FTTC Passives Inputs - Consultation Document

Contents Page

1 Document Description 3

2 Legal Statement 4

3 Background 5

4 Consultation 6

5 Guidance on Responding to this Document 7

Annex A: Overview of Openreach FTTC Product 8

Annex B: Glossary of Terms 9

1  Document Description

This consultation document has been issued to seek comments from Communications Providers (CPs) on “FTTC Passive Inputs and Backhaul Products provided over the optical fibre part of FTTC”[1]; as detailed in Section 5.56 of the Undertakings given to Ofcom by BT pursuant to the Enterprise Act 2002[2]:

“5.56 AS [Openreach] shall conduct a consultation with industry in order to assess the demand for and Communications Providers’ views on the design of FTTC Passive Inputs and Backhaul Products provided over the optical fibre part of FTTC. AS [Openreach] shall complete this consultation within three months of such time as End-Users in 1million premises are taking services based on a BT Active FTTC Product or at the latest during the course of 2011. The consultation process will address the needs of Communications Providers wishing to invest at the time of BT’s upgrade programme as well as the reasonably foreseeable needs of those considering investing at some future time”

Further relevant legal and regulatory information is included in this document in sections 3 and 4, and a description of the Openreach FTTC product (“BT Active FTTC Product”) is included in Annex A as reference material for this consultation.

Please note that Physical Infrastructure Access (PIA), Sub-Loop Unbundling (SLU) and Fibre to the Cabinet Generic Ethernet Access (GEA-FTTC) based products are regularly reviewed through Openreach cross industry/trialist working groups (IWG/TWGs) with attendance and input from CPs, the Office of the Telecommunications Adjudicator (OTA), and Ofcom. In the first instance we would expect prospective developments to these products to be addressed through the relevant working groups using the standard Statement of Requirements (SoR) process and the associated prioritisation processes. However, Openreach are also pleased to invite responses relevant to Section 5.56 of the Undertakings and any further comments on this consultation by 7th November 2011.

If you require any further assistance interpreting any of the information given in this document please contact Bob Lee at . Please also see Section 5 “Guidance on Responding to this Document”.

2  Legal Statement

This document is published for the purposes of seeking prospective CP requirements for FTTC Passive Inputs. Where appropriate it also sets out Openreach views and latest available information.

Certain statements in this presentation are forward-looking. Although BT believes that the expectations reflected in these forward-looking statements are reasonable, it can give no assurance that these expectations will prove to have been correct. Because these statements involve risks and uncertainties, actual outcomes may differ materially from those expressed or implied by these forward-looking statements.

Factors that could cause differences between actual outcomes and those implied by the forward-looking statements include, but are not limited to: material adverse changes in economic and financial markets conditions in the markets served by BT; supplier arrangements; future regulatory actions and conditions in BT’s operating areas; technological innovations; developments in the convergence of technologies and the anticipated benefits and advantages of new technologies, products and services, including broadband, not being realised.

This consultation on FTTC Passive Inputs represents the Openreach view at the time of publication. It does not represent a finalised definition or plan for product implementation. Content may be subject to change dependent on further consultation with stakeholders and assessment of relevant commercial, legal and regulatory considerations and the ability of Openreach to make a return on its investment. Any developments carried out by a CP based on the contents of this document are entirely at the CP’s own risk.

3  Background

In June 2009, BT was granted a Variation[3] to the Undertakings given to Ofcom by BT pursuant to the Enterprise Act 2002, which allowed Openreach to operate and control the active electronics for the Openreach FTTC product (described for reference in Annex A of this document).

At the time of the Variation request, some CPs expressed an interest in having access to the physical layer (also referred to as passive) elements of the Openreach network used to create the FTTC product. In response to this BT gave Ofcom a number of commitments[4]. These commitments included a plan to consult with industry to assess demand for potential passive products in the future. This consultation fulfils that commitment.

“FTTC Passive Inputs” is a defined term in section 2.1 of the BT Undertakings, as amended by the FTTC Variation in March 2009, and is described as follows:

(i)  access to the copper wires that connect the End-User premises to a Local Access Node contained in the BT FTTC street cabinet;

(ii)  the provision to a Communications Provider of a FTTC street cabinet (which for the avoidance of doubt could include a cabinet facility attached to or otherwise integrated with a BT FTTC street cabinet), cooling, ventilation and power therein where practicable, and copper tie-cables, where required; and

(iii)  the various associated components of the Physical Layer of BT’s Access Network connecting the Local Access Node in the BT FTTC street cabinet and the End-Users premises to the extent that these components are only to be used in connection with the provision of services that are run over the entirety of FTTC.

Local Access Node, FTTC and Exchange are also defined terms in the Undertakings:

“Local Access Node” means “a node in an Electronic Communications Network” which supports the provision of services to End-Users. For the avoidance of doubt, such nodes include the following, namely a distribution frame, an optical distribution frame, a digital local exchange, a digital subscriber line access multiplexer, a remote concentration unit and an MSAN”.

“FTTC” means “a network structure for access at End-Users’ premises at fixed locations in which optical fibres connect a node in an Exchange to a Local Access Node contained in a street cabinet, and copper wires connect the End-Users’ premises to the Local Access Node contained in the BT street cabinet.”

