Introduction

The Federation of Communication Services represents companies which provide professional communications solutions to business users.  Our members deliver telecommunications services via mobile and fixed line telephony networks, broadband, satellite, wi-fi and business radio.  Our members’ customers range from SMEs, home-workers and micro-businesses up to the very largest private enterprises and public sector users.  FCS is the largest trade organisation in the professional communications arena, representing the interests of around 350 businesses which supply B2B services nationwide.

Openreach independence

• Whether Openreach is acting with greater independence from BT

The appearance given by Openreach is that it is growing in confidence as an organisation that is in charge of its staff and operations. We have seen changes in the way that it manages its contractors, for example, that work to the benefit of CPs.

• The extent to which Openreach takes account of its customers views and requirements when developing its plans.

On a day to day level, Openreach is getting better at informing stakeholders of plans. Following some pressure from Industry, Openreach now reports regularly on new trial proposals and generally avoids introducing new systems or processes without adequate industry notification. It needs to always be aware of changes that it sees as internal which may actually affect industry, such as the recent reorganisation of geographical management regions.

Openreach’s engagement with its customers

• Openreach’s approach to treating all its customers equally

We raised our concerns about possible equivalence issues in the draft Fibre Special Offer volume trail with the CMO and as a result Openreach revised its offer to ensure that CPs of all sizes could benefit from the discounts offered. We have had direct discussion with Openreach over the Bulk Migrations piece and await commercials to confirm that smaller CPs are not disadvantaged.

We believe that Openreach is committed to equivalence but it needs to be front of mind at all times.

• The regularity and effectiveness of senior engagement with Openreach customers

We continue to hold meetings between FCS Board members and Clive Selley and the senior team. However, whilst the intent is that these are quarterly, it is a constant struggle to get the dates agreed and in the diary. We wonder whether the volume providers have the same experience.

• The responsiveness of Openreach to your queries or concerns, including how Openreach has dealt with any complaints or concerns raised

There is no sense that Openreach engagement with our members has changed significantly, though if we direct a member to a particular member of staff for assistance they are always dealt with promptly and efficiently.

We raised a specific issue with Openreach over the announced increase in the charge for CLI, just at the time when it was becoming mandatory under Ofcom requirements. We supplied examples of the increased costs to members and, as a result, Openreach significantly reduced the amount of the increase. This sort of positive response is of course to be welcomed.

• How Openreach has managed consultations, and the extent to which you felt your views were heard

The major consultation has been the WLR withdrawal document. The team running this have made specific efforts to ensure FCS engagement, both at the working groups and via bilats. This is welcomed, and we have no current concerns that we are not being listened to (see also “delegated authority” under Issues below).

Issues 

• Annual Plan

We have raised with Openreach our desire to understand more about the Annual Plan and Budget and how we can comment on it. The answer supplied is that our Board to Board meetings provide this opportunity, yet we have never seen a draft document to comment on.

At the recent FTTP launch meeting, when questioned by a CP about budget, Openreach was only able to comment that they had budget for the first 3m premises. We would like to have confidence that the whole project for FTTP roll-out has been budgeted for and will be fully funded.

• Delegated Authority

As the WLR consultation was launched, Openreach began talking about “delegated authority” which it saw as the means by which resellers would operate via ISPs in the new world. It transpired this amounted to a url that CPs could use to view order journeys direct. We have pressed on this as we feel it is vital that smaller CPs have systems in place that allow them to deal with Openreach directly in the order and fault journeys that they do currently. 

Openreach have agreed to “re-open” the reseller working group (part of the WLR IWG) and this will be given more focus. An interesting part of our research on how to manage this was that we learned that BTWs front desk staff are Openreach agents, which presumably Ofcom is comfortable with.

• Ownership of assets

We have confirmed with Openreach on various occasions that they do not own the network or assets and these remain with BTG. We were surprised to hear at a recent meeting with the CAO the view stated that the assets sit with Openreach. We believe that this is something that should be understood throughout BTG and Openreach.

Conclusion

On a day to day level the FCS feel that we have an excellent relationship with Openreach and an ability to get our voices heard. As stated above, although the Board to Board meetings are always productive, we find them problematic to arrange and would like to understand if there is an underlying issue with this.

Openreach has an extremely busy and complicated programme of work ahead over the next six years and we look forward to continued close engagement with them on behalf of our members.