Attendees:
Andrew Wileman (Virgin Media),
Andy May (CW)
Andy Rawnsley ( Gamma Telecom)
Clive Hillier (Ofcom)
David Halliday (OTA)
Gareth Davies (Ofcom)
Gideon Senensieb (Ofcom)
Lee Jones (Orange)
Mark Dalziel (OTA)
Martin Whewell (Openreach),
Neil McArthur (Talk Talk)
Peter Ryde (NGNuk)
Rod Smith (NGNuk)
Thomas Gransalke (Orange)
Apologies - Greg Mook (BT Retail), Robyn Durie ( T-Mobile), Steve Best (BT Wholesale), Ann Francis (Colt)
The January minutes had been agreed previously via email and are published on the NGNuk web site. An update on the actions from previous Executive meetings is appended at the end of this document.
Inspection against the Minimum Standard
The list of signatories of the Code of Practice is now BT Group, Colt, C&W, Gamma, Kcom , Orange, O2,T-Mobile, Talk Talk , Sky, Virgin Media and Vodafone.
Andy May noted that part of T-Mobile agreeing to sign the CoP was predictated on NICC agreement regarding the scope of their interconnects. Feedback from Paul Rosbotham, NICC TSG is that NICC do not consider this to form part of their role. It is the NICC view that is the responsibility of an individual CPs to consider whether and how they comply to NICC NDs. Peter Ryde was asked to clarify this with T-Mobile.
Action 1 - 25/03/2010 – Peter Ryde to write to T-Mobile clarify the role of NICC in line with the statement from NICC TSG ( Paul Rosbotham) .
Issue 1.1.1 of ND1643 ( Minimum Security Standard) was published by NICC in Sept 09. A revised version, which incorporates feedback from CPs and seeks to facilitate inspection , is under development. The draft has been reviewed twice by the NICC Security Working Group but requires at least a further iteration before it can be used for the pilot (see below). Some elements of the redraft are dependent upon the NICC SWG either obtaining the original Cabinet Office risk assessment of the risks that need to be addressed, receiving guidance on these or potentially both. It is not clear when this updated version will be available to allow dependent activities to commence, although it is hoped that this will be late April, early May.
NGNuk is using the UK Accreditation Service to help establish the inspection scheme. A formal “kick-off” meeting was held with UKAS on 12th March covering;
This meeting was attended by NGNuk, NICC SWG , BABT , UKAS and LINX. Key agreements included:
The potential time line for availability of the scheme and inspection against this are as follows:
| Activity | December UKAS Proposal | Potential Date |
|---|---|---|
| Input to scheme requirements | Feb to March 2010 | May 2010 (requires Draft 2) |
| Appointment of expert assessors | March 2010 | Identify end May 2010 Availability end July 2010 |
| Determination of assessment criteria | March 2010 | May 2010( requires Draft 2) |
| TISAC Review July 2010 | ||
| Pilot assessments | April to August 2010 | August 2010 – November 2010 |
| Review assessment findings, criteria etc | September 2010 | December 2010 |
| Complete assessment reports | September 2010 | December 2010 |
| Grant accreditation | October 2010 | January 2011 |
Wider Adoption of the Standard
The option of including compliance to the Minimum Standard as a condition of interconnection was discussed on the Sept 09 Executive call and at a work group meeting in that month. Exec Members were generally supportive of including compliance within contracts , however a concern over whether this might be deemed anti competitive was raised. It was requested that NGNuk legal seek advice. This has been obtained from Wragge & Co.
The full advice has been distributed to the NGNuk Executive and will also be sent to Participating Members for their consideration. The summary of the legal advice is as follows:
“For the reasons we explore below and in the specific circumstances of this matter, we do not consider that either NGNuk or its members, let alone individual representatives, risk investigation or censure by the competent competition authorities for either past or future activities relating to the discussion and conclusion of any agreement among themselves to implement the Minimum Standard by requiring adherence from interconnecting parties.
The nature of interconnection is such that one party's non-compliance with a base level of security compromises that of an interconnecting party. In view of this interdependency and absence of a collective arrangement, industry players have no incentive to invest in a base level of security.
On the basis of the facts as we understand them, and as explored under the so-called self-assessment analysis set out in this advice, it is our view that such a collective arrangement is either unlikely to fall within the ambit of the relevant competition rules; or in the alternative, will not produce an appreciable effect on competition such as will attract the application of the competition rules. If that is not the case, there is a good argument that the collective arrangement will benefit from exemption from the application of the competition rules.
