experimental,
innovative technological solutions will not get any enhancement
at all. In short, because their plans do not meet the Government's
aspirations in full, they will be condemned to nothing.
176. We note that the European Commission's draft
guidelines on State Aid stipulate that financial support should
be provided only to those projects which can deliver a "step
change." This is not defined, however, in terms of speed:
"A "step change" can be demonstrated
if as the result of the public intervention (1) the selected bidder
makes significant new investments in the broadband network and
(2) the subsidised infrastructure brings significant new capabilities
to the market in terms of broadband service availability and capacity."
177. The refusal to provide financial support
for a project, like that in the Northern Fells, on the grounds
that its proposal to use a technology (in this case white space
spectrum) which would not meet the Government's speed targets,
is a further illustration of the way in which such targets are
actually counter-productive. We urge the Government to reconsider
using speed targets to define the goals of their broadband policy.
This would allow them to be more flexible with regard to the technologies
used to provide enhanced connectivity, particularly to outlying
communities. Loosening the reins a little could very quickly have
the effect of bringing enhanced broadband capacity to the final
178. The alternative strategy we have put
forward would avert the situation which has arisen under the current
policy whereby communities are left stranded with a minimal service
because a viable enhancement falls below therelatively
arbitrarymark set for public funding. We invite the Government
to respond to our proposal that bringing open access fibre-optic
hubs within the reach of every community would liberate communities
and enterprises to evaluate the costbenefit calculation
themselves of the various different technological solutions available
in the access network.
The wider potential of the Mobile
Infrastructure Project (MIP)
179. The second area of policy implementation
which helps make the case for an alternative strategy relates
to the Mobile Infrastructure Project (MIP) whose first two "design
principles" are as follows:[95]
· "To improve mobile voice coverage
to outside of premises for the five to ten per cent of consumers
and businesses that live and work in areas of the UK where existing
mobile coverage is poor or non-existent;
· To enable the removal of 'complete' voice
not-spots without converting them to 'partial' not-spots."
180. The Government do not refer once to data
coverage, emphasising instead the role of the MIP in eliminating
voice not-spots.[96]
This point was reinforced by Robert Sullivan, CEO, BDUK:
"It is important to make that distinctionthat
rather than being a broadband programme [the MIP] is a voice programme"[97]
181. This strikes us as odd. According to Ofcom's
most recent Communications Market Report, "the usage
of smartphones as a means of accessing the internet has... risen
quickly. Ofcom estimates that in 2011, 32.6 million subscribers
accessed the internet via their mobile phones, an increase of
nearly 10 million since 2010."[98]
They also note the ways in which "new devices shape an explosion
in mobile data use" and that "volume of data use increased
significantly in 2011." Similarly, a recent report commissioned
by 02 showed that among smartphone users, internet access is by
some margin the most popular activity.[99]
182. It should be a fundamental 'design principle'
of the Mobile Infrastructure Project that where mobile coverage
is being widened for the purpose of eliminating voice not-spots,
coverage for data is widened and enhanced at the same time.
183. In addition, we note that BDUK is considering
implementing the MIP objectives by means of "an investment
by government in building Serviced Sites
in an appropriate
location to serve one or more not-spots, where site facilities,
power, backhaul, connectivity, cabinet and mast space were made
ready and available for 'occupation' by all mobile operators."[100]
184. In other words, the MIP, in establishing
a number of 'base stations' or 'serviced sites' with fibre backhaul,
may bring about something equivalent to the open access fibre-optic
hub which we introduced in Chapter 3. In fact, should the MIP
be implemented along the lines outlined above, these serviced
sites will be procured with clear open access stipulations, allowing
any mobile network provider to set up their own access network
services from those points.
185. There is a technically strong argument,
therefore, given the virtually unbounded capacity of fibre, that
it would be a significant enhancement to incorporate into the
MIP plan the following stipulation: that access be open not only
for mobile network providers, but also for any prospective network
provider to build out an access network from that point, should
they see a commercial opportunity or otherwise believe there is
value in doing so.
186. The Government should consider the potential
for serviced sites constructed as part of the MIP to be used as
open access fibre-optic hubs more generally, from which independent
third parties could extend out their own alternative, local access
187. Incidentally, in considering the harmonies
between mobile and broadband policy more widely, we note that
in parallel with the investments being made into fixed infrastructure,
the forthcoming 4G auction will equally serve, in its own way,
to widen access to enhanced capacity broadband. We do not comment
other than to welcome this development, in particular the recent
announcement by Ofcom that the 4G auctions are set to get underway
by the end of 2012 and that a stipulation of these auctions will
be that one of the lots of spectrum "will carry an obligation
to provide a mobile broadband service for indoor reception to
at least 98% of the UK population by the end of 2017 at the latest."[101]
Our focus in this report, however, has purposefully been on the
fixed infrastructure, and where relevant, the ways in which this
provides a necessary foundation for mobile data networks.
The importance of monitoring
infrastructure providers in relatively non-competitive markets
188. A final area which reinforces the case for
the Government to re-orient their strategy, in the way we advocate,
towards the establishment of open access fibre-optic hubs lies
in a consideration of the non-competitive nature of much of the
UK's broadband infrastructure. From the nine original bidders
in the BDUK Framework process, only two remain: Fujitsu and BT.
In fact, this may now be reduced to one as recent reports suggest
that Fujitsu has withdrawn from the process for the time being,
albeit that it is committed to bidding in the future.[102]
189. For some witnesses, this is merely evidence
of the inevitable characteristics of investors in broadband infrastructure.
Richard Hooper OBE, Chairman, Broadband Stakeholder Group, told
us: "this is, whether one likes it or not, an industry of
190. For others, the outcome is evidence of the
way in which BDUK's Framework has excluded less established bidders.
Gap-funding, the lack of open access to existing infrastructure,
and the relatively homogenous nature of the customer base within
an area as small as a local authority gives very considerable
advantage to bidders with scale. We outline in Box 4 the ways
in which the BDUK process may have reduced the ability of a wide
range of bidders to compete.
· the size of the bodies, particularly in England, acting as procurement bodies (local authorities)
· the gap-funding model adopted by BDUK. The "investment gap" is the public contribution required by a supplier's investment in broadband infrastructure to make a project commercially viable. [104]
In the case of the size of the investment authorities in England, networks within a local authority area may not be of sufficient scale to be sustainable without the assumption that the provider building the network already has scale across the country. If they do, to simplify the point, they can cross-subsidise from densely populated areas of the country with lots of potential end-users, to sparsely populated areas with only a few. As a local authority area may not contain sufficient diversity for this sort of sustainable cross-subsidy itself, an infrastructure provider unable to draw on national scale, and the ability to cross-subsidise over county borders, is likely to be unable to compete. Equally, the selection of the local authority as the focus for investment, rather than fewer bodies representing larger franchise areas, has resulted in a proliferation of procurement processes, requiring more resources to compete in a number of them at once. Inevitably, this has reduced the number of businesses in a position to bid across the country.
Similarly, consider BDUK's preference for gap-funding as the investment model to be used by local authorities. This favours large-scale businesses with a high level of knowledge about the market and likely level of demand. Having this knowledge enables them to make accurate judgements about the value of an investment, and therefore bid with a greater degree of capital, presenting a smaller, more attractive investment gap to the body making the investment. Similarly, it favours incumbents with reliable existing revenues, as these too decrease their risk and mean they can bid with a greater degree of capital, and present the procurement authority with a smaller investment gap.
191. Equally, regardless of the BDUK process,
the history of UK communications infrastructure is such that there
is now a provider, BT, to whom advantages accrue given its ability
to draw on diverse and reliable revenue streams, and an extensive
understanding of demand across the UK. These characteristics reduce
the level of risk presented by infrastructure investment, and
therefore afford those who benefit from them an unparalleled advantage
in the competition for infrastructure investment (see paragraph
192. Both views, thereforethose associating
the non-competitive nature of infrastructure provision with the
characteristics of the UK market and, those associating it with
the characteristics of the BDUK processare right to an
extent. In fact, there are other reasons too, relating to the
regulatory regime; we discuss these later in this chapter. In
our view, however, the foregoing observations are ultimately less
important than what one concludes from them. These conclusions
should be straightforward:
193. There are clear competitive advantages in
the market for infrastructure provision which accrue to those
able to draw on economies of scale and scope. If unchallenged,
these may result in the dominance of a single provider.
194. As suggested in Chapter 3, the danger
that results from the lack of competitive pressure in the construction
of the UK's broadband infrastructure lies in the fact that the
Government can easily find itself in thrall to the commercial
interests of private enterprise, and therefore unable to direct
broadband infrastructure in the wider interests of the UK.
195. We urge the Government, therefore, to
recognise as a general principle that it will be vital to monitor
the dominant, national providers vigilantly and to deploy appropriate
incentives to ensure they, and the market in which they operate,
behave in the public interest as this will not necessarily follow
automatically from competitive pressures alone.
196. In addition, we note the argument of
Chapter 3, that despite the presently non-competitive nature of
much infrastructure provision in the UK, open access to existing
connectivity can enable competition to play a role in extending
the reach, connectivity and diversity, and hence also the resilience
and performance, of these networks.
197. In the light of the previous discussion,
we are concerned about some of the decisions currently being made
by the providers bidding for BDUK projects. In particular, where
it is rolling out FTTP, BT is doing so using a technology called
PON (Passive Optical Network)see diagram below.
198. This involves single fibres being laid from
the exchange to the cabinet. However, from the cabinet to the
premises, these single fibres are not simply extended out, creating
a single fibre link all the way from the exchange to the property.
Instead, at the cabinet, each fibre (e.g. fibre A in the diagram
above) is split into a number of strands, and each premises receives
a strand from it (e.g. A1, A2 or A3). As a result, this form of
FTTP tends to be called a point-to-multipoint, rather than a more
straightforward point-to-point, solution. BT's decision to employ
PON for its roll-out of FTTP has a number of consequences about
which we harbour concern, notably on the issues of unbundling
and future upgrade.
It is not practicable, however, to unbundle PON because of the way each fibre splits at the cabinet. To do so, given current technology, it would be necessary for an ISP to attract as customers all of the premises which happen to be connected to a single fibre through one of its strands (in the region of 30-100 separate customers). There are technologies in development (e.g. wavelength-division multiplexing) which would enable unbundling of PON and the targeting of individual customers, but these are currently unproven, and require expensive active equipment. As such, until a commercial model emerges to enable a competitor to take over a connection to all premises served from a single fibre, or until new technology emerges, PON cannot be physically unbundled, and it is not possible for BTas long as it is installing PON technologyto provide a desirable level of open access to its publicly-funded fibre access networks. As TalkTalk put to us in written evidence:
"Under a GPON[105] architecture, all ISPs share the same bandwidth and equipment. This means that BT specify most of the features of the product such as: the maximum speed; the total shared bandwidth; how different traffic is prioritised (important for IPTV and business services); and, the electronics/equipment placed on the both ends of the fibre." [106]
It is on this basis that the European Commission has agreed to Ofcom's proposal that BT must offer an alternative to full, unbundled open access, namely Virtual Unbundled Local Access (VULA). This simulates unbundled access to BT's fibre but is different from full unbundling in one crucial respect: the competitor ISP not only uses BT's physical fibre connection, they must also use BT's active hardware at each end. This makes it impossible to differentiate products to customers, and means that the main basis for competition is brand. It appears to us, therefore, that Government subsidy is being used to fund a new world in which there may actually be less competition than there was over copperreinforcing BT's market power.
Another unfavourable, consequence of the use of PON technology relates to its 'upgrade path.' PON is nottechnically speakingan interim step towards full point-to-point fibre; in fact, it is something of an evolutionary cul-de-sac. If a future Government were to have as a policy goal the achievement of full point-to-point fibre, much equipment and fibre, once PON is already installed, will simply have to be replaced, conceivably with further public outlay.
