FAQ

1. Openreach - General

Q1 What is Openreach?
We work on behalf of over 450 Communications Providers such as Fujitsu, Carphone Warehouse, BT Retail and AOL.

Our job is to look after the wires, fibres and connections that link homes and offices around the country to the local telephone exchange, where the lines connect to the Communications Providers’ national networks.

Q2 Who are your customers?

Communications Providers – businesses who provide telephony and internet services to homes and businesses. This also includes other parts of BT.

By providing a level playing field on which Communications Providers can compete, we enable them to deliver innovative and competitive services to the 60 million people living and working in the UK.

Q3 Do you have competitors?

We are in competition with alternative access technologies such as Cable and Wireless.

Q4 What are your products/services? 

a) Wholesale Line Rental
Wholesale Line Rental allows Communications Providers to rent analogue or ISDN telephone lines from Openreach and resell them to their own customers. This means the end customer buys the line and the calls and receives a single bill for both services from the Communications Provider.

b) Local Loop Unbundling
The local loop is the copper telephone line between an end customer’s house or business and the nearest BT exchange. Openreach will sell two product variants. With Full Local Loop Unbundling, another Communications Provider rents the whole line from Openreach. The line is physically disconnected from BT’s network at the exchange and connected to another network. The customer only gets services from the other provider over the line and doesn’t receive bills from BT.

With Shared Local Loop Unbundling, Openreach only rents to the Communications Provider the part of the copper line used to deliver broadband services. The part of the line used to deliver voice services is retained by Openreach and made available to provider of voice services, including other parts of BT. In this case the copper line isn't fully disconnected from BT's network, but a 'splitter' is used at the exchange to separate broadband and voice. The customer gets two bills, one from the voice provider (BT or another voice provider) for the voice part of the copper line and one from the local loop unbundler.

c) Wholesale Extension Service
This is a service sold to Communications Providers that provides a permanently-connected high speed data circuit connecting a customer’s site to a point where it can be connected to the Communications Provider’s own network. The service uses Ethernet technology.

d) Backhaul Extension Service
This is an Ethernet-based service sold to operators purchasing unbundled local loops, providing a connection between the BT local exchange where the copper local loop terminates back to the Communications Provider’s network.

e) There are also products that Openreach must offer within a reasonable time of a request from a Communications Provider (Undertakings section 5.5); these include TILLAPs (Traditional Interface Leased Lines Access Product) and TILLBPs (Traditional Interface Leased Lines Backhaul Product).
These are component products sold by Openreach to Communications Providers to allow them to offer leased line services to their customers. The TILLAP runs from a customer site to the nearest BT exchange, where the circuit may be connected to the Communications Provider’s network. Alternatively a TILLBP may also be purchased to allow connection to the provider’s network at another point, subject to a distance limitation of typically 15km. The Wholesale Extension Service Access Product is a type of Wholesale Extension Service which allows Communications Providers to carry data between their customers’ sites and BT “access nodes”, typically local exchanges. The Wholesale Extension Service Backhaul Product complements the Wholesale Extension Service Access Product and is used by a Communications Provider to carry data from the BT access node to a point where it can be linked in to the Communications Provider’s own network. The Wholesale End-to-End Ethernet Product would enable a Communications Provider to link two sites belonging to one of its customers using a permanently connected Ethernet circuit. A maximum distance of 25km would apply.  Sub-loop Unbundling is a version of Local Loop Unbundling. Here, the telephone line is disconnected from BT’s network not at the local exchange, but at a point in between the customer and the exchange, generally a street cabinet.

Q5 Can consumers and businesses buy directly from Openreach?

Our products are the “building blocks” which Communications Providers use to create their own services. We sell our products to Communications Providers, which are companies which onward sell telephony and internet services (as opposed to consuming them themselves). Communications Providers include, for example, Internet Service Providers, as well as other parts of BT.

Q6 Why ‘Openreach’ as a name?

Openreach was chosen as a symbol of the way we will operate, delivering ubiquitous services on an open and even-handed basis to any and all Communications Providers, including to BT's own downstream divisions.

Q7 Are you really going to treat BT like any other customer?

Yes. Openreach will provide the same services at the same prices to BT’s other divisions in ways that are open and transparent and which overcome any suggestion that other parts of BT are favoured at the expense of the interests of Openreach’s customers.

