DOCSLIB.ORG

Fixed Access Market Reviews: Openreach Quality of Service and Approach to Setting LLU and WLR Charge Controls”

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text
Fixed Access Market Reviews: Openreach Quality of Service and Approach to Setting LLU and WLR Charge Controls” Openreach response to Ofcom’s consultation document “Fixed access market reviews: Openreach quality of service and approach to setting LLU and WLR Charge Controls” 18 February 2014 Non Confidential VERSION Redacted items shown as [] Comments on this response should be sent to: Alan Lazarus via email at [email protected] Openreach response to Ofcom’s Fixed access market reviews: Openreach quality of service and approach to setting LLU and WLR Charge Controls – non-confidential version 2 Foreword On 3 July 2013, Ofcom published its proposals on the Fixed Access Market Reviews (FAMR). It subsequently published its consultation on the charge controls for Wholesale Line Rental (WLR) and Local Loop Unbundling (LLU) on 11 July 2013 and amended this on 20 August 2013 to correct errors in its cost modelling (the First Charge Control Consultation). On 19 December 2013 Ofcom published a further consultation (Fixed access market reviews: Openreach quality of service and approach to setting LLU and WLR Charge Controls (the Consultation)). The proposed controls are for the period from 1 April 2014 to 31 March 2017 (the Control Period). This document forms Openreach’s response to Ofcom’s 19 December 2013 consultation on the Fixed Access Market Reviews and the proposed LLU/WLR Charge Controls. Openreach will be responding separately to Ofcom’s 16 January 2014 consultation. (Fixed access market reviews: Further consultation on notification periods, compliance with requirements on the VULA margin, and approach to pricing for TRCs and SFIs) This response is in addition to our previous responses submitted 30 September 2013: Openreach response to service-related questions in Ofcom’s consultation documents “Fixed access market reviews: wholesale local access, wholesale fixed analogue exchange lines, ISDN2 and ISDN30” and Openreach response to questions in Ofcom’s consultation document “Fixed access market reviews: Approach to setting LLU and WLR Charge Controls”. This submission is provided on behalf of British Telecommunications plc (BT) by Openreach, a line of business within BT, in response to the issues contained in the FAMR Consultation, the First Charge Control Consultation and the Consultation. This submission gives Openreach’s responses to Ofcom’s questions which relate directly to the regulation of Openreach service levels and charges, together with further evidence and argumentation relevant to a number of charge control issues. We may subsequently provide further information if required. BT Group has also provided a separate response (the BT Group response) to the Consultation. This covers issues with implications across the BT Group and which impact BT in its role as a provider of retail services to consumer and business end-users. Openreach response to Ofcom’s Fixed access market reviews: Openreach quality of service and approach to setting LLU and WLR Charge Controls – non-confidential version 3 Table of contents 1 Executive Summary ............................................................................................................................ 4 2 Introduction to Service related questions and answers (questions 3-5) ........................................ 19 3 Responses to the Ofcom Service questions .................................................................................... 22 3.1 Responses to Question 3 .................................................................................................................... 22 3.2 Responses to Question 4 .................................................................................................................... 51 3.3 Responses to Question 5 .................................................................................................................... 53 4 Key issues for the LLU/WLR Charge Control ................................................................................... 71 4.1 Efficiency ............................................................................................................................................. 71 4.2 Volumes .............................................................................................................................................. 72 4.3 Basket structure .................................................................................................................................. 74 4.4 Broadband line testing ......................................................................................................................... 74 4.5 Possible one off cost / price adjustments ............................................................................................. 74 4.6 Deafness provision costs and career transition centre costs ................................................................. 75 4.7 Charge control base year and 2012/13 ................................................................................................ 75 4.8 The price differential between MPF and WLR plus SMPF .................................................................... 75 4.9 Caller display ....................................................................................................................................... 75 4.10 Modelling Issues .................................................................................................................................. 76 4.11 Definitions and Legal Instrument(s) ...................................................................................................... 78 5 Responses to the Ofcom Charge Control questions ....................................................................... 