Telecommunications Adjudicator update for August 2020
An update on the principle areas of project activity being led by OTA2 in August 2020.
At the end of August 2020, the number of unbundled lines stands at 9.55 million. There are 4.28 million WLR lines and the number of telephone numbers using CPS is 2.06 million. *
We anticipate that all industry fora that we host will remain online, until such time that all participants return to travelling normally across the UK. We will continue to monitor the situation with a view to either maintaining this approach or reverting to an agreed normal.
Please all keep safe and well.
The following is an update on the principle areas of project activity being led by OTA2.
EAD orders are continuing to show signs of recovery trending back towards c1400 circuits a week with completions running at around 1k per week. Regaining control of the workstack remains a priority as does reducing the amount of suspends. Optical orders are still quite spikey but appear to be dropping back down to more normal levels. Both the workstack and the levels of suspension as with EAD are high, but given the current situation with Covid-19, this is not unexpected. Completions running at around 100 per week with a mix of Wavelength and bearers being delivered.
We are at the time of publication awaiting the outturn statistics for August.
Passive Infrastructure Access
PIA remains a very active area of both interest from CPs (Now 80 registered CPs) and in terms of systems and product development. Operational performance on the PIA product has remained good throughout the Covid-19 crisis.
Systems development - Openreach have opened their CVF facility for CP developers to use in testing of the API interfaces and functionality for automation. One CP has established and dialogue is ongoing with a further 3 CPs.
There has been considerable effort taken to develop a programmatic view of the workstreams currently running to improve the product and its usability for CPs. The current first pass view is shown below which will be developed to provide the basis for tracking activities going forwards
- Missing Inventory
- Build Complete
- Duct Overlay
- Movement of Dropwires
- Cable Coils
Copper and Fibre
Openreach and industry have expressed a willingness to engage on proactive testing, with the OTA2 acting as an intermediary, with a view to seeking some form of compromise; should this be possible. The process will begin in early August and is ongoing.
CPs and Openreach are in formal negotiations regarding the 28-Day repeat SLG following a request from industry that two network clears at different locations be included. Openreach have stated they are not willing to extend the SLG as they believe that Openreach had undertaken all that was possible or reasonable in responding to the first fault. A formal response to industry has also been provided which industry is considering.
Industry has also proposed SoR 8619 which relates to automatic compensation payments associated with a repeat fault within 48 hours. This is intended to support potential changes to the current automatic compensation scheme provided to consumers.
Openreach had informed industry that it has identified issues with the quality of testing of some DFX orders. A plan is in place which seeks to rectify these issues and progress is being reported back to industry.
Openreach has proposed the rejection of SoR 8572 – DFX Alternative option for BT only exchanges without space and power. Industry did not support the rejection and submitted a response, to which Openreach has responded reiterating its intent to reject the SoR.
Progress has been made regarding SoR 8594 – DFX Delivery Assurance following CP acceptance that the solution may affect the Openreach cost stack, which would feed through to the product. Industry did, however, stress that it did not expect to pay for these changes and that any cost reductions associated with process changes should be factored in. There is concern how this might be impacted by the anticipated WFTMR statement later this year
Industry had expressed its concern to Openreach regarding the current policy of not offering fibre that is pre-2000, as in some circumstances G.652.A fibre was used prior to this date and could solve a number of order rejections. Openreach has responded that it intends to trial the use of pre-2000 fibre on routes less than 40km. Industry awaits the opportunity to review and discuss the trial scope.
Consumer Switching & Number Porting
EECC Fixed Line Switching and Porting Working Group (ECWG)
The European Electronic Communications Code (EECC) will update and replace the existing EU regulatory framework for electronic communications within the UK.
The Code contains new provisions relating to consumer switching and porting and includes a specific requirement for Industry to establish a single, gaining provider-led process for switching domestic customers within and across different fixed networks (i.e. cross-platform switching).
At Ofcom’s instigation, OTA2 convened an industry working group (ECWG) with the task of developing the new switching & porting process.
Industry were unable to reach agreement a on a single solution and have submitted 2 alternative options (i.e. the X & Y solutions) which Ofcom are evaluating before making a decision. Ofcom’s evaluation remains in progress at the current time.
More recently, Ofcom have advised that the proposed Y solution does not fully satisfy the ‘express consent’ requirement and is not, as it stands, compliant. As such, Ofcom have invited the Y group of CPs to re-visit their proposal to see if it can be modified to accommodate the express consent requirement.
With OTA2’s assistance, the Y group have created two alternative solutions which address the ‘express consent’ requirement whilst maintaining the ‘1-stop shop’ customer experience they feel is absolutely essential in meeting the EECC requirement. These were submitted to Ofcom on the 04 August 2020.
Ofcom have continued to emphasise that they remain open minded as to which solution (X or Y) they prefer and will complete their initial assessment before launching a consultation with the wider industry community to gauge opinion on all the options under consideration.
Right to Port (R2P)
A separate ECWG workstream is underway to address an additional EECC requirement to deliver the changes needed to afford an End User the new ‘right to port’ their number to a new provider for a period of up to 31 calendar days following service termination with their previous provider.
OTA2 have developed a detailed requirements specification which has been distributed to each of the major CPs who will be developing their existing automation to fulfil the ‘right to port’ requirement.
Despite Ofcom’s recent announcement to relax the original timeline for industry to meet the new EECC requirements (i.e. in light of the pandemic impact), OTA2 and industry are keen to implement the R2P enhancement as soon as possible as it will eliminate a significant industry cost of failure whilst providing a much better End Customer experience.
Ofcom will include a revised timeline for “Right to Port” within the EECC switching consultation, expected later this year.
WLR Withdrawal and move to All-IP
A review is underway to assess the best way for OTA2 and Openreach to engage more effectively with industry. Details will be released in due course.
Copper & Fibre Provision
Openreach FAD (First Available Appointment Date) performance nationally, has been averaging 7.2, 5.5, and 6, working days for Copper, Fibre (MI) and Fibre (SI) installations respectively, over the 5-day period ending 26 August 2020 (vs backstop SLA of 12 working days).
(Note: MI and SI are Managed-Install and Self-Install orders respectively)
LLU and WLR ‘on time repair’ performance has maintained a relatively flat trend, achieving a 4-week rolling average of 85 % and 83 % respectively, by week ending 21 August 2020.
*The figures quoted exclude BT downstream connections