Issued March 24, 2011
We welcome the review. Ofcom has acknowledged that both the NTS Retail Uplift and PRS Bad Debt Surcharge retentions need to be increased. This is helpful as we are currently under recovering costs in both of these areas.
We are broadly in agreement with the analysis supporting Ofcom’s proposals for the NTS Retail Uplift. However, there are a few adjustments that we believe have been made inappropriately. These have reduced the proposed value of X (see section 2).
We are pleased to see that BDO has concluded that our PRS bad debt methodology is reasonable and that our billing processes are in line with industry best practice. BDO’s analysis has also independently validated our PRS Bad Debt Surcharge rate of 5.2%, confirming that our revised data methodology is robust (see section 3).
We agree with Ofcom that we should be able to recover our efficiently incurred costs relating to the PRS Bad Debt Surcharge. We discuss the wider impact on the telecoms market in section 4.
The current charge control expired in September 2009. We are therefore keen that this new 2.5 year control is implemented as soon as possible (see section 5). We believe that outcome of Ofcom’s current Non Geographic Calls Services Review (NGCS Review) will ensure that there will be no need to continue this control beyond September 2013.1
We agree with Ofcom’s preferred approach to compliance reporting. The proposals on regulatory reporting are set out in more detail in the Regulatory Reporting consultation2 and we will respond separately to that consultation (see section 6).
BT welcomes comments on the content of this document. Comments can be addressed via e-mail to Nicola Robbins at the following address: firstname.lastname@example.org