This statement follows up proposals made in the consultative document published in February to promote competition in services provided over telecommunication networks, in particular by those not owning their own networks. The document considered the issues of charges for the basic conveyance required to transport services to the customer and market distortion from anti-competitive behaviour.
The responses to the document demonstrated the importance of the issues discussed in it, and the different interests of the various market players – network operators, independent service providers, and end users. It is these different interests which Oftel has sought to balance in order to achieve its objective: the development of a vibrant, competitive telecommunications market, which includes both network operators and independent service providers, providing consumers with a range of innovative, quality services at affordable prices.
The UK is well on the way to seeing a genuinely competitive market in telecommunications where consumers are increasingly able to choose from a wide range of telecommunications suppliers. However a number of important competition issues need to be addressed in the transition to a fully competitive market without undermining competition and investment in network infrastructure.
The measures set out in this statement are intended to facilitate this transition to a fully competitive market. Oftel believes that they will help secure a fairer and more competitive market in services delivered over fixed networks and a better choice for the consumer as a result.
Comments are invited by 1 July 1996 on the measures set out in this statement. There will then be a further period up to 15 July 1996 during which comments are invited on any submissions made to Oftel during the initial period.
Written comments should be submitted to:
Philip Sack, Oftel, 50 Ludgate Hill, London 0EC4M 7JJ
The notices relating to the statutory consultation on the proposed licence modifications referred to in this statement will specify a period ending on 15 July 1996 for making representations on or objections to the proposed modifications.
Written comments will be made publicly available in Oftel’s library except where respondents indicate that their response or parts of it are confidential. Respondents are therefore asked to separate out any confidential material into a confidential annex which is clearly marked as such. In the interests of transparency, respondents are requested to avoid confidentiality markings wherever possible.
Comments on this document can also be sent to Oftel using the following e-mail address:
intsection.oftel@gtnet.gov.uk
Oftel encourages respondents to put their responses on their own Internet pages and set up a link with this document on Oftel’s pages. Please contact Cate McLaurin at Oftel on 0171 634 8756 to organise this. Confidential responses should not be sent via the Internet.
Chapter 1 Introduction
Chapter 2 Evolution of the Market
Chapter 3 Pricing of Network Services to Independent Service Providers
Chapter 4 Policy on Relevant Connectable System Status
Chapter 5 Split between BT’s Systems Business and Supplemental Services Business
Chapter 6 Other Needs of Independent Service Providers
Chapter 7 Summary of Proposed Measures
Annex A List of Respondents to the February Consultative Document
Annex B Proposed Modifications to BT’s Licence
Annex C Categorisation of Services
1.1 Oftel’s consultative document published on 5 February reviewed the issues relevant to the evolution of the market in services provided over telecommunication networks. It noted that there were significant concerns from independent service providers that their needs were not being addressed effectively under the current regulatory framework, and that action was needed to secure a more vigorous market and, as a result, wider choice for the customer.
1.2 The document identified the following market players:
and divided the telecommunications market into the following categories:
1.3 Oftel noted that the market in network services is becoming increasingly competitive but is not yet fully competitive. BT is still the dominant network operator although it faces growing competition from operators such as Mercury, Energis, MFS, Torch Telecom and the cable companies. On the other hand, the market for enhanced services is more competitive with competition provided by other network operators and a large number of ISPs.
1.4 The particular concern highlighted by the document was the availability and pricing of network services to ISPs. Since ISPs need to use others’ networks, and BT’s network in particular, to provide their services to the public, the terms and conditions on which they may do so are vitally important to them. Oftel noted that, in order for them to compete on fair terms, it is also important that they continue to have access to BT’s network on the same terms as the enhanced services business of BT itself.
1.5 Oftel proposed that:
1.6 Oftel asked for views on these issues. There were 41 responses. Annex A lists those that responded. Oftel also held a number of meetings with interested parties including ISPs to talk through the proposals. The views of respondents on specific issues are set out more fully in subsequent Chapters. The following is a brief summary.
1.7 On pricing, there was general, albeit not universal, support for the proposal that ISPs should obtain access to BT’s network at prices less than the full retail rate paid by end users. Respondents divided broadly into those (mainly network operators) that saw a case for allowing discounts based on cost savings but no more, and those that argued for prices at interconnect levels. However there was considerable concern that BT could use any additional pricing freedom it was given anti-competitively to the detriment of other network operators and ISPs.
1.8 There was widespread support for the principle of the SB/SSB split, tempered by concern that the proposals could be difficult to achieve in practice. A number of representations were made on the relocation of specific services across the SB/SSB divide because of concern that this could affect the existing structure of competition in the market for that service.
1.9 Oftel is grateful for the comments received in response to the consultative document and has carefully considered them in drawing up the measures outlined in this statement. Alongside publication of this statement Oftel is undertaking statutory consultation (as required under section 12 of the Telecommunications Act 1984) on the proposed modifications to BT’s licence which will implement these measures. These modifications are set out at Annex B.
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2.1 Oftel’s goal is "to get the best possible deal for the customer". Oftel remains convinced that the key to achieving a vibrant market for services provided over telecommunication networks is the promotion of fair, efficient and sustainable network competition and hence competition in the provision of network services. Network services are an essential input to enhanced services, and competition in the provision of network services will help drive innovation and ensure that the inputs to ISPs are competitively priced. The market for network services is already becoming increasingly competitive. This is helping to drive down BT’s retail prices, bringing prices closer to costs.
2.2 At the same time, increasing competition will cause BT and other network operators to focus more closely on the needs of ISPs. Oftel expects the independent service provider sector to grow significantly and believes the provision of network services to ISPs will become an increasingly important aspect of network operators’ businesses. In practice, this is likely to lead to network services that are, in essence, intermediate products for service providers, either retail products "stripped" of unnecessary retail elements, or network products with additional elements to make them more suitable for ISPs. BT has stated that it is interested in developing a portfolio of services specifically designed for ISPs.
2.3 Oftel believes that these results of competition – lower retail prices and more targeted services – will gradually erode the significance of the regulatory distinctions between different users of BT’s network. In particular, the significance, in terms of pricing, of having RCS status, which entitles the holder to Condition 13 prices for use of BT’s network, will diminish and eventually disappear. Certainly Oftel believes that in 2001, at the end of the next price control period, there will be no regulatory rules maintaining any regulatory pricing distinctions. The price paid for BT’s network services will then depend not on the regulatory identity of the customer (eg RCS operator, ISP, or end user), but on the nature of the product or service purchased. This is Oftel’s longer term goal. However, to reach that goal Oftel is convinced the advantages conferred on network operators and International Simple Resale (ISR) operators by having RCS status must remain so as to ensure that investment in competing infrastructure is not deterred and that competition in the international voice telephony market is promoted. This remains an essential means of achieving the longer term goal.
