Telecommunications Adjudicator update for July 2022

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

See the latest charts

At the end of July 2022, the number of unbundled lines stands at 8.11 million. There are 3.76 million WLR lines and the number of telephone numbers using CPS is 1.98 million.  *

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

Passive Infrastructure Access

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

In this financial year there are in-excess of 90 CPs who have raised an NoI and in-excess of 60 who have raised NA orders signifying that they are active.

As previously reported the PIA PCG remains focused on Health and Safety, to ensure that this is kept front and centre of our discussions the H&S sections have been moved to be the first item to be discussed at each PCG meeting.

Scale Build – U/G POC: The Lead-in POC is in the formative stage, with Openreach developing the trial criteria T&Cs etc. The trial will only commence once we see sufficient volume of lead-in orders passing through, going too early will not provide sufficient insight to gain any learning.

Scale Build - O/H: Heartbeat update given at the June PCG, Openreach still looking at the overall pole replacement programme and optimising the workflow with its partners. The POC is being extended to provide a second & third tranche of data to provide the basis for the ‘tour of duty’ methodology to continue beyond the life of the original POC timescales should the POC be proven to be successful. OH POC for provision of service via D poles. To date only a few CPs have completed the T&Cs and registered for the POC. The opportunity for CP to register has been extended to the end of August to give more CPs the chance to be involved. CPs are reminded that if they are interested in using this facility they need to get onboarded quickly.

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 remains very strong c1600 per week. The workstack remains an area of focus, but Openreach are managing the volatility and remain in control.  Delivery remains in a good place with c1300 orders a week being delivered.

Planning performance is beginning to show some improvement and a more detailed set of performance measures have been shared with the ESF, this will hopefully provide CPs with a much greater insight into how Planning is coping with the demand.

Copper and Fibre

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 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 with a response now deferred until September.

In May, Openreach reiterated their plans to introduce an ‘On the Day’ upgrade product for FTTP in July 2022. However, CPs expressed their concern that industry had underestimated the scale and impact of this development and potentially on end customers. Following further feedback from several CPs, Openreach have changed the scope of OTDU and will delay its full introduction until September 2023.

Openreach had previously informed industry that where an ONT was seen as powered down during a remote activation order, Openreach planned to reject the order, starting from September 2022. CPs had discussed the proposed Openreach approach and were unanimous that rejecting an order was not an option. Discussions are continuing following further feedback from industry and an updated proposal from Openreach is anticipated in September.

All-IP Steering Group

The All-IP steering group continues to work well providing a good interaction on issues and concerns.

A contract withdrawal notice was issued by Openreach for Salisbury and Mildenhall for assets that are in the FTTP footprint in Salisbury, or FTTP / SOGEA in Mildenhall.  The Salisbury and Mildenhall trials end on 19 April 2023, after this date, CP contracts for WLR3 will be terminated for assets in those areas. Where customers are connected to WLR3, where the premises has been enabled for fibre, they will potentially lose service when the trial ends. In such circumstances, where there is an urgent need to reinstate a customer’s service, CP have been informed they will need to apply for an exception. CPs have been requested to plan their migrations and provide a migration forecast to the Openreach migration managers and if there is a reason why an end customer cannot move from WLR3 to an appropriate / alternative product, CPs will need to apply proactively for an exemption. Work continues in support of the DCMS/NHS activity planning which aims to improve the migration experience for vulnerable users of telecare equipment. The current focus is on gaining alignment on some aspects of the telecoms processes.

A trial of lift lines undertaken by Openreach has demonstrated that using an ATA adaptor to convert digital to analogue signals, using the existing analogue equipment had operated adequately, although some configuration or software changes might be required by equipment vendors. Openreach have recommended that Developers engage with their analogue vendors and their CPs to ensure that solutions are in place

Dark Fibre

Dark Fibre was soft launched in August 2021, however, the product transitioned to full launch on 01 June 2022. Following full launch, it has been agreed with industry to subsume the Dark Fibre IWG within the business as usual ethernet commercial and service meetings.

Orders for DFA are continuing to increase.  Openreach continue to report that their systems and processes are working well.

Consumer Switching & Number Porting

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

• 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
• Ofcom have also stated that a GPL process must be available for Business Customers who are switching their Voice or Broadband services.
• 3 April 2023 remains the target date for Industry compliance to Ofcom’s revised switching General Conditions (GCs)

OTA2 continue to engage with industry through OTS and GPL Process Design initiatives alongside the OTS Governance structure.

