Telecommunications Adjudicator update for February 2022

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

See the latest charts

At the end of February 2022, the number of unbundled lines stands at 8.53 million. There are 3.94 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 is now closed and Openreach are going through a post-trial evaluation to review the learnings and determine the value of the changes against the product as designed. The output of the review will be shared with the whole of the PIA stakeholders.

Scale Build - O/H: 3/4 CPs have joined the POC and supplied lists poles for their build areas which are listed on the SDEDS data list as being ‘D’. Openreach now need to analyse the data and build a programme to feed into their pole replacement programme.

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

Ethernet

EAD – Demand has upturned again with significant volumes of orders being placed in February. This is pushing the workstack slightly higher. 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.

The launch of the new COF401 cable is being delayed until June/July due to supply chain challenges.

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 had a differing interpretation of what was agreed. Openreach tabled an updated proposal early October, however, this has been rejected by industry and negotiations remain at an impasse. 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).  Openreach has presented a proposal for future SLGs, which has been commented on by industry. Openreach has provided a verbal update and a written response is anticipated shortly for planned discussions mid-March.

The Equinox sign-up window for CPs wishing to participate closes 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 be 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.

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.

The most recent meetings have focussed on the next steps and learnings for Salisbury and Mildenhall. Discussions around how to approach the process of ultimately turning off WLR3 as part of these trials. This work will continue with the ambition of agreeing an industry approach, especially around managed and supported migrations.

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 repeatedly offered CPs the chance to develop and test their vulnerable customer processes as part of a formal trial and while engagement is improving, it remains limited.

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.  Discussions are ongoing in line with the agreed plans and have made reasonable progress with a refresh of the Reference Offer published in mid-January. Whilst discussions on the major proportion of the items have concluded, agreement was not reached on all aspects. Industry is concerned that some elements within the Reference Offer, when republished, may not meet what they believe to be the spirit of the Ofcom 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 (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)
• 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, and is now being reviewed by the OTS-SG. In addition, the OTS-SG have received a presentation from OTA2, based on discussions with CPs, on the various options of OTS and number porting. Again, this is under review and has also been shared with the Number Porting Community.

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. These areas will form the basis for upcoming design sessions, beginning in February, and likely to go forwards into March 2022. Additionally 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.

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 a number of formal reviews with the NICC. These requirements will now form part of the broader requirement specification library, being created by the NICC.

Service Levels

Copper & Fibre Provision

Openreach FAD (First Available Appointment Date) performance nationally, over the 5-day period ending 26 February 2022 was 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 been tracking an uplift for LLU and WLR, achieving a 4-week rolling average of 88.1% and 83.7% respectively, by week ending 18 February 2022.

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