Q8 What does ‘equivalence’ mean?

The key priorities of the new line of business will be equivalence and improving service.On equivalence, we have said we will:

Demonstrate our absolute commitment to conducting business with all Communications Providers equally, in accordance with our Undertakings to Ofcom and, indirectly, to the industry Support the UK telecommunications industry in a fair, even-handed and transparent way Protect and promote the interests of all Communications Providers On a very practical level, this means we will treat all customers in an equivalent way by:

providing the same products and services, and relevant Commercial Information, to all Communications Providers – including to BT’s other lines of business – on the same timescales, terms and conditions, including price, and by means of the same systems and processes; and Interacting with other Communications Providers using systems and processes in the same way as we do with BT’s other lines of business, and with the same degree of reliability and performance.

Q9 What does ‘improving service’ look like?

We will strive not just to provide, maintain and repair the access and backhaul infrastructures, but to improve both service and reliability.We will also reinvent our infrastructure to support the continuing success of the UK telecommunications industry – ultimately enabling it to deliver more choice, better products and lower prices for its customers and to build profitable businesses.

Q10 How will people know this is happening?

To ensure transparency, Openreach CEO Steve Robertson will report directly to BT's CEO, Ben Verwaayen, and our progress and performance against a series of legally enforceable Undertakings will be monitored by an independent newly set-up Equality of Access Board (more about them in Section 6).

Q11 What was the Ofcom Telecoms Strategic Review (TSR) which led to Openreach’s creation and why is it  important?

The creation of Openreach was actually BT’s suggestion to deal with the issues raised by the TSR, which was a fundamental review of the rules and regulations that cover the UK’s telecommunications industry, the most comprehensive review of the industry since the privatisation of BT in 1984.Regulation reflects the obligations of BT, which still holds an exceptional position because of its size and its ownership of the majority of the fixed-line network that connects homes and businesses throughout the UK. So, a major subject of the TSR was the way that BT allows access to and charges other operators to deliver their own services to their customers by making use of BT’s local access and backhaul networks. Access to these BT networks at reasonable charges is considered very important if the vast array of different telephone and internet service companies are to succeed in offering innovative products and services to customers in a competitive environment.

Q12 Why should businesses and residential customers be interested in this internal BT organisational change?

Because it aims at safeguarding their interests by encouraging the entire communications industry to innovate and to compete more efficiently. The industry will do this by providing homes and businesses with new, exciting and value-for-money services in all areas from new high-speed data business services, to television, video, popular and classical music and a host of educational and leisure applications.

This is especially important in this modern era of “broadband” where the potential of high-speed communications is much greater than in the old days of basic voice telephone services. It is therefore much more important that no-one, including companies developing new applications for the technology, and marketing and delivering them to their customers, is inhibited in their ability to reach customers over the BT network.

Q13 What is the potential impact on the local economy?

For a start, Openreach will generate about £4 billion of revenue every year. It will employ 30,000 people, all of whom will contribute to their local economies and local communities through their spending power. They buy goods and services from local suppliers, and pay council taxes to local authorities.

Openreach will also be investing considerably in new capital projects. A fair proportion will be invested in this area through normal day-to-day business operations.

Q14 What should people – businesses and residential customers – do if they want to contact Openreach?

There’s no need to contact Openreach directly. Openreach works for all the Communications Providers which use Openreach’s access and backhaul networks to deliver their own services to end-users. So end-users should just continue dealing with the companies they have chosen to provide them with the services they need. That goes for customers of BT’s own retail division too.

2. Openreach - What we do

Q15 Why do you work on my line when I'm with another telecoms company?

We're part of the BT Group, but we work in an independent way to ensure all Communications Providers get exactly the same service.

Q16 Does it matter which Communications Provider I'm with?

Not when it comes to the service you receive from Openreach. Unless you've had cable installed, Openreach is responsible for maintaining all the lines (except cable) from the local exchanges to individual homes, businesses, schools etc.

Q17 Why should I let you in?

If our engineers need access to your premises it’s to fix or install a line or to do maintenance work. They’re not trying to sell you anything, they are simply carrying out a service on behalf of your Communications Provider. All our engineers carry ID cards, and there is a number on the back that you can call if you are concerned.

Q18 The engineer who came to my house has got BT on his van (and his clothes) but says he is from Openreach.