2.4 It is clear that the competitive environment described above is not yet in place and will take several years to emerge. In addition, there are elements of the present regulatory framework which may be hindering the development of a competitive market in enhanced services. At the same time, it is vital that the success of recent years in encouraging competing network infrastructure is not lost. Oftel sees its role in the next few years as helping to manage the transition to a competitive market for network services with minimal regulatory intervention. The measures set out in this statement are a temporary, though important, part of the process. Oftel is seeking to strike the best balance between the different, often complementary but sometimes conflicting, interests of the various market players, ultimately to the benefit of consumers.
2.5 In formulating these measures Oftel is therefore guided by the following principles:
2.6 The February consultative document stated Oftel’s view that BT remains for the time being the dominant provider of network services, although the market is increasingly competitive. BT in its written response asserted that the provision of services to ISPs is already a competitive market. It argued that, in order to deliver a level playing field between all market players: other network operators should pay the service provider (rather than interconnection) prices for their use of BT’s network as inputs to their service provision activities; other network operators should be required to implement some form of accounting separation between their network and enhanced service provision activities. Other respondents also argued that all vertically-integrated network operators should be obliged to deal with ISPs on a non-discriminatory basis and offer them access to their networks on the same terms as to their own enhanced service activities.
2.7 Oftel believes that its analysis of competition in the market means that it would be wrong to oblige other network operators to deal with ISPs in the same way BT is required to. These operators, unlike BT, are not dominant in the market for network services, and could not affect competition in this market in the way BT could. Nevertheless, the measures set out in this statement would apply equally to any network operator with significant market power in the future. In the meantime, they will constrain only BT. Oftel will also be considering the position of Kingston Communications. The consultative document entitled Fair Trading in Mobile Service Provision published on 24 May, which considers the same issue in the context of mobile telephony, proposed that the regulatory framework for mobile must be kept under review with the objective of aligning it with the general framework of telecommunications regulation.
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3.1 This and subsequent Chapters set out the specific measures which Oftel now intends to take. These are then summarised in Chapter 7.
3.2 In the February consultative document Oftel proposed giving BT greater freedom to differentiate between ISPs and end users by offering lower prices to ISPs for access to its network. This freedom would be subject to the proposed Fair Trading Condition aimed at preventing abuse of a dominant position, and other existing provisions on fair competition in BT’s licence. Oftel proposed that ISPs should not have access to Condition 13 prices as of right. It asked whether, given the freedom, BT would actually offer lower prices to ISPs. Oftel also asked whether BT should be allowed to differentiate prices charged to ISPs according to end use.
3.3 Respondents to the consultative document generally – but not universally – agreed that ISPs should obtain network services at less than the full retail rate charged to end users. Some consultees, for example Ionica and MFS, questioned the need for lower prices to ISPs, arguing that if ISPs were genuinely adding value to network services they should be able to pay the full retail price for those services and still charge a premium. Beyond this, there were significant differences of view as regards the extent of any reduction and whether or not it should be required of BT. BT said it should be allowed to charge lower prices for services that stimulate greater use of its network, but was concerned about services whose ultimate use substitutes for a basic retail product. It also argued that where its SSB was competing against the enhanced products of other network operators, it would be forced either to lower the price of network services to the SSB to Condition 13 levels in order to compete, or to withdraw from markets. Otherwise it would not be able to compete with the enhanced products of other network operators who have no regulatory constraints on the prices for their own network service inputs to these products or can obtain them at Condition 13 prices from BT. Most other network operators wanted any discounts offered to ISPs restricted to cost savings entailed in serving them. BT, CCA, Ionica, Energis, MFS, ACC and others believed Condition 13 prices for ISPs would undermine the incentive to invest in infrastructure. NTL, MOTO, Barclays and others agreed that BT should be given freedom to lower prices to ISPs. Reuters, Cellcom, NOA, TUA and others argued that BT should be required to offer Condition 13-based prices so that ISPs can compete on the same basis as operators with RCS status.
3.4 There was widespread concern that BT, if given pricing freedom, would use it in an anti-competitive way to lower prices to ISPs for some services whilst maintaining them for others, to its own advantage. Some questioned whether the proposed Fair Trading Condition would provide a timely and effective deterrent or remedy. BT on the other hand considered that the economics of the market and the effects of competition would give rise to fair prices and that formal controls on price and other terms of business would be unnecessary.
3.5 Oftel remains of the view, after further careful
consideration in the light of responses, that ISPs should obtain
access to BT’s network at prices lower than those charged to
end users. In summary, Oftel proposes that:
1 BT should be allowed to offer prices for network services to ISPs below retail prices charged to end users, to reflect any lower costs incurred in serving ISPs. Oftel would not, in principle, consider that this represents undue discrimination under Condition 17 of BT’s licence (which prohibits undue preference and discrimination).
2 This freedom for BT is contingent on having the Fair Trading Condition in its licence. The principles behind the Fair Trading Condition will apply to ISP prices (so there will be an expectation of lower prices to ISPs where there are cost savings). Other relevant Conditions will also apply to the services and prices offered to ISPs, for example Condition 1 (obligation to supply), Condition 16 (publication of charges etc), Condition 17 (prohibition of undue preference and discrimination), and Condition 24F (which requires BT to obtain the Director General’s consent to prices below fully allocated costs).
3 The Director General will not have a specific power to determine ISP prices offered by BT. Condition 15 of BT’s licence is proposed to be modified to remove the power to determine prices for "systemless" resellers.
4 There will be a presumption against price discrimination between different types of ISP depending on the use to which a network service is put.
5 In order to comply with the Fair Trading Condition and Condition 17 and, to an extent, Condition 18, of BT’s licence, unbundling of services (network from enhanced services; network services from each other; and network services from the retail element) will be expected unless uneconomic or technically unfeasible.
6 A definition of ISPs will be drawn up in order to identify those who are entitled to ISP prices from BT. (Oftel will be considering with DTI whether there should be a new class licence for ISPs and if so whether this definition should be incorporated in it).
