Smart Meter Wide Area Network DCC Assurance Strategy

Similar documents
Data Communications Company (DCC) price control guidance: process and procedures

Digital Industries Apprenticeship: Assessment Plan. Cyber Security Technologist. April 2016

Electricity Market Reform (EMR) Panel of Technical Experts for the Enduring Regime:

Digital Inclusion Programme Started. BL2a

Summary of the role and operation of NHS Research Management Offices in England

Government Response on Home Area Network Solutions: Implementation of 868MHz

Smart Meters Programme Schedule 2.5. (Security Management Plan) (CSP South version)

The Gateway Review Process

7 Directorate Performance Managers. 7 Performance Reporting and Data Quality Officer. 8 Responsible Officers

Smart Metering Implementation Programme

Cyber Security Consultancy Standard. Version 0.2 Crown Copyright 2015 All Rights Reserved. Page 1 of 13

Horizon NSL Pre-Application Intervention Strategy

Consultation on DCC Enduring Release Management Policy. Consultation opens: 18 September 2015

Governance, Risk and Best Value Committee

Project Assessment Framework Establish service capability

Government Communication Professional Competency Framework

QSS 0: Products and Services without Bespoke Contracts.

Welsh Government Response to the Report of the National Assembly for Wales Public Accounts Committee on Grant Management in Wales Final Report

Business Continuity Management

Securing Information in an Outsourcing Environment (Guidance for Critical Infrastructure Providers) Executive Overview Supplement.

Health and Safety Policy and Procedures

PROJECT MANAGEMENT FRAMEWORK

OUR ASSURANCE PLAN 2016/17 MARCH Our Assurance Plan 2016/17

Outsourcing. Definitions. Outsourcing Strategy. Potential Advantages of an Outsourced Service. Procurement Process

The Levy Control Framework

Smart Metering Implementation Programme: Data Privacy and Security

System of Governance

COMPLIANCE OFFICER. CLOSING DATE: 12 June 2016

CAPABILITY MATURITY MODEL & ASSESSMENT

The FIDIC Suite of Contracts

UoD IT Job Description

Job Description Strategic Projects Team Leader

Project Management Policy and Procedure

BANKING UNIT BANKING RULES OUTSOURCING BY CREDIT INSTITUTIONS AUTHORISED UNDER THE BANKING ACT 1994

Information security controls. Briefing for clients on Experian information security controls

UK-London: IT services: consulting, software development, Internet and support 2011/S CONTRACT NOTICE. Services

QUALITY MANAGEMENT POLICY & PROCEDURES

Disability Employment Services Quality Framework Advice V 2.0

POSITION INFORMATION DOCUMENT

Network Rail Infrastructure Projects Joint Relationship Management Plan

Information and Communication Technology

Medical Appraisal Guide

Job purpose This role will play an integral part in the management and delivery of service to the business.

ICT Digital Transformation Programme

The Compliance Universe

Job Description. Information Assurance Manager Band 8A TBC Associate Director of Technology Parklands and other sites as required

Comparison of internet connection records in the Investigatory Powers Bill with Danish Internet Session Logging legislation

Info sheet : Considering labour standards in the procurement process

Efficiency Scrutiny Committee 16 th September 2014 IT - Scrutiny of the Service Review process and viability of options for change

An Insurance Contract IFRS Is Coming

Template for IT Project Plan. Template for IT Project Plan. [Project Acronym and Name]

Investors in People First Assessment Report

Meeting 2/07/10. consider and discuss the report s recommendations (as relevant to HE and HEFCW) and initial proposals for addressing these

Corporate Governance Report

TERMS OF REFERENCE For the Provision of Long Term Advisor Services To the Government Technical Advisory Centre

ISO 9001:2015 Internal Audit Checklist

Hertsmere Borough Council. Data Quality Strategy. December

D-G4-L4-126 Police contact management and demand reduction review Deloitte LLP Service for G-Cloud IV

