Summary

Chapter 1 Introduction

Chapter 2 Responses to consultation and Oftel's view on the issues raised

Chapter 3 Director's decision

Annex A New CPS Functional Specification

Annex B List of respondents

S.1 In July 2002 Oftel issued a Statement and further consultation on inclusion of directory enquiries within the carrier pre-Selection 'all calls' option. That consultation sought stakeholders' views on a proposal to include the new Directory Enquiry (DQ) codes in the range 118XXX within the carrier pre-selection (CPS) 'all calls' option.

S.2 Oftel did not seek views on the inclusion of the old DQ codes 192 or 153 within 'all calls', as it had already consulted on this and had decided not to include them within 'all calls'.

S.3 Under the previous arrangements, a customer who had the CPS 'all calls' option would not have their calls to any DQ services (either 192, 153 or the new 118XXX services when launched) routed to their CPS operator (CPSO). Instead, the calls will be routed to their access operator (at this time BT is the only access operator actively offering CPS).

S.4 Under Oftel's proposal, calls to 118XXX would be routed to the CPSO, and so would appear on a customer's CPS bill rather than their BT bill. Oftel received 6 responses to its consultation, 4 were against Oftel's proposal, and 2 (including one joint response) were in favour. The responses, and Oftel's comments on the issues raised, are summarised in Chapter 2.

S.5 After considering the responses, Oftel has decided to include 118XXX within CPS 'all calls'. The reasons for this are set out in detail in Chapter 3. However, Oftel will reassess this decision 12 months after 118XXX becomes available to 'all calls' customers. If, in Oftel's view, it appears that the introduction of 118XXX within CPS 'all calls' has had a significant negative impact upon DQ competition (for example because CPS operators do not offer access to DQ services other than their own, or impose excessive retail prices for doing so) then Oftel will reconsider the matter. If necessary, Oftel could seek to amend the Functional Specification again through a consultation to remove 118XXX calls from the CPS ‘all calls’ option, alternatively Oftel may pursue the opening of 118XXX codes on CPS operators’ networks through other means.

Chapter 1

Introduction

1.1 This statement is in response to Oftel's July 2002 Statement and further consultation on inclusion of directory enquiries within the carrier pre-selection 'all calls' option (the 'July 2002 consultation'). The July 2002 consultation asked stakeholders to consider whether the new number range to be used for Directory Enquiry (DQ) services, '118XXX' , should be included within the Carrier Pre-Selection (CPS) 'all calls' option. In order to allow this to happen, Oftel would need to amend the CPS 'Functional Specification'.

Carrier pre-selection background

1.2 The CPS Functional Specification is a document referred to in the Telecommunications Act Licences of BT and Kingston Communications. It specifies technical and other principles to enable the efficient implementation and utilisation of CPS in the UK. It is published by Oftel from time to time after consultation with the Licensees and other interested parties.

1.3 CPS is a mechanism which allows users to select alternative operators in advance without dialling additional codes on the telephone. The customer subscribes to the services of one or more CPS operators (CPSOs) and chooses the type of calls (eg all national calls) that will be routed through the alternative operator. For further background information on CPS please see Oftel’s website at www.oftel.gov.uk/ind_info/network_inter/cps_icps.htm.

1.4 There are three types of call option under CPS, these are:

• national calls (this does not include local calls, international calls, calls to mobiles or calls to non-geographic numbers including the ‘national rate’ 0870 range);
• international calls (calls to the Republic of Ireland and overseas); and
• ‘all calls’ (including international, national, local, mobile, and non-geographic – eg freephone, local rate, national rate, premium rate, personal and paging numbers).

1.5 A user can have both the national and international options at the same time, either from the same provider or from two different providers. The ‘all calls’ option cannot be combined with any other option. The proposal in the July 2002 consultation was to include 118XXX calls within the 'all calls' option only. The existing DQ codes, 192 & 153, are specifically excluded from the CPS Functional Specification. They will remain excluded until their withdrawal in August 2003.

 Competition in directory enquiries

1.6 At present, consumers are only able to use the DQ service provided by their network operator. This is typically done through the 192 code (for national DQ) or 153 (for international DQ). Independent DQ service providers would like to offer their services in competition with the existing network operators. However, there are not enough short codes to go around all interested parties. Therefore independent DQ service providers have had to use longer numbers.