3.6 Oftel is clear that ISPs should expect lower prices from BT where the costs of supplying them are lower than the costs of supplying end users. The provision of network services to service providers is effectively a wholesale service: ISPs use them as inputs to their own services which they then provide to the public. Oftel wishes to allow BT to break away from the rigidities of retail prices designed primarily for end users, and to offer ISP prices set under more competitive circumstances. Oftel believes that it would not be appropriate to charge ISPs retail prices which include costs for services not required by ISPs. Oftel notes the arguments of those who propose that ISPs should be entitled to Condition 13 prices. However, as stated earlier, these prices reflect the different nature of the use that network operators make of BT’s network compared to others.
3.7 The elements of the new pricing policy are expanded below:
3.8 This Statement is intended to make it clear that if BT chooses to offer different prices for similar services to ISPs than to end users which reflect cost savings to ISPs, the Director General would in principle not consider it to be undue discrimination or preference within the terms of Condition 17 of BT’s licence, and therefore not a breach of Condition 17. Indeed, as stated above, Oftel expects BT to offer ISPs lower prices to reflect more accurately the different costs associated with selling products or services to end users and ISPs. Oftel will look to BT to strip out elements of costs that are not incurred in supplying services to ISPs, or at least not incurred to the same extent as when supplying retail services to end users. Examples of such costs may include marketing and sales, finance and billing, customer service, and operator services. In addition, Oftel expects prices to ISPs to fall as a result of unbundling network services from enhanced services and network services from each other. ISPs may also be able to benefit from volume discounts offered by BT, assuming they purchase services in sufficient quantities. If Oftel is not convinced that BT is removing cost savings in the prices it charges ISPs, it will consider whether action should be taken under the Fair Trading Condition or Condition 17 of BT’s licence.
3.9 Oftel does not believe that this policy will significantly undermine the promotion of network competition. Other network operators will continue to enjoy the benefits of Condition 13 prices from BT, which are amongst the lowest in the world, and will be free to pass these benefits on both to their own enhanced services and, if they choose, to ISPs. They will be able to provide network services to ISPs and thereby benefit from additional network traffic generated by ISPs. They will also stand to benefit from the future limitation on RCS status (and therefore of those entitled to Condition 13 prices) set out in Chapter 4 below. In addition, if they do not have significant market power the Conditions relating to undue discrimination and unfair cross subsidy do not apply in the same way as they do to BT. Oftel believes therefore that its proposals on pricing strike the best balance between the interests of BT, other network operators, ISPs and consumers.
3.10 Oftel has made clear that its proposals on pricing are contingent on having the Fair Trading Condition in BT’s licence. Oftel will monitor ISP prices charged by BT very closely, and apply the principles underlying the Fair Trading Condition. The Fair Trading guidelines published in draft at the beginning of June will therefore be relevant. The Condition would prohibit anything done (or not done) by a dominant company which has the object or effect of preventing, restricting or distorting competition in relation to any commercial activity connected with telecommunications. Oftel would look to see whether pricing has the object or effect of driving or keeping out other network competitors from the market for services to ISPs, or of doing so to ISPs in the enhanced services sector.
3.11 Implementing these proposals will attach further importance to the way in which Oftel investigates complaints about anti-competitive behaviour. Oftel recently reviewed its competition casework handling to ensure that all investigations are conducted more transparently and that procedures operate correctly. Complainants are kept informed about the progress of enquiries on a regular basis, and wherever possible proposed remedies or changes are discussed with them before conclusions are formed. Oftel will be publishing quarterly Competition Bulletins to help the industry understand its thinking on competition matters and to encourage debate over enforcement issues. Oftel is developing targets for all phases of competition investigations and intends to publish the results of its compliance with those targets. Oftel will apply a casework audit system by a casework auditor, who is independent of the investigation process, to all significant investigations under the proposed Fair Trading Condition.
3.12 BT will be required under Condition 16 to publish and notify Oftel of any new ISP prices it introduces. In addition, BT is required under Condition 24F of its licence to obtain the Director General’s consent to any price that falls below fully allocated costs.
3.13 The Director General would not have a power to determine ISP prices offered by BT. Instead as explained earlier, he would act where necessary on the basis of relevant Conditions in BT’s licence on anti-competitive behaviour.
3.14 This new policy requires a review of Condition 15 of BT’s licence. Paragraph 15.3 of Condition 15 requires BT to provide to "Service Providers" (defined in Paragraph 15.8 and meaning "systemless" resellers) any telecommunication service they may request which BT offers to its customers generally, on terms which would not prohibit the Service Provider selling that service on. Paragraph 15.4 provides for the Director General, where necessary, to determine any charge, term or condition, proposed by BT to the Service Provider, and Paragraph 15.5 specifies that determined charges must be based on any likely cost savings, plus any likely additional costs in providing the services to the Service Provider. Paragraph 15.6 allows the Director General, with 3 months’ notice, to direct BT to cease providing telecommunication services to any Service Provider that he believes no longer proposes to be a Service Provider. Paragraph 15.7 waives the need for 3 months’ notice where it appears to the Director General that this is necessary to protect the Service Provider’s customers or any other person. Paragraph 15.8 defines the term Service Provider and limits the definition to those reselling telecommunication services but not "by means which necessarily involve the running of a telecommunication system by him or on his behalf". Paragraph 15.9 makes clear that nothing in Condition 15 affects any need for a Service Provider to have a licence in respect of the service he intends to offer.
3.15 Condition 15 has not been successful in establishing "Service Provider" prices. Whatever the reasons were, Oftel now believes that Paragraphs 15.3 to 15.9 are no longer necessary or appropriate. BT will be free to offer lower prices to ISPs as a result of the policy set out in this statement and is expected to offer prices which exclude costs not incurred in the provision of services to ISPs. In addition Oftel will consider whether action should be taken under Condition 17 or the proposed Fair Trading Condition if it believes BT is acting anti-competitively with respect to ISP prices. Removal of the Director General’s determination-making power would also be consistent with other deregulatory initiatives proposed elsewhere, for example in relation to interconnect prices under the Price Control Review.
3.16 Oftel therefore proposes to delete Paragraphs 15.3 to 15.9 of Condition 15 to BT’s licence and is formally consulting on this proposal by means of a notice published under section 12 of the Telecommunications Act 1984. It is not proposed to delete or modify Paragraphs 15.1 and 15.2 which require BT to permit anyone licensed to run a system authorised to be connected to BT’s network and authorised to provide telecommuni-cation services to others, to provide those services, and to permit anyone using lawfully connected apparatus or running a lawfully connected system to provide services by means of BT’s network.
