Telecommunications Adjudicator update for January 2022

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

See the latest charts

At the end of January 2022, the number of unbundled lines stands at 8.60 million. There are 3.97 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.

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.

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: 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.

O/H: We now have several CPs who have shown interest in taking part in the O/H POC. Openreach are undertaking bilateral discussions and setting out their input requirements.

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 returned to slightly below the levels seen before the Christmas break, but completions have made a good return allowing the workstack to come in slightly. In overall terms service remains in a good position.

Optical Services are following EAD with 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

Openreach have issued formal contract termination letters to all CPs with WLR3 assets in either Salisbury, Mildenhall or both. These give a 15-month notification period with a termination date of 19 April 2023. The associated products (FTTC, SMPF) will be subject to separate contract termination letters and notification periods.

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, so negotiations are currently 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 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 has now been implemented.

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 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 and industry considers that some aspects do not meet the spirit or intent 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)
• 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 report commissioned on governance has now been received and will be reviewed by the OTS-SG on 7 February 2022. 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 will be ultimately reviewed with industry at large.

January 2022 saw the resumption of a limited number of OTS Design related meetings, with more planned for February (see following OTS-DDG segment)

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 has been shared with the wider OTS Design community (i.e. Switching Working Group or SWG) for peer review and constructive comment, with responses requested by close of play 4 February 2022.  The OTS-DDG will collate comments and respond in turn with an up-issued version of their document. 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 on 2 February, however, due the congested calendar across the stakeholder community it is proving challenging to arrange a standing meeting schedule, this will be resolved soon.

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).

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.

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 formal first review with the NICC, a second review is scheduled mid-February. After which it is expected that the document can be brought to issue.

Service Levels

Copper & Fibre Provision

Openreach FAD (First Available Appointment Date) performance nationally, over the 5-day period ending 30 January 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 a slight decline for LLU but an uplift for WLR, achieving a 4-week rolling average of 83.8% and 79.7% respectively, by week ending 21 January 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