Cloud Sourcing G-Cloud 5 Framework

Corporate Director Environment & Community Services

U & D COAL LIMITED A.C.N BOARD CHARTER

Corporate Governance Service Business Plan Modernising Services

TG TRANSITIONAL GUIDELINES FOR ISO/IEC :2015, ISO 9001:2015 and ISO 14001:2015 CERTIFICATION BODIES

Version No: 2 Date: 27 July Data Quality Policy. Assistant Chief Executive. Planning & Performance. Data Quality Policy

Evidence of English language skills: Guidance for European doctors applying for a licence to practise

Position Description NDCO Team Leader

Request for feedback on the revised Code of Governance for NHS Foundation Trusts

Report on: Strategic and operational planning 2016/17 to 2020/21

Smart Meters Programme Schedule 8.6. (Business Continuity and Disaster Recovery Plan) (CSP North version)

Association for Project Management Business Management System

Investors in People Assessment Report. Presented by Alli Gibbons Investors in People Specialist On behalf of Inspiring Business Performance Limited

To provide administration support to an administration team.

Heads of Schools: Appointment Process and Job Description

Overview. Service Description: BCP & DR Strategy (L6)

Part B1: Business case developing the business case

SELECTING A COMPETENT FIRE RISK ASSESSOR

Executive Summary. Page 2 of 12

Assessment Policy. 1 Introduction. 2 Background

Electricity Market Reform:

Information Governance Management Framework

Application Information Pack CRM Project Manager

The Provision of Consultancy: Debt Data Collection and Presentation

Contact address: Global Food Safety Initiative Foundation c/o The Consumer Goods Forum 22/24 rue du Gouverneur Général Eboué Issy-les-Moulineaux

How To Manage The Council

Thames Tideway Tunnel Cost of capital

JOB DESCRIPTION. Hours: 37.5 hours per week, worked Monday to Friday

ICAEW TECHNICAL RELEASE GUIDANCE ON FINANCIAL POSITION AND PROSPECTS PROCEDURES

Transcription:

Smart Meter Wide Area Network DCC Describing the means by which DCC seeks to ensure that Communication Service Providers meet their connectivity and coverage service commitments Version: v1.0 Date: 2016-03-07 Author: Classification: Eric Taylor DCC Public

Document Control Heading Revision History (Document Control Subtitle) Revision Date Summary of Changes Changes Marked Version Number 4 th March 2016 Initial Draft N/A 0.1 7 th March 2016 Internal DCC Review 0.2 7 th March 2016 First Release 1.0 Reviewers Name Title / Responsibility Release Date Version Number Nektaria Efthymiou Deputy Chief Technology Officer, DCC 7 th March 2016 1.0 Approvals Name Signature Title / Responsibility Release Date Version Number Nektaria Efthymiou Jonathan Simcock Deputy Chief Technology Officer, DCC 7 th March 2016 1.0 Managing Director, DCC 7 th March 2016 1.0 DCC Public Page 2 of 15

Table of Contents 1 Executive Summary... 5 2 Introduction... 5 2.1 Smart Metering Wide Area Network... 5 2.2 Data Communications Company Assurance... 6 2.3 Document Purpose... 6 3 Assurance Approach... 6 3.1 Principles & Adaptability... 6 3.2 Types of Activity... 6 3.2.1 Review of Contractual Deliverables... 6 3.2.2 Fit For Purpose Verification... 7 3.2.3 Enduring Service Support... 7 3.3 Mobilisation and Fulfilment... 7 4 Communication Service Provider Contracts... 8 4.1 Policy... 8 4.2 Proportionate Cost... 8 4.3 Service Provision Predictability... 8 4.4 Contractor Flexibility... 8 4.5 Premises Connectivity and Geographical Coverage... 9 5 Communication Service Provider Solutions... 9 5.1 CSP South & Central: Telefonica... 9 5.1.1 Cellular... 10 5.1.2 Mesh... 10 5.2 CSP North: Arqiva... 10 5.2.1 Long Range Radio... 10 6 SM-WAN... 10 6.1 Annual Strategy Review... 10 6.2 Implementation Programme Phases... 10 6.3 Evaluation of CSP Coverage Milestones... 11 6.4 Enduring Assurance Requirements... 11 6.5 Resourcing... 11 6.6 Assurance Equipment... 12 6.7 Third Party Services... 12 6.8 Dispute Resolution... 12 6.9 Independent Peer Review... 13 DCC Public Page 3 of 15