3.17 In the February consultative document Oftel asked whether BT should be allowed to discriminate in terms of pricing between different types of ISP depending on use. The great majority of consultees expressed strong reservations about doing so, not least because this would mean BT having to know information about an ISP’s business which the ISP might not wish to divulge. There could also be practical difficulties ensuring that an ISP used a service for the stated purpose. Oftel recognises these potential problems and has concluded that there should be a presumption against usage-dependent pricing. However, there may be circumstances in which it would be desirable and efficient for some enhanced services, particularly new and innovative services, to obtain network services at lower prices than are charged to other enhanced services. The onus would be on BT to convince Oftel that any such prices would not be anti-competitive, or unduly discriminatory, or involve unfair cross-subsidy.
3.18 The February consultative document noted the importance, in the context of the SB/SSB split, of ensuring that ISPs only have to buy the services they want. A number of EU Directives, including the Voice Telephony Directive and the proposed Interconnection Directive, impose obligations in relation to unbundling of services.
3.19 A number of different forms of bundling can be conceptualised, though in practice there will be specific cases where it may not be economically or technically feasible to unbundle some elements:
3.20 In respect of (a), Oftel would expect to use the Fair Trading Condition and Condition 17 to consider whether BT should be required to unbundle retail elements from the network service. In respect of (b), if BT were supplying a network service in an unbundled form to itself, Condition 17 would oblige it to supply the same, or an equivalent service, on the same terms to ISPs. In cases where BT was not supplying such a service to itself in an unbundled form, Oftel would consider whether BT was in breach of the Fair Trading Condition if it refused to supply the service in an unbundled form to an ISP. However, there are clearly limits to the degree of disaggregation that is possible and/or economic. Oftel would consider any complaint made to it about BT’s behaviour on a case by case basis. Oftel would also take into account policy developed in the context of network intercon-nection that might be relevant to unbundling in the service provider context.
3.21 In respect of (c) – bundling of network and enhanced services – Oftel’s proposal to redefine BT’s Systems Business and Supplemental Services Business so that they correspond more closely to the distinction between network and enhanced services (see Chapter 5), is a crucial development. Additionally, when BT provides a service out of the SSB, the effect of Condition 17 will be to drive BT to identify the network service(s) element of that service and provide it, or a service of equivalent functionality, out of the SB to ISPs on the same terms as it provides it to the SSB.
3.22 A number of consultees including BT, Energis and IIISS considered that the definition of ISP needed to be developed. BT said it was essential to be able to identify with certainty those who would be able to obtain services at special prices. Racal was concerned that BT might be able to decide who is an ISP in an anti-competitive way – it suggested registration under a class licence as a possible solution. Some network operators expressed concern that BT might be able to abuse its freedom to provide lower ISP prices by offering them to large corporate users who were not genuine ISPs. Other consultees, including Mercury and WorldCom, thought the distinction between ISPs and end users was marginal and might be difficult to define.
3.23 Oftel recognises the need for as much certainty as possible as to who should be entitled to ISP prices from BT, both for BT’s sake so that it is clear whether it is compliant with its licence Conditions, and for the sake of potential ISPs who will need to develop their business plans on the basis of the prices they expect to receive. However, Oftel does not wish to adopt the approach of registration under a class licence because it would require a decision on registrability in every case – this would be very interventionist, time-consuming and resource-intensive. It prefers instead to adopt as precise as possible a definition of ISP and indicate to BT that it may only offer ISP prices to those falling within the definition without breaching the undue discrimination rules in Condition 17 or the Fair Trading Condition. As already stated, it will be discussing with DTI whether the definition should be incorporated into a new class licence for ISPs.
3.24 Oftel’s preliminary thinking on the definition is that it should cover entities whose main business is the provision of services with a telecom-munication service component, for reward to the public, or any class of the public. It would exclude:
(a) those operating under an individual Telecommunications Act licence (expected to be network operators and therefore entitled to Condition 13 prices);
(b) closed user groups (which would be defined);
(c) those who are not selling the substantial part (eg 80%) of the services to organisations not under substantively the same or joint ownership;
(d) end users;
(e) companies who supply services using telecommunications as an input, but where the output can substantially be provided by an effective alternative means of delivery other than over a telecommunications network.
3.25 More detailed consideration of the definition will be needed and Oftel will take this forward with the industry. Oftel would welcome views on the definition.
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4.1 The term Relevant Connectable System (RCS) is defined in Condition 13.9 of BT’s licence (and in certain other individual licences using identical wording). An operator has RCS status with respect to BT’s licence if the terms of its own individual licence are such that its system meets the definition in BT’s licence, or if it is operating under a class licence and BT does not offer standard terms and conditions for connection of its system to BT’s network. The Director General has the power under BT’s licence to determine that a system ought not to be deemed to be a Relevant Connectable System for the purposes of BT’s licence (and a similar power under other relevant licences).
4.2 Having RCS status with respect to BT’s licence means, among other things, that the operator of the system is entitled to interconnect with BT’s network under Condition 13 of BT’s licence. There is a published list of standard interconnect services and their prices. Currently most of these prices are determined annually by the Director General. Oftel has proposed, from August 1997, replacing the annual determination of prices with a new system of network price controls, with the extent of direct control over prices for individual services dependent on the degree of competition, or expected competition, in the market for the service in question. The formula would operate on the same principles as the retail price cap – BT would set the prices but would be required to ensure that the average price of the services in the basket fell, in real terms, to meet the RPI–X formula.
4.3 In the February consultative document Oftel proposed that RCS status should in future (from the date of the document, 5 February) be confined to network operators and, for the time being, ISR operators, who are making a significant contribution to competition in the international market. In the context of entitlement to Condition 13 prices, Oftel said, in general terms that it was not proposing to deprive any licensee who currently has RCS status of this, but noted that some ISPs are currently entitled to benefit from Condition 13 prices even though they have no network of their own.
4.4 Consultees tended to be divided between operators like BT, the cable companies, Racal, Torch and MFS, who agreed with the principle of limiting RCS status in the way proposed, and others like ACC, AT&T, IIISS, IMS, WorldCom, and Cellcom who argued that ISPs and other operators also invest significant amounts in telecommunications infrastructure like call routing equipment, intelligent network platforms, and billing systems. Oftel acknowledges the important contribution to the UK’s overall telecommunications infrastructure provided by a whole range of operators. In some cases, investment in leased lines, switching equipment, and other technology for serving customers is substantial. Nevertheless, Oftel believes that, in order to underpin the very successful and vitally important objective of promoting network competition, it continues to be necessary to limit those entitled to Condition 13 prices to operators who are installing both significant transmission and switching infrastructure. This is in the long-term interests of consumers and ISPs, all of whom will enjoy the benefits of effective, vigorous competition between network operators and hence in network services.
