Telecommunications Adjudicator update for June 2023

11 July 2023

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

At the end of June 2023, the number of unbundled lines stands at 7.07 million. There are 3.04 million WLR lines and the number of telephone numbers using CPS is 1.54 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.

We continue to see instances of poor working practices which could expose both engineers and the general public to risk. We will continue to keep H&S at the top of the agenda in our industry meetings. The OTA2 is working with Openreach to review the accreditation process to see if the guidance around safe working can be further enhanced, especially for working on Poles.

Operational performance remains good.

The OTA2 framework for incident management: Workshop with CPs organised was held on 15 June 2023. The session was very interactive and provided some good insight into the way that CPs can interact with a damage notification from Openreach. There is more to do to refine the framework document but this has provided the foundations to build upon.

Openreach have announced that they will release a file, containing the ‘at premises state’ of the underground duct which supplies the existing copper service. This data is gathered at the build stage of the Openreach FTTP deployment. CPs have been asked to review the data set and provide feedback. 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

Performance continues to be good. Order intake remains high c1500 per week with a slightly over 25% fallout to cancellation and a completion rate of c1100 orders per week.

The workstack has seen a decrease to 20.5K but fluidity of orders is proving problematic with about 55% of orders being non-fluid.
Work is continuing to look at how we can improve the quality of orders which come into the planning area and further work is being undertaken to expose any potential to remove any illegitimate delay from the whole of the delivery process.

Work on developing the Transflex system as a document sharing tool is progressing. CP input for some of the design proposals was sought at the July IWG and further interaction is planned, using the IWG and the SDF to ensure that the plans stay on course.

Openreach have reached out to the wider CP community to review the use of survey tools and how best to target them to gain the best insight into user experience. The aim is to investigate options and different approaches. Openreach are keen to engage any CPs who would like to participate via their service leads.

Copper and Fibre

Openreach has completed its detailed review of the FTTP post-Point of No Return cancellation charge and Abortive Visit Charge, which had resulted from the CP request to amend the FTTP contract to align with its existing policy. This request was made in Q4 21/22. CPs expressed their concerns that after a 14-month review, Openreach has notified and briefed its new policy. Industry continue to raise concerns and queries regarding the new approach; how it was implemented and the potential implications for the wider portfolio.

Industry engagement to review FTTP metrics is continuing and will run through to late summer. The expectation is that the metric set will include some of the existing measures 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. Work has also commenced to review the KCI2 Assure process utilised on complex FTTP provisions with a view to improving the customer experience and thereby reducing pre-installation cancellations.

Openreach intends to launch SOTAP nationally once the agreed target of 400 successful orders is met. To support achieving this volume Openreach will extend the SOTAP pilot terms nationally. The national launch is targeted for August 2023, however, if 400 successful orders are not achieved Openreach propose to continue with the pilot status nationally, using launch process to ensure capabilities are in place.

Openreach withdrew support for Battery Back-Up units they had supplied in 2018, however, Openreach still receives circa 120 jobs per week associated with battery backup faults, largely due to the BBU batteries running down. These are currently resolved by the Openreach engineers removing the BBU. Openreach have changed the process/messaging such that for any future BBU alarms, an informational message will advise the CP there is a BBU issue for them to address. This will commence mid-July. OTA2 has requested a view of the fault data, to allow for a follow-up with the CPs affected.

All-IP Steering Group

Within the Salisbury and Mildenhall trials, four batches of customers have had their service degraded, with the first three batches associated with speed reduction. Within these Openreach have seen 46% where there had been some level of customer activity in response to the service degradation. Cessation of customer services remain as being no earlier than October 2023. Openreach is currently working with industry to assess the risks associated with cessation and how to mitigate these.

National Stop-sell for WLR remains on track for 5 September 2023. There will initially be some exemptions, largely associated with where Openreach has not completed the delivery of a planned equivalent All-IP product.

Openreach has published its Consultation document on how it proposes to exit 103 priority exchanges by 2030. All Openreach products are affected by the proposed closures. Industry has been requested to respond by 21 September 2023 and Openreach has offered to engage with stakeholders to answer questions or discuss specific issues prior to any submission. Openreach intends to respond to the feedback by 22 December 2023.

Openreach remains on track to deliver the SoR which supports the migration of analogue lines to All-IP, where a telecare alarm is located at the customer premises in late Q4 2023, however CP consumption is unlikely to occur until 2024. The OTA2 has commenced briefing out the proposed process to external telecare bodies that are affected.

