Annual Report 2010
BT Group plc
Welcome to the Equality of Access Board (EAB) Annual Report. The EAB was
set up in 2005 to monitor BT’s delivery of the Undertakings. It also advises BT on
compliance and reports its findings to Ofcom and industry. Key opinions on BT’s
performance during 2009/10 are expressed throughout the report and how the
EAB forms these opinions is explained in ‘Monitoring, Reporting and Advising’ on p5.
PricewaterhouseCoopers LLP provides independent assurance on key elements of
the EAB’s Annual Report and these are indicated by the following symbol found
throughout the report.
Contents
12
20
25
Major variation to the
Undertakings
Chairman’s introduction
1
Review of the year
2
The EAB
4
A variation reschedules the remaining delivery milestones
for some products and systems.
How BT delivers the Undertakings
8
Focus on Next Generation Access
The EAB assesses whether BT is factoring Equivalence of
Inputs into the development and launch of next
generation products.
BT employees give their views on
the Undertakings
A survey of BT employees considers their views on how
the company is implementing the Undertakings.
31
Current generation products and systems
12
Next generation access
18
Next generation networks
22
Behavioural change
25
Reviews of compliance themes
30
Understanding non-compliance
33
Outlook for 2010/11
36
Indicators
38
PwC’s assurance report
48
Glossary
50
Assessments of product
development and the SoR process
The EAB reviews key processes underpinning BT’s delivery
of the Undertakings.
The Equality of Access Board (EAB) is a committee of the BT Group plc Board. BT Group plc is a public limited company registered in England and Wales.
This is the EAB Annual Report for the period ended 31 March 2010. Unless otherwise stated all facts, statistics, events or developments are correct to
the nearest practical date before 14 May 2010. The opinions expressed are those of the EAB, not necessarily those of BT Group plc. The EAB Annual
Report is a requirement of the Undertakings given to Ofcom by BT pursuant to the Enterprise Act 2002.
EAB Annual Report 2010
1
Chairman’s introduction
The Equality of Access Board is no longer the only body in the world overseeing a
functionally-separated access operation. Other countries have followed similar paths
and the Independent Oversight Group in New Zealand, the Supervisory Board in Italy
and the EAB in Sweden all hold similar roles to our own.
making progress toward the new extended milestones. We are also
monitoring performance levels to confirm there is no incentive for BT to
remain on non-EoI products and platforms.
Carl Symon
EAB Chairman, 14 May 2010
Despite the relative ‘seniority’ of the EAB compared to our international
peers, we are still evolving our approach and we have welcomed the
chance to share our experiences with other bodies overseeing functional
separation.
One of the main shared learning points has been the importance of
listening to the views of Communications Providers (CPs) as we form our
opinions. In the early days, this gave us a customer perspective on
whether the products in the Undertakings were delivering Equivalence of
Inputs (EoI) as required. Today – whilst there are still a number of
milestones to come – CP feedback is crucial in helping us to determine
whether BT is continuing to comply with its ongoing EoI obligations as
well as appropriately factoring it into future products and services.
Our support arm, the Equality of Access Office (EAO) attends industry
working groups and fora to gain an insight into the role that industry
engagement and consultation plays in the development of new EoI
products. We also continue to invite CPs to attend our meetings and the
EAO regularly looks into matters raised by industry via our issues
management process. Whilst we have no direct remit over customer
service levels, the EAB continues to recommend that BT engages with CPs
to resolve issues that come to our attention.
The benefits anticipated by the Undertakings are now being delivered
and there has been a roll back of regulation on pricing. The product key
performance indicators show that current generation products and
services are offered equivalently.
The removal of the imminent deadlines for systems separation and
Wholesale Line Rental has had a major impact on our approach to
monitoring during 2009/10. Our focus has shifted to ensuring that BT is
The focus of BT, industry, government and Ofcom has shifted towards the
launch of BT’s Next Generation Access (NGA) network. The development
of new NGA products on an EoI basis has become critical for some CPs.
During 2009/10, we continued to follow the ‘principles-based’ approach
to monitoring NGA that we developed last year. We also gained a specific
obligation for NGA regarding passive inputs to Fibre-to-the-Cabinet
products which will see us monitoring the availability of solutions that
give CPs greater access to the infrastructure. We will continue to listen to
the views of all of our stakeholders on the debates around future NGA
products and policy, and our role remains to ensure that EoI is assured
where required.
The EAB has this year paid particular attention to the processes
supporting the development and launch of new EoI products following
concerns expressed by CPs. The successful introduction of new and/or
improved services is important in both the current portfolio and that of
the next generation of services. We have taken a risk-based approach to
assessing BT’s ongoing compliance with the Undertakings. We will
continue to maintain this flexible approach to assessing and monitoring
key risk areas and advising BT on them.
The EAB continues to play an active role in making recommendations to
BT. During the year we deliberated on the underlying reasons for a
number of breaches as we have always aimed to encourage BT to address
the root causes of non-compliance. We have seen progress with fewer
reported breaches and complaints. However, there are still a few
persistent issues which are raised by CPs and which we have asked BT to
analyse further.
Ofcom’s Wholesale Local Access and Wholesale Broadband Access market
reviews due to be concluded in 2010 may result in changes to the
landscape in which the Undertakings operate. We will continue to follow
the guiding principles of the Undertakings whilst awaiting the outcome of
these reviews and we look forward to BT’s building on the good progress
it has made to date.
2
EAB Annual Report 2010
Review of the year
During 2009/10, it was widely considered by the EAB, Ofcom and industry that many
of the benefits anticipated when the Undertakings were first agreed were now being
delivered – in particular, increased competition in the access market, higher
broadband penetration and lower pricing for some products. BT remained committed
to ongoing compliance with the Undertakings, although non-BT CPs continued to
express concern about aspects of some products and services.
Partly to reflect the changing market environment but also as a result of a
re-alignment of priorities for both BT and industry, there was a major
variation to the remaining Undertakings milestones for Operational
Support Systems (OSS) separation and product Installed Base Migration
Complete (IBMC) delivery. The EAB’s role continued to evolve to include
these and other changes.
Re-prioritisation of the remaining
Undertakings milestones
In September 2009, Ofcom published a variation to the Undertakings
regarding the remaining delivery milestones for OSS and IBMC dates for a
range of products including the equivalent version of Wholesale Line
Rental (WLR3). This was the twentieth variation to the Undertakings since
they were first agreed and it rescheduled the remaining delivery dates for
OSS and IBMC. It also replaced individual product IBMC dates with a
composite measure based on customers migrated. In return, Openreach
agreed to offer a package of new service developments to its CP
customers, known as the Openreach Industry Commitments (OICs). BT
also agreed that Openreach would regularly publish a roadmap of the
OICs and the change control that would apply to these commitments.
The EAB’s role continues to evolve
The variation led to an extension of the EAB’s responsibilities. A further
exchange of letters between BT and Ofcom dealt with additional
voluntary commitments and reporting to complement the revised formal
commitments. These additional commitments included new
responsibilities for the EAB, such as monitoring delivery of the new
systems stack for business customers, attending systems ‘roadmap’
sessions and reviewing Comparative Performance Charts (CPCs). CPCs
track whether BT is advantaged by the delay in IBMC dates and the
related continued use of non-EoI products.
At the time this report was published, the EAB was validating the first
roadmap-related obligations and had completed its first analysis of the
CPCs. It found that the CPCs showed no evidence of a performance
advantage to either BT CPs or non-BT CPs resulting from the delayed
migration from legacy to EoI products.
Next Generation Access becomes a
high priority
NGA was under the spotlight throughout 2009/10 with discussions
continuing on how to develop a suitable regulatory landscape and clear
technical specifications for NGA. BT began trials of Fibre-to-the-Cabinet
(FTTC) and announced that it would start trials of Fibre-to-the-Premises
(FTTP) in 2010/11.
A variation extended the EAB’s responsibilities for monitoring
Openreach’s provision of passive inputs for FTTC on an equivalent basis,
should these be made available. The EAB also continued with its
‘principles-based’ approach to monitoring NGA. It found that BT was
compliant with EoI principles to date, but needed to ensure CPs offering
services to business customers were also engaged in product
development. This was because the initial focus had been on working
with CPs offering services to residential customers.
The EAB heard concerns from CPs during the year regarding Openreach’s
approach to developing the Voice over NGA (VoNGA) product. Openreach
will take a more active role in managing VoNGA – similar to its role in
offering WLR3. The EAB considered that its launch would not affect
Openreach’s compliance with the Undertakings. It also found that
Openreach was factoring EoI into the development of its NGA network.
Review of the year
EAB Annual Report 2010
3
21CN programme moves at a slower pace
Risk-based approach to ongoing compliance
The focus on NGA shifted attention away from the delivery of BT’s next
generation network, 21st Century Network (21CN), where a strategy
revision in 2008 has since led to slower deployment. BT completed the
‘Pathfinder’ trial successfully in South Wales and also began to roll out the
Wholesale Broadband Connect product across the UK. However, it
announced in April 2010 that it would not perform voice service
migrations as part of the Pathfinder trial. It announced also that the full
commercial deployment of its 21CN will in future be based on customer
demand and voluntary migrations. The company has acknowledged that
NGA is its current priority, but remains committed to ensuring that any
revisions to its 21CN plans are conducted in line with its Undertakings
obligations.
The EAB has broad responsibility for checking BT’s compliance with all of
the Undertakings obligations on an ongoing basis. As part of its regular
risk assessment, the EAB identified five key risks and conducted
systematic reviews in these areas during 2009/10.
Equivalence is a reality for many products
Current generation products such as WLR3, Local Loop Unbundling (LLU)
and Ethernet remain important to many in industry. In particular, the
migration from the older ‘tactical’ WLR2 product to the newer ‘strategic’
WLR3 product is an important step in ensuring that equivalent services
are on offer for all CPs. During 2009/10, the product key performance
indicators (KPIs) continued to show that equivalent services were
available across all current generation products, with few issues recorded.
Nevertheless, some of the obligations relating to current generation
milestones were not delivered in compliance with the Undertakings. This
was because of pressures on Openreach’s development resources as a
result of changes in the market, including the development of NGA and
new requirements from Openreach’s customers.
At the time this report was published, Ofcom was conducting reviews of
the Wholesale Local Access and Wholesale Broadband Access markets
and the EAB will await the outcome with interest as they may have a
significant impact on pricing and regulation for current and next
generation products.
BT employees give their views on the
Undertakings
The EAB conducted a survey during 2009/10 to measure BT employees’
perceptions of compliance with the Undertakings. The survey asked
whether employees felt that BT treated BT CPs and non-BT CPs
equivalently, and whether they considered that their colleagues acted in
compliance with the Undertakings. It also checked that employees had
the tools to remain compliant and whether they felt that BT treated all CPs
equally.
Over 90% of responses across all lines of business were positive and the
majority of employees were confident that BT was offering equivalent
services to both BT and non-BT CPs. Other measures on the EAB’s
‘behavioural dashboard’ also showed improved year-on-year compliance
rates. The EAB believes that these positive outcomes show that the
Undertakings are ‘business as usual’ for BT employees, but the company
must maintain its focus on training and communications on the
Undertakings so that these high compliance levels
can be maintained.
The EAB held reviews of information sharing across BT’s lines of business.
It was satisfied that all lines were aware of the risks around information
sharing and had put in place adequate controls and training to ensure
that employees complied with the rules. The EAB also reviewed a number
of BT’s outsourced operations in India and found that they were
compliant with the Undertakings. It did, however, identify some issues
around Undertakings awareness. It also looked at some of the processes
associated with the Undertakings – such as the product development,
Statement of Requirements (SoR) and escalations processes – partly as a
result of concerns raised by CPs.
The EAB found that these processes were largely functioning compliantly
although there were some issues requiring resolution. In particular, there
was scope for more information to be shared with CPs on the rationale for
the acceptance or rejection of SoRs. The EAB will be conducting a series
of follow up reviews in the coming year, including a review of the new
SoR process launched by Openreach.
Lower levels of non-compliance, but still
some issues
There were fewer non-compliant incidents reported to the EAB during
2009/10, with lower numbers of breaches and complaints recorded. Five
non-trivial breaches were associated with the re-prioritisation of the
Undertakings milestones, and there were fewer trivial breaches reported.
However, the EAB saw a rise in the number of issues raised to it informally
by CPs, indicating that there are still matters to be investigated and
resolved.
Conclusion
The EAB is satisfied that BT has made significant progress during the year
towards embedding compliance with the Undertakings in its way of
working. The EAB’s monitoring programme across current and next
generation products and services has found that BT is committed to
offering equivalence and adhering to the principles of the Undertakings.
The majority of BT employees have a good understanding of the
Undertakings, which they are applying in their day-to-day jobs. However
there remains a small number of persistent issues in need of resolution –
for example, the operation of the SoR process has continued to be a focal
point for industry concern – and the EAB will continue to review these
areas to check for compliance. The EAB will also continue to evolve its
monitoring programme to encompass the new requirements brought by
variations to the Undertakings and will await the outcome of Ofcom’s
market reviews with interest.
EAB Annual Report 2010
4
The EAB
The Equality of Access Board was established on 1 November 2005 as part of the
Undertakings offered by BT to Ofcom. It has five members:
1
2
3
4
5
1. Carl Symon, Chairman
4. Dr Peter Radley, Independent
Carl Symon was appointed a non-executive director of BT Group plc on
14 January 2002. He retired from IBM in May 2001 after a 32-year
career, during which he held senior executive positions in the USA,
Canada, Latin America, Asia and Europe. Carl is a non-executive director
of BAE Systems plc and Rexam plc, a former non-executive director of
Rolls-Royce plc and a former Chairman of HMV Group plc.
Dr Peter Radley is the Chair of the IET Communications Sector Panel.
He is a Fellow of the Royal Academy of Engineering and has been
involved in the telecommunications industry since 1965. Between 1991
and 2002 he held positions in Alcatel with global responsibility for
technology and marketing and as Chairman and CEO for Alcatel UK. He is
a member of the Broadband Stakeholder Group. Since 2002, Peter has
been an independent advisor to a number of organisations including the
DTI and South East England Development Agency and he has also been
chairman of technology start-up companies in the broadband, IP and
mobile sectors.
2. Sir Bryan Carsberg, Independent
Sir Bryan Carsberg was Professor of Accounting and Business Finance
and Dean of the Faculty of Economic and Social Studies at Manchester
University, before becoming Professor of Accounting at the London
School of Economics from 1981 to 1984. He was Director General of
Oftel (the former telecommunications regulator) from 1984 to 1992,
Director General of the Office of Fair Trading from 1992 to 1995 and
Secretary General of the International Accounting Standards Committee
from 1995 to 2001. Sir Bryan is currently Chairman of Council and
Pro-Chancellor of Loughborough University. He holds a number of
non-executive board appointments. He is a Chartered Accountant.
3. Stephen Pettit, Independent
Stephen Pettit is a non-executive director of National Grid plc and
Halma plc. He is Chairman of ROK plc and a former executive director of
Cable & Wireless plc. Before joining Cable & Wireless, Stephen was Chief
Executive, Petrochemicals at British Petroleum. He was previously a nonexecutive director of National Air Traffic Services, KBC Advanced
Technologies plc and Norwood Systems Limited.
5. Himanshu Raja, BT senior manager
Himanshu Raja is the Chief Financial Officer of BT Innovate and Design
and is also responsible for BT Group’s capital budgets. Himanshu joined
BT Group in 2001 and has held various senior financial positions in BT.
Most recently he was Chief Financial Officer of BT Operate and before
that Chief Financial Officer of BT Wholesale. Before joining BT, Himanshu
worked for US companies MCI WorldCom, UUNET and MFS. He is a
Chartered Accountant.
The EAB continued
EAB Annual Report 2010
About the EAB
Monitoring, reporting and advising
The EAB is a committee of the BT Group plc Board although its structure,
membership and obligations to Ofcom make it unique. It has oversight of
the whole of BT in its mission to monitor compliance with the
Undertakings. The EAB’s monitoring work with different BT lines of
business is described in more detail on p8. The EAB has Terms of
Reference setting out its role, monitoring and reporting remit, its powers,
how its members are appointed and its organisation. See
http://www.bt.com/eab for more information.
The EAB monitors BT’s delivery of key Undertakings, reports on progress
to Ofcom and industry and offers advice to BT on its compliance with the
Undertakings.
The Undertakings require that the EAB has five members: three
independent members, one BT Group plc non-executive director and one
BT senior manager. There were no changes in membership during
2009/10.
The EAB is supported by the EAO and the EAB Secretary on all matters
within its remit. The EAO reports regularly to the EAB on the detailed
status of BT’s delivery of the Undertakings. It carries out investigations
into complaints made by CPs and into possible breaches of the
Undertakings on the EAB’s behalf.
During 2009/10, the EAB Secretary organised four Board meetings as
well as a number of other informal sessions and enabled the EAB to
receive a wide range of input to its deliberations. Minutes have been
provided to Ofcom and the EAB Chairman regularly reported the EAB’s
views to the BT Group plc Board.
Monitoring
The EAB conducts a wide range of monitoring activities to assess BT’s
compliance with the Undertakings. During 2009/10, variations to the
Undertakings led to changes in these responsibilities. A variation
amended the approach and extended the dates for full systems
separation and EoI delivery as well as introducing new requirements.
These included the delivery of a set of Openreach product enhancements
and the product roadmap and associated documentation.
The changes led to new monitoring responsibilities for the EAB, including
the requirement for the EAB to review the CPCs for certain products. The
EAB continued to monitor BT’s product KPIs as part of its assessment of
whether equivalent services were on offer for BT CPs and non-BT CPs.
In the past couple of years, the EAB has developed a ‘principles-based’
approach to monitoring NGN and NGA. This involved ensuring that BT
complies with certain principles rather than assessing its ability to meet set
delivery deadlines. The EAB monitors key themes to help assess BT’s
compliance with the Undertakings for NGA and NGN (see boxes on pages
20 and 23 for more information). During 2009/10, a variation to the
Undertakings on FTTC required the EAB to oversee equality of provision of
How we work
CORE MONITORING PROCESSES
AUDIT & VALIDATION PLAN
MILESTONE VALIDATIONS
PRODUCT KPIs + CPCs
CPs
CPs
BT
COMPLAINTS
COMPLAINTS & BREACHES
EAO
BEHAVIOURAL MEASURES
EXEMPTIONS & VARIATIONS
EAO MONITORING REPORT
ISSUES MANAGEMENT
EAO REVIEWS
5
EAB BREACHES PROCESS
REGULAR & AD
HOC BT REPORTS
EAB MEETINGS: DELIBERATION & DECISIONS
DIRECT CP VIEWS
EAB MINUTES & OVERVIEWS
EAO ASSESMENTS
ANNUAL REPORT
OFCOM BRIEFING
REPORTING TO EAB
6
The EAB continued
EAB Annual Report 2010
FTTC passive inputs by Openreach, should they be available at a future
date.