6.10 Comparable Good Industry Practice... 13 7 SM-WAN Assurance Activity... 13 7.1 Completed Activity... 14 7.2 Current Activity... 14 7.3 Mobilising Activity... 14 7.4 Future Activity... 14 DCC Public Page 4 of 15

1 Executive Summary Under the guidance of the general objectives of its licence, DCC undertakes regular reviews of the Communication Service Providers (CSPs) progress of their deployment of the infrastructure for the Smart Metering Wide Area Network (SM-WAN). DCC does this in order to assure that the required connectivity to 80% of UK premises will be ready in time for DCC Release 1.2 Go Live, and that this connectivity will reach over 99% of UK premises by the end of 2020. These assurance reviews are based on evaluations of the network design, measurements of the number of premises which are within the progressively expanding Coverage Areas, and also by looking at the amount of required infrastructure which has been successfully provisioned by the CSPs. In support of SM-WAN assurance, DCC has planned in the most cost effective manner to enable the undertaking of expert CSP peer reviews, DCC architectural reviews, and DCC field-based assurance activities. Once the CSP Solution Design has been completed and the CSPs network planning models have been validated, DCC undertakes regular reviews of the progress of the rollout of the SM-WAN infrastructure which is based on those designs. In order for DCC to be able to independently assert that the service contracted for has been delivered, DCC will obtain, or make provision to gain access to the necessary sets of certified and calibrated portable equipment. At times, certain specific skillsets, competencies or experience are required by DCC to execute a planned and approved assurance activity. Where this provision does not exist internally nor is it planned to be acquired by DCC for its reasonable ongoing SM-WAN support services, then DCC will contract for this service via a third party. If instructed to do so, DCC could support arbitration by performing a SM-WAN connectivity measurement using its SM-WAN assurance equipment. This document further details the DCC strategy and approach, illustrating the issues, decisions, and SM-WAN assurance activity which is foreseen in this respect. 2 Introduction 2.1 Smart Metering Wide Area Network The Smart Metering Wide Area Network (SM-WAN) is a national network designed to provide connectivity between Smart Meters installed in premises, and the DCC computer systems providing smart metring services to DCC users. A key architectural component of the government s Smart Metering Implementation Programme (SMIP), the SM-WAN has been chosen by DECC to be realised as a wireless network, using various radio technologies. DCC Public Page 5 of 15

The Communication Service Providers (CSPs) who have been contracted to provide this wireless connectivity are tasked with the mobilisation of appropriate equipment and facilities in order to provide the necessary service levels. The CSPs are instructed to do this in the most economically efficient manner. 2.2 Data Communications Company Assurance DCC, under the direction of OFGEM and following the general objectives of its licence terms, has an obligation to cost-effectively manage the CSPs. This requires DCC to take all reasonable steps within its remit to ensure the timely delivery of the contracted SM- WAN services. This also includes DCC undertaking the necessary due diligence to assure that the CSP services foreseen will indeed be available and fit for purpose in the contracted timescales. 2.3 Document Purpose This document describes DCC s approach to SM-WAN assurance, the landscape of the CSP contracts and their solutions, followed by DCC s strategy and plans for undertaking appropriate and proportionate assurance activities. 3 Assurance Approach 3.1 Principles & Adaptability DCC is required by the guidance provided in its license conditions to strike an appropriate balance between costs incurred in undertaking assurance activities, and the benefits that this assurance brings in terms of risk mitigation and confidence levels. As the smart metering programme and the rollout of the SM-WAN develop, this balance will need to adapt accordingly. On an annual basis DCC performs an internal review of its SM-WAN and this underpins budget, resource, and equipment planning for the subsequent year. 3.2 Types of Activity The different aspects of assurance activities can be broken down into the following three categories. 3.2.1 Review of Contractual Deliverables DCC reviews and approves formal contractual deliverables from the CSPs. These artefacts are designed to support the acceptance of specific milestones during the implementation phases of the SM-WAN. For the most part, the CSP contracts were designed such that these milestone acceptance criteria could be met by the submission of document evidence to DCC, however some field-based activity is also implied. Links to the redacted CSP Contracts can be found on the menu of this page of the Smart DCC website: DCC Public Page 6 of 15

