General conditions of entitlement

BT comments on Oftel's "The general conditions of entitlement"  Sep 2002

Download full response in PDF format.

Introduction

1.  The general conditions of entitlement give effect to the General Authorisation, one of the key building blocks of the new regulatory framework which will come into force in all Member States on 25th July 2003. BT agrees with the broad approach Oftel has taken in drafting the proposed general conditions set out in this consultation document, including the emphasis on appropriate regulation. Most of the conditions are shorter and clearer than those in current licences, and many existing obligations which have no place under the new Directives have been swept away.

2.  Nevertheless, there are a considerable number of detailed comments BT would like to make on the content of the conditions. These range from suggestions for clearer wording and requests for clarification through to expressions of concern over the practicability of Oftel's proposals or, in some cases, their consistency with the Directives.

3.  Under the new Directives, National Regulatory Authorities ("NRAs") will have a duty to co-operate "with each other and the Commission in a transparent manner to ensure the development of consistent regulatory practice and the consistent application of [the Framework Directive] and the Specific Directives" . In view of this, we believe it is essential that Oftel monitor the development of general conditions across the EU and take appropriate action - including revisions to the UK conditions where necessary - if material discrepancies between Member States become apparent.

BT welcomes comments on this submission which should be addressed to:

Mike Fox
Senior Regulatory Strategy Analyst
PP 5th floor Dowgate Hill House, Dowgate Hill, London EC4R 2SU
Tel:  020 7728 4099
Fax: 020 7236 3457
mike.p.fox@bt.com