80 5.1 Charge Control Design ........................................................................................................................ 80 5.2 Charge control cost allocations and modelling ..................................................................................... 90 5.3 Proposed Charge Controls .................................................................................................................. 97 Annex A: Weather Case Study. Annex B: Deloitte – analysis of Openreach fault data Annex C: Ernst & Young response to comments made by Ofcom and Analysys Mason in respect of the Openreach Discrete Event Simulation Model. Annex D: Analysys Mason SLA and SLG comparisons for WLR and LLU MPF. Openreach response to Ofcom’s Fixed access market reviews: Openreach quality of service and approach to setting LLU and WLR Charge Controls – non-confidential version 4 1 Executive Summary Quality of Service Introduction 1. We take the opportunity in our response to this further Consultation to give our views on Ofcom’s specific proposals and also to set out what we believe are the desired outcomes from this important review. For the first time in a charge control review, Ofcom is specifically addressing the relationship between Openreach funding prices and the service standards Openreach delivers and this review provides the opportunity for a cross-industry outcome that: properly reflects the changing demands of end users and Communications Providers (CPs); balances the trade-offs between Openreach prices and service standards/service levels; recognises the challenges of delivering consistent service levels in this dynamic market; and incentivises industry collaboration to prioritise service improvements. 2. The UK has probably the most competitive voice and broadband market in the world, with the most keenly priced products from a wide range of suppliers and a record of continuous innovation. The challenge now is to establish the right service regime to go alongside this; we want consumers and businesses to be as consistently satisfied about the quality of the fixed telecoms services they buy as they are about the prices and choice they enjoy. 3. Openreach has demonstrated over the years a commitment to efficiency and innovation, delivering service with some of the lowest wholesale prices in the world. The customer (both industry and end users) has never been more important, given the heightened political focus on the cost of living and the telecoms sector is expected to drive growth, encourage innovation and deliver products and services at an affordable price, with sustainable service levels. The telecoms sector has delivered for consumers – for example, as a proportion of household expenditure, telecoms equates to less than 4% of average household expenditure compared to utility services at around 8%1. This demonstrates how far the market has delivered in relation to other sectors. Openreach wants to maintain that momentum and as part of this, wants to be able to ensure its customers (and their customers) receive a consistent quality of service that meets their expectations. 4. In this context, it is important to recognise the extent (and success) of UK regulation already governing the fixed access market. In this response we have included new international benchmarking from Analysys Mason who compared the wholesale telecommunications services provided in 15 countries, including prices and the scope and terms of applicable service level agreements (SLAs) and service level guarantees (SLGs); the UK rates very highly across this ‘balanced scorecard’. 1 Telecoms equates to 3.8% in 2012 (Ofcom Communications Market Report 2013), compared to utility services (energy and water) at c. 8% of average household expenditure in 2011 (ONS). Openreach response to Ofcom’s Fixed access market reviews: Openreach quality of service
Load more

Recommended publications
  • Inventing the Communications Revolution in Post-War Britain
    Information and Control: Inventing the Communications Revolution in Post-War Britain Jacob William Ward UCL PhD History of Science and Technology 1 I, Jacob William Ward, confirm that the work presented in this thesis is my own. Where information has been derived from other sources, I confirm that this has been indicated in the thesis. 2 Abstract This thesis undertakes the first history of the post-war British telephone system, and addresses it through the lens of both actors’ and analysts’ emphases on the importance of ‘information’ and ‘control’. I explore both through a range of chapters on organisational history, laboratories, telephone exchanges, transmission technologies, futurology, transatlantic communications, and privatisation. The ideal of an ‘information network’ or an ‘information age’ is present to varying extents in all these chapters, as are deployments of different forms of control. The most pervasive, and controversial, form of control throughout this history is computer control, but I show that other forms of control, including environmental, spatial, and temporal, are all also important. I make three arguments: first, that the technological characteristics of the telephone system meant that its liberalisation and privatisation were much more ambiguous for competition and monopoly than expected; second, that information has been more important to the telephone system as an ideal to strive for, rather than the telephone system’s contribution to creating an apparent information age; third, that control is a more useful concept than information for analysing the history of the telephone system, but more work is needed to study the discursive significance of ‘control’ itself. 3 Acknowledgements There are many people to whom I owe thanks for making this thesis possible, and here I can only name some of them.