1.7 In September 2001, following public consultation, Oftel set out its proposals for the future of directory enquiry services. (Access codes for directory enquiry services: A statement issued by the Director General of Telecommunications is also available online at www.oftel.gov.uk/publications/numbering/denq0901.htm.) Oftel concluded that a model of service-based competition, with all operators and service providers on an equal footing will provide the best deal for the consumer in terms of price, quality and choice of service. To implement this, Oftel has introduced a new range of 'type B' access codes, 118XXX, for access to DQ services. Access codes in the new range have been allocated to eligible individual DQ service providers (including network operators and independent service providers).

1.8 According to the industry project plan for the implementation of 118XXX codes, the first services are likely to go live in December 2002. The old DQ access codes (such as 192 and 153, as well as codes not used on BT's network like 142) are scheduled to be withdrawn in August 2003. For further information on the changes to DQ services, please see Oftel’s website at www.oftel.gov.uk/ind_groups/dq_group/index.htm.

 Consultation

1.9 In December 2001, Oftel consulted on the possible inclusion of 192 and 153 within the CPS 'all calls' option (Consultation on proposed inclusion of Directory Enquiries within the Carrier Pre-Selection 'all calls' option).

1.10 In its July 2002 statement and further consultation, Oftel explained that it would not be seeking to include 192 & 153 within 'all calls'; Oftel was of the view that the limited remaining lifespan of 192 would mean there would only be limited, if any, benefits in its inclusion.

1.11 Oftel did not consult on the inclusion of 118XXX within 'all calls' in the December 2001 consultation. This was because, at the time, Oftel believed that competition in the new 118XXX arena might be negatively affected by including 118XXX within 'all calls'. However, having considered the matter of 118XXX further, in the July 2002 consultation Oftel took the view that inclusion of 118XXX might be in the consumer's long-term interest and therefore sought to consult on the proposal.

 Consultation questions

1.12 Oftel was of the view that, as a general principle, all number ranges should be included within 'all calls' unless there were compelling reasons otherwise. However, Oftel had concerns about the possible impact upon the development of competition in the DQ sector (and therefore upon the benefits consumers might expect to receive) if 118XXX was so included. Oftel asked for stakeholders' views on the likely impact of 118XXX within 'all calls' and for opinions on the range of DQ services that might be open to CPS 'all calls' customers.

 Summary of responses

1.13 BT, a number of DQ service providers and SACOT (the Scottish Advisory Committee on Telecoms) were opposed to the inclusion of 118XXXcodes within 'all calls'. A joint CPS operator response was in favour of the proposal, and Reach Telecom also supported aspects of Oftel’s proposal. A further joint CPS operator response was submitted as 'comments on comments' after the initial consultation period had finished. Oftel received no confidential responses. All responses are available on line at www.oftel.gov.uk. Annex B contains a list of all the respondents.

 Director's decision

1.14 118XXX will now be included within the 'all calls' option. Oftel believes that this option is preferable because it removes an inconsistency in the definition of 'all calls' CPS. More broadly, this decision should help to develop the CPS market, and thereby benefit end-users. Oftel believes that significant diminution of competition in the market for DQ services, or significant disbenefits to the users of DQ services as a result of this change are unlikely. In particular Oftel notes that CPS operators will have commercial incentives to ensure that the new 118xxx codes are available on their networks. This will result, first, from the extensive advertising that is likely to surround the new DQ codes, second because CPSOs will receive call conveyance payments each time the services are used, and third because by carrying as many of the new 118 DQ codes as possible, CPSOs will ensure that their call service offerings to end-users remain as competitive as possible with those of access operators.

1.15 In order to provide reassurance to consumers and to the industry, Oftel will reassess the situation 12 months after 118XXX is available within 'all calls'. If, after this time, Oftel believes that there has been a significant negative impact upon competition in DQ services because of this inclusion (for example because CPS operators do not offer access to DQ services other than their own, or impose excessive retail prices for doing so), Oftel will reconsider its position. If necessary Oftel will re-consult on the matter or take other steps to ensure that the inclusion of 118XXX calls within the CPS ‘all calls’ option does not have a significant negative impact on the development of competition for DQ services. At that stage, Oftel expects that clearer evidence will be available to present to stakeholders and enable a more informed choice.

