Industry Consultation Feedback. James Lilley Andy Wright Tony Birkbeck Phil Laws

Transcription

1 Industry Consultation Feedback Upgrading the Access Network: The withdrawal of WLR products and the smooth transition to IP Voice services. September 2018 James Lilley Andy Wright Tony Birkbeck Phil Laws 1

2 End of life for WLR* is 2025 we ve started the withdrawal process with industry in May 2018 Why WLR is being withdrawn Global trend amongst telcos transitioning to support All IP delivery of voice The PSTN supports a significant volume of voice services and will reach the end of its life in 2025 Future voice will be delivered over All IP networks Investment is already underway where broadband rather than voice will be the primary service Our Challenge The PSTN supports Openreach WLR products and these will be withdrawn by the end of 2025 Start of a significant seven year programme Feedback on the timeline and process for withdrawal of WLR Over 16m lines will need to migrate to new services Residential, business and special services impacted Close collaboration needed to ensure this is a smooth transition for our customers *WLR: Includes WLR3, LLU SMPF, SLU SMPF, ISDN2, ISDN30, Narrowband line share and Classic products 2

3 Consultation process and beyond Our consultation on the timeline and processes for WLR withdrawal and the introduction of the new SOTAP product closed on 27 July CPs responded to the consultation We found there was broad support for our plans and positive feedback on the opportunity to respond to the consultation. There was a mixed response to the proposed timeline and questions around making the switch by 2025 There is also a clear appetite for more details, planning and engagement via industry working groups. We have summarised and grouped consultation feedback by key theme. 3

4 WLR product withdrawal process Generally supportive, there is an understanding of the size of the task and CPs are cautious about the time frame. General agreement with key principles, but there are concerns that the migrations may become back ended which could lead to a poor customer experience. Working groups will be required to help understand the proposed stop sell order journeys and timelines. Whilst a 2025 end date gives enough time for Openreach and CPs to manage customer migrations effectively, there are concerns that some aspects of Openreach s proposals will result in migrations that are not well spread across this period, which could result in poor end customer experience. CPs are suggesting 2025 should only be a target and we should consider a longer lead time if required. It is suggested that the stop sale of new WLR in September 2023 would back-end the migration process. The final stage of the proposed process of migrating orphaned end customers (April 2025 December 2025) is too short given the potential problems for this segment. General concerns over the December 2025 date, given this is a holiday period and could add additional complexity to support process and system changes. Restricting WLR new supply requires careful consideration which will be discussed at the industry working groups. CPs in general are not supportive of geographical withdrawal of WLR. The need for an urgent process post stop sell to provide a WLR line to support things like Civil emergencies where lines are rapidly required after major events. Certainty over the reverse migration strategy pre and post the stop sell that should be implemented by design to jeopardy mange and reinstate service issues from lines that have migrated to IP back to PSTN / ISDN. A service restoration process that can be used during the migration phase to cover things like lines ceased in error, general mistakes, miss selling etc. More information needed about BT Group s overall plan for voice withdrawal and without this CPs are unable to fully endorse Openreach s plans to the withdrawal of WLR. Clarity on what the order journey will look like if a CP places a restricted order after the stop sell date, will the order just be rejected? 4

5 Communications CPs are asking for a national media announcement / campaign to help educate their customers. The lack of end customer knowledge is causing concern and uncertainty with CPs, which ultimately could result in poor customer experience. Concern that OFCOM has stated they have no such plans to drive this as it's part of a complex message with many CPs having different timelines. Confusion over BT Group announcements such as exchange closures in relation to the withdrawal of WLR3 and the development of SOTAP questioning the longevity of the wider copper access products. More details required on the longevity of copper products including SOTAP, given the BT indication of exchange closures, as this impacts CPs consumption plans. The need for a national media announcement to help raise the awareness to end customers similar to the analogue TV switch off. There is an expectation that Openreach should fund and deliver this mass communication, under the oversight of Ofcom; there must be no cost (direct or indirect) to CPs as this is an enforced change. Consumers are likely to see efforts to make them change the way that their telephony and broadband products are supplied as a sales ploy to make them spend more money. CPs would welcome an official statement to show customers to explain the obligations they are under as a result of work by Openreach to upgrade the network. An industry opportunity to work with Openreach to produce information guides and fact sheets about the migration for older and vulnerable customers. An industry approach needed and agreed for special services so the same message is delivered to customers in terms of the possible impact of the WLR3 withdrawal. Each CP could then tailor the message to include the options available to their customers. Concerns raised that some smaller CPs don t have the resources needed to ensure market awareness, putting them in danger, and hence regulator support in this is important. Industry working groups should be run independently and chaired by the OTA, with minutes and outputs being readily available for the whole of industry. All CPs must have the opportunity to contribute to any working group discussions. 5