199. In the light of Box 5, we believe it is
incumbent on policy to ensure that there is a clear upgrade path
from any intermediate steps which may be taken, to the roll-out
of point-to-point FTTP. This will avoid major investments being
made, particularly with public money, into technologies which
represent an evolutionary cul-de-sac, and cannot be upgraded to
point-to-point FTTP without being completely replaced, possibly
with more public money.
200. We recommend that the Government's approach
be explicit in its insistence that the technologies and infrastructures
in which companies using public funds decide to invest be ones
which offer a clear 'upgrade path' to point-to-point FTTP.
201. Incidentally, there is an approach using
PON with fewer harmful effects on competition than is suggested
above. If a network is operated as a PON but the splitter is moved
up to the level of the local exchange, and alternative operators
can connect at that point, this would realise most of the capital
expenditure savings of PON, but would also enable passive unbundling,
and as a result, would equally enable real competition between
202. Where infrastructure providers using
public money decide to invest in Passive Optical Networks, we
recommend that the awarding of public money should be contingent
on the installation of the splitter at the level of the local
exchange rather than the cabinet, as this would enable passive
unbundling, and thereby real competition between ISPs.
Regulatory changes
203. The final area in which we propose changes
to the current regime in order to make it possible to realise
our vision is regulation. The success of the alternative strategy
we outlined in Chapter 3 would depend partly on a number of specific
shifts in the overall regulatory model for the broadband industry.
One shift in particular would be crucial: the establishment of
a set of open industry-led standards for both the physical network,
and the administrative interface between infrastructure and services
204. In order to understand the significance
of this measure, envisage the alternative broadband infrastructure
we depicted in Chapter 3, providing newly established open access
fibre-optic hubs within reach of every community. Now consider
a prospective infrastructure provider, weighing up the decision
to build and own a new access network, connecting the hub with
the local premises around it. This could be a community interest
group, an SME or a large-scale infrastructure provider. Beyond
the investment case itself, they will be aware of a number of
hypothetical risks and pitfalls, including the possibility that
once the network is built, no service provider will be willing
to provide a service to the premises on the network, effectively
rendering it stranded and redundant.
205. Unfortunately, this has happened. Digital
Region Limited, a regional FTTC network in South Yorkshire, provides
the textbook case, as Antony Walker, CEO, Broadband Stakeholder
Group, told us, "where a network was built and then the operator
really struggled, in fact failed, to get any big national ISPs
to provide service on its network." [108]
206. There are a number of reasons why an ISP
might find it uneconomic to provide a service over such a network.
These include:
· The administrative systems of the infrastructure
provider and the interface through which the ISP interacts with
them are a serious hurdle. Most seriously, an ISP will not be
able to countenance the administrative cost of dealing with a
proliferation of different such interfaces and procedures. Equally,
administrative systems have an impact on the procedures for matters
such as switching customers and handling complaints. For example,
when an issue is raised with the ISP about a fault whose source
is in reality something physical (e.g. a broken line), there needs
to be an easy mechanism in place for alerting the infrastructure
provider and arranging a repair visit.
· The technical standards of the products
which the ISP can offer over the infrastructure are partly determined
by the wholesale product offered by the infrastructure provider.
This creates two additional issues. First, the ISP will want these
technical standards to be harmonious with those of the wholesale
product it purchases elsewhere in the country, in order to avoid
a situation in which its retail product, and by extension its
brand, are tarnished through an inconsistency in their quality.
Second, the ISP will also be concerned that these standards remain
under continuous improvement, and again, as such, in harmony with
the wholesale product it purchases elsewhere from other infrastructure
207. The effect of these concerns is manifest
in the current broadband market, where ISPs face overwhelming
disincentives to provide services over fragmented and isolated
access networks. If unresolved, this will continue to be the case,
and would be a particularly acute issue under the alternative
strategy we propose in which a greater degree of competition at
the access network level would be a desired outcome.
208. One significant source of these issues lies
in the absence of a universally adopted and open set of standards
with definitions for both the technical specifications of the
network and its wholesale products, and for the operation, administration
and maintenance (OAM) systems which create the interface between
infrastructure and service providers. Universal adoption of such
a set of standards would have an important effect: it would make
it easierin fact actually make it possiblefor ISPs
to provide services over networks other than just those belonging
to the dominant, national providers.
209. The exact nature of these standards is important.
Unfortunately, specifying them, even in outline, can only be done
sensibly in light of a brief tour through another area of dry,
regulatory detail. This is contained in Box 6.
(1) is open, and industry-led
(2) is universally adopted
(3) contains a technical specification for:
(a) the physical network itself;
(b) the wholesale products it should provide;
(c) and stipulations regarding the operation, administration and maintenance (OAM) systems interface between infrastructure providers and ISPs.
The significance of a set of standards which succeeds in meeting these criteria is partly set out above in paragraphs 204-208, and is elaborated below.
There is, however, an existing regulatory tool with some of these characteristics. As such, unless its inadequacies are made clear, there may be a temptation for some to suggest that, to an extent, the criteria above have been met. We will briefly, therefore, describe this tool.
Its name is Virtual Unbundled Local Access (VULA). VULA is a requirement placed on Openreach by Ofcom. Ofcom would normally require full physical unbundling of Openreach's local access network, in line with European Commission guidelines. As mentioned in Box 5, the benefit of full physical unbundlingand the reason for the European Commission to require itis that it enables any ISP to take control of a single, independent connection from the exchange to a premises. As the connection is physically unbundled, the ISP can physically attach their own active equipment to each end, and that, in turn, is the basis on which they are able to tune the service they provide over it. Without full physical unbundling, on the other hand, ISPs cannot physically install their own equipment, and lose, therefore, their ability to tune and differentiate their service from their competitors.
While the European Commission, and by extension Ofcom, normally require full physical unbundling, there are cases where this is accepted as impracticable.[109] One has already been mentioned: PON (see Box 5), which is the FTTP network technology in which Openreach is investing; another arises in Openreach's FTTC network. While in this latter case, full physical unbundling is now technically achievable, in order to achieve it, an ISP would face the prohibitive cost of installing their own complex, active equipment (specifically, a Digital Subscriber Line Access Multiplexer, or DSLAM) in the cabinet; a cabinet serves less than 300 subscribersthere is no commercial justification for each ISP to install this equipment in the cabinet even if there were space available. As a result, in these two cases (where Openreach is investing in PON, and in its FTTC access network), full physical unbundling has been accepted to be impracticable, and Ofcom requires Openreach to offer Virtual Unbundled Local Access (VULA) instead. To reiterate, VULA refers to a requirement placed by Ofcom on Openreach; it is a regulatory tool.
Openreach, in implementing this requirement, has developed a specific wholesale product called Generic Ethernet Access (GEA). In summary, GEA is a wholesale product which ISPs can buy from Openreach; GEA is an implementation of the VULA requirement placed on Openreach by Ofcom because of the impracticability of Openreach offering full physical unbundling over its PON and FTTC local access networks.
Returning to the standards set out at the top of this Box, which would help pull down a major barrier to the ability of ISPs to provide services over networks other than those belonging to the major, large scale providers, it should now be understood that GEA, which implements VULA, does not meet all of the criteria we mention for these standards.
The most important criterion which GEA fails to meetquite fundamentallyis the first (that the standards be open and industry-led) which, by extension, means that it cannot meet the second (be universally adopted). GEA is a closed, proprietary specification.
210. While it is outside the scope of this report
to define precisely what an open set of standards should specify,
a set of industry-defined standards does already exist which,
in our view, provide a very good model. These are the Active Line
Access standards (ALA) fostered by Ofcom and defined by the UK's
Network Interoperability Consultative Committee (NICC), a technical
forum for the UK communications sector that develops interoperability
standards for public communications networks and services in the
UK. They are designed to provide a standard interface marrying
the needs of Communications Providers and Infrastructure providers
in the UK, and meet all of the requirements mentioned in Box 6,
barring universal adoption: Openreach, of course, applies its
own proprietary specification, Generic Ethernet Access (GEA);
see Box 6 for more detail.
211. As is made clear in Box 6, Active Line Access
distinguishes itself from Generic Ethernet Access on a number
of fronts. As Chi Onwurah, MP for Newcastle upon Tyne Central,
former Head of International Technology Strategy, Ofcom, told
"The most obvious difference is that GEA is
a set of proprietary specifications defined by BT Openreach
while ALA is a set of openly standardised specifications defined
by industry consensus through NICC."[110]
212. This distinction is equally as obvious as
it is important. As Chris Gallon, Ethernet Working Group Chair
at the NICC told us:
"This difference in open standard rather than
BT product is important because a small operator cannot implement
GEA but they can implement ALA."[111]
213. In other words, the universal adoption of
an open set of standards like Active Line Access is absolutely
crucial in enabling local access network providers without national
scale to compete with large-scale national networks like that
of Openreach which envelope many parts of the country, and at
present apply their own exclusive, proprietary specification,
inaccessible to others.
214. While there are a number of detailed technical
distinctions between GEA and ALA, and differences in how they
meet the letter and the spirit of Ofcom's VULA regulations, such
detail is outside the scope of this inquiry. We do not necessarily
suggest that Active Line Access provides a perfect set of standardsindeed
any such standards will need the flexibility to adapt to commercial
and technological changes. However, ALA seems to provide a good
initial standard, and a good model for the open standardisation
process which is manifestly required
215. It still remains to conclude exactly what
Ofcom should do. In fact, there are a number of mechanisms at
Ofcom's disposal to bring about the universal adoption of open,
industry-standards like ALA. We will briefly mention three of
these: General Conditions of Entitlement, SMP obligations and
gentler encouragement and facilitation of the industry.
216. First, under the European Communications
Framework (as enacted through UK legislation), Ofcom has the power
to impose conditions on all providers of communications networks
and services (known as General Conditions of Entitlement). Such
conditions can include an obligation to comply with relevant national
or international standards, such as General Condition 2 on Standardisation
and Specified Interfaces, which facilitates interconnection between
providers in order to promote competition. Ofcom can impose such
obligations to fulfil its duties to further the interests of citizens
and consumers, where Ofcom deems such conditions to be objectively
justifiable, not unduly discriminatory, proportionate and transparent
in relation to what they are intended to achieve. Were Ofcom to
judge it appropriate to do so, Ofcom could impose an obligation
on all providers of wholesale local access services to comply
with ALA or an analogous set of open, industry-led standards.
217. Second, Ofcom can impose specific conditions
on providers, where they are found to have significant market
power (SMP) in a relevant market. Although using this mechanism
inevitably means any such obligations would not apply universally,
we note that this may not actually obstruct universal compliance
with them. While this mechanism may not provide Ofcom with the
means to impose the adoption of these standards on those without
SMP, recall that it is those without a dominant market position
who are likely to find it entirely in their interest to adopt
such standards anyway, as they help to level the playing field.
As such, it is likely only to be necessary for Ofcom to use coercive
measures to impose their adoption on those like Openreach, who
do have SMP in relevant markets. Using SMP remedies, Ofcom can
impose an obligation to adopt these standards where it counts.
218. Finally, Ofcom can use its 'soft power'
to convene telecoms stakeholders, facilitate dialogue and encourage
the take up of open, industry-led standards more gently.
219. We recommend that Ofcom draw on one of
the mechanisms at its disposal to encourage, if not require, the
universal adoption of standards like Active Line Access, if not
ALA itself, which are open, and industry-led, and contain a technical
specification for the physical network itself, the wholesale products
it should provide, and stipulations regarding the operation, administration
and maintenance (OAM) systems interface between infrastructure
providers and ISPs. The universal adoption of such standards would
do much to level the playing field between alternative infrastructure
providers and would help to stimulate competition at the access
