BT Ignite response to OPTA’s ‘Consultation Document
Interconnecting Leased Lines’
The following submission is made on behalf of the entity BT Ignite Nederland B.V. hereinafter referred to as 'BT Ignite'.
GENERAL
BT Ignite welcomes the opportunity afforded by OPTA to comment upon its Consultation Document Interconnecting Leased Lines (the 'Consultation Document').
The response is set out in a manner that follows the Question structure of the Consultation document. BT Ignite has responded to each of the questions as relevant. Comments and issues raised against specific paragraphs in the Consultation Document have been grouped with the Question relevant to that section. Issues that BT Ignite wishes to raise that are not covered by a specific question have been grouped under our answer to Question 13.
Finally BT Ignite has included a brief Annex (annex 2) to cover additional points following the presentation at the verbal hearing at OPTA's premises on 25/02/2002.
1. The Board is keen to ascertain whether interested parties agree with the definition of the problem outlined in this section. BT Ignite believes that regulation is necessary to address
established market failure. Opta should intervene to ensure that dominant operators or those with Significant Market Power are not able to restrict competition unreasonably.
In relation to leased lines, we believe that there needs to be continuing rigour in the determination of properly defined economic markets for leased lines. This will no doubt be a key part of the implementation of the European Union new regulatory framework for communications ( the ’99 package) and BT Ignite will respond to any consultations on market definition.
At this stage, we would submit that there are retail markets for leased lines and in addition there are wholesale markets for leased lines. The main focus of this Consultation is in relation to the wholesale market for access as defined by Opta
Opta’s definition of the problem
BT Ignite agrees with the definition of the problem as formulated by OPTA. In particular, we support OPTA's conclusions in paragraphs 22 - 25 on the lack of opportunity for new entrants to compete
effectively with KPN using the standard leased line products currently available due to price squeeze effects.
In particular, we would support the OPTA statement in paragraph 24 that " Since KPN is the dominant player…. and, given the current
pricing structure for leased lines, providers using that access network cannot compete with KPN, and the development of competition on the market for leased lines and downstream services is
prevented."
To ensure effective competition in the supply of downstream services and to avoid the price squeeze issues, change is necessary in
respect of the products available to wholesale customers and the price structure.
We also ask Opta to ensure that KPN (as a dominant operator in the wholesale market for access, as defined by Opta) does not
discriminate in relation to the services which it offers to its own retail arm and those which it offers to its wholesale customers.
We have concerns that KPN may be engaging in discriminatory practices in relation to access services.
In relation to pricing, it is of great importance to BT Ignite that in markets where KPN has SMP, its tariffs are transparent and
published and that KPN sells in accordance with its published tariffs.
In relation to the types of leased lines services supplied by KPN to its own retail operations and to new entrants, we are concerned that when KPN, as an SMP operator, responds to bids, it may be utilising service components not yet available for third parties to purchase either on retail or wholesale terms.
BT Ignite would welcome an opportunity to discuss possible discriminatory practices of KPN with Opta.
Opta’s definition of access
BT Ignite would like to raise a point of clarification on the text of the consultation document. In Paragraphs 15/20/21/22 it is said that the market requires half circuits from the KPN network to the end-user. BT Ignite agrees with this statement but would also offer further clarification on what is meant by the "KPN network". Because the "nummercentrales" are also considered to be part of the access network BT Ignite believes that the definition of the "KPN network" should include the provision of half circuits going from the
"nummercentrales"/LAPs to the end-user.
outlined by OPTA under point 28. The current Leased Line retail offer by KPN does not fulfil the needs of BT Ignite. BT Ignite wishes to be able to provide access to our customers and therefore only needs a half circuit from the BT Ignite point of connection with KPN’s core network to the end user. This is currently not a product in the portfolio of KPN, therefore BT Ignite is obliged to procure an end-to-end circuit. The failure of KPN to provide
products to meet this demand is an example of insufficient unbundling of product components.
