BEREC – Examining EoI
Jon Furmston,
Director Equality of Access Office
What is EoI?
EoI in Practice
QoS
Requirements
Information
Requirements
System
Requirements
Compliance
Regime
Taking each decision tree question in turn…
Costs/Benefits
What is EoI?
EoI in Practice
QoS
Requirements
Information
Requirements
System
Requirements
Compliance
Regime
Costs/Benefits
My view from UK experience (not a theoretical regulatory perspective)
and each country is unique…
Terminology
•
•
•
•
•
Openreach – functionally separate EoI division
BT Retail / BT Global Services – downstream retailing divisions
Undertakings – the formal ‘contract’ agreement between BT and Ofcom
Equality of Access Board (EAB) – independent oversight of the Undertakings
Communication Providers (CPs) = altnets
Timeline
•
•
•
•
Undertakings signed September 2005
Openreach created January 2006
All legally binding milestones now complete
Systems roadmap is the only deliverable not (quite) finished
• 97% of lines are now EoI and 92% of customers records are on
separated systems
What is EoI?
EoI in Practice
QoS
Requirements
Information
Requirements
System
Requirements
Compliance
Regime
Costs/Benefits
EoI is the heart of the UK model, and is more effectively delivered
because it is part of a wider set of measures
• Undertakings Definition
–
EOI means that BT provides the same product or service to all Communications Providers (including
BT) on the same timescales, terms and conditions (including price and service levels) by means of
the same systems and processes, and includes the provision to all Communications Providers
(including BT) of the same Commercial Information about such products, services, systems and
processes. In particular, it includes the use by BT of such systems and processes in the same way
as other Communications Providers and with the same degree of reliability and performance as
experienced by other Communications Providers.
–
In this context “the same” means exactly the same subject only to trivial differences, specific items (eg credit vetting and payment
procedures) or as agreed by Ofcom in writing.
• Does EoI Guarantee EOO?
– CPs will combine with differing add-ons to intentionally differentiate
– SMPF/MPF: differing business models
• How tightly is EoI related to Functional Separation?
– EoI is most effective when delivered with a functional separation wrap (e.g. separate
assets, systems, information, brand, incentives)
– The boundaries of the separated organisation help define the EoI boundaries and assure
equivalent service delivery
What is EoI?
EoI in Practice
QoS
Requirements
Information
Requirements
System
Requirements
Compliance
Regime
Costs/Benefits
Price & Conditions are easy to align - other remedies can deliver that.
Service equivalence requires systems and processes and that is hard.
• Which Products
– All Access Network-based products (where BT has SMP)
– LLU, WLR, Ethernet, Fibre based Broadband
– Only one EoI point in the value chain (the Openreach boundary)
• What makes a product EoI-compliant?
– A common front end ordering/fault system for all CPs
– Engineers behaviour in front of customers
– And the commercials (but that is relatively easy)
• How to handle new product requests?
– Statement of Requirement process to transparently receive, process and deliver
or reject all requests
What is EoI?
EoI in Practice
QoS
Requirements
System
Requirements
Information
Requirements
Compliance
Regime
Costs/Benefits
QoS requirements are not needed for EoI to work but…
EoI does not guarantee a standard of QoS
Absolute service levels are outside the remit of the Undertakings.
The Undertakings only require that the same level of service is provided to external CPs
as is provided to BT CPs (as measured by KPI charts). This could be good or bad levels
of service.
LLU Repair - SMPF Service Level 2
% faults completed in objective time
Pooled-test score
LLU Repair
10
h External CPs better
0
i BT better
100
90
80
70
60
50
-10
Mar 12 Apr 12 May 12 Jun 12 Jul 12 Aug 12 Sep 12 Oct 12 Nov 12 Dec 12 Jan 13 Feb 13
SMPF_Service Level 2
Mar 12 Apr 12 May 12 Jun 12 Jul 12 Aug 12 Sep 12 Oct 12 Nov 12 Dec 12 Jan 13 Feb 13
Extl CPs
BT
QoS and EoI
In theory, Openreach poor service levels experienced by BT Retail, will make BT Group
CEO exert pressure on Openreach to raise levels, that all CPs will benefit from. In
practice it is not always as straightforward as that!
And in times of bad service the number of questions by CPs about equivalence goes up.
What is EoI?
EoI in Practice
QoS
Requirements
Information
Requirements
System
Requirements
Compliance
Regime
Costs/Benefits
Information restrictions are essential for there to be trust
in the EoI system
• Two types of restricted information
– Openreach Commercial Information (e.g. product launch dates/price
changes/network build out) must only be shared on an equivalent basis
 Openreach monthly commercial working groups and web/email vehicles help with
equivalent communication
– Openreach Customer Confidential Information (e.g. individual order details a CP
has submitted or forecast volumes) must not be shared with any other CPs
including BT CPs
 Only allowing BT CPs system access into Openreach that external CPs use, ensures
that BT CPs does not have ‘special’ access to CCI data
• Information is shared by systems and/or people
 Stopping employees sharing inappropriate information via emails / collaboration tools
requires training, reinforced behaviours and continual vigilance.
What is EoI?
EoI in Practice
QoS
Requirements
Information
Requirements
System
Requirements
Compliance
Regime
Costs/Benefits
System Separation is essential but costly, lengthy and complex
It does not have to be physical separation
• Separation is essential component, the question is, “what degree of
separation?”
 Logical should be sufficient (hence cloud computing can work).
 The focus should be on administering the staff access rights
• BT CPs moved to using the existing Altnet Openreach platform
 “Instant” EoI with costs born primarily by BT
What is EoI?
EoI in Practice
QoS
Requirements
Information
Requirements
System
Requirements
Compliance
Regime
Costs/Benefits
Faith in the EoI system is essential and this is delivered (in part)
by a full and transparent compliance regime
• Compliance takes place at four levels
1. Individuals trained and systems/processes
designed to encourage equivalent behaviour
2. BT/Openreach compliance teams
3. EAB: Independent oversight sitting within BT but
having 4 out of 5 independent members (and
audited by PwC)
4. External NRA oversight (if and when required)
• To demonstrate compliance:
 Significant reporting and meeting with CPs
 Product EoI KPIs help
• CPs can’t easily check EoI themselves
– they only ever see one input (their own)!
% faults completed in objective time
 Formal and Informal Complaint handling
LLU Repair - SMPF Service Level 2
100
90
80
70
60
50
Mar 12 Apr 12 May 12 Jun 12 Jul 12 Aug 12 Sep 12 Oct 12 Nov 12 Dec 12 Jan 13 Feb 13
Extl CPs
BT
What is EoI?
EoI in Practice
QoS
Requirements
Information
Requirements
System
Requirements
Compliance
Regime
Costs/Benefits
Systems cost BT much more than was expected, but there have
significant benefits, making the UK one of the most competitive markets
• System separation and changes were the most costly (and disruptive to
end users) element
– But EoI without all CPs using a common system is a weak EoI
• And finally and most importantly…EoI only works if it is trusted.
– Put significant effort into ensuring trust can be fostered otherwise all the
systems costs and hard work of EoI are a complete waste!