Physical Infrastructure Access (PIA) - Internal Reference Offer (IRO) - Openreach
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Physical Infrastructure Access (PIA)
Internal Reference Offer (IRO)
August 2019 – Issue 4
Issue 4 – 01/08/2019 1 of 38Foreword On 28 June 2019, Ofcom published its Physical Infrastructure Market Review (PIMR) final statement setting out the regulation applying to Openreach’s physical infrastructure (ducts, poles and underground chambers). This document forms part of Openreach’s PIMR obligations commonly referred to as an internal Reference Offer (IRO). Openreach Openreach Ltd is a wholly-owned subsidiary of BT looking after the networks and physical infrastructure that connect tens of millions of homes and businesses to phone, broadband, and TV. We have our own Board, separate brand and approximately 31,000 strong independent workforce, including the largest team of fibre broadband engineers in the country. Openreach is a highly regulated and functionally separate business designed to provide products and services in a non-discriminatory way, primarily through obligations to sell those products on an Equivalence of Inputs (EoI) basis. The major EoI products include those supporting Ethernet, local loop unbundling, and fibre broadband amongst others. Openreach relies on its physical infrastructure (its ducts and poles) to deliver these services and meet its regulatory obligations, as well as enabling it to compete commercially with operators that have their own networks, platforms and physical infrastructure (e.g. cable, wireless and TV). Consequently, Openreach does not have the same discretion as a CP investing in a new network and choosing only to access specific parts of Openreach’s physical infrastructure. The PIMR (as did the WLA market review) concluded that Openreach should not be required to purchase its own Physical Infrastructure Access (PIA) product on an EoI basis,1 as this could increase costs and require new systems and processes to be implemented within Openreach, as well as potentially impacting Openreach’s ability to invest in new fibre networks. Instead, Ofcom imposed a ‘No Undue Discrimination’ obligation for PIA.2 This document supports the regulation by increasing transparency of Openreach’s internal operations and enabling comparison with the terms and conditions of its PIA product. This document will be updated regularly to include changes to the PIA product, and where relevant, additional details of Openreach’s internal processes as they are further developed and documented. 1 See WLA Final Statement Volume 3 paragraph 3.39, and PIMR Final Statement paragraph 4.77. 2 See WLA Final Statement Annex 33 Condition 4, and PIMR Final Statement Annex 26 Condition 4. Issue 4 – 01/08/2019 2 of 38
Table of Contents 1. Introduction .............................................................................................................................................. 4 2. Overview of the PIA product and Openreach’s Fibre First programme ................................................... 6 2.1 Physical Infrastructure Access (PIA)........................................................................................................ 6 2.2 Openreach’s Fibre First Programme ....................................................................................................... 7 3. Key Differences - PIA product and Openreach Internal Usage for FTTP ................................................... 9 3.1 Forecasting and Plan & Build .................................................................................................................. 9 3.2 PIA systems ........................................................................................................................................... 11 3.3 The Order/Notice of Intent (NoI) Process............................................................................................. 13 3.4 The Build Complete Process ................................................................................................................. 15 3.5 The Network Adjustments Process ....................................................................................................... 16 4. Comparison of PIA legal instrument conditions to Openreach’s usage.................................................. 22 5. Regulatory Financial Reporting ............................................................................................................... 29 ANNEX A - Network Adjustment Categories ................................................................................................... 30 ANNEX B – Network Adjustments and the ‘Path to Collaboration’ model. .................................................... 31 ANNEX C – Key Performance Indicators (KPIs)................................................................................................ 32 ANNEX D - PIMR Legal Conditions. .................................................................................................................. 33 ANNEX E - Further Information Sources. ........................................................................................................ 36 ANNEX F - Glossary of Acronyms. ................................................................................................................... 37 Issue 4 – 01/08/2019 3 of 38
1. Introduction
Background to the PIA internal Reference Offer (IRO)
1. The Physical Infrastructure Access (PIA) product, also known as Duct and Pole Access (DPA), is made
available to Communications Providers (CPs) by Openreach. PIA allows CPs to place orders to gain direct
access to Openreach’s physical infrastructure (ducts, poles, and underground chambers) so that they
can deploy their own fibre networks to supply broadband and/or business connectivity services3 to their
end-customers.
2. The PIA product also enables PIA customers to order Network Adjustments from Openreach. Network
Adjustments are a range of network and civil engineering activities which are necessary, feasible and
efficient4 and are required to repair or relieve congestion in existing Openreach physical infrastructure.5
3. Openreach does not purchase the PIA product to use its physical infrastructure. Therefore, this internal
Reference Offer (IRO) document is intended to increase transparency of Openreach’s internal
processes, and where relevant, identify differences with the PIA product. This document is based on
two information sources.
Firstly, the most recent external reference offer issued by Openreach effective from 1 August 2019,
6
which governs the Physical Infrastructure Access product provided to third parties; and
Secondly, Openreach’s internal use of its physical infrastructure for the purposes of deploying Fibre
to the Premises (FTTP) and/or Ethernet networks, and in so far as possible, comparing these to the
externally sold PIA product.
4. This document represents a current comparison of PIA with those systems and processes that we apply
where we use existing physical infrastructure. In this context, we look to Openreach’s Fibre First towns
and cities FTTP programmes (FFC) as the primary benchmark.7 This comparison has been chosen as the
key policy driver behind the WLA PIA remedy is to support, where viable, further third party FTTP
investment in the UK.8 However where appropriate we also compare to Ethernet services.9
5. To date, we have been trialling many different techniques and operational processes10 to deploy FTTP
and are now refining these into a standardised approach to apply on a forward looking basis. It is this
broad approach which is described in this document. Therefore this document will be subject to further
development and refinement on an ongoing basis.