network level.
220. The institution of the standards raised
in the foregoing discussion would have a significant, mitigating
effect on the disincentives which confront ISPs considering providing
a service over dispersed and isolated networks. We recognise,
however, that even once these standards are in place, ISPs would
face a number of other challenges, equally likely to discourage
them from providing services over such networks. Chief among these
is the commercial viability of offering services over networks
with a small number of potential customers. This is an important
issue in its own right, but is not a regulatory problem, and does
not have a regulatory solution. Accordingly, we discuss it further
in Chapter 5, where we describe the realisation of our alternative
vision in greater depth.
221. An area in which a change in regulatory
approach could have a significant impact on the ability of different
infrastructure providers to competeand which would form
an important part of the regulatory backdrop of our alternative
proposalrelates to the provision of access to passive infrastructure
such as ducts and poles. At present, Ofcom requires that Openreach
provide open access to its ducts and poles at a regulated price.
This manifests itself in a product Openreach offers to its competitor
infrastructure providers, called Physical Infrastructure Access
(PIA). It provides prospective infrastructure providers with access,
not to any fibre, but to the passive infrastructure through which
new fibre can be run. By using these existing passive elements
of infrastructure, other providers can lay their own access networks
from an exchange, for example, to the community or end-user; once
they have done so, they would arrange for a connection to backhaul
from the exchange and be able to offer wholesale and retail products
over the new access infrastructure which they then own.
222. At face value PIA would appear to provide
a powerful stimulus to competition in the access network; it is
commonly recognised that 80% of the cost of laying access networks
lies in the civil works,[112]
which to a significant extent can be avoided altogether by using
existing passive infrastructure.
223. PIA, however, comes with a number of important
restrictions. In origin, PIA was designed by Ofcom as a remedy
to Openreach's SMP in the fixed line, local access market. By
design, therefore, it has been constrained so as not to have any
impact on other adjacent markets as Ofcom defines and segments
them. Accordingly, networks built using PIA are not currently
permitted to provide middle mile backhaul, leased line services
to businesses or backhaul for mobile and wireless masts; they
are restricted to supporting fixed line services in the local
access market.[113]
224. The effect of these restrictions, however,
appears, in the end, to be a significant limitation on the potential
of PIA to provide stimulus to competition in the local access
network. In fact, in its recent Business Connectivity Market
Review, Ofcom acknowledges the following argument which had
been put to it by a number of stakeholders in the foregoing consultation:
"the current usage restrictions of PIA could
place bidders of public funds available from Broadband Delivery
UK (BDUK) to support investment in superfast broadband infrastructure
in less populated parts of the UK at a disadvantage relative to
BT who benefits from economies of scope"[114]
225. By 'economies of scope', Ofcom means that
an investor laying a fibre network is, in the end, in the market
of optical connectivity, and will naturally seek to aggregate
demand from a range of the segmented markets that fall under that
broad umbrella; these will include domestic, mobile and business
markets. BT Group Plc, as a parent company of both Openreach and
BT's other divisions, has 'scope' across and is able to draw revenues
from all of these markets. Accordingly, the risk of investing
in local access networks is less intimidating to BT Group Plc
than it is to an infrastructure provider without the scope across
these revenue streams. Lifting the restrictions on PIA could help
provide other infrastructure providers with that breadth and thereby,
in our view, play a significant role in introducing more competition
at the level of the access network.
226. Ofcom keeps these considerations under review
and states straightforwardly that:
"We remain open to evidence that shows that
investment in next-generation access networks could be unlocked
if PIA could be used for leased lines services, to help us formulate
our policy in relation to such investment."[115]
227. However, at present, Ofcom is not minded
to do so for a number of reasons. These include real concerns
· "introducing PIA as a remedy into
the business connectivity market could undermine the remedies
that we have already imposed in that market."
· VULA already provides "an additional
option to support competition and investment in NGA networks"
· And finally, "in response to the
point about BT not being subject to any restrictions in the use
of its ducts and poles, we would note that the purpose of remedies
is to appropriately address the identified SMP in the relevant
market." [116]
228. In our view, these arguments are understandable,
but not persuasive. Under the Communications Act 2003, which implements
the EU telecoms package, Ofcom is generally bound to duties both
to promote competition and to promote investment, and in particular
in so doing, to secure "the availability throughout the UK
of a wide range of electronic communications services."[117]
229. On occasion, Ofcom's duties are likely to
conflict, and such an issue seems to arise in the case of PIA.
Ofcom's competition-based regulatory mechanism has led it to a
logically sophisticated segmentation and sub-division of the broadband
market, while its duties to promote investment would, on the evidence,
appear to suggest that a more open field is what is required.
230. Confronted by this, we fully appreciate
Ofcom's cautious stance. It has built up a coherent framework
for promoting wholesale competition and serving consumers' needs
through its remedies in the various sub-divisions of the broadband
market; it is perhaps reluctant, understandably, to undermine
231. Such a cautious stance may, we believe,
be usefully complemented by a more creative approach alongside
it. Its regulatory edifice is not to be preserved for its own
sake, and where a conflict emerges between its existing remedies
to promote competition and those it might draw on to promote investment,
it may be that a root-and-branch reconsideration of the relationship
between the two and of the entire framework is required. This
is not an easy job, but it is Ofcom's responsibility and it could
lead to a clearer, more coherent vision of the total market. As
an OECD report concluded: "segmentation of the market may
be excessive, resulting in an overly complex regulatory environment."[118]
232. We understand Ofcom's cautious stance
with regard to the removal of restrictions on Physical Infrastructure
Access. However, we urge Ofcom to give the benefits of doing so
full consideration.
233. In our view, the benefits of opening
up the restrictions on PIA are likely to be significant, particularly
were policy to be re-oriented towards the establishment of open
access fibre-optic hubs, as we advocate. Removing the restrictions
on PIA may, of course, have knock-on effects for the effectiveness
and coherence of other aspects of the overall regulatory edifice.
We, therefore, recommend that Ofcom evaluates alternative approaches
to the regulation of the broadband market as a whole, in line
with EU guidelines.
234. In the light of this discussion, we note
that since May 2011, Ofcom has had the power by virtue of Article
12 of the Revised EU Framework Directive, transposed into UK law,[119]
to impose regulatory obligations with regard to infrastructure
sharing in the broadband market without reference to SMP.
235. While Ofcom is cautious about putting these
powers into practice, as they are new and untested and any use
would have to be justified by a legally robust proportionality
test, imposing regulatory obligations on the basis of Article
12 may have a number of benefits, including but not limited to:
· Allowing Ofcom to impose regulatory obligations
on the basis of a broader set of considerations than merely SMP,
e.g. public interest and its duty to promote investment to secure
the availability of a wide variety of electronic communications
services throughout the UK;
· Adapting its regulatory obligations to
marry with Government policy, where this is proportionate;
· Removing the imperative to maintain the
distinction between fixed and mobile access markets, which is
increasingly illusory.
236. In light of the potential benefits, we
recommend Ofcom actively considers the possible implications of
putting its Revised EU Framework Directive Article 12 powers to
use, by undertaking an Impact Assessment of doing so, including
an open public consultation. Of course, some of Ofcom's existing
remedies in the broadband markets may be rendered ineffective
or incoherent by implementing these powers. In consulting on their
use, therefore, Ofcom should make positive proposals for how these
issues would be overcome.
Q440 Back
Miles Mandelson Back
Defra, Rural Community Broadband Fund (RCBF): Applicants' Handbook
- Expression of Interest Round Two, 10 May 2012 to 6 July
2012. Available online:
http://rdpenetwork.defra.gov.uk/assets/files/New%20Offer/DEF-RDPE-RDPE-Bk-R2_WEB.pdf Back
Q 583 Back
Vodafone Back
Q 509 Back
Vodafone Back
Q 511 Back
DCMS and BIS, Britain's Superfast Broadband Future, December
2010. Available online: http://www.culture.gov.uk/images/publications/10-1320-britains-superfast-broadband-future.pdf Back
European Commission, EU Guidelines for the application of state
aid rules in relation to the rapid deployment of broadband networks.
Available online:
http://ec.europa.eu/competition/consultations/2012_broadband_guidelines/en.pdf Back
DCMS, Mobile Infrastructure Project: Industry Stakeholder Engagement,
January 2012. Available online: http://www.culture.gov.uk/images/publications/Mobile_Infrastructure_engagement_Rel_1_0.pdf Back
DCMS, Mobile Infrastructure Project: Industry Stakeholder Engagement,
January 2012. Available online: http://www.culture.gov.uk/images/publications/Mobile_Infrastructure_engagement_Rel_1_0.pdf Back
Q 780 Back
Ofcom, Communications Market Report 2012, 18 July 2012.
Available online: http://stakeholders.ofcom.org.uk/binaries/research/cmr/cmr12/CMR_UK_2012.pdf Back
O2 news release, 'Making calls has become fifth most frequent
use for a smartphone for newly-networked generation of users,'
29 June 2012. Available online: http://news.o2.co.uk/Press-Releases/Making-calls-has-become-fifth-most-frequent-use-for-a-Smartphone-for-newly-networked-generation-of-users-390.aspx Back
DCMS, Mobile Infrastructure Project: Industry Stakeholder Engagement,
January 2012. Available online: http://www.culture.gov.uk/images/publications/Mobile_Infrastructure_engagement_Rel_1_0.pdf Back
Ofcom press notice, 'Ofcom unveils plans for 4G auction of the
airwaves,' 24 July 2012. Available online: http://consumers.ofcom.org.uk/2012/07/ofcom-unveils-plans-for-4g-auction-of-the-airwaves/ Back
Financial Times, 'Fujitsu withdraws from broadband funding',
10 July 2012. Back
Q 555 Back
DCMS, Broadband delivery programme: Superfast pilots - Lessons
learned report, November 2011. Available online: http://www.culture.gov.uk/images/publications/BroadbandPilots_lessons_learnt-Dec2012.pdf Back
GPON is a variety of PON; see glossary. Back
TalkTalk 2 Back
OECD, Convergence and next generation networks, 2008, Available
http://www.oecd.org/dataoecd/25/11/40761101.pdf Back
Q 595 Back
In June 2010, the European Commission released a press notice,
announcing it had "decided to accept, in view of the specific
circumstances of the case, the proposal of UK telecoms regulator
Ofcom to oblige telecoms operator BT to provide 'virtual' access
to its optical fibre infrastructure to alternative operators."
Source: EU Commission press release, 'Commission accepts UK regulator
proposal to mandate virtual unbundling of BT's fibre networks
but requests full unbundling as soon as possible,' 2 June 2010.
Available online:
Chi Onwurah Back
Chris Gallon Back
DCMS and BIS, Britain's Superfast Broadband Future, December
2010. Available online: http://www.culture.gov.uk/images/publications/10-1320-britains-superfast-broadband-future.pdf Back
Ofcom, Review of the Wholesale Local Access Market: Statement
on Market Definition, Market Power Determinations and Remedies,
October 2010. Available online:
http://stakeholders.ofcom.org.uk/binaries/consultations/wla/statement/WLA_statement.pdf Back
Ofcom, Business Connectivity Market Review, 18 June 2012.
Available online: http://stakeholders.ofcom.org.uk/binaries/consultations/business-connectivity/summary/condoc1-4.pdf Back
ibid. Back
Ofcom, Review of the Wholesale Local Access Market: Statement
on Market Definition, Market Power Determinations and Remedies,
October 2010. Available online: http://stakeholders.ofcom.org.uk/binaries/consultations/wla/statement/WLA_statement.pdf Back
ibid. Back
OECD, Convergence and next generation networks, June 2008.
Available online: http://www.scribd.com/doc/18264128/Convergence-and-Next-Generation-Network Back
The Electronic Communications and Wireless Telegraphy Regulations
2011(1210/2011). Available online: http://www.legislation.gov.uk/uksi/2011/1210/schedule/1/paragraph/38/made#schedule-1-paragraph-38-b Back
Chi Onwurah Back
Chris Gallon Back
DCMS and BIS, Britain's Superfast Broadband Future, December
2010. Available online: http://www.culture.gov.uk/images/publications/10-1320-britains-superfast-broadband-future.pdf Back
Ofcom, Review of the Wholesale Local Access Market: Statement
on Market Definition, Market Power Determinations and Remedies,
October 2010. Available online:
http://stakeholders.ofcom.org.uk/binaries/consultations/wla/statement/WLA_statement.pdf Back
Ofcom, Business Connectivity Market Review, 18 June 2012.
Available online: http://stakeholders.ofcom.org.uk/binaries/consultations/business-connectivity/summary/condoc1-4.pdf Back
ibid. Back
Ofcom, Review of the Wholesale Local Access Market: Statement
on Market Definition, Market Power Determinations and Remedies,
October 2010. Available online: http://stakeholders.ofcom.org.uk/binaries/consultations/wla/statement/WLA_statement.pdf Back
ibid. Back
OECD, Convergence and next generation networks, June 2008.
Available online: http://www.scribd.com/doc/18264128/Convergence-and-Next-Generation-Network Back
The Electronic Communications and Wireless Telegraphy Regulations
2011(1210/2011). Available online: http://www.legislation.gov.uk/uksi/2011/1210/schedule/1/paragraph/38/made#schedule-1-paragraph-38-b Back
OECD, Convergence and next generation networks, June 2008.
Available online: http://www.scribd.com/doc/18264128/Convergence-and-Next-Generation-Network Back
The Electronic Communications and Wireless Telegraphy Regulations
2011(1210/2011). Available online: http://www.legislation.gov.uk/uksi/2011/1210/schedule/1/paragraph/38/made#schedule-1-paragraph-38-b Back


