PRICING OF TELECOMMUNICATIONS SERVICES FROM 1997
Controls and Consultative Document on BT Price Interconnection
Charging
CHAPTER 8 SUMMARY OF QUESTIONS
8.1 This document seeks views on the issues which Oftel must consider
in its review of price control arrangements from August 1997.
The following is a summary of the questions raised in the document
on which Oftel invites comments:
Chapter 2 - Objectives
8.2 In light of its goal, its key objectives, and the range of
other regulatory instruments it can apply for different purposes,
Oftel's central objectives in this price control review are:
- to protect customers in markets where competition is not yet
effective, and
- to promote maximum efficiency in BT.
A secondary objective will be
- to chose a price control structures which, where appropriate,
furthers Oftel's objective of fair trading.
and, subject to consultation, it may be possible that price controls
will help
- to ensure all customers share the benefits of competition.
Oftel recognises that the effect of price controls on the development
of network and service competition cannot be ignored but these
considerations will not drive Oftel's decisions in this review.
8.3 Oftel welcomes views on this initial position.
Chapter 3 - Overview of Competition (Past, Present and Future)
8.4 Oftel would welcome comments on:
- The approach it has adopted for defining markets and for assessing
the degree of competition in those markets.
- Whether the separation of: local and long-distance calls;
and the separation of the provision of access and call services
is valid for the purposes of evaluating and monitoring effective
competition.
- The extent to which the emergence of services based on the
convergence of delivery technologies needs to be considered in
the context of this price control review and whether it is correct
at the current stage of market development to treat the broadcasting
and telecommunications markets as separate markets.
- Whether the customer groupings set out in annex C are most
appropriate for considering the impact of competition.
- The likely extent and pace of competitive developments, their
impact on the scope of the price control framework for the next
price control period from 1997 and Oftel's analysis of the potential
development of competition in Annex C.
8.5 The following further questions on effective competition related
to specific services are contained in Annex C. Oftel would welcome
comments on:
- The extent to which effective competition in the provision
of access services is likely to develop across different customer
groups and across different geographical areas in the future.
- The extent to which the market for inland calls is likely
to become fully competitive for all customer groups over the next
price control period.
- The impact on competition in the provision of IDD calls of
one-end breakout into the PSTN. It would also welcome views as
to the extent to which the IDD market is likely to become fully
competitive for all customers during the next price control period.
- The extent to which there will be effective competition in
the provision of Operator assisted/DQ calls taking into account
Oftel's proposals for stimulating competition in this area.
- Whether there is likely to be effective competition in the
provision of specially tariffed services and in particular the
extent to which competition will depend upon the implementation
of number portability for these services.
- Whether it is appropriate to make a distinction between digital
circuits with a capacity of more than or less than 64kbit/s for
the purposes of assessing effective competition. For instance,
would it be more appropriate to make a distinction based on circuits
up to 64kbit/s, circuits of between 64kbit/s-2Mbit/s and circuits
over 2Mbit/s?
- Its analysis of the prospects for competition in the provision
of low capacity inland private circuits.
- Whether corporate customers possess a degree of buyer power
in the msrket for high cspscity private circuits, and whether
there will be effective competition in the provision of high capacity
private circuits.
- The degree to which there will be effective competition in
the provision of high and low capacity international private leased
circuits over the next price control period.
- Whether it is appropriate to distinguish between vision circuits
and other private circuits and, if so, whether there is likely
to be effective competition in the provision of vision circuits.
- Whether it is appropriate to distinguish private circuits
used to provide CCTV services from other private circuits and,
if so, whether there will be effective competition in the provision
of these circuits.
- Its analysis of the market for telex services.
- The prospects for the development of effective competition
in the provision of payphones in the future.
- Whether there will be effective competition in the provision
of ISDN lines in the future.
- Whether it is appropriate to regard Value Added and Data Services
markets as being competitive at present and whether they are likely
to remain so.
- The extent to which there is effective competition within
the mobile sector. It would also welcome comments on whether the
possible convergence of fixed and mobile services might raise
issues which should be addressed in this price control review
and, if so, what they are.
Chapter 4 - General Issues in Price Cap Regulation
- 8.6 Oftel would welcome comments on:
- Its inclination not to consider the introduction of a global
price cap.
- Its view that it remains appropriate for the price control
to be based on the RPI. Also on possible alternatives, for example,
use of the RPI in addition to some other index.
- Its view that new services should not be price capped, and
on how new services should be defined for this purpose.
- How far it is appropriate to allow, in setting the price cap,
for the benefits to BT from economies of scope derived from the
introduction of new services.
- Its view that the present system should not be modified to
introduce an explicit profit sharing element.
- Its view that allowance should not be made in the price cap
for unanticipated growth in GDP or other exogenous factors.
- The appropriate duration of the price cap.
- The introduction of "roll-over" arrangements.
- Its preference to continue with a prior year revenue weighting
system for a network price cap.
- Its view that it is appropriate to make arrangements for carry-over
in future price control rules and that present arrangements should
therefore continue.
