Steve Best (BT Wholesale)
Ann Francis (Colt)
Andy May (CW)
Gareth Davies (Ofcom)
Gideon Senensieb (Ofcom)
Neil McArthur (Talk Talk)
Andrew Wileman (Virgin Media),
Rod Smith (NGNuk)
Peter Ryde (NGNuk)
Mark Dalziel (OTA)
David Halliday (OTA)
Andy Rawnsley ( Gamma Telecom)
Robyn Durie ( T-Mobile)
Tom Daniewski ( Sky)
Marcus Webb ( Vodafone)
Tonia Eales ( BT Retail)
Lee Jones (Orange)
Apologies - Alison Mitchell (BT Retail), Martin Whewell (Openreach), Thomas Gransalke (Orange)
The September minutes had been agreed via email and published on the NGNuk web site during October. An update on the actions is appended at the end of this document.
Gareth Davies and Gideon Senensieb presented some feedback to the NGN Exec regarding their current thinking following the responses received to their recent NGN consultation which closed on 24th September. GD/GS prefaced the discussion by stating that Ofcom saw the consultation as being "wide and thin" to help establish a framework for future work.
GD/GS started by outlining the Ofcom priorities for NGNs which are:
To provide incentives for efficient investment in NGNs
Promoting effective competition based on NGN infrastructure
Protecting consumers from disruption during transition to NGNs.
The purpose of the consultation had been to present the Ofcom response to recent NGN developments, including revisions of 21CN plans, and related concerns raised by stakeholders. It also aimed to provide an update on Ofcom thinking on consumer protection during migration to NGNs.
Ofcom plan to make a statement in Jan 2010, however this will not make major regulatory policy decisions or draw major conclusions but will signpost which parts of the Ofcom work programme will take issues forward.
Models of Competition
The consultation discussed likely models of competition over 3-5 years and what inputs will be needed to support these. The responses Ofcom have received asked how Ofcom will take forward the model of competition set up by the Telecommunication Strategic Review now that BT has re-planned 21CN and is starting to deploy FTTC and FTTP. The main vehicles anticipated by Ofcom for taking these issues forward are the ongoing market reviews, under the SMP framework, of Wholesale Local Access and Wholesale Broadband Access. A consultation on these is anticipated to be published in Jan 2010.
Ofcom will also consider these issues in its work on requests for variations to BT's Undertakings for FTTP ( which is ongoing) and potentially for single-jumper SMPF ( a request that is anticipated from BT since once Voice and Broadband move to a single MSAN it will affect input products).
The Exec observed that the scope of the consultation had been NGN but that the majority of issues currently of concern to CPs related to NGA and that the issues outstanding for NGNs related to voice and voice interconnection.
Interconnection of IP and TDM networks
The consultation proposed an initial view that the reciprocity principle remains appropriate within an NGN environment and that consumers should not end up paying more as a result of NGN investment.
During the consultation however BT's Reciprocity Agreement expired ( and negotiations have not yet found a way forward) and that Opal and BT referred a dispute to Ofcom relating to IP-TDM interconnection. In addition, responses to the consultation asked that Ofcom give guidance on IP/TDM interconnection.
TT expressed a concern that the current delays affecting NGN interconnection were significantly prolonging the period of dual running of IP and TDM, such that consumers would lose out through potential cost savings being lost.
Ofcom stated they are considering starting a new policy project early in 2010 that will seek to give guidance on how , where appropriate, reciprocity should be applied in the interconnection of IP and TDM networks. This would seek to take into account the different topologies of IP and TDM networks, who should bear the costs of IP/TDM interworking and whether BT should be required to offer IP interconnect, and, if so, when. This approach would allow Ofcom to address the issue more broadly than was possible during the Opal/BT dispute. The form of output was likely to be "guidance" rather than an agreement.
CPs asked the question of why it was just BT that might be expected to offer IP interconnect and not any CP that had an IP capability and termination monopoly ,Ofcom stated that this would be considered as a part of the 2010 policy project
Voice-Only LLU Product ("xMPF")
Prior to the consultation TT had argued that Ofcom should require Openreach to produce an "xMPF" product. Ofcom consider that, given the margin between xMPF and WLR , there is not likely to be reasonable demand but remain open to be persuaded otherwise. TT stated that they have a considerable base of their own and reseller customers that could be migrated to xMPF if it was cost effective. Ofcom acknowledged the migration issues that use of current MPF product would raise, but stated its current thinking is that provided the consumer is warned in advance, MPF could be used to provide voice-only. TT took issue with this and stated that they cannot compete in the voice market as a level playing field does not exist. As the migration between TDM and NGN period lengthens, this position simply gets worse.
Ofcom recognised that the margin issue between MPF/WLR was not addressed in the consultation but did not to plan to reopen this. The WLA Market review will consider what remedies are available for NGA. TT expressed their concern that by looking at many separate issues, Ofcom risked a lack of coherence of their NGN/NGA policy as a whole.
Investment Uncertainty
In their consultation responses, CPs expressed concerns resulting from BT's 21CN re-plan , their potential losses resulting from changes in BT's plans and their inability to plan their own investments in light of lack of long-term plan from BT.
Ofcom's position was that these matters should be resolved as far as possible by commercial negotiations between CPs.
Some members of the Exec expressed concern that Ofcom planned to draw back from an area where it had previously been involved, that these issues were unlikely to be resolved bilaterally and would end up with Ofcom as a serious of disputes to resolve anyway.
Consumer Issues
Ofcom's concern is that as new technologies and platforms are introduced they might through up new issues that may affect the consumer. They are therefore seeking to identify such potential issues in advance.
The move to NGA/NGN will raise potential new issues around switching, however these will be addressed by the existing project on Migrations which aims to consult in Q1 2010. This will also deal with the broader issues of bundling.
Ofcom is also planning to hold discussions with the stakeholders in the care industry to try to resolve the matter of who pays for the replacement of incompatible Telecare alarms.
Concerns were also raised in the consultation responses regarding terminal incompatibility and voice quality concerns. Ofcom asked whether NGNuk might play some part in exploring these issues. A lot of work has been undertaken within 21CN , by TT and in various interest groups. The Exec felt the issue may be how to share this information more widely and that NGNuk might play a part in signposting this. Gamma also raised the issue of multiple IP/TDM conversions leaving devices struggling to cope with transmission budgets.
Ofcom agreed that they would write to NGNuk to clarify what support they required from NGNuk
Action 1 - 26/11/2009 - Ofcom to write to NGNuk to clarify what support they require from NGNuk with respect to terminal incompatibility and voice quality concerns
Ofcom also raised concerns that network operators are not complying with their obligations to publish interface specifications in compliance with GC2 and R&TTE. The Exec were unaware of the issue and asked Ofcom to provide greater clarification.
Action 2 - 26/11/2009 - Ofcom to write to NGNuk to clarify where they feel that network operators are not complying with their obligations to publish interface specifications in compliance with GC2 and R&TTE
NICC Standard (ND1643)
Issue 1 of ND1643 ( Minimum Security Standard) has been published by NICC. A draft Issue 2 will be circulated , within NICC, towards the end of Q4 2009 which:
Implementation Plans
The following has been agreed with CPs regarding implementation for "endorsement" by TISAC;
All CPs [who have signed the CoP] intend to have gained certification by end 2010 and that where any non compliances are identified , to have an agreed plan to address these. This is subject to the general provisos that relate to any changes introduced within Issue 2 of ND1643, its publication date and the timely availability/cost/complexity of the certification scheme.
Certification
NGNuk has approached the UK Accreditation Service for support in establishing a certification scheme. As ND1643 does not mandate ISO27001, the certification scheme cannot be an extension to ISO certification. An inspection scheme is therefore being pursued, however where controls are common, and already assessed under ISO27001, these will count towards ND1643 certification
It was agreed with CPs that certification should be extended to Suppliers to simplify the schemes introduction , since the latter may have multiple CP relationships
A certification body has also volunteered to undertake "free of charge" assessments of smaller CPs to better understand the impact of the standard to allow any necessary changes to be made to Issue 2 of the specification and for NGNuk to consider any necessary support for smaller CPs.
UKAS have provided a quotation for this work which is approximately £13.5k. Their draft timeframe is as follows:
Activity | Timescale |
Input to scheme requirements | Feb to March 2010 |
Appointment of expert assessors | March 2010 |
Determination of assessment criteria | March 2010 |
Pilot assessments | April to August 2010 |
Review assessment findings, criteria etc | September 2010 |
Complete assessment reports | September 2010 |
Grant accreditation | October 2010 |
Code of Practice
The list of signatories to the Code of Practice remains unchanged and is; BT Group, Talk Talk , Colt, C&W, Gamma, KCom, Orange, O2, Sky and Virgin Media
Global Crossing and T-Mobile have indicated they support signing the Code subject to clarity regarding the scope of the standard and the certification scheme. T-Mobile made it clear that they are currently out of scope as their IP interconnect is in Germany.
