Physical Infrastructure Access (PIA) - Openreach · This document is the Internal Reference Offer for the Network Access product called Physical Infrastructure Access (PIA), also

Issue 2 – 16.5.13 Issued by Openreach © British Telecommunications plc 2013 Page 1 of 28

16 May 2013 – Issue 2

Physical Infrastructure Access (PIA) Openreach Internal Reference Offer


1. Introduction Background to this Internal Reference Offer (IRO) This document is the Internal Reference Offer for the Network Access product called Physical Infrastructure Access (PIA), also known as Duct and Pole Sharing. This product has been launched by BT as a standalone product and is offered to external Communications Providers (CPs) by BT’s functionally separate organisation Openreach. PIA allows external CPs to gain direct access to BT’s duct and poles so that they can deploy their own Next Generation Access (NGA) networks using the physical infrastructure of BT’s network. IROs are intended to identify differences between wholesale Network Access products sold externally to CPs by BT and those sold internally to BT’s downstream operations. However,Openreach’s PIA product is not purchased by BT downstream, and hence it is not possible to make any comparison with the externally available product at that level. Instead this document focuses on Openreach’s use of its physical infrastructure (ducts and poles) for the purpose of deploying an NGA network which is used in the provision of Openreach’s Generic Ethernet Access1 (GEA) product, and in so far as this is possible, compares this to the externally sold PIA product. This is the appropriate comparison as the PIA product has been defined as a regulatory remedy for NGA network deployment and not for any other purpose. The Role of Openreach Openreach is a highly regulated and functionally separate organisation within BT designed to provide specified Network Access services, often referred to as “economic bottleneck” services, in a non-discriminatory way through an obligation to sell those products on an Equivalence of Inputs (EoI) basis. The EoI obligations placed upon Openreach in respect of particular products or services, mean that those products or services must be provided to all CPs (including other parts of BT) on the same timescales, terms and conditions (including price and service levels) by means of the same systems and processes, and includes the provision to all CPs (including other parts of BT) of the same Commercial Information about such products, services, systems and processes. In particular, it includes the use by BT of such systems and processes and with the same degree of reliability and performance as experienced by other CPs. In this context “the same” means exactly the same subject only to:

• Trivial differences; • Such other differences as may be agreed by Ofcom in writing; • Differences relating to the following:

o Credit vetting procedures; o Payment procedures; o Matters of national and crime-related security, physical security, security required to

protect the operational integrity of the network and such other security requirements as agreed between BT and Ofcom from time to time;

o Provisions relating to the termination of a contract; and o Contractual provisions relating to requirements for a safe working environment; or

1 This is also referred to as VULA or Virtual Unbundled Local Access by Ofcom in their 2010 Wholesale Local Access Market Review final statement.


o Such other differences as are specified elsewhere in the Undertakings, including where Commercial Information is provided in accordance with the Undertakings to any of the nominated individuals, and individuals occupying the roles and functional areas (and their relevant external advisers, subcontractors and agents) listed in Annex 2 to the Undertakings.

The EoI regulation of Openreach products such as Local Loop Unbundling (LLU), Ethernet Access Direct (EAD) and Generic Ethernet Access (GEA) fits within this regulatory model. These are the points of regulation in the telecoms value chain which ensure vertical non-discrimination within the BT organisation. Brief History of PIA For reference PIA was introduced by regulation in 2010 in order to enable CPs to build high speed broadband networks by using access to Openreach ducts and poles between an end-user and an appropriate NGA node (or similar) in the Openreach network. The key dates in the products development are as follows: October 2010 PIA introduced as a remedy by Ofcom in the Wholesale Local Access

Market Review. January 2011 Openreach publish PIA Draft Reference Offer (DRO) for further consultation

with CPs, OTA and Ofcom. March 2011 Openreach ready to start PIA trials.

July 2011

First customer signs up for PIA trial.

October 2011 New PIA prices and pricing structure published by Openreach.

November 2011 First End-user connected.

November 2011 Tactical automation delivered.

November 2011 Formal Reference Offer published including revised Contract, Pricing, Process and Product documentation (“Soft Launch”).

Currently, there are four active CPs (approximately two more in pipeline) taking part in four small scale trials and at this stage only one trial scheme has so far completed and connected end-user customers. Strategic automation has been defined and is targeted to be delivered in Openreach’s Equivalence Management Platform (EMP) Release 2000 in summer 2012 (subject to sufficient customer demand). It should be noted at this time that there is a material difference in scale for PIA and GEA products and this is a significant factor to consider. The GEA service is delivered by an integrated and large scale national programme within Openreach which has been designed to achieve a target of 66% coverage of UK premises by 2014. It is this scale of committed roll-out by Openreach and its contractors, and the financial and operational risks borne by Openreach, which enables and drives efficient delivery of the EoI product and hence supports its availability through the Openreach EMP to any external CP. Openreach has also been consistently clear in public and with stakeholders that its investment in NGA is contingent on an integrated and efficient operational model and that there is no commercial or operational scope to build inefficient internal hand-offs into the production process. Ofcom has previously consulted on these matters and recognised the importance of operational


efficiency for Openreach in both the Fibre to the Cabinet (FTTC) and Fibre to the Premise (FTTP) Undertakings variations granted in 20092 and 20103. Contents of this IRO As stated above this IRO is based on a comparison of the PIA product and specific elements of the GEA product and does not cover other Openreach products, although typically all products use physical infrastructure to some degree as part of the value chain. The IRO covers the following:

• Section 1 - provides supporting context and background information on IROs, PIA and GEA.

• Section 2 - contains a description of the three relevant Network Access products (GEA-FTTC, GEA-FTTP and PIA) including schematic diagrams and supporting information, and identifies which elements of the services can be mapped onto each other.

• Annex A - sets out the relevant conditions for a Network Access reference offer and compares appropriate processes and network components Openreach uses internally within the GEA service against the external PIA product.

• Annex B - summarises and compares GEA and PIA operational processes. • Annex C - contains an overview of relevant accounting and financial information. • Annex D - includes links to useful and related information, much of which is already in the

public domain and has been shared with CPs and other stakeholders via bodies such as the GEA Trialist Working Group (TWG), NGA forum, PIA Industry Working Group (IWG) and the Openreach website.

