OTA2 Update for July 2012

 

At the end of July, the number of unbundled lines stands at 6.92 million. There are 6.01 million WLR lines and the number of telephone numbers using CPS is 3.31 million.

General

This month we are publishing our more comprehensive update. We continue to make progress on a broad number of subjects and as always are grateful for the commitment of all our stakeholders in supporting our efforts to improve consumer experience across the areas where we engage.

At the moment we have no official role in Openreach’s NGA (Fibre to the Cabinet / Premise) programme as they requested right at the beginning that we did not engage. However, we have recently had discussion with Openreach as we believe we can be helpful in a number of areas and they are considering this at the moment.

Migrations, Homemovers & Fixed Line Number Porting

OTA2 continue to work with Ofcom, Openreach & Industry to tackle various weaknesses within these processes and, in doing so, improve consumer experience whilst maintaining effective competition in the market place.

Migrations – We have now completed a comprehensive assessment of the weaknesses contained within existing MAC (Migrations Authorisation Code) & AOT (Advice of Transfer) migrations processes and with help from a number of industry stakeholders, a detailed ‘plan for improvement’ has been produced for both processes. This plan & final report will be published during August and its execution thereafter will be owned & progressed by the industry ‘Migrations Programme Board’.

Homemovers – The process used by industry to deliver a seamless experience for Consumers moving from one house to another, requiring their new services to be ‘live’ as soon as they move into their new premises, is called the ‘Working Line Takeover’ (WLTO) process.

Unfortunately, there are some weaknesses within the process, the result of which is that the wrong line is occasionally taken over causing major disruption for the 3rd party consumer concerned, not to mention the homemover who fails to receive the services they expected on the day they move to their new home.

These failures are referred to as ‘ELTs’ (Erroneous Landline Transfers) and examples have been extensively analysed to determine root causes and possible remedies. One such root cause has been that some CPs do not fully understand their responsibilities in supporting the WLTO process and, to remedy this, a new Code of Practice will soon be published by Ofcom which will detail the specific steps which each CP must complete to ensure a successful experience for the homemover concerned whilst protecting other 3rd party consumers from any unnecessary disruption.

In addition to analysing root cause, efforts have also been focused on developing consumer restoration processes and activities. The first of these activities focussed on aligning WLR3 with MPF is now rapidly progressing through development in Openreach.

Fixed Line Number Porting – Following various concerns being expressed by Ofcom and Industry stakeholders over the last 12 months, OTA2 were invited to collaborate with the stakeholder community to produce a ‘problem statement’. Soon after this work started it quickly became apparent that the concerns were both deep-rooted and well-founded with a number of the issues significantly impeding industry’s ability to:

i) compete effectively
ii) deliver an optimum consumer experience.

We have now produced a comprehensive problem statement which all participating stakeholders have ‘signed-off’ as accurate and clear. Following this important step, an industry workshop was held to determine the best approach to tackling the various issues and it was agreed that the most pressing issues for industry to address were:

i) Service Establishment (i.e. process for establishing porting arrangements in the first place)
ii) Order Handling (i.e. process whereby consumer requests to port their numbers are executed seamlessly and swiftly).

OTA2 will continue to lead this programme on behalf of the stakeholder community in conjunction with the Fixed Line Number Porting Commercial Group.

EMP Consumption model

We have now secured full industry commitment to adopt the new Consumption Model with effect from Release 1700 which is currently planned for July 2011. To achieve this objective Openreach & CPs will need to undertake a number of preparatory steps during the 12 month period leading up to R1700. A formal industry governance arrangement is being established by Openreach and OTA2 to ensure this process is managed carefully, and that all parties are in position to successfully adopt the new model next July.

Service Performance

At our last OTA2 Executive meeting, Openreach provided a retrospective review of last year’s (09/10) service level achievements and were invited to explain the thinking behind the targets which Openreach have proposed for this year (2010/11)

09/10 – A number of targets were not achieved despite the fact that many improvement projects were delivered. Openreach made the point that without these projects actual achievement would have been much worse. In mitigation, last winter’s severe weather was a major contributor to target shortfalls.

10/11 targets – Openreach explained that whilst the proposed targets for 2010/11 were lower than 09/10 targets, they were higher than 09/10 ‘actual’ performance and realistic.