Consumer Switching

There is an Ofcom mandated process, known as ‘One Touch Switch’ (OTS), for switching Consumers (residential customers) between Retailers.

The revised Ofcom General Conditions (GCs) mandating this process came into effect on 3 April 2023, although industry has not yet been in a position to implement OTS.

TOTSCo (The One Touch Switching Company) was created, by the Industry, to specify, deliver, and run the OTS Hub. To view the latest news, technical and commercial updates for the Hub, please consider registering (it free) on the TOTSCo website www.totsco.org.uk

Industry and TOTSCo continue to work to agree and publish a timeline for delivery of OTS and the supporting Hub technology, along with proposals for on-boarding of Retailers (Consumer facing Communications Providers), billing and service support.

OTA2 maintain close engagement with Industry and TOTSCo, supporting both through a number of initiatives. These include the OTS-PWG (Process Working Group) which is addressing the details behind the baseline OTS process design, including the creation of ‘Best Practice’ guides and more detailed process advice.

In the revised Ofcom GC’s effective from 3 April 2023, Ofcom have directed that switching for Business customers must follow a Gaining Provider Lead (GPL) process, though unlike Consumer switching, there is no mandate of a specific process, only that Industry should adopt agreed ‘Best Practice’

To help define and document a ‘Best Practice’ for Business switching, OTA2 helped establish and co-chairs the Gaining Provider Lead Business Steering Group (GPLB-SG), with a membership that represents a cross-section of the parties involved in Business Communications service provision and switching. The group now has an active website, available for all at: www.fcs.org.uk/gaining-provider-led-business-switching/ Including in the available material is the initial GPLB Switching Process, an expanding FAQ section, etc.

The GPLB-SG are planning to run a webinar event in the near future, which will include a run-through of Business Switching Principles, the proposed process, and other areas.

Number Porting

The NPESG and NPPCG continue to consider what improvements should be made to the Porting process, which has been running for over 20 years. There is a growing acknowledgement that the UK has not kept pace with developments in Europe and around the world, and that the result is a process that no longer compares to the speed and efficiency achieved in other countries. The impending transition to an All-IP voice platform and the removal of limitations imposed by legacy analogue services opens up the opportunity for change in how porting works. However, as identified in OTA2 chaired NPESG sessions, any change will require investment, time and effort to overcome the inertia of moving from a solution that has been in place for so long.

The recent changes to GC’s made by Ofcom to address CLI validation (seen as a step to prevent phone fraud) and debates around the adoption of direct routing and a Centralised Database (of Phone Numbers), also add challenges to the community.

Number Porting is also not immune from the changes to switching (OTS and GPLB) and the fora are continuing to respond to this, considering how best to complement the aspirations of OTS (quick, easy and reliable switching), along with the new rules associated to revised GC’s. This also extends into Business Switching, through GPLB and alternative approaches, with a warning to CPs that the Number Porting process in itself does not deliver all aspects of the revised GC’s and that CPs should not rely solely on porting to discharge their obligation.

Supplier of Last Resort

The increasingly complex trading and supply structure adopted for VoIP (aka All-IP) services has highlighted the need for a review of the existing SoLR (Supplier of Last Resort) processes, which has been given more prominence due to the current economic climate. OTA2 are working closely with Industry, drawing on their expertise and knowledge, to both better define the problem statement and identify potential solutions.

Service Levels

Copper & Fibre Provision

Openreach FAD (First Available Appointment Date) performance nationally, over the 5-day period ending 3 July 2023 was as follows: -

Service Installation type	FAD First Available Appointment Date (Backstop SLA = 12 days)
Copper	6.0
FTTC (MI)	5.5
FTTC (SI)	6.3
FTTP (MI)	7.9
SOGEA (MI)	7.0
SOGEA (SI)	5.8
GFAST	5.9

Notes:

MI and SI are Managed-Install and Self-Install orders
FTTC is Fibre to the cabinet
FTTP is Fibre to the premises
SOGEA is Single Order Generic Ethernet Access
GFAST is Fibre-base Ultrafast Broadband

Copper Repair

LLU and WLR ‘on time repair’ performance has seen a relatively steady trend for LLU and WLR, achieving a 4-week rolling average of 86.4% and 82.1% respectively, by week ending 30 June 2023.