3. The Board is keen to ascertain whether interested parties agree that ILLs can also be used to connect base stations.
As BT Ignite has no base stations we do not feel that this question is relevant to our response.
4. The Board is keen to ascertain whether interested parties agree with the assessment of the legal framework outlined in this section and if not, why not.
BT Ignite agrees with the outline of OPTA with respect to the definition of interconnection as laid down in the interconnection Directive article 2 paragraph 1 a. It is true that leased half-lines fall within the definition of interconnection.
The obligation to interconnect does indeed apply to providers of leased lines (See article 6.1 paragraph 5 TW.
The obligations as listed in Chapter 3.1 do indeed have to be met by providers of leased lines with an SMP.
5. The Board is keen to ascertain the views of interested parties concerning restrictions on use, and the reasons for these views. BT Ignite agrees with OPTA that there is no justification for the restrictions and that the restrictions in the current ILL offer (v0.4) paragraph 1.2.2 should be removed.
The terms and conditions for procurement of half circuits (ILLs) should be no more restrictive than the equivalent terms for the KPN retail leased line offer as half circuits are a substitution for KPN’s retail leased lines. It is our understanding that the terms and conditions for the KPN retail leased lines have no restrictions on use therefore the terms and conditions for half circuits (ILLs) should have no restrictions on use.
6. The Board is keen to ascertain the views of interested parties concerning the capacities and network levels where ILL services must be available. Please make a distinction between your views on the presence or absence of alternatives, i.e. the level of
terms of requirements, please specify exactly what your company's plans are for connection at specific network levels if an ILL service is offered. To what extent do you expect your company to purchase ILL services? Specify what tariff differences between NAP, RAP and LAP level would cause your company to connect at specific levels.
BT Ignite wants to interconnect to KPNs access infrastructure on both LAP and RAP level for all sub 2Mbit/s, structured and
unstructured 2Mbit/s and all higher bandwidth.
Whilst in theory there are technical alternatives available to interconnect at this level to provide broadband access links, in reality these alternatives do not make economic sense. The extent of the KPN infrastructure and the investment made in this
infrastructure during the period of monopoly provision is such that in many areas where customer access is required it is uneconomic to provide access solutions via existing technologies such as self provide fibre, DSL or Wireless Local Loop (WLL). Even in situations where self provide by a new entrant to a particular customer site is economic, the package of solutions to that customer will often
require access to other sites in areas where self-provision is not economic. The provision of ILLs is therefore essential to new
entrants ability to construct a "solution" for a customer even where some of that customer's access needs can be met by self-provision. The structure of the Local Loop unbundling offer from KPN
effectively promotes the provision of infrastructure by the new entrant to the LAP level of the KPN network. BT Ignite is therefore concerned that the Consultation Document appears to suggest that operators will not be able to utilise this investment for the provision of sub 2 Mbit and Structured 2Mbit circuits. This is an area of potentially major concern for BT Ignite. We have expanded further on this point under our answer to Question 13 of this consultation document.
With regard to the question on tariff differences between ILLs at LAP, RAP and NAP level, all of these access points for ILLs are considered to be interconnect products supplied by an SMP operator and thus tariffs should be cost orientated for all three access points. BT Ignite would therefore expect these tariffs to reflect the underlying cost differences between these different types of access.
network levels we would not expect to see substantial differences in price between the various levels. Furthermore we would expect price differences between different data rates to reflect only the cost differentials between the "electronics" on these circuits (primarily component 1).
7. The Board is keen to ascertain the views of parties regarding interconnection locations.
BT Ignite agrees with the view of OPTA as stated in point 62, 63, 64, 65 and 66.
BT Ignite considers that interconnection to ILLS is effectively equivalent to the "normal" voice transmission type interconnect already provided between KPN and its wholesale customers. Therefore we would expect the same range of interconnect locations and options to be made available. BT Ignite would also expect that the ability to collocate equipment for this service including internal cables, for this service under transparent, cost-orientated terms in the most efficient manner will be provided as part of the offer.