Our only recommendation is that NGNuk continues to engage with smaller companies in the implementation process to ensure that implementation does not place an unduly heavy burden on them, contrary to the spirit and intention of the Minimum Standard.”
Peter Ryde stated that the legal advice received seemed to address the concerns raised by the Executive regarding the potential for NGNuk acting contrary to competition law. It was agreed that the Executive would review the advice within their own companies, with a view to discussing the next steps for promoting wider adoption of the Standard at the May Executive meeting.
Action 2 – 25/03/2010 – May 2010 Exec to include a discussion on the wider adoption of the Minimum Standard following member’s internal review of the legal advice obtained by NGNuk from Wragge & Co.
Gareth Davies provided a brief update on the activities which have followed Ofcom publishing its statement “Responding to recent developments to protect consumers, promote competition and secure efficient investment” on 28th January 2009 (http://www.ofcom.org.uk/consult/condocs/ngndevelopments/ngnstatement/)
An Ofcom letter to NGNuk dated 26th January and representations at the NGNuk January Exec requested; “that NGNUK should lead the development of a common industry approach to mitigate the risks of the limitations in compatibility of alarm terminal equipment with NGNs, establishing constructive engagement between its members and alarm industry associations for this purpose”
Ofcom had made six specific requests of NGNuk namely;
1. Ensuring that the alarm communities get as much advance notice as possible of changes in technical characteristics of networks that would be likely to affect alarm services;
2. Providing technical guidance on terminal equipment compatibility – we would appreciate it if NGNUK members could secure the resources necessary for NICC to complete its guidance document and to develop the suggested testing guidance
3. Making timetables for NGN deployment and migration more visible to the alarms industries
4. Ensuring that NGNUK members provide advice about alarm compatibility to consumers migrating to NGN telephony services in an appropriate/timely manner;
5. Ensuring that consumers receive appropriate reactive advice in response to queries or issues concerning alarms; and
6. Ensuring that detailed queries on alarm compatibility are directed to alarm providers
Peter Ryde was tasked with reviewing these requests and recommending a course of action to the NGNuk Exec. For the purposes of the discussion PR treated the first three “asks” as being technically focused and the second three as largely communications orientated.
PR gave an summary of the process that he had gone through to identify the needs of the two sectors covered by the Ofcom request , the current levels of support and the issues to be addressed. In addition a brief overview of the how NGN terminal compatibility issues affect the sectors was provided.
Status of Technical Issues
PR stated that there is a need to differentiate between CP support for 21CN migration and any lines affected by this , from those lines affected by a CPs own implementing of an NGN. PR also remarked that despite the excellent work by BT21CN there appears a general lack of support from non BT CPs for this BT21CN led activity. 21CN has suggested CPs establish industry fora for critical industries, which would include both the Telecare and Security industries , although it is not clear the level of support that CPs are willing to give to this.
PR commented that it seems that the 21CN led activity has raised expectations of the impact of NGN deployments. CP network deployments are not directly comparable to that of 21CN in their impact on end users. Some CPs have already implemented large scale NGNs and whilst these have created some problems , evidence would suggest that the scale is manageable rather than “catastrophic” That said, little information is provided by major CPs to Industry Associations ( IAs) and Alarm Providers (APs) . Ofcom noted , however, that feedback they have received recently indicates that the level of problems being encountered by Alarm Providers is increasing.
PR stated that the key technical data and network information that APs require from CPs is benchmarked against BT21CN. This may not be appropriate but no dialogue exists between IAs and non BT CPs to resolve this or reset expectations
He reported that NICC are progressing the request from Ofcom for technical support via a) Pan-industry guidance to CPE designers for NGNs, and b) the compilation of a common test suite. The former is anticipated shortly although the latter may not be available until Q3 2010. PR considered that whilst 21CN testing activities can inform IAs/CPs on the compatibility of equipment with other NGNs , this BT 21CN data cannot be taken as any form of guarantee of compatibility. BT has had to physically change the 21CN network to achieve compatibility. Others may not have done or do likewise. This point was accepted by the Executive. Guidance by NICC is not therefore not just about provision of information – it is also about the availability of some level of test capability against the NICC guidance.
Peter Ryde also identified that during discussions with APs, it was clear that there was a desire for information across a variety of existing and developing products, over and above that which will be addressed by NGNuk. It was also clear that APs might benefit from clearer guidance on the impact of multiple interconnecting networks and associated IP/TDM conversions , the use of LCR within PBXs or diallers and of using non geographic numbers on the solutions they implement .
Recommendations to support Ofcom Technical “asks”
1. Wherever possible NGNuk members need to support the existing 21CN activity
2. That the 21CN suggestion of industry fora should be supported by NGNuk members, as appropriate
3. An NGNuk led workshop should be held involving CPs and IAs (including manufacturers) to;
a. Identify the key technical data and network information Alarm Providers require from CPs relating to their NGNs, that is practical and feasible for CPs to collate. Agree the frequency with which this is updated and the method of distribution.
b. Review the options available regarding how the alarm industry and CPs can best support testing against the NICC specification (Note; for feedback and future consideration by NGNuk Exec)
c. Review the practicality of developing guidance for IAs on the impact of multiple networks , of using LCR, Non Geographic numbers etc
d. Clarify how end users will be affected by the various products/NGNs
4. NGNuk should write to IAs communicating the scope of its work as being only PSTN. Other products can be addressed via the 21CN proposed Industry Fora , once established. This letter should also clarify how NGNuk members apply the NICC NDs
5. NGNuk should provide support to NICC with the development of guidance information and /or the test specification where appropriate and when requested to do so by NICC.
Status of Communications Issues
PR started the communications feedback by saying that he had contacted 2 CPs with a scenario which when migrated from an existing PSTN line , would NOT work on an NGN. With both CPs he went through sales process and found that;
PR reported that there were a limited number of alarm problems during BT 21CNs Pathfinder 1 trial . This, plus greater knowledge of alarm compatibility means that BTR will scale back future support to end users. EUs will be referred back to their AP in the first instance
PR stated that it was impractical for CP agents to advise end users on alarm compatibility with their NGN since similar testing to BT21CN has not been undertaken by the CP, as the 21CN tests do not infer performance on another NGN and it is outside of the scope of the agents expertise. A safer option (for EUs) is to refer them to their alarm provider, providing test data is available
Some confusion exists as to which products are affected and how e.g. MPF vs. WLR vs.CPS
PR stated that whilst the problems associated with NGN migration appear to be low in number , he considered the lack of information to alarm providers and end users needed to be considered where:
Recommendations to support Ofcom Communications “asks”
PR recommended that NGNuk members deploying NGNs , should actively support the 21CN proposal for industry fora since this would help establish communications channels to address the wider product set and any emerging issues.
PR also proposed an NGNuk led “communications” CP work shop to:
Discussion of recommendations
It was accepted that the current arrangements did not alert end users adequately, especially when moving providers and that this needed to be addressed.
Peter Ryde was challenged as to whether CPs would not be duplicating effort between the workshops and the proposed fora. PR stated that he did not consider this to be the case since the NGNuk workshops were a short term and immediate action , whereas he anticipated that any BT21CN inspired fora would be unlikely to commence in the immediate future.
It was agreed that the fora suggested by BT 21CN appeared a useful and practical option , and that members would endeavour to support these where appropriate.
Peter Ryde suggested that the initial technical work should be undertaken in association with the TSA , who he had found to be more pragmatic and with a better understanding of the technical issues. Subsequent engagement of the BSIA would then be on the basis of whatever was agreed with the TSA.
The general view of the meeting was that the IA/alarm manufacturers should take responsibility for testing against the anticipated NICC test suite. PR stated that whilst he did not disagree with this stance, that he was keen to use the dialogue with the IAs to understand any practical problems that would need CP support, since having test data available worked to the benefit of the CP customers.
The recommendations were accepted in principle with feedback on progress requested at the next Exec.
Action 3 – 25/03/2010 – Peter Ryde to develop a briefing/scope document covering the background and objectives to the proposed workshops on terminal compatibility for comment and agreement by members prior to the workshops
Action 4 - 25/03/2010 – Peter Ryde to run the proposed Technical and Communications workshops, relating to Terminal Compatibility
Neil McArthur proposed 3G offload as an discussion item for the NGNuk Executive and had distributed a short paper on the background.
He stated that data volumes from Smart phones are increasing rapidly. Demand created by smart phones, initially the iphone, more latterly Google’s Nexus with Android and now a lot more devices is driving up data volumes on mobile networks but also for the fixed line operators delivering the users home service.
