Requests from BT for Specified exemptions and agreements to its Undertakings under the Enterprise Act 2002: Part 2


Requests from BT for Specified exemptions and agreements to its Undertakings under the Enterprise Act 2002: Part 2

Issued November 15, 2006

Executive Summary

  • BT agrees with Ofcom that the exemption and agreement requests upon which Ofcom is consulting arise from the operation of mechanisms and provisions envisaged when the Undertakings were agreed on 22 September 2005.

  • BT shares, and supports, Ofcom's view that the requests if agreed would not 'materially affect the comprehensive solution that the Undertakings represent.”

  • BT notes that Ofcom does not view the requests as having a material impact on the Undertakings in terms of Section 155 of the Enterprise Act 2002 but has decided to seek stakeholders' views.

  • In preparing its requests BT has adopted the starting point, consistent with its commitments to and in the Undertakings, of seeking EOI solutions. This is reflected by the fact that in almost all cases and respects the requests lead to an EOI solution.

  • While the requests, if agreed with Ofcom, are not seen as 'material', delivery of the end solutions proposed will require significant effort across the BT Group, and in particular for Openreach, in addition to the product activities already specified in the Undertakings. BT is committed to delivering the solutions detailed in our requests.

  • BT is very pleased that Ofcom is proposing to agree nine of the thirteen requests.

  • BT notes that Ofcom is adopting a neutral stance at this stage with respect to the four requests relating to fibre-based inputs from Openreach. However we remain of the view that the solutions proposed in our requests are appropriate, achievable and pragmatic in the circumstances.

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BT welcomes any comments on the contents of this document. Comments should be addressed to Graham Lamb via email to graham.hp.lamb@bt.com.