6 Product Plans and timelines CPs request a joined up All IP Openreach roadmap that shows all product, technical, systems and commercial changes taking place up to the withdrawal date of This will help mitigate concerns over Openreach's proposals that have the potential to cause unwelcome end customer disruption if not manged correctly and enable CPs to join the dots across Openreach product initiatives. CPs would like to understand interconnect plans (a BT Enterprise product) as a result of WLR withdrawal whilst stating that the 2025 date should remain flexible. CPs raising concerns that Openreach will not offer a voice managed solution post CPs believe that this should be an Ofcom led, project managed programme - to set a framework for delivering IP migration and to achieve such solutions. Appropriate governance structures for industry stakeholder participation and decision-making processes would also be required. Concerns raised regarding BT Group s announcement to retire exchanges in relation to the impact of developing SOTAP and longevity of MPF. Concerns that the launch date of SOTAP could be too late and needs to be quicker whist believing that the withdrawal of WLR should be tied to the same timeframe. CPs have stated there must also be commitments in the following areas to allow them to accept the proposals: Availability of go to products (in all areas including remote areas) Migration capability, when that will be available, how it will work Specifications of go to products do they meet industry requirements. Appropriate commercial arrangements Customer experience journey being satisfactory. Testing facilities being available Visibility of a product and system roadmap that overlays the development of new services (SOTAP, SOGEA, Gfast, SOGfast), with changes to existing services (GEA- FTTC, GEA- FTTP) and future plans for withdrawal of older products (e.g. WLR3, LLU SMPF, SLU SMPF, CPS). Delays in launching new products means the WLR challenge grows. Battery backup is an issue and needs addressing, as batteries can go flat. Concerns that SOTAP is only viable for existing BT Enterprise and LLU CPs. To maintain competition there is an expectation that Openreach should offer a similar managed voice service on SOTAP as exists for WLR today removing the need to have an exchange presence or consume the product via a wholesaler. There were concerns that if this is not implemented, CPs would be obliged to purchase an alternative product via different wholesale providers to supply the IP products that they 6 require. This would involve new contracts and product sets with appropriate system developments and APIs to enable CPs to order products that their customers want.

7 Commercials Industry is asking for early visibility of all fibre and new product commercial offerings. Some CPs are of the view that migrations should be free of charge. Suggestions we could speed up migrations by offering commercial incentives. Questions raised about the development of a low cost/low speed product on fibre (for voice only customers). CPs want a clear view of: o all fibre and new product commercials, ensuring they are attractive, not only for SOTAP but all the alternative fibre product offerings; o incentives for migration from WLR e.g. specifically reduced connection prices (to other products); o the SOGEA rental strategy to encourage greater take up; o the commercial incentives that Openreach could provide in order to ensure that CPs migrating lines early are not penalised; o the commercials in order to share their migration plans; o a lower priced GEA-FTTC/SOGEA service to be aimed at voice only customers with similar commercials to SOTAP. CPs were of the view that commercials will need to be equivalent to a WLR voice only service where appropriate, to allow provision to consumers at similar rates; o the planned commercials for moves to new technology will the first customer bear the charge of the move to fibre? It was considered not appropriate for a first mover charge where there is no alternative due to Openreach upgrading the network. Some CPs considered that if Openreach save cost through the migration that some of the savings are passed back to industry. This should be considered as an incentive to industry to ensure a successful WLR closure. It was stated that it would not be appropriate for Openreach to put up WLR prices in the period leading up to WLR closure. CPs require MIS reports to be available to manage their assets during the migration phase. CPs expressed concerns that they will need to understand the full cost to provide service (if buying through a wholesaler). 7