6. We have reviewed the external reference offer conditions set out in the PIMR legal instrument, and
cover these in Section 4 of this document. But have also focussed in more detail on specific areas where
we understand stakeholders require more information regarding Openreach’s internal use of physical
infrastructure in the context of FFC, and have covered these in Section 3 of this document.
7. In Section 3 we set out the main differences between Openreach’s internal use and the PIA product and
an explanation of why such differences exist. The areas covered include the Plan and Build process, PIA
Digital Maps system, Order/Notice of Intent (NoI) process, Build Complete process and the Network
Adjustment validation process.
3 Previously under WLA regulation PIA customers could only use the PIA product if they were planning to supply ‘mixed usage’ services i.e. primarily
broadband services but business connectivity services could also be supplied as a secondary use case. These restrictions have now been removed
by the PIMR final statement.
4 Please see paragraphs 2.31 to 2.93 ‘WLA Market Review: Statement – Volume 3 – PIA remedy’. Ofcom also set a range of other criteria which a
network adjustment must fulfil. Also see paragraphs 5.87 to 5.123 of the PIMR final statement.
5 Please see Section 2 of this document for an overview of the PIA product, including Network Adjustments.
6 Please see the PIA contractual documentation at: https://www.openreach.co.uk/orpg/home/products/ductandpoleaccess/ductandpoleaccess.do
7
Please see: https://www.openreach.co.uk/orpg/home/index.do for further details.
8 Rather than other Openreach uses such as for the LLU MPF product for example.
9 We will continue to work with stakeholders to refine the process and KPI comparisons going forward to take account of the new unrestricted
nature of the PIA products.
10 Please see Section 2.2 for some further background on our Fibre First towns and cities programmes.
Issue 4 – 01/08/2019 4 of 388. For ease of reference, the legal conditions covering the IRO are attached at Annex D of this document.
These are set out in Annex 26 of the PIMR Final Statement published on 28 June 2019.11
9. The structure of the IRO is as follows:
Section 1 - provides background information on Openreach, PIA and on how the IRO has been
prepared.
Section 2 - contains a high-level description of the PIA product and the Openreach Fibre First
programme.
Section 3 – covers the main areas that stakeholders have identified as needing further transparency
such as PIA ordering processes and systems, and network adjustments.
Section 4 – lists the legal conditions in the PIMR legal instrument for the PIA Network Access
reference offer and comments on the comparison with Openreach’s internal usage of infrastructure.
Section 5 – gives an overview of current regulatory accounting consultations and how they will
develop to give further transparency to both internal and external PIA transactions.
Annex A – summarises our approach to validating different categories of Network Adjustments.
Annex B – outlines how our ‘Path to Collaboration’ approach will operate for Network Adjustments.
Annex C – sets out our initial views on KPIs and operational metrics that we will publish.
Annex D – includes an extract of the legal conditions applying to the PIA reference offer.
Annex E - provides links to PIA product and contractual information as well as other supporting
information from the Openreach website including relevant Passives Industry Working Group (PIWG),
and Copper and Fibre Products Commercial Group (CFPCG) information.
Annex F – includes a glossary of the abbreviations and acronyms commonly used in relation to
Openreach products and services.
11 PIMR Final Statement Annex 26 – Conditions 7.2, 7.3 and 7.4.
Issue 4 – 01/08/2019 5 of 382. Overview of the PIA product and Openreach’s Fibre First programme
10. In this section we highlight the major similarities between the PIA product and Openreach’s internal
usage of physical infrastructure for FFC. Section 3 focusses on the main differences.
2.1 Physical Infrastructure Access (PIA)
11. PIA is a product which enables CPs to utilise Openreach’s physical infrastructure in ways which support
their investment in new fibre networks. CPs are able to rent access to ducts, poles, underground
chambers, plus request Network Adjustments, and purchase a range of other ancillary services to help
link into their own physical infrastructure. 12 Openreach uses the same physical infrastructure 13 to
deploy its own FTTP networks.14 Openreach also uses infrastructure belonging to third parties such as
energy companies but this infrastructure does not form part of Openreach’s PIA product.
12. Please see Figure 1 below, which illustrates how PIA customers can access the same Openreach
infrastructure elements that Openreach uses for FFC. Working from the left-hand side of the diagram
the text boxes explain the common elements used by both Openreach and a PIA CP when building an
FTTP network from an Openreach exchange/Point of Handover (PoH), or CP Point of Presence (PoP) to
an end-user premises.
2. Duct, poles & chambers 4. Duct, poles & chambers occupied by
occupied by e-side fibre d-side fibre (shown by blue dashed
(shown by blue dashed line) line) – can be used for an FTTP based
can be used by both deployment.
Exchange or Openreach and PIA customers
Pole End-user
CP PoP as part of an FTTP deployment.
8. Final drop
6. Spine Duct
7. Lead in duct
Fibre cable Fibre cable
1. Cablelink is required if CP 5. Final FTTP drop to end-user could be via
wants to link its FTTP network 3. A GPON Splitter or other
a pole or lead-in duct. The Connectorised
installed in Openreach physical fibre equipment can be
Block Terminals (CBTs) or alternative CP
infrastructure to space rented in placed in an underground
equipment could be attached to poles or
an Openreach POH/Exchange. chamber for FTTP by CPs or
placed in UG chambers.
Openreach.
Figure: 1
13. PIA customers do not need to collocate at an Openreach PoH or in the Openreach exchange area serving
the end-user, and since the introduction of the PIMR they are no longer restricted to using PIA for their
access network.15
14. Openreach does not purchase the PIA product as an input into its services,16 however the Openreach
physical infrastructure elements used are the same (i.e. the occupation of spine and lead-in ducts, poles,
footway boxes and manholes by Openreach network). Openreach also carries out many different civil
12 Please see the full set of PIA products at: https://www.openreach.co.uk/orpg/home/products/ductandpoleaccess/ductandpoleaccess.do
13
Where it exists. Openreach also utilises methods such as Direct in Ground (DIG) as do other CPs.