• Annex E - includes additional process documentation for GEA and PIA products. • Annex F - describes the OSI 7 Layer Network Model and its relationship to GEA/VULA. • Glossary - includes a summary of the abbreviations and acronyms commonly used in

relation to these products and services.

2 FTTC Variation - http://www.ofcom.org.uk/consult/condocs/fttc/statement/ 3 FTTP Variation - http://stakeholders.ofcom.org.uk/binaries/telecoms/policy/bt/fttp.pdf


2. Overview of Products

2.1 GEA FTTC - Schematic diagram

Figure: 1 Generic Ethernet Access over Fibre to the Cabinet (GEA-FTTC) is a basic connectivity service provided by Openreach on an EoI basis to enable CPs to offer Super-fast Broadband (SFBB) at up to 40Mbit/s downstream and 10Mbit/s upstream, plus multi-play services (e.g. voice, data and video) to residential and small business customers. GEA-FTTC is based on a fibre overlay to the existing copper network between the exchange and the street cabinet. Ofcom has coined the term Virtual Unbundled Local Access (VULA) to describe this type of unbundling where a single fibre based access infrastructure is electronically unbundled and made available to all providers on an equal and non-discriminatory basis. At present, there are two variants (Note: higher speeds to be introduced during 2012): o up to 40Mbit/s peak downstream - with up to 2Mbit/s peak upstream o up to 40Mbit/s peak downstream - with up to 10Mbit/s peak upstream These have a downstream prioritisation rate of up to 20Mbit/s or the actual achieved line rate whichever is the lower. Congestion can be managed by CP prioritisation of traffic on each line, and CPs can cap or set their own downstream line rates. The product design allows the CP to provide voice services over copper (via MPF or WLR) and fibre-based broadband services, or to allow one CP to provide voice services over copper via WLR while a second CP provides fibre-based broadband services. GEA was developed by Openreach to overcome the challenging economics of Fibre to the Cabinet (FTTC) investment by carrying out a single network upgrade at the PCP (connecting fibre to a secondary cabinet and installing DSLAM electronics there) and then providing open shared access to all CPs at a local handover point, thereby enabling them to benefit from the upgrade of Openreach’s infrastructure. The Network Access is shared at one layer above the physical layer at the Ethernet layer or “layer 2”. This is why it is referred to as “virtual unbundling”4.

4 See Annex F


2.2 GEA FTTP - Schematic diagram

Figure: 2 Generic Ethernet Access over Fibre to the Premises (GEA-FTTP) is a further way in which Openreach provides access to a virtually unbundled EoI connectivity service. This enables CPs to offer Super-fast Broadband (SFBB) at up to 110Mbit/s downstream and 30Mbit/s upstream, plus multi-play services (e.g. voice, data and video) to residential and small business customers. GEA-FTTP is based on deployment of a Gigabit Passive Optical Network (GPON); which is a fibre infrastructure deployed between the exchange and end-user. Unpowered optical splitters enable a single fibre pair to serve up to 32 homes and businesses. The splitter device is buried underground close to the premises being served, and fibres from the splitter are physically dedicated to an end user; whereas the fibre connection back to the exchange from the splitter is shared “virtually” between those users. From the communications perspective, fibre means that there is no distance-related limitation of the broadband service typically associated with copper. Moreover, as there are no active components in the external network with a GPON, it produces a highly robust and reliable service. In concept the regulatory approach to the virtual unbundling of a wholesale Ethernet product for FTTP is identical to FTTC, although the underlying transmission technology is necessarily different as explained above. Both technologies present a standard Ethernet interface at the end-user premises which enables the end-user to interface with a wide variety of customer premise devices as Ethernet is now a universally available standard for consumer equipment. The product also presents a standard Gigabit based Ethernet interface at the CP handover point. Currently there are a number of variants of the products and additional and higher speeds are planned to be introduced during 2012 which will enable consistency with the planned increases in speed for

Splitter(s)


FTTC products as well as extending the potential of the GPON infrastructure. Currently features include: o Up to 110Mbit/s downstream - with up to 30Mbit/s upstream o ‘Always on’ Virtual LAN (VLAN) lit fibre circuit connection from the exchange Optical Line

Terminator (OLT) to end-users Optical Network Termination (ONT) in their premises. o Enables up to two CPs to provide voice and data services to each ONT. o Prioritisation of traffic up to a pre-determined limit. o CPs can cap or set their own downstream line rates. The roll-out of FTTP infrastructure is currently taking place on a smaller scale than FTTC in the UK but 'Brownfield' and New Build sites along with potential Fibre Only Exchange areas (FOX) are all now anticipated deployment opportunities in the coming few years as part of the existing two-thirds coverage plans of Openreach as well as in BDUK funded areas.


2.3 PIA - Schematic diagram

Figure: 3 Physical Infrastructure Access (PIA) is a product which enables CPs to utilise Openreach’s network infrastructure in ways which support their investment in new Next Generation Access networks and for no other purpose. CPs are able to rent access to duct, poles, chambers and a range of other ancillary services as required to link to their own infrastructure. For pricing purposes duct is classified into different groupings: • Spine and Lead-in Duct - These are explained below and different prices apply for CP use. • Spine Duct - is further broken down for pricing by the number of bores along a duct route;

single duct bore, two bores and three or more bores and different prices apply, as for lead-in duct.

There are a number of different aspects to the product range:

The pole sharing product allows CPs to attach their cables (and manifolds) to Openreach poles for the deployment of an NGA network..

Enables a CP to install their own sub duct (maximum diameter 25mm) within Openreach’s access duct for their own NGA deployment. Smaller diameter lead-in cable may be installed between the final distribution point and the end user.

CP POP or Openreach Handover Point or

Exchange

CP Core & Backhaul Network

PIA for SLU “backhaul” can use infrastructure between CP POP and cabinet

PIA for FTTP - can use Openreach duct, poles, chambers etc between CP POP and End User

New DSLAM cabinet SLU CP End User

For FTTC - SLU connection to EU provided over existing copper


• Spine Duct - This is the terminology used to describe the main duct infrastructure running from the serving exchange to a distribution point close to the end-user premises. Under the duct share product, CPs are granted a licence to install a sub duct, up to 25mm in diameter, for the spine part of their next generation access (NGA) network deployment within the Openreach access duct.