8 Special Services Concerns raised that currently we don't have universal agreement across the WLR base on how lines with these type of services will be managed. There is clear requirement for an industry focus group in this area. CPs are asking for support identifying end customers who have these services working on their lines. Non BT CPs are concerned about the ability to test the equipment in advance of any transition. A requirement to urgently restore the WLR service both pre and post stop sell if there is a problem to avoid a poor customer experience specifically as in some cases this could impact the most vulnerable. Questions raised around the management of special services and whether this should be managed by Ofcom s All IP Working group and not specifically the WLR withdrawal groups?. There is an expectation that special services providers will develop alternative products suitable for operation over All-IP network. Requests for a dedicated process to support requests for emergency supply that originate from Blue-light services or Government agencies. Concerns regarding the regulatory responsibilities to end customers i.e. landline providers on customer access to emergency services when there is a power cut and telemetry data communications between remote outstations and centrally located master stations or data concentrators where it is essential that any solution remains powered in the event of a mains supply failure. Access to an Openreach white label testing facility specially for testing end customer equipment against different CP solutions. Industry to work closely with Openreach and special services providers to understand in more detail what is classed as a special service. In addition clarification regarding the Openreach role in managing these suppliers and subsidisation for the cost imposed on customers. Any process designed for identifying these customers should be industry wide with Openreach s role clearly defined. Careful planning for any migration to identify locations which may not be able to move to IP to plan alternative solutions such as terminal device to process debit and credit cards that use TDM dial up facilities. Security: what process does Openreach expect the vendors of Gateways / ATAs to go through to demonstrate the suitability of their equipment for the proposed UK network. 8

9 Diverse and Vulnerable Customers An expectation that Openreach will support CPs and industry groups to provide a clear definition of this segment enabling smooth migrations away from WLR to a suitable alternative product. An acknowledgement that CPs and Openreach will need to work closely together to manage the transition of vulnerable customers which includes categories of critical sites e.g. national security, national infrastructure. The requirement for specific focus groups managing elderly, vulnerable and critical site customers supported by an urgent restoration process pre and post the stop sell dates of WLR3. Industry has a large variety of diverse requirements that Openreach is expected to support ensuring every customer has smooth migration away from WLR to a suitable alternative product. Feedback suggests that special focus group should be set up, comprising of older customers and other voluntary sector organisations to discuss the migration with Ofcom, Openreach and the telecoms companies, these should include any Local Authorities, the advocacy provider sector, as well as the NHS, in any such working groups. Some CPs have raised concerns they may not know their end customer is deemed vulnerable. Clear CP customer communication will be important to support the identification of vulnerable customers. CPs have suggested that the Ofcom consultation on access to emergency services and customers who qualify for a free solution under GC.A3 is a good starting point to help define this customer base, which if adopted should become an industry agreed process shared within the working groups. CPs are asking for clarification on the support and identification that will be needed for vulnerable customers, and what role Openreach intends to play in helping provide this. 9

10 Managing orphaned end customers CPs are keen to have input and understand the estimated scale and complexity of managing potential end customers not migrated by Industry expects that no one will be left without service and is asking for more information from Openreach on how this will be facilitated. Queries were raised on how this works with the wider BT USO obligation. CPs are keen to understand the estimated scale and complexity of this problem and how Openreach envisages such end customers will be catered for. Also, there is a need to understand how this will relate to BT s obligations under the USO. There is concern that the final stage of the proposed process for migration of orphaned end customers (April 2025 December 2025) is too short given the potential problems for this segment. CPs have asked for more information around the plans and thought process behind the forced migration window. Is there an opportunity to extend the WLR service post 2025 using spares from other exchanges? Industry is unclear how a supplier of last resort process will be designed. Further discussion via industry working groups is needed, to see if a process is still required, and if industry is willing / able to adopt such a process. It was stated that due to demographics, most orphaned end customers still left by April 2025 will likely be in the residential market. Hence, support from Openreach would be welcome, especially with landline only consumers, who ll be most resistant to change. Support is also expected from Openreach in helping find suitable solutions for any migration tails, with the expectation being that those tails won t be facing any down time. CPs feel that flexibility is needed for orphaned end customers who don't get migrated by end of

