Select Committee on Trade and Industry Appendices to the Minutes of Evidence


Supplementary memorandum submitted by Colt Telecommunications


  This memorandum gives Colt's views on the BT 10 November local loop unbundling announcement.


  On Friday 10 November BT announced its local loop unbundling implementation plans at a meeting attended by industry and Oftel.

  Colt is disappointed at the lack of any tangible progress and considers the headline announcement to be highly misleading.

Sites delivered by 1 July 2001

  BT has over 6,000 sites (known as MDF sites) at which other operators could potentially co-locate high-speed DSL equipment.

  On Friday BT announced that, at best, only 190 of these sites would be available for other operators to physically co-locate at by 1 July 2000. BT's headline figure of 600 sites by July 2001 is primarily made up of distant co-location sites (see below).

  Even by 1 January 2002 (a full 12 months after the European Union deadline for full unbundling of 1 January 2001), on BT's timetable BT will have delivered less than 800 physical co-location sites to other operators.

  This timetable will leave the UK trailing behind all its European Union neighbours, with less sites delivered than in other countries, and less citizens and businesses able to obtain broadband internet access.

Distant Co-location Sites

  Much of BT's "progress" is based on the use of distant co-location sites.

  BT has never identified that there was any constraint on BT providing distant co-location, as BT only has to provide a tie cable out of its premises to another operator. As such, to start including this in the figures is highly misleading.

  Distant co-location is a poor substitute for physical co-location. It:

    —  reduces the customer footprint served;

    —  increases costs; and

    —  has uncertain availability.

  The diagram below demonstrates one of the major drawbacks.

  There is a technical distance limit on how far a customer can be away from an operator's DSL equipment. This means that the area served decreases with the square of the distance between the distant co-location site and the BT site.

  In each case the centre of the larger grey circle is the site of the BT exchange, and the operator equipment location is indicated by the smaller green circle.

  The top diagram, where physical co-location is available shows that all customers within the DSL distance limit (for example 3.5 kilometres for ADSL) can be served by the competing operator.

  The bottom diagram shows that for an operator half of this distance away (eg 1.75 kilometres) from the BT exchange can only serve a quarter of the number of customers and that a large number of potential subscribers cannot be served from the distant co-location site.

  In addition, distant co-location is dependent on other operators being able to obtain and fit out suitable sites close to BT exchanges, which in some cases is impossible and in all cases difficult.

Service Level Agreement

  For the first time, BT has accepted that it should offer a service level agreement, which is a positive step. However the lead times (in working days, so divide by five to get weeks) are still long, and are longer than those suggested in the Oftel guidelines, with the physical room build taking four months from receipt of the final order, rather than the initial order.

  The end to end process is still seven months (three for initial and final surveys and four months for room build), which is still longer than in other countries.

Outgoing Delivery

  BT has offered to deliver 100 co-location sites per month after July next year, which is a positive step forward.

Oftel Involvement

  Oftel is now actively involved in the process, and the Deputy Director General (Anne Lambert) is personally chairing the group driving these issues forward. Despite the lack of substantive progress on room delivery, a change in BT's attitude is apparent and we welcome Oftel increasing focus. We note that in the Oftel press release they say:

    "However, Oftel has made it clear to BT that it expects further improvements to be made and we will ensure that no resources are spared in preparing its exchanges as quickly as possible."

  We feel it essential that they continue their involvement and in particular move quickly to resolve the complaints on the contract and discrimination by BT.

13 November 2000

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