 Timeframe for implementation

1.16 Oftel understands that BT will need to carry out work in a number of areas to ensure that 118XXX calls are included within 'all calls'. It is Oftel's understanding that this work is unlikely to be completed before December 2002. Therefore, for an interim period 118XXX will still appear on an 'all calls' customer's BT bill. Oftel will work with BT & CPSOs via the CPS Commercial Group to ensure the work required is given the appropriate level of priority.

1.17 Oftel has agreed to reassess the impact of including 118XXX within 'all calls' 12 months after work is complete. It is possible that OFCOM may be in operation within this timeframe (see www.communicationsbill.gov.uk/ or www.ofcom.gov.uk for further information on OFCOM). Stakeholders should be aware that this is an Oftel statement and that OFCOM may take a different policy approach.

Chapter 2

Responses to consultation and Oftel's view on the issues raised

2.1 Oftel received 6 responses within the consultation period. Oftel also received 1 response as 'comments on comments'. Oftel also received a response during the 'comments on comments' phase which was more appropriate to the initial consultation phase (see other comments below).

BT

2.2 In its response BT said it was unconvinced that the inclusion of 118XXX numbers within ‘all calls’ will contribute to the development of competition in DQ services. Oftel agrees that there is unlikely to be a positive impact upon DQ competition. However, the key factor for Oftel is whether there is a risk of a significant negative impact upon DQ competition. (Oftel believes that the inclusion of 118XXX numbers within ‘all calls’ will be of some benefit in the call origination market as the ‘all calls’ option may become more desirable, and there should be reduced consumer confusion in the medium-to-long term – which is why Oftel on balance has decided to make the proposed change to the Functional Specification.)

2.3 BT pointed out that the average household spend on DQ was only 60p per quarter, and hence was of the view that CPSOs restricting access to DQ Service Providers would be unlikely to suffer from any substantial negative consumer perceptions as a result of this restriction. Therefore, there would be little incentive on CPSOs to open their networks to as many DQ Service Providers as possible.

2.4 Whilst Oftel accepts that the average spend is indeed low, Oftel’s own research suggests that there is quite a wide spread in terms of consumer patterns of use of DQ (see www.oftel.gov.uk/publications/research/2001/q3fixr.htm). CPSOs have little way of knowing which consumer is likely to spend more on DQ services, other than through market research such as Oftel’s. Oftel’s research at least showed that so called 'ABC1' and younger consumers were more likely to use DQ services regularly. Similarly, Oftel believes that these consumers are more likely to be targeted by CPSOs.

2.5 BT was also of the view that consumers must have access to at least one DQ service. It felt that, under Oftel’s proposals, it was possible that consumers might be left without access to a DQ service. Oftel recognises that the CPS override is not an ideal solution (for gaining access to a wide range of DQ services), but it does ensure that customers have access to at least one, if not many (following 118XXX’s introduction) DQ services. BT also queried what the arrangements would be for future Wholesale Line Rental (WLR) products. If an override (such as BT’s 1280) was not available under WLR, BT suggested that CPSOs must make at least one DQ code available. Oftel thinks it is highly unlikely that any CPSO would choose not to make any DQ service available. Oftel agrees it would be unacceptable for consumers to be left with no DQ service, even via an override, and will take the matter further in the industry discussions on WLR.

2.6 BT also noted that the work required to include 118XXX within ‘all calls’ was unlikely to be completed before 10^th December 2002 (the launch date for 118XXX). Oftel will discuss the prioritisation of CPS work within the appropriate industry fora to ensure 118XXX is made available within ‘all calls’ as soon as is practically possible.

2.7 Because of its own concerns, and those raised by BT and other stakeholders, Oftel has agreed to revisit the matter 12 months after 118XXX is first available within 'all calls' to make sure that DQ competition has not been significantly impacted by the inclusion of 118XXX within ‘all calls’.