8. The Board is keen to ascertain the views of parties regarding the interface specifications.
BT Ignite believes that at higher speeds, the determination of the interface should be lead by the required Virtual Channel (VC) capacity not the total physical required bandwidth.
In total BT Ignite requires the following interfaces and speeds (the nx64kb/s and T3 interfaces are only needed at the subscriber unit):
0
BT Ignite would also highlight its agreement with OPTA’s statement in paragraph 69. BT Ignite would expect to be able to interconnect in the most efficient way. However, since BT Ignite do not have access to the cost information of these different variants, we
believe it is too early in the process to rule out this as an option and so the ability to hand over at a 2mb level should be maintained (especially when the POC is on a requester location).
9. The Board is keen to ascertain the views of parties regarding quality guarantees. The Board would like to receive specific, detailed proposals relating to quality guarantees.
BT Ignite believes that KPN should be required to enter into a Service Level Agreement in respect of ILLs which should contain guarantees as to quality and should provide for appropriate payments/refunds in the event of failure to meet the quality guarantees. We have discussed this further below.
When constructing the appropriate SLAs and payments BT Ignite believes that it is essential that KPN should not discriminate between the provision of leased lines components to OLOs and the provision of those components to its own retail downstream
operations. To ensure that there is a level playing field and to eliminate any suggestions of discrimination, BT Ignite suggests that KPN should be obliged to report information on the comparative
quality of its service as delivered to its own downstream operations and separately to interconnect operators.
This information needs to be suitably audited, and provided to OPTA for publication. Such performance figures could be in the form of a statistically significant sample in order to minimise any additional measurement. As an example of the type of comparative parameters that should be produced BT Ignite would draw OPTAs attention to the situation on leased line reporting in Ireland and the UK. An UK example is included as Annex 3. The detail of these measures and corrective actions is a matter for resolution between KPN and the Dutch industry with the strong involvement of OPTA and so we have not provided details in this answer.
10. The Board is keen to ascertain the views of parties regarding migration costs.
There are a number of significant issues relating to migration costs, which can only be resolved with a better knowledge of the cost base of the circuits. Unfortunately the current state of accounting separation in the Netherlands and the lack of
transparency in respect of KPN’s costs makes it difficult for us to respond fully to this question.
However we have submitted a high level view below.
As OPTA has correctly pointed out in their consultation document this issue can be broken down into two distinct elements. Migration costs associated with physically converting an existing Retail
leased line into an ILL and secondly "compensation" to KPN for early "termination" of the retail contract.
BT Ignite believes that this issue can also be illustrated in the following
manner:-Time
Cost recovered
t
Cost based tariff
Retail based tariff
On the first point of costs associated with converting the circuits from one product type to the other Ignite believes the key point is made in paragraph 79 of the consultation document namely: " to what
extent it is reasonable for providers to be charged again for
connection costs if they are already connected to the KPN network."
I.e. the connection already exists and no new connection is required merely a change of the product records. This is merely an
administrative task for an efficient operator and no new connection charge is relevant or justified.
Ignite therefore see no reason for a Migration charge per se when converting an existing retail leased line to a ILL. If the circuit in question is also beyond time "t" in the diagram above we would also contest that there is no case for any charge.
The second point of "compensation" for early termination is more complex and any answer will depend on where the circuit is in the time/cost diagram above and the cost recovery structure inherent in both the current retail price for leased lines and the proposed cost recovery structure of the future interconnect prices for ILLs.
