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Leased Lines
Disaggregated Markets: Leased Lines
Issued June 8, 2006
BT appreciates the considerable effort and resource which Ofcom has put into understanding the variability of competition across the UK. This work has already contributed significantly to understanding of how competition is dispersed by region.
Ofcoms work to date results in the clear conclusion that there is significant variation in competitive conditions on the markets for high bandwidth TISBO services, wholesale AISBO services and Trunk services. The preliminary conclusions that can be inferred from the analysis presented are that in certain business locations BT is a minority supplier and in many others is unlikely to be in a dominant position.
Despite the above however, BT has some reservations about the analytical methodologies which Ofcom has utilised. The maps do not always reflect the depth on competition in some areas. While this is sometimes due to limitations in the available data, in other cases it reflects assumptions made by Ofcom which BT suggests should be revised. This is addressed in BTs detailed answers. BT is of the view that if the analysis were revised along these lines then the picture of competition in certain geographic areas would be even more apparent.
Where there is an extensive degree of competition it is proportionate to vary remedies on BT. Whilst BT welcomes the recognition by Ofcom that remedies should be varied in the more competitive areas for high bandwidth TISBO services and AISBO services, BT believes that it would be proportionate to take further steps than those outlined in Ofcoms discussion document.
In relation to Trunk services, BT would suggest that the existence of competing network infrastructure along with Openreachs obligations with respect to Equivalence of Input and in backhaul services make the market for core services effectively competitive. We therefore urge Ofcom to revisit this area and identify some relaxation of regulation for Trunk segments, a development which would bring the UK regime into closer alignment with that in many other Member States.
Download BT's response as a PDF document
BT would welcome any comments on the contents of this document which should be addressed to Richard Budd by e-mail to richard.budd@bt.com.
