Telecommunications Adjudicator update for December 2022

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

See the latest charts

At the end of December 2022, the number of unbundled lines stands at 7.66 million. There are 3.49 million WLR lines and the number of telephone numbers using CPS is 1.82 million.  *

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

Passive Infrastructure Access

Health and Safety, and good working practice continues to require attention. Instances of poor behaviour continue to surface, which is not acceptable.  This remains top of the industry agenda.

Operational performance remains good.

The OTA2 framework for incident management has been shared with Openreach and CPs from the PIA Executive meeting. Next step is to consider any feedback and then share with the wider industry group. A request has gone out to all the registered CPs to provide a Single Point of Contact, phone number and e-mail address to facilitate Network Provider to Openreach and intra Network Provider contact for resolution of incidents and issues. The list will be hosted on the Openreach portal through the log-in for security.

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
• Incident Management

Ethernet

Service over the holiday break has followed the usual trend and the challenges of getting access to customer sites has slightly increased the number of suspended orders. Openreach focus remains on getting control of the workstack and driving completions.

Further work looking at the parts of the order journey where delay and suspension occurs is being carried out. Delays in survey and planning are under the microscope.

Openreach have instigated a SIP to look at task closure delays and how these can be managed and closed as quickly as possible and where appropriate by either the system or the service desk.

Copper and Fibre

At the January 2022 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 has been under consideration by Openreach for some considerable time with an anticipated response, now deferred until at least February 2023.

When FTTP was launched, Openreach chose to adopt a defined tier approach to installation options rather than offer time related charges. However, CP consumption of the Premium option has not materialised. This has the potential to create issues during installation where the work required exceeds that ordered.  Openreach and industry agree on the need to find a workable solution and have initiated discussions to address this. This work is continuing, and it is anticipated that Openreach will provide an outline proposal to discuss with industry.

Industry has presented a draft SoR to support the migration of analogue lines to All-IP where a telecare is located at the customer premise.  This will be formally submitted in January. While there is unanimity regarding the action required where either the broadband or IP-voice installation fail, agreement has not yet been reached where the final test of the telecare device on the digital line fails. Discussions are ongoing and it is hoped agreement will be reached by the end of the month.

All-IP Steering Group

The All-IP steering group continues to work well, providing a good interaction on issues and concerns. Openreach requested CPs re-forecast the migration of their WLR assets for Salisbury and Mildenhall by early November. Progress against these will now be tracked. Openreach plans to make direct contact with end customers of non-engaged CPs, or CPs with ‘off-track’ migrations towards end-January 2023. In February 2023 Openreach will send further postcards to impacted end customers and in March 2023 Openreach will send final postcards to all impacted end customers, with a message to inform of potential termination.

The remit of the All-IP group has been extended to support Exchange Exit, for which a Pilot has commenced covering five locations. The Pilot will be utilised to identify the operational enablers required and to test processes and notification periods for exchange exit. The end date for the Pilot is set as 30 March 2024. Letters will be sent to affected CPs shortly for the first exchange, Deddington, giving 15-months’ notice of termination.

Openreach has shared a refreshed list of the 103 priority exchanges that it will be exiting by 2030, which has changed from the list published by Openreach in February 2021. There are 959 enduring exchanges, which are the long-term exchanges Openreach currently intend to retain as Openreach Handover Points. Work continues in support of the DCMS/NHS activity planning which aims to improve the migration experience for vulnerable users of telecare equipment, although progress has not been as rapid as hoped. The current focus is on gaining alignment on aspects of the telecoms processes and the draft SoR presented by industry will, hopefully, allow progress to be made with an effective process that can be discussed with the Telecare industry.

Consumer Switching & Number Porting

The ‘One Touch Switch’ Process (OTS) for Residential Customers and Gaining Provider Lead (GPL) for Business Customers

• 03 April 2023 remains the target date for Industry compliance to Ofcom’s revised switching General Conditions (GCs)
  - please be aware that these GCs are not limited to ‘switching’ and encompass a broad spectrum of activities.
• OTS is the process selected by Ofcom for all residential fixed Voice (NBICS – Number Based Interpersonal Communications Service) and Broadband (IAS – Internet Access Service) switching. Unlike the existing Notification of Transfer (NoT, also known as NoT+) process, OTS will function across all UK Residential fixed Voice and Broadband switching scenarios, encompassing all Access Networks (not just Openreach and KCOM – as mandated in the current C7 GCs).
  - OTS will replace NoT, due to NoT failing to satisfy the revised switching GCs
  - OTS will be complemented by optional developments in the Number Porting process (please see ‘Express Porting’)
• Ofcom have also stated that a GPL process must be available for Business Customers who are switching their Voice and/or Broadband services.
  - the GPL Business switching process will also replace NoT, an like OTS will provide a switching solution that is Access Network, technology and product (as marketed by providers) agnostic

OTA2 are heavily engaged with industry for both OTS and GPL Business Switching Process Design initiatives and are also working with TOTSCo (The One Touch Switching Company) on the specific role they have in delivering the Hub functionality that will support OTS.