• Lead-in duct - This is the duct between the last distribution point and the end user premise. CPs cannot install sub duct but can install smaller fibre or co-axial cables or tubing to allow blown fibre to be deployed.

• Pole Access - Under the pole share product, Openreach will grant a CP a licence to attach and maintain a cable or blown fibre attachment or pole top equipment to one of Openreach’s existing poles in compliance with specified engineering rules and health and safety standards as part of their NGA network deployment. Pole access allows CP to use poles that provide the distribution to customer premises or carry cables between distribution points and the spine network. Some poles will provide both functions (for distribution and carrier purposes). A CP will be charged as appropriate for the CPs usage of the pole which may be to provide an attachment to a CPs individual customer or to provide an attachment for serving multiple customers, plus running cables up and down poles and fitting pole top equipment.

• Chambers - With the exception of in line splices and spine fibre cable coils, a CP must put their underground equipment in sub duct and joints (including splitter nodes, aggregation nodes and fibre DPs) must be put in a CPs own jointing chambers; this includes any splitter nodes that may fit in similar housings to in line splices. CPs need to do this to avoid congestion or disturbance within the Openreach network and vice versa. Openreach provides the outline sub duct, splicing and cable specifications for installation in ducts, joint boxes, manholes and poles as part of its contractual documentation.

• Other - there are a range of other ancillary services a CP can request including network information, duct unblocking, new infrastructure etc. All of these are charged separately and product, price and contractual information is available on the Openreach website5.

2.4 The Common Network Elements of PIA and GEA PIA can be purchased for use in the access network between an end-user and the CPs NGA point of presence (POP). In broad terms such CP POPs may be similar in distance from end-users as Openreach’s own NGA handover points and they do not need to be co-located. This boundary condition is required as PIA is not permitted for use to construct CP core or backhaul networks. For the avoidance of doubt CP usage to connect cabinet based NGA deployments and CP POPs is a permitted usage as this is within the access network (although it is often referred to loosely as “cabinet backhaul”). • FTTC - For CPs FTTC based deployments, at least part of the service continues to be

delivered over the copper network. In these scenarios only those Openreach duct routes or poles which link the CP POP to the vicinity of the cabinet (e-side) will form part of the PIA order. For the avoidance of doubt this IRO does not deal with any aspects of the use of duct by copper based services as these are covered by the appropriate regulation pertaining to LLU, WLR etc.

• FTTP - Such deployments are still in their early stages in the UK and hence it is difficult to fully predict their technical architectures and how they might utilise the Openreach PIA product. The anticipated usage is based on an all fibre service from CP POP to end-user (both e-side and d-side) which provides both voice and broadband data service.

Openreach does not consume PIA as an input into its GEA product. However there are network/process elements underlying the PIA product which are similar to those used within the GEA product. These are the occupation by fibre of spine and lead-in duct, poles, footway boxes and manholes, the manual processes carried out on the infrastructure (e.g. construction, provision,

5 http://www.openreach.co.uk/orpg/home/products/ductandpolesharing/ductandpolesharing/ductandpolesharing.do

http://www.openreach.co.uk/orpg/home/products/ductandpolesharing/ductandpolesharing/ductandpolesharing.do


repair, blockage clearance etc), survey, reservation, accreditation, access to the Exchange , planning and information provision. In Figure 4 below the common network elements are illustrated in purple. In pure physical terms these represent only a small part of the overall network infrastructure required for an NGA network deployment, being solely the occupancy of the duct and poles between exchange and end-user. All other access infrastructure required to build a next generation access network is outside of the domain of the PIA product and is provided either by Openreach as part of its GEA product build or by CPs as part of their NGA deployment.

DP

End-user

New DSLAM cabinet SLU CP

E side fibre D side fibre

Exchange or POP

3. Duct/poles/chambers occupied by d-side fibre (shown by purple dashed line) – typically this would only be used for an FTTP based NGA deployment, as Copper would be used for FTTC.

2. GPON Splitter in chamber eg for FTTP.

4 End-user final drop pole or lead-in duct can be used for FTTP. Existing copper would be used for FTTC.

1. Duct/poles/chambers occupied by e-side fibre (shown by purple dashed line) – typically this would be used for FTTC based deployment or as part of an FTTP NGA deployment.

5. Cablelink (required if CP wants to link duct to space in BT Exchange)

Fibre connection to cabinet

Figure: 4


Common Network Elements

GEA PIA

1. Duct, poles, chambers in the e-side network. • Identical for both

products.

• GEA uses same physical network as purchaser of PIA.

• Openreach installs up to 25mm sub-duct and optical cables for both FTTC and FTTP deployments.

• Purchaser of PIA has access to same physical network as GEA.

• CP is required to install sub-duct up to 25mm and optical cables for both FTTC and FTTP deployments.

2. Space in chambers. • Required for hosting

cables etc


• GEA uses chambers for hosting cable coils, in line splicing etc but also for housing GPON splitters and fibre distribution points in an FTTP deployment.

• Any new duct construction required

and break-in to the Openreach duct network is sub-contracted to Openreach’s civils contractor.


• PIA purchasers can lease space for hosting cable coils, in line splicing etc but all other joints (including splitters) must be located in CPs own chambers.

• Under PIA Openreach only permits in-line splices because of space and reliability concerns (if boxes get multiple visits to configure connections these extra interventions cause risk of damage). Openreach’s intention is to keep vulnerable plant separate to minimise risk to both parties. This is consistent with other European PIA offerings but will be under ongoing review in the PIA trial.

• Openreach currently offer a duct construction and break-in product (provided by Openreach’s civils contractor) to CPs, but have also recently introduced a new variant allowing CPs to use their own accredited contractor to carry out the work.

3. Duct, poles, chambers in the d-side network. • Identical for both

products.


• Openreach installs 25mm sub-duct and/or mini cable in smaller sub-duct sizes for FTTP deployments.


• CPs can install 25mm sub-duct (or smaller) sub-duct sizes.

4. Final drop or lead-in to end-user premises.


• The basic termination point/process will be the same for GEA and PIA purchasers.


• The basic termination point/process will be the same for GEA and PIA purchasers.

5. Access to the Exchange.

• GEA deployment uses same process to pull through cable directly into the exchange and connect to the optical distribution frame (ODF). GEA does not consume an exchange access product.

• CP can choose to use a CableLink product to connect its NGA network to space within a BT Exchange; or can choose to link directly into an alternative non-Openreach duct network or POP via a connecting footway box using its own contractor/personnel.


These common elements are analysed further in Annex A below by looking at the main dimensions of an external reference offer. Any differences are identified and explained further or referred to the relevant Annex for further information.


ANNEX A - NETWORK ACCESS USED BY OPENREACH’S GEA SERVICE 1. Standard Elements of a Reference Offer (a) a description of the Network Access to be provided, including technical characteristics (which shall include information on network configuration where necessary to make effective use of Network Access);

• This is detailed in Section 2 above. • PIA can only be used for the purposes of deploying a Next

Generation Access network. Hence only comparisons with the Openreach GEA service are provided in this document.

• Openreach’s GEA service uses identical infrastructure components as used by a PIA purchaser.

(b) the locations of the points of Network Access;

• Network Access is possible at all points in the Openreach network (subject to survey, obtaining the relevant wayleave/planning consents and for the prescribed purposes of building an NGA network).

• This element of the reference offer is identical for the GEA and PIA products.

(c) the technical standards for Network Access (including any usage restrictions and other security issues);

• Openreach applies the same standards to all infrastructure whether it is used for Openreach NGA deployment or a CP deployment (eg duct, fibre, pole regulations etc).

• This element of the reference offer is identical for the GEA and PIA products.

• Openreach also applies specific physical standards to cables (overhead and underground) for both GEA and CP’s installations in order to minimise damage and maintain safety. Openreach do not specify technical standards relevant to service capability to CP’s. See item (j) below.

(d) the conditions for access to ancillary, supplementary and advanced services (including operational support systems, information systems or databases for pre-ordering, provisioning, ordering, maintenance and repair requests and billing);

• Due to the very different stages of product life cycle and scales of operation between PIA and GEA, different external CP interfaces have been developed by Openreach:

o GEA is EMP based, and: o PIA is currently an electronic CRF based process with front

end automation and workflow. • Most infrastructure level internal work flows are governed and

managed by the same or similar systems such as Workflow etc once any initial activity has been triggered via EMP or an electronic CRF process. Jobs are passed to the relevant planner to progress.

• Openreach does not consume the individual elements of the PIA product internally and therefore does not use the external interfaces developed for CPs such as EMP or manual processes to deploy and operate its GEA service.

• Options to move to full EMP style development for PIA needs to be assessed as commercially viable and subject to reasonable demand.

• Openreach’s civils contractor permits Openreach access to an on-line system which enables direct checking of the status of works, estimated dates etc. For PIA, CPs will need to request information from Openreach.

• The target timescales for provision of the ancillary and supplementary services by Openreach’s supplier are exactly the same for both products.

• Further information is given at Annex B.


(e) any ordering and provisioning procedures;

• Openreach does not consume the elements of the PIA product internally and hence does not raise an internal order for duct/pole provision.

• In so far as Openreach’s supplier’s contract allows all requests for civil engineering work will be actioned through the same standard systems and processes for both GEA and PIA related work.

(f) relevant charges, terms of payment and billing procedures;

• Openreach does not consume the elements of the PIA product internally and hence does not raise an internal charge, have terms of payment or produce a bill.

• Also processes such as credit vetting which are applicable to an external customer and form part of the contractual terms are not applicable within BT as it is a single legal entity.

• Regulatory accounting will be addressed as described below in part (q). Further details are given as to how the common network elements of PIA are accounted for within the Openreach GEA business case in Annex C.

(g) details of interoperability tests; • Not applicable for passive infrastructure.

(h) details of traffic and network management;

• Not applicable for passive infrastructure.

(i) details of maintenance and quality as follows: (i) specific time scales for the acceptance or refusal of a request for supply and for completion, testing and hand-over or delivery of services and facilities, for provision of support services (such as fault handling and repair); (ii) service level commitments, namely the quality standards that each party must meet when performing its contractual obligations; (iii) the amount of compensation payable by one party to another for failure to perform contractual commitments; (iv) a definition and limitation of liability and indemnity; and (v) procedures in the event of alterations being proposed to the service offerings, for example,

In summary, tasks associated with construction and repair of physical network are carried out by Openreach’s supplier who are contracted to provide a large array of services to BT Group. Wherever appropriate exactly the same terms apply to work carried by Openreach’s civils contractor for PIA and GEA products. (i) There are no contractual provisions relating to these matters internally within Openreach. (ii) There are no contractual service level commitments internally within Openreach. (iii) There are no compensation schemes internally within Openreach. (iv) There are no legal liability and indemnity issues within a single legal entity such as BT. Strict liability and indemnity clauses apply to external parties connecting equipment to the Openreach network or carrying out operations in the network. Openreach applies the same or similar liability and indemnity clauses to its own chosen contractors. (v) The external PIA product will be subject to the notification periods specified in the WLA MR final statement6 (eg Condition FAA6 - Requirement to notify charges, terms and conditions). CPs can also

6 http://stakeholders.ofcom.org.uk/binaries/consultations/wla/statement/WLA_statement.pdf


launch of new services, changes to existing services or change to prices;

request changes to the existing product or new products via the Openreach SoR process7.

(j) details of measures to ensure compliance with requirements for network integrity;

• All network integrity measures apply equally to GEA and PIA implementations (eg cable breaking strengths, gas testing, pole structural assessments etc).

• This element of the reference offer is identical for the GEA product and PIA.

(k) details of any relevant intellectual property rights;

• Not applicable within a single legal entity such as BT.

(l) a dispute resolution procedure to be used between the parties;


(m) details of duration and renegotiation of agreements;


(n) provisions regarding confidentiality of non-public parts of the agreements;


(o) rules of allocation between the parties when supply is limited (for example, for the purpose of Co-Location or location of masts);

• All deployments are subject to the same survey rules and dependent on space being available. Should particular problems arise in future more detailed rules would be developed to address them (eg if the PIA product were to substantially change in specification or volume).

• The main limitations for the PIA product are more likely to be applied externally (e.g. obtaining the necessary wayleaves which is not in the control of Openreach).

(p) the standard terms and conditions for the provision of Network Access; and

• Openreach does not contract with itself for the provision of PIA and hence there are no standard contractual terms to apply.

