Telecommunications Adjudicator update for March 2023

An update on the principle areas of project activity being led by OTA2 in March 2023.

See the latest charts

At the end of March 2023, the number of unbundled lines stands at 7.39 million. There are 3.25 million WLR lines and the number of telephone numbers using CPS is 1.68 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 across industry.

Operational performance remains good.

The OTA2 framework for incident management: CP feedback has been consolidated into a revised document and additional detail added with some draft process descriptions. Review meeting held with Openreach, scope and impact being reviewed with the wider Openreach organisation. Written feedback on the document to be returned in the next week which will then be circulated to CPs.

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

Demand and performance figures are not yet available for March orders. The Openreach SIP to look at task closure delays and how these can be managed and closed as quickly as possible is ongoing.

Engagement with the CPs to look at the challenges of getting better quality orders into system and to reduce the number of orders which hit the planning phase and instantly go into delay. This is a very complex area and a challenge to drive the requirements for quality orders up whilst not creating impossible hurdles for the CPs to cross. This work will be on-going for some time.

Copper and Fibre

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. A fourthworking group session was held in March. This reviewed the output of previous workshops to ensure a joint understanding and continued support for the approaches being developed. This review identified some issues with implementation and a further workshop in April will seek to address these.

Openreach has agreed with OTA2 to run industry engagement during Q1 2023/24 to review FTTP measures, which will include KCI2 Assure performance. The expectation is that the metric set will include some of the existing SLA/SLGs and also metrics currently shared by the service managers with CPs. The aim is to define a set of Key Performance Indicators which are appropriately supported, relevant and recognised by Openreach and Industry and which will effectively track the end customer experience.

The latest version of Retransmission has been successfully deployed on 150k lines associated with Ribbon (ECI) DSLAMs. Openreach has not observed any issues since the DLM code was modified and this live version delivers a faster, more stable NGA1 platform with a lower fault rate. In view of this Openreach intends to start to deploy the version of Retransmission across the Ribbon (ECI) base of lines between April and December 2023.

CPs had previously identified that repeat fault SLGs, when associated with MBORC, had not been paid correctly. Openreach has stated that it will recalculate repeat SLG payments back to September 2021, which will be 12-months retrospective from the matter being raised at CFPCG and that these rebates are likely to be applied in Q1 2023/24. While the system issue affecting payments had existed for some time, Openreach consider that the 12 months proposed is consistent with the period that Openreach itself would apply if seeking to recover any billing discrepancies (e.g. under payments) from CPs.

All-IP Steering Group

Openreach had communicated that it would be ceasing services within the Salisbury and Mildenhall trial areas in April 2023 and to support this had served contractual notices for the affected products (but also provided an exemption process). However, in scope customers remaining on WLR are higher than Openreach expected and that learning from the trials has been less than anticipated. In view of this Openreach are planning to introduce service measures to prompt end customers to contact their CP. These are applying speed reductions to FTTC and applying outgoing call redirection to credit control numbers.

The changes will include:

• Gfast will not be in scope for FTTC speed degradation
• ISDN30 will not be in scope for Route to Credit Control
• Remote call forwarding will not be removed as part of Route to Credit Control
• When requested and agreed, Openreach aim to remove FTTC speed degradation and Route to Credit Control within 24 hours (except on weekends)

These measures will be applied in batches through April to end-July. Cessation of services will now be no earlier than 09 October 2023, with at least 4-weeks’ notice provided FTTP ECCs are charged by Openreach where an FTTP installation requires work beyond the end customer’s curtilage. Openreach plans to change its policy within FTTP stop-sell exchange areas to enable non-FTTP orders to be placed and accepted where a customer is unwilling to proceed due to the level of ECCs. The process impact on CPs is currently ongoing.

Industry has now submitted its SoR to support the migration of analogue lines to All-IP, where a telecare alarm is located at the customer premises. The draft process has also been discussed with a representative group of Alarm Receiving Centre's, who provided valuable feedback on how the process could be improved such that it had less impact on the Telecare industry. This feedback has been incorporated. Further dialogue with the Telecare industry and other non-engaged CPs will commence during April when Openreach have worked through the next level of process detail.

Consumer Switching & Number Porting

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

OTA2 continue to be engaged with industry for both OTS and GPL Business Switching Process Design initiatives.

The revised Ofcom General Conditions (GCs) will come into effect on 3 April 2023 – it should be noted that the new GCs are not restricted to switching (OTS or GPL) and include other requirements that communications providers need to be compliant to.

Residential Switching

TOTSCo (The One Touch Switching Company) has been created to specify, deliver and run the OTS Hub, which provides the messaging capability between gaining and losing retail CPs, as described in the OTS process. 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, including the OTS Process, API developer guides and Hub technical specification, and meeting schedules (registration is free).

Business Switching

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. A website, dedicated to GPLB processes and supporting material, is under construction and content review, and should be available to users in April 2023 – a communication by the GPLB-SG will be issued announcing this and providing more information.

A dedicated sub-group (known as the DDG – Draft Design Group) has been established to create a baseline GPLB switching process. This work is nearing completion, supported by Process Principles and a draft interface specification, and is planned to be shared for peer review in the very near future.

Both OTS and GPLB process have also been assessed when associated to a Number Port activity, when the end customer is switching their NBICS service (fixed voice), which has identified a number of interactions with the Porting process that require review and possible modification to optimise the switching journey – please see ‘Porting Improvements’ for more details.

Porting improvements

A new Porting process solution, called ‘Express Porting’ has been created to support the aspirations of OTS to offer a minimum lead time (MLT) for OTS authorised switching of NBICS (voice) that is not constrained by the artificial MLT applicable to existing Porting processes (today this is necessary to allow the ‘losing’ supply chain to inform the end customer of a ‘switch’ – OTS will have already delivered that message and gained the end customer’s ‘Express Consent’ for the switch to progress, removing the need for that step in the process.

The process is optional and not mandated for all voice providers to follow. Supporting voice service providers will be recorded in a published list, allowing OTS users to identify when the reduced MLT option is available. Note: there are many factors that influence switch order lead times, so not every order will benefit from this specific change, but the removal of the artificial MLT is considered to deliver benefits.

The prevention of 'customer harm’ remains an area of concern for the Porting community and representations from both residential and business customer retailers have been made to confirm that both OTS and GPLB processes will include steps to address erroneous switching of customers, specifically when utilising the porting process. Focus sessions have already been held and will continue to be run where these concerns can be reviewed and the appropriate responses defined and agreed.

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.

Supplier of Last Resort

Whilst the existing ‘skip one’ approach in the published ‘Supplier of Last Resort’ (PDF, 749.1 KB) (SOLR) process continues to offer a solution for many scenarios, it does not address all potential incidents.  An example of a scenario that requires addressing is of a VoIP provider with their own Number Range and no ‘upward’ supply chain getting into ‘distress’ and the need to devise a solution that would mitigate impacts on direct end customer services (the VoIP providers own customers) and indirectly (customers whose numbers have been exported) – this remains a key deliverable and OTA2 are working with industry to seek proposals in this area.

Service Levels

Copper & Fibre Provision

Openreach FAD (First Available Appointment Date) performance nationally, over the 5-day period ending 26 March 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 steady trend for LLU and WLR, achieving a 4-week rolling average of 90.4% and 87.7% respectively, by week ending 17 March 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