To receive both the latest news on the technical and commercial updates for the TOTSCo Hub, please consider registering on the TOTSCo website www.totsco.org.uk - which will provide access to documentation and meeting schedules (registration is free).

Included in the documentation already published via the TOTSCo website are the OTS Process Design, API developers guide and Technical Hub interface specification. These documents provide a good baseline for CPs to assess changes required to their own process and system development.

Business switching is being led by members of the Gaining Provider Lead Business Steering Group (known as the GPLB-SG), consisting of a cross-section of the Business service provider community, who have volunteered their time and expertise to this enterprise. The GPLB-SG is co-chaired by OTA2 and FCS and has produced an agreed set of guiding ‘principles’, a process design that is at an advanced stage and has engaged directly with Ofcom to outline both the principles and challenges facing the successful delivery of business switching processes.

Further work will be undertaken to produce supporting technical documents, that will shape requirements for any system solution development. It is planned to distribute these documents for wider review and feedback in the very near future.

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 (agreed as 31 calendar days) after the termination of a contract, unless the customer expressly agrees otherwise when terminating that contract. This requirement extends to scenarios that would not require the number to be ported (hence ‘Right to Retain’) in order to reactivate a ceased number and will address existing issues with customers attempting to recover their number after ceasing service. A revised ‘Best Practice’ document has been shared and reviewed by the NPPCG members, with the intent to re-publish at Issue 1.0 status. For more please see under ‘Porting Improvements’.

Porting Enhancements to compliment the ‘One Touch Switch’ process

The proposed ‘Express Porting’ solution documentation is near completion, and a presentation of the detail will form part of the February 2023 NPPCG agenda, this will include more details of the process and rejection codes planned to be used.

This will be an optional process and seeks to compliment the functionality of OTS specifically with respect to the validation achieved by following the OTS process and opportunity to reduce lead-times for switching customers.

It has been proposed that the Business switching process may also consider complimentary developments in Number Porting, though this is at a very early stage and no firm suggestions have been tabled for consideration.

Porting improvements

Input from across the Number Porting community, has identified the need for investigations into a broad spectrum of Porting issues, mostly stemming from areas of friction in the existing Best Practice processes, which reflects on both the documentation’s age and its focus on analogue voice services, when it is recognised that an ‘All-IP’ voice service is rapidly becoming the mainstream solution and will, in all probability be universal in the UK before the end of 2025.

The coincidence of this and the anticipated requirements to support new switching processes present both a challenge and opportunity to the Number Porting community

Related to the move to ‘All IP’ CPs should be aware of the upcoming ‘stop sell’ and withdrawal of Openreach WLR service (analogue PSTN). More information about WLR withdrawal can be found at the Openreach portal:WLR Withdrawal (openreach.co.uk) and if CPs wish to reach out for assistance then they should email wlr.consultation.feedback@openreach.co.uk.

The Plan of Works for 2022 (as set out below) will be reviewed in the first quarter of 2023 and a decision made on which items can be closed and if new items should be added.

• The NPPCG continue to monitor the transition to All-IP, with no reported issues raised at the November NPPCG session
• A Best Practice for the Bulk Transfer process to facilitate Wholesale Porting. (i.e., porting at the Wholesale level) has been created, reviewed and agreed, and is now published on the Number Porting website
• PoV (Pre-order Validation) Uptake of the PoV process continues to grow, with more CPs registering themselves to support and utilise this facility. More information can be found on the OTA2 website
• CDB - Common (Numbering) Database: The Number Porting community, via the NPESG and NPPCG, has provided significant contributions to the requirements catalogue for a CDB. At this time the initiative, and any technical requests for information to potential suppliers’ rest with the NICC. (NICC (niccstandards.org.uk) ) This community continues to support the NICC in its work.
• Right to Port/Right to Retain (EECC Requirement – April 2023): The Right to Port industry spec draft 0.j was shared with NPPCG and NPESG members for review on 3 November 2022, and feedback has been received – many thanks to those who took the time to review. OTA2 will undertake to bring the revised document to issue shortly.

One new item that has already been discussed by the NPESG is the need for an industry agreed ‘Supplier Of Last Resort’ (SOLR) process proposal to address the scenario of a VoIP provider getting into ‘distress’ and provide a solution that would mitigate impacts on end customer service (directly or indirectly).

Service Levels

Copper & Fibre Provision

Openreach FAD (First Available Appointment Date) performance nationally, over the 5-day period ending 8 January 2023 was as follows: -

Notes:

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 seen a upward trend for LLU and WLR, achieving a 4-week rolling average of 83% and 76% respectively, by week ending 4 January 2023.

Ethernet

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

Signed David Halliday