Telecommunications Adjudicator update for July 2020
An update on the principle areas of project activity being led by OTA2 in July 2020.
At the end of July 2020, the number of unbundled lines stands at 9.06 million. There are 4.28 million WLR lines and the number of telephone numbers using CPS is 2.06 million. *
Covid-19 Impact
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.
Ethernet
EAD orders are showing signs of recovery trending back towards c1400 circuits a week with completions running at around 1k per week. The workstack is running at c19k the greatest challenge for service is the level of suspends running at 15% of the workstack which is understandable given the challenges of access due to Covid 19. As we have seen previously, full-service recovery and good service levels are returned once we see a controlled workstack and the levels of suspend reduce to allow Openreach greater fluidity of work. We will continue to monitor with Openreach and the CPs as the lockdown eases.
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 Covid19 this is not unexpected. Completions running at around 100 per week with a mix of Wavelength and bearers being delivered.
Re-imagining Ethernet Programme (REP)
Openreach have set out their revised plan for REP, taking into account the lessons learned from the Covid challenges, and to the points raised by CPs in their responses to the consultation. An outline plan has been shared with CPs and further discussions will follow to finalise the detail.
Passive Infrastructure Access
PIA remains a very active area of both interest from CPs (Now 77 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. To date there has been little CP take up of the facility which is somewhat disappointing.
There has been further work on the challenges of Inventory Missing from the map tool, Openreach have started to undertake a records matching exercise to populate missing sites and have created a breakout process for CPs to query gaps in records where a whole area is obviously served but missing from the map tool.
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.
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.
Dark Fibre
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 reported back to industry.
Openreach has proposed the rejection of SoR 8572 – DFX Alternative option for BT only exchanges without space and power. Industry does not support the rejection and has submitted a response, which Openreach are considering.
Industry has expressed their 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.
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 & 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 are considering various 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.
Ofcom have emphasised that they remain open minded as to which solution they prefer and await a revised proposal from the Y group.
It is anticipated that the Y-Group’s revised proposal will be submitted to Ofcom 31 July 2020
Thereafter, it is anticipated that Ofcom 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.
WLR Withdrawal and move to All-IP
Ofcom have written formerly to OTA2 to ensure that adequate best practice is agreed with industry for vulnerable and CNI (critical national infrastructure) customers in moving to an all IP environment. The timescale is to agree with industry by December 2020, in advance of the Openreach trials at Salisbury and Mildenhall. OTA2 have also been asked to reach out to other infrastructure providers to establish a common approach.
A key component of ensuring the specially vulnerable community are properly catered for, will be the introduction of a ‘special service restoration’(SSR) process which will be invoked by CPs in the event that the customer’s ‘special service’ (e.g. remote dialysis machine monitor) cease to work after switching from a traditional copper-based phone line to a new VOIP-based service.
To support this SSR process, Openreach have established a new ‘Emergency Restoration of Copper’ process for CPs to use when needed.
To supplement this, OTA2 have published a Best Practice Guide (Special Service Restoration) and is accessible via the OTA2 web-site.
Service Levels
Copper & Fibre Provision
Openreach FAD (First Available Appointment Date) performance nationally, has been averaging 7.3, 5, and 6.5, working days for Copper, Fibre (MI) and Fibre (SI) installations respectively, over the 5-day period ending 27 July 2020 (vs backstop SLA of 12 working days).
(Note: MI and SI are Managed-Install and Self-Install orders respectively)
Copper Repair
LLU and WLR ‘on time repair’ performance has maintained a relatively improving trend, achieving a 4-week rolling average of 85 % and 83 % respectively, by week ending 24 July 2020.
*The figures quoted exclude BT downstream connections