4.5 Oftel is therefore confirming the policy set out in the February consultative document. Anyone applying for an individual licence after 5 February 1996 which would confer RCS status will keep that status only if they are:
(a) a network operator making a significant contribution to infrastructure competition in the UK market in terms of installing transmission (this would include any company whose initial investment on entering this market is small); or
(b) an international simple resale (ISR) operator making a significant contribution to competition in the international market, until such time as competition in the UK international facilities market is established.
4.6 In order to prevent circumvention of this policy, Oftel would consider taking away RCS status from a licensee if a complaint was made to Oftel that the licensee was not, (after an appropriate length of time), offering the services on the basis of which RCS status had been granted, in other words, that it did not fall into either of the categories at paragraph 4.5 above.
4.7 Oftel is working with DTI to establish more detailed guidance for prospective licence applicants explaining how it would implement the policy on RCS status.
4.8 A number of respondents to the February consultative document, for example, Ionica, IMS, DMA and ISPA, pointed out that, to allow some operators to keep their RCS status because they had applied for a licence on or before 5 February, whilst denying RCS status to other operators who might be in competition with them, could constitute discriminatory treatment and might distort competition.
4.9 Oftel recognises that there may be some transitional problems because some operators not falling within the categories at paragraph 4.5 above have already acquired RCS status. Oftel will keep the situation under review in order to assess whether any significant discrimination or distortion of competition lasting for an unacceptable length of time has occurred. Oftel considers however that the measures set out in this statement should minimise the risk of discrimination and distortion.
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5.1 BT is a vertically integrated company providing both
network services and enhanced services and is dominant in the
supply of network services. It is therefore important to ensure
that it does not leverage its dominance in network services into
the enhanced services market. The regulatory framework set up to
ensure this is the requirement on BT to provided separate
accounts for the SB and the SSB together with other provisions in
BT’s licence, in particular those on unfair cross subsidy
between the SB and SSB and on undue discrimination and undue
preference. This regulatory structure ensures that:
(a) BT’s SB is obliged to offer to ISPs the same, or equivalent, services that it offers to its SSB. This means that when it is developing an enhanced service to be provided from the SSB, BT must ensure that the underlying SB service which is an input, is configured in such a way that it, or a functional equivalent, is capable of being provided to ISPs for use as an input to their own enhanced service in competition with BT.
(b) BT’s SB is required to charge ISPs the same prices for its services as it charges (for accounting purposes) its SSB. These prices include the allocation of common costs and the retail elements such as billing, marketing and customer service.
(c) Under Condition 16 of its licence, BT is required to publish the charges and other terms and conditions on which it offers to provide any telecommunication service it is obliged to provide. It is therefore required to publish the charges for network services to ISPs.
5.2 In the February consultative document, Oftel proposed redefining the split between the SB and the SSB so that the SB more accurately mirrors the split between network services and enhanced services. Network services are described in paragraph 1.2. They are those services which are most economically provided by network operators because of the economies of scale and scope inherent in owning a network. Enhanced services are also described in paragraph 1.2 and are readily capable of being efficiently provided by ISPs. Network services are the underlying inputs to enhanced services and therefore it is these services which ISPs must be able to buy on the same basis as BT’s SSB in order to compete with it.
5.3 In particular, technological trends drive the need for a redefinition of the allocation of services. Increasingly, networks are employing digital technology which enables voice networks to carry data and, as has been seen on the Internet recently, data networks to carry voice. With the emergence of Asynchronous Transfer Mode (ATM) as a converged network technology capable of handling all forms of communication service, it would be unrealistic to continue with different regulatory treatment of voice and data.
5.4 Most respondents agreed with the need to redefine the split and the underlying principles proposed. BT was more concerned to develop products specifically aimed at service providers than redefining the split. Oftel believes that both a redefinition of the split, and the development of new products aimed specifically at ISP needs, are necessary. Respondents did however raise concerns about how the split would be achieved in practice. Oftel agrees that while it may not be easy, it must nevertheless be done in order to ensure that the market is protected in future from any unnecessary distortions where services are provided out of the "wrong" business. Oftel also agrees with the view expressed by some operators (such as Racal, Mercury and Energis) that the SB should not remain static over time. Some respondents (such as ISPA and Reuters) did not agree with the proposed classification of certain services, in particular where this would undermine an existing competitive advantage.
5.5 Oftel has put a great deal of effort into reviewing the proposals it set out in the consultative document in relation to individual services, as a result of which some of the services proposed for reclassification will not be moved. For three services – Internet Transport Protocol, Call Minder and Directory Enquiries – Oftel proposes to delay a decision on classification pending further consultation with the industry.
5.6 It is important that the principles which underpin the new SB/SSB split and which are given effect through the proposed licence modifications set out at Annex B, are clear. Oftel wants to ensure that the regulatory framework supports a variety of market players who provide sustainable and efficient competition. It wants to encourage competition by ISPs in as many services as possible where they can provide such competition efficiently. Oftel believes however that only network operators can provide efficient and sustainable competition in the provision of transmission capacity, and that it would be economically inefficient to force BT to unbundle transmission from switching across the SB/SSB divide. The reason for this is that when network operators provide network services, they benefit, solely by virtue of their ownership and control of the network, from economies of scope and scale and the ability to exploit their network topology, in a way that ISPs could not.
5.7 Oftel wants to ensure that network operators are able to exploit these advantages for the benefit of customers. BT will be able to do so when the service is provided from the SB whereas it may not be able to do so if it is obliged to provide the service out of the SSB. This is because, as explained above, when BT provides a service out of the SSB, it has to buy the underlying network services from the SB. These underlying services must be configured in such a way that they, or their functional equivalents, are capable of being provided to ISPs (and, at present, end users). This requirement can result in BT having to develop an underlying network service which is less efficient in its use of the network than the equivalent service provided to the SSB. Where this is the case, competition from ISPs (as opposed to network operators) may not deliver any overall benefits. In addition, if such network services were provided from the SSB there is a risk that the charge for the service to the customer will be artificially high. This is because in some cases the actual cost to BT of providing the service out of the SB or the SSB may not be different but the price of an SSB service may have to take into account two retail elements (the SB retail element and the SSB retail element). For these reasons, Oftel is of the view that all network services should be in the SB.
