BT Carrier Price List - Proposed ‘Quick Win’ Improvements

1. BT Carrier Price List- Proposed ‘Quick Win’ Improvements presented by Helen Edwards, Vodafone Limited Interconnect Scope & Strategy

2. Vodafone welcomes the recent steps BT has undertaken to improve consistency of content in the CPL. We hope that BT will look to build upon these improvements. The lack of consistent format, file types (e.g. Microsoft Word & Excel)and change control makes some of the CPL price lists very difficult to navigate, identify changes and automate downloads. Those Operators who use INTEC, or an equivalent tool, must undertake substantial workarounds to convert files into csv readable format before they can be loaded. This causes unnecessary costs and delay in loading the data. Vodafone would therefore like to request a few “quick wins” which we consider are easy to implement and would significantly address many of the issues. These are:- Reformatting of BT Non Geographic Price List B1.06 Reformatting of DQ Price Lists B3.46 & B3.47 Improvements to the ‘Change Report to Operator’ in B1.12.1 The information contained in the above price lists would be easier to comprehend and to automate downloads if presented in contiguous columns. A format similar or the same as BT CPL 1.12.1 would work well. Changes would benefit all of Industry and save all Operators considerable time on a monthly basis. This work will also be time well spent in preparation for the proposed NGCS database. Improving CPL Layout and Consistency Interconnect Scope & Strategy

3. Price List, CPL 1.06 The format of the price list is cumbersome; pricing for individual chargebands are split amongst multiple tables, with separate tables for PPC and PPM charges. Notes on charging are written freehand within the file and across multiple worksheet cells. The number ranges to which the charges pertain are presented in an entirely separate worksheet and are not listed at all for BT own 08 ranges. This would also be a good opportunity to review some of the potential number range anomalies on B1.06. DQ Price Lists B3.46 (Operator DQ) & B3.47 (BT DQ) Identifying the relevant charges for a number range are hindered by the format of separate tables for PPC and PPM charges. The size of B3.46 would be significantly reduced if the PPM and PPC appeared on the same row entry. There is no ‘Change’ (signifying date) or ‘Reason’ (descriptor of the change) field in either B3.46 & B3.47, as a result trying to identify recent amendments and additions to either price list is difficult. The BT DQ Price List (B3.47) is a Microsoft Word file, which is particularly unwieldy to navigate. Change Report to Operators Vodafone welcomes the implementation of improved change reasons and would like BT to build upon this improvement. ‘The Change Report to Operators’ would be significantly enhanced if it contained the details of the new charges and gave the relevant BT CPL reference, thus providing an effective summary of the changes. This information is already known in order to update the CPL. It would not require much additional effort to replicate (copy & paste) into the report. The arbitrary cut off points in updates often means that change information for a particular number range is disjointed. Three Quick Wins… Interconnect Scope & Strategy

4. Charges for PRS Chargeband P34 highlight the issues with the format of BT CPL 1.06. Extract from BT CPL 1.06 Table 1.6.5.1.36a shows the PPM charges Number Ranges listed on separate worksheet in B1.06 Table 1.6.5.2.31 a) shows the PPC charges. • P34 PPC charge info is some 1108 rows below the P34 PPM info Notes relating to the PPM charges Notes relating to the PPC charges • The format of the price list is cumbersome; pricing for individual chargebands are split amongst multiple tables, with separate tables for PPC and PPM charges. • Notes on charging are written freehand within the file and across multiple worksheet cells, e.g. columns C to Y. • The number ranges to which the charges pertain are presented in an entirely separate worksheet and are not listed at all for BT ‘s own 08 ranges. Is the number range information up-to-date and accurate? Old Charges, which have been struck through Interconnect Scope & Strategy

