Telstra-NBN customer migration policy released

The Australian government has released its final Migration Assurance Policy, detailing the process for customers to transition from Telstra's legacy copper network to the fixed-line National Broadband Network (NBN).

The policy calls for migration data and information to be shared between Telstra Wholesale, NBN, retail service providers (RSPs), application service providers (ASPs), and other involved parties in a way that will promote efficiency "while respecting confidentiality and privacy".

Data to be shared includes the fixed-line footprint list, which outlines all premises that have been or will be passed by NBN's fixed-line network; the historical footprint list, which contains details on premises that can be served by the NBN; Telstra's disconnection list; service and location identification data; order information between Telstra and its customers, and between RSPs and NBN; and information on Telstra's active copper and hybrid fibre-coaxial (HFC) services.

Telstra is also required to provide its wholesale customers "on a best efforts basis" with information on which customers are close to reaching their disconnection date, so that they can be assisted in their transition to NBN services.

The plan identifies four "pillars" of customer migration onto the NBN: Serviceability, wherein NBN commits to making areas ready for service; product availability in regards to RSPs and ASPs providing broadband, voice, and over-the-top services over the NBN; end-user awareness and management, with NBN, RSPs, and ASPs to provide customers with information on the disconnection timings, the impacts of this, and the status of their connection; and installation and activation of NBN services in a timely manner by NBN and RSPs.

One of the primary issues addressed in the final migration policy concerns the management of safety critical services, such as fire alarm panels and lift phones; and management of vulnerable end users, including those with medical alarms that function over Telstra's copper or HFC networks, priority assistance end users, those with a severe chronic illness or disability, the elderly, those with limited English capacity, and people with mental disorders.

In regards to this, Telstra must provide location identification information to NBN for all active Telstra copper and HFC services in areas that are ready for NBN's services, including in the absence of wholesale customers' consent, to enable NBN to manage the fire alarm register, lift phone register, and medical alarm register, as well as to advise end users to migrate to the NBN.

Under the policy, NBN, medical alarm service providers, RSPs, Telstra, building managers, fire alarm and lift phone monitoring and maintenance service providers, state authorities, and other regulatory bodies are all also required to assist in the customer migration to make it as easy and as fast as possible.

"It is important that end users who rely upon a fixed telecommunications service for their health or safety (whether because of the application of a medical alarm or otherwise), and other vulnerable end users, successfully migrate to the National Broadband Network or alternative network platforms prior to the disconnection date for their service. Failure to do this may present a risk to their health or safety, or may otherwise result in an unnecessary disruption to their everyday lives," the policy document says.

"The successful migration of these services is reliant upon the end user receiving the necessary information from their application service provider, and from NBN and RSPs where relevant, and taking the appropriate action to migrate before their services are disconnected."

End users of all fixed-line services have been given an 18-month window to transition from Telstra to NBN from the date that an area is declared to be ready for service, with Telstra to disconnect its services once the timeframe has expired. The migration plan calls on RSPs to develop and offer retail products and services within this 18-month window to ensure minimal disruption to end users.

The draft policy, released in July last year, called for industry feedback on the issue, drawing on this to establish the final policy.

The government will also continue monitoring the progress of migration, including customer experiences and complaints to the Telecommunications Industry Ombudsman (TIO), the Australian Competition and Consumer Commission (ACCC), the Australian Communications and Media Authority (ACMA), NBN, and the Department of Communications.

In September 2014, Communications Minister cum Prime Minister Malcolm Turnbull began consultation to modify the migration process after the original May 2014 deadline to get residents off the legacy copper had failed. Three months after that deadline, there were premises in the first 15 regions "still subject to the migration process" as a result of poor coordination and communication between NBN and RSPs, and inadequate construction that prevented premises that had been passed by the NBN to actually connect to it.

Last June, the ACCC approved the migration plan seven months after Telstra and NBN had entered into a revised AU$11 billion deal allowing NBN to take ownership of Telstra's copper and HFC network assets. The modified agreement came as a result of the Coalition government's decision to move away from a full fibre-to-the-premises rollout to the present so-called multi-technology mix (MTM) network incorporating fibre to the node (FttN), fibre to the building (FttB), and HFC.

