ICSTIS revising the code of practice

BT's response to ICSTIS consultation "Revising the Code of Practice"

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Introduction

BT welcomes the opportunity to comment on ICSTIS proposals for the revision of the Code of Practice to take account of the implications of the Communications Bill.  Whilst BT recognises the practicalities associated with the need for Service Providers to fund the premium rate regulatory regime, BT is concerned that, contrary to the comments made by ICSTIS within the consultation, the approach detailed does have a material effect on the costs of collection.  It places a significant level of administrative burden and cost on ECNPs in undertaking what is effectively a revenue collection service for ICSTIS.  It would be improper for ECNPs to undertake this work without recompense and yet this element appears to have been overlooked within the consultation.  As an ECNP, BT will need to undertake changes to its billing system and also to all associated contracts; the cost of this work is significant and cannot be absorbed by ECNPs.  BT, therefore, requests that an allowance for these costs is made within ICSTIS's annual forecasting process, and that this amount is deducted by ECNPs before remitting the balance owed to ICSTIS.   BT believes that it would be appropriate for these costs to be borne equally between SPs and ICSTIS.  It is also vital that ECNPs are indemnified by ICSTIS in respect of any potential liability to SPs incurred by ECNPs in acting on the instructions of ICSTIS.

Given that this consultation concerns the ICSTIS Code of Practice, BT has taken the opportunity to highlight within this response the practical issues associated with management of the 118 directory services via the current combination of the PRS Code of Practice and the DQ Guidelines. BT would welcome the development of a separate CoP for DQ services and an associated consultation within the next six months and commits to helping ICSTIS achieve this.

BT would welcome further discussion on the contents of this paper with interested parties. In the first instance comments, questions, requests for further details or points of clarification should be emailed to: liz.ea.williams@bt.com