text:
Property Reference 115515
In a beautiful natural environment, just 2 kilometres from the Mediterranean Sea, this stunning 3-bedroom house in Cyprus is for sale and creates an outstanding opportunity to purchase a permanent residency or a holiday home in the village of Pissouri, near Limassol, on the island of Cyprus.
The scenic village of Pissouri village is about 30 kilometres west of Limassol city centre and is in between the cities of Limassol and Paphos. With sights of exceptional natural beauty, combining both mountain and sea, the village of Pissouri has become one of the most significant tourist areas of the island and an idyllic place to invest in properties in Cyprus. It is a village with all sorts of comforts and conveniences, which is distinguished for its traditional temperament and the hospitality of its locals. This Cyprus property is one of the exemplary properties for sale in Pissouri and also presents an exquisite opportunity for non-European citizens to gain a permanent residence permit visa in Cyprus.
The property in Cyprus for sale consists of 3 bedrooms, a kitchen with a combined living area and dining room, a bathroom, a washroom, and an en-suite bathroom in the master bedroom, thus making it a unique find amongst numerous properties for sale in Pissouri village (near Limassol), which are perfect for anyone looking to buy property in Cyprus for permanent residency or a holiday home. With impressive mountain views and surrounded by greenery, this house exudes an atmosphere of relaxation and tranquility. Furthermore, the finely-designed fireplace, the lush green garden and the parking place add to the numerous characteristics and further highlight the elegant design of the home for sale in Pissouri village (Limassol - Cyprus).
Stately beauty perfectly describes the impressive facade with its stone-sheathed walls, whilst the private swimming pool further enhances the luxury and comfort of this house for sale in Pissouri, Limassol - Cyprus. It is a property well-fitted for families and individuals who want to buy a house for permanent residency or a holiday home in Cyprus, given also its proximity to Limassol - a cosmopolitan coastal city of Cyprus. With mountain views yet at also a short drive away from the Mediterranean beaches, this property for sale in Pissouri village, requires great consideration as it promises a lifestyle of luxury in Cyprus.

