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EAB Overview: August 2016

EAB’s July 2016 meeting

The EAB met in July and had presentations from BT and Openreach, as well as the Office of the Telecommunications Adjudicator 2 (OTA2).

Presentations

Rod Smith and David Halliday of the OTA2 shared with us their views on the current performance of Openreach, particularly for Ethernet. We discussed with them Openreach’s Statement of Requirements (SOR) process and where they thought it could be changed, and sought their view on Openreach’s launch of the Generic Ethernet Access (GEA) 55/10Mb and GEA 8/2Mb products, currently the subject of an EAO investigation. We endorsed the EAO’s plans to work with the OTA2 to do a joint review of Openreach Key Performance Indicators (KPIs), and noted that it would be valuable if KPIs could be developed which identified the root cause of issues. The EAO reported that Openreach’s ‘Missed Appointments’ would be the first KPI piloted, and we will receive a report on the results of this in our October meeting, as well as plans for more KPIs to be reviewed.

Gavin Patterson, BT CEO, Clive Selley, Openreach CEO, and Stef Norman, Openreach’s Director of Business Integrity, presented on Ethernet, updating us on Openreach’s progress in reducing the ‘tail’ of old Ethernet orders, and changes Clive had made to improve Ethernet performance going forward. We asked Clive to provide us with additional detail on Openreach’s network spend and capex. Jon Hurry joined the meeting to answer our questions on the launch of the GEA 55/10Mb and GEA 18/2Mb products, specifically around the speed of launch and content of bilateral meetings held with CPs prior to launch. We have asked the EAO to look into some additional questions before concluding its investigation into these launches, and will provide an update in our next bulletin.

Delivery of systems milestones

We reviewed with BT its progress on delivering the Equivalence of Inputs (EoI) and Customer Side Record (CSR) migrations. BT reported that it believed it was on track to achieve its internal forecasts of 99.8% EoI migration and 98.4% CSR migration by April 2017, and that ISDN30 CSRs were not being migrated separately from other CSRs and therefore would not be fully migrated in the current financial year. We expressed our disappointment that this was not in line with the migration expectation set on ISDN30 in BT’s July 2015 letter to Ofcom. We asked BT to review the commitments in that letter before presenting to us again.

Complaint

We have reported previously on the formal complaint received from Vodafone, alleging that BT’s Customer First programme had allowed BT CPs to influence Openreach’s actions and developments in a way that was not open to other CPs. We reviewed the EAO’s investigations to date, which have been extensive due to the wide-ranging nature of the Customer First programme. We decided that - while we thought it unlikely evidence would be found to uphold the specific allegation made in the complaint – the EAO should investigate further the process used to assess potential changes to products within Openreach’s Service Based Solutions (SBS) portfolio before we conclude on the complaint. We will provide a final report in our next bulletin.

EE integration

We reviewed with BT its progress on compliantly integrating EE, including the implementation of a substantive Undertakings training programme. We noted that one part of the integration had been delayed, to ensure it was done compliantly and system access to BT Wholesale Customer Confidential Information (CCI) remained appropriately restricted.

Breaches

There were three breaches on which we concluded at our July meeting:

 

Description

Status

Remedy

Failure to ensure migration processes were equivalent for a non-BT CP who wanted to transfer Classic lines to WLR3

Non-Trivial

Openreach is issuing briefings to the agents who handle these orders manually and is also addressing system problems which contributed to the migration issues. The EAB has requested a report from Openreach on the remedial actions at its next meeting.

Inappropriate sharing of BT Wholesale CCI when a slidepack was circulated to BT Business employees

Trivial

The email was recalled and all parties deleted the content.

Failure to supply a product on an equivalent basis due to BT Wholesale employees having access to a system containing Openreach civil engineering updates which were not available to other CPs

Trivial

Access has been removed and the authorisation process tightened. Relevant teams have been re-briefed.

We also requested more information about ‘win back’ orders. This was as a result of a case which had been investigated and found not to be a breach, but which had identified that orders BT had ‘won back’ from other CPs could sometimes be placed on legacy systems rather than equivalent systems.

EAB activities

We noted the results of a recent strategy day during which we reviewed our current activities to ensure we were continuing to fulfil our role to monitor, report and advise BT on its compliance with the Undertakings. We decided that we would focus on Openreach SORs and KPIs over the course of this year, and asked Openreach and the EAO to provide more information on the SOR process and current SORs at our October meeting. . We have now seen Ofcom’s draft DCR proposals, which include the replacement of the EAB by a sub-committee of the proposed Openreach Board. We are clear that our current initiatives, such as the KPI review, remain of benefit to industry and we will pursue these. We are committed to continuing our role with rigour whilst the current arrangements are in place.

Following publication of our 2016 Annual Report, we have sought feedback on the report and our own activities through a number of industry interviews. While results were largely positive, with favourable comments on the clarity and content of the Annual Report in particular, we have concluded that our services and materials need greater promotion and will be reviewing this over the next quarter.

Product Key Performance Indicators (KPIs)

BT published KPIs showing the output performance of its regulated wholesale products. The KPI charts for each product portfolio compare service performance for BT’s business units to that for other CPs.

Glossary

CCI - Customer Confidential Information, a term defined in the Undertakings
CSR - Customer Side Record, defined in the Undertakings as a Customer Service Record relating to BT as a purchaser from Openreach
DCR - Digital Communications Review, Ofcom’s strategic review of the communications market
EAB – Equality of Access Board
EAO - Equality of Access Office
EoI - Equivalence of Inputs, defined in the Undertakings to mean that BT provides the same product or service to all Communications Providers on the same timescales, terms and conditions by means of the same systems and processes
GEA - Generic Ethernet Access, an Openreach product
KPIs - Key Performance Indicators
OTA2 - Office of the Telecommunications Adjudicator 2
SOR - Statement of Requirements, the process set out in the Undertakings for a Communications Provider to submit a request to BT for new or enhanced Network Access
WLR3 - Wholesale Line Rental 3, the EoI version of BT’s legacy product, Classic