5.8 The principles described above have underpinned the proposed licence modifications set out at Annex B.
5.9 BT’s licence contains the definitions of BT’s SB and SSB in Condition 18, which prohibits unfair cross-subsidy by the SB of apparatus supply, mobile radio and the SSB. From this split has grown the further definitions of BT Businesses which underpin the Interconnection and Accounting Separation (ICAS) regime (governed by provisions in Condition 20B of BT’s licence).
5.10 The SB consists essentially in ‘activities’ carried out by BT comprising running its network, maintaining it, connecting equipment to it and conveying and switching messages through it. The SSB consists in ‘Relevant Services’. Since 1987, ‘Relevant Services’ have been defined (at paragraph yA of Schedule 1 Part 1 of BT’s licence) by reference to a now defunct class licence, known as the Value Added and Data Services or ‘VADS’ class licence, which essentially covers every type of telecommunication service except live speech, telex, ISR, cable programme services and land mobile radio services. Oftel is proposing to amend the definition of ‘Relevant Service’ in BT’s licence which would, in its turn, affect the definition of SSB and SB. ‘Relevant Services’ would be defined as any services provided by BT’s system which are not ‘Network Services’. The term ‘Network Service’, to be defined in Condition 18, would mean simple conveyance together with two other categories of services with special features. The definition of the SB is proposed to be changed so as to include activities relating to the provision of ‘Network Services’.
5.11 In formulating this licence amendment, Oftel has given careful consideration to the way in which network services should be defined. Given the issues of efficiency, Oftel is conscious that there can be no clear cut definition that will, in all circumstances, objectively identify whether some services are or are not network services. Nevertheless many network services can be identified by certain general objective characteristics: basic conveyance, for example. In relation to other services, a decision may have to be made on a case by case basis. The definition therefore sets out to maximise clarity while avoiding creating a situation which will result, by virtue of the very precision of the definition, in services falling into the "wrong" class in future and thereby causing distortions in the market which do not benefit the consumer.
5.12 Network services will first include all those services which are ‘Basic Conveyance Services’ (defined in the proposed licence modifications – see Annex B) together with any service necessarily incidental to that service (for example basic call set up and billing). In relation to existing services, these will include services such as voice telephony, telex, private circuits, and ISDN bearer services. ‘Basic Conveyance Services’ also include basic data services such as the basic components of frame relay, X25, ATM, and SMDS. Sub-paragraph (a) of the definition of ‘Network Services’ is intended to cover these services, which are listed in Annex C.
5.13 In addition to ‘Basic Conveyance Services’, there are services which cannot practicably be provided in identical form by anyone other than a network operator because that operator provides Basic Conveyance Services. One group of such services are the supplementary services associated with telephony and ISDN, such as Call Waiting and Calling Line Identity (CLI). For customers being served by a network operator with telephony/ISDN service, only that operator can provide these extra services. The second group of services are those referred to in the consultative document as "line sharing services". These are services which are delivered over the access lines provided primarily for telephony or ISDN service. They cannot practicably be provided by an ISP in the same form. They include such services as "Data over Voice", "No Ring Calls" and ISDN "D Channel Access". By classifying these services as Network Services, they would have to be provided to ISPs and BT’s SSB on equal terms. These services are described in sub-paragraph (b) of the definition of ‘Network Service’, and are listed in Annex C.
5.14 Subject to certain exceptions, any other type of service will be an enhanced service. These will normally all be provided out of the SSB as they should be services which ISPs will be able to provide on the same basis as BT as long as they can get access to the underlying network services on non-discriminatory terms.
5.15 There is an exception to this general rule however. Oftel has recognised that there may be cases, crucially where the "enhanced" element is small, where it would be more efficient for a particular enhanced service to be provided by network operators than by ISPs. An example of this might be where the cost of configuring the underlying SB service so that it could be provided to ISPs might outweigh the benefits to the market and consumers of competition from ISPs, particularly where competition already exists in the provision of that service from other network operators. Oftel is concerned that it does not create an inefficiency in the market by insisting that these services are to be provided out of the SSB, with the risk that prices to the customer for the services remain artificially high.
5.16 Oftel proposes therefore, in such cases, to agree with BT, subject to consultation with interested third parties, that a particular service should in fact be provided out of the SB rather than the SSB. Where Oftel takes such a decision in respect of a particular service that service will then be described in a list published by BT for the purpose and kept by Oftel. This mechanism is described in sub-paragraph (c) of the definition of ‘Network Service’.
5.17 An example of such a service would be Number Translation Services. Number Translation Services have a small level of enhancement over basic conveyance: the call set-up sequence is somewhat more complex, usually involving translation of the number and some special routing options. Network operators have an inherent advantage over ISPs in their provision, since the regular telephony network can be exploited to minimise the degree of network conveyance. A list of services Oftel proposes should come under this category is in Annex C.
5.18 The consultative document raised the possibility of BT developing a new service, referred to as a "Controlled Routing Service", which would go some way to reducing the competitive disadvantage of ISPs in certain types of service, for example those based in number translation, as a result of the need for a two-stage call. However Controlled Routing Services are not presently available, they might take a long time to develop, and they could prove very costly. After careful consideration, Oftel has come to the view that on balance Number Translation Services should be provided out of BT’s SB. The same applies to Personal Numbering, Calling Card services, VPN and Centrex.
5.19 Annex C lists the existing services which, according to our information would fall within the SB on the basis of the proposed definition, and those which the Director General would agree should be provided from the SB. It also lists the services which are currently provided out of the SB and would, under the new definition, be provided out of the SSB.
5.20 In addition, Annex C lists several services in respect of which Oftel is still considering, in consultation with the industry, whether they should be provided from the SB or the SSB. These are:
This service is the subject of a formal complaint currently being investigated by Oftel. The complaint is that BT’s provision of Call Minder out of the Systems Business as a network embedded service is an abuse of its market position and that provision in this form is stifling the growth of competing services. Call Minder does contain a level of enhancement over and above basic call conveyance and therefore should normally be provided out of the SSB. This would enable ISPs to buy the underlying components of the service and to provide a competing service. However it is not clear that customers would enjoy any overall benefits if the service were provided out of the SSB. There is a likelihood that the price of Call Minder will rise if the service is provided out of the SSB. In addition, there is a view that sufficient competition in the service already exists from the suppliers of answering machines. Oftel is therefore currently considering whether or not the service should be classified as a Network Service (under sub-paragraph (c) of the definition of ‘Network Service’) provided out of the SB. As part of this process, Oftel is consulting with interested parties on the issue, and would welcome views in response to this document as to whether or not Call Minder should be provided out of the SB.