subset: commoncrawl


text:
Muskrat (Ondatra zibethicus) at Oxbow Nature Study Area, Feb. 26, 2015. Photo: Kelsey McCutcheon.
Common Muskrat
Ondatra zibethicus
- A semi-aquatic rodent.
- Brown, dense, waterproof fur.
- Long, scaly tail used like a rudder when swimming.
- Less than two feet long from nose to tail.
Record Observations
Species Description:
Muskrat, semi-aquatic rodents that are widespread and common in North American waterways, are named for their smell; they have two scent glands located at the base of their tail, and leave their "musky" scent around their dens and trails during breeding season.
Muskrat have tiny front feet used for digging and holding food items, and semi-webbed hind feet for swimming. They feed mostly on plant foods, especially the stems of cattails, and have large front teeth for gnawing. A "valvular mouth" with lips that close behind the front teeth allows the muskrat to gnaw on underwater vegetation without inhaling water (Wilner, Feldhamer, Zucker and Chapman 1980).
Some muskrat live in holes in riverbanks, and others build houses of vegetation. They may have different burrows for sleeping, eating and nesting, with multiple entrances located below water level. To avoid predators (including mink and raccoons), muskrat prefer habitat with water that is deep enough to dive into. They can stay underwater for up to 20 minutes (Wilner, Feldhamer, Zucker and Chapman 1980).
They have litters of 4-8 (usually 6-7), and may give birth to multiple litters per year — from late spring through early fall (Wilner, Feldhamer, Zucker and Chapman 1980). Muskrat are most active at night, but can sometimes be seen during the day. Look for their tracks in the mud along the river banks. Along the Truckee, Muskrat can be seen in the pond at Oxbow Nature Study Area. If you see them somewhere else, please record an observation!
Additional Images:
Photos & Information needed!
Do you have information on Truckee River Muskrat, or original photographs taken locally? If so, please contribute photos and observations here, or email information to email@example.com. Thanks!
Hall, E.R. 1995. Mammals of Nevada. Reno: University of Nevada Press. (Originally published 1946)
Orr, Robert T. 1949. Mammals of Lake Tahoe. California Academy of Sciences, San Francisco, CA.
Willner, G.R., Feldhamer G.A., Zucker, E.E., and Chapman, J.A. 1980. Ondatra zibethicus, Mammalian Species No. 141, pp. 1-8. http://www.science.smith.edu/msi/pdf/i0076-3519-141-01-0001.pdf


text:
Please read the site regulations carefully. Waivers must be filled out and dues must be paid and given to an appropriate person prior to flying the site.
All memberships expire December 31. A pilot can only purchase three Day Passes per year, after which they may purchase a Season Pass.
You can contact Tony Covelli at (845) 647-4917 for more information.
2019 Site Dues & Fees
|Type of Pass
|January 1 – February 28
|$180 Single, $270 Couple*
|March 1 – September 30
|$200 Single, $300 Couple*
|September 30– December 31
|$160 Single
|November 1 – December 31
|$20 per day
|Day Pass
|$20 per day
*married pair or family member.
Please make checks payable to:
Tony Covelli
Please mail signed waivers and checks to:
Tony Covelli
80 Hang Glider Rd.
Ellenville, NY 12428


text:
Raman signals are proportional to concentration and are extremely robust (i.e. no energy transfer between labels such as in fluorescence). It is thus possible to mix a high number of Raman-based labels without affecting their spectral signatures and intensity, making them perfect candidates for simultaneous multicomponent analysis. They can be used in applications such as biomarker identification, protein interaction studies, immunological profiling and vaccine development, among others.
Modifying the Raman label
Modification of the dyes@CNT-COOH labels can easily be achieved through the carbodiimide-mediated amidation. The carboxylic acid group (-COOH) of the label is activated by carbodiimide and will couple with any primary amine (-NH2). On proteins and antibodies, primary amines are present in lysine residues and at the N-terminus of polypeptide chains and can react with the Raman label to form an amide bond. This ecofriendly and biocompatible reaction is done in water and is depticted below.
Biotin-Avidin interaction
Our Raman labels are also available with a biotin moetie. Biotin and avidin form the strongest non-covalent complex known between ligand and protein. As seen below, one avidin will bind 4 biotins with a binding constant (Kd) of 10-15 M. Many applications such as enzyme-linked immunosorbent assay, immunohistochemistry, protein arrays, and cell sorting amongst others, utilize this interaction. Kits can be purchased commercially to modify biotin or streptavidin. Our biotinylated Raman labels will attach to any streptavidin/avidin or anti-biotin modified antibody, receptor, or peptide allowing the detection of a target molecule by Raman spectroscopy.
Our Raman labels offer new properties compared to traditional fluorescent tags. For exemple, as illustrated below, multiple target molecules can be tagged on the same cell with unequivocal identification of each Raman label because there is no energy transfer between the labels and they offer quantitative analysis. This multiplexing capability reduces sample size, time of analysis and volume of reagent required. The very stable read-out signal of the Raman label also permits prolonged acquisitions, and repeated illumination of the same surface. For instance, one could follow a target over the course of weeks. Raman labels can also be used as non-specific labels since they readily penetrate the cell membrane.