5. CPL 1.06 and 1.06a could simply and quickly be converted to a much more user friendly format. This would also be easier for BT to maintain going forward. BT CPL 1.06 – How it could look Historical Rates shown PPC charges PPM charges Relevant notes for the Chargeband are grouped together • CPL 1.06 (v. 12.5) has 131 chargebands in total, including PNS, Nat, Local and Freefone etc. • The above example for all P34 number ranges and notes took less than 5 minutes to create and format from scratch. • We estimate that it would take around 5 hours at most to reformat into a csv compatible format and pull out the relevant 08 and 09 number ranges for this Price List. • This would save all Operators, including BT, considerable time and effort on a monthly basis. Interconnect Scope & Strategy

6. Extract from BT CPL 3.47 • Identifying the relevant charges for a number range are hindered by the format of the price lists with separate tables for PPC and PPM charges. • The size of B3.46 would be significantly reduced if the PPM and PPC appeared on the same row entry. • There is no ‘Change’ (signifying date) or ‘Reason’ (descriptor of the change) field in either B3.46 & B3.47, as a result trying to identify recent amendments and additions to either price list can be tricky. • The BT DQ Price List (B3.47) is a Microsoft Word file, which is particularly frustrating for billing teams. This Table shows the PPC charges Page 1 Notes section Page 9 This Table shows the PPM charges Page 5 Interconnect Scope & Strategy

7. CPL 3.46 and 3.47 could fairly simply and quickly be converted into Excel in a user friendly format. This would also be easier for BT to maintain going forward. BT CPL 3.47 – How it could look New Columns to assist in identifying changes PPM & PPC charges Historical Rates shown • CPL 3.47 has 63 DQ chargebands in total. • The above example and notes took less than 2 minutes to format. • We estimate that it would take <= 2 hours to reformat CPL 3.47 into a csv compatible format. • This would save all Operators, including BT, considerable time and effort on a monthly basis. Interconnect Scope & Strategy

8. Change Report to Operators: Notifying of Changes • Operators need access to an information source where significant price changes, such as change of chargebands can be identified quickly and easily in order to avoid loss of Margin, AIT and arbitrage. • BT ‘s ‘Change Report to Operators’ does list changes, but does not fully meet the need as it does not give sufficient or consistent information about the new charges nor does it provide the reference of the relevant CPL. • BT’s implementation of additional change reasons, which identify the type of change, e.g. ‘new’, ‘change of chargeband’ etc, is certainly a step in the right direction, but the ‘until date added’ reason code is still confusing and seems to be used for various scenarios. • Pricing is provided for certain number ranges e.g. PNS and 0870, but not others e.g. PRS and 0845. • Currently Vodafone is having to run it’s own bespoke workarounds, whereby we run queries against the prior version of the CPL price lists versus the new. This is a very time-consuming exercise and still requires manual analysis of ‘anomalies’. Extract from ‘Change Report to Operator What happens to the PNS no ranges and 0845492 after 14/08? 09 pricing changed due to retrospective acceptance of an OCCN Details of the old and new price are provided for Relax Telecom. Interconnect Scope & Strategy

9. Change Report to Operator: Proposed Improvements • The Change Report to Operators’ could quite easily be improved with just a few tweaks to provide an effective summary of all price changes. Suggested improvements are:- • Current charges and new charges and /or new operator ownership for each number range are provided on the Report. This information is already known as part of the OCCN process. In many instances the individual CPL has also been updated with the details. • BT CPL reference is provided for each relevant number range. • Change reasons are further refined and standardised, particularly with reference to ‘Until date added’. Where services are ceased a new change reason ‘Number cessation’ is used. Proposed Format for ‘Change Report to Operator Current and New PPM and PPC pricing provided. CPL reference provided. DQ pricing information consolidated. Interconnect Scope & Strategy

10. In Summary… • The changes that Vodafone are proposing that BT make to the CPL are:- • Reformatting of BT Non Geographic Price List B1.06 • Reformatting of DQ Price Lists B3.46 & B3.47 • Improvements to the ‘Change Report to Operator’ in B1.12.1 • The changes could be quickly and cheaply implemented. • These changes would address a significant amount of issues and frustrations that Operators have today with the CPL. • We hope that BT will give due consideration to the proposal and advise on next steps. • Thank-you for listening! Interconnect Scope & Strategy