This is a data conveyance service which is an input to the provision of Internet services and currently resides in the SSB. There is a strong logical argument that, as it is a connectionless data service, it should be relocated to the SB alongside such services as SMDS. However, Oftel is concerned to ensure that innovation and competition in Internet services continues in order to provide the customer with both quality and choice in these services. Oftel is therefore investigating all of the issues surrounding the delivery of Internet Services to customers before it takes a final decision, at the end of the consultation period, on the classification of Internet Protocol Transport. Oftel would welcome views on whether or not Internet Protocol Transport should be classified as an SB service.
The market for directory products and services is currently the subject of a major review by Oftel. This is looking at the fundamental structure of the market and, in particular, the issue of ownership of the core database of directory information, currently held by BT. A final decision on the treatment of directory services will be taken in the light of emerging conclusions from that study. Under the proposals, it is likely that the majority of services which go to make up BT’s directory products and services would fall outside the definition of Network Services, unless any were to be included under the special agreement procedure. Several issues remain to be resolved in this area. Competition would be likely to increase if BT sold its products and services from the SSB because ISPs would be purchasing their inputs – essentially basic call conveyance – to the services at the same price as BT. On the other hand, the price to consumers would be likely to increase because BT would have to account for the Network Service inputs to the services at retail charges (minus any discounts offered to ISPs). Oftel would welcome views on this.
5.21 Oftel believes that the new definition will clarify the way in which the regulatory framework will apply to a particular service and encourage the market in services to develop in the most efficient way.
5.22 It is important to ensure that the operation of the SB/SSB split works effectively. This means that accounting information must be available to Oftel in sufficient detail, and where necessary published, to monitor BT’s compliance with relevant provisions in its licence. Therefore:
5.23 Oftel would welcome comments and views on this.
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6.1 The consultative document identified two further issues in relation to the needs of ISPs which needed further consideration:
(a) whether ISPs should have the same access to numbers as network operators;
(b) whether the more sophisticated interconnect interfaces should be made available to ISPs where normal retail interfaces do not provide the appropriate degree of functionality.
6.2 At present, only those with RCS status have rights to interconnect interfaces other than at normal retail network termination points and, broadly speaking, rights to direct allocation of numbers. The policy on limiting RCS status requires these issues to be considered now.
6.3 Currently, ISPs operating under the Telecommunication Services Class Licence (TSL) are able to obtain numbering capacity only through their contractual arrangements with operators that have been allocated numbers. Holders of individual licences which contain a relevant numbering Condition are entitled to have allocations of capacity directly from the UK Numbering Scheme.
6.4 To give ISPs greater flexibility in their connection arrangements and to provide greater choice in the types of numbers they can offer their customers, Oftel is considering how to give relevant ISPs direct access to numbers. Indications from some ISPs have suggested a demand for direct allocations in particular for the fixed geographic range (currently numbers beginning 01), personal numbers, for special services (freephone,shared-cost and shared revenue services) and for access codes (short codes beginning 1XXX).
6.5 To maximise the efficiency of routing calls within networks direct allocations are currently made in blocks varying in size from 10,000 numbers for the fixed geographic range to 1 million numbers for personal numbering and other non-geographic services. Numbering demand from ISPs is likely to be far less than 10,000 numbers in most cases. Meeting this demand by maintaining the current allocation structure would considerably reduce the efficiency of the Numbering Scheme and would be likely to lead to the exhaustion of codes and ranges. The Numbering Administrator could resolve this by making allocations:
6.6 In either case, the Numbering Administrator would only allocate capacity where ISPs intended to make allocations to end-users.
6.7 In the case of access codes, there is great pressure on capacity. In theory 1000 four-digit 1xxx codes are available but, because of the use made of codes such as 100, 112 and 192 and allocations made by operators to provide indirect access, only about 300 four-digit 1xxx codes remain unallocated.
6.8 Proposals will be made this summer in Oftel’s consultative document on the Numbering Scheme for rules which will consider the needs of ISPs in more detail and how numbering resources can be managed in a way which enables some direct allocation of numbering resources to ISPs. In the meantime, Oftel would welcome views on the needs of ISPs for numbers.
6.9 Oftel wishes to understand more fully the extent to which ISPs need access to interfaces other than those available as retail interfaces at BT’s regular Network Termination Points (NTPs). It is particularly concerned to do so in the light of the proposed Interconnection Directive which requires certain telecommunciations organisations with significant market power to meet all reasonable requests for access at points other than NTPs.
6.10 Those ISPs who currently have RCS status are entitled to interconnection with C7 signalling. The extent to which this is the only satisfactory means of interconnection is not clear. There may be ISPs who need the full functionality that C7 provides in order to deliver their service offerings. This connectivity brings with it the need for BT and the ISPs to ensure that mutual testing is carried out to confirm the absence of network integrity problems, and a significant additional demand here created by ISPs could introduce difficulties. However, other ISPs may only require connectivity that is already available as a retail interface (eg DASS2) in order to provide their services.
6.11 In the medium term, we would expect that the industry would want to explore the provision of a wider range of services with appropriate retail interfaces for ISPs than is available today. This would avoid the need for interconnect interfaces with the consequent burden of testing to ensure maintenance of network integrity.
6.12 Oftel has recently helped to establish a Service Provider Interest Group under the Network Interoperability Consultative Committee (NICC), and expects this Group, among other things, to address this issue as one of its priorities. Oftel would welcome views on the needs of ISPs for interconnect interfaces.
6.13 Oftel is considering how best, in regulatory terms, to meet the possible needs of ISPs for numbers and interconnect interfaces. One possibility is a new class licence which would confer appropriate rights and obligations. Oftel is considering this with DTI which is responsible for issuing licences under the Telecommunications Act. As explained earlier, such a licence might also be an appropriate vehicle for defining those entitled to ISP prices from BT.
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7.1 Oftel’s proposed measures are, in summary:
1 BT should be allowed to offer prices for network services to ISPs below retail prices charged to end users, to reflect any lower costs incurred in servicing ISPs.
2 This freedom for BT is contingent on having the Fair Trading Condition in its licence. The principles behind the Fair Trading Condition will apply to ISP prices.