• Details of the overall internal working processes and practices are summarised at Annex B.

(q) the amount applied to: (i) each Network Component used in providing Network Access with the relevant Usage Factors; (ii) the Transfer Charge for each Network Component or combination of Network Components described above; reconciled in each case to the charge payable by a Communications Provider other than the Dominant Provider.

• BT has a requirement to report on the Network Components (costs and usage factors) used to make up SMP products as part of the cost accounting/accounting separation obligations.

• There is also a requirement to provide a Wholesale Catalogue of SMP products, which shows any differences between internal and external offerings.

• The existing regulatory accounts do not yet include GEA or PIA. However, the work necessary to generate this information for the accounts has already started and BT Group Regulatory Finance aims to build the reporting in line with Ofcom guidance and agreement as volumes develop (further information in Annex C).

• When it is appropriate to disclose, Openreach proposes to discharge its obligations relating to costing transparency through these regulatory reporting requirements. This is the approach that it has adopted for other products.

• When the internal work is complete, appropriate thresholds have been reached, and reporting requirements agreed with Ofcom the Regulatory accounts will provide stakeholders with detailed information on the network components used to make up its GEA and PIA products (by application of the cost accounting/accounting separation requirements (OA1 to OA34)).

• At this stage Openreach does not expect to undertake regulatory reporting of GEA and PIA services in the Regulatory Financial Statement this financial year 2011/12.

7 Please see: http://www.openreach.co.uk/orpg/home/products/productdevelopment/productdevelopment.do


2. Additional Elements included in the PIA Reference Offer (a) the location of Physical Infrastructure or the method by which Third Parties may obtain information about the location of Physical Infrastructure;

• CPs need to make requests for information by area eg. a specific route or exchange area (to minimise the cost of producing the information for the customer).

• Information provided is at the same granularly as that used by Openreach planners (ie. sourced from the same systems such as PIPeR and PRM) showing the same information, detail and accuracy.

• Openreach planners using PIPeR and PRM directly have the ability to ‘zoom’ in and out of images – this is not available on the electronic snapshots sent to CPs as part of the PIA plans product.

• All street works operators can use Openreach’s Maps By Email service which gives open access to high-level PRM sourced data providing an indication of where Openreach’s network is located in a given area.

(b) technical specifications for Physical Infrastructure Access including: (i) technical specifications for permitted cables and associated equipment; and (ii) cable installation, attachment and recovery methods.

• Specifications quoted are the same as those that apply to Openreach’s NGA deployment, and further details are given in the PIA product descriptions, and Engineering Principles documentation (referenced in Annex E).

• Quality and workmanship standards and quality accreditation details are common to CPs, Openreach people and Openreach contractors.

(c) the methodology for calculating availability of spare capacity in Physical Infrastructure;

• CPs are required to use the same rules as Openreach uses and these are defined in the Engineering Principles document.

• Duct space for PIA will be allocated using the Openreach ‘0.7 Rule’ to assess when ducts are full. This is based on the summation of cable diameters versus usable duct aperture diameter. The ‘0.7 Rule’ is Openreach policy for all programmes. It is possible in certain circumstances to override this policy when the commercial cost of new infrastructure build outweighs the commercial risks of using congested duct but it is not standard practice. In these circumstances Openreach’s bears the financial and operational consequences resulting from duct fill in terms of Universal Service Obligations (USO) and other operational responsibilities. Also historically, in legacy situations such a rule was not as significant as it is today as there was no sharing of duct space mandated. Within a multi-CP environment a standard operational rule is required.

• Pole space is allocated to CPs after considering how much Openreach needs to satisfy its universal service obligations and the physical and safety limitations of the plant. Openreach NGA programmes necessarily need only consider the physical and safety aspects.

(d) procedures for the provision of information to Third Parties about spare capacity, including arrangements for visual surveys of Physical Infrastructure to determine spare capacity;


• Openreach sends CPs copies of the information which is available on its systems such as Piper and PRM hence information is the same as Openreach planners use. However where information is available on-line internally CPs would not have same analytical tools as Openreach and customers will not have the same “zoom” facility.

(e) conditions for reserving capacity that shall apply equally to BT and other CPs;

• CPs are required to use the process defined in the Process Documentation and Space Reservation document. These are symmetrical with Openreach’s own space reservation process.


Openreach NGA capacity is booked when the planned routes are marked up on the records systems prior to work execution. However, these reservations are not subject to validation and approval by a separate non NGA planner. As the NGA planner is an internal Openreach employee they have responsibility for implementing rules and processes correctly.

(f) conditions for the installation and recovery of cables and associated equipment;


(g) arrangements for relieving congested Physical Infrastructure, including the repair of existing faulty infrastructure and the construction of new Physical Infrastructure;


(h) a procedure for the Dominant Provider to announce plans reasonably in advance for new construction of Physical Infrastructure such that Third Parties may request BT to install additional capacity for those Third Parties;

• These are described in the Process and Contract documentation. • Openreach will publish new build schemes where they are greater

than 1km in length and offer CPs to co-invest in return for exclusive use of this capacity for the contract period. This arrangement excludes schemes within the curtilage of new developments. In these cases CPs will be able to buy PIA once the roads have been adopted by the highways authority.

(i) conditions for Third Parties to gain access to the Physical Infrastructure including if appropriate training, certification and authorisation requirements for personnel permitted to access and work in/on Physical Infrastructure;

• These are described in the Product, Contract and Engineering documentation. They are the same requirements as Openreach uses for its workforce and sub-contractors. All operatives will be accredited and licensed to work in their relevant skill areas. This applies to both CPs and Openreach (and Openreach contractors).

(j) the arrangements for maintenance of cables and associated equipment installed by Third Parties and of the Physical Infrastructure, including provision for the temporary occupation of additional infrastructure capacity for the installation of replacement cables;

• CPs are required to follow the processes in the Process description. These are largely the same processes as Openreach already has in place for CPs, sub-contractors, other utilities etc.

(k) conditions for the inspection of the Physical Infrastructure at which access is available or at which access has been refused on grounds of lack of capacity;

• CPs carry out their own surveys so have access to all relevant information.

• CPs are required to carry out surveys in line with the Process and Contract documentation.

(l) anything which may reasonably be regarded as being likely to materially affect the availability of the relevant Physical Infrastructure Access.