NMcA expressed the view that 3G networks might not scale easily to cope with this exponential demand, especially since only about 10% population are using smart phones. Offload to Wi-Fi would therefore increase rapidly with the availability of a generation of new low cost smart phones. He noted that 3GPP Release 8, is all about 3G off load onto Wi-Fi and that Release 10 is all about 3G Wi-Fi use by application.
He expressed the view that “industry” should therefore be considering how to deal with the exponential demand in data. He noted that whilst fixed line operators were unlikely to have any issue with their consumers using their BB line for WiFi connectivity to mobile devices in the home , this might not be the case where mobile operators use this capacity/functionality as part of their own tariff package.
Whilst T-Mobile had expressed the view that 3G Offload was not an appropriate subject for the NGNuk Exec, following the discussion of the points raised by Neil McArthur those members present considered that it merited a more detailed discussion at the May Executive meeting. Gareth Davies stated that in view of the points raised he would wish to invite other interested parties within Ofcom.
Action 5 – 25/03/2010 - Peter Ryde to support Neil McArthur in developing the existing paper further to facilitate a more detailed debate at the next NGNuk Exec.
Rod Smith provided an update on the year to date position against the 2009/10 budget and its impact on 2010/11.
1. Neil McArthur raised an issue relating to unbundling in rural locations where he felt that addressing some common issues would allow a significant number of currently uneconomic exchanges to be unbundled. It was agreed that this would be better raised via OTA2.
2. Given the previous NGNuk activity regarding points of interconnect, BTW were asked to confirm where the BTW consultation on VoNGA was being discussed. This was confirmed as 21CN.
3. The next scheduled meeting was 10.00 to 13.00 on 20th May at Riverside House.
Peter Ryde
NGNuk Office
07771 555 048
020 7783 4688
peter.ryde@ngnuk.org.uk
| 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. Closed. Reopen should NICC output be received | Peter Ryde Closed |
| 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. This was due to be presented at the January Exec but held pending decision on NGNuk position in 20010/11. There is no active sponsoring member. Closed pending a sponsor. | Peter Ryde Closed |
| 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. Agenda item for March Exec | 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. This had stalled awaiting discussion with GSMA however there is no active sponsoring member. Closed pending a sponsor. | Peter Ryde Closed |
| 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. This had stalled awaiting discussion with GSMA however there is no active sponsoring member. Closed pending a sponsor. | Peter Ryde Closed |
| 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. Presented at the January Exec but held pending decision on NGNuk position in 20010/11. There is no active sponsoring member. Closed pending a sponsor. | Peter Ryde Closed |
| 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 Presented at the January Exec but held pending decision on NGNuk position in 20010/11. There is no active sponsoring member. Closed pending a sponsor. | Peter Ryde Closed |
| 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. Closed. Reopen should NICC request further assistance | Peter Ryde Closed |
| 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 . Meeting with CESG on 17th February. No subsequent feedback. | Peter Ryde Ongoing |
| Action 1 – 28/01/2010 - Peter Ryde was asked to highlight to the signatories of the CoP not present , that the Exec agreed that it would accept any decision by NICC that T-Mobile’s interconnects were out of scope so as to allow them the opportunity to comment | Peter Ryde Completed |
| Action 2 – 28/01/2010 - Peter Ryde to distribute the legal advice from Wragge and Co , once received by NGNuk. Distributed | Peter Ryde Completed |
| New Actions | |
| Action 1 - 25/03/2010 – Write to T-Mobile clarify the role of NICC in line with the statement from NICC TSG ( Paul Rosbotham) . | Peter Ryde |
| Action 2 – 25/03/2010 – May 2010 Exec to include a discussion on the wider adoption of the Minimum Standard following member’s internal review of the legal advice obtained by NGNuk from Wragge & Co | Exec /Peter Ryde |
| Action 3 – 25/03/2010 – Develop a briefing/scope document covering the background and objectives to the proposed workshops on terminal compatibility for comment and agreement by members prior to the workshops | Peter Ryde |
| Action 4 - 25/03/2010 – Run the proposed Technical and Communications workshops, relating to Terminal Compatibility | Peter Ryde |
| Action 5 – 25/03/2010 - Developing the existing paper on 3G Offload to facilitate a more detailed debate at the next NGNuk Exec. | Peter Ryde /Neil McArthur |