The business has only been in existence since January this year, and the uniforms and vans are being rolled out gradually because we have so many to replace. After all, we've got 22,000 vans and 25,000 engineers!

Q19 I'm sure my telephone bill was wrong last month. Can you sort it out for me?

Sorry, no. Your Communications Provider is the one who sends you your bill. You will have to talk to them to sort out any problems.

Q20 Is Openreach trying to sell me something?

No. It's our job to make sure that the connection from here to your provider's network is working. They pay us to do it − you don't. In fact, our engineers can't give you advice about the suitability of any products or services because it would be unfair for them to recommend the products of one of our customers over another. We have to be fair to all of them and give them an equal chance of getting your business! For completely impartial advice you can get in touch with Ofcom, the regulatory body that oversees the telecoms industry. Here are some links – this first one is to Ofcom’s web site, giving advice to end users about telephone services

http://www.ofcom.org.uk/advice/ofw165/

This next one gives access to Uswitch, a price comparison web site:

http://www.ofcom.org.uk/telecoms/ioi/orp/comparative_20031214/

Q21 Can consumers and businesses buy directly from Openreach?

Our products are the “building blocks” which Communications Providers use to create their own services. We sell our products to Communications Providers, which are companies which onward sell telephony and internet services (as opposed to consuming them themselves). Communications Providers include, for example, Internet Service Providers, as well as other parts of BT.

3. Openreach - Roles and Assets

Q22 How many people, vans etc will Openreach have?

Openreach will have approximately 30,000 people. Of these, 25,000 will be engineers. These people came almost equally from BT Wholesale and BT Retail. Openreach has more than 22,000 vans (out of BT’s total of 32,000 vans).

Q23 What assets and revenues will it have?

It will have assets of roughly £8 billion and its revenues will be in the region of £4 billion a year.

Q24 When will Openreach be operational from?

Openreach will become operational during January 2006.

Q25 Will Openreach have its own Board and a Chairman?

No.

Q26 Is Openreach part of BT?

Yes. It will, however, be operationally distinct from the rest of BT with a high level of independence. Openreach will treat all Communications Providers equally – and be seen to do so. Its name is also distinct.

Q27 Will Steve report to Ben? Won’t that affect his neutrality?

Steve will report to Ben, but this won’t affect Steve’s commitment to treat all Communications Providers equally. Like every Openreach employee, his remuneration package will be based on Openreach rather than BT objectives. The performance of Openreach against the Undertakings will also be monitored by the EAB.

Q28 Will Openreach be able to sell other wholesale products to its customers to avoid them having to buy services from two parts of BT?

Generally not. However, where a customer needs its purchase of non-Openreach BT services co-ordinated with the supply of Openreach products, or if it buys its BT products predominantly from Openreach and would find a single point of contact more convenient to purchase low volumes of non-Openreach products, then Openreach will show flexibility. But its primary role is to sell its portfolio of products rather than that of BT Group’s.

Q29 Will BT Wholesale be able to sell Openreach products to its customers to avoid them having to buy services from two parts of BT?

Yes, BTW will be able to provide its customers with both Openreach and BTW products in certain circumstances. The terms under which Openreach products are sold will be the same irrespective of where in the BT Group the customer chooses to buy them from.

Q30 How much will it cost to set up Openreach?

Several millions of pounds to cover systems, training, new identity etc.

Q31 Will Openreach have its own capital budget and have autonomy over the investments it makes?

Openreach will have an annual operating plan which it will agree with the BT Group CEO. The CEO of Openreach will have delegated authority from the BT Group plc Board to authorise capital expenditure up to a certain limit within that annual operating plan.

4. Openreach - New Identity

Q32 Will the words BT appear on Openreach’s vans or on the engineers’ uniforms?

Openreach vans and uniforms will carry the new identity. This will include an endorsement stating that Openreach is ‘a BT Group business’.

Q33 The globe is still prominent, so how can Openreach be viewed as distinct from BT?

The endorsement ‘a BT Group business’ and the BT corporate mark always appear in conjunction with the Openreach word mark. This is so people understand how Openreach relates to BT. It is also so end-users (consumers and businesses) are reassured that they can allow Openreach engineers into their homes and office premises. Openreach is a new and distinct line of business, but it is still part of BT.

Q34 The name is very similar to an old division at BT. Has BT pulled the wool over the regulator's eyes?

The ‘open’ in the Openreach name is about having a new, more open way of working and being open to all Communications Providers. This new name was very well received in focus groups. This has nothing to do with the former ISP BT Openworld.

Q35 How much did BT spend on developing this new identity?

We are not disclosing the amount we spent on this project; however it was not significant by comparison with typical corporate identity budgets. Less than you’d think too because we will be rebadging the vans and uniforms over several years, during which time much of the fleet and most of the uniforms would have had to be replaced anyway.

Q36 Is this a new brand or a new logo? Why do you refuse to use those words?

The Openreach logo is just the word ‘Openreach’ in purple – it’s a word mark. It always appears with the BT endorsement. Openreach itself isn’t a completely different brand – it uses BT colours and is based on the same values of trust and helpfulness as the rest of BT.

Q37 Who chose the new name and look? Did Ofcom have the power of veto?

The new name and look were created by BT Group Marketing & Brand in consultation with Ofcom.

Q38 Will you be doing advertising to let people know it exists?

Yes. We are planning a range of promotional activities as well as an advertising campaign.

Q39 When will marketing / advertising begin for Openreach?

In January 2006 when Openreach becomes operational.

Q40 Will other companies – who rely on Openreach engineers – be asked to contribute to any awareness campaign so their customers know to let the engineers in? Either in terms of funding that campaign or using their own marketing to alert customers?

Yes. We will be working in tandem with Communications Providers during all of this activity to ensure a co-ordinated approach to the public and with this in mind, we set up an industry forum specifically for this purpose which met for the first time in October.

Q41 Will all BT vans change or will there still be BT Globe vans (i.e. for BTW). What is the split of the fleet?

Of the 32,000 vehicles in BT's fleet, more than 22,000 will carry the new Openreach design with the remaining 10,000 staying as the BT “connected world” livery. The re-livery of the Openreach fleet does not involve any paint re-spraying. The existing white BT body colour is being retained right across the fleet.
Following existing, tried-and-tested practice, the Openreach identity will be applied to each vehicle as a self-adhesive vinyl, either at the point of supply to BT, or by our own workshops at a convenient in-life
service visit.

5. Openreach - Remuneration

Q42 Will Openreach’s employees still be part of BT’s pension scheme?

Yes.

Q43 Will you need to consult the unions for changing the terms for 30,000 people?

No because people's terms and conditions are not changing. It is their incentive schemes which will change. The unions have been fully briefed and consulted.

Q44 Will Openreach employees still be eligible to receive free BT shares, as they have done in previous years, if BT achieves its performance targets?

Yes. They will.

Q45 Will the Chief Executive and senior managers within Openreach have their bonuses based on any BT Group targets?

No. Any performance-based remuneration for Openreach people will be based on performance against Openreach objectives only.

Q46 How will you convince a BT engineer, who has worked at BT for many years, that he/she should now adopt a different culture?

A Code of Practice sets out what Openreach people have to do to ensure compliance with the formal Undertakings. This is only one part of a wider culture change and training programme within Openreach, which includes training and guidance aimed specifically at the Openreach engineering community.

6. Openreach - Financials

Q47 How do your revenues of more than £4 billion break down?

Openreach will sell LLU and WLR to both BT divisions and external businesses. Clearly a large proportion of this is sales of WLR to BT Retail.

Q48 What assets make up the £8 billion?

This includes copper, fibre and other non-electronic assets contained within the access and backhaul networks.

Q49 Will Openreach be reported separately for Q4 2005/6?

Openreach will be reported as a separate division, but this is unlikely to be done before the financial year 2006/7.

Q50 What will the profit / EBITDA be for Openreach?

(Haven’t Ofcom said what this should be?)
While there will be a small overhead for maintaining an organisationally separate entity, we would also expect some synergies from the combination of BT Retail and BT Wholesale’s engineering forces. There is no predetermined EBITDA which Ofcom expects Openreach to meet.

7. Equity of Access Board - Role and Composition

Q51 What is the role of the Equality of Access Board (EAB)?

The EAB will provide transparent and objective monitoring of BT’s compliance with the Undertakings given to Ofcom, reporting and advising BT on its compliance. It is important for BT, Ofcom and the UK telecoms industry that the agreed Undertakings are implemented fully and successfully. It is the EAB’s role to monitor this performance against the Undertakings, but the EAB is not responsible for executing it – that is down to BT and Openreach. The EAB is NOT the management board of Openreach; neither does it have the role to act as the supervisory board of Openreach.