11 SOTAP Appetite for more information on this product including the product definition, coverage, commercials, scope and how this will be used to underpin any USO obligation. The use of the Transitional definition has caused CPs concerns over the longevity of the product and potential impacts on the viability of any commercial business case. More information is required on how CPs will understand the bandwidth per line to ascertain where there could be speed implications that prevent VOIP type services being supported. There is a general question regarding the Openreach strategy, CPs have questioned if we should not be investing in the fibre roll out plans rather than developing SOTAP. Concerns raised regarding the consumption of SOTAP, it seems that the only viable option is via BT Enterprise given any alternative requires an exchange presence. CPs requirements are to have equivalence on customer experience and commercials aligning to the MPF product. Concerns raised over the CP obligation to provide 112/ 999 services in power cut situations as there will be no line power similar to the WLR3 service. Early sight of roll out plans and SOTAP coverage is required to help build commercial business cases for the consumption of the product Certainty over the SOTAP product specification by Nov 2018, supporting SLAs and if there is likely to be a service wrap to support both the residential and business sectors. Testing plans, the use of service layer data, including a suitable warranty of the line, line speeds for target areas to help underpin their voice and USO obligation. Questions also raised why there is not a default voice service with the product. Industry sees the product being used to support their existing customers where end customers have either decided to stay on an ADSL type service, existing voice only customers or customers who are unable to get a fibre product greater than 2mg. Clarification is required on what other product options are when SOTAP doesn t meet the broadband USO. A clear testing strategy is required as part of the product development. CPs want clear visibility on plans to support provision and repair order journeys. Questions raised, should SOTAP be universally available and coordinated by Openreach and not via a wholesaler. Industry would like to understand more about the rationale and commercial case for SOTAP given the systems costs as opposed to using MPF whilst taking into account there must be minimal disruption to end customers with the opportunity and potential for parallel running. Migration to the SOTAP product should be equal in terms of both commercials and technical process to other migration journeys. It is essential that migrating a line to SOTAP does not give any advantage to the CP performing the move, thus disadvantaging CPs who do not use the product. CPs concerned that it could be anti-competitive if SOTAP is being introduced to deal with orphaned users but is not being restricted to those areas where alternative products are not available. It would be unfair if only CPs who have a SOTAP POP can offer voice only customers this solution. Early trials of SOTAP are essential to make the launch as smooth as possible. March 2020 should remain a target to commence the trial period. CPs questioning if Openreach should be restricting any sale of copper and state it 11 should be the CPs decision.

12 Migration CPs suggesting there will be complex migration journeys involving coordination between several parties and in some cases requiring a change of end customer CPE and associated cost. Need for industry to agree a policy on who can trigger a migration if a line supports different services with different CPs (e.g. WLR, SMPF and CPS all with different CPs) Concerns being raised if Openreach can support the number of additional engineering visits. Requirement for out of hours visits and frames activities at no additional costs to support specifically business migrations. CPs raised concerns over the management of split customers - line and broadband service with different CPs - which CP will initiate migration? Industry is keen to understand what volumes Openreach will commit to handle per week / per month, how will capacity be equivalently managed across multiple CPs. More information regarding the plans for bulk migrations and the criteria that could be used (e.g. by geography, by exchange, by product type). Concerns specifically focussed on the business segment to minimise impact to their end customer during migration. This will require migration options including but not limited to out of hours, project management support, optional timed slots available if done during the day, where the end customer is able to specify a time when their service can be changed. A clear rollback process has been requested (possibly multiple lines) to the original product if the migration to the new product has problems. CPs will have specific requirements to manage their base which could be on a customer by customer basis or exchange by exchange basis. Understanding the down time to each journey is critical to minimise customer disruption, specifically with payment card machines in businesses. Orphaned assets and migration planning will need careful thought and industry agreement. CPs will need to work together to build processes and support teams in each area. Geographic phasing to be considered to allow targeted marketing. There is a requirement for a suite of data reports that detail all of the information that Openreach has for each of their lines, the exact specification for these reports to be worked through. Concerns raised over the high number of end customers that will require engineering visits and the complex journeys involving coordination between several parties and in some cases requiring a change of end customer CPE. There is an expectation that Openreach will still manage and validate some customer data address details regarding 999 services, which may require systems development to help manage this. CPs concerned that they will need new or additional teams to support the migrations and deal with technical and general issues from their customers. General complexity with the existing copper products which has many layers of configuration applied which will have impact on migrations. Will CPs consuming WLR indirectly be given priority as the migration journey is more complex in this situation. 12