text:
Zero Halogen Heatshrink Sleevings
Our zero-halogen heatshrink sleeving is made from a halogen-free, flexible, flame retardant, heat shrinkable material. It has been specially developed for transportation, marine, offshore and construction markets. Common applications include insulation, marking, strain relief, mechanical protection and colour coding. Low smoke, low toxicity and halogen-free. UL File No. E180908.


text:
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Ever heard of a place called The Heart Attack Grill? Sound appetizing? Would YOU EAT THERE? It is located inRead more
Have you ever wondered about if something was in the food you're eating that's not suppose to be there. ImRead more


text: BUSINESS Grammys sing sweetly Sun. for CBS 4:00 AM PST 2/12/2007 by Paul J. Gough , AP FACEBOOK TWITTER EMAIL ME Empty NEW YORK -- The Grammy Awards regained some of its lost luster in a return to Sunday night, a year after the professional music awards were thrashed by the amateurs over at "American Idol."The 3 1/2-hour CBS telecast averaged 20.1 million viewers and an 8.3 rating/20 share in adults 18-49, according to preliminary estimates released Monday by Nielsen Media Research. It was the best ratings showing since 2004 in both viewership and adults 18-49.The Grammy telecast was up 18% from last year's all-time low of 17 million viewers, when it aired on a Wednesday against "American Idol" and "Idol" brought upward of 29 million viewers against it. It also was up 17% in the adults 18-49 demo from last year's 7.1/18, and up similar percentages in both adults 18-34 and adults 25-54. Compared with 2005, the last time the Grammys aired on a Sunday night, last night's telecast was up 7% in viewers (18.8 million) and up 2% in adults 18-49 (8.1/19).The telecast peaked at 9 p.m. with 21.8 million viewers. Sunday night's ratings were still down significantly compared with the 26.3 million viewers who watched the Grammys in 2004.But the telecast was easily the biggest thing on television Sunday night, surpassing ABC's "Desperate Housewives" (18.1 million, 7.1/15). "Housewives" was down 14% compared with its season average of 8.3/18, though it was up from its last original episode. Freshman drama "Brothers & Sisters" (11.3 million, 4.5/11) was down 10% from its season average of 5.0/12.Taking a bigger hit from the Grammys was NBC's two-hour, live "Grease: You're The One That I Want" (6.5 million, 2.0/5), which was down 35% from its season average of a 3.1/7. "The Apprentice" (6.4 million, 2.4/5) fell to its lowest original adults 18-49 rating in its history. "Crossing Jordan" (8.3 million, 2.5/6) also was an original.At 7 p.m., "60 Minutes" (14.2 million, 2.9/8) was the hour's top show in viewership, while the first of a two-part "Extreme Makeover: Home Edition" (10.9 million, 3.9/11) won in the demo. But "Extreme Makeover" jumped to 16.9 million viewers and a 6.2/14 in the demo in its second hour at 8 p.m.Fox had originals of "The Simpsons" (8.3 million, 3.8/9) and "King of the Hill" (7 million, 3.2/7) along with "Family Guy" (7.9 million, 3.9/8) and "American Dad" (6.6 million, 3.2/7).Nightly averages: CBS (19 million, 7.1/17); ABC (14.3 million, 5.4/13); NBC (6.8 million, 2.2/5); Fox (6.5 million, 3.0/7); and the CW (2.4 million, 0.9/2). FACEBOOK TWITTER EMAIL ME Paul J. Gough email@example.com @thr AP firstname.lastname@example.com @thr


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The Top 12 Valentine's Day Gifts for Men
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Getting your man the perfect gift for Valentine's Day can be a particularly difficult and daunting task. How much do you spend? Is it a long term or short term relationship? Does that make a difference? We at Snizl believe that no matter how big or small the gift is, it's the time you spend that [Read more…]


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Job reference: 00529
Location: Leeds
Closing date: 07/01/2018
Salary: £79,415 - £100,431
Employment type: Permanent
Hours per week: 37.5
An exciting opportunity has arisen for an Associate Director of Communications who will be responsible for providing strategic leadership and direction to the teams delivering marketing campaigns, media relations, social media delivery, internal communications, publications and events.
About the role
This role is part of the senior leadership team within the Communications Directorate at NHS Digital, working with the Director of Communications. You will:-
Provide excellent leadership and coaching to the communications team.
Ensure the communication function has the right structure, staff and skills to deliver against our business objectives, in line with the Government Communication Service Modern Communications Operating Model.
Deliver our communications strategy, ensuring there is an effective planning and prioritisation process in place for communication including insight development and evaluation.
Deputise for the Director of Communications and work closely with system partners in the delivery of communication.
Manage and ensure delivery against the communication business plan and communication improvement plan being accountable for financial performance and demonstrating value for money.
Manage the Communication Business continuity plan and operational response in a crisis.
The role will ensure the team delivers high quality, professional advice to the business, operating within the framework set out in the NHS Digital Communication Strategy.
About you
Relevant specialist degree in communications or equivalent senior, professional experience.
Evidence of ongoing professional, management and leadership development.
Membership of relevant professional associations for example Chartered Institute of Public Relations (CIPR).
Significant experience of leading and managing communications teams in a senior communications role in a complex public, private or voluntary sector environment.
This assignment opportunity is available at our Leeds office, although there will be a occasional requirement to travel to our London offices.
The closing date for this job has now passed.


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Well, here we are again.
Another January and another devastating Ravens playoff loss.
This one hurts.
Maybe not as much as last year's loss to the Steelers or the loss to the Colts in January 2007, but this still hurts, none the less.
Victory was in hand, for at least a split second, before Sterling Moore made a flukey motion for the ball and knocked it out of the hands of Lee Evans.
Despite that drop, we always had a field goal kick in our back pocket to force the game into overtime. But even that wasn't in the cards, as Billy Cundiff raced out onto the field after being confused, distracted, whatever, and shanked it.
Not only did Ravens fans have to suffer through another playoff loss, they ran the gamut of emotions -- from victory, to the relief that we can still tie the game, to losing the game. All within twenty seconds.
And that's why being a Ravens fan is so hard. They play with your soul like Chris Farley played with that biscuit in Tommy Boy. I had prepared myself for the realistic outcome of a loss to avoid the devastating feeling that always accompanies a playoff loss. After all, going to New England and beating Tom Brady and Bill Belichick is a daunting task.
But as the game progressed and the possibility of winning became greater as each minute ticked off the clock, and Joe Flacco drove the offense down the field in the last minute of the game, I knew that any preparation I'd made to deal with a loss was out of the window.
So what's left now is the thought of what could have been and the image of what actually happened. A crushing contrast.
And that, in a nutshell, is what being a Baltimore sports fan is all about. What exists in our minds compared to a sobering reality. What splendid agony.
Outside of the "it happened too fast" Super Bowl that the Ravens won in 2000, Baltimore sports fans have known mostly nothing but misery over the last 30 years.
From the Colts leaving town for Indianapolis – from the Orioles losing 21 straight games to start the 1988 season – from Jeffrey F*cking Maier – from the O's racking up 14 losing seasons in a row after 1997 – from tragic Maryland losses to Duke basketball – and finally from the stinging playoff defeats that have mounted for the Ravens since 2001.
Compare that to the fortune that Boston has experienced in the last ten years. Each of their four sports teams has won at least one championship in that time. The Red Sox and Patriots have five titles between them, and the Patriots will be going for another in two weeks.
That is where the torture exists for Ravens fans in that loss. We wanted that feeling so bad. With the Orioles continuing to wallow in the annals of the American League, we have no choice but to put all our eggs into the Ravens basket. But no. Boston fans are celebrating another championship game appearance a mere seven months after the Bruins won the Stanley Cup.
I know Baltimore has a long way to go to equal the epic misery of Cleveland sports fans. But we're getting close. And I know that doesn't offer fans any consolation, but at least we can embrace our tragic sports heritage instead of dreading it.
What the hell else are we gonna do?