Q52 What will the EAB monitor? If it is to oversee SMP products in BT Wholesale why don’t these products sit within Openreach?

EAB will monitor compliance with the Undertakings across the whole of BT, with a particular focus on the provision of products on an Equivalence of Input basis and the operation of Openreach. To do this it will monitor the relevant product/service KPIs as well as BT’s behavioural performance against the Undertakings.

Openreach is designed so regulation can be focused on BT’s access and backhaul products. This stringent treatment is not appropriate for the SMP products remaining in BT Wholesale, where the need for regulation may be shorter-lived.

Q53 What will be the makeup of the Equality of Access Board (EAB)? 

The EAB is chaired by Carl Symon, a non-executive director of BT Group plc. The other members of the EAB are Sally Davis (BT chief portfolio officer) and Sir Bryan Carsberg, Stephen Pettit and Dr Peter Radley, who are the three independent non-executive members.

Q54 Will the chairmanship of the EAB rotate or will Carl be the permanent chairman?

The Undertakings require the Chairman of the EAB to be a BT Group plc non-executive director. Carl Symon is the first Chairman.

Q55 Does Ofcom have a say in the makeup of the EAB?

The composition of the EAB is set by the Undertakings. Ofcom was consulted as required by the Undertakings with regard to the three independent members.

Q56 How often will the EAB meet?

The Undertakings require it to meet between six and 10 times in its first year of operation. We certainly anticipate the number of meetings to be at the upper end of that range.

Q57 How much will the EAB members be paid? Will this be set out in the BT Annual Report?

Carl Symon is being paid £50,000 a year as the EAB Chairman. As he is a non-executive director of BT Group plc this information is public knowledge and will be disclosed in the BT Group plc annual report. Sally Davis is not receiving any additional remuneration for being on the EAB. The fees of the independent members are a private, contractual matter between them and BT. They do not have to be disclosed in the BT Group plc annual report or anywhere else.

Q58 How many days a year will EAB members work?

The issues to be considered by the EAB are complex, so a significant degree of preparation, research and pre-reading will be necessary in addition to attending each EAB meeting. We are expecting that the independent members will need to devote around 20 working days a year (maybe 25 to 30 in the first year while they become acquainted with the work of the EAB). As Chairman, Carl Symon will devote more time than this.

Q59 Where will the EAB meetings be held? Will they be in a BT building?

The EAB is a committee of the BT Group plc Board, therefore, it is appropriate that its meetings are in a BT building.

Q60 When will the EAB be functional?

The Undertakings required the EAB to be functional by 22nd March 2006. However, BT set up the EAB on 1 November 2005 to allow it to start monitoring BT’s compliance with the Undertakings in parallel with the company making the organisational and other changes required by the Undertakings. This early set up of the EAB (some four and a half months ahead of schedule) is also in line with efforts elsewhere in BT to deliver ahead of schedule in other areas of the Undertakings. The first meeting of the EAB was on 3 November 2005.

Q61 When will the Code of Practice be published and is this Code the responsibility of the EAO?

The Undertakings require BT to publish the Code of Practice within four months of the Undertakings being agreed (i.e. by 22 January 2006). BT published the Code at the beginning of December 2005, well ahead of this deadline. The Code is the responsibility of BT, not the Equality of Access Office or EAB. Under the Undertakings, the EAB must review the content of the Code and, as the EAB has been set up before the Code has been published, the opportunity has been taken for it to carry out that review ahead of the Code’s publication.

Q62 Will the EAB have regular liaison with industry both before it is established and once it is functional? If not, why not? Isn’t it the case the EAB needs to fully understand the concerns of the wider industry? 

One of the Undertakings requires the EAB, once formed, to define its strategy for engagement with representatives of industry in order to understand their issues and concerns. This will be considered by the EAB at one of its early meetings. It would be inappropriate to pre-judge the outcome of the EAB’s deliberations. However, regardless of the EAB’s decision, it is first and foremost the role of the part of BT serving the customer to understand the concerns of the customer.

Q63 Will the EAB produce regular reports or will it also investigate specific cases? How will the whole reporting process be driven?

