The significance of this consultation should not be under-estimated. Strictly, Oftel's proposals relate only to financial year 2003/04. To the extent that Ofcom adopts them, however, they will shape notification and charging systems which may be in use for a number of years.
BT believes strongly that a comprehensive but "light touch" notification system is essential for the efficient functioning of the new regulatory framework. We therefore urge Oftel to reconsider its decision not to implement a notification system.
Arrangements for the setting of licence fees for the part-year from 1 April to 24 July 2003 present particular problems. We agree with Oftel's proposals for this period, which in BT's opinion represent a practical solution.
We support a number of aspects of Oftel's proposals for the calculation and collection of licence fees for the remainder of 2003/04 following 25 July. In particular, BT agrees that:
All electronic communications providers should in principle be liable to pay administrative charges;
Gross turnover should continue to be used as the basis for the calculation of the amounts to be recovered from individual providers;
The safety cap set at 0.08% of relevant turnover should be retained.
However, we disagree with certain other proposals and believe that Oftel should reconsider them:
BT considers the turnover band system is discriminatory and should be replaced with a methodology based on actual relevant turnover;
The abolition of fixed fees for providers with relevant turnover below the £5m threshold could mean significant increases in charges for other providers. BT believes providers below the threshold should also pay charges based on actual turnover, although exemptions could be granted to new entrants.
BT believes it essential that Oftel provide greater clarity on the activities for which turnover is to be considered relevant in the calculation of charges. This need is underlined by the contentious nature of some of the entries in, and omissions from, the list of "relevant activities" given in the consultation document.
The process used for the collection of administrative charges must be transparent. The Ofcom website should include lists of providers identified as liable to pay charges.
BT welcomes comments on this submission which should be sent by e-mail to: