Access key 0 - Accessibility, Access key 2 - Jump to content, Access key 7 - Jump to navigation
Skip To Content | Skip To Navigation
 

Home > Consultations > Consultation Documents > Requirement on BT to publish KPI > Requirement on BT to publish KPI > Section 5


Section 5, Proposed requirement on British Telecommunications to publish Key Performance Indicators consultation

Proposals for draft Directions for KPIs under the Quality of Service Condition (AA7) in the Fixed Narrowband Review

Consultation published: 15|03|2005
Consultation closes: 15|03|2005

Wholesale Line Rental

5.1 Wholesale line rental ("WLR") is a service whereby competing providers effectively lease an exchange line from BT and decide how best to route their customer's calls. Providers therefore take on the full retail relationship with the customer and offer a 'single bill' for all basic communications services.

5.2 In August 2002, Oftel required BT to provide a Wholesale Line Rental (WLR) product to competing providers. Although BT introduced a basic analogue WLR product in September 2002, Oftel was of the view that this basic product needed to be enhanced in order for it to be an effective mass-market product that was commercially attractive to service providers and end-users. Oftel developed with industry a product and process specification. In March 2003, the Director issued a statement setting out the proposed specification for an enhanced WLR product that BT would be required to provide, which is set out in the annex to the statement http://www.ofcom.org.uk/static/archive/oftel/publications/whole_line/2003/wlr_1_0303.htm. Part of that specification proposed that BT should provide transparency of its operational performance in relation to key business processes by publishing such KPIs, to be defined by Oftel. Also that BT should publish data on its performance in relation to its retail arm (where appropriate) as well as in relation to communications providers in sufficient detail to show whether they are receiving an equivalent Quality of Service to that provided to BT's retail arm. BT has developed with Ofcom a set of KPIs that Ofcom will use to assess whether the product is "fit-for-purpose." However, Ofcom wishes to identify a set of KPIs for publication on an ongoing basis, taking into account the views of stakeholders. Those KPIs should be representative of key business processes but not disproportionate for BT to collect and publish data on. It is the ongoing KPIs which are the subject of this consultation.

5.3 In the Fixed Narrowband Review, Oftel/Ofcom concluded that BT has SMP in a number of UK markets (excluding the Hull area) including the following:

5.4 The KPIs being proposed in this consultation apply to wholesale residential and business analogue exchange line services; and wholesale business ISDN2 and ISDN30 exchange line services. The KPIs are not proposed in relation to wholesale residential ISDN2 exchange line market as in the Fixed Narrowband Review (para 7.3) the Director decided not to require BT to provide WLR in response to the finding of SMP in that market.

Description of proposed KPIs for WLR

5.5 The measures proposed for WLR take into account stakeholder views expressed during the previous consultation exercise. For each of the measures listed, the data should be split between:

as these are the different markets identified in the Fixed Narrowband Market Review, for which the SMP obligation to publish provide WLR applies. It is in relation to those markets therefore that Ofcom proposes that BT should publish Quality of Service KPIs. Following the WLR launch, Ofcom expects there to be sufficient data for the KPIs to be statistically meaningful.

Publication requirement

5.6 In order to provide transparency of the Quality of Service provided, it is proposed that BT should publish:

for each of the KPIs outlined in this section.

5.7 In addition, Ofcom proposes that BT should publish the volume information for the following:

Ofcom considers that publication/provision to Ofcom of this underlying volume data is important in order for Ofcom to assess the statistical significance of the KPIs which are published.

It is proposed that publication should be required in relation to aggregate volume figures but that volumes in relation to "top ten" providers and BT's provision to itself should be provided separately to Ofcom.

5.8 Although BT does not purchase WLR from itself explicitly, there is an implicit wholesale transaction that is necessary in order for BT's retail arm to be able to offer retail exchange lines. If it is not possible to measure the operational performance in relation to this wholesale transaction directly, then it may be derived from the performance at the retail level. It will not be possible to derive a comparator in this manner for all KPIs - in particular, this will not be possible in the case of the KPIs relating to gateway availability and order rejection rates. Ofcom is therefore not proposing such a requirement.