• Openreach’s GEA trained engineers and contractors are deployed area by area in line with a pre-planned programme of activity and robust and committed

• The relevant Process and Contract Documentation comprehensively covers all aspects of the product, but some further points are noted below for completeness:

• CPs control and prioritise all tasks related to NGA network build or

buy in components from Openreach/other external civil engineering contractors. In any event the working practice appropriate for GEA is not currently applicable to PIA given it is in the early stage of its development and the small scale nature of projects currently being trialed.


customer forecast per exchange area.

• Service Products: GEA has access to alternative service levels as part of the Service Harmonisation programme. GEA FTTC has Superfast Visit Assure service - similar to Special Fault Investigation (SFI2) on copper services.

• Novation capability not available for manual PIA process, but is available for GEA.

• A number of options for PIA systems development and SLA/SLGs

are currently being assessed for commercial viability, although a direct mapping of service levels/packages between layer 2 and physical infrastructure is not straightforward.

• Possible as part of a full automation solution (subject to commercial

viability and reasonable demand). However requirements are being considered for this feature – if it was to arise before the functionality is available Openreach would carry out the activity manually.


ANNEX B - Further Information on GEA and PIA Related Processes Plan and Build The Openreach NGA deployment process is subject to a highly structured and phased approach. This has a direct implication for how resources can be assigned and deployed for Openreach and its contractors. NGA operations are driven by a high volume, targeted and committed roll-out plan. An overall UK target coverage of approximately 66% of UK homes has been set with resources and a £2.5bn funding plan made available to support this by BT Group. As part of the overall coverage objective individual exchange areas are identified in phases looking approximately 12-18 months ahead and included in the rollout plan based on their suitability for a premium access product with good economics for Openreach, CPs and end-users. Major factors taken into consideration during the selection process include:

• Anticipated demand for the product - taking particular account of CP and regional development stakeholder demand.

• Cost of deployment and potential return on investment • Existing network performance

Underpinning the analysis of these major factors are a number of more detailed activities which feed into the overall assessment of the viability of deployment in the selected areas. For example:

• Engineering assessments may rule out individual cabinets which are likely to be uneconomic for FTTC deployment (eg due to a low number of premises served by the cabinet; or where estimated performance (eg due to long lines etc) is not expected to be sufficient; or where existing broadband take-up is known to be very low).

• In parallel, Openreach Regional and Public Policy teams continuously engage with local development agencies and stakeholders to assess their commitment to NGA roll-out.

• Other factors can come into play such as conflicting demands on the available Openreach resource and that of its contractors which might restrict the capability to install the infrastructure in the target timescales. The geographic spread of the Openreach or contractor workforce may therefore result in changes to deployment dates with some initial selections being delayed to later phases of deployment and a consequential need to include new target areas in the roll-out plan.

The GEA plan and build, and roll-out programme is a different order of magnitude to current PIA based projects which do not yet have significant volumes, although this may change if opportunities mature in BDUK funded areas or further investment is made in existing NGA/Broadband areas. Additionally there is no hard commitment to volume or coverage within the PIA contract currently that can be tied to the pre-provision of Openreach resource or investment or that of its civil engineering contractors. This comparison to GEA is important context in understanding the way that the two products have developed. GEA has achieved approximately three hundred thousand connections since its launch in 2009, is available to approximately six million homes in the UK and the roll-out programme is currently activating circa three hundred cabinets per week. In contrast, PIA is currently only beginning to be used by CPs and so far there are four small scale trial deployments in place. Operational Processes Due to the very different scales of operation between PIA and GEA different external interfaces have been developed by Openreach: • The external GEA interface is through the Equivalence Management Platform (EMP) and: • PIA is a Customer Request Form (eCRF) spreadsheet based process.


Openreach does not consume the PIA product internally within Openreach and therefore does not use the external interfaces developed for CPs internally when deploying and operating the GEA service. However much of the internal work flow is governed and managed by the same (or similar systems) such as Workflow etc. These internal systems manage the relevant infrastructure level activities both for PIA and GEA once the task is triggered via the appropriate front end system (eg through EMP or via a spreadsheet based CRF order to the relevant SMC). For GEA (and as described under Plan and Build above) after an exchange area has been chosen for NGA network deployment, large scale engineering resource is committed by Openreach and its contractors to the specified area as required to achieve the target roll-out plan. A coordinated and committed delivery plan is agreed internally and with the engineering contractor concerning the speed and coverage for cabinet activation and other infrastructure related work on duct, poles and chambers. After the required infrastructure build is completed, specialist engineers are also assigned to the area to carry out the skilled tasks required to support the product ordering and fulfilment process. In particular the GEA end-user installation process is very important in achieving a robust and premium quality product. Additionally the presence of active electronics and mains powering in a GEA cabinet requires a different engineering skill set than those needed to work in an existing non-NGA cabinet environment. PIA related tasks are also recorded and triggered in the same (or similar) internal systems but as noted above, the external interface is currently via a spreadsheet CRF raised through one of two Openreach Service Management Centres (SMCs) specifically dealing with this type of work. Generally, separate CRFs are required for each type of activity (eg repair submitted on a separate CRF to a provision etc). The CRF undergoes an initial automated validation which triggers an acceptance message to the CP with an Openreach reference. All details are then passed to a Planner who checks the technical details in the documentation submitted along with the CRF. Where appointments are required, the CP will nominate a time and place (giving sufficient notice) and the planner will confirm their availability. At a summary level: • Current process is: emailed eCRF automated validation planning system (TCP8/WFMT) • Potential strategic process will be: Siebel (EMP) Flow planning system (TCP/WFMT) Further details on product processes are included at Annex E for both GEA and PIA.

8 Twenty-First Century Planning (TCP) is the gateway system allowing access to other relevant engineering systems.


ANNEX C - FINANCIAL ASPECTS NGA and PIA Related costs The Openreach NGA programme experiences the same financial challenges faced by PIA based projects although currently at a far higher absolute level of investment and scale. The majority of costs experienced by the investor are not simply related to PIA inputs as the additional supporting infrastructure required is extensive; however the main focus of this document is on the common product features described in Section 2.4. PIA operators can access infrastructure using regulated prices from Openreach which are subject to a cost orientation obligation imposed by Ofcom. Openreach has recently reviewed and benchmarked these prices by assessing the relevant activities and drivers required for cost recovery and also where appropriate, have compared them with findings from recent and ongoing Ofcom consultations to ensure that prices are in line with the prevailing regulatory obligations. A summary of some of the major costs associated with physical infrastructure are compared in the table below: Cost/Activity

NGA PIA

Plan and Build Costs associated with planning, installing and activating NGA related infrastructure are borne by Openreach through direct labour, the payments it makes to its contractors and payments made to equipment suppliers.