14 And all other services such as Ethernet, FTTC, LLU, WLR etc.
15 Ofcom’s ‘Physical Infrastructure Market Review’ introduced unrestricted PIA and the product can now be used for any purpose in the network
including access, backhaul and core.
16 Or for any other services such as Ethernet, FTTC, LLU, WLR etc.
Issue 4 – 01/08/2019 6 of 38engineering activities when it builds networks, and therefore if applicable will also use a range of
network adjustment activities similar to PIA customers for adjustments to its physical infrastructure.
15. The Openreach physical infrastructure represents only a part of the overall fibre and infrastructure build
required for an FTTP network deployment. Openreach and CPs also need to carry out a much wider
range of network build activities which are not part of the PIA remedy (e.g. installing fibre cabling, new
infrastructure asset construction, site surveys, obtaining relevant wayleaves, training and accreditation
of their engineers and contractors etc.).
16. The PIA product range maps onto Figure 1 as follows:
Spine duct - this is the main duct infrastructure running from the serving exchange to a distribution
point close to the end-user premises (see 6 above in Figure 1). CPs are granted a licence to install
multiple cables up to 25mm in diameter for the spine of their fibre network within Openreach’s duct
infrastructure.
Lead-in duct - this is the duct between the last distribution point and the end user premise (see 7
above in Figure 1).17
Pole access - Openreach grants a CP a licence to attach and maintain a cable, blown fibre attachment
or pole top equipment to one of Openreach’s existing poles to carry out a final drop (i.e. distribution)
to an end-user premises (see 7 above in Figure 1); and/or to provide the ‘carrier’ element of their
network deployment (i.e. serving a similar function to duct access to build out from their PoP).
Underground chambers - CPs can rent space in Openreach’s underground chambers to place their
equipment (see 3 above in Figure 1).
Network Adjustments - the PIA product also provides the facility for CPs to order Network
Adjustments from Openreach. These are a range of network and civil engineering activities which
are necessary to repair or relieve congestion in existing Openreach physical infrastructure. For a
Network Adjustment to qualify as a legitimate request it has to be a necessary, feasible and efficient
adjustment. 18 CPs can either request Openreach to carry out the adjustment or carry it out
themselves (a self-provide order) in line with the terms and conditions of the PIA contract. Please
see Section 3.5 of this document for more details.
Ancillary Services - there are a large range of ancillary services that a CP can request from Openreach,
all of which are charged separately at cost oriented tariffs and listed on the Openreach price list.19
Access to the Exchange - PIA customers are able to use Openreach exchange space (see 1 above in
Figure 1) or their own PoP to house their headend equipment. If they choose to purchase Openreach
exchange space they are also able to buy a Cablelink product (which is not a PIA portfolio product)
to connect their external FTTP network into their space within the Openreach PoH/Exchange.
Alternatively, they can choose to link directly into a non-Openreach duct network or non-Openreach
PoP without using Openreach Cablelink products. Openreach FTTP deployments use Openreach
exchange space to house headend equipment but do not purchase a Cablelink product for exchange
access.
2.2 Openreach’s Fibre First Programme
17. Openreach already provides close to one and a half million premises in the UK with the capability to
buy FTTP, and the Fibre First programme aims to support a potentially a much larger upgrade of the
UK’s fibre infrastructure and to extend well beyond the existing coverage.20
18. Our current plan is to make 4 million premises capable of ordering GEA-FTTP by March 2021. This target
will set Openreach on a potential trajectory to achieve its ambition of building a fifteen million FTTP
17 There is also an element of the product which is referred to as Lead-in link duct which is currently under review by the product team.
18 Please see paragraphs 5.87 to 5.123 of the PIMR final statement. Ofcom also set a range of other criteria which a network adjustment must fulfil.
19 http://www.openreach.co.uk/orpg/home/products/ductandpolesharing/ductandpolesharing/ductandpolesharing.do
20 Please see: https://www.homeandbusiness.openreach.co.uk/fibre-first
Issue 4 – 01/08/2019 7 of 38footprint by the mid-2020s and if the conditions are right, to go significantly beyond, bringing the
benefits of FTTP to many more homes and businesses across the UK.
19. However, ensuring the majority of properties in the UK can have a full fibre connection is a massive task
and will take significant time, engineering, manpower and investment to deliver. Therefore, Openreach
needs to gain experience in building FTTP networks at scale and at a competitive cost. Our consultation
with industry21 helped us identify a set of enablers which would help to support this ambition.22
20. Fundamentally, we need to reduce the costs of delivering fibre at scale and ensure that there is demand
for and take up of the new FTTP platform. Therefore, we are trialling lots of different processes and
operating models around the country, with the aim to choosing and adopting best practice for all our
projects. The multiple FFC programmes have been particularly effective in enabling us to do this.
21. Consequently, we have already made significant progress in reducing the cost of delivering FTTP. We
are also piloting new ways of working, for example, with local government to simplify regulations and
traffic management.
22. Importantly, Openreach is also committed to providing CPs with a ‘fit for purpose’ high quality PIA
product to support their own investments in full fibre networks and/or business connectivity services,
both for large scale and more niche operations. As part of the FFC programme, Openreach uses the
same Openreach ducts, poles, and underground chambers for its fibre programmes as PIA customers
do.23 We have also sought to align our processes and systems, as far as possible, to ensure there is no
undue discrimination between how we use our physical infrastructure, and how PIA customers can use
it, including how we deal with the new Network Adjustment obligations. However, legitimate and
necessary differences do exist. We set out the major differences in Section 3 of this document and
explain why they are necessary.
