The boss of UK ISP Andrews & Arnold (AAISP), Adrian Kennard, has written somewhat of a spicy open letter to Ofcom – highlighting both their concerns with the preparedness of the organisation (TOTSCo) overseeing development of the new broadband provider switching system and with the regulator’s own “lack of response” to this.
Just to recap. The industry-led One Touch Switching Company (TOTSCo) is responsible for implementing Ofcom’s now heavily delayed One Touch Switch (OTS) migration system for faster and simpler consumer broadband switching between ISPs on physically separate networks, which is currently due to go live on 12th September 2024 (here).
The OTS system was originally intended to go live in April 2023, but it’s since suffered several delays, which is something we’ve covered extensively several times before (here, here and here). Most of the blame for this was placed at the feet of the major providers, with Ofcom singling out BT, Sky Broadband, TalkTalk and Virgin Media (VMO2) for not being able to complete the necessary testing and trials before the revised go-live dates (here).
However, it’s not entirely fair to shift all the blame for this on to the shoulders of ISPs, since Ofcom largely seemed to step back and allow a now heavily fragmented and aggressively competitive industry to figure it out for themselves (a bit like trying to herd cats). Put another way, establishing more effective regulatory leadership earlier on in the process might have avoided all this, but we’ve covered that in previous articles.
The problem today relates to the challenge of getting the system being developed by TOTSCo ready in time. Suffice to say that if you’ve been following Adrian Kennard’s blogs on the subject, then you’ll know there are still a lot of bugs, issues with a lack of standardisation, questionable processes and other obstacles that could make it difficult for OTS to reach the current deadline.
At the same time, ISPs appear to be coming under increasing pressure from Ofcom to be ready in time, even though they are all now dependent upon TOTSCo getting their act together in order to do that. All of this recently boiled over into Adrian’s latest open letter.
Open Letter from A&A CEO to Ofcom
I am quite disappointed at the lack of response at all to this.
You sent us a letter, and I have replied by email, and letter.
I have not even had an acknowledgement of my email, nor letter.
I have serious concerns about the way TOTSCO are operating, and would be interested in engaging (constructively) with OFCOM on this.
I am seriously concerned at the whole way specification and testing is being done.
We have completed all testing at TOSTCO, but it was a total joke. ZERO testing against any reference system, nor against the specification, at any point. The only practical testing is pot luck against another CP that has not yet passed testing, and just hope one or the other pick up any issues.
Specifications which are unclear, incomplete, contradictory, and just plain wrong, now subject to a “change freeze” at the very time lots of CPs are trying to meet those specifications.
And the latest is a bulletin suggesting better handling of messages which basically changes the specification such that some CPs will not work properly with some other CPs, even after both passing all testing, and nobody will know until the 12st September.
If OFCOM are not interested in making this happen properly, then that is your choice, ultimately, but if that is the case have the guts to remove it from the GCs and give up on it.
Some of us are trying to make it work and running in to a lot of problems. I have even set up a complete OTS testing platform, because TOTSCO don’t actually have one, and made it free to the many CPS using it now. This really should not have been necessary. It is the least I could do though.
When I say TOTSCO don’t have one, I mean it – their “simulator” generates a few fixed (and hence invalid) message responses only, and their production integration test (PIT) seemed to involve them hand crafting messages, one of which was invalid, even!
Hundreds of small CPs are, right now, trying to comply with this crazy system, and they really are struggling.
—
Adrian Kennard
Director
Andrews & Arnold Ltd
Naturally, we raised these concerns with both TOTSCo and the regulator. TOTSCo declined to comment but did inform us that they were currently reviewing the concerns raised by Adrian’s letter, while Ofcom say they have now responded to A&A and have offered a meeting to discuss the concerns.
A spokesperson for Ofcom told ISPreview:
“We have responded to A&A, offering a meeting to discuss their concerns.
One Touch Switch was one of the options put forward by industry to implement our new simpler switching rules, and TOTSCo was established by industry to help deliver the new process.
We are engaging regularly with industry and doing everything we can to support them in getting the new system up and running as quickly as possible.”
We should point out that some of the problems being raised by A&A are well known within the industry (i.e. it’s not solely an issue for one provider), although it’s rare that we get to hear about such things in public as they’re normally handled behind closed doors. On the other hand, there’s still time for a lot of bugs to be squashed before the deadline, with TOTSCo now entering the final ramp-up stage of trials before launch.
However, we wouldn’t be surprised to see a small additional delay creep in and that might even be for the best, particularly since launching the new system in an unfinished state may risk doing much more harm to consumers than good.