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This Easy Fruit Dip recipe has only 4 ingredients and takes just a few minutes to whip together. It is smooth and creamy with a hint of citrus. It is a delicious complement to fresh fruit.
Easy Cream Cheese Fruit Dip
This Easy Fruit Dip is always a hit at potlucks, parties, and for an after school snack. It's a great way to entice kids to eat more fruit. A little creamy sweetness goes a long way to enhance the natural flavors of the fruit. The fruit dip should be made at least an hour before serving and will last up to a week in the refrigerator.
How to soften cream cheese – 3 methods
It is very important to make sure the cream cheese is at room temperature when making the dip. If you use it straight from the refrigerator, no matter how long it is beaten there will still be little lumps. No one wants lumps in their fruit dip! There are a few methods I like to use for bringing cream cheese to room temperature depending on how much time I have.
- The first method is to simply set the cream cheese out on the counter for 30 minutes to an hour in its original packaging. It shouldn't be left out much longer than an hour.
- The second method is a hot water bath. Fill a bowl with hot tap water and place the cream cheese, still wrapped in foil, in the bowl for 5-10 minutes to bring it to room temperature. If the foil has been opened, place the cream cheese in a resealable plastic bag before placing it in the water bath.
- The third method is to soften it in the microwave. This is my least preferred method because it can melt and overcook. Most microwaves have a "soften" setting. If not, cut 8 ounces of cream cheese in cubes and microwave on high for 15-20 seconds. Stir. If not softened to the desired consistency, continue to microwave at 10 second increments until completely softened. This recipe makes approximately 2 cups of dip.
Fresh Fruit Tray Ideas
This fresh fruit dip is smooth and creamy with a hint of citrus. It complements the flavor of every kind of fruit. These are some of our favorite fruits to use with this dip. Fresh fruit, in season and bought locally, is always the best. Even the best fruit dip can't compensate for fruit that isn't ripe.
- Apples
- Bananas
- Orange wedges
- Strawberries
- Pineapple
- Kiwifruit
- Grapes
- Watermelon
- Cantaloupe
- Honeydew
- Peaches
- Pears
- Cherries
- Raspberries
- Blackberries
How to Make Easy Cream Cheese Fruit Dip
- 8 oz cream cheese softened
- 7 oz marshmallow cream
- 2 Tbsp frozen orange juice concentrate
- 1 Tbsp orange zest grated orange peel
- Fresh fruit - see ideas above
- Beat cream cheese with a hand mixer or stand mixer until smooth.
- Add remaining ingredients and mix well.
- Chill 1 hour in the refrigerator or until ready to use.
- Serve with fresh fruit.
- Hand Mixer


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Who remembers the heady days of the adult colouring book trend? (Just to be clear, that's colouring books aimed at adults rather than x-rated colouring material – although colouring books of that nature do exist too…if you want to colour in swear words or kama sutra positions then you can!). There were times in 2015 and 2016 when adult colouring books dominated more than HALF of the top ten bestselling books lists. Felt tips were suddenly very cool. And if you weren't spending your evenings keeping between the lines of a secret garden/New York City skyscraper/Hogwarts then were you even relaxing at all?
I never liked colouring as a child, it struck me as an incredibly boring pastime, so naturally I wasn't interested in having another go in my late twenties. But I understood the appeal of it. Anything that's "offline", relaxing and reminiscent of childhood is going to find a captive audience. After all, it was for those exact reasons that I recently found myself on Amazon ordering a jigsaw puzzle.
Now I don't think jigsaws are going to become the next big thing the way that colouring books did; you can't do a jigsaw on the train to work and they require more than a fair bit of patience. But having just completed my first 1000 piecer, I've found myself a bit of a puzzle convert.
I wasn't sure whether to choose a 500 piece or 1000 piece puzzle for my first "adult attempt". I wanted it to be a challenge, but I didn't want to give up half way through and have a dining table covered in half finished corners for the next eight months. A lot of the puzzle designs I liked came in both 500 and 1000 piece variations but it was an anonymous Amazon reviewer who swayed me to go big: "You could buy the 500 piece version, but if it's not irritatingly hard then what's the point?". Quite! And I do prefer my relaxation to come with a heavy dose of intense frustration, wherever possible.
It took me a long while to actually start the puzzle after it arrived, I knew it was going to take over the lounge (not to mention MY WHOLE LIFE) and so I waited til the optimum Sunday to crack open the box and look for those elusive edges.
The first thing I noticed on emptying the box across the table was that 1000 pieces is quite a lot. Who would have guessed that hundreds upon hundreds of jigsaw pieces would amount to "a fair few"? Not me, evidently. I tried not to have a low level panic attack as the pieces spread out before me. This was relaxation, guys! A spa day for the mind!
I finally completed the outer edge and, slowly but surely, the rest of the puzzle took shape over the next few days and weeks.
Top tip! If you have two tables in fairly close proximity, I certainly found it easier at first to make the edges on one table and keep all the loose pieces on another.
As a card-carrying Parrot Obsessive, I enjoyed putting together the bird sections the most. Their beaks! Their wings! THEIR COLOURFUL PLUMES! And with no less than thirty-one birds to assemble, this was a fun part of the puzzle to prioritise. Recognising the species and knowing the colours helped, as I could get on with this part without constantly referring to the box (yes I am as cool as I sound) plus there was just the constant satisfaction of finishing each bird…even if the rest of the puzzle seemed an impossible beast.
What I hadn't appreciated when choosing this design, was that there are huge sections to this puzzle which can at times feel exactly the same – brown leaves, splashing waterfalls, intertwined branches. At one point I was convinced I had 400 identical green/brown pieces scattered across my dining table and that I may as well have bought one of those tortuous baked bean puzzles (WHO DOES THOSE?!), but with persistence, patience and a LOT of Radio 2…every empty space eventually became smaller and smaller. It was a glorious feeling.
The final completion of the puzzle was more satisfying than I could have expected, even if I did know that my handiwork was about to be smashed up and stuffed back into the box so that our table could become functional again. I was proud of my puzzle. I took lots of photos. There was a genuine sense of achievement and, more than anything, I wanted another puzzle to start.
I know jigsaws won't become "the new colouring", they require far more time, space and patience to complete and they cost a bit more (although not much more) too. But if you haven't jigsawed since you were a wee one then I'd definitely recommend having another go. They ARE relaxing, in their own all-consuming maddening way, and I'm sure a finished puzzle is more rewarding than a well-coloured landscape.
This specific puzzle, if you're keen, is this one by Gibsons. I bought it for £11.89 with free delivery. I was really happy with the quality and loved the design.
I certainly didn't expect to be entering my thirties with a newfound love for jigsaws, but here we are. I am officially a puzzler.
May all your edges be quickly located…and if in doubt, always check the bottom of your socks.


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Unlike other recent visual offerings, Sacramento punk-rap outfit Death Grips' music video for "I've Seen Footage" won't induce migraines. This time around, the trio opt for a montage of behind-the-scene snapshots, including pics from the studio and rehearsal, pretty girls and the aftermath of wild parties, and more than a few quick glances at random drug paraphernalia. Watch it below.
Death Grips first album of 2012, The Money Store, hits shelves on April 24th via Epic Records. You can stream it in full at SoundCloud.


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1 in stock
Species: Knightia eoceana #904
Age -Eocene ( 50 Million years old )
Location – Kemerer, Lincoln County, Wyoming
Size -1 1/2 " long ( fish )
Size – 2 1/4 "x 2 1/4" ( matrix )
Price $ 12
Display box comes with fish .
Species of fish is the most common fish found fossilized and is Wyoming's State Fossil..
Note: Seasonally some 58 million years ago, in the Green river region of Wyoming, torrential rains would occur in the mountains. The rain would flow down the mountain sides and then wide shallow lakes would form in the valley below. When the dry season would occur these lakes would dry up due to evaporation (similar to certain parts of Africa today). Millions of fish would die in this short period of time. This climatic cycle happened over a 20 thousand year period. Layer upon layer of mud was deposited over these years entombing all these fish. At a much later date volcanic activity uplifted this area to expose all those layers of fossil fish.
Additional information
|1 lbs
|4 × 4 × 3 in


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Did I mention we finally got the sign to put up?? We are official. We are a tree farm Grow little seedlings, grow! (they are doing well)
This is where I like to spend time after school. Lately the weather hasn't cooperated. Stormy and rainy, but I am hoping it will turn off nice for the long weekend.
Bob takes his 'dog' Quarrie for a ride on the 4-wheeler...not often you will see a cat riding on one, but I think he is getting tired of the dogs getting all the attention..
Today I got home to find the kitchen cabinet open. Hmmmmm. Didn't leave it that way.
But, there on the floor near the cats dish was a tiny present. Dead mouse. Good boy Mac. He's the mouser and has been diligently checking in and out of the cabinets in the kitchen lately. Apparently he can hear the little devils when I have no clue...other than the torn paper lining the silverware drawer! I have had to put all the silver in the dishwasher twice..but Mac has also gotten 2 mice!
Good boy Mac.


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The Ruby-throated Hummingbird (Archilochus colubris) is a species of hummingbird.
The only breeding hummingbird in eastern North America, the Ruby-throated Hummingbird is more often mistaken for an insect than for another species of bird. The smallest bird encountered in its breeding range (3-3 ¼ inches), the Ruby-throated Hummingbird may be identified by its small size, green back and forehead, long bill, and off-white breast. Males have a striking red throat (called a gorget) and forked tail, while the female lacks this adornment and has a rounded tail. The Ruby-throated Hummingbird breeds across most of the eastern United States and southeastern Canada. In winter, many Ruby-throated Hummingbirds migrate across the Gulf of Mexico to winter in southern Mexico and Central America, while others spend the winter in south Florida and the Florida Keys. Small numbers of Ruby-throated Hummingbirds winter further north along both coasts of Florida into the Gulf States and the Carolinas. During the summer, Ruby-throated Hummingbirds breed in deciduous forest, woodland edges, and around human developments. This species winters in tropical forests. Ruby-throated Hummingbirds eat small insects and drink nectar from tubular flowers, and will often enter gardens and yards to feed from hummingbird feeders. It is a major pollinator in its breeding range. Ruby-throated Hummingbirds may most often be observed feeding from flowers and hummingbird feeders, where they may either hover or perch while feeding. It is also possible to observe Ruby-throated Hummingbirds defending feeders or productive patches of flowers, when they may engage in acrobatic mid-air dogfights with other hummingbirds. This species is primarily active during the day.