    [Show full text]
  • Services Provided by British Telecom
    [Translating and the Computer 9. Proceedings of a conference… 12-13 November 1987, ed. Catriona Picken (London: Aslib, 1988)] New ways to communicate: services provided by British Telecom Malcolm Jones British Telecom Research Laboratories, Ipswich, UK INTRODUCTION Since 16 November 1984 British Telecom has been a private company with some two million shareholders who hold 50.2 per cent of the shares, with the UK government retaining the remaining 49.8 per cent. British Telecom now operates under a licence from the Department of Trade and Industry (DTI) which is administered by a special unit of the DTI called Oftel whose main task in life is to reprimand BT when they breach the terms of their licence. British Telecom is one of the largest companies in the United Kingdom with an annual turnover of some £10 billion in 1987 and it reflects this magnitude of trading in its capital investment programme which has been running at £2,000 million per annum since privatisation. A very large part of this expenditure, approximately 90 per cent, is with UK companies. NETWORKS The British Telecom telephone network is similar in size to that of France and the Federal Republic of Germany at about twenty-two million lines with only the United States and Japan having significantly larger networks. The international connectivity provided by British Telecom is one of the best anywhere, with over 90 per cent of the world’s telephones (550 million) being available by direct dialling from practically any telephone in the country. To support this international traffic there are approximately 28,000 international telephone channels connecting the United Kingdom with the rest of the world and all these channels carry some 500,000 calls per day.
    [Show full text]
  • Digital Exchanges – a Timeline
    March 2008 Digital exchanges – a timeline 1968 The concept of a digital network started in 1968 when an advisory group on System Definitions was established. This was an alliance involving the Post Office and industry groups intended to define the shape of the future telephone network and achieve it. The result was a processor controlled digital switching system, known as System X. 1979 The System X digital exchange was given an international launch at Telecom 79 in Geneva. System X was a collaboration between the Post Office and its three principal equipment suppliers, GEC, Plessey and STC, which culminated in a British designed processor controlled digital switching system. An evaluation model UXD 5 digital telephone exchange was opened for trial in Glenkindie, Aberdeenshire, making them the first subscribers to be connected directly to a digital exchange. This was the first digital public exchange introduced into the UK network. The introduction of UXD 5s into the network brought rural customers digital Network Services ahead of their counterparts living in more urban areas. 1980 The first System X exchange was installed in Baynard House, London. It was a tandem junction unit which switched telephone calls between about 40 exchanges. It was brought into service on 1 July and formally inaugurated in September. The development of System X exchanges was at the centre of the modernisation of the existing network, replacing analogue plant with digital switching centres interconnected with digital transmission links and enabling an increased variety of facilities and service. 1981 The first System X digital exchange to which subscribers were directly connected was opened at Woodbridge, Suffolk.
