BT's response to Ofcom's consultation on "Proposals regarding the requirement on BT and Kingston to provide payphone access"

BT's response to Ofcom's consultation on "Proposals regarding the requirement on BT and Kingston to provide payphone access"

EXECUTIVE SUMMARY

BT is very supportive of Ofcom's policy to reduce unnecessary regulatory intervention.  The proposed discontinuation of Condition 48, with respect to payphone access, is a positive step in this direction that will in no way threaten consumers' access to Indirect Access Service Providers' (IASPs') services from payphones.

BT's views on the consultation document are as follows:

• BT's payphone operations are experiencing an ongoing decline in use and in revenues.  As a direct result, all services that generate incremental traffic and revenue streams are commercially attractive to BT.  Payphone access, with the associated Payphone Access Charge (PAC) remains a commercially vital part of BT's payphone business;

• BT agrees that payphone access remains an important service for consumers, for the IASPs that use it and for BT's own commercial wellbeing;

• Payphone access is, therefore, a service that BT will certainly continue to provide for the foreseeable future.  BT is happy to provide undertakings to Ofcom to that effect.  BT notes Kingston Communications' similar response to Ofcom, which presumably reflects similar commercial dynamics;

• BT is also willing to continue to offer the BT Payphone Access Levy Collection service, providing outsourced billing, collection and distribution services for PAC to other payphone operators that use the BT telecommunications network.  Third party payphone operators are currently restructuring their contractual arrangements with each other and with BT and BT continues to work with the relevant payphone operators to ensure continued PAC collection, where this is required; and

• BT therefore supports Ofcom's selection of 'option 2' and believes that Ofcom's existing powers offer an adequate back-stop protection, in the event of significant future market failure.

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