Conduit

2.8 Conduit's principal concern was that the inclusion of 118XXXwithin 'all calls' would have a negative impact upon competition in DQ services. Conduit believes that, because of the low volume of DQ calls as an overall percentage of call volumes, DQ service providers will not be in a strong position to force CPSOs to open competing 118XXX codes on their networks. Furthermore, Conduit was of the view that, as a result of the likely interconnection arrangements in place, calls were likely to cost more for a CPS customer then they would for an equivalent call made using BT.

2.9 In Oftel's view the possibility of higher prices for some services or types of call from a CPSO is an existing aspect of the market place. For example, some CPSOs charge less than BT for international calls, but more for calls to mobiles. If well informed consumers choose to use a provider who is cheaper than BT for some types of calls, but more expensive for others, that is a consumer's prerogative to choose based on their anticipated pattern of usage.

2.10 Oftel does have concerns about consumer choice being restricted, or retail prices being unjustifiably higher on CPS networks, and this is why Oftel will reassess the situation 12 months after the inclusion of 118XXX numbers within 'all calls'.

2.11 An additional concern raised by Conduit was with regards to Oftel's comments on the use of the BT override code to access any DQ services available on BT's network but not on a CPSO's. In Conduit's view, Oftel's 'proposed solution', using the override would be impractical and confusing, especially for less frequent users of the override and / or DQ services. Oftel does not regard this as a long term solution, but notes it could be used as a stop-gap whilst the market was settling down or a consumer had a particular need to access a particular service not available on their CPS network. Oftel also notes that less frequent users of DQ services are, by definition, likely to have a less significant impact upon competition in the DQ market.

2.12 Conduit's response also stressed the potential for additional consumer confusion by including 118XXX within all calls whilst 192 was excluded. Conduit suggested that, if Oftel were to go ahead with its proposal, 118XXX should only be included after parallel running was complete (August 2003).

2.13 Oftel accepts that there may be some confusion regarding the status of 118XXX with regards to CPS whilst 192 is excluded. However, Oftel is of the view that most 'all calls' customers probably believe DQ calls are already included within CPS. Therefore, Oftel believes any confusion of the sort identified by Conduit would be outweighed by the opposite effect - namely consumers believing 118XXX should appear on their CPS, as opposed to their BT, bill. In addition, at this time Oftel does not have a firm timeframe from BT as to how long the necessary network work required to include 118XXX within all calls will take. Oftel proposes that this should take place as soon as is practically possible.

Joint industry (CPS operators) response

2.14 The joint response was firmly of the view that 118XXX should be included within 'all calls'. The joint respondents argued that there were two principle reasons why CPSOs would allow access to the full range of DQ services on their networks. CPSOs could expect to benefit from call conveyance revenues (even without direct negotiation between CPSO and DQ service provider) and from a perceived increase in customer service levels (by appearing to offer a more comprehensive service).

2.15 Oftel accepts that direct negotiation is not fundamental in opening 118XXX codes on CPSO networks. Oftel does remain concerned that there is an opportunity to reduce consumers' choice. However, Oftel is prepared to give the industry an opportunity to demonstrate that it will not seek to do this.

2.16 In response to concerns that the sheer number of both CPSOs and DQ service providers would create practical problems in opening up the full range of services, the joint response said that the respondents did not believe that DQ service providers would need to enter into agreements with each CPSO. Rather, they were of the view that DQ SPs could access CPSO networks through interconnection arrangements through transit operators. It was noted that existing Premium Rate Service (PRS) arrangements do not demand that every PRS service provider negotiate directly with each CPSO.

2.17 The joint industry response also suggested that the cost of carrying out the changes needed to implement Oftel's proposal should be included in Oftel's forthcoming general review of CPS costs. Oftel's initial view is that this might be an appropriate way forward, but Oftel will discuss the matter further within the appropriate industry groups.

Reach telecom

2.18 Reach argued that consumers, once signed up for 'all calls', expect to be billed for DQ services by their new calls provider. They also argued that consumers should not be limited in who they actually pay for their DQ calls (i.e. their calls provider) as well as not being limited in their choice of actual DQ service provider.

