Telecommunications Adjudicator update for December 2021

An update on the principle areas of project activity being led by OTA2 in December 2021.

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At the end of December 2021, the number of unbundled lines stands at 8.68 million. There are 3.98 million WLR lines and the number of telephone numbers using CPS is 2.04 million.  *

OTA2 Terms Of Reference

Following reviews with Ofcom and key stakeholders the OTA2 Terms of Reference have been published on the OTA2 website. Ofcom will also provide reference to these TORs in due course on their website. This work was requested by Ofcom in 2021 to replace the now defunct MOU.

Covid-19 Impact

We have now put plans into place to reintroduce some element of face to face meetings where justified. Recognising the benefits of both face to face and online meetings, we are continuing to blend the two approaches.

Please all keep safe and well.

Passive Infrastructure Access

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

Systems Improvements – API adoption remains an area of focus. OTA2 are interested in understanding what CPs require from any automation and how CPs view adoption.

Scale Build – U/G POC: OTA2 working with Openreach to determine the learnings from the trial to date and review any potential process or product changes, such as street works notices impact on the continuity of activity once a blockage is found or any other street works which requires a notice.

O/H: A small number of CPs have engaged with Openreach to develop the proposals for Scale O/H. This will be developed into a trial scope over the next few weeks.

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

  • Duct Overlay – this POC has now closed, CPs have until December to provide the evidence from the trial or cancel the orders.
  • Connecting Customers


EAD – Taking into account the usual Christmas Holiday effect the picture remains very consistent with the report from last month.

Both demand and completions have been affected by the holiday season but if we exclude this the overall picture remains the same. Demand remains very high. Performance is overall good. However, planning times remain under sharp focus as we are still seeing challenges in getting performance back to normal.

Optical Services are following EAD with good levels of service being reported.

The previously reported MFD issues associated with the use of COF950 cable which was being used on Cable link jobs has been addressed and a new COF401 cable will be used on future cable link deliveries.

Copper and Fibre

An issue has arisen within the reconciliation of historic auto compensation payments up to April 2021 and are associated with cancelled provisions, where the two sides have a differing interpretation of what was agreed. Openreach tabled an updated proposal early October, however, industry requested some additional data from Openreach prior to any response. This has now been provided. The position post April 2021 is unaffected.

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). Discussions are ongoing on how best to include in contract. Industry still await Openreach proposal for way forward, which is promised for mid-January.

Openreach informed CPs in December that they have published their consultation regarding the piloting of exchange closures. The Openreach plans are centred on 5 exchanges, starting April 2022. The deadline for responses is 21 January 2022.

Openreach had previously flagged their concerns regarding the potential incorrect use of New Line Provides and had presented a proposal to address these. Following feedback from CPs, a revised approach has been put forward, which the OTA2 considers addresses the concerns raised by CPs and also supports adherence to the General Conditions.

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.

Openreach remains concerned that industry order journeys may not fully cater for the migration needs of vulnerable customers with existing telecare devices and that there is a risk they may be left without a working service. Openreach has offered CPs the chance to develop and test their vulnerable customer processes as part of a formal trial but there continues to be limited engagement from industry.

The Openreach test lab is now operational and manufacturers of special services equipment (such as health pendants) can now book test slots.

Dark Fibre

There were some 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.  Discussions are ongoing in line with the agreed plans and have made reasonable progress to date. Whilst discussions on the major proportion of the items have concluded, agreement was not reached on all aspects and industry considers that some aspects do not meet the spirit or intent of the Ofcom Statement.

The current DFX trial to allow use of pre-2000 fibre on routes has been extended but with the inclusion of DFA and will run to the end of March. A formal proposal regarding allowing the use of pre-2000 fibre has been made by Openreach, which was welcomed by CPs.

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 (baselined against the ‘Option Y HUB’ design proposal, but with some notable changes)
  • Date of 3 April 2023 for Industry compliance to revised switching General Conditions (original date was December 2022)
  • Included in Annexes to statement are the revised GC (General Conditions) for consultation, which include the withdrawal of NoT+ processes for in scope services The statement also requested that OTA2 re-engage with industry to further the OTS design, built, test and delivery process and also to bring Industry together to consider ‘Governance’ and its role in both the OTS solution establishment, it’s ongoing maintenance and management, and the potential for convergence of Porting and Switching governance.

OTA2 continue to engage with industry through OTS Design and the recently established OTS Steering Group forums and meetings, with a number already held and well attended in the final quarter of 2021

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 5 January saw the initial meeting of 2022, with the theme of Openreach Network Provider taking a first look at the thoughts of that particular Network operator and how they envisaged changes in their processes to move from NoT+ to OTS

Also, on 05 January 2022 was the initial OTS Design Drafting Group meeting – comprising of a small team of designers, tasked with creating a draft OTS design before the end of January, to be reviewed by the wider switching community.

Further OTS Design meetings for 2022 are in the process of being scheduled.

Right to Port (EECC Requirement – December 2022)

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.

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).

Initial responses from the NPESG have been positive and further investigations are underway.

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
  • 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 focus group session has been undertaken to investigate operational issues experienced with PoV, with follow-up sessions to be arranged. The objective being to identify and agree possible improvements to this process.

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 CNDB (Common Numbering Database) to transform number porting in the UK. Progress on this has not advanced as quickly as anticipated due to a number of factors (i.e. Ofcom statement publication and resultant priority meeting arrangements)
  • A high-level draft requirements document has been shared for review, with a follow-up session to be arranged and an agreed target date of 12 December 2021 to share with the NICC.

Service Levels

Copper & Fibre Provision

Openreach FAD (First Available Appointment Date) performance nationally, over the 5-day period ending 02 January 2022 was follows: -

Service Installation type FAD First Available Appointment Date (Backstop SLA = 12 days)
Copper 6.6
FTTC (MI) 7.9
FTTC (SI) 7.3
FTTP (MI) 10.8
SOGEA (MI) 8.4
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 a slight decline achieving a 4-week rolling average of 84.3% and 76.0% respectively, by week ending 24 December 2021.


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