IOG Meeting Overview - May 2009

    Milestone Status Update

    The IOG considered the status of milestones due during the period 1 January to 31 March 2009 and Telecom’s progress towards meeting the milestones due during the quarter 1 April to 30 June 2009. The IOG also reviewed a status update on issues outstanding from the previous quarters.

    1 January to 31 March 2009
    Telecom has reported that all milestones have been met for this quarter. The IOG agreed that required milestones have been met with the exception of 8.1G, clause 66.5 and compliance with UBA Backhaul STD as discussed below.

    Key milestones met were

    • EUBA 180 kbps delivered
    • Detailed design for Chorus Inventory management
    • Primary Line Voice trial – the Retail voice service delivered over EUBA without POTS
    • Pilot of B2B and Online Portal for UCLL commenced
    • UCLL and UCLL Co-location full launch
    • Physical accommodation separation of all Chorus employees completed

    The IOG noted that the Support Office are awaiting certification for UBA Backhaul. The expectation is that it will be provided in due course with no issues, however, until received, this milestone will remain outstanding for tracking purposes.

    BUBA/EUBA Pilot
    Milestone 8.1 G (Tracking Milestone) B2B and Online Portal pilot for BUBA/EUBA pilot was due 31 March. However at the last meeting Telecom signalled that this was the subject of a variation request which, if approved, would see this milestone being replaced by two new tracking milestones;

    • 31 March 09 Fault Management design complete and
    • 30 June 09 Fault Management build complete.

    The IOG noted that variation has not yet been approved by the Minister. Accordingly the Support Office does not consider that this milestone has been met. If the variation is not approved, failure to meet this milestone will not be a breach as the milestone is Tracking only. However, the IOG resolved to raise an Issue of Concern with the Telecom Board with respect to clause 79.1(j) around the ability of Telecom to meet future related milestones.

    Wholesale IP Interconnection Plan
    Clause 66.5 requires Telecom by 1 February 2009 to develop and publish on the Wholesale web site, a plan for delivery of the IP Interconnection for Voice Service and IP Interconnection for Virtual Private Network Service. The IOG noted that Telecom Wholesale have provided the plan however believe it did not contain sufficient level of detail.  Telecom Wholesale agreed to provide more detail and a list of expected tasks to be completed and the IOG noted that a revised plan was received which was considered acceptable. The IOG resolved that the failure to publish an acceptable plan is a trivial breach.

    Issues outstanding from previous periods
    The IOG noted outstanding milestones and other matters from previous periods as:

    • DSTN (as described below),
    • plan for system separation which will be subject to a variation request (see below)
    • UCLL Backhaul soft and full launch which cannot be certified as complete as there are no Service Providers interested in taking up the service at this stage.

    Schedule 1 16.1C DSTN
    This milestone requires that the Retail units will Withdraw Service for DSTN Services. Prior to the end of 2008, Telecom reported that it was likely that DSTN would not be withdrawn from one customer prior to the required date. Subsequently Telecom reported that all required services had been withdrawn with the exception of the circuits from the customer referred to above. The Support Office are reviewing to confirm that all required circuits have been withdrawn. A report will be provided to the next IOG meeting.

    9.3 (e) (iii) Requirement to separate shared systems information
    The IOG noted that Telecom have submitted a revised plan and have indicated that they intend to consult with the Government around a variation request in relation to shared systems and data separation.  The IOG requested the Support Office to continue to closely monitor this milestone.

    The resolution of other previously outstanding issues was considered and is summarised below:

    Schedule 1 Milestone 11.1D Unmet Broadband Demand
    This milestone requires Telecom to have policies in place which require that decisions to install broadband services will not take into account whether such service requests are made by Service Providers or Telecom Business Units. The Policy has now been received and the IOG found Telecom to be compliant.

    Schedule 1 Milestone 10.1 B UNS over Ethernet available to Telecom and Service Providers
    The milestone requires UNS (over Ethernet) to be available to Telecom Business Units and Service Providers.  Telecom have provided evidence that they have delivered a product that is called HSNS over copper.  Telecom have now provided sufficient evidence to satisfy the IOG that the HSNS product offers the same service as was anticipated by the UNS product. Essentially HSNS includes a base product that would be considered UNS, as well as additional features that are not required by the base UNS product. The IOG therefore consider Telecom to be compliant with this Milestone.

    BUBA
    Telecom Wholesale have now provided certification that all STD requirements have been met.

    Forward looking period - 1 April to 30 June 2009
    The IOG considered the status of milestones in the next period as reported by Telecom.