PIA CPs incur these costs directly through direct labour, payments to contractors and equipment suppliers. Where new build is required CPs can carry out the additional construction work themselves or request an Openreach ancillary service.

Openreach Exchange/CP POP Access

Costs associated with provision and jumpering connections into an Openreach exchange are borne directly by Openreach through direct labour charges and where appropriate through the payments made to contractors.

PIA CPs choose whether to link into an Openreach exchange or to a separate CP POP. When connecting to an Openreach exchange they are required to pay a cost oriented charge for any work carried out by Openreach and any products supplied. As with Openreach the CP will incur costs associated with any materials provided (such as cabling) and other associated costs such as direct labour or payments to their contractors.

Repair/Enabling Works

Openreach faces full capex and opex costs of repairing, unblocking, de-silting etc duct through direct labour and contractor payments.

CPs can carry out some of the more straightforward tasks (such as de-silting) but are required to pay a cost oriented charge to use Openreach and its contractor for duct unblocking and repair.

Annual rental/cost of infrastructure

Openreach incurs the full capital expenditure, associated depreciation and ongoing costs for the operation and maintenance of its physical infrastructure.

When CP chooses to use Openreach infrastructure it is required to pay a cost oriented rental charge for the ongoing operation and maintenance of the physical infrastructure.

Non-discrimination is achieved in pricing terms through the use of regulated cost oriented Openreach tariffs for the relevant network access and/or activity. PIA operators are charged the cost based price associated with the PIA related services provided. Openreach incurs and pays


the capital and current account costs associated with the provision and ongoing support of its infrastructure and NGA network. This risk of investment is fully borne by Openreach. For a PIA operator the full cost recovery of the Openreach activity is correctly attributed to the PIA operator and so is the investment risk. Openreach charges are set to recover costs for the activity carried out and resources used. NGA Business Case Openreach does not consume the PIA product internally within Openreach and hence does not use external PIA related prices in its business case. However Openreach does incur capex and opex costs directly (albeit at a much larger scale) associated with investment in the GEA product and infrastructure in the same way as a CP building an NGA infrastructure would including:

o Manpower o Materials o Overheads o Sub-contractor payments o Wayleaves o All capital costs associated with planning, new build of cabinets, electronics, new

fibre and duct and pole works, new systems developments etc. o All ongoing operational visits including cabinet work and end-user visits and

ongoing maintenance of infrastructure and systems. Such costs are captured within Openreach’s internal accounting systems and are used to generate regular monthly cost control reports; and combined with other relevant statistics such as coverage, take-up and revenue, the data is used to monitor progress against the long term investment case. All investment risk in infrastructure and the NGA programme is borne by Openreach. There is no requirement or obligation for any end-user to purchase SFBB products based on the new access infrastructure. Currently the case is anticipated to deliver a payback period and return commensurate with a long term infrastructure investment at the Openreach level and this is critical to how prices need to be set. Prices of GEA are cost based and set at a level to encourage take up of the service but within an overall framework of achieving an acceptable return for Openreach for a long term infrastructure build. The Openreach NGA platform is already subject to competition from existing copper network services and alternative service platforms such as cable, satellite and mobile. Recent Ofcom consultations have recognised this pressure and hence have chosen not to regulate GEA prices as these are viewed as being constrained by the existing non fibre based broadband services which are available. The Openreach business case needs to fully absorb these competitive and pricing risks An acceptable return for Openreach could differ from a PIA based investor, either because the alternative investment scenario may be different or because Openreach views its NGA programme as a long term infrastructure investment and may be willing to consider an alternative target return over a different period. Such an approach could naturally lead to a difference in attitude towards investment risk and in what cost levels are acceptable in the business case. Regulatory Accounting Initial analysis and work has commenced on the Regulatory Accounts reporting structure for GEA and PIA products. The current intention is to introduce a set of Component codes to capture relevant costs as listed below. For GEA - these will be summarised under Super Component CL197, “FTTx Service Delivery & Development”: CL950 GEA Access Fibre Spine


CL951 GEA Distribution Fibre CL952 GEA Electronics CL953 GEA DSLAM & Cabinets CL954 GEA Customer Site Installation CL955 GEA FTTC Repairs CL956 GEA FTTP Repairs CL957 GEA FTTP Provisions CL958 GEA FTTC Provisions CL959 Access Distribution Fibre CL960 Access Fibre Spine These will be recorded against four ASPIRE services as follows: SL950 GEA Fibre to the cab (FTTC) rentals - Ext SL951 GEA Fibre to the cab (FTTC) conns - Ext SL952 GEA Fibre to the prem (FTTP) rentals - Ext SL953 GEA Fibre to the prem (FTTP) conns - Ext All four services will then be assigned to the Residual products class and in line with existing Accounting Separation regulation such costs will become part of the regular SMP based reporting when the relevant thresholds have been reached (as described in Annex A (q)). For PIA - the relevant codes have not yet been defined for PIA as the product has no material volumes as it has only very recently been launched. However, the work necessary to generate this information for the accounts has already started and BT Group Regulatory Accounting aims to build the reporting in line with Ofcom guidance and agreement as volumes develop. Openreach proposes to discharge its obligations relating to costing transparency through its regulatory reporting requirements. This is the approach that it has adopted for other products. When the relevant internal work is complete, appropriate thresholds have been reached, and reporting requirements agreed with Ofcom the Regulatory accounts will provide stakeholders with detailed information on the network components used to make up its GEA and PIA products. At this stage Openreach do not expect to undertake regulatory reporting of GEA and PIA services in the Regulatory Financial Statement this financial year 2011/12.


