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Overview

EAB Overview

7 November 2007

Breaches

Three breaches reported by BT

BT notified the EAB of three breaches of the Undertakings at its October meeting. All three concern the use of non-Equivance of Input (EoI) processes or systems for Openreach products by teams in BT. One breach relating to wideband planning for Openreach EoI Ethernet circuits by Managed Site planners from BT Wholesale (who later became planners in BT Operate through reorganisation) was considered to be non-trivial by the EAB. The other two breaches by BT Wholesale were trivial. The EAB will validate BT’s remedial action with regard to these breaches.

Remedial action completed

The EAO has validated BT’s remedial action for the following six breaches previously reported in the April, June and August EAB Overviews:

Broadband escalation by BT Global Services
Openreach sharing of commercial information in a Statement of Requirements process
MDF capacity planning process
Inappropriate sharing of Openreach customer confidential information by BT Wholesale
A BT Global Services diagnostic team accessing Openreach assets inappropriately
Non-Openreach employees accessing Openreach assets inappropriately to carry out advanced diagnostics for PSTN and ISDN2.

Undertakings delivery update

Operational Support Systems (30 June 2007)

The EAB’s validation of BT’s delivery of the first stage of Operational Support Systems (OSS) separation is still ongoing. The first stage involves the validation of User Access Controls for support systems for Metallic Path Facility (MPF), Shared Metallic Path Facility (SMPF) and Wholesale Line Rental (WLR). The validation will be completed by December 2007.

WLR3 RFS (30 June 2007)

BT’s delivery of WLR Ready for Service (RFS) is still undergoing EAB validation. The complexity of the WLR product has led to a large-scale validation including extensive interviews with industry and an examination of numerous aspects of the delivery. The validation is expected to be complete by the end of 2007.

WLR ISDN2 RFS (30 September 2007)

BT has asserted that WLR ISDN2 RFS was delivered using the existing tactical systems. BT expects to launch this product on the new strategic system in 2008. The EAB is validating the delivery of this product.

Exemptions and variations

Five Undertakings exemptions concerning items in the Openreach product portfolio—such as Local Area Network Extension Service (LES) circuits and Short Haul Data Services (SHDS)—came to an end at 30 September 2007. From that date BT must ensure that existing customers using the exempt products have been migrated to EoI compliant versions as the exempt products should no longer be available. The EAB is validating the migration.

Industry viewpoint

KCOM Group

Huw Saunders, Group Regulatory Affairs and Technology Development Director, KCOM Group, attended the October EAB meeting. He told the EAB that as KCOM’s main emphasis outside of the Hull area was the business-to-business market, he felt that the Undertakings had created better conditions for sustainable mass market competition but, there was further work to do to bring benefits for business customers. He said that while Openreach’s engagement with industry had improved, more could be done with regards to business-to-business focussed CP customers and their particular product and service needs.

OTA2 and NGNuk

Peter Black, Executive Chairman of NGNuk and the Office of the Telecommunications Adjudicator (OTA2), reviewed progress in both areas at the October EAB meeting. He said that NGNuk had received good support from BT and that the company had been helpful in the resolution of 21CN Points of Service Interconnect (POSI). With regards to OTA2, he said that there were some improvements in MPF processes but that these were still below acceptable levels. OTA2 was encouraging CPs to ramp onto EMP but this was raising a number of problems, in particular the need to avoid new bottlenecks in product development and system deployment. Peter concluded by saying that while Openreach needed to further improve the effectiveness of its customer relationships, progress also required positive contributions from CPs.

EAB reviews

BT Northern Ireland

The EAO has concluded a review of information boundaries (‘Chinese Walls’) within BT Northern Ireland (BTNI). Although BTNI is not required to comply with the rules on information sharing in the Undertakings, the EAO’s review found that BTNI had put measures in place to limit information flows between upstream and downstream divisions within its operations. The EAB commended BTNI on this positive step and suggested further measures to help BTNI build on its achievement, for example it agreed with BTNI’s proposed separation of the engineering workforce from the rest of the business to ensure appropriate information boundaries are maintained.

Next Generation Networks

The EAO’s quarterly review of the current status of BT’s next generation network (NGN) planning found that although there were some issues regarding the 21CN programme, there were no immediate compliance concerns. As part of the review, the EAO heard CP views on topics such as progress towards agreeing the 21CN POSI plans and concerns regarding the changes to the 21CN IPStream migration plans. The EAO will continue to monitor developments in both areas. In responding to the EAO’s review, the EAB acknowledged a large rise in interest in Next Generation Access (NGA) and noted Ofcom’s consultation document on this subject.

Parallel systems and products

The EAO reviewed the existence of ‘parallel equivalence’, which occurs when both new and legacy systems and/or products run beside each other with CPs opting for one option and BT choosing another. The review concluded that all the current examples of parallel systems exist as a result of CPs choosing to remain on legacy platforms. It also found that there were actions in place by BT to mitigate the impact of parallel products where they exist, for example the plan to move existing IPStream Central and IPStream Central Plus customers to the converged IPStream Connect product in 2008. The EAO will continue to monitor and report to the EAB in this area to ensure BT’s action plans are effective.

Governance update

Appointment of new EAB member

Himanshu Raja, Chief Financial Officer of BT Operate, has been appointed as the BT senior manager on the EAB with effect from 5 November 2007. Himanshu replaces Sally Davis who left the EAB in September following her appointment as CEO of BT Wholesale. Himanshu joined BT Group in 2001 and has held various financial positions in BT, including most recently CFO of BT Wholesale. Prior to joining BT, he worked for MCI WorldCom, UUNET and MFS.

Links

KCOM: http://www.kcom.com/

NGNuk: http://www.ngnuk.org.uk/

Openreach: http://www.openreach.co.uk

OTA2: http://www.offta.org.uk/

Glossary

CPs: Communications Providers

EoI: Equivalence of Input

EMP: Equivalence Management Platform

LES: Local Area Network Extension Service

MDF: Main Distribution Frame

MPF: Metallic Path Facility