IOG Meeting Overview - August 2008

The fourth IOG meeting was held on 5 August.  This overview summarises matters considered by the IOG at that meeting. 

 

Industry Perspective

Martin Wylie, CallPlus CEO and Scott Bartlett, Orcon CEO, provided perspectives on the impact of operational separation on their respective companies.  They both spoke about their expectations to be treated increasingly like customers in an operationally separated environment, as well as their expectations of the IOG and its role.

Ralph Chivers, Telecommunications Carriers Forum (TCF) CEO gave an overview of the TCF’s role, and provided feedback on how industry participants saw Telecom progressing under operational separation and the industry expectations of the IOG.

 

Paul Reynolds, Telecom CEO, provided his perspective on operational separation and its impact on Telecom and the industry, and on the British Telecom separation process.

 

Update on separation obligations

The majority of Telecom’s Undertakings came into effect on 1 July (other than Schedule 1 milestones which have future deliverables).  The Support Office is monitoring Telecom’s ongoing compliance with these obligations in accordance with the IOG Audit and Assurance Plan and will provide regular updates to the IOG on its findings. 

The following separation obligations were considered by the IOG at their August meeting. 

 

Update on customer service address classification breach

The IOG considered Telecom’s failure to provide the Minister of Communications with the method by which Telecom will classify customer service addresses into Zones 1, 2, 3a and 3b by 30 June 2008.  The IOG considered that the breach was unintentional and noted the progress being made to rectify the breach. 

Key Performance Indicators (KPIs)

Telecom presented further information on proposed KPIs measuring Telecom’s compliance with the Undertakings and progress toward compliance.  There was discussion on the need for KPI data to evidence material trends, demonstrate equivalence and focus on areas that are meaningful and important and/or high risk in the context of Telecom meeting key Undertakings requirements.  Some changes were recommended, and consultation with Telecom is continuing with a view to Telecom providing revised KPIs to the IOG at its October meeting.

Trading and written arrangements

Telecom has submitted to the IOG a number of trading and written arrangements which are required to be in place from 1 July.  The IOG noted that the extent to which these arrangements are complete, meets the requirements of the Undertakings, and the implementation of the arrangements, will be reviewed by the Support Office as part of the planned trading arrangement assurance review due to be performed later this year. 

Chorus legal and regulatory resources

Employees providing legal or regulatory advice to Chorus in respect of relevant access network services are required to work solely for Chorus by no later than 1 July.  The IOG noted that at 1 July, Chorus had its own legal and regulatory teams in place.  Further assessment is required to validate that legal and regulatory advice to Chorus in respect of relevant access network services is provided solely by way of this team. 

Wholesale relevant services on website

Wholesale is required to publish a list of all relevant wholesale services that it makes available to service providers on its internet site.  The IOG noted that wholesale relevant services are published on the Wholesale public internet site. 

Commercial policy of general application

Telecom submitted to the IOG a register identifying commercial policy of general application across Telecom that could materially impact on the provision of relevant services.  The IOG Support Office has requested Telecom to refine the register to identify those policies that are likely to have a material impact on the provision of relevant services.   

Processes for Chorus relevant services and/or the access network requests

Chorus was required to establish a process for making, considering, advising and implementing decisions about requests in respect of relevant network access services and/or the access network whereby all requests are made using the same request form, and the process is substantially the same, for all persons who have or seek access to relevant network access services.

The IOG noted that service order, provisioning and activation processes for relevant network access services will be the subject of an assurance review by the Support Office during August and September.   

 

Consultation with service providers about which unit they prefer to deal with

Telecom was required to consult as soon as practicable with service providers about whether they would prefer to deal only with Chorus or the Wholesale Unit in respect of all of the relevant services that the service provider purchases from Telecom.  The IOG noted that following consultation, Telecom has determined that there is no apparent support from service providers for a One Desk facility, and has announced that it will not be developing a One Desk facility.   

Update on equivalence milestones (Schedule 1)

The IOG considered that in respect of Schedule 1 milestones due in July, Telecom has met the requirements with regards to vendor or service supply contracts for:

• the Sales Order Management component of the Order Management EOI building block in accordance with the UCLL migration plan
• the Sales Order Management component of the Order Management EOI building block in accordance with the BUBA and EUBA migration plan
• the Inventory Management EOI building block in accordance with the BUBA and EUBA migration plan
• core capability for Retail Primary Line Voice in accordance with the PSTN migration plan.

The IOG noted ongoing work by the Support Office to confirm that the Inventory Management statement of work satisfies the requirements of the UCLL migration plan for the Chorus Inventory Management EOI building block (required 1 July).

 

The IOG also noted that as required by the UBA STD that the BUBA service launched on July 8 and that the EUBA 40/90 kbps service soft launched on July 29, and noted ongoing assessment by the Support Office with regard to these STD requirements.

 

The IOG considered the status of other Schedule 1 milestones due by the end of September, and noted that Telecom reports a lack of contingency within the delivery plan for the EUBA 40 kbps and 90 kbps full launch due 23 September.  Telecom has also reported an issue relating to the timing of technology selection for the Workforce Management System.

 

Assurance reviews

The IOG noted the ongoing assurance work by the Support Office to assess Chorus and Wholesale’s incentive arrangements.

The IOG also noted the ongoing work by the Support Office to assess the effectiveness of Telecom’s overall Telecom compliance framework, noting that some core elements of the framework are not yet implemented, and until they are business units will not have processes in place to provide long term assurance of compliance.  The IOG also noted that Telecom is working to finalise guidelines for business unit investigators to ensure reliable, complete and consistent whistleblowing investigation processes across business units.

 

Whistleblowing

Based on IOG Support Office investigations to date, the IOG resolved that there were two trivial breaches of the Undertakings.  The trivial breaches involved:

-         the disclosure of Wholesale customer confidential information to Retail by Chorus due to the incorrect placement of Wholesale service orders in a Retail work queue; and

-         the temporary ability for some Telecom people to be able to access information online on projects undertaken by Technology & Shared Services for Chorus and Wholesale, which may contain Wholesale and/or Chorus commercial information.

The IOG noted that the Support Office is investigating the failure to publish Radio Communication (Non-mobile) Co-Location on the Chorus website until 8 July. 

Service Provider complaints

The IOG deferred finalising its draft Initial Assessment on a complaint about Wholesale UBS and Telecom Retail broadband promotions, pending a response to the draft assessment from the complainant.  

Other matters considered by the IOG

Amended wholesale asset influence policy

Wholesale is required to have sufficient influence over Telecom network assets that it does not control and that are used to provide relevant wholesale services (excluding assets controlled by Chorus).   In March 2008, the Telecom Board approved a Wholesale Asset Influence Policy.  In June 2008 the Policy was amended to increase the network assets controlled by Wholesale.  The amended Policy has been submitted to the IOG.  The IOG noted that the Support Office will review the implementation of this policy, and the requirement for any associated trading arrangements. 

Glossary