BT agrees with Oftel that the USO conditions and ex post regulation are a proportionate response to securing end-to-end connectivity. We agree with Oftel that an additional condition requiring BT to buy call termination from other network providers is unnecessary and that there has been no evidence to suggest that such a
condition is required.
We are of the opinion that a shortcoming of the Guidance is that it does not address the issue of other network providers denying access to other service providers. BT believes that there is evidence to show that commercial pressure alone does not provide a sufficient incentive for other network providers to open number ranges. We believe that it would be appropriate to address this under the Access Directive.
BT welcomes comments on this submission which should be sent to:
Manager Wholesale regulation Telecom and Radio Licensing Policy
Office: 500.1 Mondial House, 90-94 Upper Thames Street, London EC4R 3UB