The EAO also assesses BT’s ongoing compliance with obligations from
previous years. It does this through audits of ongoing compliance with
specific sections of the Undertakings on a rolling basis as defined in the
EAO’s Audit and Validation plan. The EAB also agrees a programme of
ongoing compliance reviews based on areas of known or potential risk. In
devising the programme, the EAB considers common themes arising from
breach cases or issues identified during the validation of key milestones
and other Undertakings obligations. The EAB also takes account of the
findings of relevant internal and external audit reports that have assessed
BT’s delivery of the Undertakings, as well as issues raised by stakeholders.
The EAB’s monitoring footprint is shown in the table below:
Approach to
monitoring
Milestone-based
Principles-based
EAO activity
Application
Full scale product
Current generation
validations examining
products, e.g.
delivery by set timescales. WLR3, LLU.
Also covers products
due by dates amended
by exemptions and
variations to the
Undertakings.
Regular monitoring of
agreed areas of focus
through attendance at
working groups and
meetings with key
stakeholders. Also
includes product
validations with launch
dates at BT’s discretion.
Regular compliance Monthly, quarterly or
annual recurring reviews
of areas mandated by
the Undertakings.
NGN and NGA.
Product KPIs,
behavioural
monitoring, systems
access (e.g. the new
obligations in relation
to systems).
Ongoing compliance A rolling programme
testing all other
non-milestone related
Undertakings obligations.
It also includes detailed
reviews and ‘spot checks’
of areas identified
through risk assessment.
Investigation of key
risk areas (e.g.
information sharing)
through compliance
spot checks and full
scale reviews.
Breaches and
complaints
Breaches notified by
BT as found by the
EAO or complaints
reported to the EAB
or BT.
Investigations of
breaches and complaints
reported to the EAB by
BT and those found by the
EAO, as well as complaints
received from CPs via its
formal complaints
process.
The EAB applies similar criteria across all of its monitoring activities:
Blue
Undertaking delivered or review completed.
Green
Undertaking delivery on track, or in the case of ongoing
compliance, review completed with no issues identified.
Amber
Undertaking is at risk, or in the case of ongoing compliance,
issues identified.
Red
Undertaking date has been missed or is in jeopardy,
or review has identified major deficiencies or issues.
The EAO Director has authority to move the delivery status of significant
Undertakings from Green to Blue before reporting the outcome to the
EAB, although this authority is delegated for more minor obligations. This
applies to both the delivery of milestones and the completion of ongoing
compliance reviews. As part of its assurance opinion,
PricewaterhouseCoopers LLP (PwC) assesses the EAB’s work across all of
these monitoring areas. Those activities referred to in its assurance
opinion are marked by
throughout the report.
Reporting
The EAB is required to publish this report following a briefing to Ofcom. In
previous years it has published a separate, confidential report to Ofcom
but this year it has aggregated all of its findings into one report.
The EAB is required by the Undertakings to report on areas including its
views on the governance measures associated with the Undertakings,
BT’s delivery of major milestones, potential future breaches and the
findings of the product KPIs.
PwC provides independent assurance to Ofcom and the EAB on elements
of this report. For more information about the assurance of key elements
of the report – which is agreed on a tri-partite basis between the EAB,
Ofcom and PwC – see p48.
The EAB also publishes a regular update about its activities on its website,
http://www.bt.com/eab.
Advising
The EAB advises BT on areas where it needs to improve its compliance
with the Undertakings. During 2009/10, the EAB offered advice to BT
based on the findings of its monitoring programme. It made a number of
recommendations to BT regarding the company’s compliance in areas
such as information sharing and learning from breaches. During its
participation in industry working groups, the EAO also made a number of
recommendations regarding compliant ways of working and sharing
information on an equivalent basis.
The EAB continued
Stakeholder engagement
The EAB has three key sets of stakeholders in the UK: CPs and industry
associations in the UK telecommunications industry, Ofcom and BT. The
EAB actively engages with all three on the activities covered by the
Undertakings. Its relationship with BT is the most complex in terms of its
responsibilities of monitoring, reporting and advising on the company’s
delivery of the Undertakings.
The EAB and EAO seek to engage with a wide range of industry
stakeholders. During 2009/10, Virgin Media, Cable & Wireless and Sky
attended EAB meetings. The EAO continued to hold meetings with CPs
and industry associations, as well as attending Consult21, Next
Generation Access, Systems and other product-related industry forum
sessions and working groups. It also attended the Telecom Stakeholder
Forum in Northern Ireland.
The EAB also continues to hold regular meetings with Ofcom. The Ofcom
CEO attended an EAB meeting in February 2010 and the EAO has regular
meetings with Ofcom policy directors regarding the Undertakings. The
EAO has regularly met the Office of the Telecommunications Adjudicator
(OTA2) to discuss progress.
The EAB met a range of BT stakeholders during the year. This included the
BT Group CEO and representatives from BT’s lines of business.
International interest in the UK functional separation model continued,
and the EAO worked with other countries implementing similar models. It
shared working practice with Telecom New Zealand’s Independent
Oversight Group, Telecom Italia’s Supervisory Board and TeliaSonera of
Sweden’s Equality of Access Board.
EAB Annual Report 2010
Our view on our governance and
resourcing
The EAB has considered its governance arrangements against the
criteria listed in the box below. It is satisfied that these are functioning
well and that it is effective in monitoring progress and advising BT on
future steps.
The EAB is also satisfied with the level of resourcing available to enable it
to fulfil its remit. It is engaging with a wide range of stakeholders as its
role evolves.
How we formed our opinion
The EAB is required by the Undertakings to give its opinion on its
governance arrangements and whether BT is providing it with
adequate resources to fulfil its role. In reaching our conclusion, we
looked at:
• The confidence of the EAB in the quality of information received
from BT and the EAB’s access to senior BT executives
• Development of the EAB’s monitoring process in response to
variations to the Undertakings
• The quality and timeliness of the reports submitted by the EAO to
the EAB
• The performance of the EAO’s breach and complaints processes
• The findings of the BT Internal Audit review of the EAO in Q4
2009/10
• The relevant skills and experience of the EAB members
• The EAO’s access to information held by BT
• The adequacy of the process for compiling annual reports and the
ability of the EAB to have unfettered influence on the detailed
content and conclusions of the report
• The views of the Director EAO on the level of resources at their
disposal.
7
8
How BT delivers the Undertakings continued
EAB Annual Report 2010
EAB Annual Report 2010
How BT delivers
the Undertakings
BT has a company-wide responsibility to deliver its Undertakings commitments.
The EAB works with each of BT’s lines of business to monitor compliance with the
Undertakings obligations specific to their area of work.
The role of each line of business and the EAB’s focus during 2009/10 is described in the table below:
Line of business
Description
Current generation products
Next Generation networks (21CN)
Next Generation access
Systems and processes
EAB focus during 2009/10
Openreach
Openreach was set up as part of the Undertakings to
offer access services to CP customers.
Supplies many of the products covered by the
Undertakings: WLR, LLU and Ethernet.
Launches and supplies Ethernet
products via BT’s 21CN.
Rolling out the NGA network and
developing NGA products.
Required to operate a separate
OSS. Runs product development
and SoR processes.
WLR3 milestones, launch of
equivalent NGA products and
associated product development
process, key measures of
employee behaviour, exchange
space monitoring.
BT Wholesale
BT Wholesale changed structure when the
Undertakings were agreed and offers network
products to CP customers. It underwent a further
reorganisation in 2007.
Supplies products in the IPstream portfolio.
Supplies the products which
underpin the 21CN programme
(MSIL, WBC); runs the Consult21
industry programme.
Planning to launch a call
conveyance product.
Required to operate a separate OSS, Functioning and governance
runs product development
of the 21CN programme,
and SoR processes.
information sharing within
BT Wholesale, key measures of
employee behaviour.
Does not own or supply any legacy products or services
but is involved in network and/or system design at
the request of Openreach and the other lines
of business.
Does not own or supply any 21CN
products or services but manages
BT’s 21CN programme.
Does not own or supply any
products or services but is
involved in network and/or
system design at Openreach’s
request.
Involved in the design and
development of systems, networks
and products specified by its client
divisions.
Information sharing within BTID,
monitoring progress towards
the delivery of systems
milestones, key measures of
employee behaviour.
Does not own or supply any
products or services but helps to
maintain and operate the
platforms upon which they run.
Maintains and operates the
systems specified by its client
divisions and has permitted access
to systems shared with Openreach.
Information sharing and key
measures of employee behaviour.
BT Innovate and Design (BTID) BTID was set up in 2007 as part of a BT Group
reorganisation and is responsible for the design and
development of the systems and networks to support
the products and services of its client divisions. It also
manages BT’s Undertakings and 21CN programmes.
BT Operate
Operate was set up in 2007 as part of a BT Group
reorganisation. It deploys and manages the services
on behalf of the lines of business.
Does not own or supply any products or services but
helps to maintain and operate the platforms upon
which they run.
Does not own or supply any
products or services but helps to
maintain and operate the
platforms upon which they run.
BT Retail
BT Retail offers telephony and broadband services
to residential customers and SMEs.
Consumes products including WLR3 from Openreach
and IPstream from BT Wholesale.
ConsumesWholesale BroadbandConnect Offers super-fast broadband
(WBC) from BT Wholesale to provide services to end customers.
higher speed Broadband services.
Required to migrate customers
to new EoI systems.
Information sharing and key
measures of employee behaviour.
BT Global Services
BT Global Services offers managed services to UK and
multi-national corporate customers.
Consumes WLR3 and Ethernet products.
No direct involvement with the
development of NGN but may
consume NGN products.
No direct involvement with the
development of NGA but may
consume NGA products.
Required to migrate customers
to new EoI systems.
Information sharing and key
measures of employee behaviour.
BT Ireland (North)
BT Ireland (North) has both access and retail arms.
Although it is not subject to the structural provisions in
the Undertakings, it must comply with some
obligations.
Offers products provided by both Openreach and
BT Retail.
Offers NGN products.
Offers NGA products provided
by Openreach and will offer
super-fast broadband services
to end customers.
No additional systems separation
requirements.
Attendance at Telecom
Stakeholder Forum and checking
that products are offered
compliantly in Northern Ireland
by Openreach.
9
10
How BT delivers the Undertakings continued
EAB Annual Report 2010
THE EAB’S ROLE WITHIN BT’S REPORTING STRUCTURE
OFCOM
EAB
BT GROUP PLC BOARD
PUBLIC REPORTING
BT CEO
OPERATING COMMITTEE
OPENREACH
BT WHOLESALE
Management reporting
BT RETAIL
BT GLOBAL
SERVICES
Compliance oversight
BT’s governance framework
The EAB is required to assess the effectiveness of BT’s governance
framework. It has oversight of BT’s operations as shown in the diagram
above.
The governance structure that was established by BT when the
Undertakings came into force has remained largely unaltered in function.
However, the form of some of the key bodies changed slightly during
2009/10 to continue to support the company’s delivery of the
Undertakings.
In September 2009, BT agreed to adapt its governance structure following a
consultation to reprioritise the remaining milestones (see p12). An Enterprise
Programme within BTID manages the implementation of products and
systems in compliance with the Undertakings across BT. It is also accountable
for the successful delivery of Undertakings milestones on behalf of the rest
of BT, collaborating with other parts of the business and reporting progress
to the EAB. The governance framework during 2009/10 consisted of:
• The Enterprise Programme Steering Board (PSB): this forum is the
most senior governance body within the programme and has a groupwide responsibility for setting policy and direction, managing
priorities, resolving risks and issues and ensuring consistency across
BT’s business units.
• BT Undertakings Customer Delivery Board (CDB): this forum provides
pan-BT monitoring and governance across workstreams. It ensures
effective risk and issue mitigation and reporting.
• Workstream Execution Boards: the programme is divided into three
key workstreams: UK Business Solutions, Migrations and Openreach
Industry Commitments, each of which has its own lead who is
responsible for the governance of a portfolio of projects via their own
Execution Boards.
• The Undertakings programme – which consists of an Undertakings
representative in each line of business – reports progress, plans and
issues into the leadership team within BTID on a monthly basis via its
own Customer Delivery Board/Execution Board to ensure that any
major delivery issues are resolved.
GROUP
FUNCTIONS
BT INNOVATE
AND DESIGN
BT OPERATE
Compliance reporting
The Undertakings programme reports into the BT Design Council – which
also oversees the effective development and delivery of the global 21CN
platform – on a monthly basis. It also reports to the BT Operating
Committee on a quarterly basis to ensure that the programme is costeffective and is consistent with BT’s strategic direction.
The EAB and BT’s governance framework
The EAB conducts reviews of different aspects of BT’s governance of the
Undertakings on a year-on-year basis. During 2009/10, it reviewed the
governance processes around NGA and NGN.
With regards to NGN, in 2007 BT established a 21CN governance
framework comprising leadership, delivery and external affairs teams to
liaise with key stakeholders. Together, these bodies oversee the compliant
launch of new 21CN products, services, processes and platforms.
In October 2009, the EAB reviewed this governance framework. It found
that BT had put measures in place to improve its consultation process with
industry and that this was functioning well. However, there was still scope
for key groups within the 21CN programme to meet on a more regular
basis and also to ensure that the Undertakings were embedded
throughout the programme through proactive activities such as
‘Undertakings health checks’. For more information, see p24.
The EAB also reviewed the governance processes around BT’s NGA
programme. It found that improvements were required to ensure the full
involvement of business-focused CPs rather than just those serving
consumers. It also proposed that BT should manage risks such as the
potential for non-compliant information sharing within the programme.
For more information, see p21.
BT is also required to report to the EAB on exceptional incidents relating
to the Undertakings as part of its governance process. In 2009/10,
Ofcom published letters between BT and itself regarding the declaration
of an ‘exceptional’ incident arising from the emergency work BT carried
out following the floods in Cumbria. On this occasion, BT said that it may
be necessary to share both Customer Confidential and Commercial
Information, to access computer systems and to work on physical layer
How BT delivers the Undertakings continued
EAB Annual Report 2010
11
and transmission equipment in a way that would normally result in a
breach of the Undertakings.
The EAB also checked that Openreach products were offered compliantly
in Northern Ireland and identified no areas of concern.
Ofcom responded by asking that BT continue to keep it informed until the
incident was resolved. Following the closure of the exceptional incident,
BT produced a written report which Ofcom published. This report stated
that the only possible departure from the Undertakings was the release of
Customer Confidential information relating to circuits which had to be
re-routed following possible infrastructure failure. This was the first time
that the exceptional incidents section of the Undertakings had been used,
and the EAB is satisfied that BT complied with its obligations during this
incident.
Our view on BT’s governance of the
Undertakings
Openreach’s governance
Openreach is the BT line of business with responsibility for the delivery of
the majority of the current generation EoI products and the roll out of NGA.
The EAB has a duty to monitor Openreach’s operations and governance
processes to ensure that equivalence is embedded in its operating model.
This includes oversight of its annual operating plan, executive scorecard and
operating model. The EAB performs compliance spot checks in different
areas each year to ensure that Openreach remains compliant.
During 2009/10, the EAB carried out a series of checks to look at the
activities of Openreach senior executives. It performed a compliance spot
check to confirm that the Openreach CEO is not a member of the BT
Group Operating Committee – although he may attend when business
relevant to Openreach is discussed – as required by the Undertakings. The
check found that Openreach has a governance process in place to review
whether his attendance is appropriate for each agenda item; and it will
also inform the EAO if the Openreach CEO attends.
The Undertakings require that the Openreach CEO has delegated
authority from the BT Group plc Board to authorise capital expenditure of
up to £75m within Openreach’s annual operating plan, although this may
be varied at the discretion of the BT Group plc Board. If it is varied, the
EAB must be notified within five days. During 2009/10, BT and
Openreach confirmed to the EAB that it continued to comply with the
Undertakings on this requirement.
The EAB is also required to monitor executive remuneration in Openreach
to ensure that it reflects the Openreach scorecard. The Undertakings
stipulate that:
• All incentive remuneration of Openreach employees shall reflect solely
the objectives of Openreach.
• Openreach will operate to a scorecard which reflects its responsibilities
to deliver EoI and fair access to its products.
• The principles of that scorecard will be cascaded to all employees
working for Openreach who have currently, or may have in the future,
bonus payments.
• Bonus payments based on scorecard performance shall relate solely to
the performance of Openreach and to any other relevant obligations
under these Undertakings.
• Such bonus payments shall not be denominated in BT Group plc
(“BT Group”) shares, but Openreach people remain eligible to
participate in BT’s ongoing and future general all employee share
plans and benefits arrangements.
The EAB found that these remuneration arrangements were continuing
to work in compliance with the Undertakings.
The EAB has considered BT’s governance framework against the
criteria listed in the box below and is satisfied that it has a compliant
governance structure and process in place. The EAB also found that the
particular aspects of governance which it analysed as part of its reviews
and compliance spot checks during 2009/10 were functioning
effectively.
The EAB will perform follow up reviews on the governance processes
around the delivery of NGN and NGA to ensure that EoI principles remain
fully embedded.
How we formed our opinion
The Undertakings require that the EAB forms an opinion on BT’s
governance arrangements associated with the Undertakings. In reaching
our conclusion we looked at:
•
•
•
•
The measures in place to detect and address potential breaches.
BT’s processes to handle complaints relating to the Undertakings.
BT’s governance processes for 21CN and NGA.
The reviews conducted on specific aspects of BT’s governance
framework.
The EAB also took account of the following information resulting from
the implementation of these processes and the EAO’s own in-depth
reviews and audits of BT’s ongoing delivery of the Undertakings:
• BT’s programme of reporting to the BT Group plc Board and the
relevant committees.
• The findings of the EAO’s monthly monitoring reports on BT’s
compliance with the Undertakings, including steps being taken to
deliver future commitments.
• Half yearly reports from BT to the EAB of its progress in implementing
and measuring behavioural change.
• The EAO Director’s quarterly report to the EAB which, inter alia, tracks
and comments on governance developments.
• Quarterly operational reports from the Openreach CEO, on the
measures being taken to ensure and maintain a compliant
organisation.
• The views expressed by individual CPs in presentations to the EAB.
• The EAO’s quarterly reports on complaints relating to the
Undertakings which include an assessment of BT’s complaints
handling arrangements.
• Experience of reporting to the EAB on breach investigations and
follow-up by BT and the EAO.
• The results of the EAO’s issues management (Quick Checks) process
where all the issues raised by CPs, BT or the EAO itself are assessed to
determine if they require further investigation.
• The findings of the EAO’s ongoing compliance audits as detailed in the
EAO’s Audit and Validation Plan which includes exemptions and
variations to the Undertakings that BT has agreed with Ofcom.
