BT's response to Ofcom's consultation Regulation of Business Retail Markets


BT's response to Ofcom's consultation Regulation of Business Retail Markets

Issued November 16, 2005

Executive Summary

  • BT welcomes the consultation and its intent to seek to reduce regulation from particular retail services.

  • BT supports Ofcom's proposals to permit BT to consent to BT departing from its published prices where services are replicable. Such prices should be subject to BT's internal compliance measures and competition law and need not be notified to Ofcom.

  • Business inland calls and exchange lines should be considered replicable for both bespoke pricing as well as bundling. Such service bundles which fail an implicit-price cost test should not be presumed to be unduly discriminatory.

  • However, BT is concerned with the proposal that the price floor for bespoke prices should be based on fully allocated costs. Instead BT suggests that the more appropriate price floor in this regulatory context should be based on the long run incremental costs.

  • The threshold associated with bespoke prices being offered should be for those spending £1m per annum on all telecommunications, not just with BT.

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BT would welcome any comments on the contents of this document which should be addressed to Teresa Wright  by e-mail to teresa.wright@bt.com .