In December last year, however, a leaked NBN internal draft document revealed that the cost to replace or repair this legacy copper network will amount to AU$641 million.

"State of copper network considerably worse than expected, leading to extensive work beyond the node," the document, dated February 26, 2015, said.

NBN ranked this risk as "almost certain", with "major" consequences.

"Decision to minimise remediation during build could reduce speeds available, create additional burden on connect, and hamper timely migration."

With NBN building 24,544 nodes by FY19 -- with 178 premises connected per node -- at AU$26,115 per node, the cost for copper remediation totals AU$640.97 million.

This figure is a significant increase from the AU$2,685 per node estimated in the December 2013 Strategic Review, which would have totalled AU$90.4 million.

An NBN spokesperson pointed out that the document was an unendorsed draft from March with no bearing on the current state of the network, the cost of which was accounted for under its Corporate Plan.

"Based on our experience in the field, which for FttN now extends to more than 550,000 homes in construction and more than 40,000 homes ready for service, our cost per premises for FttN as outlined in the Corporate Plan in August is proving accurate," the spokesperson told ZDNet.

"Any costs related to the FttN network are accounted for in the corporate plan released in August, which included the increase in peak funding ... Risks and mitigation plans for the network are outlined in the Corporate Plan, and the revised peak funding figure takes these scenarios into account. We have produced a peak funding range and provided a contingency as prudent measures to manage a project of this size and complexity."

NBN had previously said that while copper lines between the node and the home will not need to be replaced, the company will need to add or replace copper between the node and the pillar where necessary in rolling out its FttN network.

"We have to put new copper in to run to the pillar that serves all of our homes from our node to that pillar. And that could range in distance between right next to each other ... it is a short section, but it is new copper that has to go in the ground that doesn't exist today," NBN CEO Bill Morrow told Senate Estimates in October.

According to Morrow, copper has to be used rather than fibre-optic cable in certain cases depending on the distances being covered. He added that defective cabling could also be replaced, with more copper also added where there is not enough to service homes.

"The other area to where we could be putting copper... is that if there are defective joints that are out there that have a trouble rate that's too high, we'll need to go ahead and make that investment to replace that joint as it stands," the chief executive said.

"And then in the other case that I mentioned, if it turns out that there's not enough pairs going down the street to be able to serve all the homes that are there, then we may actually have to add pairs in that path to be able to get to each one of the homes."

Morrow's comments came just a week after claims made by NBN that it has not had to replace any of the legacy copper between node and home in installing its FttN network, with end users able to achieve high speeds while relying on existing infrastructure.

At the end of last year, Telstra announced entering a memorandum of understanding with NBN for a "significant contract" to manage the design, engineering, procuring, and construction of NBN's HFC network currently within Telstra's HFC footprint, including updating HFC to include DOCSIS 3.1 technology in order to deliver end users speeds of up to 1Gbps.

Telstra also signed two contracts to repair faults on the copper network and undertake a "small number" of service connections that have yet to transfer to the NBN, and repair faults and connect new services on NBN's FttN, FttP, FttB, and HFC networks after a customer has migrated onto the NBN.

This came after documents were released late last year to media revealing that Optus' HFC network is "not fully fit for purpose", with 470,000 premises in the footprint needing to be overbuilt by either Telstra HFC or fibre services.

A leaked document, called HFC Plan B: Overbuilding Optus, dated November 2015, stated that the necessary work of overbuilding Optus' HFC network with FttN, FttB, or fibre to the distribution point (FttDP) will lead to a peak funding increase of between AU$150 million and AU$375 million, with NBN to miss its FY17 ready-for-service target by 300,000 premises, and its FY18 target by 333,000.

"Overbuilding the Optus HFC network with either Telstra HFC or FttX could deliver higher probability of success given the current state of the network [and] significant operational simplicity," the document said.

"Optus' network is not fully fit for purpose. Optus nodes are oversubscribed compared with Telstra, and will require node splits. Existing Optus CMTS don't have sufficient capacity to support NBN services. Noise (ingress) [is] causing interference and degrading end users speeds."