CPS local calls option

BT's Response to Ofcom's Consultation Document - Review Addressing The Local Call Disadvantage: A CPS Local Calls Option

This paper comprises BT's formal response (dated  July 5, 2004) to Ofcom's consultation document published on June 4,  2004.

Executive summary

In May 2004, BT announced its intention to develop the existing Carrier PreSelection (CPS) product in order to address certain aspects of the CPS interconnect regime.  This response document provides both comment on Ofcom's consultation as to how this CPS product development should be implemented and further detail as to BT's current intentions in this regard.

BT agrees with Ofcom's assessment that its third proposed option, that of a CPS Local Calls product, is an appropriate response to the identified CPS interconnection issues.  BT therefore intends to enhance the CPS product in order to retain CPS calls on its own network, where those calls remain on a single Digital Local Exchange (DLE), or pass between adjacent, connected DLEs.  BT remains in negotiation with its suppliers on the cost and timescales for delivery of this product.  There is substantial complexity involved in achieving Ofcom's current proposals and whilst BT is seeking rapid delivery, it is looking increasingly challenging to meet Ofcom's aspirational end-of-year timeframe;

Ofcom has proposed two additional CPS Subscriber Options, to ensure certain functionality in the new BT CPS product.  However, BT does not believe that network traffic routing is a subscriber issue.  Consequently, BT has identified an alternative approach, using routing options within CPS Subscriber Option 3 (all-calls), that would achieve the same objectives, but with reduced development cost.  BT proposes using this alternative approach, which would also not require the associated changes to the CPS Functional Specification;

BT agrees with Ofcom's proposal that the new CPS product should be directly available, at a specific DLE, only to those CPSOs that have a direct interconnect route at that DLE.  The direct interconnect route must be configured to carry CPS traffic.  BT will also enable the resale of the new CPS product at a given DLE by CPS Operators (CPSOs) with connections to that DLE;

BT is currently enhancing its Network Information Publication Principles (NIPP) and Element Based Charging (EBC) data files to include connections between DLEs, which have not previously been relevant to network interconnection.  BT is aiming to make this data available prior to the launch of the new CPS product;

BT will provide billing Call Detail Records (CDRs) to relevant CPSOs, using the same format and timescales as are already used for the Wholesale Access product;

BT currently intends, subject to this consultation and the Product Management, Policy and Planning (PPP) consultation, to price the new CPS product as follows:
Own-DLE Calls = (1xPPP) + (1xLECO) + (1xLECT stick)
DLE-DLE Calls = (1xPPP) + (1xLECO) + (1xLECT) + (1xLLC stick)

The timeline for implementation of the new CPS product is not yet clear.  However, BT has committed to offering an adjustment to CPS charges that will place CPSOs on an equivalent cost base to BT's own operations.  This interim charging adjustment will apply from 1st July 2004 and will cover the difference between what BT invoices CPSOs currently and what they would be invoiced if the new CPS product were in place.  This charging adjustment will also include the costs incurred by CPSOs within their own networks, using BT's published network costs as a proxy.  The interim charging adjustment will cease at a given DLE, once the new CPS product is enabled at that DLE.  Subject to the outcome of this consultation and the PPP consultation, BT currently intends to price the interim charging adjustment as follows:
Own-DLE Calls = (1xPPP) + (1xDLE processor) + (1xLTC) + (1xLTC stick)
DLE-DLE Calls = (1xPPP) + (1xLTC) + (1xLTC stick) - (1xLLC stick)

BT does not believe that there is a feasible technical solution that would provide a similar 'local calls' product for IA calls.  Instead, BT proposes that CPSOs migrate their existing IA customers to a CPS product, if they so wish.  However, BT is deeply concerned at the levels of customer mis-selling that forced customer migrations have previously generated.  CPSOs need no help from BT to undertake customer migrations from IA to CPS services and BT does not believe that it needs to implement any new processes to enable this.  BT wishes, however, to see such migrations take place on an 'opt-in' basis, whereby customers are given a specific opportunity to make a choice as to their telecommunications supplier, particularly in a market where there can be multiple existing communications suppliers using a single customer line.  BT is not willing to support processes that remove this customer choice, or undermine customers' existing multiple-supplier arrangements, but intends to work with CPSOs to explore suitable processes;

BT has ongoing concerns about the scalability of its existing STP platform and is reticent about further signalling investments in a PSTN that is shortly to be shut down.  However, BT will reopen discussions with those CPSOs that remain interested in further STP availability;

BT intends to treat traffic using the new CPS product as being DLE-terminated, for the purpose of the Reciprocity Agreement, which calculates other communications providers' geographic call termination charges.  To do otherwise would increase these charges, which would run counter to Ofcom's intended impact on retail markets.

Download response as PDF document

BT would welcome comments on this response. Comment should be addressed to Colin Annette at: colin.annette@bt.com