Percentage of wholesale access orders that are rejected

5.9 Ofcom proposes that an appropriate KPI would be the number of orders accepted by the Gateway, allocated an order number and subsequently rejected, based on pre-determined business rules. This data would be published as a percentage of validated orders rejected.

5.10 Orders submitted by the communications providers but rejected at the pre-validation stage (before an order number has been generated) would be excluded from this measure. Reasons for rejecting orders at the pre-validation stage include incorrectly formatted orders (e.g. wrong address, wrong telephone number etc).

Percentage of orders provisioned on time

5.11 Ofcom proposes that BT should provide a KPI showing percentage of orders provisioned within the confirmed Contractual Delivery Date (CDD). The CDD is determined by adding the standard lead time for the product to the order entry date.

Percentage of new provisions reported as faulty

5.12 Ofcom proposes that BT should publish a KPI showing the percentage of lines reported as faulty (via BT's electronic fault management system) within the first 30 calendar days after being provisioned.

Percentage of installed base reported as faulty

5.13 Ofcom proposes that BT should publish a KPI showing the total number of network faults (reported via BT's electronic fault management system), expressed as a percentage of the average of the installed base of the exchange line types as listed in para 5.5 above.

Average time to restore service

5.14 Ofcom proposes that BT should publish a KPI showing the average time to clear faults. This should be measured as the average time in hours between when the fault is reported and when service is restored, excluding any parked time. Given that BT offers communications providers three different levels of service care for wholesale access, ie standard (level 1), prompt (level 2) and total (level 3), Ofcom considers BT should also split the data by care level.

Percentage of repeat faults

5.15 Ofcom proposes this measure should show the percentage of faults reported by communications providers to BT which recur within 30 calendar days of the clearance of an immediately preceding qualifying fault report.

Gateway availability

5.16 Ofcom proposes that BT should publish a monthly figure showing the total time that the gateway is potentially available over that period. In addition, it is proposed that BT should demonstrate the impact of planned as opposed to unplanned outages by providing two measurements:

Volumes

As mentioned above, Ofcom has also proposed that the underlying volume information be published/provided to Ofcom.

Frequency of publication

5.17 It is proposed that the KPIs should be published monthly.

Interconnection circuits

5.18 An interconnection circuit provides a circuit between the exchanges of two interconnecting communications providers in order to allow traffic to pass between their networks. There are several forms of interconnection circuits:

These are explained in the glossary in Annex 7.

5.19 In the Fixed Narrowband Review, the Director concluded it would be insufficient to regulate only one type of Interconnection circuit product as they each perform very different functions. Regulation of CSI is considered essential to ensure that barriers for entry for new interconnection communications providers are low as there are significant costs involved in building ISI circuits to the BT exchange. Regulation of ISI is necessary to ensure that providers have the option of building out their own networks and connecting closer to BT's exchange. IECs are used when an interconnecting provider has connected to one exchange in a given area and is seeking to interconnect to other exchanges in the same area. It would be difficult to justify constructing ISI circuits to all these exchanges where traffic volumes are low (such as at local exchanges).

5.20 Ofcom considers that BT should be able to demonstrate transparency as to the Quality of Service provided for interconnection circuits, especially given their importance to smaller operators. The circuits are effectively sub-products and are related to the following products as follows:

which are covered in this section.

which are part of the Broadband Review and are therefore covered in section 6.

which are covered separately in the Leased Lines Review.

KPIs proposed for Interconnect circuits

5.21 The KPIs proposed cover key processes, namely order provision and service restoration. As mentioned below, Ofcom has also proposed that the underlying volume information be published/provided to Ofcom. Ofcom considers this information is important for the same reasons set out in relation to WLR.

Publication requirement

5.22 Ofcom's aim is that the KPIs demonstrate transparency of the performance BT provides to its retail arm and that provided to communications providers who compete downstream. BT does not interconnect to itself (with the exception of FRIACO) but it should nevertheless be possible for its competitors to detect from the aggregated total where there may be potential problems. It is therefore proposed that BT should publish KPIs showing:

Percentage of orders provisioned on time

5.23 Ofcom proposes that BT should publish a KPI measuring the percentage of orders provisioned within the confirmed CDD.