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Financial Advisor, Vice President
Mr. Resendez is a financial advisor at Cary Street Partners, LLC.
- UBS Wealth Management, Financial Advisor
- Presidio Asset Management, LLC, Chief Executive Officer, responsible for developing and executing the business strategies of the firm, all business development and institutional fundraising.
- National Conference on Public Employees Retirement System (NCPERS), Executive Director, responsible for coordinating all national legislative activities with legislative counsel, corresponding with member groups in every state and developing agenda and coordinating annual conferences, annual legislative conferences and strategic financial member conferences.
- Texas Permanent School Fund, Executive Director responsible for the development and implementation of all investment strategies and overseeing firm's personnel.
- San Antonio Fire and Police Pension Fund, Executive Director, established Board Policies and drafted all state legislation affecting system. Responsible for developing and implementing all financial strategies.
- St. Mary's University, J.D.
- University of Texas, BBA
- FINRA Series 7, 65 & 66
- email@example.com
- 210.477.7680 Office
- 210.887.0678 Mobile
- Download Vcard


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Nearly 750,000 people missed the deadline to file their Self Assessment tax return, running the risk of a £100 fine.
HMRC said that 10.7 million people filed on time, but that 6.5 per cent of those required to submit a tax return failed to do so by the deadline.
- How to set up as self-employed with HMRC
- Can I pay my tax bill with a credit card?
- HMRC reveal the worst tax return excuses and failed expenses claims
- Why do I need business insurance?
This is down on the seven per cent who were late in 2017.
How much could you be fined for missing the Self Assessment deadline?
Self-employed people who miss the Self Assessment tax deadline are theoretically liable for an automatic fine of £100, providing they file within three months of the deadline.
In addition, there are penalties for paying your tax bill late.
- If you're up to 30 days late, you'll be fined five per cent of the total tax due.
- After three months, you'll receive a £10 penalty for each further day overdue, up to a maximum of £900.
- At six months late you'll be charged another five per cent, and again at 12 months late.
The penalties for late payment are strictly enforced. However, there have been indications that the penalties for late payment are being relaxed.
In 2015, the Revenue said it would concentrate its penalties on "those who persistently fail to complete their tax returns and deliberate evaders," and is keen to "differentiate between deliberate and persistent non-compliers and those who might make an occasional error."
The government has also announced the planned introduction of a 'points' system, under which late filers will accrue points for infractions, similar to those added to driving licenses. When a points threshold has been reached, a fine will be given. It's thought that this system will be rolled out from 2019, beginning with VAT returns.
Shortly after the 2017 deadline, the Low Incomes Tax Reform Group encouraged late filers to appeal their fine if they had a genuine excuse. However, Self Assessment taxpayers who do appeal should be aware that HMRC may ask for evidence to back up their claim.
What are the other key self-employed tax deadlines?
As a self-employed person or small business owner, there's a range of important tax deadlines that you need to be aware of. It's not just Self Assessment – you might also need to deal with VAT returns, Corporation Tax, PAYE, and National Insurance Contributions.
Read more in our guide to tax deadlines for your business.
How can I make my tax return easier?
Completing your Self Assessment tax return can be a pain, and if it's your first time it might seem daunting.
To help, we've compiled the small business guide to Self Assessment tax returns, giving you comprehensive information on how and when to file, and some tips to make your return easier.
Is your business insured?
475,000 UK policies. Plus, a 9/10 satisfaction score. Why not take a look at our expert business insurance options - including public liability insurance and professional indemnity - and run a quick quote to get started?


text: Ask the Auditor. What to expect during your ISO Transition Audit Do you sometimes wonder how to prepare for your upcoming ISO Transition audit? The new ISO 9001 Standard has some key changes in the way a quality management system (QMS) is viewed as part of your organization's strategic direction. One of the Key changes is the requirement for Top Management to be more involved. Another change is the focus on Risk-based thinking and finally, the documentation requirements have been reduced. In the webinar, we will bring you some examples of the approach that auditors are using to determine what level of conformance to ISO 9001:2015 your QMS is demonstrating. We'll give you some examples of how clients are meeting these new requirements, and leave time to answer questions that you may have about what to expect, so that you can ask the Auditor about any concerns you may have about your upcoming Transition audit.What you will take away from this webinar: How will Top Management be assessed? What kinds of evidence will auditors be looking for? What will Top Management have to demonstrate? How can Top Management show that they have met the new requirements? How will our processes be assessed? How much is 'enough' detail? How far 'down in the weeds' will the auditors go? For our Quality Objectives – detailed do our Action Plans have to be? What will auditors look for if we have reduced our documentation?How detailed do we have to be in our process flow charts for maximum effectiveness?Can we show '…the sequence and interaction…' with a visual representation of our organization?How can we prove that we're using 'Risk-based thinking'? This webinar will help you get ready for your transition audit. To make sure you are up to date with your transition plan,you need to attend this webinar. Register today!


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A definition essay basically describes or defines a term, a word or a concept in detail by providing a personal view that what actually a particular term, word or a concept means. The scope of a definition essay is very narrow and deep for which the author has to research well in order to produce a meaningful and comprehensive essay.
The simple search of a definition essay topic might return you a list filled with a lot of non professional or immature essay topics which might not be accepted at the college well. In order to search for the right and professional essay topics, one has to understand the scope and limitations of the definition essay. The search engine might return you a long definition essay topic list very conveniently by using the keyword, but you have to put some effort in order to filter out the good and professional definition essay topics. Following are the few points which could be really helpful in selecting a professional and an open to write definition essay topics:
We pointed out the best solvers for the most common problems with essay drafting, composing and editing.
Nowadays all you need is available on the web. But you should always check source for its credibility.


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- Created: 06 February 2018
- Hits: 1184
We sure are lucky to call this place home. Our Crissy Field Paddles are not for beginner paddlers but paddling under the Golden Gate should be on everyone's bucket list.
We had first Crissy Field paddle this past Monday and it was one to remember. A combination of the nasty flu going around and the Superbowl hangovers thinned our normal crowd quite a bit. We welcome paddlers in any forward facing paddle craft to join us.
Our normal routine is meeting at Crissy Field's East Beach in San Francisco and then paddling up to and under the Golden Gate Bridge.We leave the beach promptly at 7:30 am to get the best weather. Once we get up to the bridge we make a judgement call on the next best step and today the order of business was to hug the coast and make our way out to Baker Beach.
More advanced paddlers can choose to navigate in and around the rocks while the others simply swing wide and enjoy the gorgeous views. A we made our way back under the bridge we had a nice treadmill of ebb tide to make for some challenging fun. I was able to surf a few waves on SIC's new RS race board while the group padde. The 14 x 23 is one fast board that surfs great too.
Our next paddle is actually this Friday and you can more opportunities in our date list below. These paddles are free to all. We highly recommend wetsuits for this adventure which again is not for beginners. We can also bring a board, paddle, and pfd to the beach for you. Just call the shop at 415-524-8492 to arrange that and then let the adventure begin.
Upcoming Crissy Field Paddles
Monday February 19th - More Information
Friday February 23rd - More Information
Monday March 5th - More Information
Monday March 19th - More Information


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Although Red Bull New York isn't a franchise, like you said they neglect NJ and when a foreign owner comes in to buy a football club in England, everyone is suspicious of whether they are out to make money quick or whether they actually genuinely want the club to succeed. These foreign owners don't change the name, dump the history and move towns. So, upon hearing that Red Bull have bought a second team, after buying SV Austria Salzburg, I and many of my friends in football talked about this. We all agree that maybe this isn't right for football in America. It is an up and coming footballing country with exciting prospects and, right now it doesn't need something like this.
But that is just our opinion across the pond.


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All division of land and most all transfers of title of land require the services of a Professional … Click Here
CB & Associates, Inc., provides professional land surveying services to clients all over Montana, Idaho, South Dakota and Utah. In addition to our diversified experience, we are also Certified Federal Surveyors, trained and certified to work efficiently and correctly on Indian Lands. Our projects have included boundary resolution, land development, transportation surveys, mining interests and subdivisions. CB & Associates, Inc., is networked with a team of professionals from all disciplines in the engineering/surveying profession and are fully capable of completing your project in an expeditious and cost efficient manner.