https://www.smartdcc.co.uk/about-dcc/service-providers/ 3.2.2 Fit For Purpose Verification Whilst overseeing the delivery of the contracted CSP service in a formal manner, DCC must also take actions to validate that the SM-WAN service will yield the intended outcomes during its operational use. This is known as Fit For Purpose assurance. Unlike the review of contractual deliverables, these Fit for Purpose actions are generally not defined specifically. DCC is however able to infer its obligations by following the spirit and intent of the general objectives of the DCC Licence. The nature of the SM-WAN service means that the majority of these Fit For Purpose actions would to some extent involve field based activity by DCC or an independent third contracted third party. For example, to check if SM-WAN connectivity was fit for purpose, DCC would need to undertake the same actions as Service Users and try to perform the same actions as would be undertaken when installing a Communications Hub in a premises. DCC would also look at different scenarios and determine which set of SM-WAN use cases would best deliver a Fit For Purpose Test. 3.2.3 Enduring Service Support Where appropriate as a regulated service provider, DCC will seek views from Industry to align its vision for SM-WAN enduring support with both established and developing good industry practice. It is expected that this will include consideration of typical profiles of support which would normally be delivered by equivalent commercially-driven services. Pertinent examples are established Machine to Machine (M2M) and developing Internet of Things (IoT) provider support services. DCC will take guidance in this matter from feedback gained via consultations and discussion at its monthly SM-WAN Industry Forum. 3.3 Mobilisation and Fulfilment Under the remit of the Chief Technology Officer, DCC maintains internal business planning which provides for the necessary resources, equipment and budget to fulfil the objectives of the SM-WAN assurance strategy. The forecasted characteristics of the upcoming assurance activity lead to carefullycontrolled DCC investment for targeted assurance work. In time, this activity will converge towards a Business As Usual or Target Operating Model, the objective of which will be to deliver enduring service support. DCC Public Page 7 of 15

4 Communication Service Provider Contracts In order to appreciate the context of the assurance strategy, it is necessary to clearly identify the key principles of the CSP contracts which are being assessed by the assurance regime. 4.1 Policy Under the direction of the Department of Energy and Climate Change (DECC), the CSP contracts were designed to strike an effective balance between proportionate cost, predictability of service provision, and contractor flexibility. This approach was applied to all three Coverage Regions; North, Central, and South and are summarised below. 4.2 Proportionate Cost When compared against the measured consumer value of the benefits of smart metering, DECC s evaluation of the cost of provision of SM-WAN connectivity to premises found that just over 99% of premises could be connected and this could be achieved without disproportionate connectivity costs being incurred. Other premises (<1%) were considered to require disproportionate cost to provide SM- WAN connectivity. The CSPs were contracted to make the decision as to which premises would fall into this category, and therefore for the time being, those premises not receive SM-WAN connectivity. In the future, DCC may receive instruction requiring DCC to investigate the possible connectivity options for these premises. 4.3 Service Provision Predictability Within a CSP Coverage Region, those premises which will receive SM-WAN connectivity are considered to be in a Coverage Area. In order to reduce to a minimum the costs of risk premium added into the CSP contract bids, DECC recognised that it would not be economically efficient to ask the CSPs to identify in advance those specific premises which would not finally be in the Coverage Areas. This decision established the principle that the CSPs would develop some of the details of their deployment on a continuous basis as the SM-WAN rollout progresses. For this reason, CSPs make projections in the Coverage Checker Database as to when premises are likely to receive SM-WAN connectivity, but the dates associated with the projections may change. This is because some dependencies, such as planning applications for masts for example, are not under the full control of the CSPs and CSPs must adapt accordingly. Note that in this context, a Coverage Area is not a blanket geographical connectivity commitment, rather a method of describing a grouping of premises which could be connected to the SM-WAN without disproportionate cost. 4.4 Contractor Flexibility Under DECC governance, the SMIP programme analysis demonstrated that the most economically efficient model was to contract the CSP to: DCC Public Page 8 of 15

(i) (ii) (iii) (iv) progressively determine, during the SM-WAN rollout, which premises (<1%) would not finally receive connectivity; and, reasonably predict at a high level, the date at which SM-WAN connectivity was likely to be available for a given premises, but be free to adjust this prediction up until 30 days prior to installation of a Communication Hub at that premises; and, be accountable that once a connectivity commitment had been made 30 days prior to installation of a Communications Hub at a given premises, the CSP would not normally be able to rescind this connectivity commitment (99% SLA). publish the projected SM-WAN delivery dates at a premises level so that Service Users can check: a. when future SM-WAN connectivity is likely to be delivered, b. which premises should already have SM-WAN connectivity available and publish this 30 days in advance of that connectivity being available, c. which Communications Hub variant to use at those premises where SM-WAN connectivity should be already available. 4.5 Premises Connectivity and Geographical Coverage Communication Hubs are devices designed to be installed at a fixed location unlike other radio devices which are intended to require connectivity as they move, such as cellular mobile phones. It is important to note that the CSP contracts are crafted to cost effectively provide connectivity at premises, and not specifically provide geographical coverage. Therefore, the SM-WAN network which serves Communication Hubs does not specify geographic coverage This premises-based connectivity commitment is designed to provide premises coverage of 99.25% of premises in the South and Central CSP Regions, and 99.5% of premises in the Northern CSP Region. 5 Communication Service Provider Solutions The choice of technology employed by each CSP has an impact on the DCC evaluation of its reasonable assurance actions, taking into account the maturity of those technologies and the service provider s familiarity with their implementation. When considering the appropriate level of scrutiny to apply, DCC assurance choices are influenced by a risk-based approach to these and other factors. 5.1 CSP South & Central: Telefonica Telefonica have chosen to deliver as much of its connectivity commitment as possible using Cellular technology, with the remainder being provided using Mesh Infill. Telefonica are highly experienced in the management of devices which are used to access their network, especially for consumer devices. DCC Public Page 9 of 15

5.1.1 Cellular 5.1.2 Mesh The Cellular solution is built on very mature and well-understood Machine to Machine (M2M) technologies, but the scale of the implementation is a very significant extension of the existing Telefonica M2M platform capability. The challenges and characteristics of the use of Cellular M2M technology in domestic smart metering are well known, and experience exists in the UK due to the SMIP Foundation Phase. Cellular M2M is sometimes considered to be a very rich technology for the needs of some of the more straightforward aspects of smart metering. The Mesh technology, whilst well proven elsewhere in large smart metering deployments outside of the UK, is less mature and Telefonica do not have previous experience of hosting and operating this solution. Industrial Mesh technology is well suited to smart metering applications, especially Neighbourhood Area Networks (NAN). 5.2 CSP North: Arqiva Arqiva selected Long Range Radio technology to be the most appropriate for the topology of the CSP(N) region. Arqiva are experienced in the deployment and management of radio networks and broadcast. 5.2.1 Long Range Radio The selected Long Range Radio technology is very mature, and it has been extensively proven, specifically with large smart metering architectures outside of the UK. Long Range Radio requires a highly efficient technology implementation in order for the overall solution to be successful. The implementation is a significant increase in the scale of Arqiva s operations related to network provision for industrial devices. 6 SM-WAN DCC takes into account the following considerations in its management of SM-WAN assurance. 6.1 Annual Strategy Review SM-WAN assurance activities are underpinned by normal internal DCC business planning and the assurance strategy is reviewed annually prior to this business planning cycle. This ensures that there is an annual adjustment and refinement of the resource, effort and budget allocated to the targeted assurance outcomes in the forthcoming year. 6.2 Implementation Programme Phases As a greenfield project, the Smart Meter Implementation Programme presents a diverse set of stewardship requirements for DCC in its overseeing role as CSP contract manager. DCC Public Page 10 of 15

