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EAB Overview

3 March 2008

Undertakings delivery update

OSS separation (30 June 2007)

The EAB has completed its validation of BT’s delivery of the first stage of Operational Support Systems (OSS) separation (User Access Controls) at 30 June 2007. The validation covered OSS access controls for Metallic Path Facility (MPF), Shared Metallic Path Facility (SMPF) and Wholesale Line Rental (WLR) and included sample testing of the user access controls. Based on this sample the EAB raised concerns with BT that access controls for one of the twenty relevant systems had not been adequately applied. This was because some users had inappropriate access to a search engine for almost three months after the milestone date.

BT investigated these concerns further and notified the EAB of a trivial breach of the Undertakings. As required by Ofcom the milestone is also the subject of an external audit currently in progress by PwC. The audit includes testing of the user access controls of all 20 systems in scope of the changes and the findings will be reported by June 2008.

The EAB has confirmed that this was a trivial breach of the Undertakings and considered that although BT delivered the majority of this milestone by the required date of 30 June 2007, it only met the milestone in full in late September 2007 when the breach was remedied. That aside, the rest of the systems tested appeared to have satisfactory controls in what was a large and complex systems development programme undertaken by BT.

21CN validations

The EAB has validated the delivery of the first two products in BT’s 21^st Century Network (21CN) programme. Although not strictly a 21CN network access product, the EAB monitored the delivery of NGN Virtual Interconnect Circuit product (VIC) as a trial run ahead of the forthcoming NGN product validations. It found that BT had met the necessary requirements for delivery of this product, although the EAB made some minor recommendations to BT regarding aspects of the product. The EAB validated that a second NGN product, NGN Openreach Network Backhaul Services (ONBS) was delivered compliantly by BT. ONBS was launched on 9 October 2006 to support the start of the ‘Pathfinder’ trial in the Cardiff area.

WLR ISDN2 RFS (30 September 2007)

The EAB’s validation of WLR ISDN2 Ready for Service (RFS) is still ongoing. To date, the EAB’s validation has identified three concerns which are being investigated further.

WLR ISDN30 RFS (29 February 2008)

The EAB believes that there are increased risks that BT will not meet the RFS date for WLR ISDN30. BT is aware that the deadline is at risk and has told the EAB that it is dedicating resources to the issue.

WLR IBMC interim milestone (30) June 2008

The EAB heard from Ian Livingston, BT Retail's CEO, about BT Retail's approach to the migration of its existing customers to WLR3. Ian described how this process had begun and that he expected the pace of migration to increase as operational learning gave confidence that the customer experience could be maintained during and after migration. Ian was confident that BT Retail would complete migrations by the Undertakings deadline. The EAB notes that the process of migration has begun and welcomed the reassurance that the end date will be met but that the initial interim target of 30% migration by 30 June 2008 is at high risk depending on operational performance.

Exemptions to the Undertakings

The EAB has completed validations of a series of amended delivery deadlines following exemptions to the Undertakings. No issues were found in relation to BT’s delivery of Low Loss Exchange Lines IBMC, ISDN Connect IBMC and agreement with Ofcom on a list of overlong SHDS circuits.

Breaches

The EAB has been notified of four new breaches of the Undertakings. One of these was classified by the EAB as non-trivial and the remainder as trivial. The EAB also validated that remedial action was put in place for two previously reported breaches. See below for a fuller description:

Non-trivial breach

The EAB Overview on 13 August 2007 reported that the EAB had been notified of a breach concerning the delivery of the Openreach Special Faults Investigation (SFI) product. The SFI product enables CPs to have an extensive range of tests undertaken on the Openreach access network and at the end customer’s premises to resolve broadband faults. BT reported to the EAB that two aspects of this product did not comply with the Equivalence of Input (EoI) requirements.

The EAO investigated the non-compliant aspects and found that the design of the SFI product had failed to encompass fully the EoI requirements even though it had been launched months after Openreach’s establishment. The EAB considered this to be a non-trivial breach of the Undertakings.

Trivial breaches

The EAB has confirmed two separate trivial breaches of the Undertakings regarding inappropriate information sharing between Openreach and other BT Lines of Business. The first involved sharing of customer information between Openreach and BT Wholesale. The second involved BT Global Services accessing Openreach customer confidential information. The EAB has asked the EAO to validate the remedial action put in place for both breaches.

A trivial breach regarding user access controls was also confirmed. See the article above on OSS for more information.

Remedial action

The EAB has validated that BT put in place appropriate remedial action for a trivial breach regarding non-EoI provision of Openreach products for the 21CN IPStream trial (see August Overview for more details).

The EAB also agreed that BT had effectively remedied the non-trivial breach associated with wideband planners which was first reported in the November Overview.

Regular reporting

NGN and 21CN update

The EAO provided its regular update to the EAB on progress towards the implementation of 21CN. The EAO updated the EAB on industry concerns regarding IPStream migrations. It also described how Ofcom requested that BT publish its 21CN ‘plan of record’ on a quarterly basis to provide some reassurance for plans going forward. It also explained that as BT’s 21CN programme had started before the Undertakings were signed, some early decisions were not consistent with the principles of the Undertakings. As a result, the EAB recommended to BT that it should review all design decisions to ensure equivalence was built in wherever appropriate.

Al-noor Ramji, CEO of BT Design, gave his perspective on progress in the 21CN programme and his intent to make it more customer-centric. He explained how BT would look to deliver new services first in order to create customer demand to migrate to the new platform, rather than simply replicating existing services. He also said that the industrial scale migration of end customers would only take place as part of the 21CN implementation plan when BT was satisfied it could maintain the level of customer experience.

Openreach quarterly report

Openreach gave its regular update to the EAB in February. It explained that the creation of BT Design and BT Operate had tested the existing understanding of how it should work on an end-to-end basis with the rest of BT. Openreach said that it planned to focus on new product development moving forward and that it was seeking ways to gain a greater understanding of all CPs’ development needs.