2.19 Oftel accepts that the majority of consumers (who were unaware of the current exclusion of DQ calls from 'all calls') would probably expect that these calls were included in 'all calls'. Oftel also accepts that, in the absence of a pressing rationale otherwise (such as the exclusion of 999 calls), 'all calls' should indeed include all call types.

2.20 However, as mentioned elsewhere, Oftel does remain concerned about the potential impact of the proposal upon competition in DQ services, and so will reassess the situation 12 months after the inclusion of 118XXX within 'all calls'.

2.21 Reach also said they did not believe that a CPS service provider should be forced to offer a DQ service to its customers. Oftel's understanding is that this means a service provider should not have to have an own-branded service. Oftel does not require service providers to offer their own branded DQ service and does not believe such a requirement is necessary due to the wide range of alternative DQ services that are likely to be available in the future.

2.22 Reach also had a concern about the opening up of 118XXX codes on mobile networks. This concern was outside the scope of this consultation, but Oftel has commented on its wish to see all DQ codes available on all networks; for further information see www.oftel.gov.uk/ind_groups/dq_group/index.htm.

 SACOT

2.23 SACOT expressed particular concerns about the ability of CPSOs to limit competition by, for example, entering into an exclusive agreement with a particular DQ SP. SACOT acknowledged that a consumer in such a situation could use the CPS override, but pointed out that this was complicated and the average consumer was only an occasional user of DQ (and therefore unlikely to go through such a procedure).

2.24 SACOT did not believe it was realistic for Oftel to require all network operators to open all codes on their networks; indeed it was not sure that Oftel would have the power to do this anyway.

2.25 Oftel shares SACOT’s concern about the potential for CPSOs to limit DQ competition on their networks. Oftel also acknowledges that the CPS override is unlikely to be a useful method of avoiding this potential problem, as it is quite cumbersome. However, Oftel also notes that any CPSO seeking to seriously restrict the range of DQ services available on its network does run the risk of being perceived as having a less attractive offering then other networks. CPS operators have stated in their joint response to Oftel’s consultation that there are strong incentives on CPS operators to carry a range of DQ 118 services. In any case, Oftel intends to review its decision 12 months after the introduction of DQ 118 calls within CPS to ensure that CPSOs are indeed offering an acceptable range of DQ 118 services other than their own.

2.26 Oftel believes its proposal, to allow 118XXX into ‘all calls’, but to reassess the situation in 12 months time, gives ample time for CPSOs to demonstrate that they will not restrict competition in DQ services.

 Telegate

2.27 Telegate suggested there may be resource issues for some of the smaller DQ SPs in dealing with a large number of CPSOs. Oftel accepts that there may indeed be resource issues for the smaller players, but believes this is an unavoidable aspect of a competitive marketplace. The UK market for DQ services is large and likely to be contested by many SPs, it could also be said that those with the largest marketing budgets or past experience in this area are likely to be in a stronger position than those without.

2.28 Telegate expressed a concern about possible fraudulent behaviour, arguing that CPSOs might be able to route calls directed at any 118XXX code to their own choice of service. Quite apart from the technical problems with such activity, Oftel believes such behaviour is highly unlikely as it may contravene CPSOs’ licences and generate significant adverse publicity.

2.29 Telegate's chief concern was that a CPSO might deliberately seek to limit the range of DQ services available on their network, with the hope of forcing consumers to use a CPSO's preferred DQ service. Telegate argued that, if Oftel were to go ahead with its proposal, Oftel should force CPSOs to open all 118XXX codes on their networks.

2.30 Whilst Oftel shares Telegate's concern that a CPSO might potentially limit the range of codes available on its network, Oftel does not plan to force all 118XXX codes onto CPS networks at this time. At present, Oftel does not force CPSOs to complete to any number and is not convinced that a change in this policy would be appropriate at the present time. However, as stressed elsewhere, Oftel will review the situation and, if necessary, take action to ensure CPS 'all calls' customers have a reasonable choice of DQ service.

 Comments on comments received

2.31 The joint industry respondents also submitted comments on comments received.

2.32 The respondents did not believe that CPSOs would introduce excessive costs into the network element of DQ call charges. Furthermore, they were of the view that CPSOs in a competitive market could not afford to charge substantially more for some services than their rivals as customers would go to those CPSOs who priced more competitively.