12
EAB Annual Report 2010
Current generation products
and systems
In September 2009, Ofcom published a summary of the achievements of four years
of the Undertakings. It said that the Undertakings had had a major impact on
telephony and broadband services in the UK and that they were one of the reasons
why consumers were now paying 40% less for broadband than in 2005.
Ofcom recognised the impact of the delivery of many of the current
generation EoI products on the UK market and consequently rolled back
regulation in some areas during 2009/10. In particular, the regulator
removed the remaining Significant Market Power (SMP) controls for retail
voice services provided by BT during 2009/10. This enhanced the
company’s ability to offer bespoke consumer pricing and special prices for
bundles of products. There were also consultations on the charge controls
for WLR, Partial Private Circuits and Ethernet.
As well as these broader regulatory actions – which in part occurred as a
result of the successful delivery of EoI products and their impact on the
UK telecoms market – there were also specific variations to the
Undertakings during 2009/10. These led to changes in the approach and
timescales for the delivery of current generation products and the
systems that underpin them.
This section of the report looks at BT’s delivery of the remaining
Undertakings milestones and ongoing compliance with regards to some
products. Reviews of non-compliance with the Undertakings are covered
in more detail later in the report.
Eol product milestones due in previous years were:
2005/06
2006/07
IPstream
EoI RFS
Local Loop
Wholesale Line WLR3 Analogue
Unbundling EoI Rental Analogue IBMC 30%
RFS including
EoI RFS
target
IPstream using
LLU
2008/09
EoI RFS for
Ethernet
products (such
as Wholesale
Extension
Services)
WLR3 ISDN2
EoI RFS
WLR3 ISDN2
IBMC
EoI IBMC for
relevant
Ethernet
products
WLR3 ISDN30
EoI RFS
IPstream
Connect
available for
order
IPstream using
LLU IBMC
Changes to the Undertakings for current
generation products and systems
Whilst many of the delivery milestones for current generation products
had been delivered in previous years, there were some milestone
obligations still outstanding for EoI products and the associated
operational support systems.
2007/08
BT’s relevant
broadband
service IBMC
WLR3 Analogue
EoI ‘good faith’
date
IPstream
Connect IBMC
and migration
of CP end-user
base
Current generation products and systems continued
EAB Annual Report 2010
The following systems milestones were also due in previous years:
The following systems separation milestones were also due:
2006/07
2007/08
2008/09
Undertaking
Date due
Management
Information Systems
logical separation
Operational systems
separation – user
access controls
(phase 1)
OSS separation – user
access controls
(phase 2)
50% of non-WLR supply side records migrated to
physically separate OSS
31 May 2009
Implement physically separate OSS for WLR
manual exception tasks
31 May 2009
MIS roadmap
50% of customer-side
records migrated to
physically separate OSS
90% of relevant customer side records migrated to
physically separate OSS
30 Sept 2009
90% of non-WLR supply side records migrated to
physically separate OSS
31 Jan 2010
90% of users migrated to physically separate
OSS for WLR manual exception tasks
31 Mar 2010
Completion of additional independent, external
audit of user access controls for OSS separation
30 June 2010
MIS Level 2 separation
30 June 2010
OSS physical separation
30 June 2010
OSS – user access
controls
The table below shows the EoI product commitments that were due to be
delivered in 2009/10 and beyond:
Undertaking
Date due
WLR Analogue IBMC 70% target
30 June 2009
Ready to mass migrate customer side records
relating to Featureline
30 June 2009
WLR ISDN30 IBMC
31 Dec 2009
WLR Analogue IBMC 100%
30 June 2010
Wavestream Connect and Regional IBMC
30 Sept 2010
13
In May 2009, Ofcom published a consultation on re-prioritising the
remaining Undertakings commitments shown in the tables. BT made the
initial request because its systems’ resources were coming under pressure
such that it was concerned it would not be able to meet the forthcoming
systems separation deadlines and at the same time meet industry
demand for new products and services.
There were also challenges with the implementation of BT’s downstream
business systems separation programme. Consequently, many of the
Undertakings milestones that were not achieved largely related to
business customers and products. The EAB had flagged its concerns
around BT’s ability to meet these commitments in 2008/09.
The consultation proposed three major changes:
• The potential rescheduling of BT’s remaining Undertakings
commitments relating to operational systems separation, which would
involve:
– Full physical separation taking place over a longer period of time
– Longer timescales for the migration of BT’s end user customer
records onto systems that are separate from those belonging to
Openreach
– A new target for migration of BT’s installed base
• A changed approach and longer timescales for the other remaining
EoI obligations.
• A new set of commitments to cover the delivery of service
developments as requested by Openreach’s customers.
14
Current generation products and systems continued
EAB Annual Report 2010
In September 2009, Ofcom published the conclusion to its consultation,
which upheld the proposed changes. The variation resulted in changes to
specific milestones as shown in the table:
Original obligation
New commitment
Full physical separation by
30 Jun 2010 of OSS except
for exempted systems
OSS for Openreach to be run
physically separate from those of
the rest of BT when reasonably
practicable and proportionate.
80% of customer-side service
records to be separated by 30 June
2010 and 90% to be separated by
31 December 2012.
BT to advise Ofcom by 31 December
2011 of the further percentage of
customer records to be separated by
30 June 2014.
Removal of obligations relating to
supply side records.
IBMC dates for WLR3 Analogue,
ISDN2 and ISDN30
All IBMC dates to be removed
(except 70% interim target for
WLR3 Analogue).
IBMC dates for Featureline,
Featurenet, MegaStream
Ethernet, Redcare CCTV, Media
& Broadcast, Wavestream
Connect and Regional
90% of BT’s relevant installed based
to be migrated by 30 June 2010
and 95% by 31 December 2012.
None
In association with these changes – and in light of the issues raised in the
consultation process – BT wrote to Ofcom clarifying the informal
safeguards and reporting it would put in place with respect to systems
separation and EoI delivery. The aim of these informal safeguards and
reporting was to complement the revised formal obligations. They
included:
• Openreach’s providing the EAO, at least quarterly, with Comparative
Performance Charts (CPCs) of the EoI and non-EoI variants of the high
volume products (namely, the WLR3 products). With the removal of
the IBMC dates, Ofcom believed that this voluntary commitment
would highlight any potential incentive for downstream BT to delay
migrating its installed base onto the EoI service. Analysis of the CPCs is
included in the ‘Indicators’ section on p41.
• BT’s reporting to Ofcom on its progress in building the systems ‘stack’
– a collection of inter-related systems – for business customers. It
would also give an update on the implications for the expected
migration of specific product groups. This expanded BT’s existing
obligation to produce systems roadmaps for review with Ofcom.
During 2009/10, the EAO attended roadmap review sessions with BT
and Ofcom to monitor progress in building the systems stack.
BT also said it would deliver four non-binding systems stack milestones to
be monitored by the EAB:
•
•
•
•
Operational trial to have started by 30 April 2010
Initial live deployment to have begun by 31 December 2010
Trial migration to have begun by 31 March 2011
Volume migration to have begun by 30 December 2011.
BT to advise Ofcom by 31 December
2011 of the further percentage of
installed base to be migrated by
30 June 2014.
In its statement, Ofcom stated that Openreach will consult its customers
about easing the migration to the EoI product variants for those
customers still on non-EoI versions.
Openreach’s delivery of specific
service developments and
functionality to industry to be
published in a roadmap by
30 September 2009 alongside the
associated change control process,
with subsequent publication of each
on an at least six monthly basis.
Ofcom concluded that the impact of the changes to the original
milestones was limited as BT had agreed to these further milestones. The
EAB will continue to monitor BT’s progress in these areas in the coming
year.
The variation to the Undertakings impacted the delivery of the current
generation EoI version of WLR3, and also led to changes in the way that
systems separation was delivered. These are described in more detail
opposite.
Current generation products and systems continued
Products
The delivery of EoI products requires Openreach and BT Wholesale to
offer products on the same timescales, terms and conditions and using
the same systems and processes for both BT CPs and non-BT CPs. This
enables both sets of CPs to use the same network ‘building blocks’ to
offer services to their own end customers.
EAB Annual Report 2010
15
Apparent differences in performance levels shown by the product KPIs for
WLR3 can be explained and there was no evidence that non-BT CPs were
receiving an intentionally poorer performance (see p39 for more
information).
The variation to the Undertakings had a significant impact on the delivery
requirements for WLR3 during the year, and the EAB also continued to
monitor ongoing compliance with EoI obligations for the other current
generation products.
The EAB will continue to monitor BT’s delivery of WLR3 as part of its
oversight of BT’s delivery of a business plan for the remaining EoI
products. BT has said that migration to the new systems will take place on
a customer-by-customer basis rather than by product. It has committed
to informing Ofcom and the EAB when the systems capability has been
built and when high-volume live migrations of customers using major
products such as WLR3 has commenced.
Wholesale Line Rental
LLU and IPstream Connect
Wholesale Line Rental (WLR) supplied by Openreach is used by CPs to
offer their own branded telephony and narrowband data services to
customers. Over the past few years, Openreach has aimed to move
customers away from using the previous version of WLR (known as
WLR2) supplied via older ‘tactical’ operational support systems to a
newer version – known as WLR3 – supplied via the Equivalence
Management Platform. This shift continued throughout 2009/10, with
some CPs still expressing concern about moving over to WLR3 because
of the cost of configuring their own systems and interfaces to support
the new product. Openreach plans to move all customers to WLR3 by
30 June 2011.
The LLU portfolio enables non-BT CPs to lease the local loop
infrastructure from Openreach to offer telephony and broadband services
to end users (in contrast, BT CPs use WLR3 and IPstream Connect rather
than LLU to offer telephony and broadband services to their customers).
Some of the WLR3 milestones due in 2009/10 were delayed as a result of
the reasons set out in Ofcom’s statement on reprioritising the remaining
Undertakings commitments (see the previous page). In the run up to the
variation, BT did not achieve the migration of 50% of non-WLR supply
side records to a physically separate OSS and the implementation of
physically separate OSS for WLR manual exception tasks (both due on
31 May 2009). The EAB found these to be non-trivial breaches of the
Undertakings.
In September 2009, BT said that it had migrated 70% of its WLR
Analogue installed base to a physically separate OSS although this was
three months after its due date. A subsequent review by the EAB
confirmed that this obligation had been delivered.
Two further non-trivial breaches were reported regarding the processes
supporting WLR3. In one case, a BT CP was provided with a dedicated
e-mail account to escalate faults relating to WLR3 when the standard
escalation process failed for a short period in 2008. This e-mail account
was later withdrawn. In the other case, a BT CP received an additional
report regarding the status of WLR3 orders and faults. This breach was
remedied when the report was withdrawn and the information was made
available to all CPs on an EoI basis.
The EAB is satisfied that BT remains committed to the delivery of WLR3. It
will continue to monitor that the processes supporting WLR3 function in
an equivalent way following the breaches identified during 2009/10.
The IPstream Connect portfolio is supplied by BT Wholesale and the
products enable BT CPs and non-BT CPs to offer broadband services to
end users. All of the delivery milestones for LLU and IPstream were due in
previous years, and the product KPIs show that the products appear to be
performing equivalently (see p40).
Deregulation on price has been applied to IPstream Connect products in
recent years. The Wholesale Broadband Access Market Review of 2008
defined new geographic markets for network services. In ‘Market Three’ –
areas covered by exchanges where there are four or more operators –
Ofcom agreed that BT did not have SMP and removed all SMP obligations
and the related EoI requirements in relation to IPstream Connect.
Requirements were also removed for the NGN successor product to
IPstream, known as Wholesale Broadband Connect (WBC). This gave BT
pricing flexibility in Market Three, allowing it to provide differentiated
products and prices to customers.
In October 2009, the EAB reviewed broadband Market One, in which BT
is the only operator; Market Two, where there are two or three operators
(including BT) and Market Three. The purpose of the review was to
determine whether any changes made in Market Three by BT as a result of
the deregulatory steps taken by Ofcom would result in BT not complying
with its regulatory obligations in Markets One and Two.
The review looked at changes affecting the SoR process, changes to
service level agreements, the potential impact on IPstream Connect and
WBC and pricing. It found that even though IPstream Connect and WBC
are deregulated in Market Three, BT continues to use the same product
management processes and SoRs as it does in Markets One and Two, even
though it is not required to do so.
The review also found that BT had added one exchange to the list
published on Ofcom’s website in relation to Market Three as a result of
16
Current generation products and systems continued
EAB Annual Report 2010
the creation of a new exchange within an existing Market Three area. The
review looked at the process by which Market Three customers are
identified and noted that the accuracy of the exchange list is important as
it reflects the areas where deregulation is in force. The EAB recommended
to BT that it should tighten the controls around the database which
contains the list of Market Three exchanges. This was to ensure that BT
could not end up offering reduced pricing in exchange areas where it was
not entitled to do so. BT has since put these controls in place.
Systems
In conclusion, the EAB is satisfied that BT is complying with its ongoing
EoI obligations with regards to IPstream Connect and LLU. The product
KPIs also show that BT appears to be offering IPstream Connect and LLU
on an equivalent basis.
The EAB oversees that Openreach and the other lines of business are
compliantly accessing Operational Support Systems (OSS) and
Management Information Systems (MIS). OSS are large and complex
systems containing tens of millions of customer records. The
Undertakings require that OSS are physically separated. This involves BT
separating a large number of the systems used by Openreach from those
used by the rest of BT so that confidential information cannot be shared
inappropriately across organisational boundaries. Physical separation is to
be preceded by the ‘logical’ separation of systems, which involves the
creation of user access controls to prohibit users from gaining access to
parts of the system containing restricted data.
Ethernet
There were no specific Undertakings milestones for Ethernet products
during 2009/10 as BT met the EoI obligations in previous years. However,
all future Ethernet products to be launched by Openreach must be
delivered on an EoI basis. The EAB monitors that this is the case. The EAB
has also agreed with BT that it will assess factors such as the effectiveness
of industry consultation when validating future Ethernet products not
included originally in the Undertakings.
The development and delivery of Ethernet products remains crucial to
many CPs – particularly those serving business customers – as they form a
high bandwidth link between CPs’ and BT’s networks. During 2009/10,
Openreach continued to develop its Ethernet product portfolio. It has said
that it will gradually phase out traditional products such as Wholesale
Ethernet Services (WES) and Backhaul Extension Services (BES). These
will be replaced by new services such as Ethernet Backhaul Direct (EBD)
and Ethernet Access Direct (EAD), which is a point-to-point access
product offering high bandwidth connectivity linking end user sites, CP
networks and BT exchanges.
Openreach launched a range of EAD products in 2009 and the EAB found
that they had been launched equivalently. Following the review,
Openreach updated the product customer service plan to provide greater
clarity on the escalation process by which customers can raise faults. The
EAB is also aware that several CPs have been unhappy with the
transparency of the SoR process for Ethernet products, although no
associated breaches of the Undertakings were identified.
The EAB will continue to monitor the delivery of Ethernet products, even
though the key Ethernet delivery milestones in the Undertakings were
due in previous years. In the absence of milestones, the EAB is satisfied
that BT met the ongoing compliance monitoring obligations for Ethernet.
The product KPIs also show no material evidence of any EoI issues in the
Ethernet portfolio.
The EAB expects to see further debate around Ethernet products as part
of the development of NGA.
Systems play an important role in BT’s delivery of the Undertakings. The
EAB needs to be sure that access to certain systems is appropriately
controlled to ensure that BT does not gain an advantage from information
that would not be available to other CPs. It also observes the impact of
the Equivalence Management Platform (EMP) on the delivery of EoI
products.
MIS are large systems which hold commercial and customer confidential
information and which BT uses to plan and direct its business and
organisational operations. The Undertakings require BT to ‘logically’
separate its MIS at two levels:
• Level one: the application of access rights and controls to ensure that
users have access only to the data to which they are entitled
• Level two: separation of systems data and separate versions of the
application software to ensure that users are confined by their access
rights.
Ofcom’s reprioritisation of the Undertakings led to changes in the delivery
deadlines for OSS separation (see p14), placing them beyond this
reporting year. MIS delivery deadlines remain unaltered. The EAB will
cover progress towards these due dates in its regular bulletins.
BT’s obligations to provide Ofcom with a roadmap showing progress
towards systems separation were unaltered as a result of the variation,
although the roadmap has been updated to reflect the revised
milestones. BT will continue to report progress to both Ofcom and the
EAB. As part of this roadmap reporting, BT had told the EAB that the
delivery of MIS Level 2 separation – due 30 June 2010 – was at risk
because there was not an agreed solution for one of the key systems
involved – ‘ASPIRE’, which is a system for regulatory reporting. Ofcom
agreed subsequently with BT on 4 March 2010 that ASPIRE did not need
to be separated.
At the time this report was published, BT reported that it had reached its
80% target (30 June 2010) in relation to moving customer records to
separate systems, although this is subject to EAB validation.
The systems variation also required the EAB to commission an external
audit every 24 months of the ongoing effectiveness of user access
Current generation products and systems continued
controls to 28 OSS until full separation is in place. The EAB expects that
this will be similar to the scope of audits of user access controls that the
EAB has commissioned in previous years. The EAB will commission an
external audit of the application of user access controls for 11 systems in
2010, with the first full audit of all systems due to take place in 2011.
Equivalence Management Platform
The effective functioning of systems underpinning the products and
services covered by the Undertakings remains an area of ongoing focus
for the EAB. Openreach reports regularly to the EAB on progress with the
EMP – the strategic system underpinning the delivery of EoI products. It
has reported that the average performance for the EMP throughout
2009/10 was above 99% service availability. It has also continued to
upgrade the functionality on the EMP, including building in NGA
functionality ahead of the trials of FTTC and FTTP. The EAB regularly
consults OTA2’s bulletins on the status of the EMP.
EAB Annual Report 2010
17
Our view on current generation products
and systems
The EAB is satisfied that – once the systems variation and some issues
relating to processes for WLR and LLU exchange lists are taken into
account – BT continues to deliver current generation products
equivalently when assessed against the monitoring criteria shown in the
section entitled ‘Monitoring, Reporting and Advising’ on p5. The product
KPIs also show that BT appears to be offering current generation products
on an EoI basis.
The EAB is also satisfied that BT has plans in place to deliver the
systems underpinning equivalence within the framework of the revised
systems obligations. It will monitor the forthcoming revised milestones
for OSS in the same way as it would those originally included in the
Undertakings.
18
EAB Annual Report 2010
Next Generation Access
BT’s upgrade of the network connecting homes and businesses to local exchanges
continued to hit the headlines during 2009/10. Commercial and regulatory
developments pushed the roll out of NGA forward rapidly and many in industry
shifted their attention to which NGA products and services will be offered and what
this means for the services they can offer to their own customers.