    [Show full text]
  • Telecommunications in the Highlands and Islands of Scotland
    TELECOMMUNICATIONS IN THE HIGHLANDS AND ISLANDS OF SCOTLAND This book is to be returned on or before the last date stamped below. REPORT TO: The Highlands and Islands Development Board and The Office of Telecommunications Highlands and Islands Development Board 1986 ISBN a 9*7872 67 1 EOSYS LIMITED Clove House, The Broadway. Farnham Common. Slough SL2 3PQ Telephone: 02814 5123 Telex: 849826 Report to: The Highlands and Islands Development Board and The Office of Telecommunications On: Telecommunications in the Highlands and Islands of Scotland C/319 HDBAAQ This report for the Highlands and Islands Development Board and the Office of Telecommunications (Oftel) was completed in January 1986 by Eosys Limited. Eosys is an independent consultancy specialising in the application of advanced telecommunications and information technology. CONTENTS Page No SECTION 1 MANAGEMENT REPORT 1 Preamble MR1 2 Findings MR2 3 Conclusion MR12 SECTION 2 MAIN REPORT 1 Introduction 1 2 Basic telecommunication facts 3 3 Application opportunities 36 4 Telecommunication options for the year 2000 onwards 42 5 Conclusions and recommendations 54 SECTION 3 APPENDICES A Telecommunications an overview B Individuals and organisation contacted during this study C Advisory group membership D Introducing Eosys E Eosys in Telecommunications HDBAAQ - MR1 - PREAMBLE Telecommunications provide a medium for communication, between people, between machines and between people and machines. The growth in other communication facilities, car ownership and usage, air travel or newspaper readership for example substantially exceeded early forecasts. The very rapid growth experienced so far in telecommunications is merely the tip of an iceberg, and can be expected to continue unabated.
    [Show full text]
  • Accounting Methodology Document 2018-19
    Accounting Methodology Document 2019 Relating to the Regulatory Financial Statements Contents Page 1 INTRODUCTION ........................................................................................................................................ 5 1.1 REGULATORY REPORTING REQUIREMENTS ......................................................................................................... 5 1.2 INTRODUCTION TO THE AMD ........................................................................................................................ 5 1.3 STRUCTURE AND PURPOSE OF THE AMD .......................................................................................................... 5 1.4 SCOPE OF DOCUMENT ................................................................................................................................... 7 2 BUSINESS AND SYSTEM OVERVIEW ........................................................................................................ 11 2.1 BT GROUP AND REGULATORY REPORTING ....................................................................................................... 11 2.2 THE REPORTING HIERARCHY FOR USE IN THE AS SYSTEM .................................................................................... 12 2.2.1 Financial and Management Reporting route ................................................................................ 12 2.2.2 Regulatory Reporting Route (AS system) ...................................................................................... 12 2.2.3 Attribution
    [Show full text]
  • BT's Innovation
    September 2011 BT’s innovation timeline 1837 William Fothergill Cooke and Professor Charles Wheatstone demonstrate, and patent, the world’s first successful electric telegraph between Euston and Camden. 1846 The Electric Telegraph Company is founded by William Fothergill Cooke and John Lewis Ricardo to work the patents of Cooke and Wheatstone. The first electric telegraph company in Britain, the ETC lays the first national communications network in the world. 1851 The world’s first successful submarine cable is laid between the UK and France by the Submarine Telegraph Company. 1878 The Telephone Company is founded to market Alexander Graham Bell's patented telephone, the first telephone company in the UK. 1880 The Post Office wins a landmark legal action against the Edison Telephone Company for infringing the Post Office’s telegraph monopoly. Telephone companies needed licences from the Post Office until The Telephone Act, 1951. 1891 The Post Office lays the first submarine telephone cable between the UK and France, one of the first transnational long-distance links and enabling telephone calls between London and Paris. 1896 The Post Office hosts the first successful demonstration of ‘telegraphy without wires’. Guglielmo Marconi successfully transmits a message from the roof of the Central Telegraph Office in London (now the site of BT’s headquarters) to a receiver on the roof of GPO South in Carter Lane 300 yards away. Engineer in chief, William Preece, was mentor to Marconi and in August, the Post Office permits Marconi to experiment with wireless apparatus on Salisbury plain and other places, and gave him financial backing.