2.33 Oftel still has some concerns that CPSOs might seek to either restrict access to DQ services or set unreasonably high retail prices for them. Oftel notes the concerns raised by others that the impact of DQ prices on a consumer's choice of CPSO was unlikely to be significant. However, with the introduction of 118XXX there is likely to be much more publicity surrounding DQ services, and an attempt to block access to popular 118XXX codes or to attempt to charge significantly more then the equivalent service on other networks is likely to attract at least some adverse publicity.

2.34 With respect to concerns over consumer confusion, the joint response noted that the respondents believe many customers would assume that DQ was already included within 'all calls'; and that therefore stopping 118XXX from going into 'all calls' on the basis that consumers would be confused would be counter-productive. Oftel agrees with this position, although it does accept that there is likely to be some small degree of confusion no matter which option was taken. However, Oftel does not believe this will be of any serious inconvenience to consumers and Oftel's consumer guide to CPS will be updated appropriately.

Other comments

2.35 One DQ SP wrote to Oftel during the comments on comments period, although its comments were addressing the issues raised in the consultation rather than other comments received and was therefore outside the appropriate deadline. However, the issues raised by the DQ SP were very similar to those raised by other respondents and Oftel believes all the points raised have been responded to above.

2.36 In addition, one CPSO wrote to Oftel after the consultation deadline stating that it did not support the joint industry response. That CPSO said it would detail its disagreement with the joint industry position in future correspondence with Oftel (at the time of writing it had not done so).

Chapter 3

Director's decision

3.1 Oftel believes that, in general, all number ranges should be included within CPS 'all calls' unless there are clear reasons otherwise (for example calls to the emergency services or to Indirect Access codes).

3.2 Oftel considered that there might be reasons for excluding 118XXX from CPS 'all calls'. This was because Oftel was concerned that competition in DQ services might be adversely effected if CPSOs did not open up a range of DQ services on their networks, or sought to set excessive retail prices for those services.

3.3 However, Oftel remains of the view that 118XXX calls should be within 'all calls'. It is Oftel's view that new number ranges, should, in general, be included within 'all calls' unless there are compelling reasons otherwise. However, Oftel still has concerns that CPS 'all calls' customers may not have access (unless they use the BT override code) to the full range of DQ services available to other consumers, or may end up paying excessive retail prices. Therefore, Oftel will amend the CPS Functional Specification to include 118XXX within 'all calls', but will closely monitor developments in the market to ensure that DQ competition is generally available to CPS consumers.

3.4 Oftel proposes re-examining the issue 12 months after the introduction of 118XXX within 'all calls'. If it appears to Oftel that the introduction of 118XXX within CPS 'all calls' has had a significant negative impact upon DQ competition then Oftel will reconsider the matter. If necessary, Oftel could seek to amend the Functional Specification again through a consultation to remove 118XXX calls for the CPS ‘all calls’ option, alternatively Oftel may pursue the opening of 118XXX codes on CPS operators’ networks through other means.

3.5 Oftel notes that the new European Directives will be in force 12 months after the introduction of 118XXX within the CPS ‘all calls’ option. Oftel considers that powers will exist under the new European Directives to allow Oftel (or OFCOM) to pursue the opening of 118 numbers on CPSOs’ networks.

3.6 For example, Article 5(1) of the new Access Directive states:

3.7 Oftel believes that a 12 month period after the introduction of 118XXX within ‘all calls’ prior to any review should allow sufficient time for a clearer picture to emerge, this is because:

• DQ SPs and CPSOs will have had sufficient time for negotiations, if needed;
• Parallel running between the legacy DQ numbers and the new 118XXX DQ numbers will have ended, and therefore the majority of new entrant DQ Service Providers will have already entered the market and be up and running with their operations; and
• CPS market growth, even if it matches industry forecasts, will not be so great as to have captured the majority of BT’s customers. Therefore, if DQ Service Providers did have significant problems in offering their services to the customers of CPSOs in this timeframe, there would still be a very large customer base available to them (as well as potential customers on alternative fixed access networks and mobile networks).