23. We also aim to ensure transparency by reporting on a range of internal and external KPIs and
operational metrics to demonstrate that there is no undue discrimination across a number of key civils
related activities.24 The first tranche of reports was issued on 1 April 2019 showing the Openreach
metrics for Mean Time to Provide (MTTP), and a second tranche issued in July 2019 comprised two
major reports focussing on (i) PIA Service Performance and (ii) PIA Openreach Comparisons related to
the no undue discrimination obligations.25 The reports were issued to PIA customers, Ofcom and the
OTA.
24. These reports were built on significant work carried out to date with stakeholders and PIA customers.
However we are fully committed to continuing to work with all parties to develop and improve our KPI
information as part of our ongoing product development,26 both to increase the information available
to PIA customers on processing and completion times for a wide range of network adjustments, and to
provide further information to demonstrate that we are not unduly discriminating with respect to
Openreach’s internal activities. Please see Annex C of this document for further details on existing KPI
information.
21 Please see: https://www.openreach.co.uk/orpg/home/updates/briefings/generalbriefings/generalbriefingsarticles/gen04717.do
22 In addition to improving our own operational processes and commercial case, we also need a supportive public policy and regulatory
environment that encourages infrastructure investment.
23 Openreach may also decide to use the physical infrastructure of other providers to support its programmes through application of the ATI
Regulations.
24
The metrics are published on the PIA Closed User Group area of the Openreach Customer Portal under ‘My Dashboard’ at:
https://www.openreach.co.uk/orpg/home/home.do
25 These covered Mean Time to Provide (MTTP), Time to Verify and Performance vs CCD%,
26 Which is referred to as the ‘Day 2’ development phase. Day 2 refers to a series of future product, systems and process developments we are
working with the OTA and CPs to implement during 2019/20.
Issue 4 – 01/08/2019 8 of 383. Key Differences - PIA product and Openreach Internal Usage for FTTP
25. Stakeholders have raised a number of key items on which they require further transparency, which we
therefore cover in this section.27 They are addressed in the order of a PIA customer deployment process
and include:
Site selection, Forecasting and Plan & Build processes.
The systems used by PIA customers (the PIA Digital Maps system) and Openreach’s PIPeR system.
The Notice of Intent (NoI) ordering process.
The Build Complete process.
The Network Adjustment process.
26. In broad terms, these differences arise because a PIA customer is a third party accessing Openreach
assets (i.e. Openreach being a separate legal entity), and the PIA customer is the only party which knows
the inventory of the Openreach infrastructure that they are using, and on which date they start
providing ‘live’ end-customer services. These important elements are captured in the formal contract
(i.e. the terms of the Reference Offer) and are not applicable to transactions within Openreach.
27. Further, in the case of Network Adjustments, Openreach has a corporate governance responsibility to
apply sufficient controls to authenticate and control costs and liabilities generated by third parties
which directly impact Openreach’s cash flow and capital budgets.
3.1 Forecasting and Plan & Build
Openreach Process
28. The Openreach FTTP deployment process is subject to a highly structured and phased approach. As part
of the overall coverage objective individual cities, towns or other areas are identified in phases looking
approximately 12-18 months ahead and included in the rollout plan based on their suitability for an
FTTP product with good economics for Openreach, CPs and end-users. Major factors taken into
consideration during the selection process (amongst others) 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.
29. No forecast information provided by PIA customers to Openreach is used in any way other than to help
ensure we meet our contractual obligations to the PIA customer and to provide a quality PIA service.
Such information is strictly controlled and restricted to individuals on a need to know basis and who
only need it for operational purposes to support the PIA product.28
30. Underpinning the analysis of the major commercial 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:
1. Engineering assessments may rule out individual areas which are likely to be uneconomic for FTTP
deployment (e.g. due to a low density of premises or where existing broadband take-up is known to
be very low).
2. Openreach Regional and Public Policy teams continuously engage with local development agencies
and stakeholders to assess their commitment to fibre roll-out which can change over time.
27 This section does not address every detailed requirement that Ofcom has set for the PIA reference offer – the full list (twenty nine items) are
covered in Section 4 of this document.
28 Openreach recently held a briefing session for CPs on 22 July 2019 (organised by the OTA) to explain the extensive controls we have in place to
ensure the confidentiality of commercially sensitive CP information, including the recent introduction of the internal directory ‘PIA Marker’ system.
Any requests for further information on our internal controls can be made through the Passives Industry Working Group (PIWG) where a
presentation by the Business Integrity team (part of the Openreach Legal team) can be arranged.
Issue 4 – 01/08/2019 9 of 383. Other factors can also 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 or in a particular geography. 29
31. After a deployment area has been chosen for an FTTP network deployment, a coordinated and
committed delivery plan is agreed internally and with engineering contractors, concerning the coverage
and other infrastructure related work on duct, poles and chambers. Detailed internal forecasts of
resourcing and costs are then generated during January and February covering the whole upcoming
financial year commencing in April, and it is this process which enables the correct scaling of engineering
resource to be committed by Openreach and its contractors to the specified area to achieve the plan.
Additionally, all major operating and capital expenditures by fibre programme will be subject to a
detailed five year overview as part of our Medium Term Plan (MTP). We set out further operational
details of the Fibre First planning process in Section 3.5 of this document.
32. After the FTTP build is completed, 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 FTTP end-user
installation process is very important in achieving a robust and premium quality product.
PIA Customer Process
33. PIA customers have control over their site selection and build process; and to the extent that they
require access to Openreach physical infrastructure to build their network, the PIA Digital Maps system
provides the inventory information they need to feed into their planning tools, as well as estimates of
duct availability by individual duct section.
34. At the point that the CP decides that they wish to use Openreach infrastructure, then Openreach needs
to gear up to provide resources in the right locations, just as we do for our own deployments, as well
as tailoring our scalability and readiness plans for future demand. This is why we require good quality
forecasts from CPs. The hard reality is that Openreach and its external civil contractors cannot resource
appropriately for regional or national projects unless PIA customers provide reasonable and reliable
forecasts with sufficient lead-times, comparable to what we do for ourselves.