    [Show full text]
  • Review of BT's Cost Attribution Methodologies
    Review of BT’s cost attribution methodologies Consultation Publication date: 12 June 2015 Closing Date for Responses: 7 August 2015 About this document This document sets out our proposals for changes to the way that BT attributes its costs to services. BT is subject to regulatory financial reporting obligations. These have been imposed by Ofcom where BT has been found to have Significant Market Power in a relevant market. These include obligations relating to accounting separation and cost accounting and include requirements to produce and publish annual Regulatory Financial Statements and to maintain and publish certain accounting documents setting out how BT prepares those statements. In May 2014, we decided that BT’s Regulatory Financial Statements should comply with a new set of guiding principles, which we called the Regulatory Accounting Principles. We explained that we would establish Regulatory Accounting Guidelines which will contain high level guidelines and accounting rules. We explained that we would review BT’s existing attribution rules against the new Regulatory Accounting Principles and that we would consult on the findings from this review alongside the Business Connectivity Market Review consultation, with the intention that any proposed changes to the attribution rules would be reflected in any consequent price control. This document sets out the initial findings from that review and invites stakeholders’ views on if and how BT’s existing attribution rules need to change. Contents Section Page 1 Summary 1 2 Introduction
    [Show full text]
  • Accounting Methodology Document 2015-16
    Accounting Methodology Document 28 October 2016 1 Contents 1. INTRODUCTION ....................................................................................................................................... 5 1.1 REGULATORY REPORTING REQUIREMENTS ......................................................................................................... 5 1.2 INTRODUCTION TO THE AMD .......................................................................................................................... 5 1.3 STRUCTURE AND PURPOSE OF THE AMD ........................................................................................................... 5 2. BUSINESS OVERVIEW ............................................................................................................................. 8 2.1 BT GROUP AND REGULATORY REPORTING ......................................................................................................... 8 2.2 AS SYSTEMS AND THE REPORTING HIERARCHY .................................................................................................... 8 2.2.1 Attribution of financial information to Markets and Services .......................................................... 10 2.2.2 Scope of document ......................................................................................................................... 10 3. OPENREACH REPORTING ...................................................................................................................... 11 3.1 INTRODUCTION .........................................................................................................................................
    [Show full text]
  • Annual Report & Form 20-F 2018
    wholly-owned subsidiary of BT Group plc, British Telecommunications plc meets the conditions set forth in General set the conditions plc meets Telecommunications plc, British Group subsidiary wholly-owned of BT a As Form 20-F with filing this 20-F and is therefore reports on Form 10-K as applied to of Form Instruction (I) (1)(a) and (b) format. disclosure the reduced 2018 Form 20-F Form Report & Report Annual BRITISH TELECOMMUNICATIONS plc BRITISH TELECOMMUNICATIONS BRITISH TELECOMMUNICATIONS plc 2018 THE StratEGIC REPOrt GOVERNANCE FINANCIAL statEMENts ADDITIONAL INFORMatION Contents The Strategic Report Our strategy Our strategy in a nutshell How we’re doing – Delivering great customer experience 3 – Investing for growth 4 – Transforming our costs 5 Key performance indicators 6 Our non-financial performance 8 Our evolving strategy 10 Our business model Our business model 12 What we do 14 Our resources and culture Financial strength 16 Our networks and physical assets 16 Properties 17 Research and development 17 Brand and reputation 19 Our culture / The BT Way 20 Respecting human rights 21 Our stakeholders Our people 22 Customers 25 Communities and society 25 Lenders 26 Pension schemes 26 Suppliers 27 HM Government 27 Regulators 28 The environment 31 Our risks Our approach to risk management 33 Our principal risks and uncertainties 34 Operating review BT Consumer 48 EE 55 Business and Public Sector 59 Global Services 64 Wholesale and Ventures 69 Openreach 73 Technology, Service and Operations 79 Group performance Group performance 82 Governance 89 Financial statements 95 Additional information 208 Overview British Telecommunications plc (‘the group’ or ‘the company’ ) is the principal operating subsidiary of BT Group plc.
    [Show full text]