Both. It will produce regular reports and may commission specific investigations into certain matters.

The reporting process will be driven by a set of KPIs, having taken the views of Ofcom, industry and BT’s operational units into account.

Q64 How often will the EAB report on the performance of BTW and Openreach? If it’s purely an annual report, doesn’t this fly in the face of the transparency we’ve been promised?

The EAB will review performance against the Undertakings in each of its meetings and the minutes of these will be sent to Ofcom. It will also report regularly to the BT Group plc Board. However, the EAB is only required by the Undertakings to report annually to Ofcom on BT’s compliance with the Undertakings and to publish a summary report annually. It is BT that is required by the Undertakings to publish its performance against the KPIs relevant to the Undertakings on a quarterly basis.

Q65 Will BT issue the findings of the EAB? If so, isn’t that a conflict of interest?

There is no requirement on either BT or the EAB to publish the EAB’s findings. What will be published, and when, is still being considered.

Q66 Will EAB reports be made available to the media? If not, why not? Isn’t the new approach about transparency and BT meeting the spirit, not just the letter, of the agreement?

The EAB annual report will be made available to everyone.

Q67 Will the media be allowed to speak to members of the EAB? If so, who do they arrange this through?

With the exception of Carl Symon, no. Contacts with the media will be handled via the Equality of Access Office and the BT Press Office.

Q68 If the EAB only meets a few times a year, who will actually do the investigating?

The Equality of Access Office will do the detailed investigative work and then report their findings to the EAB.

Q69 What is the role of the Equality of Access Office?

The Equality of Access Office will provide the necessary information and reports to allow the EAB to perform its role effectively. It will also perform specific functions such as the handling of customer complaints relating to the Undertakings.

Q70 How many people will work in the Equality of Access Office? Will these people all be BT staff or will there be some independent people as well?

Until the exact workload is known, it is difficult to define the exact number, though the initial expectation will be around a dozen. All the staff will be BT employees. Some members of the EAO will be recruited externally; indeed, Simon Milner has been recruited from outside BT as the EAO’s Head of External Relations and Communications. The Equality of Access Office has its own Code of Conduct to ensure objectivity and impartiality.

8. Equality of Access Board - Complaints

Q71 Can you explain how the industry can complain about alleged Openreach wrongdoings?

The industry should take issues regarding Openreach to Openreach itself in the first instance. If it feels that Openreach has not dealt fairly and adequately with its complaint and the complaint involves a possible breach of an Undertaking, then it can escalate the complaint to the EAO who will review the situation, report its decision to the EAB and, once the EAB has responded, the EAO will let the complainant know what action, if any, has been taken.

Q72 Will the EAB be the first resort for companies who have a complaint against a part of BT?

No. The first resort should be with the part of BT against which it has the complaint.

Q73 If the EAB finds BT “guilty” will companies then have the ability to claim damages from BT or will they have to go to court?

If BT breaches the Undertakings, a third party has the right to seek damages in the courts.

Q74 If companies go to court on the basis that the EAB have found BT in breach of its undertakings will the EAB ruling have any legal status?

No, a court will not be bound by the EAB’s decision. However, a court may take into account an EAB decision that BT is in breach of the Undertakings. But if the alleged breach is disputed it will be for the court to make its own decision on whether there has been a breach.

Q75 If an EAB ruling has no legal status, isn’t this all a bit of a charade?

No, because a court may take account of an EAB decision in reaching its own decision. The Undertakings also provide for the EAB to be able to suggest remedial action to BT to ensure compliance with the Undertakings, of which BT must take due account. BT must tell the EAB what it has done in relation to any suggested remedial action and the EAB has the right to comment to BT on the action BT has taken, its appropriateness in ensuring compliance and to suggest further remedial action if necessary. The EAB therefore has its own tools to remedy non-compliance. The reason the EAB Chairman is a non-executive director of BT Group plc is to ensure that the EAB is in a position to influence BT and to ensure that BT takes proper account of the EAB’s recommendations.

Q76 If the EAB find BT “not guilty” will companies have a right of appeal either to the EAB, Ofcom or the courts?

If a Communications Provider believes that BT has breached any of the Undertakings, it always has the right to take the matter to Ofcom and/or bring legal proceedings against BT, whatever the outcome of any complaint to the EAB, and whether or not the EAB has been involved.