Following a variety of approaches to industry, feedback from smaller CPs is that there is little, if any , interest to adopt the minimum security standard. Their feedback is that unless, or until, they are forced to do so they'll not adopt it.
Relationship of NICC ND1643 to CESG 2.2.4 Assured standard
Peter Ryde explained the background that in conversations with a variety of contacts differing views of the impact of ND1643 on 2.2.4 certification had been provided ranging from lack of ND1643 "compromising" 2.2.4 CPs through to it merely being a best practice guide.
NICC/NGNuk and CESG met on 18th Nov to clarify the relationship between 2.2.4 certification and a CPs ND1643 status. The output of the meeting was;
NGNuk approached BT regarding the feasibility of segregating CPs within MUAs. Preliminary feedback from BT is that if isolation is required by a CP [ to enable them to comply with 2.2.4], then cages could be provided with costs in the tens of thousands [per site] but "In many cases it would be very difficult to segregate individual CP's. Many MUA locations are full and second/ third areas opened up within a site. Consideration would have to be given to entry and exit routes together with safe working space such that caging off of areas or racks within the MUA would be in many case extremely difficult. The physical constraints support the argument that we would really struggle to isolate a 224 CP". Potentially this implies that even if the major CPs adopt the Minimum Security Standard, where the Openreach MUA is used a CP cannot comply with the standard for an assured service ( 2.2.4) whilst CPs who do not meet ND1643 are co-located. The problem cannot be solved by isolating the 2.2.4 CPs as this is impractical. Dependent on how 2.2.4 is assessed, the only solution might to be to find a way of ensuring all CPs, within the MUA, comply with ND1643. Peter Ryde was asked to clarify with CESG how 2.2.4 would be assessed, with respect to this issue.
Action 3 - 26/11/2009 - Peter Ryde was asked to clarify with CESG how 2.2.4 would be assessed, with respect to the impact of sharing/interconnection with none ND1643 CPs
Wider adoption of ND1643
Following the September Exec call, NGNuk wrote to Ofcom on 5th and 30th October seeking clarification on how Ofcom might treat potential disputes relating to the Minimum Standard. A copy of an Ofcom response was circulated at the meeting. In summary it stated that:
The options for encouraging wider adoption of the Minimum Standard had been reviewed on Sept Exec call and at work group meeting dated 23rd Sept. These discussions concluded that whilst members were generally supportive on including compliance with ND1643 as a condition of interconnect, assurances were required that such action could be deemed anti-competitive, despite the open approach to developing the standard and industry's concern that compliance was not onerous. Peter Ryde had requested views from a number of CPs and received feedback from two but with differing views of whether the activity might be construed as anti competitive. The general feeling of the Exec was that as CPs were merely trying to support what had been requested by the UK Government, that the process was entirely open and as every effort was being taken to ensure it should not be a barrier for any responsible CP that it should not be an issue, however the Exec recognises that this is an issue that needs thorough consideration and agreed to maintain the suspension of further discussions until external legal advice is taken. It was suggested that NGNuk might seek an introduction , through Ofcom , to Counsel used by Ofcom itself so as to take advantage of any lower rates Ofcom may have negotiated..
Action 4 -26/11/2009 - Rod Smith to write to Ofcom seeking an introduction to Counsel , with a view to NGNuk requesting them to undertake a review of whether discussions regarding including ND1643 within interconnect contracts might be deemed as anti competitive.
Budget Update
Rod Smith presented the year to date budget position. He also outlined his thoughts regarding 2010/11. If NGNuk carries on for another year he proposed that fees would be reduced on 2009/10 and that BT members would pay the equivalent rate to other CPs. It was agreed that a key element of the focus in January Exec should be agreeing whether NGNuk should continue beyond year end and if so the areas of focus and output. It was also felt important that Ofcom provide its views on what it wished industry, through NGNuk, to resolve for itself.
Action 5 - 26/11/2009 - Peter Ryde to schedule a discussion at the January Executive of whether it is appropriate for NGNuk continue next year and if so what should NGNuk be seeking to achieve
Action 6 - 26/11/2009 - Ofcom to provide its views on what areas of focus /outputs it would wish to see from NGNuk in 2010/11 , should members vote for its continuation
ERG B&K Consultation
Peter Ryde was asked for an update on the NGNuk response to the ERG consultation on Bill and Keep. Peter Ryde stated that a draft response would be circulated by 30th November for comment. The letter would re-iterate the agreed NGNuk position taken from work and minutes published to date.
