Telecommunications Adjudicator update for September 2023

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

See the latest charts

At the end of September 2023, the number of unbundled lines stands at 6.80 million. There are 2.73million WLR lines and the number of telephone numbers using CPS is 1.21 million.*

The following is an update on the principal areas of project activity being led by OTA2.

Passive Infrastructure Access

Given the prevailing challenges of the wider economy we have developed a framework document which sets out the principles to be followed by Network operators looking to exit or acquire assets built using PIA. The document will be published on the OTA2 web portal and referenced in the PIA Product description.

Operational performance remains good.

The product continues to mature and as it does a small number of issues are surfacing, these largely are characterised as ‘Learning to Live with Together’. The fact that we have multiple networks resident within the Openreach Duct & Pole estate was always going to produce some new challenges. The Incident Management Framework is one of these areas, together with a challenge of both CPs and Openreach using other CP infrastructure without prior permission, which we are working through at the working group level.

Active workstreams currently running to improve the product and its usability for CPs are:

• Health & Safety and good working practices
• NA Evidence and quality documentation for CPs to able to instruct their field resources.
• Connecting Customers
• Incident Management
• Multiple Network Adjustment orders for the same blockage.

Ethernet

Performance remains steady. Order intake remains high but slightly lower c1500 per week with a slightly over 25% fallout due to cancellation and a completion rate of c1100 orders per week. CPs are raising concerns over the closure of declared delays and some challenges in booking surveys. Openreach are reviewing both areas of concern and will feedback at the EPCG & ESF.

The workstack reduction continues slowly and stands at just over 20k. Fluidity of the workstack has improved slightly but this remains a key area of focus for Openreach c58% non-fluid.

Areas of interest

Order Quality – Front desk order quality and setting standards. This work is proving difficult for a number of the CPs to support. Openreach are reviewing options

Transflex phase 2 – Information sharing and embedding the use of Transflex into orders. This work is progressing internally with the Openreach design teams, the next stage is to present the outline designs to CPs to ensure that the output meets the expectation.

Survey Tools – getting the most out of customer surveys. Openreach are continuing to look at how they can get the most out of the feedback mechanisms.

Copper and Fibre

Openreach has responded to the recent letters from industry on FTTP post-PONR cancellation charges and sought to clarify its cost-based approach, re-emphasising that it considers the charges as reasonable. The new policy was adopted by Openreach on 16 September 2023. However, the industry position remains that it does not feel that Openreach has fully responded to the points raised and that it considers there has been a change in rationale for the new policy during the discussions. Openreach agreed to review how it might better clarify the constituent elements of the charge, but without disclosing cost information.

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 is also continuing regarding the KCI2 Assure process utilised on complex FTTP provisions with a view to improving the customer experience and thereby reducing pre-installation cancellations.

Openreach withdrew support for Battery Back-Up (BBU) units in February 2018 and since this date the BBUs have been a CP responsibility for maintenance or replacement. Openreach are still receiving repair requests from CPs, which can only be resolved by Openreach engineers removing the BBU. Openreach is currently testing new processes that will advise the CP that the BBU needs to be addressed by the CP, so that they can action support for these vulnerable customers.

All-IP Steering Group

Openreach deployed the WLR UK Stop Sell on 05 September 2023. The deployment was successful, with some very minor issues resolved by 06 September 2023. A modification of the rule set was implemented to enable CPs to continue to order WLR and/or SMPF outside of the GEA footprint until 28 March 2024 to reflect that SOTAP is not yet widely available. In addition, the ‘Exceptions’ process remains in place to address circumstances where no equivalent product currently exists on FTTP or SOGEA

Within the Salisbury and Mildenhall trials, Openreach have successfully migrated, ceased or exempted 95% of the WLR assets. Within the 5%, Openreach has informed CPs that it will cease those customer lines where it has seen no voice or data traffic in the last 6-months, on 31 October 2023. These assets have already had service degradation measures applied. Where there has been voice or data traffic in the past 6-months, the service degradation currently being applied will be removed and will remain active, however Openreach reserve the right to take further measures against these lines as it nears the December 2025 deadline to encourage migration.

Openreach delivery of its development to support a new “On the Day” process for customer migrations involving Telecare alarms remains on track for delivery in November. Once the lead CP has finalised its own systems development, a pilot will be undertaken commencing early 2024.

Openreach has had over 20 responses regarding its Exchange Exit consultation, with some further bilateral discussions planned on the responses. Openreach has committed to an official response to industry prior 22 December 2023. Openreach have stated that feedback from industry indicates there is support for a phased approach but that industry have stressed that Openreach must not under-estimate the potential impact on CPs. Industry indicated they consider the commercial offerings from Openreach as welcome but that the responses flagged additional areas of support that industry consider is required.

Customer Switching

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 (One Touch Switching) for Residential customers.

Industry and TOTSCo (www.totsco.org.uk) 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. Significant effort has gone into the production of supporting documentation, to complement the OTS process, including guidance for ‘Best Practice’ when using OTS to switch customers.

OTA2 maintain close engagement with Industry and TOTSCo, supporting both through a number of initiatives.

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’.

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 has an active website, available for all at: www.fcs.org.uk/gaining-provider-led-business-switching/ where CPs can find Process documentation, draft interface specifications, FAQs and more.

Number Porting

Ofcom have written to OTA2 requesting that we lead on the implementation of OTS Porting (aka Express Porting).

The request is for OTA2 to work with Communications Providers in scope of OTS rules, including, as appropriate, in consultation with the existing industry number porting groups, to focus wider industry effort on developing and implementing changes to number porting best practice to ensure it fully takes account of the interactions with OTS and achieves a better switching and porting experience for residential customers. It is recognised this should not compromise industry’s ongoing preparations for OTS launch on the go-live date of 14 March 2024, however it must happen as quickly as possible thereafter.

Engagement with industry is already underway, with the Ofcom letter a major agenda item of the recent NPPCG (5 October 2023) – OTA2 will schedule a further session in the very near future and continue working closely with industry to identify and implement uplifts to the Number Porting process, that will best compliment the aspirations of OTS and expectations set out within Ofcom’s letter.

Notwithstanding the letter from Ofcom, the NPESG and NPPCG continue to consider what improvements should be made to the Porting process, which has been running for more than 2 decades, seeking to identify opportunities for improvement and simplification within the existing framework and processes. At a time when the move to All-IP is being accelerated by the pending withdrawal of WLR, there is real opportunity to reshape the existing processes and devise a strategy to further exploit the opportunities that this will bring, with more radical thinking about the future of Porting included in those discussion.

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 switching processes.

Service levels

Copper and fibre provision

Openreach FAD (First Available Appointment Date) performance nationally, over the 5-day period ending 03 October 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 a slight downward trend for LLU and WLR, achieving a 4-week rolling average of 86.2% and 81.3% respectively, by week ending 04 October 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