Details of the cost base for leased line elements in KPNs network are however not available to us due to the lack of separated accounting information from KPN for these network elements. As a result we must make a response based on assumptions and scenarios. The "connection fee" for a retail leased line is designed to recover the up front costs of installation etc. but it is recognised that this may not be a full cost recovery and an element of the ongoing charge may be used over the contract period to offset the up front costs (Retail line in above diagram). Therefore there may be a case for charging an element of a connection fee as part of the migration costs to an ILL. However this would only be valid if the up front costs had not already been recovered in the retail price and were also not going to be recovered in the interconnect price for the replacement ILL. Furthermore if it was sensible to spread the connection costs of a retail circuit over the lifetime of the
contract then it is presumably also sensible to do the same for the ILL circuit and "loading" all this cost up front on the ILL circuit is unreasonable. Therefore it appears sensible to Ignite to assume an equivalent cost recovery methodology for set up costs on both retail and ILL circuits therefore any "connection fee" will be recovered during the lifetime of either the retail contract or the ILL contract with no need to front load the cost recovery in the form of any connection fee.
Issues such as what to do in the case of over recovery of cost for long duration retail circuits or safeguards in the event of re-use of equipment where costs have already been recovered etc will need to be addressed first.
11. The Board is keen to ascertain the views of parties regarding
forecasting.
BT Ignite recognises the importance of a forecasting mechanism to the efficient operation of a networks business. However we have concerns about the forecasting proposals in the ILL – RO and therefore agree with the OPTA statement in Paragraph 83 of the consultation that “ the forecast included in the ILL-RO should be removed in its entirety." However our concern is with the specifics of the ILL-RO forecasting proposal rather than with the concept of forecasting per se.
BT Ignite accepts that a forecasting system is a means of ensuring efficent allocation of resource and thus a well designed
forecasting system has the potential to lower the network operation costs of KPN to the benefit of all concerned. However forecasting systems can also be used by a reluctant supplier as a means of delay and obfuscation if not designed effectively. BT Ignite would
therefore propose that a forecasting system is developed for ILLs between KPN and its customers and that such a system should be based on the following principles.
• A forward looking, but non-binding view of general volumes etc should be provided for a period X.
• A more detailed forecast of specifc service volumes, again non binding, should be provided for period Y (Where Y is less than X) • A binding committed forecast volume should be provided for Period
Z (Where Z is less than Y)
• Under ordering of volumes by more than N % during period Z will result in bills being raised against the original forecast minus N% i.e. in effect paying for a percentage of forecast volumes even if not ordered. Such payments can be offset against future orders.
• Over ordering by M % of the volumes during period Z will be possible but the normal delivery targets cannot be guaranteed. Over ordering of the forecast volumes but by less than M% would not affect the service guarantees.
The actual periods X, Y, And Z and the percentages M & N will vary from product to product and Ignite would also expect these to vary from one member state to another for the same products. As such we would expect the variables to be discussed and agreed by the
industry groups as part of the service development process for the ILL offering.
Forecasts should be provided to the Carrier services – or wholesale division – of KPN and should be treated as confidential. They should not be disclosed by KPN’s wholesale division to KPN’s retail
division. BT Ignite would welcome the opportunity to discuss with OPTA in a meeting between only BT Ignite and OPTA the details of a forecasting procedure on ILLs.
12. The Board is keen to ascertain the views of parties regarding the requirement in the market for this service and the content of the offer.
KPN International ILL:
BT Ignite does not see a particular need to redefine the definition of an ILL (= half circuit from POC to end customer) to cater for international circuits. If BT Ignite has leased multiple circuits from KPN at one of the 7 KPN Border stations then it should be possible to treat the international circuits as ILL's and aggregate the circuits at the border station into an E1/E3/STM-1 etc. In this case the border station will act as a RAP for international
connections. According to the definition as stated in paragraph 85 where the international circuits need to be transported from the border station to a RAP or requester's POP this should be done against core bandwidth cost tariffs because, unlike the situation with other ILLs, there are no local loops involved here.
13. The Board is keen to ascertain the views of parties regarding any aspects not dealt with in the preceding paragraphs. The Board requests that you distinguish between content-related and textual points and, as far as possible, refer to the paragraph numbering of the KPN ILL-RO.
BT Ignite has included below a number of additional points we wish to raise that are not addressed by specific questions in the
consultation document. As requested we have highlighted the relevant paragraph numbering to each point.