Plan & Build

Executive Members expressed strong concerns regarding the current deterioration in ‘Plan & Build’ performance citing excessive ‘cycle’ times as particularly poor. Plan & Build activities include new PoP site build and expansion to existing PoP sites.

It was felt that perhaps ‘cycle’ times have been allowed to increase to ensure RFT (Right First Time) targets are met, although Openreach are clear that this is not the case.

Members pointed out that there are limited KPIs/SLAs/SLGs for Plan & Build activities and concerns over how interdependent activities are linked together. This is considered unacceptable given the importance this activity holds for CPs.

Openreach agreed to review what further measures can be produced within their information systems and to hopefully present a more comprehensive set of Plan & Build targets at next OTA2 Executive meeting, including RFT and Cycle times.

This entire subject is being managed under the auspices of the CPCG (Copper Products Commercial Group)

Openreach Industry Commitments (OICs)

Openreach have now delivered many of the original OICs which industry declared as ‘high priority’ requirements approximately 18 months ago, and which Openreach signed-up to as part of the wider Ofcom review of BT’s TSR Undertakings.

However, a very small number have not been delivered because they have been deemed as ‘not suitable’ or ‘to be deferred’.

OTA2 are working with Openreach and the relevant industry stakeholders to try to understand why these commitments are stalling and to try to find a solution to the problem.

In the meantime any roadmap development slots released as a result of a ‘cancelled’ or ‘deferred’ OIC, will be backfilled from a list of ‘OIC replacement candidates’ which will be developed & jointly owned by the Copper & Connectivity Products Commercial groups. OTA2 will oversee this process.

Connectivity Services

Ethernet Systems Transformation - The EST programme is very significant for the Connectivity Services CPs moving the trading platform from ECO X onto the EMP systems stack. OTA2 have been working with Openreach and the CPs to ensure that the User Requirements are captured, validated and signed off by the CPs. The focus of the activity is the EAD product which will be first onto the new systems but much of the learning and output will be utilised on the products which will follow.

Business Connectivity Market Review (BCMR) - Openreach have confirmed their belief that they meet their obligations as set out in the BCMR – that by utilising the existing Openreach equipment footprint they can address 80/90% of the business requirements, and that the geographic areas they do not reach can be addressed through other means, although they have no current requirements from CP's in those areas. They have confirmed that they will consider any requests which they receive.

Ofcom have concluded that, in the absence of any demand, this seems a reasonable position and that if any CP wishes to challenge this then it must follow the formal dispute route. This closes the formal action raised at the OTA2 Executive.

Strategic Ethernet Aggregation Product - Openreach have reviewed the SOR output from the workshops and have concluded that the requirements are beyond their near term development window of 18 to 24 months. There is a smaller requirement for an aggregated hand off product for EAD which will be considered in the nearer term, but the main requirement will be parked for the time being.

Minimum Security Standard

The NICC Minimum Security Standard (ND1643) has been published and can be downloaded via the following link;

http://www.niccstandards.org.uk/publications/llu_spec.cfm

NGNuk are also working to develop an inspection scheme which will be piloted later this year. As part of this activity, preliminary audits of smaller communications providers are currently being undertaken to ensure that the standard, its interpretation and implementation are written appropriately for such organisations. NGNuk are seeking to obtain accreditation for the scheme via UKAS (United Kingdom Accreditation Service) during the first half of 2011.

The Code of Practice (CoP), committing CPs to the full implementation of the Minimum Security Standard (ND1643) has now been signed by 12 major CPs/LLUOs. The task of OTA2 is now to work with those CPs that have signed the CoP, to monitor and report on progress towards implementation. The previously agreed task for the OTA2 of widening the scope of signatories to the CoP also remains a priority.

Service Levels

Our KPI charts show current performance levels.

OTA2 will continue to focus on:

  • 18 month Development Roadmap - implementation & change control
  • EMP consumption issues
  • Documentation issues
  • Data Integrity issues
  • WLR/LLU Process development
  • Connectivity Services - Product Issues
  • Connectivity Services Process Development
  • Current migrations processes-Critical Review
  • Erroneous Fixed Line Transfers activity
  • Fixed line porting - Improvements
  • Service levels (LLU/WLR/Ethernet)
  • Migrations Process development for NGA to/from Copper
  • Minimum Security Standards
  • Displaced Mobile Emergency Calls
  • Openreach Ethernet strategic Product review

    Rod Smith