Telecommunications Adjudicator Update for September 2006

The number of Lines Unbundled has exceeded 850,000 The Tactical Automation Platforms remain stable. The EMP Platform is delivering increasing volumes of orders, albeit currently with lower than acceptable end to end Right First Time results. Co-Mingling and Backhaul Delivery are returning to their improvement paths.

A number of Quality of Service Measures are causing severe concern. The Right First Time delivery of Business As Usual (BAU) unbundled lines continues to deviate from planned quality levels (currently 78% against a target of 98%). As reported previously this measure has not yet met its planned quality targets. Openreach continue to develop an Improvement Plan that John Small (Openreach MD Service) is confident will address the problems; however, significant improvement has so far failed to materialise. John had targeted September for a significant improvement in Delivery Quality, this however has been missed. I have discussed this matter with Steve Robertson, CEO of Openreach, and Steve has assured me that a Robust Plan will be presented to the OTA and LLUOs in the near future. Fault Repair quality (Assurance) is also showing a significant and ongoing deterioration in performance.

As I am sceptical of the assurances I have received over many months I have specifically requested a Performance Improvement Paper that will set out all the Improvement & Ongoing Stability Plans that will cover Plan & Build, Backhaul Delivery, BAU Unbundled Loop Delivery, EMP, and Assurance (Repair) Performance. I require a clear Staircase of Improvement Targets, each point on the staircase defined by Time and the Actions to be taken and the Resultant Improvement in Quality to be delivered. I would expect this plan to have a number of stages, but the most significant uplifts in Quality to be delivered in the next three months. OTA will then test the assumptions and plans against the reality of what is happening in the operating LLU world.

Migration problems for customers are becoming increasingly apparent where the losing provider of service is based on LLU. These problems were first raised with BT by OTA and the LLUOs as key challenges that could impede the development of the market 18 months ago; OTA is concerned that unless concerted action is taken swiftly the LLU market will be put at a disadvantage. OTA in conjunction with Ofcom and Openreach will be setting up and coordinating a cross-industry plan involving LLU operators, IPStream Resellers and BT Wholesale to allow inter-product migrations to take place seamlessly. A further area OTA and Ofcom wish to act on is where a new service cannot be provided because there is already a live service on the line that has been left by a previous occupier. The discussions will also take into account the potential role of new regulation proposed by Ofcom to support broadband migrations.

Bulk Migration throughput volumes have accelerated in the last few weeks. RFT Delivery has recovered and is moving towards target.

Backhaul Delivery performance has improved in recent weeks and work continues to manage and refine the End to End process which includes BT Wholesale to ensure greater consistency & predictability.

Comingling PoP delivery to CDD (Contracted Delivery Date) is consistently achieving target whilst Delivery to CRD (Customer Required Date) has recovered an improving trend.

An increasing number of LLUOs including BT Wholesale are using the EMP Service and volumes are increasing, however the take up is slower than anticipated whilst LLUOs and Openreach work through the continuing teething problems associated with the introduction of a new IT Platform.

The new release, R300, was postponed allow testing to complete.

With increasing numbers of LLUOs now using EMP, greater focus is being given to ‘in-life’ performance and how it is measured & reported. In particular I have asked for and have been assured by Openreach that a version of the First Touch Last Touch measure that fully reflects the EMP parts of the processes will be available in the next few weeks. I expect to be able to share this with Industry in my next update.

To date, the amount of downtime due to ‘scheduled activity’ is a major cause for concern for the LLUOs and is under review with Openreach.

An SLA/SLG agreement for the EMP platform is nearing completion.

There are no Disputes in progress with the OTA at the present time.

I am pleased we have reached 850,000 lines on the current tactical platforms and processes. The Key to success is now getting the Right First Time KPI back on track for BAU as well as an OTA/LLUO supported Improvement Plan from Openreach. The expansion of LLU is still critically dependant on the Quality of PoP build and the Timely delivery of Backhaul circuits to enable the PoPs to Operate. It is therefore crucial that Openreach continue to focus on the Quality for Co-mingling and Backhaul services as well as BAU.

OTA will continue to focus on: Openreach Service Improvement Plan that covers Business as Usual Line Delivery; Assurance; Backhaul & Co-mingling Delivery Quality and Strategic Automation ( EMP) Plans & Delivery and Migrations Processes.

Peter McD. Black

Telecommunications Adjudicator