The ‘Digital Britain’ report published on 16 June 2009 was welcomed by
many as a pivotal moment in the future of broadband and next
generation access in the UK. The report contained 78 recommendations,
including the UK Government’s intention to deliver broadband with
speeds of 2Mbps on a universal service basis by 2012 to nearly all people
in the UK. The government, Ofcom and industry considered how to build
on these proposals during 2009/10.
The European Commission also made recommendations on NGA
including how to balance investment and risk between those rolling out
infrastructure and those leasing it and also urges the adoption of a
Europe-wide approach. A wider package of telecoms reforms which had
been proposed by the Commission was also accepted at the end of 2009,
with NGA high on the agenda of the new Europe-wide regulator, the
Body of European Regulators for Electronic Communications (BEREC).
Development of NGA during 2009/10
BT announced in July 2008 that it would spend £1.5bn rolling out fibrebased, ‘super-fast’ broadband to approximately 10m homes in the UK by
December 2012 subject to a supportive regulatory environment. These
plans continued to progress during 2009/10 as BT launched trials of both
Fibre-to-the-Cabinet (FTTC) and Fibre-to-the-Premises (FTTP). FTTC
involves installing fibre to street cabinets and using the existing copper
infrastructure into the premises. It is most likely to be deployed on
existing or ‘brownfield’ sites. FTTP involves installing fibre into homes or
premises, superseding the copper local loop. It is used typically in new
premises or ‘greenfield’ sites but recent trials have suggested it could be
used for some existing sites too. Openreach is responsible for rolling out
both FTTC and FTTP. BT’s FTTP deployment is based on Gigabit Passive
Optical Network (GPON) which means that the access network is shared
between a number of end users.
NGA: FIBRE TO THE PREMISES
LOCAL
EXCHANGE
SPLITTER
FTTP GIGABIT PASSIVE OPTICAL NETWORK (SHARED)
Next Generation Access continued
EAB Annual Report 2010
19
NGA: FIBRE TO THE CABINET
EXIST
ING C
OPPE
R
EXISTING COPPER
EXISTING
CABINET
LOCAL
EXCHANGE
LINKING
COPPER
NEW
CABINET
FTTC
POWER
Copper
Fibre
Fibre-to-the-Cabinet
During 2009, BT launched a commercial pilot of FTTC in Muswell Hill,
London and Whitchurch, South Glamorgan. By February 2010, two
thousand end user installations had been completed and there were three
CPs active at the sites. Openreach planned to have 500,000 homes across
26 exchanges enabled for FTTC by March 2010.
In June 2009, Ofcom published a variation to the Undertakings relating
to FTTC. This included the following stipulations:
• Openreach may control and operate the electronics contained within
the transmission layer of BT’s access and backhaul networks. This
permits Openreach to work on the FTTC electronics in the backhaul
network to which it would not normally have access.
• The FTTC product must be robust and have scalable processes and
systems supporting provision, migration, monitoring and fault repair
such that CPs using the product are able to provide their end-users
with a reasonable experience.
• The products must meet industry standards, have SLAs, meet
reasonable CP demand in terms of locations, and be delivered in
accordance with the Openreach product roadmap.
• Openreach will set out in published guidelines the principles it will
follow for consultations relating to FTTC.
• Openreach will conduct a consultation (in 2011) to assess the demand
for, and CPs’ views of the design of FTTC ‘passive’ inputs. Openreach
will ensure that it meets reasonable demand from CPs wishing to
locate their equipment attached to or in the vicinity of BT’s cabinets
and will adopt design principles to enable this in the most costefficient manner, where practicable.
• Openreach will, where practicable, adopt design principles in its
systems for a BT active FTTC product that makes it possible in future to
enable the delivery of FTTC ‘passive’ inputs, and the EAB shall monitor
the provision of these inputs in accordance with appropriate metrics to
be agreed by BT and Ofcom.
• BT will by 31 December 2011 review with Ofcom whether aspects of
the FTTC variation need to be varied, superseded or released in light of
the FTTC deployment and relevant FTTC market and technological
developments.
The variation gave the EAB new responsibilities for monitoring
equality of any passive inputs to FTTC provided by Openreach. Passive
remedies enable greater levels of access to the underlying fibre
infrastructure. They provide greater flexibility for CPs wishing to develop
and offer their own services, but they can be more complex to make
available and the economics are more challenging.
Openreach’s wholesale NGA product – known as Generic Ethernet Access
(GEA) – is referred to as ‘active’ as it includes the operation of electronics
by Openreach. However, unlike the current generation IPstream product
– which is also an active product – GEA is Ethernet-based and may
therefore allow some additional scope for CP innovation and
differentiation.
20
Next Generation Access continued
EAB Annual Report 2010
Fibre-to-the-Premises
BT’s FTTP programme also developed quickly during the year. Openreach
announced plans to deliver speeds of up to 100Mbps to approximately
2.5m UK homes and businesses using FTTP, more than doubling its
original roll out plans. Work on the original FTTP pilot at the ‘greenfield’
housing site in Ebbsfleet, Kent had 120 homes occupied by February
2010. Openreach is also planning to conduct an FTTP ‘brownfield’ trial at
Highams Park, London and Bradwell Abbey, near Milton Keynes. The
company intends to review the access technology options in both areas
and to maintain a ‘mixed economy’ approach incorporating both FTTC
and FTTP.
In October 2009, Ofcom issued a consultation on a variation to allow
Openreach to control and operate the electronics in BT’s access network
required for FTTP. The consultation did not look at passive elements, such
as duct sharing, as it considered FTTP to be at an earlier stage of
development.
Due to concerns raised by CPs in the consultation responses, Ofcom
delayed its decision on the variation until it was in a position to clarify how
these issues would be considered as part of the Wholesale Local Access
and Wholesale Broadband Access market reviews.
The EAB monitors six areas of compliance for NGA as displayed in the
table below:
NGA theme
Consultation and Openreach’s consultation with industry on key
engagement
changes and product developments.
Product and
systems
Products are designed, launched and CPs’ users
migrated to the new product on an EoI basis.
Equipment and
locations
NGA solutions are not made unattractive to CPs,
either because of cost or availability of equipment,
space or power.
Backhaul
The NGA product does not preclude or dictate the
choice of backhaul for CPs or make the product
commercially unattractive because of the cost or
limitations of the backhaul solution.
Passive
components
New theme as a result of the FTTC variation, which
includes:
• A requirement to consult with industry on any
changes to passive components.
• Design principles to enable CPs to locate their
equipment at or close to BT’s street cabinets
• Openreach to adopt design principles that make it
possible to provide FTTC passive inputs.
• Openreach should use the same components,
processes and systems it uses itself for the purposes
of its active product where reasonable and on the
most cost-efficient basis.
• The provision of the FTTC passive inputs to be
monitored by the EAO in accordance with metrics to
be agreed by BT and Ofcom.
Governance
A range of obligations including the use of statement
of requirements processes on the same basis for all
CPs, appropriate sharing of customer confidential and
commercial information and all transactions to be
carried out on an EoI basis.
In March 2010, Ofcom published the FTTP variation as agreed in the
consultation document, enabling Openreach to work on the electronics in
BT’s access network. It also granted an exemption regarding BT’s Fibre
Integrated Reception System (FIRS) at Ebbsfleet allowing Openreach to
work on the TV broadcast-related electronics. The variation and
exemption did not impose any additional monitoring responsibilities on
the EAB, although the scope of the EAB’s monitoring activities has
expanded to cover BT’s compliance with the terms of the FTTP variation.
The EAB’s approach to monitoring NGA
In the previous reporting year, the EAB developed an initial approach to
monitoring BT’s delivery of NGA. At this time there were no specific NGA
obligations in the Undertakings, but the generic obligations upon
Openreach – including product equivalence and information sharing
restrictions – still applied. In 2009/10, the variation to the Undertakings
on FTTC added a new obligation with regards to passive components,
which the EAB incorporated into its overall monitoring programme
for NGA.
BT activity
The EAB applies the same monitoring criteria for NGA as it does for
current generation products, using colour-coded indicators to measure
performance (see p5 for more information). BT’s performance against
each theme during 2009/10 is described below.
Consultation and engagement
The EAB is satisfied that Openreach engages effectively with industry. The
Openreach NGA Forum meets every quarter and a collaborative approach
is taken at working group level.
Products and systems
The EAB assessed whether Openreach’s GEA product over FTTC had
been launched on an equivalent basis. GEA enables broadband
connections and was launched over FTTP in the previous reporting year.
At the time of the validation, GEA was available on a trial basis and had
not yet been offered commercially. The EAB was satisfied that the trial
product was on offer on an EoI basis but it identified some issues with the
supporting systems that Openreach said would be resolved with the full
commercial launch.
Next Generation Access continued
During 2009/10, most NGA products were still in trial stage and were
undergoing testing for technical functionality rather than being tailored
to meet customer requirements. As a result, much attention has been
focused on product development and the functioning of the SoR process
in determining the type of products that will be part of the full
commercial launch.
Concerns have been expressed over the development of a voice access
product by Openreach – known as Voice over Next Generation Access
(VoNGA) – which will require CPs to use an Openreach call server to offer
voice services to their own users. Some CPs have suggested that VoNGA
recreates the situation where Openreach provides a managed WLR3
product over copper in the fibre market, and offers little opportunity for
innovation – although there is no evidence to show that its development
would breach the Undertakings.
CPs which did not wish to purchase VoNGA were hoping that an ‘Open
Analogue Telephone Adapter (ATA)’ product would be developed, which
would allow them to install their own call server equipment. Some CPs
have also asked for a ‘wires-only’ product which would allow them to
terminate fibre networks themselves in customers’ homes.
At the time this report was published, Openreach had just concluded
consulting with industry on an Open ATA product (also known as a Direct
Controlled ATA product) with a view to deploying such a service. However,
it decided not to commit to a ‘wires-only’ option although it said it would
review the approach in three years’ time. VoNGA would still be available,
and some CPs (those who currently purchase WLR) have indicated that
this is an attractive option for them as they do not have their own call
servers. Once the products are defined and launched, the EAB will assess
whether they are available on an EoI basis.
Equipment and locations
The EAB monitors that exchange space and power are allocated on an EoI
basis. It is satisfied that the NGA access products for FTTP and FTTC use
existing exchange space and power.
Backhaul
The FTTC and FTTP products use existing Openreach backhaul products or
a CP’s own infrastructure. The EAB is satisfied that the backhaul inputs to
FTTP and FTTC do not undermine the commercial viability of these
products.
Passive components
At the time this report was published, passive components had not been
launched and therefore the EAB’s Undertakings obligations with regards
to this product had not commenced. The EAB will continue to monitor
product development for FTTC and FTTP. However, the EAB asked BT to
consider how to provide clear evidence that it is adopting design
principles to make it possible to provide passive NGA products in the
future.
EAB Annual Report 2010
21
also recommended that the programme develop a clearer approach to
managing risks around information sharing. In addition, it expressed a
concern that Openreach could not demonstrate that it was factoring in
the design principles to make it possible to offer FTTC passive inputs to
meet future demand from CPs.
The EAB is satisfied that Openreach is running a compliant SoR process,
despite concerns from some CPs about its operation. Whilst some SoRs for
NGA products have been rejected by Openreach, the EAB is satisfied that
Openreach assessed each one fully on an EoI basis. It hopes that the
situation has become more transparent since Openreach made further
improvements to its new SoR process (see page 32 for more information
on SoRs).
Future monitoring factors
At the time this report was published, Ofcom was consulting on reviews
of the Wholesale Local Access and Wholesale Broadband Access markets.
The reviews set out Ofcom’s proposals for a Virtual Unbundled Local
Access (VULA) product, which – whilst being an active remedy – would
emulate many of the characteristics of LLU. In Ofcom’s view, Openreach’s
GEA product in the form it had taken at the time this report was published
fulfils most, but not all, of the characteristics of VULA.
Other proposals made by Ofcom in the Wholesale Local Access review
included the potential for CPs to use duct and pole access for delivering
FTTP. Ofcom also proposed that CPs use duct access and Sub-loop
Unbundling (SLU) – which involves unbundling the copper from the
end-users’ premises to the street cabinet – to deliver FTTC.
In its Wholesale Local Access review, Ofcom also sets out its provisional
view that if an ATA is to be embedded in the GEA/VULA product it must
be an ‘open architecture’ ATA, which would enable different CPs to use it
to communicate with their own networks. The EAB will await the
outcome of the reviews and will include any relevant factors in its
monitoring programme.
Our opinion on NGA
When assessed against the monitoring criteria shown in the section
entitled ‘Monitoring, Reporting and Advising’ on p5 and the monitoring
themes on the previous page, the EAB is satisfied that BT is factoring EoI
into its development of NGA products and services. Its assessments of the
FTTC and FTTP trials found that BT is working where possible to develop
services that will meet CP requirements – although it could do more to
address the needs of business customers.
The real test will be the full commercial launch of products over FTTC and
FTTP. The effective functioning of the SoR and industry consultation
process will play a crucial role in ensuring that CPs are given an
opportunity to assist in shaping future NGA products. The EAB also
recommends that BT makes improvements to some of the governance
processes around its NGA programme.
Governance
The EAB reviewed NGA governance during 2009/10. It found that there
was no formal governance process in place to enable business CPs –
particularly those using Ethernet – to engage with the NGA programme
to the same extent as those supplying services to consumers. The EAB
The EAB will continue to monitor the development of NGA in relation to
the Undertakings, although no significant compliance concerns have
been identified to date.
22
EAB Annual Report 2010
Next Generation Networks
First announced in 2004, the replacement of BT’s PSTN network with a next
generation network – known as ‘21st Century network’ (21CN) – is a large-scale
project to upgrade the capacity and capability of the company’s core and backbone
networks.
Following a review of its 21CN strategy in 2008, BT decided to reduce the
pace of deployment substantially and change to a voluntary-led
customer migration. This involved publishing shorter 12-18 month goals
and suspending the development of an NGN voice product.
These alterations to BT’s NGN deployment plans coupled with changes in
market conditions led Ofcom to consult on NGN during 2009/10. In July
2009, it published a consultation seeking views on the future regulatory
environment to support the development of NGNs. It acknowledged that
BT’s focus had shifted from NGN to NGA and aimed to understand the
impact that this could have on the market and on the supporting
regulatory framework.
It concluded in January 2010 that the current priorities with regards to
NGN remained unchanged. They were:
• To provide incentives for efficient investment in NGNs
• To promote effective competition based on NGN infrastructure
• To protect consumers from disruption during the transition to NGNs.
The consultation also discussed the issues posed by interconnection of
voice services between NGNs and legacy networks. It also considered the
investment uncertainty brought about by the changes to BT’s 21CN
plans, and concluded that BT’s existing commitment in the Undertakings
to publish a 21CN plan of record remains appropriate. Ofcom said that
any consequences of deviation by BT from its published plans should in
the first instance be governed by reference to contractual arrangements
rather than determined by regulatory intervention.
21CN developments during 2009/10
BT completed the first phase of its ‘Pathfinder’ trial for 21CN in South
Wales in May 2009. It had planned originally to migrate 120,000
customers by March 2010 and a further 275,000 by July 2010 as agreed
with CPs as part of BT’s consultation process. However, technical issues
led to delays to those dates.
In April 2010, BT announced that it would not perform further voice
service migrations as part of the Pathfinder trial. It said that this was
because of significant changes in the market such as the prospect of voice
over fibre services and the uptake of unbundled lines.
BT has also continued to roll out the 21CN Wholesale Broadband Connect
(WBC) product. This enables CPs to provide broadband services to both
service providers and end-user customers and has the capability for voice
services to be integrated using the Wholesale Broadband Connect
Converged variant (an unregulated product).
It planned to increase availability of WBC to 55% of all exchanges by
March 2010 and to 75% coverage by spring 2011. The company has said
that it will take a demand-led approach to rolling out the product. It
expects to concentrate deployment in Market Three areas, where there is
likely to be the most demand. There has also been limited deployment in
Markets One and Two.
Despite the roll-out of WBC, product development remained a concern
for many CPs during 2009/10. BT’s decision in the previous reporting
year not to continue with the development of new voice products via
21CN continued to have implications for both the overall progress of the
programme and for CPs which had made investment decisions based on
BT’s original plan.
Some CPs also expressed concern about the design of 21CN MultiService Access Nodes (MSANs) – which channel converged voice and
broadband services – as this could give BT an advantage in offering
broadband services to customers. This is because the 21CN MSANs are
configured so that any end user in a 21CN exchange who is connected to
BT for voice services is effectively also ‘pre-wired’ to receive BT’s
broadband services. However, BT Wholesale must purchase EoI LLU to
provision wholesale broadband in the same way as other CPs.
If non-BT CPs wish to offer their end customers broadband, a physical link
must be created so that this can be achieved. This could potentially
disadvantage non-BT CPs if it took longer to make services available to
their customers as a result. BT is aiming to resolve the potential issue
before PSTN voice and broadband services are commercially deployed on
the same MSAN.
Next Generation Networks continued
CPs have also told BT that they require a product known as Next
Generation Call Conveyance which will enable voice calls to be conveyed
between BT’s and CPs’ networks using NGN IP-based technology. BT has
said that it will develop this product but at a slower pace than originally
anticipated because of the wider changes to the programme. It will
continue to discuss the best approach to delivery with CPs.
EAB Annual Report 2010
NGN theme
BT activity
No foreclosure
of network
access
BT must ensure that non-BT CPs can purchase SMP
products using its 21CN infrastructure and on terms
that allow them to compete effectively with BT’s endto-end services provided over 21CN. The company
must ensure that it does not take design decisions that
would preclude the aforementioned obligations
without industry consultation.
Charges based
on efficient
design
Where BT’s network access charges are required by
SMP obligations to be applied on a cost-orientated
basis, the costs should be what BT would have
reasonably incurred had the company designed and
built its NGN in the most efficient manner. There are
also some exceptions to this obligation regarding
further changes that could be made by Ofcom or
through consultation with industry.
Provision of
network access
on an EoI basis
BT must ensure that SMP network access products
provided over its NGN are offered on an EoI basis from
launch, although this doesn’t apply to all products.
The Undertakings and 21CN
There are a number of Undertakings obligations covering NGN with
which BT must comply. The Undertakings require BT to offer NGN
products (which it does via 21CN) on an EoI basis where the company has
SMP. The Undertakings also contain other requirements for NGN – such
as obligations around consulting with industry – that BT must fulfil.
The Undertakings regarding NGN (and therefore 21CN) do not have
specific dates for EoI product launch like those for the current generation
of products and supporting systems. Instead, where BT has SMP, NGN
products must be delivered on an EoI basis from launch, on dates notified
in advance by BT. There are also requirements regarding the design and
delivery of the underlying NGN infrastructure, consultation with industry
and a number of principles to be applied to compensation arrangements
associated with some NGN products.
In 2008 the Undertakings were varied to include a further obligation for
BT to publish an NGN ‘plan of record’ – which charts BT’s progress in the
delivery programme – on a quarterly basis. BT was also required to
publish the principles that it will follow for consultations related to its
NGN programme.