3.8 Oftel will reissue the CPS Functional Specification to include calls to the 118XXX range within the CPS 'all calls' option. The new Functional Specification is attached at annex A.

Annex A

New CPS Functional Specification

FUNCTIONAL SPECIFICATION FOR CARRIER PRE-SELECTION (V3)

Definition

Carrier Pre-Selection (CPS) is the facility offered to customers which allows them to opt for certain defined classes of call to be carried by an operator selected in advance (and having a contract with the customer), without having to dial a routing prefix or follow any other different procedure to invoke such routing. CPS can be overridden by dialling an indirect access code of another operator (again where there is a contract between the customer and the operator).

Scope

Carrier Pre-Selection will be provided by the following originating operators:

• BT; and
• Kingston Communications,

on, or as soon as practicable after, 1 January 2000 (subject to any deferment agreed to by the Commission in the light of the timescales needed to introduce the facility, technically and geographically).

CPS facilities will be provided to any operator (referred to as the CPS Operator) which qualifies under Schedule 2 of the Interconnect Regulations and has established Points of Interconnection with the originating operator and been allocated a CPS prefix code and/or a Type B single stage indirect access code by Oftel.

Originating Operators will provide CPS facilities to all customers, on request of CPS operator, on direct exchange lines, including ISDN and Centrex lines (1). CPS will not be provided on public or managed payphone lines or lines on Low User Schemes.

Originating Operators shall support up to 100 CPS Operators on any switch. Where demand appears likely to exceed this limit, steps will be taken to develop further capacity.

Customer Options (2)

Customers opting to use CPS may select from the following options:

Option 1: International Calls
Option 2: National Calls
Option 3: All Calls (to include international, national, local, mobile, specially tariffed (eg freephone, local rate, national rate), premium rate, personal, paging and 118XXX codes for Directory Enquiry services )

If a customer selects Options 1 and 2 they can either have calls from both options carried by the same CPSO or by different CPSOs. In all other cases there is only one CPSO involved.

CPS will not apply to calls using Type A short codes (eg 100, 999, 112, 192), Type C (operator specific) short codes or the 0844 04yyxxx and 0808 99yyxxx number ranges used for unmetered Internet access (with unmetered interconnect).

Where no option is made, relevant calls will be routed according to the decision of the originating operator.

Local calls shall be interpreted as calls to those geographic destinations which are charged at local call rate by the originating operator.

Routing

Where a customer has elected to have calls routed by CPS, the following will apply:

1. calls to ranges subject to CPS (see paragraph six) will be routed according to the customer’s selected CPS Operator to an agreed Point of Interconnection; and

2. calls to ranges excluded from paragraph six will not be affected

Where a call is routed by CPS, the originating operator will prefix the customer’s dialled digits with the ‘CPS access code’ before passing the call across the Point of Interconnection. The CPS access code ensures routing through the originating operator’s network to the Point of Interconnection.

Where a pre-selected call is dialled using the local dialling format, the originating operator will insert the leading zero and area code between the CPS access code and the dialled number.

CPS facilities shall not apply to operator controlled calls, including transfer charge calls. Operator and other special services of CPS Operators will be accessed using the appropriate indirect access code.

A CPS access code will be a four digit non-diallable prefix (3).

Override

Calls made to Type B Indirect Access Codes will override CPS options and route to the operator identified by that code, without alteration to the digit string dialled by the customer (for the avoidance of doubt it should be noted that this does not included 118XXX DQ codes).

Billing

Responsibility for billing the calling customer on CPS and Indirect Access calls rests with the CPS Operator. Where no pre-selection or other form of selection has been made by the calling customer, the originating operator will bill for those calls.

CPS services

CPS calls will be provided as a standard interconnect service to qualifying CPS Operators.

Annex B

List of Respondents

Oftel received six responses to its consultation. The respondents were:

The companies who signed the joint industry response were:

–Cable and Wireless;
– Centrica;
– Colt;
– Energis;
– Kingston;
– Opal Telecom;
– Reach Telecoms;
– Redstone Communications Ltd;
– Telco;
– Telia;
– Thus; and
– Your communications.