35. As set out above, we do this ourselves when planning for national or regionally focussed projects, but
we do not use the same forecasting process as that set out in the PIA contract. Openreach requires
much greater granularity and a longer view of all its operational activities, as it needs to forecast all
major products and operational field led activities by region for the whole of the UK. Therefore all major
operating expenditure and capital programmes (LLU, WLR, Ethernet, Fibre First, and BDUK etc.) will be
subject to a detailed five year overview as part of its Medium Term Plan (MTP).
36. This is why we need PIA customers to engage with Openreach ahead of their demand impacting
Openreach, in line with the agreed PIA forecasting requirements and process,30 to ensure alignment of
Openreach and external civils resources across all activities we are responsible for delivering.
37. This is particularly important to enable us to provide a quality service and given that a failure to deliver
to an SLA on our (or our external contractor’s) part means that Openreach may be liable to pay an SLG
on PIA or potentially another impacted product. PIA is not a service where Openreach can forecast
demand based on run rate, which is more viable for active services. The PIA customer’s capital
investment programme is under the control of the CP, and Openreach need the PIA forecasts to be
matched to CPs investment plans in order to be able to provide a good quality service and help tailor
our service capabilities.
29 Openreach works closely with its public funding partners such as BDUK, and civil engineering suppliers and depending on their priorities this can
lead to tactical changes to coverage plans being agreed which will be picked up in revised forecasts.
30 Please see PIA Contract Schedule 2.
Issue 4 – 01/08/2019 10 of 3838. Establishing best practice is also very important at this stage of the PIA lifecycle. If significant un-
forecasted demand materialises then it will put a significant strain on Openreach and external suppliers
and that will not generate good outcomes for either party.31 We need to deliver on our obligations, but
it is not unreasonable that a PIA customer has a proportionate incentive not to over or under forecast
to help Openreach resource to an efficient level, especially given the ambition for the PIA product over
the next few years to be the primary regulatory remedy for large regions of the UK.
39. We consider that the terms and conditions relating to forecasting for PIA32 are reasonable and not
disproportionate compared to our own processes, which are far more extensive and demanding, and
cover a much longer time period. We also consider the forecasting requirements to be proportionate
in relation to the obligations and responsibilities which fall on Openreach to make our infrastructure
available and to carry out network adjustments subject to SLA/SLGs.
40. As noted above, we recognise that PIA customers may have concerns about Openreach ensuring strict
confidentiality over the forecast information that they supply to Openreach. Therefore, we would be
pleased to provide further information to any stakeholder on the detailed controls we have in place to
ensure that such information is not shared inappropriately in Openreach, and therefore cannot be used
to influence Openreach’s own fibre deployment plans.
3.2 PIA systems
Overview of inventory and ordering systems
41. Openreach does not use the same inventory and ordering systems as PIA customers, as Openreach does
not purchase its own PIA product. Openreach uses its existing inventory system, called PIPeR, which
contains both physical infrastructure and network level information (including information on cables,
joint user poles, planned infrastructure etc.). PIPeR was not designed as a multi-CP system and is not
able to support the planning, ordering, and billing requirements of multiple third party PIA customers.
42. This level of system functionality needed by PIA customers is incorporated into our PIA systems so that
CPs can (i) access Openreach’s physical infrastructure records to assist their network planning, (ii) order
the PIA product, and (iii) record which elements of the Openreach infrastructure they are occupying.
More details of the ordering functions are given below in Sections 3.3 and 3.4.
43. However, a very important and key correlation between the PIA and Openreach systems and processes
is that the infrastructure records which feed the PIA system are the same as those used by Openreach,
and are sourced from the same system (i.e. PIPeR). A continuous update process ensures that PIPeR
updates are passed to the PIA system in approximately 24 hours.33 Please see the illustrative diagram
below:
Physical infrastructure records from PIPeR feed both the Openreach planning process and PIA systems.
PIPeR system
Openreach’s physical infrastructure (duct, pole &
underground chamber) records are held on the PIPeR system.
Openreach FTTP Planners PIA Digital Maps system
FTTP planners access inventory PIA customers access PIPeR inventory
records via the PIPeR interface. records via the PIA Digital Maps system.
31 Also significant over forecasting will result in excess resources being deployed in the wrong locations, which could be equally damaging.
32 See PIA Contract Schedule 2.
33 Physical infrastructure which is still in the planning or build stage is not passed to the PIA Digital Maps system until it is formally handed over to
Openreach and forms part of its physical infrastructure inventory.
Issue 4 – 01/08/2019 11 of 3844. The infrastructure data fed into the PIA Digital Maps system can then be used by the PIA customer to
plan its deployment, automatically populate its Openreach inventory records and create an agreed
billing record.
PIA Digital Maps system
45. The primary reason why a different system to Openreach’s internal legacy system PIPeR was developed
for PIA customers (apart from PIPeR’s unsuitability as a multi-CP system) was that implementation of a
tailored PIA system could be introduced much more quickly and efficiently in 2017, significantly ahead
of the WLA obligations being imposed in 2018. Thereby providing significant improvements to the
product and enabling efficient and significantly increased consumption of PIA by CP customers over a
year before the WLA final statement was published.
46. This enabled major benefits for PIA customers, making it possible to plan and record network
deployments through on-line access to the PIA Digital Maps tool and a web services interface, in a
comparable manner to Openreach and by accessing the same underlying Openreach physical
infrastructure record information as Openreach planners use, but through a much more flexible and
adaptable system. In summary the new PIA system:
enabled PIA customers to download and import network data into their own GIS network planning
tools;
provided estimated capacity information for spine duct calculated from Openreach’s inventory
systems which was presented in a suitable format to enable PIA customers to estimate duct
availability and;
included relevant duct, pole, joint box and manhole information at a sufficient level of granularity
for planning, ordering and billing, with the required physical attribute and network code information
to speed up planning, ordering and billing.