The EAB has developed a ‘principles-based’ approach to monitoring BT’s
NGN obligations which involves assessing performance in a range of
areas. The EAB also monitors that NGN products were delivered on an EoI
basis where required, and that BT publishes a quarterly plan of record.
The EAB’s monitoring themes are as follows:
23
Provision of
Where BT launches a new downstream product using
network access NGN network access in an SMP market, it must ensure
on a timely basis the network access is available sufficiently in advance
of the launch, such that non-BT CPs are able to launch
competing downstream products at the same time.
Broadband
dialtone
BT could potentially use its 21CN to enable
connections to its broadband service via software
control alone rather than the manual engineering
required for LLU. This facility is known as ‘broadband
dialtone’ and BT is obliged to ensure that LLU CPs are
not materially disadvantaged solely as a result of this
software-controlled migration.
Industry group
BT must participate in any industry group established
by Ofcom to agree aspects of the transition from
existing networks to NGNs.
Operational
dispute
adjudicator
BT must agree to participate in any 21CN operational
dispute adjudication scheme established by Ofcom.
Compensation
arrangements
BT’s migration to 21CN may impact non-BT CPs in a
number of ways. The Undertakings set out principles
to be applied if BT has agreed to pay compensation to
non-BT CPs and if they incur increased network costs.
NGN
The Undertakings allow for BT lines of business to
implementation cooperate with each other to carry out the design,
build and implementation of NGN.
24
Next Generation Networks continued
EAB Annual Report 2010
The EAB applies the same monitoring criteria for NGN as it does for
current generation products, using colour-coded indicators (see p5 for
more information).
The EAB has monitored each of these themes throughout 2009/10. It
reports no major concerns and has found that BT is delivering its
obligations for each. The areas which may be at risk as a result of changes
to the voice strategy for 21CN and concerns over converged MSANs
include ‘provision of network access on an EoI basis’ and ‘broadband
dialtone’. This is because BT CPs could theoretically benefit from a nonequivalent provisioning process which is software controlled. The EAB will
continue to monitor the situation but had seen no evidence to support
non-equivalence at the time this report was published.
The EAB is satisfied that BT’s governance of the 21CN programme is
working effectively. Throughout 2009/10, BT published a quarterly plan
of record in compliance with the 2008 variation to the Undertakings and
continued to engage with industry on its plans.
The EAB continued to assess BT’s 21CN governance arrangements during
2009/10. In the previous reporting year, the EAB had conducted a review
of these governance arrangements. It found that BT had put in place a
comprehensive governance framework, but that there was scope for
increased transparency of design decisions to allay industry concerns that
BT had pre-determined outcomes.
In October 2009, the EAB conducted a follow up review, finding that BT
had put measures in place to improve its consultation process with
industry and that the process was functioning well. However, there was
still scope for key groups within the 21CN programme to meet on a more
regular basis and also to ensure that the Undertakings were embedded
throughout the programme through proactive activities such as
‘Undertakings health checks’. BT’s Internal Audit team working together
with the EAB also identified that better controls were needed over
information sharing on the programme, including the amendment of
systems access controls and the correct confidentiality markings to be put
on documents. Corrective action has been taken and Internal Audit has
confirmed that all recommendations have been addressed. It will conduct
a follow up review in the coming year.
In terms of other Undertakings commitments, BT met its obligation to
change the format used for LLU tie cables on its NGN. The RFS
commitment was delivered on schedule at the end of July 2009 and the
IBMC commitment was met a month later, two years and five months
ahead of the actual commitment date of 31 December 2011.
Our view on NGN
The EAB assessed BT’s performance against the criteria shown in the
section entitled ‘Monitoring, Reporting and Advising’ on p5 and the
themes shown on the previous page. It concludes that BT continues to
comply with its NGN Undertakings obligations. The publication of the
plan of record and the functioning of the 21CN industry consultation
groups have improved the transparency around BT’s future plans with
regards to 21CN. However, the delay to the original aims of providing
converged voice and broadband services has been significant, and the
EAB has adjusted its approach to monitoring the programme’s
compliance with the Undertakings accordingly.
With BT’s focus shifting to the delivery of NGA, the EAO will continue to
attend 21CN industry working groups and monitor key themes although
it is not aware of many significant new developments or issues requiring
consideration from an Undertakings perspective during 2010/11.
EAB Annual Report 2010
25
Behavioural change
BT employees must comply with the Undertakings in the way that they behave when
working with colleagues and dealing with customers. However, ensuring that
equivalence is applied across all lines of business and is embedded in a wide range of
processes is a complex and ongoing task. The EAB monitors BT’s progress towards
encouraging Undertakings-related behavioural change.
During 2009/10 the EAB continued to keep under review the dashboard
it developed with BT to monitor behavioural change. This uses a matrixbased approach to tracking behavioural change in three areas: ‘abiding by
the rules’, ‘industry trust’ and ‘customer satisfaction’. Each of these areas
has three categories for measuring change: ‘product’, ‘processes and
systems’ and ‘people’.
• Does BT provide the tools (for example processes, systems and
training) to help you comply with the Undertakings?
• In your view, do other BT people try to comply with the Undertakings?
• Do you think that as a result of the Undertakings, BT treats all
Communications/Service Providers, including BT lines of business,
equally?
The EAB also conducted a survey among BT employees to gain an insight
into whether the Undertakings had become embedded in the way that
they work. Each line of business also continued to run initiatives to ensure
that people had access to the necessary tools and information to stay
compliant. These activities are described below.
Participants were also asked how long they had worked for BT and were
given the chance to add written comments where necessary.
In late 2009, the EAB surveyed BT employees to gain a better
understanding of their perceptions of the Undertakings. The survey was
sent out to over 12,000 BT employees and achieved its target of a 20%
response rate which was agreed to be a statistically significant number.
The sample size captured people across all of the main functions in each
line of business. All of those selected to receive the survey were
permanent BT employees based in the UK who had completed the
computer-based training course on the Undertakings.
The survey had five key questions:
• Are you aware of the Undertakings (also known as the Code of
Practice, Telecoms Strategic Review or Equivalence)?
• Is compliance with the Undertakings an important part of your
role/job in BT?
BT employees’ responses to the perception survey
100
XX
XX
XX
XX
XX
XX
XX
95
XX
% positive response
Abiding by the rules
Overall the responses to the survey showed that people had a strong
awareness of the Undertakings and this was embedded in the way that
they worked. Over 90% of people responded positively to the questions
as shown below:
90
XX
XX
XX
85
80
XX
75
Are you aware Is compliance Does BT provide Do other
of the UTs
with UTs an you with tools BT people
important part to comply
comply with
of your role
with the UTs
the UTs
Source: the EAO
Does BT
treat all
CPs equally
Behavioural change continued
EAB Annual Report 2010
The responses showed a high level of awareness across all lines of
business and identified that most people understood the key principles of
the Undertakings and were committed to complying with them. People
also felt that BT as a whole aimed to comply and that the Undertakings
were ‘business as usual’ for most employees. The totals were lower than
expected in some areas, although all of the people participating had
completed compliance training on the subject.
Responses were largely positive for the question: “is compliance with the
Undertakings an important part of your job/role in BT?” Some of the
positive responses included comments that engineers did a great job of
remaining objective, sometimes under pressure from customers.
Respondents also commented on the restrictions in dialogue now in place
between lines of business as a result of the Undertakings. Other feedback
showed that restrictions around information sharing were very important
when dealing with CPs.
Two questions had lower response rates than the others. Over 90% of
employees responded positively to the question: “does BT provide you
with the tools to help you comply with the Undertakings?” However,
some people gave negative responses, commenting that some processes
were too complex and opaque as a result of the Undertakings and that
this made their jobs more challenging. Many were satisfied with the
Undertakings-related training packages and overall guidance on the
Undertakings available to them.
The second question to have higher negative totals than the other
responses was: “Do you think that as a result of the Undertakings BT
treats all Communication/Service providers, including BT lines of business,
equally?” Negative responses were higher than expected in some lines of
business, and some respondents said that they felt that as result of the
Undertakings, BT employees were more likely to take a cautious
approach by giving non-BT CPs better service than BT CPs.
BT’s lines of business have put in place action plans to address some of
the issues raised in the survey responses. BT Operate, Openreach, BT
Wholesale and BT Global Services have developed communication and
briefing plans to focus on areas of concern highlighted by their
employees in the survey.
BT Operate and BT Innovate and Design have implemented a frequently
asked questions section on their Undertakings and Compliance websites.
These provide tailored answers and clarification around the questions and
concerns raised in the survey responses. Openreach has also confirmed to
the EAB that it will focus compliance monitoring activity on an area of
concern highlighted in the survey and has completed an investigation of
a specific issue identified by its employees in the survey.
Undertakings training completion
Training plays a vital role in ensuring that people are kept up to date with
changes to the Undertakings and understand how these can be applied in
their day-to-day roles. BT passed its targets for those completing training
on the Undertakings during 2009/10 as shown in the graph below:
Manager and Team Member Undertakings training
completions
100
99
XX
XX
XX
97
XX
XX
XX
XX
98
Percentage of completion
26
XX
96
XX
95
XX
XX
94
93
92
XX
91
90
BT
Operate
Open- Innovate Global Wholesale Retail
reach & Design Services
Group
UK based BT Managers – target 95%
UK based Team Members – target 90%
Source: BT
The lines of business continued to develop a range of tailored training
activities. Openreach produced podcasts geared towards breach learning
and other key Undertakings topics. BT Wholesale delivered face-to-face
training on products and ensured that new joiners completed
Undertakings training. BT Wholesale has also carried out its annual
‘Confidence in Compliance’ survey and found that 86% of BT Wholesale
employees were completely or very confident that they were fully
compliant when carrying out all aspects of their job requirements. BTID
completed six Undertakings refresher presentations to its employees.
Behavioural change continued
EAB Annual Report 2010
Industry trust
Maintaining industry trust that EoI products are on offer and that BT
employees are behaving compliantly is crucial to the success of the
Undertakings. The dashboard includes measures of BT’s responsiveness to
customer needs and other measures that can be used as indicators of
industry trust, for example the number of SoR requests Openreach and
BT Wholesale accepted or rejected from BT and non-BT CPs.
Statement of Requirements requests
BT CPs and non-BT CPs must use the SoR process to request changes to
Openreach or BT Wholesale products with SMP. Openreach and BT
Wholesale are required to respond to SoR requests within set timescales.
The dashboard compares data on the number of SoR requests from BT
CPs and non-BT CPs that are accepted or rejected – as well as those
delivered – by Openreach and BT Wholesale. There are many ways in
which this data can be interpreted but the two main indicators of industry
trust are firstly, the number of requests submitted – a large number
possibly showing trust in the process – and secondly, whether there are
significant differences in the number of requests from BT CPs and non-BT
CPs that are accepted or rejected.
The chart in the adjacent column shows that during the period April 2009
to March 2010 Openreach received a total of 66 SoR requests from all
CPs. Of these, 42 SoRs were received from BT CPs, representing 64% of
the total volume and 24 SoRs were received from non-BT CPs,
representing 36% of the total volume. Although non-BT CPs had
submitted about half of the number of those submitted by BT, they only
had one accepted and one delivered. The EAB will continue to monitor
the number of requests progressed to ensure that the process is
functioning on an equivalent basis.
Openreach launched a new SoR process in August 2009 to provide
greater transparency around the progress of requests. The new system
allows CPs to share their own SoRs and see requests raised by other CPs.
Openreach has also encouraged CPs to work collaboratively before
requests are submitted into the SoR process. The EAB reviewed the
process during 2009/10 – for more information see p31.
The chart below shows that BT Wholesale recorded twice the number of
SoRs from non-BT CPs than it did for BT CPs.
BT Wholesale SoRs
April 2009 to March 2010
The charts on this page show the number of SoRs received by both
Openreach and BT Wholesale, together with how many are pending
currently, how many have been accepted or rejected and how many have
been delivered.
50
45
XX
XX
XX
XX
Number of SoRs
XX
XX
XX
XX
XX
80
70
XX
XX
60
XX
XX
50
XX
40
30
20
XX
XX
XX
XX
10
0
received
XX
30
25
pending
SoRs raised by non-BT CPs
XX
20
SoRs raised by BT CPs
15
XX
5
0
received
pending
rejected
SoRs raised by non-BT CPs
SoRs raised by BT CPs
rejected
XX
XX
10
Source: BT
90
XX
40
35
100
Number of SoRs
Openreach SoRs
April 2009 to March 2010
accepted
delivered
27
Source: BT
accepted
delivered
28
Behavioural change continued
EAB Annual Report 2010
Customer satisfaction
The dashboard measures customer satisfaction with both the
Undertakings-related performance of Openreach and BT Wholesale.
Customer satisfaction remains an important indicator of behavioural
change as it demonstrates customer confidence in BT’s delivery of the
Undertakings. It can also be one of the most challenging to interpret
as explanations are not always available as to why figures fluctuate
year-on-year.
Satisfaction with Openreach
The chart below shows that satisfaction with Openreach’s overall
compliance with the Undertakings continues to rise slowly.
Openreach Delivers Products Equivalently
100
90
% customers agree
In the first six months, one CP was responsible for 19 of the SoRs
submitted, 14 of which were rejected. BT Wholesale reported to the EAB
that this was because some CPs were using the SoR process to make
requests related to services not available via SoRs and that this has now
been resolved. Despite this, 19 SoRs were delivered for non-BT CPs while
one was delivered for BT CPs. BT Wholesale delivered more SoRs than it
accepted during the year because of the balance already in progress at
the start of the year. The EAB believes that BT Wholesale’s SoR process is
operating on an equivalent basis, once the anomaly regarding the CPs
requests is taken into account.
80
70
60
50
Apr
09
May
09
Jun
09
Jul
09
Aug
09
Sep
09
Oct
09
Nov
09
Dec
09
Jan
10
Feb
10
Mar
10
Source: BT
Satisfaction with engineers’ behaviour
Openreach regularly surveys its customers to assess how satisfied they are
with the behaviour of engineers on visits. Many of Openreach’s CP
customers sell Openreach services under their own brand to end customers
but rely on Openreach engineers to make site visits. It is therefore important
that Openreach engineers behave in an impartial way when visiting the end
customers of both BT CPs and non-BT CPs. This was an area the EAB asked
Openreach to focus on specifically in 2009/10. The chart below shows that
customer satisfaction with engineers’ behaviour continued to increase
during 2009/10, although with a slight dip in January 2010.
Satisfaction with BT Wholesale
Overall, the results below show that confidence that BT Wholesale
delivers its products equivalently has remained consistent during
2009/10 .
BT Wholesale Delivers Products Equivalently
100
Openreach Engineers Behave Appropriately
90
% customers agree
100
% appropriate behaviour
90
80
80
70
60
70
50
Apr
09
60
50
Apr
09
Source: BT
Source: BT
May
09
Jun
09
Jul
09
Aug
09
Sep
09
Oct
09
Nov
09
Dec
09
Jan
10
Feb
10
Mar
10
May
09
Jun
09
Jul
09
Aug
09
Sep
09
Oct
09
Nov
09
Dec
09
Jan
10
Feb
10
Mar
10
Behavioural change continued
Our view on behavioural change
The EAB is satisfied that BT continues to ensure that the behaviour of its
employees supports the Undertakings. Our survey of BT employees
during 2009/10 showed that compliance with the Undertakings is
embedded in the way that people work with few areas of concern. The
behavioural dashboard also shows year-on-year consistency across all
compliance measures. CPs have told the EAB that they continue to be
satisfied with the behaviour of BT employees in dealing with their
requests.
The EAB will continue to keep track of behavioural change as a result of
the Undertakings. The development and launch of NGA products and
services – as well as the continued availability of current generation
products – creates a complex environment for those working in some
parts of the company. The fact that the Undertakings – and the
compliance programme relating to them – has been in place for nearly
five years may also lead to complacency among those whose work is only
occasionally touched on by the Undertakings. Continued training and
development will be necessary to ensure that the high levels of
compliance and customer satisfaction are retained in the coming years.
EAB Annual Report 2010
29
30
EAB Annual Report 2010
Reviews of compliance themes
The EAB has broad responsibility for checking BT’s compliance with all of the
Undertakings obligations. These include dated milestones and specific audit
requirements as well as own-initiative investigations based on identified risks.
Compliance work based on ongoing
obligations
The EAB has responsibility for monitoring certain areas that require
regular reviews but do not follow the same monitoring approaches as the
current generation product milestones or the ‘principles-based’
monitoring of NGN and NGA.
Exchange space
Space in BT’s local exchanges is an important part of the infrastructure
supporting the delivery of the Undertakings. BT Operate manages the
local exchanges which house the local access nodes owned by
Openreach.
In October 2008, BT and Ofcom agreed a variation to the Undertakings in
response to CPs’ concerns that they had difficulty in reserving space in BT
exchanges. The variation required BT to publish guidelines for the process
of allocating exchange space and power for Openreach’s LLU and
Ethernet products. BT was also required to conduct a proactive review of
exchanges with a view to freeing up space. Openreach also needed to
develop and launch a space-only allocation product on an EoI basis and
review the scope of the existing LLU co-mingling product to allow more
flexible use of exchange space. Finally, the variation required the EAB to
carry out regular audits of exchange space and review allocation
processes focusing on those exchanges where the main distribution
frames were constrained.
During 2008/09, the EAB carried out the first validation of exchange
space and as a result recommended changes to the process for allocating
space in exchanges. Openreach reported that these would be addressed
by a new proactive space and power review process that it was launching
in March 2009.
The EAB performed a further compliance spot check in early 2010. It
found that Openreach was maintaining the guidelines and
documentation for the new review process compliantly, but there were
some concerns around the operation of the process. In response to
concerns from industry stakeholders, the EAB investigated Openreach’s
management of the proactive review process. It found that in some
cases a BT CP was receiving a consistently faster service than non-BT CPs.
It also found that there was no proactive review service available for nonBT CPs unless they submitted a particular request. At the time this report
was published, Openreach was investigating these issues.
Risk-based compliance
The EAB keeps a risk register to track the most important areas of
concern. It bases its assumptions on the findings of its monitoring work as
well as the frequency of non-compliant incidents.
In 2008/09, the EAB identified a range of risks which shaped its
monitoring work during 2009/10. It undertook a range of actions to
further investigate these risk areas and made recommendations to BT.
Risk
2008/09
recommendations
Outcome
1 Late delivery of
future milestones
(e.g. WLR3 ISDN2
IBMC)
To be decided once
outcome of variation
known.
Milestone delivery
dates varied, new
responsibilities for the
EAB. See p13.
2 Inappropriate
information
sharing
The EAB planned to
conduct reviews of
information sharing.
See below for the
outcome of reviews on
this topic.