3 The Director General will not have a specific power to determine ISP prices offered by BT. Condition 15 of BT’s licence is proposed to be modified to remove the power to determine prices for systemless resellers.
4 There will be a presumption against price discrimination between different types of ISP depending on the use to which a network service is put.
5 Unbundling of services (network from enhanced services; network services from each other, and network services from the retail element) will be expected unless uneconomic or technically unfeasible, and subject to the Fair Trading Condition and Conditions 17 and 18.
6 A definition of ISPs will be drawn up in order to identify those who are entitled to ISP prices from BT. Oftel will consult further with the industry on this and would welcome views in response to this document.
7.2 Oftel is undertaking statutory consultation on the deletion of the relevant elements of Condition 15 to give effect to 3 above.
7.3 Anyone applying for an individual licence after 5 February 1996 which would confer RCS status will keep that status only if they are:
(a) a network operator making a significant contribution to infrastructure competition in the UK market in terms of installing transmission and switching infrastructure; or
(b) an international simple resale operator making a significant contribution to competition in the market for international calls until such times as competition in the UK international facilities market is established.
7.4 Oftel is working with DTI to establish more detailed guidance for prospective licence applicants explaining how it would implement the policy on RCS status.
7.5 Oftel proposes redefining the split between BT’s SB and SSB by defining the services which should be in BT’s SB to cover:
1 Services which are basic conveyance services (basic transmission and basic switching) together with any service necessarily incidental to that basic conveyance (for example basic call set up and billing).
2 Services which cannot practicably be provided in identical form by anyone other than a network operator because that operator provides Basic Conveyance Services (for example CLI).
3 Services which do not fall into the first two categories and would therefore normally be categorised as SSB services, where the Director General, after consultation with interested parties, agrees with BT that they should be in the SB because the enhanced element is small and they are more efficiently provided from the SB.
7.6 Oftel is undertaking statutory consultation on proposed modifications to BT’s licence to give effect to this new definition.
7.7 In the light of this new definition, Oftel has identified the existing services which fall within the SB.
7.8 Oftel however intends to delay a decision on the categorisation of three services (Internet Protocol Transport, Call Minder, and Directory Enquiries) in order to consult further with the industry, and would welcome views and comments in response to this document on the appropriate classification of these services.
7.9 Oftel will consider further with BT the issue of (a) greater public transparency; and (b) further disaggregation of BT’s SB and SSB accounts and would welcome comments and views on this.
7.10 Oftel will consult further with the industry on the issue of access by ISPs to numbers in their own right, and Oftel would welcome views on this. Proposals will be made in Oftel’s consultative document on the Numbering Scheme this summer.
7.11 Oftel will consult further with the industry on the issue of access by ISPs to interconnect interfaces. It will do this through the Service Provider Interest Group which has recently been established under the Network Interoperability Consultative Committee (NICC), but would also welcome views on this issue.
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ACC Long Distance UK
AT&T Communications
Barclays Network Services (confidential response)
Bonneller Communications
BT
Cable Communications Association (CCA)
Cellcom
DIALnet
Direct Marketing Association (DMA)
Electricity Association
Energis
Federation of the Electronics Industry
ICSTIS
ICTOS
Imminus
Interactive Media Services (IMS)
International Integrated Information Systems Services (IIISS)
Internet Services Providers Association (ISPA)
Ionica
London Internet Exchange
Mercury One 2 One (MOTO)
Mercury Communications
MFS Communications
Network Outsourcing Association (NOA)
North-West Net
Northern Ireland Advisory Committee on Telecommunications
NTL
Orange
Police National Network (PNN)
Purbeck & East Dorset Telecom Advisory Committee
Racal Network Services
Reuters
Scottish Advisory Committee on Telecommunications
Technocom
Telecommunications Managers Association (TMA)
Telecommunications Users Association (TUA)
The Internet in Nottingham
Torch Telecom
U-NET
WorldCom
XARA Networks
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B.1 In Part 1 of Schedule 1, paragraph 1 (yA) of Condition 1 shall be deleted and the following shall be inserted:
“ ‘Relevant Service’ means any service which is provided by means of the Applicable Systems, not being a service which consists wholly in the provision of any Network Service as defined in Condition 18.3;”
B.2 In Condition 15, paragraphs 15.3 to 15.9 inclusive shall be deleted.
B.3 In Condition 18, paragraph 18.3:
(1) The following shall be inserted after the definition of ‘Apparatus Supply Business’:
“‘Network Service’ means any service which is provided by the Licensee by means of the Applicable Systems in relation to which the following provisions apply:
(a) the service consists in the provision of a Basic Conveyance Service and any other service necessarily incidental thereto; or
(b) the Licensee is able to provide the service, being one which could not practicably be provided in identical form by any other person, to any End-user solely by virtue of providing a Basic Conveyance Service to that End-user; or
(c) the service is one which the Director and the Licensee have agreed, following consultation with Interested Parties, should be provided by the Licensee as a Network Service;
‘Basic Conveyance Service’ means a telecommunication service consisting in the conveyance of Messages, including switching incidental to such conveyance;
‘End-user’ means any person running a telecommunication system authorised to be connected to the Applicable Systems, not being a person running a telecommunication system under a licence granted individually by the Secretary of State under section 7 of the Act;
‘Interested Parties’ has the same meaning as in Condition 16B.10. ”
(2) Sub-paragraph (d) of the definition of ‘Systems Business’ set out in paragraph 18.3 shall be deleted and the following shall be inserted:
(3) The following shall be inserted after paragraph 18.3:
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(a) services coming under category (a) of proposed Condition 18.3:
Basic Voice Telephony
ISDN Bearer Services
Telex
Private Circuits, including access to satellite uplinking and other broadcasting services
Basic X25
Basic Frame Relay
SMDS
Broadband ISDN Bearer Services (ATM)
Aeronautical and Maritime equivalents of the above
(b) services coming under catgory (b) of proposed Condition 18.3:
PSTN and ISDN supplementary services (except Call Minder)
ISDN D Channel access
‘No ring’ calls
Data over voice
(c) services proposed to be included under category (c) of Condition 18.3:
Number Translation Services
Calling Card Services
Personal Numbering Services
Virtual Private Networks
Centrex
Managed Bandwidth Services
Operator Services
Services currently provided from the Systems Business, but to be provided from the Supplemental Services Business under proposed Condition 18.3:
Redcare Alarms
Oftel is still considering whether the following services should be provided from the Systems Business or the Supplemental Service Business:
<Internet Protocol Transport
Call Minder
Directory Enquiries