    Six milestones are due in this period including delivery of UBA Backhaul full launch, end customer trials for new Retail Broadband service, PSTN milestones progress report and withdrawal of further legacy data services. In addition there are two significant milestones due against which Telecom is reporting significant risk:

    • Wholesale Inventory Management Detailed Design document due 30 April. (8.1F)
    • Chorus Opt-in and December 2009 requirements due 30 June 2009 (5.1 J)

    Detailed briefings were given to the IOG by Telecom’s General Manager Separation Office, including presentations on Chorus Front End Equivalence (FEE) and the Retail Broadband Service External Trial.  Following the FEE presentation the IOG resolved to write to Telecom identifying the Chorus FEE issue is an Issue of Concern and noting that the delay in meeting the June milestone (expected to be met in July) whilst currently acceptable to the IOG raises a concern with respect to Telecom’s ability to complete the implementation of Netcracker and meet schedule 1 clause 5.1K enforceable milestone.

    Audit and Assurance Reviews

    There were no separate Audit and Assurance reviews completed for the period 1 January to 31 March 2009. Telecom Internal Audit have a number of reviews underway which will be provided to the IOG when completed.

    Complaints and Honesty Box Summary

    Service provider complaints
    No complaints have been received by the IOG from Service Providers during the reporting period and there are no outstanding complaints from Service Providers to the IOG. 

    Telecom has notified the IOG that it has received complaints from two Service Providers alleging that Loyalty Offers made by Telecom Wholesale in December 2008 and March 2009 are discriminatory.  Since the IOG meeting Telecom has provided its investigation report to the IOG Support Office which is reviewing Telecom’s findings.

    Non-trivial breaches
    The IOG Support Office did not identify any non-trivial breaches from the Honesty Box submissions during the reporting period.

    Investigations – overview
    Overall, Honesty Box submissions over the January to March 2009 period reflected the higher ‘average per month’ following the introduction of the WAVE reporting (for reporting Retail activity on Wholesale accounts).

    Submissions in February dipped as expected in comparison to January due to both fewer working days and the catch-up of prior months WAVE related submissions that was seen in January.  The March volumes show a slightly higher than expected number of submissions, with the lead contributing factors being the automation of Short-lead reporting into the Honesty Box and, to a lesser extent, Gen-i’s introduction of WAVE. 

    Honesty Box Submissions

    The distribution of submissions across business units continues to be very constant with Retail accounting for 86.6% of the submissions for the eight months August 2008 to March 2009; followed by Wholesale 5.2%, Chorus 2.3% with the remaining Business Units under 2% each. 

    Consistently, half of the submissions relate either to Short-leads (refer section 3 below) or what is termed “accidental action with no on customer impact”.  The latter is usually a service order processed on a Wholesale account in error, the CSR realising this and deactivating the service order straight away with no customer or Service Provider impact, and no advantage to Telecom.

    The percentage of submissions that are compliant versus trivial or de minimis continues to be strongly on the compliant side at 66% (1 July to 31 March 2009), versus 11% being adjudged trivial or de minimis.  The remaining large percentage is Short-leads (17%). 

    Industry Perspective

    Mr John Furmston, Director of British Telecom’s Equality of Access Office (EAO) provided the EAO’s perspective on their role. 

    Mr Jamie Baddeley, President of ISPANZ provided feedback from ISPANZ, members about Operational Separation and Telecom’s Undertakings compliance.

    Ms Anita Mazzoleni and Mr Peter Taylor from the Commerce Commission provided a Commission perspective on Operational Separation and the IOG’s role.

    Key Performance Indicators (KPI's)

    The Telecom KPI report to 31 March 2009 had not been received in time for analysis at this meeting and will therefore be tabled at the next IOG Meeting on 10 June.

    Other Matters Considered

    Commerce Commission Protocol
    The IOG approved a revised protocol to be forwarded to the Commission for comment.

    IOG Annual Report
    Good progress continues to be made with the IOG Annual Report. 

    IOG Evaluation
    The IOG approved the annual evaluation process.

    Service Level Agreement (SLA) reporting
    The IOG are required to review Telecom’s performance against service level agreements in respect of Relevant Services (Undertakings Clause 79.1 (f)).   Both Chorus and Wholesale produce SLA reporting in relation to STD requirements and both make these reports available on their respective websites.

    It was resolved that the Support Office will request Telecom to report to the IOG on an exception basis where it does not meet an SLA.

    Codes of Conduct
    The Commerce Commission confirmed they were satisfied with the legal advice the IOG received on the outstanding issue with the Codes.

    CEO Directive
    Reviewed the CEO directive dated 20 April 2009 and determined the directive did not indicate any breach of the Undertakings.  The IOG agreed to write to Telecom requesting that the IOG be updated on any matters which arise that may impact on the Undertakings (letter written subsequent to meeting).

    Post Meeting Communication
    The IOG wrote to the Commerce Commission and Telecom on 21 May outlining the key decisions made at the meeting.

    Letters of Concern have also been written to Telecom detailing the matters referred to in the Milestone Status Update.

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