47. As set out above, the separation of the PIA system development from the legacy PIPeR system has
already enabled a significant number of other developments to be progressed with PIA customers and
the OTA through the Passives Industry Working Group (PIWG). These systems developments could only
have been this reactive to PIA customers’ needs because they did not impact Openreach’s legacy PIPeR
system.
48. Over time the functionality of the different systems has also been more closely aligned on some key
items. In particular, the browsing capability of the PIA system was increased from a 1km 2 window to a
5km2 area enabling CPs to view, and whilst on-line, move around the map display to view large areas of
infrastructure to assist CP planning. Additionally, CPs can now download Openreach infrastructure
information via multiple 1km2 sections which can be automated to build up whole city databases (or
larger) in CP’s own geospatial systems. Whilst currently Openreach planners do have the capability to
pan across and view the whole of the UK without limitation via the PIPeR interface, they typically do
not do so, as their work tends to focus on specific deployment areas. Therefore we do not currently
have such functionality in scope for PIA systems development. However, should we identify that it is
causing CPs issues, then it is something that we would consider as part of a future development.
49. At this time, Openreach planning information is not passed from PIPeR to the PIA system. This is
primarily because the PIA obligation does not apply to planned physical infrastructure that has not yet
Issue 4 – 01/08/2019 12 of 38been built by the site developer or been handed over to Openreach. In these circumstances it would
not yet form part of Openreach’s infrastructure (even if it has been constructed).34
50. In relation to new sites, we recognised that delays in updating PIPeR inventory data on completion (or
partial completion) of infrastructure build was causing issues for CP planning. Hence we have
introduced a new process for PIPeR which enables early phases of fibre new site infrastructure,35 when
built and handed over to Openreach, to be flagged as built on our inventory systems, triggering that
phase of information to be automatically updated on the PIA Digital Maps system (i.e. prior to the whole
site being built, signed-off and handed over to Openreach).
The Openreach PIPeR system
51. Openreach’s planners use the PIPeR interface to access physical inventory information in the same way
as PIA customers use the PIA Digital Maps system, and in broad terms the operational activities carried
out by Openreach planners are the same as those carried out by PIA customers (please see further
details in Section 3.3 below).
52. At this time, PIPeR is integral to Openreach’s operations and processes across all networks and
products.36 However, in-line with PIMR regulation and guidance, we are committed to reviewing all
future platform developments as they occur, including potential replacements for PIPeR, and ensuring
we continue to meet our regulatory obligations on a forward looking basis.
53. These future developments will require careful consideration of PIA customers’ and Openreach’s needs,
as even for a relatively recent and new development such as the PIA Digital Maps system the
requirements and priorities of PIA customers at the time were different to those of Openreach.37
3.3 The Order/Notice of Intent (NoI) Process
Overview of the NoI Process
54. Please note that the ‘Order/NoI process’ was previously part of a process that was referred to as the
‘Reservation process’, and this has led to some confusion with stakeholders, as it did not confer any
formal space reservation rights. Rather it denoted potential future occupancy of infrastructure by the
PIA customer which could then be taken into account by other PIA customers when assessing physical
infrastructure availability and also by Openreach’s physical infrastructure planners. Access to
infrastructure capacity operates on a ‘first come, first served’ basis for everyone including Openreach
and there is no formal reservation.
55. Therefore the order process is now referred to as the Order/NoI process as it describes the PIA
customer’s order for, and intention to occupy space in, or on, a particular section of Openreach’s
physical infrastructure, although the space is not formally reserved. Following a NoI/Order, the CP is
then able to confirm and amend their NoI/Order records once they have installed their equipment and
completed their build (i.e. the ‘build complete’ process). Openreach does not use the NoI process and
this is explained further below.
PIA Customer Process
34 The WLA final statement concluded that Openreach does not have an obligation to publish its planning information – ‘WLA Statement Volume 3
– paragraph 6.353’.
35 Further work is continuing to address any new site record backlog and should complete by end of Q2 2019/20. Copper related processes are also
being reviewed and this is expected to complete by end of Q2 2019/20.
36 The potential complexity and cost of unravelling these processes within Openreach was recognised in the WLA Final Statement. Please see
Volume 3 - paragraph 3.39, and PIMR Final Statement paragraph 4.77.
37
PIA customers were looking for a multi-CP system enabling electronic access to, and download of specific physical layer information, plus
automation of the ordering process to link into their own planning, inventory and ordering systems. However, Openreach as a national operator
providing all products and services needed to access integrated nationwide inventory information for all technologies and at all layers of the
network architecture (both physical and active). Also there was no requirement for Openreach to develop or operate an internal physical
infrastructure ordering or billing capability.
Issue 4 – 01/08/2019 13 of 3856. When a CP chooses to use Openreach’s physical infrastructure as part of its network deployment
process (i.e. purchase the PIA product):
• It will combine information about Openreach’s physical infrastructure with information about its
own physical infrastructure, and then add its cabling and equipment design to produce a
deployment plan.
• Only the PIA customer knows its plan, and therefore what equipment it will be deploying and at
what locations in the Openreach physical infrastructure and/or its own infrastructure. Openreach
is unable to gather this information and therefore requires it to be provided by the PIA customer
to Openreach. The information is required so that:
o Openreach can produce a bill for PIA usage.
o There is an accurate record of the locations where Openreach can expect ‘Whereabouts’
notices when the PIA customer is operating in the Openreach network for security, quality
and health and safety reasons.
o Openreach knows where the CP’s equipment will be located in its infrastructure. The records
need to be easily accessible by Openreach so that it can contact the equipment owners at
times of emergency, or for re-planning and other network rearrangement projects.
• The core purpose of the Order/Notice of Intent (NoI) process is to fulfil the needs set out above
(i.e. for the PIA customer to accurately record the inventory of Openreach physical infrastructure
it is using as part of its network deployment plan).
