Telecommunications Adjudicator update for April 2022

An update on the principle areas of project activity being led by OTA2 in April 2022.

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At the end of April 2022, the number of unbundled lines stands at 8.38 million. There are 3.89 million WLR lines and the number of telephone numbers using CPS is 2.03 million.  *

The following is an update on the principle areas of project activity being led by OTA2.

Passive Infrastructure Access

Operational performance remains steady even with good volume of both NoI and NA orders.

Scale Build – U/G POC: POC feedback given at the PCG – Openreach are looking at utilising the process developed for the POC to test the suitability of the ticketing system for ‘lead-in’. The proposal for using the ticketing system for NA is not being carried forwards.

Scale Build - O/H: Heartbeat update given at the April PCG, Openreach still looking at the overall pole replacement programme and optimising the workflow with its partners.

Active workstreams currently running to improve the product and its usability for CPs are:

  • NA Evidence and quality documentation for CPs to able to instruct their field resources.
  • Connecting Customers


EAD – Demand remains very strong. The workstack remains an area of focus, but Openreach are managing the volatility and remain in control.  Delivery remains in a good place with c1100 orders a week being delivered.

Planning performance remains an area of focus with day 6/8 running flat at c35%, the day 14 measure is showing signs of recovery and trending upwards.

Optical Services: good levels of service being reported.

Work to review the T2R process and its associated KPIs has begun with a review of the actual process against the process description which follows the contractual description. CPs are keen to understand what happens with the stop and start of clocks and what activity is enabled in the assessment stage of the process.

Copper and Fibre

The system capability for payment of a Dead-on Arrival SLG for FTTP went live on 1 November 2021 and Openreach has published a payments schedule for both forward looking and retrospective payments. Initially the quantum is set at £12 (in line with that for other products).  Openreach has presented a proposal for future SLGs, which has been commented on by industry. Openreach has provided a verbal and written response to the points raised by industry. The OTA2 will now review with Openreach and in in turn industry next steps.

The Equinox sign-up window for CPs wishing to participate closed on 31 March 2022.

At the January CFPCG, Openreach stated that dependent on circumstances a cancelled provision would only lead to either to a cancellation charge or an AVC being levied, however, the contract gives Openreach the right to charge for both. Industry and OTA2 consider that the contract should reflect the policy being applied.  This is being considered by Openreach with a response anticipated early June.

Openreach reiterated their plans to introduce an ‘On the Day’ upgrade product for FTTP in July. CPs expressed their concern that industry had underestimated the scale and impact of this development and potentially on end customers.

Openreach informed the CFPCG that it is considering implementing a ‘stop sell’ of the Fibre on Demand (FOD) product from 1st November 2022, following a 6 month notice period. CPs felt it was not reasonable to cite low demand as this had always been constrained. CPs stressed that they believed there was a very real demand, especially for those pockets that will be affected by the PSTN switch-off.

All-IP Steering Group

The All-IP steering group continues to work well providing a good interaction on issues and concerns.

The forum commenced planning on the programme of activity required to manage the active migration of customers off legacy products addressing aspects such as roles and responsibilities within the process, timelines, roadblocks etc.  Discussions have commenced in detail regarding how Openreach approach the process of ultimately turning off WLR3 as part of the Salisbury and Mildenhall trials. This work will continue with the ambition of agreeing an industry approach, especially around managed and supported migrations.

Work has commenced to support the DCMS/NHS activity planned for April/May which aims to improve the migration experience for vulnerable users.

Dark Fibre

There were aspects of both the product and contracts discussion, which could not be completed prior to the publication of the Reference Offer for soft launch. The issues needing to be addressed were captured and a timetable for review agreed between Openreach and Industry.  The discussions have concluded, although agreement was not reached on all aspects. Industry remains concerned that elements within the Reference Offer, when republished, will not meet what they believe to be the spirit of the Ofcom WFTMR Statement.

Orders for DFA are gradually increasing and Openreach report that their systems and processes are working well.

Consumer Switching & Number Porting

The ‘One Touch Switch’ Process (formerly EECC Fixed Line Switching and Porting)

On 28 September 2021 – Ofcom published their statement on quick, easy and reliable switching, which briefly contains the following:

  • OTS (One Touch Switch) is the process selected by Ofcom for all residential fixed Voice and Broadband switching
  • Date of 3 April 2023 for Industry compliance to revised switching General Conditions (original date was December 2022)
  • On 3 February 2022 – Ofcom published the conclusion of their consultation on revised General Conditions and an update to their Statement on Quick, easy and Reliable switching. The revised statement included responses to a number of points raised by Communication Providers and an important clarification on the definition of NBICS (Number Based Interpersonal Communications Services), which concerns the ‘Voice’ element of services in scope of OTS.
  • Included in Annexes to the statement are the final revised GC (General Conditions)

OTA2 continue to engage with industry through OTS Design and the recently established OTS Steering Group forums and meetings.

OTA2 responded to industry’s desire to move the project forward at pace by establishing and chairing an OTS Steering Group which would act as a proxy to a full governance group that will ultimately be established in some form. Between 17 and 20 representative CPs, industry associations and Ofcom (as observer) form the group. Proposals of this group will be fed back periodically to the wider industry groups in a transparent fashion. More will be reported as the group makes progress.

The report commissioned on governance was received and presented to the OTS-SG on 7 February 2022, with a subsequent consultation undertaken and presented to the OTS-SG on 21 April 2022, which included a recommended framework for a formal governance structure.

