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BT's response to Ofcom's consultation document - Number Translation Services Retail Uplift charge control and Premium Rate Services bad debt surcharge

Summary

BT considers that the competitive environment for NTS calls has changed significantly since the existing NTS regulatory regime and "formula" were put in place.
The Ofcom 'NTS Framework Re-examination' is therefore welcomed, but BT considers that it is inappropriate that Ofcom should have consulted on the NTS retail uplift charge and allied charge control mechanisms in advance of the broader review.
BT believes that the time is right for certain calls, presently deemed as NTS, to return to a geographic call price control model with appropriate margins for the originating operator.
Such a move would be seen by BT as overcoming inconsistencies in the present regulatory regimes being operated by Ofcom on different parts of BT's business.
For those calls that should rightly continue to be regarded as NTS, BT supports the continuance of the present regime, provided that the parameters used in calculating the NTS retail uplift and charge control are based on reasonable assumptions and result in a fair assessment of the costs allowable for recovery.
BT also considers that the NTS call volume forecasts used by Ofcom are not reflective of latest historic trends or actual effects operating within the market. Any price cap should certainly reflect the uncertainties which surround future volumes.
BT also considers that Ofcom's approach to cost causation is flawed and leads to excessive cost exclusions from BT's legitimate cost base.

Please note that certain confidential information that BT considers to be commercially sensitive has been removed from the document.

BT would welcome comments on this response. Comments should be addressed to Barry Aspinall by email: barry.aspinall@bt.com.