Paragraph 54 and 56
In paragraph 54 a direct relationship is made between
already possible to get analogue unbundled half circuits. BT Ignite presumes that OPTA are referring here to the LLU case: KPN provides access to the copper pairs going to a certain customer location. On a LAP level the copper pair is handed over to the LLU operator and this operator puts its own modem on the circuits. Whilst BT Ignite agrees that the copper pairs are handed over we do not agree that such copper ‘hand over’ constitutes the provision of an analogue leased line as operators are not allowed, under the current
agreement, to put modems on this copper to build circuits with e.g. ‘Digistream’ (Leased Line) quality.
In paragraph 56 it is stated that ILLs on a LAP level will be more expensive then ILLs on a RAP level due to the lack of cross connects at LAP level. BT Ignite does not fully understand this argument. Whilst we can see that interconnect at LAP level may take more handling (manpower and processes) to build an ILL than interconnect on a RAP level, where much of the changes can probably be achieved via software, we have no concrete information to judge the cost differences. However we do know that technically there are no issues to provide interconnection on a LAP level, because this is already done for LLU.
As a result BT Ignite would wish to see the cost orientated price for each of these options i.e. LAP and RAP interconnect so that a valid commercial comparison can be made. To remove an option at this stage is we believe premature.
BT Ignite would also wish to point out that in cases where the LAP and RAP are co-located in the same building the different products effectively become one and the same and the Cross connect equipment is effectively located in the LAP. Therefore provision of LAP type interconnect using cross connects in these cases appears essential to us.
BT Ignite would also expect that interconnection at these various locations would be achieved using aggregated circuits and not by single circuits as appears to be the proposal from KPN. Failure to offer such aggregated circuits would be an additional inefficiency and potential area for discrimination between the interconnect products and KPN upstream products.
Paragraph 113
BT Ignite does not have access to the cost base information from which these prices are built up and as such we are unable to comment on their validity. We would expect to see a break down of the
underlying cost components as discussed in our answer to question 6, before we would be in a position to comment in detail on the
proposed KPN prices. However we will make the following observations at this stage:
the circuit speed. The only cost drivers are the copper pair and the modems used to build up the circuit and only the modems are likely to vary by circuit speed.
• The current stated LAP price for a 64k circuit is much higher then the current standard retail pricing. Currently a 64kb/s local Digistream delivered on CTS-2 cost only (approx.) 82 Euro (including a part of the cost of the CTS-2 rack).
• The 2mb price for RAP level appears to be a retail price not a cost orientated price. BT Ignite would expect any charges for this service to be cost orientated as required by Dutch and EU regulatory frameworks. Therefore it is BT Ignite's opinion that the cost for a RAP level 2mb can only be higher then a LAP level 2mb by the cost difference associated with its provision.
• The price structure according to the VC structure is not clear and not in line with what BT Ignite believes to be the real cost. Costs are made to build the physical connection.
• BT Ignite believes that it will often be unnecessary to connect a customer location with multiple VC's, so the suggested price structure is not realistic. BT Ignite wants to connect customer locations based on physical connections as outlined in the interface table. It is unclear if there will be any additional cost on top of the VC cost for the physical connection.
• The table does not show any prices for bandwidth from LAP to POC/RAP to POC if these are not the same physical location.
14. The Board is keen to ascertain the views of parties regarding the issues dealt with in this paragraph. If parties believe that a different squeeze test is necessary, they are requested to indicate as specifically as possible how a test of this type would be carried out.
Ignite believes that the discussion in this section provides a comprehensive review of the situations that give rise to Squeeze effects. However we would add further detail to the Discrimination section, namely that anti-competitive effects arise where KPN, in markets where it is dominant or has SMP, offers services or
components to its retail arm which are not available to other customers.
consolidate access circuits or transmission technologies together at certain nodes in ways that are more efficient but not available to competitors it can produce cost savings in its bid structure that are not available to others.