3 Non-equivalence
of Openreach
billing and
charging processes
Openreach to provide
further information to
the EAB.
All EoI billing for all CPs
was moved onto a
single new system
(Atlantis) significantly
reducing this risk.
4 Ineffective
compliance
governance
processes (e.g.
ineffective control
of Openreach
assets)
The EAB recommended The EAB reviewed key
a review of BT’s high
processes as part of its
risk processes.
ongoing compliance
programme. See the
next page for more
information
5 Non-equivalent
escalation
processes
The EAB planned to
conduct a follow-up
review of Openreach’s
escalation process.
Findings from the
review can be found
on p32.
Reviews of compliance themes continued
Information sharing
Sharing commercially sensitive or customer confidential information across
boundaries within the company has remained a persistent source of
breaches since the Undertakings were agreed four and a half years ago.
Therefore, the EAB has identified information sharing as one of its main
risk areas, although the overall number of cases is small in the context of
BT’s operations. The EAB conducted a series of reviews during 2009/10 to
check that information boundaries were functioning effectively:
EAB Annual Report 2010
Line of business Findings
BT Innovate
and Design
Line of business Findings
BT Global
Services
Review found no evidence of non-compliance but
recommended that BT Global Services should conduct
an audit to ensure that behavioural controls are
sufficient to mitigate the risk of inappropriate systems
access. BT Global Services confirmed that it had put
these measures in place.
BT Retail
Review found no evidence of non-compliance.
However a potential breach was investigated as part
of the BT Wholesale information sharing review. This
involved the rights of some BT Retail employees who
worked with the BT Wholesale billing team to access
confidential information. This was found not to be a
breach of the Undertakings as the employees were
covered by Annex 2.
BT Wholesale
BT Operate
Review found that BT Wholesale was compliant and
that considerable thought and effort had been
applied to training its staff on the information sharing
obligations. The review identified one isolated
example of potential inappropriate sharing of
customer confidential information although it was
unlikely that a ‘downstream’ line of business could
have benefited from the information. As a result,
action was taken to reinforce the information sharing
rules.
The EAB completed a follow up review of information
sharing in BT Operate (the first review took place at
the end of 2008) focusing on the process for
controlling information shared in Permitted Access
Teams (PAT). It also looked at the effectiveness of
information sharing briefings to the field engineering
workforce. The PAT process has been developed to
ensure that anyone outside Openreach who needs to
have access to Openreach data does so in a controlled
and managed environment.
The review found that although manual and labour
intensive, the PAT process was being professionally
managed and no areas of concern were identified. BT
Operate planned to partially automate this process in
future. The review also found that BT Operate had
ensured that field engineers have access to tailored
Undertakings information and briefings that
specifically address the focus of their work. It
concluded that engineers understood the boundaries
between Openreach and BT Operate, and knew who
to contact if they needed further guidance.
31
The EAB completed a follow up review of information
sharing in BTID focusing on areas of concern raised in
the initial review in December 2008. The review found
that all concerns had been addressed and no other
issues were identified. An EAO concern related to the
Undertakings training that contractors receive is being
investigated by BTID which has agreed to keep the
EAB updated on this matter.
The EAB is satisfied that all of BT’s lines of business are aware of the risks
around information sharing and have put in place adequate controls and
training to ensure that employees comply with the information sharing
rules. While it is likely that there may be further incidences of noncompliant information sharing in future, the EAB no longer considers this
to be a high risk area as the impact of these breaches has so far been
minimal.
The EAB also conducted a review of BT’s compliance with some of the
Undertakings obligations that require BT to maintain organisational
separation between upstream and downstream divisions. This review
looked at not only the management of information flows but influence
over commercial policy and account management arrangements. The
EAB concluded that BT had adequate mechanisms in place to ensure
compliance.
Processes
The processes that underpin the delivery of EoI products have continued
to evolve in recent years with the development of NGA products.
CPs have raised a number of issues with the EAO regarding the
transparency and functionality of Openreach’s SoR process – the
mechanism for requesting changes to existing products and the
development of new products. The EAO reviewed the new SoR process
launched by Openreach in August 2009 to provide greater transparency
around the progress of each SoR. Openreach also launched an online
tracker tool so that CPs could follow the progress of requests.
The EAO found that the process was working compliantly but that it was
still relatively new and some elements needed to be improved. The new
system allowed CPs to see SoRs raised by other CPs for the first time,
although there was an option for CPs not to share their SoRs with other
CPs. However, in these cases, Openreach will not progress the
requirement until it has been reviewed and agreed by the relevant
industry forum.
The EAO proposed that Openreach could improve the effectiveness of the
SoR tracker tool by providing guidance and training to those using it. It
suggested that the new process should be shared fully with industry, and
it will conduct a follow-up review once the process has been operating for
a longer period of time to ensure that these improvements have been
made.
32
EAB Annual Report 2010
The EAO also reviewed the product management process, which is closely
related to the SoR process described on the previous page. In 2008/09,
the EAO conducted a review of the Openreach product launch process. It
found that too much reliance had been placed on an implicit
understanding of regulatory requirements and equivalence issues by
those involved in the operation of the process, and this had been the root
cause of some related breach cases. At the time of the review, although
Openreach had already introduced improved regulatory guidance and
inputs at key decision points in the process, there were further end-toend changes to be made and embedded.
In a follow up review during 2009/10, the EAO examined changes to key
phases of the product development and launch process including the
assessment of product requirements; the design, development and
testing of solutions; and the release and preparation of products for
launch.
The EAO found that throughout the product launch process, there were
now clearer regulatory checkpoints including the sign-off of product
business cases by regulatory specialists. Product manager assessment
checklists had also been prepared to help ensure that, at each step of the
product launch process, appropriate actions had been taken to satisfy key
Undertakings requirements relating to equivalence.
The review noted that more specific guidance on equivalence could be
incorporated into the checklists but that Openreach had introduced a
range of on-line tools to help its employees act compliantly. In addition,
Openreach was considering if there was scope for the increased
participation of regulatory specialists at key decision points within the
development and launch process. The review did not test industry
perceptions of the effectiveness of the recent changes, as they are still
relatively new. However, once the volume of requests that go through the
full product launch process increases, the EAO will seek industry’s
feedback.
The EAB also undertook ongoing compliance checks of other processes
relevant to the Undertakings. It looked at the functioning of the Contract
Management Mechanism (CMM). The CMM is a process that BT and
industry can use if parties reach an impasse during contract negotiations
around terms and conditions relating to SMP products. The EAB reviewed
the process and found that even though it had not been used since its
launch in 2006, Openreach was compliant with the requirement to offer a
CMM. It also found that Ofcom had been used as an arbiter rather than
the CMM on one occasion. It also discovered that there were few
references to the CMM as an option on contracts. The EAB recommended
that this should be included in future documents.
The EAB also performed a follow up review of escalations processes in BT
and found that all outstanding issues highlighted in the original report
and related breach cases had been addressed. However, in common with
other core processes designed to safeguard equivalence, the EAB has
Reviews of compliance themes continued
continued to keep the escalations process under review. During the year,
the EAB investigated a non-trivial breach relating to escalations, although
this related to an incident dating back to 2008 (see the table on p33 for
more information).
During the year the EAB commissioned several reviews of BT’s outsourced
operations in India. These initial reviews were intended to give the EAB
visibility of any key weaknesses in processes, systems or behaviours which
might require further detailed investigation.
The reviews were completed in March 2010 and the findings have
highlighted that, in the main, there is evidence of compliance with the
Undertakings in the areas visited. However a number of potential issues
were identified in respect of Undertakings awareness relating to Annex 2
status. In addition there are some potential areas for further examination
in relation to the allocation of provision and repair activities and handling
of escalations. The findings have been shared with local management in
India and with the relevant UK compliance teams, and a formal response
has been requested. Any outstanding issues will be followed up during
the coming year.
The effective functioning of the processes underpinning the delivery of
current and next generation EoI products remains a key focus area for the
EAB. Improvements made by Openreach to the SoR process during
2009/10 may help to resolve some of the issues raised by CPs, but the
EAB will continue to monitor that this and other processes continue to
uphold the principles of the Undertakings.
Our view on the key monitoring themes
When assessed against the monitoring criteria shown in the section
entitled ‘Monitoring, Reporting and Advising’ on p5, the EAB is satisfied
that BT is working to address risk areas, such as those processes identified
as being non-compliant by the EAB. It also continues to cooperate
effectively with the EAB in its programmes of ongoing compliance
monitoring.
Some issues identified as part of the review work will be further
investigated during 2010/11. See p36 for more information.
EAB Annual Report 2010
33
Understanding non-compliance
The Undertakings place obligations on both the EAB and BT to identify, investigate
and report on incidents of non-compliance.
There are a number of ways in which the EAB investigates non-compliance:
• It examines in detail the cases of non-compliance reported to it by BT via the breaches process and complaints reports. It forms a view on these cases
and makes recommendations to BT accordingly. It also makes recommendations to BT on breaches that the EAO has identified and investigated.
• It receives complaints directly from CPs via its formal complaints process and investigates issues raised by CPs on an informal basis through its ‘Quick
Checks’ process.
• It carries out ‘spot checks’ and reviews of higher risk areas on an ongoing basis.
Breaches
The Undertakings place obligations on BT and the EAB to identify and report on breach cases. Following a breach notification from BT or the EAO, the EAB
determines its view on the case and its significance (non-trivial or trivial) and the appropriateness of the proposed remedial actions. The EAB can also
recommend additional actions which can help mitigate the impact of a breach – particularly when a remedial action cannot be implemented immediately
as it requires the development of a new process or systems solution. These are known as ‘consequential’ actions and are designed to minimise the risk of
similar breaches occurring in the future. A description of the breaches reported in 2009/10 as well as their root cause is set out below.
In 2009/10 BT reported ten non-trivial breach cases and three trivial cases to the EAB (seven fewer than were reported in 2008/09). The EAB
considered that eleven of the cases were non-trivial and two were trivial. Five of the non-trivial breaches involved the late delivery of Undertakings
milestones – although these were later removed by a variation to the Undertakings – and six related to equivalence issues:
Non-trivial breach details
Remedy
BT did not achieve the milestone for the migration of the installed base
of WLR3 ISDN2 (due by 31st March 2009).
The milestone was incorporated into the revised 90% EoI migration target for
measured products introduced in the twentieth variation to the Undertakings.
BT did not achieve the milestone to migrate 50% of all supply side records
held on shared OSS systems, to separate systems (due by 31 May 2009).
This specific milestone was removed subsequently by a variation to the
Undertakings.
BT did not achieve the milestone to implement physically separate OSS
for users across the rest of BT with access to manual exception tasks for a
number of WLR3 products (due 31 May 2009).
This specific milestone was removed subsequently by a variation to the
Undertakings.
BT did not achieve the milestone to migrate 70% of BT’s installed base to
WLR3 (due by 30 June 2009).
In February 2010, the EAB confirmed BT’s delivery of this milestone by
the revised (informally agreed) date of 30 September 2009.
BT did not achieve the milestone to migrate Featureline customer side
records to physically separate systems (due by 30 June 2009).
The milestone was incorporated into the 80% customer side record
migration target introduced in a variation to the Undertakings.
A BT CP was provided with a dedicated email account to escalate faults
relating to WLR3 when the standard escalation process failed for a short
period in 2008.
The email account was withdrawn and Openreach reinforced the need
for the Customer Service Teams to provide EoI solutions at all times.
The EAB validated the remedy and the case was closed in November 2009.
The EAB disagreed with BT’s assessment that the breach was trivial.
A BT CP received an additional report regarding the status of WLR3
orders and faults.
The breach was remedied when the report was withdrawn and the
information was made available to all CPs on an EoI basis.
The EAB agreed with BT’s assessment that the case was non-trivial as all
product reporting should be made available on an EoI basis.
The EAB validated the remedy and the case was closed in September 2009.
Openreach at the request of a BT CP used a separate process to report
faults to its DSLAMs (the pieces of equipment owned by CPs and located
in a local exchange to provide broadband services to an end user).
The breach was remedied when Openreach developed an EoI solution to
reporting DSLAM faults.
The EAB validated the remedy and the case was closed in February 2010.
34
Understanding non-compliance continued
EAB Annual Report 2010
Non-trivial breach details
Remedy
The BT Revenue Assurance Team responsible for billing accuracy shared
data with a BT CP relating to billing errors for EoI products that should
have been provided to all CPs simultaneously.
At the time this report was published, BT Retail had submitted SoRs to
Openreach and BT Wholesale to supply data on an EoI basis to meet all
CPs’ needs. BT Wholesale had agreed an SoR to develop a strategic
solution later in 2010 and Openreach was completing a feasibility study
to do likewise. In the interim, non-BT CPs were being provided with a
tactical solution to meet their requirements.
BT Innovate and Design implemented a systems change to improve the
provisioning of the EAD product before Openreach had fully completed
its approval of the SoR request from BT Wholesale.
Industry was informed of the SoR and subsequent systems change. The
process for authorising such changes has been reviewed and updated.
A system feed to the BT Retail Data Warehouse contained a coding error
that led to the inclusion of a very small number of non-BT CP customers’
details in the downloaded data. The EAB disagreed with BT’s assessment
that the breach was trivial.
The system controls were updated to exclude all records that did not
relate to BT Retail’s customers.
The two cases classified as trivial this year related to inappropriate information sharing and are summarised below:
Trivial breach details
Remedy
Product data was inappropriately shared with a small group of people in
BT support functions who were not eligible to receive it.
The data was deleted from the files of the recipients who should not have
received it and from a shared database.
Disciplinary proceedings were also instigated where appropriate.
The EAB validated the remedy and the case was closed in July 2009.
Openreach routed third party calls regarding public works carried out to
the access network via a BT Retail Call Centre without agreeing a service
level agreement (SLA).
Openreach agreed an SLA with BT Retail to provide a call centre service
on its behalf.
Three further issues were under assessment as potential breaches at the time this report was published, and the EAB will report on the outcome of these
in its regular bulletins.
In its deliberations on some of the service-related breaches, the EAB was keen to emphasise that four and a half years after the Undertakings were
agreed and after the notification of 57 breaches, BT should not be repeating the same mistakes that have led to previous similar breach cases. The
provision of additional WLR3 status reports, for example, could easily have been made available to all CPs. Although a main root cause of breach cases
has been a desire to satisfy customer requirements and to preserve the end-user experience, it is also clear that some BT employees have not sufficiently
considered the EoI implications of their actions.
Building on this feedback, BT has continued to examine and disseminate the root cause of individual cases and how they might be prevented in the
future. Openreach in particular has made good progress in this area employing web-based and face-to-face briefings to inform its service teams of key
issues. It has also provided training to encourage a greater level of compliance.
Managing and remedying breach cases
During 2009/10 the EAB has continued to work with BT to improve the effectiveness of the breach process. The EAB has noted that BT has sought to
reduce the time taken to investigate and remedy cases and provide an interim remedy where a longer term solution will take time to develop.
The EAB conducted a review of BT’s remedial actions in respect of a non-trivial breach which was reported in the previous year as a result of Openreach
not correctly billing other parts of BT for some of its products and services. The review found that all remedial actions had been discharged and noted
that BT internal audit had also conducted an audit which concluded that the billing process supported by the Atlantis system was operating on an
equivalent basis.
Complaints
Both BT and the EAB handle complaints from CPs regarding potential incidents of non-compliance. BT also receives complaints directly from employees.
Complaints to BT
As in previous years the EAB has continued to receive quarterly reports of the complaints to BT from CPs. The number of complaints in 2009/10 has
fallen significantly to seven (up to Q3 2009/10) compared to 19 in 2008/09 and 40 in 2007/08.
Understanding non-compliance continued
EAB Annual Report 2010
One of the complaints this year related to the WLR incentive scheme
which a CP alleged breached BT’s Undertakings responsibilities. BT’s
investigation of the issue found that the scheme was compliant and
operating fairly. The EAO also examined the issue through its ‘Quick
Checks’ process described below and found no evidence that the scheme
had failed to comply with appropriate obligations or was designed to
operate non-equivalently.
35
Half the investigations were triggered by various product-related issues
and the product SoR process. The single topic resulting in the most
investigations was Openreach’s SoR process. Product concerns were
predominantly around the Ethernet portfolio, and most notably the SLU
product and the EAO has informed Openreach of these concerns.
Equivalence and information sharing concerns also featured heavily.
The outcome of each of the issues is shown below:
Unlike in the previous year, no complaints were raised by CPs in respect of
engineers’ behaviour during 2009/10 possibly demonstrating the
effectiveness of Openreach’s engineers’ training programme.
Outcomes of closed Quick Checks
Complaints to the EAB
There have been no CP complaints to the EAB this year. This may be
because the EAB has successfully addressed CPs’ potential concerns
through the ‘Quick Checks’ process.
3
1
3
12
Issues
The EAO looks into issues raised informally by key stakeholders including
BT, non-BT CPs, Ofcom and the OTA2 as part of its ‘Quick Checks’ process.
This process allows the EAO to record and track issues and assess rapidly
whether they need more detailed, formal investigation. Non-BT CPs have
told the EAO that they find the process a useful way of resolving their
concerns without needing to submit a formal complaint and this may
explain partly why the EAO has only received four complaints in the last
four and a half years.
In 2009/10, the EAO investigated 34 issues – an increase of 22 from the
previous year. Many of the issues investigated came from the EAO’s
ongoing engagement with CPs during the reporting year, and therefore
the rise does not necessarily indicate increased dissatisfaction.
The issues investigated during 2009/10 can be grouped into areas:
Quick Checks – Initial areas of concern
4
11
Actions
recommended to
BT and CP briefed
No actions
recommended to
BT (Internal only)
Not applicable to
the Undertakings
No actions
recommended to
BT and CP briefed
Actions
recommended to
BT (internal only)
Potential breach
identified
The EAB made a number of recommendations to BT following
investigations into the issues raised. These included recommendations on
process improvements, refinements to internal governance mechanisms,
and communications opportunities to the CP community.
Our view on non-compliance
1
1
1
1 1
1
Based on the findings of the processes described on p33, the EAB is
satisfied that the number of non-compliant incidents has reduced
significantly during the year. While there were eleven non-trivial breaches
of the Undertakings, five of these related to the re-prioritisation of
milestones. The lower number of complaints is also a positive indicator,
although the increased number of issues raised informally with the EAO
implies that there are a small but persistent set of issues still requiring
further investigation and resolution during the coming year.
10
1
3
7
7
Products
Information sharing
Complaint handling
Openreach SoR
process
Space and Power
Contracts
Time Related
Charging
Financial accounts
EoI
BTs’ organisation
Image clothing
36
EAB Annual Report 2010
Outlook for 2010/11
The EAB’s focus shifted during 2009/10 from monitoring product milestones
with dates determined by the Undertakings to a broader programme of ongoing
and ‘principles-based’ compliance. It expects this focus to continue to evolve
during 2010/11.
