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 national and international private enterprises and public sector users.  FCS is the largest trade organisation in the professional communications arena, representing the interests of around 350 businesses who supply B2B services nationwide.

We have asked members for their views on the areas Ofcom highlights in its letter, so this response reflects both the on-the-ground changes and the changes that the FCS team have noted.

General Engagement with Openreach

The FCS management team has been impressed with efforts made by senior Openreach staff to include FCS and its members in consultations and areas that may affect members. We have worked with Openreach to help our Board to Board meetings become an effective tool for exchange of information and views and hope to continue to build on these this year.

Following an FCS regional meeting to which Openreach were invited, we were able to set up a small working group that looked at ways of involving FCS members in the FTTP roll out and this also led to working closely with Openreach to identify standard products that could be used with the DCMS gigabit voucher scheme.

Member feedback suggests that interaction at senior levels has been very limited, but with middle management it could probably be described as broadly unchanged. One member has noted an improvement in the level of information provided during the escalations process, whilst another has commented:

Since having the GoToAssist option, Provisioning have found communication with Openreach vastly improved.  We also then have a copy of the e-chat conversation which in some circumstances has been helpful.  At a guess it would only be 1 in 20 where we would need to request a team leader/senior person.

Consultations and the Consultation Process

We commented in our response to Openreach’s consultation on process that we were concerned that Openreach raising potential changes with volume CPs on a bilateral basis could lead to changes that may impact the B2B market without input from FCS members. We are concerned that there is potential for members to be squeezed out of opportunities as the market become increasingly vertically integrated.

Openreach contacted FCS directly about the Long-reach VDSL consultation and presented to members at one of our monthly meetings. The FTTP consultation was shared at a Board to Board, which gives us the opportunity to gather and input the views of our members. Nevertheless, we have received this view from one of our members:

We have had no invitation from Openreach to engage directly with them in any consultation in the past 12 months.  Whilst we are very happy to have our interests represented through FCS, Openreach does not appear to be seeking the views of smaller CPs.  This is potentially damaging to the competitive and innovative market that exists in the B2B channel if products and services developed by Openreach are shaped only by a small number of large-scale suppliers.  Even if we were limited to online surveys to take our input that would be an improvement, and provide us with some opportunity to make suggestions such as offering some FTTP variants which are better suited to business needs.

Investments

Whilst maintaining the copper network during its remaining lifetime we think it is vital that Openreach moves investment towards full fibre provision. It is important that Ofcom and Government offer incentives to Openreach to invest and that these investments are monitored accordingly.

Conclusion

The FCS feels that monitoring is not the best way of creating adequate incentives for BTG. We believe that “separation” should mean that the infrastructure ownership is moved from BT Group to Openreach, leaving divesture as the ultimate threat Ofcom holds

Whilst we welcome the early start that Ofcom has made on ensuring that improvements in the Openreach operating model are generated and apparent, it is still early days and it is difficult to comment on change retrospectively as observing it has not been front of mind from March last year. It would be interesting to understand the baseline that Ofcom is using for monitoring change and improvement and what KPIs are being measured against so that more substantive answers can be provided going forward.

We would welcome the opportunity for formalised meetings with the OMU so that we can fully represent the interests of our members, new entrants and SMEs.