Whilst some components of the CSP solutions were already in place at the time of contract signature, most of the SM-WAN assurance roadmap follows the expected progression from design, implementation, test, and transition to live operations. 6.3 Evaluation of CSP Coverage Milestones CSPs are contacted to provide evidence to DCC meet their milestone acceptance criteria. Some of the earlier milestones related to the validation of their deployment models and testing to verify their projected connectivity level. This demonstrates to DCC that CSPs have evaluated and proven their coverage solution design. Later milestones track that the CSPs have completed the necessary and expected network build work required to meet the required coverage targets by the milestone dates. The evidence which is presented to DCC allows the CSPs to claim connectivity to the prescribed coverage percentage of premises in their CSP region. These milestones are published and updated on an annual basis in the DCC Statement of Service Exemptions document which can be found on DCC s website: https://www.smartdcc.co.uk/operations/live-operations/ In advance of the CSPs reaching specific milestones, DCC reviews the nature of the evidence which a CSP would need to submit in order that DCC can make the necessary assertions that the milestone acceptance criteria have been met. Whilst building a new network, in some cases this evidence might relate to the amount of mast or site construction work which had been undertaken, and in other cases it might reference the results of a coverage drive test. Depending on the technology, the CSP, and the milestone, the evidence required could vary significantly, and typically this evidence is commercially sensitive information. DCC intends to publish some redacted assurance evidence on its website in the future. 6.4 Enduring Assurance Requirements SM-WAN assurance work will continue at least up until the point at which the CSPs complete their contracted SM-WAN rollout. Once the CSPs service delivery has been demonstrated it is expected that there will still be further requirement for DCC s SM-WAN assurance competency. DCC foresees that its SM-WAN assurance capabilities will transition to facilitate typical expected support. DCC considers that mobilisation for assurance is a key enabler for its enduring operational SM-WAN support. 6.5 Resourcing In support of SM-WAN assurance, DCC has planned in the most cost effective manner to enable the undertaking of expert CSP peer reviews, DCC architectural reviews, and DCC field-based assurance activities. DCC Public Page 11 of 15

Existing DCC design and architectural staff will be complimented by experienced smart metering Subject Matter Experts (SMEs). These SMEs will interact with Service Users, CSPs and other parties as required in order to support field based assurance. The SMEs will be trained to support the Communications Hub and SM-WAN DCC services and will be capable of undertaking practical and empirical SM-WAN assurance work. Where DCC requires independent specialist advisory to scrutinise the CSP solution or perform due diligence in the form of CSP peer review, then external contractors or service providers will be employed for the duration of that need. It is not expected that such skills will be required on a permanent basis in DCC. 6.6 Assurance Equipment In order for DCC to be able to independently assert that the service contracted for has been delivered, DCC will obtain, or make provision to gain access to the necessary sets of certified and calibrated portable equipment. This assurance equipment will allow DCC to independently test the point-in-time connectivity at premises and perform the test in such a way that neither the Service User nor the CSP can reasonably doubt the technical accuracy of the outcome of the test. DCC will review the value of extending the ability of this portable equipment to also measure the connectivity at premises over a period of time. This will perform a test of the reliability of SM-WAN service availability at a specific individual location. It is foreseen that such measurements would normally be taken from the location in the premises where the Communication Hub would be installed, and using the auxiliary equipment prescribed by the CSP for that premises. 6.7 Third Party Services At times, certain specific skillsets, competencies or experience are required by DCC to execute a planned and approved assurance activity. Where this provision does not exist internally nor is it planned to be acquired by DCC for its reasonable ongoing SM-WAN support services, then DCC will contract for this service via a third party. DCC typically uses its approved Framework Providers as third parties to supply these services. Under certain circumstances DCC may discuss its requirements with other parties under DCC Market Warming Rules. For further information please refer to DCC Procurement Policy. 6.8 Dispute Resolution After having followed the required processes for installation of a Communication Hub as specified in the Communication Hub Installation and Maintenance Support Materials, it is possible that there may be a dispute about the actual availability of SM-WAN connectivity at certain premises. In the event that there is such a challenge from a Service User, DCC may be required in certain limited circumstances to perform a specific assurance activity in support of this situation. If instructed to do so, DCC could support arbitration by performing a SM-WAN connectivity measurement using its SM-WAN assurance equipment. DCC Public Page 12 of 15