5.24 Ofcom also proposes that BT should publish the total volume of orders on which this measure is based. The volume of orders for each of the "top 10" providers should not be published but should be provided to Ofcom separately.

Average time to restore service

5.25 Ofcom proposes that BT should publish a KPI showing the average time to clear faults. This should be measured as the average time in hours between when the fault is reported and when service is restored, excluding any parked time.

5.26 Ofcom also proposes that BT should publish the total volume of reported faults on which this measure is based. The number of faults reported by each of the "top 10" providers should not be published but should be provided to Ofcom separately.

Data Management Amendments (DMAs)

5.27 BT does not currently track average time to complete a DMA, only the performance against the customer required date (CRD). The delivery for BT's retail arm is not tracked in the same way but is subject to a 30 day delivery policy. Ofcom proposes that BT should publish a KPI showing the percentage of DMAs that are completed within 30 days for all providers including BT. BT should publish the total volume of DMAs on which this measure is based. The volume of DMAs carried out by BT and by each of the "top 10" providers should not be published but should be provided to Ofcom separately.

Frequency of publication

5.28 Ofcom proposes that the data for these KPIs should be published quarterly.

Flat Rate Internet Access Call Origination (FRIACO)

5.29 BT currently provides FRIACO at the local exchange (DLE FRIACO) and tandem exchange (Single Tandem (ST) FRIACO). Volumes for ST FRIACO are low and therefore Ofcom does not propose that BT should include KPIs for ST FRIACO as the data would not be statistically meaningful.

5.30 There is a close relationship between the supply of FRIACO services and competition in the narrowband unmetered Internet termination market. The ability to compete in the unmetered Internet termination market is highly dependent on the level of utilisation that can be achieved on a Communications Provider's FRIACO network, and also on the speed at which it can respond to changes in demand. Both of these are affected by the speed (and the confidence in the speed) at which orders can be provisioned.

5.31 FRIACO is both an Interconnect circuit (and therefore measurement of the performance of the circuits needed to support FRIACO is required) and a product on its own (hence the proposals for a separate KPI). FRIACO is one type of Interconnect circuit that BT buys from itself and therefore it is possible to provide an explicit wholesale comparator.

5.32 In the July Consultation, the Director proposed that a priority KPI for the FRIACO product would be the "percentage of orders provisioned on time", to be split between new routes and route augmentation. In view of the fact volumes of new provisioning may diminish but that there is likely to be substantial switching between suppliers, Ofcom proposes that the KPI should include new routes and route augmentation.

KPIs proposed for FRIACO

Publication requirement

5.33 BT provides FRIACO to its retail arm on the same basis as it supplies it to other providers. Ofcom therefore proposes that BT should publish the proposed KPIs as:

5.34 As there are only a few providers using FRIACO in any volume, BT will not be required to publish a disaggregated figure for the "top 10" providers.

Percentage of orders provisioned on time

5.35 Ofcom proposes that BT should publish a KPI showing the percentage of orders provisioned to CDD for all routes (including new routes and route augmentation).

5.36 Ofcom also proposes that BT should publish the total volume of orders provisioned. The volume of orders provisioned for BTs retail arm should not be published, but should be provided to Ofcom separately.

Average time to restore service

5.37 Ofcom proposes that BT should publish a KPI showing the average time to clear faults. This should be measured as the average time in hours between when the fault is reported and when service is restored, excluding any parked time.

5.38 Ofcom also proposes that BT should publish the total volume of faults on which this measure is based. This is currently the total number of Faults registered during the Reporting Period. The volume of faults for BTs retail arm should not be published, but should be provided to Ofcom separately.

Frequency of publication

5.39 Fairly long maximum delivery timescales apply to the provision of FRIACO. This is 65 working days for new routes on existing transmission and 25 working days for augmentation. For this reason, and because volumes are low, Ofcom proposes that the FRIACO KPIs should be published quarterly.