The OTS DDG (Design Drafting Group), comprising of a small team of expert solution architects, all of whom volunteered their dedicated time, worked through the middle weeks of January to construct and publish the first version of the OTS Process Design. This was reviewed by the wider OTS Design community and a significant number of constructive comments were received. The OTS-DDG collated and responded to all comments directly to the submitting party. This was followed by the publication of Version 2.0 of the High-Level process design for OTS w/e 25 February. As part of this process a number of areas remain that will require broader discussion and contributions to define the best technical process solution to follow, this is being undertaken as a series of review session with the wider CP community.

A number of key ‘principles’ have been identified and presented to the OTS-SG, seeking affirmation of the design steps. Similarly, a number of areas have been identified that require decisions on choices of which process step should be adopted, where a number of options exist, these will also require a decision from the OTS-SG. Following feedback from the OTS-SG the principles are currently being uplifted and will be re-presented.

Though there is the need for further revision of the V2 Process design, this will take place alongside a number of workshops to consider ‘Business’ switching processes and how they will satisfy the requirement to be GPL (Gaining Provider Lead) in April 2023. The OTA2 have already chaired a business switching focus session, to begin defining a ‘Best Practice’ approach, pan industry that will form the basis of the process design development, these sessions are now progressing under the chair of a Business focused CP, with OTA2 support.

A presentation has been made, proposing an approach to linking OTS to the Number Porting processes, in such a way that benefits could be achieved in both areas. This proposal has been shared with the Switching, (OTS-SG) and the Number Porting (NPP&CG and NPESG) communities and is currently under review.

Right to Port (EECC Requirement – April 2023)

Under this requirement, CPs must provide number porting to customers that request it for at least a month after the termination of a contract, unless the customer expressly agrees otherwise when terminating that contract. CPs will be expected to ensure customers can contact them regarding porting of a number after the termination of a contract through a variety of means, such as online, by phone or in person in a store.

The delivery by a major CP of this functionality in July 2021 has already delivered benefits to many 100’s of end customers and their service providers, demonstrating that ‘early’ delivery into live can be achieved without negative impacts on existing solutions.  It should be noted that the full benefits of this change will only be realised when all CPs have delivered this functionality and also updated their order handling processes in such a manner that customer who have recently ceased service can still attempt to use their ‘old’ number in a new order.

Porting Alignment with the ‘One Touch Switch’ process

OTA2 continue to work with the Number Port Executive Steering Group (NPESG) to develop a roadmap which achieves 2 primary objectives: -

  • To establish the most effective way of aligning the number port process with the new ‘one touch switch’ process, by April 2023
  • To transform number management and porting in readiness to meet the demands of an All-IP environment following the planned withdrawal of legacy TDM networks and analogue services (i.e. by 2025).

Although there is support within the NPESG and NPP&CG for this effort, the timescales and other industry initiatives are challenging and will require considerable effort to overcome.

Porting improvements

Continuing feedback from across industry has identified the need for ongoing investigations into a broad spectrum of Porting issues, due to friction in the associated processes. The coincidence of this and the anticipated requirements to support a new switching process present both a challenge and opportunity to the Number Porting community

Improvements already underway include: -

  • The delivery of enhancements to existing Analogue (TDM) to IP based voice services already made by some parties are delivering ‘in-life’ benefits and process improvements, these will continue to be monitored alongside future planned improvements - no major issues have been identified to-date, though the expected ramp-up in volumes will be a key test for all parties.
  • For single-line residential port orders, to re-engineer the existing process to reduce the minimum lead times to match the lead-times expected of the new ‘One Touch Switch’ process (e.g. next working day port activation)
  • To establish a new Bulk Transfer process to facilitate wholesaler ports. (i.e. porting at the Wholesaler level).

Singleton Transfer has also been identified for consideration in the same investigation (i.e. same end customer and retailer, but a change in wholesaler/voice service provider to offer customer a new service package)

  • A number of focus group sessions have been undertaken to investigate operational issues experienced with PoV. The objective being to identify and agree possible improvements to this process.  These have proved productive, but follow-up sessions will be required to agree a strategy to implement some of the options suggested.
  • A proposed ‘Plan of Works’ has been created for 2022 and will, when agreed, form the basis of targeted improvements in the coming year.

Common Numbering Database

  • The OTA2 chaired Number Port Executive Steering Group (NPESG) and the NICC (UK Interoperability Standards) are collaborating with regards to establishing a CDB (Common Numbering Database) to transform number porting in the UK.
  • A high-level draft requirements document has been produced and taken through several formal reviews with the NICC. These requirements will now form part of the broader requirement specification library, being created by the NICC. A small number of issues remain outstanding and will be re-presented to the NPESG next month (April) for closure

Service Levels

Copper & Fibre Provision

Openreach FAD (First Available Appointment Date) performance nationally, over the 5-day period ending 23 April 2022 was as follows: -

Service Installation type FAD First Available Appointment Date (Backstop SLA = 12 days)
Copper 6.3
FTTC (MI) 5.9
FTTC (SI) 7.5
FTTP (MI) 11.5
SOGEA (MI) 8.3
SOGEA (SI) 6.0


  1. MI and SI are Managed-Install and Self-Install orders
  2. FTTC is Fibre to the cabinet
  3. FTTP is Fibre to the premises
  4. SOGEA is Single Order Generic Ethernet Access
  5. GFAST is Fibre-base Ultrafast Broadband

Copper Repair

LLU and WLR ‘on time repair’ performance has been tracking an up-turn for LLU and WLR, achieving a 4-week rolling average of 85.1% and 82.8% respectively, by week ending 18 March 2022


Due to the performance data not being available this month, the Ethernet KPI charts have not been updated.

*The figures quoted exclude BT downstream connections

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Signed David Halliday