Telecommunications Adjudicator update for May 2022

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

See the latest charts

At the end of May 2022, the number of unbundled lines stands at 8.28 million. There are 3.89 million WLR lines and the number of telephone numbers using CPS is 2.00 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.

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 May PCG, Openreach still looking at the overall pole replacement programme and optimising the workflow with its partners. Feedback is being provided to the 4 trialists and learnings will be shared with the wider CP community once there is detail to share.

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 c1200 orders a week being delivered.

Planning performance remains an area of focus with day 6/8 running flat, the day 14 measure is flattening off remaining a bit low and is an area of concern for CPs. The challenge is given the higher than anticipated demand mobilising resource to both handle the increased volume and attack the workstack is challenging.

Optical Services: good levels of service being reported.

Copper and Fibre

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).  Dialogue between Openreach and industry has been ongoing for some time, however, Openreach plan to present an update and next steps at the June CFPCG.

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 anticipated in July.

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 are planning to change the scope of OTDU and will outline the detail of this at the June CFPCG.

Openreach informed the CFPCG that it is considering implementing a ‘stop sell’ of the Fibre on Demand (FOD) product from 1st November 2022, following a 6-month notice period. Following CP feedback, Openreach have stated that any ‘stop-sell’ will not progress until this has been fully considered.

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.  Discussions have commenced in detail regarding how Openreach approach the process of ultimately turning off WLR3 as part of the Salisbury and Mildenhall trials. This work will continue with the ambition of agreeing an industry approach, especially around managed and supported migrations. To date, Openreach have forecast migration plans covering 95% of the installed base for the two trials.

A discussion took place with Ofcom at the All-IP Steering board regarding the potential requirement to standardise the BBU across CPs/Network operators to avoid the need for swap outs etc. Ofcom suggested that NICC might be best placed to undertake this work.

Work continues in support of the DCMS/NHS activity planning which aims to improve the migration experience for vulnerable users of telecare equipment.

Dark Fibre

Dark Fibre was soft launched in August 2021, however, the product transitioned to full launch on 01 June 2022.

Orders for DFA are gradually increasing and 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 Switch 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 a working group drawn from the Business service provider community, reflecting a cross-section of retailers and wholesalers. With OTA2 support they are considering both the ‘simple’ and ‘complex’ scenarios associated with Business withing of Voice and/or Broadband services, recognising and addressing the specialist requirements of Businesses (e.g., parallel running of services, out of hours switching, etc)

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, by April 2023

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 agreements) and simplified validation (reducing rejection volumes). These are now being refined and defined to a greater level of detail. Before being re-presented to the NPESG and NPPCG for approval to progress.

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, so that any potential issues associated to the Number Porting process and be quickly identified and addressed.
• 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).
• 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.
• 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.
  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 5 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 an up-turn for LLU and WLR, achieving a 4-week rolling average of 87.9% and 83.6% respectively, by week ending 27 May 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