13 Fibre availability Current gaps in fibre availability, particularly to support business customers, is causing concerns about viable product alternatives, specifically in the ISDN market. CPs are also concerned that spending money on developing alternative products like SOTAP may deflect and slow down the rollout of fibre across the country. Some CPs believe a more appropriate approach, where fibre is not available, is for Openreach to maintain WLR in these areas rather than develop SOTAP. Clarity and a clear understanding is required by CPs around all of Openreach s fibre plans, including plans to increase existing capacity. The point was raised that CPs feel that the business community continue to be poorly served by the Openreach fibre rollout programme. CPs are concerned about double migrations and the impact on their customers and would prefer to migrate directly to fibre rather than any transitional product. Industry has raised concerns that the fibre rollout coverage in the consultation is based on an assumption that the UK has near universal fibre availability. Although government and the regulator regularly quote levels of 95% availability, this is only true in relation to residential customers. For business customers, availability is likely closer to 40%. CPs have stated that Openreach ought to be focusing on driving out FTTX availability and enabling superfast speeds for exchange only lines, rather than proposing stop gap products such as SOTAP. Industry has no objection to the roll out of Gfast services but the fact that it is only being deployed in existing GEA-FTTC areas means that there is no extension of coverage, merely an increase in speeds for those who already enjoy GEA-FTTC services. If anything Gfast will simply widen the gap between those who currently have superfast services and those who do not. The question was raised around whether Openreach will be providing a variant of the other product options (e.g. SOGEA), which enables more than one CP to deliver service to the end customer on one piece of fibre. It is believed by CPs that a reduction in prices of GEA-FTTC 40/10 will lead to greater adoption of fibre broadband. 13

14 Number portability CPs have expressed concern about the robustness of the number port process to manage large scale migrations. General agreement that this is an industry issue to solve but CPs point at Openreach playing a key role to support the process. General recognition that the existing industry Number Porting Working Group is best placed to facilitate improvements. CPs consider there to be significant challenges facing the current number porting process. There are concerns regarding the volume of errors within the existing process which impacts on the volume of numbers that can be successfully ported, putting the capacity of the migration under strain. The porting process needs to: o support peak migration volumes, as some CPs have tens of thousands of ports per week; o ensure minimal end customer down time; o support a new customer journey for migration back to WLR from an IP voice service during the migration phase; o provide the capacity to manage migrations on top of normal day to-day activity; o ensure it does not place unnecessary burden for porting between platforms for the same CP. It is considered imperative that this work is progressed as soon as possible as without it the WLR closure timescales may not be feasible. There is a view that the scale of changes required are such that Ofcom needs to be involved because: o changes are out of the control of individual CPs; o changes to the process may require the development of a centralised number porting system. 14

15 Consultation Next Steps Key Dates 27 July 2018 Consultation closed 7 September 2018 A call to summarise the CP responses all CPs and industry groups / bodies invited 7 September 2018 Publish CP response summary on openreach portal 1 October 2018 Publish formal Openreach response to consultation 5 October 2018 First industry working group Kick off working group session with CPs who provided a response W/C 8 October 2018 Publish industry working group meeting schedule going forward September 2023 Restriction of WLR3 new supply December 2025 Focus is on how we achieve the withdrawal of the WLR3 product set before the end of December

16 Overall Concerns raised by CPs regarding the lack of media coverage and how this impacts on plans to educate their end customers. CPs are calling for Ofcom to take much more of a lead role in managing industry through this change, similar to the consumer switching project. Concerns raised around migration planning and the robustness of the number portability process that will need working through to minimise CP and Openreach plans from becoming back ended to Feedback raises some areas of concern specifically in the business sector but also across the different customer segments which highlights the size of the task. Vulnerable end customers and lines with special services needing support and engagement from the associated trade bodies to support migration planning and potential urgent roll back restoration journeys that may be required. The SOTAP naming convention which contains the word transitional has caused concern over the longevity of the product. Coupled with the BT Group indication to reduce the number of telephone exchanges by 2033 has prompted calls for clarification on the impact on our plans. A requirement for Openreach to publish a roadmap that shows all of the All-IP product and commercial requirements and linkages in one place. This will help provide a consistent approach to feedback and early visibility of any commercial announcements to support migration activities. Industry has suggested that some of these journeys are expected to be free of charge. The requirement for a wider BT Group led consultation on the impacts of interconnect services, exchange closures and BT s voice USO given the close linkages with WLR withdrawal. CPs have raised concerns over requiring an exchange presence to consume SOTAP directly or the need to buy via a wholesaler as they will lose their relationship with Openreach. 16

17 The contents of this pack cannot be copied or reproduced in whole or in part without the written consent of Openreach. British Telecommunications plc