OTA2 established and chaired the OTS Steering Group, which successfully acted as a proxy to a full governance group, which has now been established. OTA2 continue to work with the governance Board of Directors in their new organisation ‘The One Touch Switching Company’ (TOTSCo)

The OTS DDG (Design Drafting Group), working with OTA2, continue to incorporate feedback and clarifications on process issues and will be producing an updated OTS process document shortly.

GPL Business switching design is being undertaken by two working groups with members drawn from a cross-section of the Business service provider community. With OTA2 support they are considering both the ‘simple’ and ‘complex’ scenarios associated with Business switching of NBICS (Voice) and IAS (Broadband) services.

For ‘simple’ business switching (e.g. single services at the same location) the option to use OTS is being considered, whilst for the ‘complex’ switching scenarios (e.g. multiple service at the same or different locations) a more ‘project managed’ process is being discussed, Key to both of these undertaking is to establish the baseline principles of business switching and also a simple, easy method for all Retail CPs to communicate with each other as part of the process workflow.

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. For more please see under ‘Porting Improvements’

Porting Enhancements to compliment the ‘One Touch Switch’ process

OTA2 continue to work with the Number Port Executive Steering Group (NPESG) to establish the most effective way of complimenting the Number Port and the OTS process.

A number of proposals have been produced and reviewed with stakeholders from both communities, identifying solutions that Porting CPs can opt into, which will offer shorter lead-times (compared to Porting Best Practice service level agreements) and simplified validation (reducing rejection volumes). A provisional choice has been made on which option to pursue, and Industry lead detailed design development is now underway to further refine this proposal, before re-submission to the NPESG and NPPCG for review and approval.

Porting improvements

Input from across the Number Porting community, has identified the urgent 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 their age and focus on analogue (TDM) voice services, at a time when ‘All-IP’ voice service is rapidly becoming the mainstream. 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

A Plan of Works for 2022 has been created to focus efforts this year and into the future, it includes:

• Porting Enhancements to compliment OTS
• Delivery of Right to Port (and Right to Retain) into live for all CPs
• CDB - Centralised (Number) Database
• Wholesale Porting
• Direct Routing
• GPL Number Porting Process
• Overhaul of Number Porting processes

Improvements already underway include: -

• Enhancements to facilitate the smooth and efficient transfer of analogue (TDM) to VoiP services for customers who are either switching or up-grading services – this has been delivered and is already supporting the increased volume of Porting requests associated with the move to ‘All-IP’

The NPPCG continue to monitor the transition to All-IP, with no reported issues raised at the July NPPCG session

• To establish a new Bulk Transfer process to facilitate Wholesale Porting. (i.e. porting at the Wholesaler level). A working group has been established to deliver an agreed process and a first draft is expected imminently.

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 process design has been produced and will be shared for review in the upcoming NPPCG session before being presented to the NPESG (assuming NPPCG approval) for their approval and sign-off

• PoV (Pre-order Validation) is seeing increased registrations and usage, which in turn are identifying opportunities to refine and improve the process as issues and exceptions are encountered that require addressing. This area is also being considered by the GPL process working groups, with recognition of the opportunity to streamline the over-lapping ‘validation’ processes when switching NBICS (Voice), and taking lessons learnt from Number Porting PoV into the Business IAS (broadand) ‘validation’ stage.


• CDB - Common (Numbering) Database - A strong document has been created that outlines the Number Porting requirements of a CDB, which will be used by the NICC as part of their RFI undertaking for the provision of a CDB. Progress will be monitored, and ongoing liaison undertaken with Ofcom and the NICC, looking at the strategy to develop and deliver a CDB solution. The NICC have requested a ‘summary’ version of this document to be produced, which has been drafted and will be circulated with the NPESG and NPPCG for their consideration.

CDB is considered a critical element of any Direct Routing solution, and so the two initiatives are closely linked.

• Right to Port/Right to Retain (EECC Requirement – April 2023) - A phased delivery of this capability is underway, already bringing benefit to customers and CPs, but the focus is now on delivering this capability across all Porting CPs, in time to be compliant to the revised GCs in April 2023. To support this OTA2 have drafted a ‘Right to Port’ document and are in the process of up issuing and publishing this, reflecting the latest agreements.

Service Levels

Copper & Fibre Provision

Openreach FAD (First Available Appointment Date) performance nationally, over the 5-day period ending 27 June 2022 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 been tracking steady for LLU and WLR, achieving a 4-week rolling average of85.7% and 83.2% respectively, by week ending 22 July 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