Focus on reprioritised systems separation dates
As a result of the 2009 variation to the Undertakings, some of the remaining milestones for systems separation were rescheduled. Obligations such
as 80% migration of customer-side records were put back until 30 June 2010. The EAB will monitor that these milestones have been delivered. It will
also monitor the four non-binding milestones relating to the systems stack for business customers – in particular, it is concerned that the ‘Initial Live
Deployment’ due on 31 December 2010 is at risk. The EAB will also continue to monitor that user access controls put in place in lieu of full physical
systems separation are functioning effectively. In terms of other deliverables also due, the status of the Wavestream National RFS obligation (due
31 December 2010) was under review at the time this report was published. The EAB considers its delivery deadline may be at risk of being missed. In
addition, based on its monitoring of EoI obligations, its ongoing compliance checks, its review work described in ‘Monitoring reporting and advising’ on
p5 and the incidences of non-compliance identified during 2009/10, the EAB updated its risk register. It reviews risk on a quarterly basis and makes
recommendations on this basis to BT. The key areas of risk identified during 2009/10 were:
Risk area
Planned action
1 Openreach’s SoR process – operation and industry confidence
The EAB will conduct a follow up review during 2010/11
2 NGA – risk of launch of non-EoI products and/or non-compliance with
passive input obligations
The EAB will conduct reviews of the NGA product launch process and
Openreach’s engagement on NGA with external entities (such as the
Regional Development Agencies).
3 Ineffective compliance governance processes (e.g. product
management and the escalations process)
The EAB will review Openreach’s product management process,
including how commercial differentiation is used in bids and solution
development and aspects of service management including the
escalations process. It will also review the Ethernet portfolio.
4 Prioritisation of BT product developments over those of CPs (undue
influence of Openreach decisions)
The EAB will assess whether the competing product investment demands
of BT’s downstream businesses prejudice the investment decisions
required to support Openreach requirements.
5 Inappropriate access to systems
PwC will conduct audits of the effectiveness of user access controls
applied to OSS and there will be ongoing internal quarterly analysis of
these controls.
Outlook for 2010/11 continued
The EAB will incorporate these areas into its work for the coming year by
conducting reviews and compliance spot checks. It will also focus on a
number of broader areas as part of its overall monitoring programme.
Ongoing development of NGA
During 2009/10, NGA was one of the key focal points for industry and
government alike. The debates around the future regulatory framework
for NGA are likely to continue beyond 2010, although BT’s NGA is
scheduled to develop at a rapid rate during the coming year. The EAB has
particular responsibility for monitoring the delivery of FTTC passive inputs,
if they are provided. It will also monitor the delivery of NGA products,
such as the Open ATA product if it is launched.
Continued focus on product
management and SoRs
The EAB’s reviews of processes such as escalations, the SoR process and
the CMM during 2009/10 highlighted that while the majority of these
processes were functioning effectively, there was still room for greater
transparency and better communication with industry.
The EAB will continue to focus on the functioning of Openreach’s new
SoR process to ensure that it is operating on an EoI basis and that industry
requests are progressed fairly. It will also focus on the product
management process – which has come under criticism from industry –
particularly during the development of NGA products. Openreach has
said that it is planning to make improvements to this process.
EAB Annual Report 2010
37
Beyond 2010
The fast-paced regulatory environment – particularly around NGA – will
continue to lead to changes that could affect the EAB’s monitoring of BT’s
delivery of the Undertakings.
In particular, the Wholesale Local Access and Wholesale Broadband
Access market reviews that were under way at the time this report was
published were consulting on proposed remedies for issues arising from
the implementation of next generation products. The EAB will factor any
outcomes relevant to the Undertakings into its future monitoring plan.
The EAB will continue to stay focused on the principles and requirements
of the Undertakings over the coming year and will report regularly on BT’s
progress in its online bulletin.
38
EAB Annual Report 2010
Indicators
This section of the report looks at the measures of equivalence for current generation
products. It also includes a record of BT’s delivery of its Undertakings obligations.
Product Key Performance Indicators
The EAB assesses key performance indicators (KPIs) published by BT showing the performance of BT’s EoI products. The KPI charts for each product
portfolio compare service provided to CPs within BT to that for non-BT CPs.
The KPIs are shown as line charts with one line representing the product performance experienced by BT CPs and the other the performance as
experienced by non-BT CPs. If the two lines are consistently different it may indicate that there is an equivalence issue. However there are several factors
that can cause differing performance and these don’t necessarily constitute a breach of the Undertakings. Tests are also applied to assess whether any
difference is statistically significant. These factors are explained on a product-by-product basis below for a selected number of KPIs.
KPI measure
EAB non-equivalence
concern investigated
during the year
WLR3 Analogue provision
WLR3 Analogue repair
WLR3 ISDN2 provision (EoI tactical)
WLR3 ISDN2 repair (EoI tactical)
WLR3 ISDN30 provision
WLR3 ISDN30 repair
LLU SMPF provision (basic provide)
LLU SMPF repair
LLU SMPF migrations
LLU MPF provision
LLU MPF repair
WES provision
WES repair
BES provision
BES repair
WEES provision
WEES repair
IPstream Connect provision
IPstream Connect repair
IPstream Connect migrations
Wholesale Broadband Connect provision
Wholesale Broadband Connect repair
yes
yes
no
yes
yes
no
no
no
no
no
no
no
no
yes
no
yes
no
yes
yes
no
N/A*
N/A*
*The KPIs for Wholesale Broadband Connect were outside of the scope of this
report.
Charts where performance was similar throughout the year for non-BT
CPs and BT CPs are not shown.
WLR3 Analogue provision and repair
BT publishes KPIs for WLR3 Analogue provision and repair. The chart
below shows that provision performance has been generally equivalent
with the dip in July caused by some failures in a large batch of transfer
orders by a single non-BT CP. The provision KPI comprises a series of
sub-order types such as modifications and cessations as well as new
provisions, each of which have different average times to process.
Changes in this mix can sometimes cause the overall performance to vary
slightly. As a result the EAB believes that the chart does not indicate a
non-equivalence issue and is satisfied that all CPs are experiencing similar
performance.
WLR3 Analogue – Basic Provision
100
98
Percentage of orders provided on time
The performance recorded for each product during 2009/10 was as
below and is described in more detail in the following pages:
96
94
92
90
88
86
84
82
80
Apr
09
May
09
Jun
09
Jul
09
Non-BT CPs
Aug
09
Sep
09
Oct
09
Nov
09
BT CPs
Dec
09
Jan
10
Feb
10
Mar
10
Indicators continued
EAB Annual Report 2010
WLR3 ISDN30 provision
WLR3 Analogue Repair
The WLR3 ISDN30 provision order volumes have remained low during the
year for both non-BT CPs, and especially for BT CPs. The chart below
identifies that non-BT CPs have experienced a generally higher level of
provision success for the majority of the year. During the year, the EAB
identified an error in the reported ISDN30 provision metrics and,
following an investigation and analysis by Openreach, this was rectified
subsequently and is reflected in the chart shown below.
100
Percentage of faults repaired on time
95
90
85
80
75
As a result of the low volumes and the complexity of individual ISDN30
orders, the EAB believes that the higher provision levels for non-BT CPs
shown on the chart may not indicate a non-equivalence issue. It will
continue to monitor this situation closely during the coming year.
70
65
60
Apr
09
May
09
Jun
09
Jul
09
Aug
09
Sep
09
Oct
09
Non-BT CPs
Nov
09
Dec
09
Jan
10
Feb
10
Mar
10
WLR3 ISDN30 Provision
BT CPs
100
The chart above for WLR3 Analogue repair performance shows that
performance for non-BT CPs was consistently better than performance
for BT CPs throughout the year due to BT CPs’ having a higher percentage
of residential underground faults. These generally take longer to repair
than other types of faults due to accessibility. In addition, performance in
January 2010 was affected by the severe weather conditions. This
suggests that there are no equivalence issues with the product.
WLR3 ISDN2 provision (EoI tactical)
The chart below shows BT CPs have experienced better performance for
much of the year. This was due to a significantly higher volume of failures
for non-BT CPs than BT CPs, which were attributed to customer
equipment faults. In addition, a single non-BT CP was found to be not
closing its faults in a timely manner, which influenced the performance
chart. The EAB will continue to monitor both of these situations in the
coming year.
WLR3 ISDN2 (Eol Tactical) Repair
100
Percentage of faults repaired on time
98
96
94
92
90
88
86
84
82
Jul
09
Non-BT CPs
Aug
09
Sep
09
70
60
50
40
30
Jul
09
Aug
09
Sep
09
Non-BT CPs
WLR3 ISDN2 repair (EoI tactical)
Jun
09
80
20
WLR3 ISDN2 provision performance was broadly equivalent for BT CPs
and non-BT CPs throughout 2009/10.
May
09
Percentage of orders provided on time
90
80
Apr
09
39
Oct
09
Nov
09
BT CPs
Dec
09
Jan
10
Feb
10
Mar
10
Oct
09
Nov
09
Dec
09
BT CPs
Jan
10
Feb
10
Mar
10
40
Indicators continued
EAB Annual Report 2010
WLR3 ISDN30 repair
IPstream Connect provision
WLR3 ISDN30 repair performance for BT CPs and non-BT CPs has
remained broadly equivalent throughout the year. A slightly worse
performance for BT CPs in the latter months was caused by a high
proportion of digital access carrier system (DACS) orders making provision
more complex.
The chart below shows that BT Wholesale has consistently provided
IPstream Connect on time for a higher percentage of orders from non-BT
CPs than it has for orders from BT CPs. Analysis shows that the difference
throughout the year can be attributed to the relative complexity of
orders.
LLU SMPF provision (basic provide)
BT CPs have a higher proportion of ‘simultaneous provide’ orders, where
telephony and broadband are provided at the same time. These orders
are generally more complicated to fulfil and therefore have a lower
success rate for provision within target timescales than other more simple
order types. If the effect of the ‘simultaneous provide’ order type is
excluded from the results, the number of orders completed on time by BT
Wholesale for BT CP and non-BT CPs is broadly similar.
BT publishes KPIs on provision and repair for the LLU products, Shared
Metallic Path Facility (SMPF) and Metallic Path Facility (MPF).
BT CPs and non-BT CPs experienced broadly equivalent performance
throughout the year.
LLU SMPF repair
LLU SMPF repair performance was similar for BT CPs and non-BT CPs
throughout the year.
IPstream Connect Provision
100
LLU MPF provision and repair
LLU SMPF migrations
The EAB is satisfied that performance for LLU SMPF migrations has been
broadly equivalent throughout the year.
WES provision and repair
BT publishes KPIs for WES provision and repair. The EAB remains satisfied
that all CPs are experiencing similar performance for both WES provision
and repair. There was a dip in the WES provision performance (as
experienced across several of the Ethernet products) in March 2010 but
this affected all CPs similarly.
BES provision and repair and WEES provision and repair
The performance of very low volume BES and Wholesale End-to-End
Ethernet Services (WEES) as regards both provision and repair was
broadly equivalent for both BT CPs and non-BT CPs for the majority of the
year. Volumes for these products were very low. During March, there was
a dip in provision performance – which appears to have affected
particularly non-BT CPs – and this was under investigation at the time this
report was published.
98
Percentage of orders provided on time
The provision performance for MPF was broadly the same for both BT CPs
and non-BT CPs and there are too few BT CP repairs for MPF to make a
valid comparison.
96
94
92
90
88
86
84
82
80
Apr May Jun
09 09 09
Non-BT CPs
Jul
09
Aug Sep
09 09
Oct
09
Nov Dec
09 09
BT CPs
Jan
10
Feb Mar
10 10
Indicators continued
EAB Annual Report 2010
41
IPstream Connect repair
Wholesale Broadband Connect
The chart below shows that BT Wholesale has achieved a better repair
performance for BT CPs than for non-BT CPs during much of the year. The
main difference can be attributed to BT CPs’ greater use of the
Knowledge Based Diagnostics (KBD) tool – which is available to all CPs –
rather than the legacy ‘one shot check’ tool. The KBD tool undertakes
diagnostic testing and it prompts appropriate questions to be asked when
CPs are in communication with customers. The overall effect is that
genuine faults are more accurately diagnosed and assessed prior to
reporting. Towards the end of the year, increased use of KBD by non-BT
CPs had improved their performance to a level comparable with that of
BT CPs.
A statement by Ofcom in December 2008 led to the removal of EoI
obligations for WBC in Market Three. For most of 2009/10, WBC was only
provided in Market Three and therefore the WBC KPIs were not regulated
and were outside of the scope of this report.
IPstream Connect Repair
Our view on the product KPIs
The EAB is satisfied that the product KPIs for a range of EoI products show
that there are equivalent services on offer for BT CPs and non-BT CPs.
Some EoI products are reaching maturity and the KPI charts reflect the fact
that their performance largely falls within the agreed limits. For those
products where performance falls outside of the limits, this can often be
explained by differences in the orders placed by CPs. The EAB will continue
to monitor trends in this area in the coming year, particularly with the
launch of NGA and new Ethernet products.
100
Comparative Performance Charts
Percentage of faults repaired on time
98
96
In the course of agreeing the OSS variation in 2009, Ofcom reflected
industry concerns that slower progress towards migration to the new EoI
products following changes to the remaining IBMC dates (see p14 for
more information) might have adverse consequences on equivalence in
practice. Accordingly, BT offered to provide Openreach Comparative
Performance Charts (CPCs) to the EAO.
94
92
90
88
86
84
82
80
Apr May Jun
09 09 09
Jul
09
Aug Sep
09 09
Non-BT CPs
Oct
09
Nov Dec
09 09
Jan
10
Feb Mar
10 10
BT CPs
IPstream Connect migrations
Performance for IPstream Connect migrations was similar for non-BT CPs
and BT CPs throughout the year.
The intent of the CPCs is to indicate whether Openreach’s service
performance levels for the EoI and non-EoI product variants
disincentivise the rest of BT from migrating to the EoI product variants.
The CPC reports indicate whether or not BT may be getting better
performance by leaving its installed customer base on the non-EoI (i.e.
‘classic’) product variant rather than migrating them more quickly to the
EoI variant (usually WLR3, but also WLR2 for ISDN2) now that the IBMC
dates have been reset.
42
Indicators continued
EAB Annual Report 2010
Ofcom’s OSS variation statement said:
“Given the consultation responses Openreach will also advise the EAO, at
least quarterly, of the comparative performance stats between EoI and
non-EoI for the main product sets (PSTN, ISDN2, ISDN30, WLR2, and
WLR3) where the IBMC dates have been reset by the variation.
Openreach will report to the EAO on a quarterly basis, from January 2010
at the latest, on key performance metrics comparing EoI and nonEoI/legacy supply. Measures will cover installation times, early life fault
rates, fault repair times and repeat fault rates. The relevant (high-volume)
products covered include WLR Analogue, ISDN2 and ISDN30.
The EAB’s analysis of the CPC metrics from
October 2009 – March 2010
CPC
Analogue provision The performance levels of one metric show that
there appears to be a potential incentive and
another metric shows a potential disincentive for
ensuring all new analogue telephony provisions are
EoI. This ‘mixed’ picture means that it is unlikely
therefore to have a significant impact on BT’s
behaviour.
Analogue repair
The performance levels show that there appears to
be a potential incentive regarding repeat faults and
a potential disincentive from an overall repair
performance perspective to encourage BT to
migrate to an analogue EoI product. This ‘mixed’
picture means that it is unlikely for there to be a
significant impact on BT’s behaviour.
ISDN2 provision
ISDN2 provision is more complex than analogue
telephony. This is because BT first moved to a
tactical EoI service using a WLR2 variant which is still
in operation. It then migrated to a strategic WLR3
EoI variant. Low volumes also have an impact on
determining a trend. That said, the performance
levels show that there appears to be no clear
disincentive for migration to either EoI version.
ISDN2 repair
There is a potential incentive and a potential
disincentive regarding repair performance to
ensuring all ISDN2 circuits are migrated to EoI
systems. Once again, the volumes are very low and
a clear trend is not visible at this stage of reporting.
This ‘mixed’ picture means that it is unlikely for
there to be a significant impact on BT’s behaviour.
ISDN30 provision
There is a potential incentive and a potential
disincentive to ensuring all ISDN30 provisions for all
end users are processed on EoI systems. Once
again, the transaction volumes are very low, with
little or none for the classic BT product. This ‘mixed’
picture means that it is unlikely for there to be a
significant impact on BT’s behaviour.
ISDN30 repair
There is a potential incentive and a potential
disincentive to ensuring all ISDN30 products are
migrated to the EoI variant and thus supported by
the new systems. This ‘mixed’ picture means that it
is unlikely for there to be a significant impact on
BT’s behaviour.
We consider that this will place pressure on Openreach to deliver broadly
equivalent performance to CPs and those BT downstream customers
depending on non-EoI inputs. This additional reporting and monitoring
has been agreed between BT and us subsequent to comments made in
responses to the consultation.”
The CPCs provided to the EAO since October 2009 are not necessarily
comparing ‘like-for-like’ products and it is still early to form firm
conclusions. Some categories shown on the charts may comprise only a
small number or only one CP and hence expose commercially confidential
information. As a result, BT and Ofcom have agreed that the charts should
not be published. However, Ofcom and BT have asked the EAB to publish
its opinions on the charts.
It is also important to note that the CPCs do not perform the same
function as the EoI product equivalence KPIs shown on the previous page
and they should be viewed independently as both the subject matter and
the statistical approach are different.
Two metrics are examined for both the provision and the repair processes
for each of the products:
Provision:
1. Time to install (in working days)
2. The percentage of provisions suffering early life failures.
Repair:
1. Time to clear the fault (in working hours)
2. The percentage of repairs requiring a repeat repair to clear.
To draw a conclusion, the EAB reviews both metrics to assess whether BT
would benefit by remaining on the non-EoI product variant. In the case
of a ‘mixed picture’ where one metric is an incentive and one metric is a
disincentive, the EAB assumes that it is unlikely to have a significant
impact on BT’s behaviour.
Commentary
Indicators continued
The EAB found no obvious examples of there being a clear and consistent
disincentive across all of the metrics of a particular product to cause BT to
delay moving to EoI products and systems. In most of the cases, there was
a mixed picture. For example, the EoI product would perform better in
one metric but worse in the other metric. In some cases the CPCs indicate
there will be a benefit in a particular metric of a product; but in all cases
this is offset by a disadvantage in another metric.
On this basis, the EAB can provide some reassurance that the metrics
indicate that BT is not gaining a clear advantage compared to non-BT CPs
by remaining on non-EoI products and systems longer than originally
planned.
In addition, BT’s progress towards the delivery of its remaining
Undertakings obligations for current generation products and systems
would also support the CPCs in showing that BT is not gaining an
advantage by remaining on non-EoI products.