• PIA customers are required to provide this information when they place their Order/NoI, but they
are able to deviate from the original route for a variety of reasons (e.g. poor records, route
congestion, to avoid blockages etc.) with no penalty as these would be legitimate operational
reasons. They are required to inform Openreach of the deviations as part of the process.
• In summary, the PIA Digital Maps System is the CP interface that Openreach specially developed
to allow multiple PIA customers to plan and place NoIs/Orders and record their usage of
Openreach physical infrastructure.
Openreach Process
57. Openreach planners do not use the Order/NoI process as they do not access or use the PIA Digital Maps
System. This is because although Openreach planners do need to carry out the same functions as a PIA
customer, they already use the existing Openreach inventory system (PIPeR) to source and record the
relevant Openreach information. Broadly the relevant design steps are:
Assess available Openreach physical infrastructure - this is taken from PIPeR, the same as the
source data for the PIA Digital Maps System.
Construct a network design (equipment and cabling etc.) – both Openreach and PIA customers will
have their own processes and practices for doing this.
Record the information in an inventory system – Openreach inputs this information into the PIPeR
system where its network design (i.e. equipment & cabling etc.) and usage of its physical
infrastructure is held. In comparison, PIA customers will hold their own detailed network design
information locally in their own systems (i.e. not on the PIA Digital Maps system), but they also
need to record their usage of Openreach’s physical infrastructure on the PIA Digital Maps Tool for
the reasons explained above.
58. Additionally, Openreach imposes obligations on its own contractors in terms of ‘whereabouts’
information, plus tracks the location of its own personnel which is recorded in Openreach’s operational
systems. This information is required for health and safety, security, quality and audit purposes.
Issue 4 – 01/08/2019 14 of 38Summary
59. The PIPeR system was not designed as a multi-CP system and cannot be used by multiple CPs to record
their usage. Therefore the PIA Digital Maps System was specifically developed to provide the interface
for multiple CPs to be able to plan their potential use of Openreach infrastructure, and after completing
their network build, to feed their actual PIA usage data back into Openreach (via the Build Complete
process) for the reasons set out above.
60. Openreach carries out the same network functions as the PIA customer, using the same physical
infrastructure source data (i.e. from PIPeR), but does not record billing or location information on the
PIA Digital Maps System. This is because it is not required for ordering and billing purposes, and would
be a duplication of the activities already carried out and the information already recorded by Openreach
in its PIPeR system.
3.4 The Build Complete Process
PIA Customer Build Process
61. Following on from the Order/NoI process, the build complete process is a key stage in the overall PIA
ordering framework. As explained in Section 3.3 above, a PIA customer can place an initial Order/NoI
with Openreach for PIA before they install any equipment in Openreach’s physical infrastructure, but
once they have completed the installation of their network, they are required to submit a Build
Completion Pack to Openreach. This is the finalised NoI order, inclusive of any changes the PIA customer
may have needed to make to their original NoI information whilst they were building their network.
62. In the context of the PIA product, the function of the build period and build complete process is to
support the formal contractual relationship established between the PIA customer and Openreach, so
that the CP can legally occupy Openreach’s physical infrastructure and consequently pay the
appropriate regulated charges for its usage. Therefore, as Openreach does not contract with itself,
there is no simple internal analogy for the contractual build complete process.
63. Once a CP has notified Openreach that it has an intention to access Openreach physical infrastructure
via the Order/NoI process and they provide their whereabouts, they are free to start placing equipment
in the infrastructure and occupying space. They have no obligation to pay for the occupancy38 at this
stage even though they may have already taken up significant space in the physical infrastructure.
Therefore, there needs to be a reasonable control placed around this process to prevent unpaid and
open-ended occupancy of Openreach’s physical infrastructure by CPs. The build complete process is
the trigger point at which CPs are required to start paying for their occupancy.
64. The overriding principle is that whenever live services are provided by the PIA customer then Openreach
should also be enabled to charge for its infrastructure. This principle is supported by the contractual
build period and the build complete process, as these are the key controls which establish the
contractual relationship for the PIA customer to legally occupy Openreach’s physical infrastructure, pay
the appropriate regulated charges for its infrastructure usage, and consequently sell its services.
65. This is also why Openreach restricts the ability of a PIA customer to indefinitely extend an Order/NoI,
as this would enable CPs to occupy Openreach infrastructure indefinitely without paying for it, and/or
without informing Openreach of which parts of the network they have occupied or not. Therefore, the
contract also maintains Openreach’s right to require CPs to remove their equipment in these
circumstances.
66. Broadly, the CP chooses the size of the NoI, the time and rate at which they build, and the point at
which they offer live services to end-users (i.e. after build complete takes place). The initial build period
38 The original method of charging for ‘reservations’ was intended to overcome this anomaly.
Issue 4 – 01/08/2019 15 of 38for a PIA NoI is currently set at 12 months.39 Due to a current systems constraint the build period cannot
be extended beyond 12 months at this time, but as part of the Day 2 40 programme we have now
developed the capability to extend up to a maximum of 18 months where the CP encounters matters
beyond its reasonable control.41 In such circumstances, the customer is required to inform Openreach
of the delay or the build period will expire at the 12 month limit.42
67. Some recent changes have been made to the PIA product with regard to the build complete and billing
process. We now permit PIA customers to connect up end-users prior to submitting a build completion
pack as long as these connections are reported to Openreach as part of the forecasting requirements
on a monthly basis. We are also assessing a further systems development to support partial build
complete recording (i.e. the ability to complete a sub-part of a larger NoI order). This is likely to be
delivered in the next financial year (subject to funding). In the interim PIA customers can continue to
connect up customers prior to submitting their final build report but must report customer connections
on a monthly basis (in the ‘lead-in’ report).
