IrelandOffline Briefing Document on the current LLU Process

damien

This just got sent out to our media list. Well done to Gareth (Viking) who put this together. Thanks too to the other parties who helped check the facts and figures.

You can also read this on our Wiki: http://www.irelandoffline.org/wiki/index.php?title=LLU

IrelandOffline's Guide to the Current LLU Process

Present Situation with LLU

As of April '05, there have only been approximately 1700 telephone lines unbundled in Ireland mainly by BTIreland (subsidised through government funding) and a handful by Smart Telecom.

This was due to the high costs (both one-off and ongoing costs) charged by eircom to other operators (originally agreed between eircom and ComReg). These charges were based on eircom’s cost orientation obligations associated with the unbundling process. Reduced capital expenditure by telecom companies also played a part in preventing LLU from succeeding at that time.

Last year ComReg directed eircom to reduce some of the one-off costs associated with LLU (site offer, connection, etc) by up to 50%, LLU line rental was also reduced to €14.67 down from €16.81 (eircom were seeking €27). This, coupled with the building of Metropolitan Area Networks (MANs) around the country, brought a renewed interest from other operators in a now more viable LLU process. IrelandOffline understands that other LLU charges are being reviewed by ComReg and reductions will be published shortly.

As interest grew, other operators discovered the following flaws with the eircom LLU ordering process which initially met the requirements of OLO's but now do not and therefore need to be addressed before it can become fully scalable:

1) Automated LLU Ordering Process

At present, all processes associated with LLU (initial ordering, handling of faults, billing) are handled manually by eircom. Unbelievably, orders are passed between the other operator and eircom using email communications and a manual handling process, this means only a small number can be processed each month due to the manual work involved. Operators have forecasted significant demand and the manual nature of the process is not adequate and is not scalable for the predicted demand.

2) Movement of Bitstream Customer Base to LLU

Bitstream customers are those who are currently receiving ADSL from IOL, UTV Internet, Netsource etc. These companies are simply reselling eircom's ADSL service and are unable to offer much competition through product differentiation. At present, a company cannot move one of its bitstream customers to LLU because if it places an LLU order on that bitstream customers line, the order is rejected. Currently, the only way a bitstream customer can be moved to LLU is by cancelling the bitstream service and ordering LLU on the line, however this results in several weeks of service outage for the customer which is obviously unacceptable.

3) Loss of Voice Service due to LLU and GNP being separate processes

Firstly, Geographic Number Portability (GNP) is the process for “porting” a telephone number between different operators. For example, when you change your calls from eircom to Smart your telephone number is seamlessly ported from eircom's network to Smart's network. It is identical to the way you can move from Vodafone to O2 but still keep your 087 number.

At the moment, when an operator places an LLU order on a telephone line they must wait for the line to be fully unbundled and connected to their network before they can apply for the telephone number to be “ported”. However, this means that a customer can be without a voice service if they wish to retain their existing number because the telephone line is now essentially “off-network” as there is no telephone number associated with it. The timeframe involved with this can be several weeks. Obviously this is a serious issue for other operators as they cannot have their customers without a voice service while LLU occurs. It is only when the phone number is fully ported that the customer’s voice service returns. A parallel or integrated ordering process for LLU and GNP needs to be established. (A workaround has emerged in which the new operator can instead assign a new number which does not result in loss of service but this is obviously quite inconvenient for many customers.)

IrelandOffline understands that a complete outage free LLU order including voice services (as well as broadband) may not actually be possible without changing the number. Eircom's internal systems use the actual telephone number as the “unique identifier” in their database. Each record in the database stores all the associated services (voicemail, diverts, etc) in relation to that particular telephone number. If that telephone number is unbundled and a GNP order is then placed by the other operator to move the number onto their network, eircom's internal systems identify that number as having moved off eircom's network and therefore all services associated with it are cancelled including LLU. This results in the customers telephone line being completely cut off when the number is ported!

The court case will be begin on Thursday April 28th and while IrelandOffline wishes for a speedy resolution to some obvious issues regarding eircom's LLU processes, we recognise that even if the court upholds ComReg's position, eircom will still be required to build the necessary internal systems and implement the required changes. IrelandOffline believes that Ireland is still at least 12 months away from a scenario where eircom's LLU ordering systems function as required and consumers can be offered better value and pricing through real competition.


Original ComReg LLU Direction to eircom: http://www.comreg.ie/_fileupload/publications/ComReg0504.pdf

dahamsta

Fantastic work Gareth, and others, well done. Let's hope the "technology journalists" that receive it actually have the sense to read it.

adam

viking

Currently on holidays, so don't have much time to respond.

Hoping to see some media outlets pick this up as the issues contained above are major stumbling blocks for LLU implementation.

Gareth