When ex ante price regulation based on a measure of ‘fair and reasonable’ is imposed on any communication provider, it is preferable that both the operator and its customers can refer to an authoritative source for what the term means in practice. For that reason alone, BT will welcome the publication of Ofcom’s proposed guidance.
On the guidance itself, BT has no substantive comment to make. BT has long argued that voice call termination should be priced at cost and not be used to subsidise other services, and we are pleased to see this principle being applied here. In any case, once the benchmark, regulated mobile termination rate reaches appropriately cost-based levels (as we expect from Ofcom’s current proposals in the market review), mobile voice call termination will cease to be a potential source of such subsidy.
However, we would like to draw attention to two areas for which, we believe, the guidance will have implications.
BT welcomes comments, which should be sent by email to firstname.lastname@example.org