By Simon Woodhead & Peter Farmer
We discussed recently what we’d like to see from the Narrowband Review. Less than 24 hours later Ofcom published its Wholesale Voice Markets Review 2021-2026. This is important and going to govern our industry for the next 5 years, and arguably reshape it forever.
Rather than brain-dump all our reactions (there are many) here, or indeed simply share our response, which by nature will be somewhat legalistic, we wanted instead to serialise a few points in plain English.
Our response will obviously feature these, so if they resonate with you and you think they matter, we would encourage you to respond to the consultation. You are very welcome to cite Simwood, this blog, or our formal response if it helps.
If you missed them, see Part 1 – Huawei bad for Internet; Huawei good for Voice over Internet, Part 2 – CP Status – we need a new one! , Part 4 – BT’s unchecked monopoly in porting and Part 5 – A prime opportunity to improve porting?
In our response to Ofcom last year, we counselled that they needed to be careful with terminology as ‘IPX’ means different things to different people. In those differences lies massive room for confusion and gaming. Heck, we’re pretty sure that Ofcom have yet to fully get their heads around this subject.
As well as defining who is who in the market, we need to recognise the various personalities of IPX rather than treating it as one fluffy cloud and allowing BT to define it as suits their argument du jour. When you do so, you find a lot of contradiction, double-think and gaming already taking place. In a review which sets the tone for the lock, stock and barrel migration to IP, a regulator not giving this sufficient attention is gifting BT huge opportunities at the expense of a free market and consumer protection.
So in our view, IPX colloquially is the product offering that sits atop SDIN, BT’s IP voice network. BT themselves view IPX in two flavours which we interpret as:
- Type A. This is a managed service for resellers providing services such as termination, numbering and number hosting.
- Type B. IP access to SDIN.
These are worlds apart from each other and a review which talks about IPX in general terms is ignoring the specific characteristics of each.
We would argue that Type A is hosting number ranges for range holders and this is confirmed by how they describe them on the fabled Yahoo Group and the fact that they’re not paying those range-holders the FTR on calls to them. They’re also giving those range-holders tools to manage porting implying that the numbers reside on BT switches which is a critical fact in regulatory terms. It has its own porting team, distinct from OpenReach’s porting team, which is providing a porting service, much like Simwood. In our experience many Type A operators consider BT is providing them with a hosting service and thus they do not have many of the obligations they would otherwise.
If indeed they are deemed hosted then this should mean certain things for the industry:
- Other CPs should be able to access FTR just as if they were BT numbers
- Other CPs should be able to port numbers under agreements with BT
Type B is what we’ve referred to as the ‘Secret Club’, i.e. a proper interconnect over IP and absent any of the managed features one would expect with Type A. So Type B might be a transport for calls and porting, a lot like the good ol’ fashioned arrangements on TDM under the SIA, but has no access to IPX’s porting service or other managed features. Those ranges are nowhere near BT switches so they wouldn’t announce to the fabled Yahoo Group and nor would they be able to apply porting prefixes on their switches as the numbers do not live there. Calls traversing the interconnect are either termination to/from the BT network or Transit.
Type B, therefore, is very clear.
Where it falls down is where someone refers simply to IPX. This allows BT the rock under which it can hide and profess that IPX is a transit service when defending its commercial practices with ranges we would argue are hosted on it. It may treat it as transit and charge transit to reach it but the very fact those numbers live on its switches, it does not offer FTR to Type A customers, it provides facility for them to export those numbers from BT, and it announces them on the fabled Yahoo Group, very clearly says that these numbers are hosted on the BT network. We also have other important, but increasingly esoteric, evidence we will put before Ofcom in our response that makes the same point.
Whilst this review goes some way to addressing the problems with IPX, allowing BT to pick and choose which mask to wear rather than formally recognising Type A is hosted with all the logical conclusions that flow from that is distortive and in the case of porting is ultimately just allowing consumers and businesses alike to be harmed.