This would provide to the arbitrator with information over and above that which could be gained simply by performing the test with a Communications Hub, to see whether or not it connected successfully to the SM-WAN. The aspirational requirement DCC will seek to achieve when undertaking such measurements is that the ideal equipment used in the test should, as far as is reasonably practical, have the same type of enclosure, antenna, and radio chipset as the Communications Hub in use for that premises. 6.9 Independent Peer Review At times, certain assurance work requires DCC to evaluate if the actions and plans of a CSP are in line with good industry practice or would be approved by an equivalently experienced person or organisation. This requires DCC to appoint a CSP peer who could objectively and competently provide DCC with a balanced assessment of the part of the delivery being scrutinised. Using this method, DCC will bring to bear very specific knowledge and experience. 6.10 Comparable Good Industry Practice The implementation of the SM-WAN service has many characteristics of a commercial Machine to Machine (M2M) service offering, albeit with the specific connectivity commitments under the umbrella of the Smart Energy Code and CSP contracts. When considering how to assure the SM-WAN implementations, DCC can compare those parts of the CSP SM-WAN solutions with their equivalent elements in a typical Industrial M2M service. This allows the comparable evaluation of these distinct underlying components. Typical examples of some of these individual components are; radio access, backhaul, device management, provisioning, SIM management, analytics, service management, and operational monitoring. 7 SM-WAN Assurance Activity Once the CSP Solution Design has been completed and the CSPs network planning models have been validated, DCC undertakes regular reviews of the progress of the rollout of the SM-WAN infrastructure which is based on those designs. These reviews look at the measurement of the number of premises which are within the progressively expanding Coverage Areas, and also measure the amount of required infrastructure which has been successfully provisioned. The progress of CSPs in meeting their SM-WAN rollout milestones is documented at a high level in the DCC Statement of Service Exemptions document. DCC reviews this document once per regulatory year. DCC Public Page 13 of 15

7.1 Completed Activity DCC has assured the CSPs Coverage Field Trial Reports as additional proof of the accuracy of the CSP coverage models; this validated the CSPs network planning assumptions. DCC has, and continues to assure coverage milestone achievement reports which demonstrate that the actual deployment or testing of coverage has met the prescribed contractual requirements. DCC has witnessed CSP drive testing, the methods of gathering data, and the evaluation of these results. DCC has presented its SM-WAN assurance strategy to the CSPs so that there is clear objective understanding of the DCC approach to evaluation of milestone acceptance criteria. 7.2 Current Activity DCC will continue to sign off coverage milestone achievement reports demonstrating actual deployment or testing of coverage does meet contractual requirements. DCC will continue to monitor witness and evaluate the methods used by the CSPs to assess their actual coverage. DCC is recruiting into its staff and training Subject Matter Experts who will be ready to support DCC R1.2 Go Live and undertake field based and Service User facing work. 7.3 Mobilising Activity DCC is investigating and procuring the necessary equipment required for it to be able to independently verify coverage claims at specific premises. Field-based Subject Matter Experts will perform limited test measurements to validate coverage claims of the CSPs prior to DCC Go Live. DCC is evaluating the most appropriate methods of undertaking CSP peer reviews and considering which partners would be best placed to provide advisory to DCC. Mesh technology will not be employed before 1 st Jan 2017, and in the second half of 2016 DCC will prepare its staff and equipment to validate the true field effectiveness of the CSP(S&C) Mesh implementation. 7.4 Future Activity In live operations, DCC will track installation success rate and overall coverage as these are formal contractual CSP performance measures. Field-based Subject Matter Experts will perform ad-hoc and targeted measurements on an enduring basis in order to validate coverage in specific premises. DCC Public Page 14 of 15

In late 2017 the CSP(N) will make available a Communications Hub variant for use in the area surrounding Fylingdales. DCC will mobilise to test and evaluate the specific SM-WAN service which is delivered to that particular Communication Hub. As the coverage commitments approach the high 90 %, DCC will adapt its approach to validate the delivery of these more difficult connectivity milestones and alternative approaches may be required to assure the CSP delivery. DCC Public Page 15 of 15