ANNEX D Physical Infrastructure Access (PIA) and Generic Ethernet Access (GEA) Under the terms of Ofcom’s final statement on the “Review of the wholesale local access market” (WLA MR) published on 7 October 2010, BT is required to publish reference offers in relation to network access provided within SMP designated markets. • For PIA , the relevant product information, technical and contractual information can be found

at:


• For GEA (referred to as Virtual Unbundled Local Access (VULA) within the WLA MR) the

relevant product information, technical and contractual information can be found at:

http://www.openreach.co.uk/orpg/home/products/super-fastfibreaccess/superfastfibre.do • PIA and GEA related charges are published in the Openreach price list and can be found at:

http://www.openreach.co.uk/orpg/home/products/pricing/loadPricing.do • Interface Specifications can be found at:

http://www.sinet.bt.com/

• Information on the Openreach Statement of Requirements (SOR) process can be found at:

http://www.openreach.co.uk/orpg/home/products/productdevelopment/productdevelopment.do • BT’s Regulatory Financial Statements can be found at:

http://www.btplc.com/Thegroup/RegulatoryandPublicaffairs/Financialstatements/index.htm • Lead times for PIA and GEA and associated service level for delivery, repair etc have not been

set by the Regulator but are the subject of ongoing working groups with industry. Notes of the PIA Industry Working Group (IWG) can be found at:

http://www.openreach.co.uk/orpg/home/products/industryforums/copperproductswlrllu/copperproducts.do

• And notes from the GEA Trialist Working Group (TWG) can be found at:

http://www.openreach.co.uk/orpg/home/products/industryforums/superfastfibreaccess/sffafora.do



http://www.openreach.co.uk/orpg/home/products/super-fastfibreaccess/superfastfibre.do

http://www.openreach.co.uk/orpg/home/products/pricing/loadPricing.do

http://www.sinet.bt.com/


ANNEX E - DETAILED PIA AND GEA PROCESS DOCUMENTATION PIA Process Overview Detailed PIA process documentation is available on-line at: http://www.openreach.co.uk/orpg/home/products/ductandpolesharing/ductandpolesharing/ductandpolesharing.do PIA Space Reservation and Engineering Principles https://www.internal.openreach.co.uk/orpg/customerzone/products/ductandpolesharing/ductandpolesharing/description/supplementaryinformation/supplementaryinfo.do GEA FTTC Process Overview - Flow Charts Detailed GEA process documentation is available on-line at: http://www.openreach.co.uk/orpg/customerzone/products/super-fastfibreaccess/fibretothecabinet/businessprocessmodels/fttcbpm.do

Please note: If you require any of the on-line information referenced in Annex D or Annex E but are unable to access the relevant website please contact [email protected] for assistance and further information.

http://www.openreach.co.uk/orpg/customerzone/products/super-fastfibreaccess/fibretothecabinet/businessprocessmodels/fttcbpm.do

http://www.openreach.co.uk/orpg/customerzone/products/super-fastfibreaccess/fibretothecabinet/businessprocessmodels/fttcbpm.do


ANNEX F

Generic Ethernet Access (GEA) was developed by Openreach to overcome the challenging economics of NGA deployment. This is achieved by carrying out a single network upgrade at the Primary Connection Point (PCP) by connecting fibre to a secondary cabinet and installing DSLAM electronics for FTTC or by installing a Gigabit Passive Optical Network for FTTP. Open shared access to this infrastructure is then made available to CPs at the local exchange enabling all CPs to benefit from the single local infrastructure upgrade. The Network Access is shared at one layer above the physical layer (i.e. at the Ethernet layer or “layer 2”). This is why it is referred to as “virtual unbundling”. Opening up a Network Access product at this point stimulates efficient investment and delivers substantial cost savings through removing the need to duplicate the physical layer. However the access still allows for innovation and investment at all higher layers in the protocol stack by CPs, and includes the option for the CP to geographically extend their network build in a way which is analogous to physical local loop unbundling (LLU). *Note: ALA stands for Active Line Access - a set of technical recommendations introduced by Ofcom in 2009 and which are currently being developed further by NICC. The ALA consultation carried out by Ofcom also helped inform the basis of Ofcom’s later regulation on Virtual Unbundled Local Access (VULA).

BT Internal Reference Offer


Glossary of Acronyms ADSL Asymmetric Digital Subscriber Line ALA Active Line Access ANFP Access Network Frequency Plan BDUK Broadband Delivery United Kingdom CAT Competition and Appeals Tribunal CP Communications Provider CPCG Copper Products Commercial Group CRF Customer Request Form CSS Customer Service System CT Carillion Telent D side Distribution side DSLAM Digital Subscriber Line Access Multiplexer E side Exchange side eMLC Enhanced Managed Line Characteristics EMP Equivalence Management Platform EoI Equivalence of Input EU End User FTTC Fibre To The Cabinet FTTP Fibre To The Premises GEA Generic Ethernet Access GPON Gigabit Passive Optical Network IRO Internal Reference Offer IWG Industry Working Group LLU Local Loop Unbundling MDF Main Distribution Frame MPF Metallic Path Facility NGA Next Generation Access NICC Network Interoperability Consultative Committee NTE5 Network Terminating Equipment (number 5) ODF Optical Distribution Frame OSI Open Systems Interconnection OTA Office of the Telecoms Adjudicator PCP Primary Cross-connection Point PIPeR Physical Inventory Planning and eRecords POP Point of Presence PRM Planning and Recording Modernisation PSTN Public Switched Telephone Network SFBB Super Fast Broadband SFI Special Fault Investigation SIN Suppliers Information Note SLCP Sub Loop Connection Point SLU Sub Loop Unbundling SMC Service Management Centre SMP Significant Market Power SMPF Shared Metallic Path Facility SoR Statement of Requirements SSFP Service Specific Front Plate TWG Trialist Working Group VDSL Very high speed Digital Subscriber Line VLAN Virtual Local Area Network VULA Virtual Unbundled Local Access WLA Wholesale Local Access WLA MR Wholesale Local Access Market Review WLR Wholesale Line Rental xDSL Digital Subscriber Line

BT Internal Reference Offer


Document History

Status Date Details of Change Issue 1.0 Issue 2.0

21/11/2011 16/5/2013

Initial publication Update following Exchange Access Link withdrawal

End of Document

Documents

Physical Infrastructure Access (PIA) - Openreach · This document is the Internal Reference Offer for the Network Access product called Physical Infrastructure Access (PIA), also