To address such a situation and prevent unfair competitive advantage being gained it is essential that where KPN has SMP, KPN retail business always utilises standard services provided under standard terms when responding to customer needs. Utilising non standard or tailor made services or terms not available to competitors or failing to demonstrate the use of standard services and terms in areas where KPN has SMP is, in the opinion of BT Ignite, a case of Discrimination.
Squeeze test
BT Ignite supports OPTA's analysis on the cost elements underlying the various ILL services and their relevance to a Squeeze test. Furthermore we agree that once all of the underlying cost
information is available for these various components in a transparent and audited form then these cost components give an effective mechanism for identifying price squeeze effects. However we would point out that such cost data does not exist currently for the KPN network and we are unclear on the time scales for the
provision of such data in a sufficiently robust form. We would therefore propose an additional price squeeze test that could be used in the interim. This is further explained below.
Non-discriminatory tariffs
Incumbent
local TX
node
Incumbent
local TX
node
Terminating
segment of ILL
Terminating
segment of ILL
Core Xmission
path
Tariffs
After best discounts
Costs
Network costs, based
on ILL prices
+ Retail costs, inc CoC
If Tariff after best discount < twice *ILL price
⇒
likely to indicate price squeeze
The diagram shows the situation of a typical Retail leased line. We can assume that the retail price( after best discount) must be at least as high as the sum of the network costs, the retail costs and the cost of capital.
This test is much less dependent on the availability of cost data from KPN. Rather it depends on the availability of the retail price list and discount structure. The underlying cost base is assumed to be below the retail price and is therefore not formally required for the test to work. Since ILLs are in effect single ended leased
circuits whereas Retail leased lines are two ended circuits a simple comparison of the retail price minus the best available discount to all customers with twice the price of an ILL in the same location will give a quick and simple test of potential price squeeze.
A third issue is an issue of the ”geographical squeeze”. KPN has no SMP for the above 2Mbit/s Retail Leased Lines. However BT Ignite would contest that this is an issue of market definition for wholesale products as discussed in or answer to Question 1. As an example KPN has connected all the “wijkcentrales” to fibre. As a result if KPN has to dig to a customer this dig will utilise existing infrastructure (Duct etc) provided as part of its SMP business in voice and therefore the dig distance will not be as far as the OLO’s would have to dig. In this case KPN will always be cheaper and always will deliver faster then OLO’s. As KPN does have SMP on interconnection this geographical advantage should be
addressed.
15. The Board is keen to ascertain the views of parties regarding geographical tariff differentiation.
The consultation document states that it is "It is conceivable that
the costs for leased lines may be dependent ……..on the region where the connection points (or interconnection points) are located"
BTIgnite believes that clearly it will be possible for KPN to produce evidence that the costs of ILLs vary in different geographic regions should they wish to do so. It is also fairly obvious that the areas that operators will wish to make use of ILLs will be those areas where it is uneconomic for them to provide their own capacity and so it is unlikely ILLs will be needed only in those areas in which provision of bandwidth is the cheapest. BT Ignite therefore believes that there will be cost differences in different regions for ILLS.
The key question is, as stated in the consultation document, whether such cost differences should result in a differential tariff.
In answering this question it is important to look at the reasons why KPN would want such a tariff structure. For example:
• Alternatively KPN could feel under competitive pressure in areas where ILL would cost less than the average cost therefore
allowing their own input costs to fall in these areas.
Clearly if either of the two cases above are valid then geographic de-averaging at this stage is likely to result in reduced
competition.
BT Ignite therefore believes that to allow differential charging at this stage would effectively condone the selective use of accounting separation and cost transparency information from KPN for its own benefit. KPN have failed to produce transparent and separated
accounting information on interconnect services in the past when to have done so would have benefited interconnecting operators.
Therefore to allow KPN to use such information now to produce a geographically de-averaged tariff when such an outcome is likely to be in KPNs favour would effectively promote a discriminatory use of cost information that is only available to KPN.