- Its belief that the best approach is to set X so that the
expected rate of return reaches an acceptable level by the end
of the price control period.
- The best way of ensuring that BT achieves the outputs implicit
in the levels of investment allowed for in setting the price cap.
Chapter 5 - Interconnection and Network Price Cap
8.7 Oftel would welcome comments on:
- Its proposal to introduce a general network charge control
on BT's interconnection charges, and on the division of the services
into four distinct categories based on the level of competition.
- The scale and range of costs likely to be considered as common
costs; whether BT should be able to vary the degree of recovery
of common costs; the criteria that should be used to assess to
which services this flexibility might apply; and the use of components
as the chosen level of disaggregation.
- The proposed methodology to calculate incremental costs which
is set out at Annex D.
- Its proposal to include safeguards on the charge for each
prospectively competitive interconnection service; the proposals
that the 'lid' should be set at RPI+0%; and on the services that
should be covered by the safeguards.
- Its definition of call termination, its proposal for a sub-cap
to regulate BT's charges for those services, and on their exclusion
from the flexibility BT may have in setting other charges.
- The need for changes to the regulation of call termination
charges on the networks of other operators than BT, and on the
form that any such changes should take.
- The range of interconnection services that should be included
in the BT network charge cap basket.
- Its proposal to use ceilings and (guideline) floors to restrict
BT's charges for network components and on Oftel's proposals on
the burden of proof.
- How far and in what ways charge controls should cover the
quality aspects of BT's network services.
- Whether adjustments to asset values should be part of the
charge control calculation and on Oftel's proposed approach.
- The interaction between network and retail price caps and
on mechanisms to ensure compatability.
Chapter 6 - Form and Structure of Retail Price Control
8.8 Oftel would welcome comments on:
- The suggestion that three groups of retail markets should
be distinguished and that a 'safeguard cap' should be applied
to those newly removed from the basket. Should this safeguard
cap be set at RPI+0% or should it take account of expected price
or cost movements.
- The possible removal of IDD calls from the price control basket.
If so, should IDD be made subject to a maximum increase of RPI+0%,
and should this 'safeguard cap' be applied to each individual
price or to IDD calls in aggregate.
- The possible removal of Operator Assisted Calls/DQ and Specially
Tariffed Voice Services from the basket. If so, should such services
be subject to a maximum price increase of RPI+0%, and should this
'safeguard cap' be applied to each individual price or to these
services in aggregate
- The appropriateness of including calls to mobile in BT's price
cap and how this might best be done.
- The proposal not to cap payphone prices but to link them to
the price of other calls. How should this be done?
- Its inclination to include ISDN prices in the new price control.
If included, should they be placed in a separate basket or in
the main PSTN basket?
- Its belief that the approach outlined in the August document
on the regulation of broadband switched mass market services,
principally that the prices of such services should not be capped
unless it proves necessary to do so, is correct.
- Whether, and under what circumstances, it might be appropriate
to introduce separate price control arrangements for business
and residential services and what monitoring would be necessary
to ensure that there was no dispraportionately negative effect
on particular groups.
- The proposal to retain controls on analogue and low capacity
digital private circuits but to subject prices of high capacity
digital private circuits only to a safeguard cap. Also on the
level of any safeguard cap and on whether limits on individual
private circuit prices should be retained.
- The proposal to continue control of prices of international
private circuits and on whether provision should be made to remove
the control if the market becomes sufficiently competitive.
- The proposal to retain separate caps for analogue (including
low capacity digital) and high capacity digital private circuits
and for international private circuits.
- The proposal to subject vision circuits to price control and
on whether they should be subject to an individual price cap.
- Whether any new tariff packages offered by BT in the context
of the lifting of the constraint on line rentals should be brought
within the price control basket.
- Whether, as part of future controls on BT's prices, specific
limits should be put on the effect of price changes on the Median
Residential Bill or on other representative customer bills. Also,
on whether and how the customer groupings outlined in Chapter
6 could provide a useful basis for monitoring BT's price changes.
- Its proposal not to introduce a formal quality requirement
into price control arrangements and to instead promote quality
improvements through the strategy set out in Chapter 6. Also on
Oftel's suggested approach to monitoring BT's quality of service.
Chapter 7 - Financial Forecasts over the Next Price control
Period
8.9 Oftel would welcome comments on:
- Its proposed range for the pre-tax weighted average cost of
capital for BT, the assumptions that lie behind the choice of
this range, and the size of any adjustment necessary to arrive
at a cost of capital for the price-controlled activities.
- The most appropriate methodology for calculating the rate
of returns on different activities in order to compare it to estimates
of the cost of capital for those activities. Also on how a change
in the basis of regulation to CCA or economic rates of return
could be reconciled with the HCA rates of return which BT reports
to its shareholders and the wider community.
- The likely trends in demand in the main service markets identified
in Chapter 3 (both network and retail) over the next control period.
Also on the likely scale of demand for important new telecoms
products that may appear over the period.
- The efficiency improvements that could be expected of BT in
its network and retail activities over the next price control
period.
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