The systems variation agreed in September 2009 set out targets relating
to separation of BT’s systems. In relation to the movement of customer
records to separate systems, BT believes that it has now reached its 80%
target – which is required by 30 June 2010 – although this is subject to
EAB validation.
In relation to the migration of its customer base to equivalent products,
BT reported that by 31 March 2010, 90% of its residential customers
were now served on an equivalent basis, which included the migration of
over 12m consumer customers. The EAB was validating this assertion at
the time this report was published.
EAB Annual Report 2010
43
EAB Annual Report 2010
44
Undertakings status indicators
Monitoring the delivery of major EoI products
The EAB monitors the delivery of major EoI products covered by the Undertakings. Many of those with set delivery dates have been delivered in
previous years and the remaining WLR3 obligations were removed in 2009/10. The EAB monitors the delivery of NGN and NGA products to ensure that
they are launched on an EoI basis, even though these do not have set launch dates in the Undertakings.
Key
Achieved
Not achieved by due date
Concerns
On track
Removed
Replaced
IPstream
Undertaking
Date due
IPstream EoI RFS
31 Dec 2005
Relevant Broadband service using EoI IPstream/IBMC
31 Dec 2006
Milestone Status
Comments
Milestone Status
Comments
LLU
Undertaking
Date due
LLU EoI RFS
30 June 2006
Non-trivial breach; BT paid allowances to CPs. The EAB
confirmed that the breach was remedied
in December 2006.
IPstream using EoI LLU IBMC
31 Dec 2006
Non-trivial breach; BT completed delivery end of August
2007.
Ethernet
Undertaking
Date due
WES, BES, WES Backhaul and WEES EoI RFS
30 Sept 2006
Relevant Retail Ethernet Service using EoI WES IBMC
31 Mar 2007
Milestone Status
Comments
Milestone Status
Comments
WLR3 Analogue
Undertaking
Date due
WLR Analogue EoI RFS (informal milestone)
31 Dec 2006
WLR Analogue EoI RFS
30 June 2007
WLR Analogue IBMC 30% target
30 June 2008
Milestone reached November 2008.
WLR Analogue IBMC 70% target
30 June 2009
Milestone reached September 2009.
WLR Analogue IBMC 100%
30 June 2010
Revised obligation included in OSS variation.
BT paid allowances to CPs.
WLR3 ISDN2
Undertaking
Date due
Milestone Status
Comments
WLR ISDN2 EoI RFS
30 Sep 2007
Trivial breach regarding some new end-user orders.
BT’s Retail ISDN2 using EoI WLR ISDN2 IBMC
31 Mar 2009
Non-trivial breach; revised obligation included in OSS
variation.
Undetakings status indicators continued
EAB Annual Report 2010
45
WLR3 ISDN30
Undertaking
Date due
Milestone Status
WLR ISDN30 EoI RFS
28 Feb 2008
(was 31 Dec 2007)
BT’s Retail ISDN30 Service using EoI WLR
ISDN30 IBMC
31 Dec 2009
Comments
Revised obligation included in OSS variation.
IPstream Connect
Undertaking
Date due
Milestone Status
Comments
IPstream Connect available for order; start of BT and
CP end-user base migration
31 Oct 2008
Achieved ahead of schedule.
IPsream Connect IBMC and migration of CP
end-user base
31 Mar 2009
Achieved ahead of schedule.
GEA
Undertaking
Date due
Milestone Status
Comments
GEA over FTTP
Not applicable
Not applicable
Launch review completed by EAB.
GEA over FTTC
Not applicable
Not applicable
Pre-launch review completed by EAB.
Systems separation obligations
The EAB monitors the delivery of systems separation through either full physical separation of systems, or through the implementation of user access
controls. During 2009/10 there was a variation to the Undertakings that resulted in changes to the delivery dates for systems separation.
OSS separation – User access controls and Physical Separation
Undertaking
Date due
User Access Controls for WLR3, SMPF, MPF and ISDN2 30 June 2007
Milestone Status
Comments
Mostly delivered by the required date, but only fully met
in late September 2007 due to a trivial breach.
Independent external audit of User Access Controls
including ISDN2 and ISDN30
30 June 2008
Implement physically separate OSS for WLR
manual exception tasks
31 May 2009
Non trivial breach; milestone removed by OSS variation.
Additional audit of User Access Controls
30 June 2010
Achieved early.
Implement User Access Controls for OSS listed
in Annex 6
30 June 2010
Implement physically separate access and user
access controls for BT people not listed in 5.44.6 (a)
30 June 2010
OSS physical separation
30 June 2010
EAB to perform quarterly checks of access to OSS
listed in Annex 6 starting in June 2010
From June
2010 onwards
Implementation and ongoing application of the
obligations in relation to Customer Side Records
is subject to an audit commissioned by the EAB
on an ongoing basis at least every 24 months
from 30 June 2010
30 June 2012
(latest)
Milestone removed as part of OSS variation; BT now has
to deliver physical separation when “reasonably practical
and proportionate”.
46
Undetakings status indicators continued
EAB Annual Report 2010
Migration to EoI products
Undertaking
Date due
Milestone Status
At least 90% of BT’s relevant installed End-User base 30 June 2010
shall be migrated so that the products that this base
purchases, that consume the Measured Products,
do so on an EoI basis from Access Services (Openreach)
BT to advise Ofcom of the further increased
percentage migrations of both the relevant installed
End-User base and BT’s Customer Side Records to
be achieved by the 30 June 2014
Comments
In March 2010, BT reported that it had
migrated 89% of its end-user base, subject
to EAB validation.
31 Dec 2011
(latest) or
6 months
after completion
of business stack
migration (if earlier)
At least 95% of BT’s relevant installed End-User
31 Dec 2012
base shall be migrated so that the products that this
base purchases, that consume the Measured Products,
do so on an EoI basis from Access Services
BT to achieve further increased percentage migrations 30 June 2014
previously notified to Ofcom by 31 Dec 2011
Customer records migration
Undertaking
Date due
Ready to mass migrate PSTN customer side records
31 March 2008
50% of relevant customer side records migrated to
physically separate OSS
30 Nov 2008
50% of non-WLR supply side records migrated to
physically separate OSS
31 Jan 2010
Non trivial breach; milestone removed by OSS variation.
Ready to mass migrate customer side records relating
to Featureline
30 June 2009
Non trivial breach; revised obligation included in OSS
variation.
90% of relevant customer side records migrated to
physically separate OSS
30 Sept 2009
Revised obligation included in OSS variation.
90% of non-WLR supply side records migrated to
physically separate OSS
31 Jan 2010
Removed by OSS variation.
90% of users migrated to physically separate OSS for
WLR manual exception tasks
31 March 2010
Removed by OSS variation.
At least 80% of BT’s Customer Side Records relating to 30 June 2010
the Measured Products held on Operational Support
Systems shared between Access Services and the rest of
BT are migrated to at least Level 2 System Separation
BT to advise Ofcom of the further increased
percentage migrations of both the relevant
installed End-User base and BT’s Customer Side
Records to be achieved by the 30 June 2014
31 Dec 2011
(latest) or
6 months
after completion
of business
stack migration
(if earlier)
At least 90% of BT’s Customer Side Records relating to 31 Dec 2012
the Measured Products held on Operational Support
Systems shared between Access Services and the rest of
BT are migrated to at least Level 2 System Separation
BT to achieve further increased percentage
30 June 2014
migrations previously notified to Ofcom by 31 Dec 2011
Milestone Status
Comments
In March 2010, BT reported that it had delivered this
obligation, subject to EAB validation.
Undetakings status indicators continued
EAB Annual Report 2010
47
UK Business Stack implementation (non-binding milestones)
Undertaking
Date due
Milestone Status
Comments
Business Stack – Operational Trial Starts
30 April 2010
The EAB was validating BT’s delivery of this obligation
at the time this report was published.
Business Stack – Initial Live Deployment
31 Dec 2010
Rescheduling of external trial from April 2010 to
September 2010 means little or no contingency to
accommodate further delays.
Business Stack – Trial Migration Begun
31 March 2011
Business Stack – Volume Migration Begun
31 Dec 2011
Management Information Systems separation
Undertaking
Date due
MIS separation
22 Oct 2006
MIS roadmap
30 June 2007
MIS Level 2 separation
30 June 2010
Milestone Status
Comments
Includes Level 1 separation for Annex 5 systems and
Level 2 separation for others.
BT and Ofcom reached agreement on the Aspire system
on 5 March 2010.
Exemptions and variations
Undertaking
Date due
Overlong SHDS circuits
28 Sept 2008
Redcare Fire and Security IBMC
30 June 2009
Wavestream National RFS
31 Dec 2010
Milestone Status
Comments
Project complexity means risk of non-delivery.
48
EAB Annual Report 2010
Independent Assurance Report
to the Equality of Access Board
and Ofcom
Respective responsibilities of the Equality of Access Board and
PricewaterhouseCoopers LLP
We have been engaged to express an independent opinion on selected
aspects of the Equality of Access Board (“EAB”) Annual Report for the
year ended 31 March 2010 (the “Report”). The preparation of the Report
in accordance with the requirements of the Undertakings given to Ofcom
by BT Group plc (“BT” or the “Group”) pursuant to the Enterprise Act
2002 effective 22 September 2005 (the “Undertakings”) is the sole
responsibility of the EAB.
There are no generally accepted standards for reporting on compliance
with the Undertakings or in respect of related performance measures. The
reporting policies adopted by the EAB in forming their opinions expressed
within the Report are described in the sections entitled “Monitoring
Reporting and Advising” on pages 5, 6 and, “How we formed our
opinion” on pages 7 and 11 (the “Reporting Policy”).
Scope and approach
Our engagement was designed to provide assurance on:
• whether, in our opinion, the EAB’s opinions in respect of:
– its governance arrangements;
– BT’s governance framework associated with the Undertakings;
– BT’s delivery of the Undertakings during the year ended 31 March
2010 comprising the EAB’s opinions in respect of Current
Generation Products and Systems, Next Generation Access, Next
Generation Networks, Key Monitoring Themes and Noncompliance; and
– the future risks associated with the Undertakings after 31 March
2010;
are fairly stated in accordance with the Reporting Policy. These
opinions, indicated by the
symbol, are shown on pages 7, 11, 17,
21, 24, 32, 35 and 36 of the Report (the “EAB’s Opinions”).
In this regard, we planned our procedures to have a reasonable
expectation of detecting material misstatements or omissions in the
EAB’s Opinions. We obtained an understanding of the relevant
controls and procedures applied by the EAB and the Equality of Access
Office (“EAO”) to generate, aggregate and evaluate information in
respect of the Group’s governance, delivery and ongoing compliance
with the Undertakings, including the EAO monitoring and reporting,
the audit and validation plan, the quick checks, the exemptions and
variations and the breaches and complaints processes. We performed
tests of these controls and procedures and reviewed the work
undertaken by BT’s Internal Audit team on behalf of the EAB
including, to the extent considered necessary, review of detailed
workpapers and re-performance of testing;
• whether, in our opinion, the Product Key Performance Indicators for
WLR3 Analogue – Basic Provision, WLR3 Analogue Repair, WLR3
ISDN2 (EoI Tactical) Repair, WLR3 ISDN30 Provision, IPstream
Connect Provision and IPstream Connect Repair indicated by the
symbol on pages 38 to 41 are properly prepared in accordance with
the Reporting Policy. In this regard, we planned our procedures to
provide us with reasonable assurance they are properly prepared in
accordance with the Reporting Policy. We completed, in conjunction
with BT’s Internal Audit team, tests over data generation within the
underlying management information systems of the group, data
consolidation and reporting.
In addition, we reviewed the minutes of EAB meetings, discussed with
employees of the Equality of Access Office the processes to collate the
Report and reviewed the remainder of the Report for consistency with
our knowledge of the Group in order to report whether anything came to
our attention to indicate that the remainder of the Report is inconsistent
with the findings of our work.
Our engagement includes the expression of an opinion on the fairness of
the EAB’s opinions in respect of BT’s governance associated with the
Undertakings, BT’s delivery of the Undertakings during the year ended
31 March 2010 and future risks associated with the Undertakings due
after 31 March 2010. Our assurance procedures, which are described
above, focus on understanding and evaluating the relevant controls and
procedures applied by the EAB and the EAO to generate, aggregate and
evaluate information in respect of the Group’s governance and
compliance with the Undertakings. We have not been engaged to
provide any separate independent assurance over the internal controls
and other actions implemented by the Group to ensure compliance with
the Undertakings. Accordingly we do not express an opinion in this
regard.
We planned and performed our evidence-gathering procedures to obtain
a basis for our conclusions in accordance with the International Standard
on Assurance Engagements 3000 (Revised) – “Assurance Engagements
other than Audits or Reviews of Historical Information”. We have not
performed an audit, and therefore do not express an audit opinion, in
accordance with International Standards on Auditing (UK and Ireland).
We believe that our work provides a reasonable basis for our conclusions.
Considerations and limitations
The Group’s governance measures to ensure compliance with the
Undertakings represent a set of internal controls and other actions
designed to provide reasonable assurance regarding compliance, in all
material respects, with each of the Undertakings and to support reporting
of compliance with those Undertakings. Further, the EAB’s governance
measures to monitor, assess and report on the Group’s compliance with
the Undertakings represent a set of internal controls and other actions
Independent Assurance Report to the Equality of Access Board and Ofcom continued
designed to provide reasonable assurance regarding the assessment of
compliance, in all material respects, with each of the Undertakings.
Because of the inherent limitations in any set of internal controls, for
example the degree of judgement required in applying certain controls,
internal controls may not prevent, detect or report non-compliance with
the Undertakings. Also, projections of any evaluation of effectiveness to
future periods are subject to the risk that controls may have become
inadequate because of changes in conditions, or that the degree of
compliance with the policies or procedures may deteriorate.
This report, including the conclusion, has been prepared for and only for
the EAB and Ofcom for the purpose of allowing the EAB to meet its
requirements under the Undertakings and for no other purpose. We do
not, in giving this opinion, accept or assume responsibility for any other
purpose or to any other person to whom this report is shown or into
whose hands it may come save where expressly agreed by our prior
consent in writing.
Conclusions
In our opinion:
• the EAB’s Opinions, indicated by the
symbol, on pages 7, 11, 17,
21, 24, 32, 35 and 36 of the Report are fairly stated in accordance
with the Reporting Policy;
• the Product Key Performance Indicators for WLR3 Analogue – Basic
Provision, WLR3 Analogue Repair, WLR3 ISDN2 (EoI Tactical) Repair,
WLR3 ISDN30 Provision, IPStream Connect Provision and IPStream
Connect Repair indicated by the
symbol on pages 38 to 41 are
properly prepared in accordance with the Reporting Policy; and
• nothing has come to our attention to indicate that the remainder of
the EAB Annual Report for the year ended 31 March 2010 is
inconsistent with the findings of our work.
PricewaterhouseCoopers LLP
Chartered Accountants
London
14 May 2010
EAB Annual Report 2010
49
50
EAB Annual Report 2010
Glossary
21CN
BT’s 21st Century Network programme
Active remedies
Next Generation Access products with most of the network functionality offered by Openreach
Annex 2
Restrictions applied to BT employees working in some functions related to the Undertakings
BES
Backhaul Extension Service, a product in the Ethernet portfolio
BT CPs
BT Wholesale and BT’s two downstream businesses BT Global Services and BT Retail
BTID
BT Innovate and Design
Business stack
A collection of inter-related systems which allow BT’s business customers to be served
CMM
Contract Management Mechanism
Consult 21
BT’s 21st Century Network programme consultation group
CoP
Code of Practice
CPs
Communications Providers
CPCs
Comparative Performance Charts
Direct Controlled ATA
Analogue Telephone Adapter product which allows CPs to install their own call server equipment on Openreach’s NGA
network
EAB
Equality of Access Board
EAD
Ethernet Access Direct, a point-to-point access product in the Ethernet portfolio offering high bandwidth
connectivity, linking end user sites, CP networks and BT exchanges.
EAO
Equality of Access Office
EBD
Ethernet Backhaul Direct, a product in the Ethernet product portfolio
EMP
Equivalence Management Platform
EoI
Equivalence of Inputs, which means that BT provides the same product or service to all CPs on the same timescales,
terms and conditions by means of the same systems and processes
FIRS
Fibre Integrated Reception System
FTTC
Fibre-to-the-Cabinet, an NGA technology that involves installing fibre to street cabinets and using the existing copper
infrastructure into the home
FTTP
Fibre-to-the-Premises, an NGA technology
GEA
Generic Ethernet Access, a product enabling broadband connections over Next Generation Access
IBMC
Installed Base Migration Complete, which is the date by which the migration of all of the relevant BT installed customer
base to the EoI product is completed
IPstream Connect
Product supplied by BT Wholesale to enable BT CPs and non-BT CPs to offer broadband services to end users
ISDN
Integrated Services Digital Network
KPI
Key performance indicator
LLU
Local Loop Unbundling, a product which enables non-BT CPs to lease the local loop infrastructure from Openreach to
offer telephony and broadband services to end users
Market One
Areas in which BT is the only operator
Market Two
Areas where there are two or three operators (including BT)
Market Three
Areas where there are four or more operators
MSAN
Multi-Service Access Nodes, which channel converged voice and broadband services on BT’s 21CN
MIS
Management Information Systems
NGA
Next Generation Access
NGN
Next Generation Network
Non-BT CPs
Communications Providers external to BT
Open ATA
See Direct Controlled ATA
OSS
Operational Support Systems
OTA2
Office of the Telecommunications Adjudicator
Passive remedies
Products that allow greater access to the underlying infrastructure on BT’s Next Generation Access network
Glossary continued
EAB Annual Report 2010
PwC
PricewaterhouseCoopers LLP
RFS
Ready for Service, which is the date by which an EoI product or service is available for use by other CPs for their new
51
end-users
SLA
Service Level Agreement
SLU
Sub-loop Unbundling, which involves unbundling the copper from the end-users’ premises to the street cabinet
(rather than all the way to the exchange)
SMP
Significant Market Power
SoR
Statement of Requirements, the process by which CPs submit their product requirements to BT
VoNGA
Voice over Next Generation Access, a product being developed by Openreach which involves CPs using an Openreach
VULA
Virtual Unbundled Local Access
call server to offer services to their own customers
Wavestream National Wideband fibre-based service between sites up to 70km apart
WES
Wholesale Extension Service, a product in the Ethernet portfolio
Wires-only
potential future product which would enable CPs to terminate fibre networks in customers’ homes
WLR
Wholesale Line Rental, a product supplied by Openreach which is used by CPs to offer their own-branded telephony
and narrowband services to customers
WLR3
An EoI version of Wholesale Line Rental
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Registered Office: 81 Newgate Street, London EC1A 7AJ
Registered in England and Wales No: 4190816
Produced by the Equality of Access Office