Home > BT Group > Regulatory and public affairs > Consultative responses > Ofcom > 2006 > Broadband migrations

Broadband migrations: enabling consumer choice

Issued October 6, 2006

Executive Summary

Broadband is an essential enabler in 21st Century life, leisure and work, and it is welcome that Ofcom has initiated this analysis into the critical broadband issues impacting consumers.
As acknowledged in the Consultation Document, in the majority of cases, MAC-based migrations do work well and offer a good customer experience. In principle, BT supports Ofcom's proposal to introduce a new General Condition to mandate the use of the MAC process by all Service Providers offering DSL and SMPF services.
The scope of this Consultation covers both the mandating of the MAC process as well as operational issues such as Tag on the Line and Home Movers. BT has been working with its wholesale customers for many months to address the Tag and Home Movers process and systems issues. However, we recognise that progress has been slower than we would have liked and that the solutions identified to date have only had a limited impact.
BT, in common with its wholesale Service Provider customers, views these operational issues as critically important consumer issues that require the highest levels of focus and commitment if they are to be resolved to the satisfaction of end users. Consequently, BT Wholesale has committed to stepping up the effort in this area.
BT has agreed with a number of major broadband Service Providers to lead workstreams that will resolve the outstanding issues. BT is setting up an initial workshop within the next two weeks to rejuvenate this process, which will be led at Director level with direct involvement from BT Wholesale's CEO.
In light of the above, we believe that the definition of migrations and scope of the proposed General Condition should focus, at this stage, only on the mandating of the MAC process - regulatory intervention to solve the other operational issues is currently not appropriate.
BT has enormous sympathy with customers who are extremely frustrated when they cannot obtain a MAC from their broadband Service Provider when they wish to transfer service. Processes aimed at minimising consumer impact as a result of this are very important but the answer is not to mandate the provision of MAC codes by the wholesale broadband Service Provider. BT is convinced that alternative solutions will be possible and we see this as a key output of the focused workstreams outlined above.
Given the highly competitive nature of the broadband industry, the withdrawal or closure of broadband Service Providers from the market as a consequence of debt related issues is inevitable. However, this specific issue should not drive the migrations process debate. BT sees the development of new and innovative ways of minimising the cost and impact for all parties to be part of the forthcoming BT Wholesale-led industry discussions.
BT agrees that all services should be subject to similar rules governing promotion, sales and transfer processes. To ensure consistency in terms of customer experience we suggest that the mandatory guidelines under General Condition 14.3 for narrowband services should be updated to include broadband migrations.
Ofcom is right to seek further analysis before advocating a Third Party Verification and/or Validation solution – the added complexity and cost to industry (and ultimately cost and potential delays to consumers) would appear to render this option unacceptable for all parties involved.

BT would welcome any comments on the contents of this document. Comments should be addressed to Katherine Roche by email to katherine.roche@bt.com