In the context of FTTC, “Exchange” means “a BT building containing a Local Access Node”.

The FTTC Variation was granted to enable Openreach to deploy all network elements of the FTTC GEA product in an integrated way, facilitating an efficient and economically viable Next Generation Access (NGA) network roll-out. A full discussion of the relevant regulatory and legal factors associated with the Variation can be found in both the original Variation Consultation[5] and Final Statement[6] and therefore are not reproduced here.

4  Consultation

Since the original FTTC Variation was drafted and approved in 2009, there have already been significant regulatory, product and technology changes. Openreach has further developed products such as GEA, SLU and PIA to take account of regulations introduced by Ofcom’s Review of the Wholesale Local Access Market (WLA MR)[7] concluded in October 2010. These developments now enable CPs to deploy NGA based services or infrastructure in a variety of different ways to suit their needs or business models.

In the first instance, we would expect the standard Industry/Trialist Working Groups (IWG/TWGs) to be appropriate forums to accommodate discussions and requirements capture for any new prospective passive inputs for FTTC - in particular the PIA and SLU groups as these naturally focus on access to the physical infrastructure of the Openreach network. However to ensure we fully meet the terms of the Undertakings Variation, we are formally consulting with Industry on the requirements for ‘FTTC Passive Inputs’ through this document.

In particular, in the light of Section 5.56 of the BT Undertakings, Openreach would welcome views on the following:

1.  Are there elements over and above those already provided by the SLU, GEA and PIA products that you require Openreach to provide as an FTTC Passive Input?

2.  If yes, please provide the following information:

a.  details of the additional requirements;

b.  your estimated demand for those elements;

c.  whether an SoR request has already been submitted for the request; and

d.  any other information relevant to the prospective developments which would normally be contained in an SoR[8] (for example target date, target price and priority to your business etc).

3.  Any other views on the design of FTTC Passive Inputs and Backhaul Products provided over the optical part of FTTC, and their related systems and processes.

5  Guidance on Responding to this Document

Openreach invites responses and any further comments on this consultation document.

As an open invitation to ongoing dialogue on this consultation please contact your Sales and Relationship Manager if you wish to hold bi-lateral discussions with Openreach prior to submission of your response.

This consultation will also be discussed further at the main Openreach Industry meetings (NGA, Ethernet, Copper, SLU, PIA) during October/November 2011.

Customers wishing to input into the consultation are asked to send their comments to the following email address:

The closing date for the consultation is 7th November 2011.

Annex A: Overview of Openreach FTTC Product

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 15Mbit/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 four variants (Note: higher speeds to be introduced during 2012):

o  up to 40Mbit/s downstream - with up to 2Mbit/s, 10Mbits/s or 15Mbits/s upstream

o  up to 15Mbit/s downstream - with up to 2Mbit/s 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 (e.g. duct) at the Ethernet layer or “layer 2”. This is why it is referred to as “virtual unbundling”.

The additional ability to share the infrastructure improves the challenging economics of fibre deployment and is a common principle applied when building high speed networks. Each network connection is not individually and physically hard wired from every point to all other points but “virtual connections” or VLANs can be established which can connect “many to many” ie all users to all other users.

Annex B: Glossary of Terms

Abbreviation / Full Name
BT / British Telecommunications plc
CP / Communications Provider
D-side / E-side / Distribution side / Exchange side
DSLAM / Digital Subscriber Line Access Multiplexer
EoI / Equivalence of Input
FTTC / Fibre To The Cabinet
FTTP / Fibre To The Premise
GEA / Generic Ethernet Access
IWG / Industry Working Group (Industry wide attendance)
MPF / Metallic Path Facility
MSAN / Multi Service Access Node
NGA / Next Generation Access
NTE / Network Termination Equipment
OTA / Office of the Telecoms Adjudicator
PCP / Primary Connection Point
PIA / Physical Infrastructure Access
SFBB / Super Fast Broad Band
SLU / Sub-Loop Unbundling
SMPF / Shared Metallic Path Facility
SoR / Statement of Requirements
SSFP / Service Specific Front Plate
TWG / Trialist Working Group (Attendance focussed on those CPs trialling the product)
VLAN / Virtual Local Access Network
VULA / Virtual Unbundled Local Access
WLA MR / Wholesale Local Access Market Review
WLR / Wholesale Line Rental

** END **

Issue 1 - 10th October 2011

Issued by Openreach

© British Telecommunications plc 2011 Page 2 of 9

[1]The Openreach FTTC product (the “BT Active FTTC Product”) is called Generic Ethernet Access (GEA), and a description is included in Annex A of this document.

[2] http://stakeholders.ofcom.org.uk/binaries/telecoms/policy/bt/consolidated.pdf

[3] http://stakeholders.ofcom.org.uk/binaries/consultations/fttc/statement/statement.pdf

[4] See paragraphs 5.56-5.58 of the variation for the detail of the requirements

[5] http://stakeholders.ofcom.org.uk/binaries/consultations/fttc/summary/fttc.pdf

[6] http://stakeholders.ofcom.org.uk/binaries/consultations/fttc/statement/statement.pdf

[7] http://stakeholders.ofcom.org.uk/consultations/wla/statement

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

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