Rationale for selection of specific KPIs

5.40 As mentioned at paragraph 2.10 above, in accordance with section 49(2) of the Act Ofcom considers that the proposed KPIs are objectively justifiable because they have been selected to detect where there may potentially be discrimination in the Quality of Service provided. They also reflect key business processes which In Ofcom's view are important in the promotion of competition. The ability of competing providers to address the business and retail wholesale access markets depends critically on the availability of, and Quality of Service provided for Wholesale Line Rental. BT is the only provider able to provide Interconnect circuits, which are particularly important to smaller operators. The ability to compete in the unmetered Internet termination market depends on utilisation of the provider's FRIACO network and the speed at which it can respond to changes in demand, thus transparency of the Quality of Service provided is paramount.

5.41 It is Ofcom's view that the individual KPIs selected reflect processes that have a significant impact on the customer experience on the end-user. For example, if there are problems with BT's ordering process, then its competitors will experience a high level of order rejections which can lead to a loss of customers, which is particularly important when BT's competitors are offering a new service ie WLR. Speed of response at which orders are provisioned is also crucial for both new and established products as it will affect the speed at which BT's competitors can respond to changes in demand. Ofcom' therefore believes that transparency as to the quality of the service provided in these areas is key.

5.42 BT's competitors have to process orders for WLR through BT's gateway, which BT's retail arm does not. As gateway availability is therefore crucial, a KPI Is being proposed.

5.43 KPIs are also proposed which relate to the speed at which faults are repaired/service restored. Excessive fault clearance times may result in BT's competitors experiencing a high level of churn in their customer base and may indicate potential discrimination in favour of BT's retail arm - transparency is also therefore key in this respect.

5.44 Ofcom considers its proposal for a KPI for DMAs (part of the operational management of the Interconnect circuit product) is justifiable as BT's competitors consider visibility of the time taken by BT to complete DMAs for its own services is crucial for determining whether discrimination may exist.

5.45 Ofcom considers that the proposed KPIs do not discriminate unduly against BT. Although an equivalent condition is not proposed for Kingston, it does not unduly discriminate as the condition only applies where there is sufficient demand for the wholesale service in question such that the data provided will be statistically meaningful.

5.46 Ofcom considers that the KPIs are proportionate to what they are intended to achieve. Publication is only required where wholesale remedies have been imposed following the Fixed Narrowband Review, where BT is found to have SMP in the relevant markets and where the demand for the wholesale product or service is sufficient that the data provided would be statistically meaningful. BT is not required to publish each KPI for each product, nor is it required to drill down to a high level of granularity eg to provide a breakdown of order rejection codes (although Ofcom would expect BT to be able to justify a high level of order rejections in the event of a complaint). For established products, namely interconnect circuits and FRIACO, BT will be required to publish the two pivotal KPIs, namely the percentage of orders provisioned on time and the average time to restore service.

5.47 Ofcom considers that the measures are transparent as the requirements are clearly set out in the draft Directions and are further explained under the individual product areas ie WLR, Interconnect circuits and FRIACO. Ofcom also explains the reasons for the different frequency of publication requirements. For example, FRIACO is subject to maximum delivery timescales that would render it impractical to require monthly reporting and the low volumes associated with the product would make it difficult to obtain a statistically meaningful sample in a shorter reporting timeframe. The proposed reporting requirement for FRIACO KPIs is therefore quarterly.

5.48 Ofcom has considered its duties under section 3 of the Act and all the Community requirements set out in section 4. For example, the requirement for consistency is met by selecting one set of KPIs across all products and services, except where there is an objectively justifiable reason for doing otherwise. The KPIs are targeted at key business processes, rather than applying across the board. Transparency is provided by ensuring that all KPI information that is not commercially confidential is published.

5.49 Ofcom has also had regard to its duties under section 4 of the Act, in particular the requirement to promote competition. Ofcom considers that its proposals promote competition amongst providers of electronic communications networks and services as the KPIs are designed to ensure that alternative providers have an equivalent opportunity to compete with BT.


Back to top Back to top


Further information

Help

Keep up-to-date