68. The build complete process is also fundamental to the calculation and linking of network adjustment
funding (whether Openreach provided or self-provided), where Openreach can only fully reconcile
financial balances and liabilities on receipt of the build completion notifications from CPs.
69. There is currently a system limitation of 1500 items within an Order/NoI on the PIA Digital Maps System.
This was not viewed as an operational constraint at the time the PIA system was originally implemented.
However we are currently planning a future development43 which will provide the systems capability to
create a ‘project’ and associate a number of NoIs within it, thereby enabling customers to benefit from
a ‘pooled’ network adjustment fund (in-line with PIA contractual terms and conditions). This will
effectively increase the aggregate limit for a group of NoIs enabling an order to address circa 100k
premises passed. In addition, we are continuing to discuss other longer term requirements with
stakeholders.
70. The planned future developments will add greater flexibility to the product, but a build complete
process of some form will still need to be in place for the reasons set out above. The correct incentives
and controls are necessary so that PIA customers submit accurate build complete notifications, as only
then can Openreach have any proper view of what is actually ‘in’ or ‘on’ the Openreach network and
where it is located, and align PIA customers’ ability to sell end-customer services, and Openreach’s right
to bill its regulated access charges.
71. As and when new systems developments and processes are agreed with industry these will be reflected
in a revised version of the PIA IRO.
3.5 The Network Adjustments Process
Overview of Network Adjustments
72. The PIA product provides for PIA customers to order Network Adjustments from Openreach. These are
a range of network and civil engineering activities which are available where necessary to repair or
relieve congestion in existing Openreach physical infrastructure. For a Network Adjustment to qualify
as a legitimate request it has to be a necessary, feasible and efficient adjustment.44
39 This was changed prior to publication of the 1 April 2019 reference offer following stakeholder feedback. It was previously 6 months.
40 Day 2 refers to a series of future product, systems and process developments we are continuing to work with stakeholders to implement during
2019/20.
41 This functionality is due to be delivered in release R4150 in September 2019.
42
Please note that increase to a 12 month build period and changes to extension functionality occurred shortly before the 1 April 2019 final
reference offer was in force and hence we are still working through some transitional issues with PIA customers until the R4150 systems release.
43 We are currently targeting deliver in R4150 but this is still subject to final confirmation.
44 Please see paragraphs 2.31 to 2.93 ‘WLA Market Review: Statement – Volume 3 – PIA remedy’. Ofcom also set a range of other criteria which a
network adjustment must fulfil. Also see paragraphs 5.87 to 5.123 of the PIMR final statement.
Issue 4 – 01/08/2019 16 of 3873. This includes typical activities such as repairing a length of damaged duct to make an existing duct route
suitable for new network installation, or replacing a pole which has been classified as unusable 45
because it is considered unsafe to add any additional dropwires or equipment to it.46
74. For qualifying underground adjustments Openreach is responsible for funding a proportion of the cost
up to the financial limit,47 and for qualifying overhead adjustments no financial limit is currently applied.
Many Network Adjustments can be carried out by the CP itself, or by Openreach.48
75. This means there are three key aspects to the network adjustment process:
a) If Openreach is paying for the Network Adjustment, then there is a need for Openreach to
validate that it is a legitimate order.49
b) The validation process needs to be efficient and timely, but also provide sufficient information
to enable PIA customers to make informed deployment decisions.
c) In the cases where Openreach undertakes the work, the Network Adjustments should be carried
out efficiently and completed in a reasonable timeframe.
76. Our Network Adjustment processes for the PIA product are designed to meet all these objectives.
Further, we are also committed to producing and sharing KPIs and indicative operational metrics with
PIA customers and wider stakeholders to provide evidence that the validation process is operating
efficiently, and that there is no undue discrimination taking place in the validation and delivery of
Network Adjustments.50
77. It is challenging to map Openreach’s internal activities exactly onto the external Network Adjustment
ordering and validation process,51 as Openreach has a variety of operating models and is also in the
process of standardising its approach to fibre programmes and reorganising how work is shared
between its Chief Engineers (CE), Fibre Network Delivery (FND) and Service Delivery (SD) teams.
However, for its FFC programmes Openreach primarily controls its civils costs in two main ways. Firstly,
by carrying out significant survey activity and pre-validation of any civils work required (including
Network Adjustments) for FFC deployments before commissioning any build work. And following this
phase, maintaining very tight controls on any additional work identified by contractors or direct labour
in the build phase through additional control processes52 to continue to drive out unnecessary civils
costs.
78. Where possible below, we have identified Openreach activities which are similar to the PIA product,
but in summary we view an appropriate PIA validation process as a proportionate and pragmatic way
to ensure that PIA customer network adjustment costs are also controlled in a similar way to
Openreach’s civils costs. We set out the key elements and comparisons of the PIA process and
Openreach’s internal processes below.
The PIA Process
79. The process set out in the current reference offer (1 August 2019) includes a 5 day SLA for completing
the Network Adjustments validation process prior to work being carried out. This process is required to
provide the correct corporate governance and contractual controls around complex and expensive civil
engineering processes. The 5 day period in the reference offer does not reflect the ‘time to verify’ for
45 Openreach has a major pole testing and safety programme which identifies defective poles and assigns a ‘D pole’ classification. In broad terms
this means that (i) some are usable but can’t be climbed, (ii) some are usable but need to be replaced over the next two years, and (iii) some are
not usable and need immediate replacement.
46 Even with the use of specialised overhead equipment such as hoists or mobile platforms.
47 This is £4750 per kilometre for UG adjustments.
48
PIA customers can also order Ancillary Services from Openreach for which they pay a cost oriented tariff.
49 Sufficient to satisfy UK corporate governance rules such as Sarbanes Oxley.
50 Please see Annexes A, B and C for further information on these points.
51 This also makes it difficult to map internal and external KPIs, but we are working with stakeholders to find the best comparators (see Annex C).
52 Primarily the Departure from Estimate (DFE) process.
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