Ebbsfleet

Ebbsfleet Fibre to the Home Pilot

Issued July 10, 2008

Question 1: Do you agree with Ofcom’s proposal to consent to BT’s request for permission under Universal Service Condition 1 to charge non-uniform prices for the Ebbsfleet FTTP Pilot?

BT supports and welcomes Ofcom’s proposal and its pragmatism in recognising the need for tariff flexibility during the initial roll-out of Fibre to the Premises at the Ebbsfleet Greenfield site. Deploying NGA, as with the provision of new services on legacy networks, requires a level of trialling and testing that is part of the normal business process of a competent Communications Provider. This request allows BT to trial services (and to price those services accordingly) at the Ebbsfleet pilot site to ensure customer confidence in the delivery of communication services over new technology.

Question 2: Do you have any comments about the proposed wording of the draft consent specified in the schedule to Annex 6?

No. The draft consent is satisfactory for the needs of the Ebbsfleet service roll-out.

Question 3: Do you have any comments on Ofcom’s impact assessment for the proposed consent as set out in Annex 5?

BT agrees with Ofcom’s assessment that the requested consent, once granted, has minimal impact on competition and that refusal has potential to negatively impact consumers in relation to Next Generation Access and services.

Question 4: Do you have any other comments?

BT agrees with Ofcom that the granting of the requested consent does not undermine the overall effectiveness of BT’s Universal Service obligations. Indeed it will encourage innovation and investment in Next Generation Access which is in line with Ofcom’s policy objectives.

However, BT believes that the overall process for gaining consents is bureaucratic and unwieldy. We believe that the need for Ofcom to consult in such a way on each minor variation from Uniform Pricing is out of step with the underlying objective of the USO. Local variations in BT’s pricing are neither detrimental to customers nor anti-competitive as long as the overall principles of Universal Service continue to apply where necessary.

A more flexible approach from Ofcom is required going forward and we believe this is possible within the existing UK legislative and regulatory framework. BT welcomes the opportunity to discuss this matter further with Ofcom with a view to putting such arrangements in place.

BT welcomes comments on the content of this document. Comments should be addressed to Jeremy Benson by email at jeremy.benson@bt.com.

You can download this document as a PDF file