Therefore whilst BT Ignite would strongly support the production and publication of transparent cost information for the elements making up the proposed ILL service we would not support the use of such information to justify geographically de averaged charges at this time. In the future when KPN have an effective, transparent and audited cost accounting system that enables cost information for all of their interconnect services to be determined and compared with their retail costs in place then the particular cost averaging situation for ILLs could be reviewed
Amsterdam, 27 February 2002 BT Ignite Nederland B.V. Olaf J.M. Olmer
Annex 1 - Diagrammatic breakdown of "cost components" of an ILL
Diagram 1 - network components of an ILL
Diagram 2- equipment within a network component
Point of
Handover
Serving
Exchange
OLO
Network
Incumbent-sited Mux OLO-sited Mux1
1
2
Core Xmission Network
3a
3a
3b
4
Hand-over Line system
5
n
= key cost building blocks
3rd party
customer site
Local
Loop
Equipment dedicated to 3rd
party customer
@ 3rd party site @ serving exchange + installation + indirect costs1
Local End Infrastructure
Between 3rd party site and serving exchange
- Local Copper / Fibre - Duct
- related operating and indirect costs - possible new build
2
Core Transmission Network
“fixed” costs “Distance-based” costs
3
Core SDH Network 3a 3a 3bPoint of Hand-over Costs
Either OLO-handover or In-span handover
4
OLO networkCircuit Provision
5
One-time costs of configuration, activation, testing, etc.
3a 3b
Wholesale Selling
Supporting the OLO customer (selling, customer service, billing, etc.)
Annex 2
Additional points following the KPN presentation at OPTAS verbal hearing 25th February 2002.
KPN presented a pictorial representation of an end to end circuit constructed using ILLs at the hearing. BT Ignite wish to support KPNs view that an ILL is defined as a circuit running from the point of connection to a customers premises. However we consider that the restriction KPN seek to impose whereby at least two ILLs must be used to complete a service to a particular customer constitutes an unnecessary bundling of the service. We consider such bundling to be in breach of the interconnect Directive and Dutch Telecomms. law and therefore suggest that such a restriction is unacceptable. ILLs should not therefor be constrained in their use to being only one end of an end to end leased circuit.
Annex 3
Private Circuit Provision - targets: MegaStream 2 (1st Circuit) –
30 Working days. MegaStream 2 (Successional Circuit) - 10 working days
Operator % Achieved
2000 Year to Mar Year to June Year to September Year to December
% ? 3 3 % ? ? % ? ? % ? ? BT 96.2 93.2 94.32 93.23 Operator Average 98.45 .43 ? 97.34 .46 ? 96.71 .45 ? 96.09 .45 ? OPERATOR 1 OPERATOR 2 OPERATOR 3 55.56 7.43 76.92 5.60 86.36 4.68 OPERATOR 4 92.86 1.73 86.19 1.49 82.79 1.41 82.16 1.36 OPERATOR 5 100 3.24 ? 100 4.17 ? 100 4.59 ? 100 4.49 ? OPEARTOR 6 96.43 4.58 ? 90.63 5.57 ? 90.63 6.18 ? 90.63 6.12 ? OPERATOR 7 100 2.53 ? 100 2.16 ? 100 1.80 ? 100 1.77 ? OPERATOR 8 90.00 7.66 ? 91.89 5.38 ? 92.50 5.53 ? 93.18 5.43 ? OPERATOR 9 93.33 6.26 ? 66.67 5.49 66.67 5.21 69.81 5.21 OPERATOR 10 95.45 6.72 ? 96.67 6.38 ? 96.00 5.38 ? OPERATOR 11 OPERATOR 12 94.42 1.12 97.12 .98 ? 96.62 .90 ? 95.18 .85 ? OPERATOR 13 99.82 .5 ? 99.78 .60 ? 99.72 .61 ? 99.62 .61 ? Private Circuit Restoration - Target : 5 clock hours
Operator % Achieved
2000 Year to Mar Year to June Year to September Year to December