Technology Strategy Board
Peter Ryde had been contacted by John Nolan of First Mile Networks , who is undertaking a project for the Technology Strategy Board to look at WDM in the access network. In summary, the project's main focus is to understand market demand for open access (at the service layer) for 1 GBit/s (and above) services. FMN are seeking to obtaining member contacts who they can engage to help shape our research. It was agreed to ask FMN to provide a fuller scope of what they are seeking and that Peter Ryde would aim to facilitate the appropriate introductions
Next Meeting
The next scheduled meeting was 10.00 to 13.00 on 28th January at Riverside House.
Peter Ryde
NGNuk Office
07771 555 048
020 7783 4688
Action 5 - 29/01/2009 - Establish a joint session with NICC regarding the Usage of Non-numeric Identifiers with the aim of delivering feedback for debate at the March NGNuk executive. This work shop was held with NICC. Those NGNuk representatives present found that whilst accepting the validity of the debate it was unlikely, based on past evidence , that NGNuk would gain much active support from members to progress this beyond the feedback provided at the workshop. Awaiting NICC output | Peter Ryde Ongoing |
Action 5 - 21/05/2009 - Represent the problem statement for "Fair access to new services " at the January 2010 for the Exec to consider whether the situation remained unchanged. | Peter Ryde Ongoing |
Action 1 -23/07/2009 - Work with CP nominees to consider how NGNuk members might seek to proactively widen adoption of the NICC Minimum Security Standard across industry. Initial meeting held on 21st September for feedback to the September Executive. Activity on hold awaiting legal advice. | Peter Ryde Ongoing |
Action 6 - 23/7/2009 - Work with NGNuk members to review in greater detail a policy or CoP is required by industry covering the legitimate uses of the inspection of NGN media and content by other CPs. Awaiting discussion with GSMA | Peter Ryde Ongoing |
Action 7 - 23/7/2009 - Contact the GSMA to identify what work they might be undertaking regarding policing of signalling and media over NGN interconnects. The appropriate contact has been identified at GSMA however no date for a meeting has yet been agreed. | Peter Ryde Ongoing |
Action 8 - 23/07/2009 - Represent the problem statement for "Use of 3rd Party Elements within a Session " at the March 2010 for the Exec to consider whether the situation remains unchanged | Peter Ryde Ongoing |
Action 9 - 23/7/2009 - Work with NGNuk members to consider whether there is scope for constructive NGNuk activity in the areas of Quality of Service Principles , Presence and Location , Security and Authentication and Numbering and Addressing The Secretariat had intended to include these as an additional item when some other work shop was scheduled with the appropriate attendees, No suitable work shop had been identified, so Peter Ryde was asked to arrange a "one of work shop" to cover off these items. | Peter Ryde Ongoing |
Action 1 - 24/09/09 - NGNuk to write to Ofcom to seek clarification on what Ofcom are willing to state publicly regarding the adoption of ND1643 by industry and also to seeking confirmation of the Ofcom position on adopting a General Condition | Secretariat Completed |
Action 2- 24/09/2009 - Document and agree within NGNuk, any requirements that are in addition to the existing NICC work study on un-trusted sources, to send this agreed statement to NICC and then to jointly review with NICC. | Peter Ryde Ongoing |
Action 1 - 24/09/09 - NGNuk to write to Ofcom to seek clarification on what Ofcom are willing to state publicly regarding the adoption of ND1643 by industry and also to seeking confirmation of the Ofcom position on adopting a General Condition | Secretariat Completed |
New Actions | |
Action 1 - 26/11/2009 - Ofcom to write to NGNuk to clarify what support they require from NGNuk with respect to terminal incompatibility and voice quality concerns | Ofcom |
Action 2 - 26/11/2009 - Ofcom to write to NGNuk to clarify where they feel that network operators are not complying with their obligations to publish interface specifications in compliance with GC2 and R&TTE | Ofcom |
Action 3 - 26/11/2009 - Clarify with CESG how 2.2.4 would be assessed, with respect to the impact of sharing/interconnection with none ND1643 CPs | Peter Ryde |
Action 4 -26/11/2009 - Rod Smith to write to Ofcom seeking an introduction to Counsel , with a view to NGNuk requesting them to undertake a review of whether discussions regarding including ND1643 within interconnect contracts might be deemed as anti competitive | Rod Smith |
Action 5 - 26/11/2009 - Schedule a discussion at the January Executive of whether it is appropriate for NGNuk continue next year and if so what should NGNuk be seeking to achieve | Peter Ryde |
Action 6 - 26/11/2009 - Ofcom to provide its views on what areas of focus /outputs it would wish to see from NGNuk in 2010/11 , should members vote for its continuation | Ofcom |