Supplementary memorandum submitted by
This memorandum gives Colt's views on the BT
10 November local loop unbundling announcement.
2. BT 10 NOVEMBER
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
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
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
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;
has uncertain availability.
The diagram below demonstrates one of the major
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
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
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.
BT has offered to deliver 100 co-location sites
per month after July next year, which is a positive step forward.
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
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