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September 2000 Chapter 1 Introduction Chapter 2 Review of existing universal service regime and affordability Chapter 3 Re-evaluation of the costs and benefits of the Universal Service Obligation Chapter 4 Should the level of universal service be revised? Chapter 5 Consultation details Annex A List of respondents to July 1999 consultative document Annex B Glossary S.1 This document sets out Oftel’s conclusions following its 1999 review of the Universal Service Obligation (USO). Comments are now invited on Oftel’s proposals on the operation of the existing obligation, its costs and its scope. In the light of these comments, Oftel proposes to issue a statement in spring 2001 which will set out the level for universal service from September 2001. USO objective S.2 The objective for universal service is to ensure that those telecommunication services which are used by the majority and which are essential to full economic and social inclusion are made available to everybody upon reasonable request, in an appropriate fashion and at an affordable price. The main requirements are for BT and, in the Hull area, Kingston Communications, to provide a telephone line on reasonable request; special tariff packages to assist those people with special social needs, particularly those on low incomes, to obtain basic telephony; and disconnection procedures which provide people with adequate opportunities to pay bills. Operation of existing regime S.3 Independent research between September 1999 and April 2000 assessed how many homes in the UK do not have a fixed line phone; their demographic characteristics; circumstances and special social needs. Currently around five per cent of homes in the UK do not have a fixed line phone, but this varies by geographic region. There is a strong link between low income and absence of a fixed line. There is a high incidence of mobile phone ownership instead amongst those without a fixed line phone (three in five). S.4 Control of expenditure, ease of accessibility and flexibility are vital considerations for low-income users of telephony services. People using a mobile instead of a fixed line are in the main satisfied with the alternative, whereas those using payphones face practical difficulties as well as feeling social isolation. S.5 Oftel’s conclusions are:
The cost of USO S.6 Currently BT and Kingston fund the USO. Under European law a fund can be established, where the costs of USO are shared between all operators, but only if there is a net cost associated which imposes an unfair burden on the USO provider. Oftel’s 1997 review of USO showed a significant net benefit to being a USO provider. From an initial re-evaluation, the 1999 review concluded that the benefits may have reduced but that the USO does not represent a significant net burden on BT and Kingston. S.7 BT and Kingston argue that there is a significant net cost and unfair burden on them arising from the obligation. BT has undertaken its own research from which it has argued that Oftel has overestimated the benefits of brand image. Most other responses either supported Oftel’s conclusions or suggested that Oftel was underestimating the benefits. S.8 Further work is therefore needed and BT and Kingston have offered to provide detailed information. Oftel will then decide whether a full reanalysis of the costs and benefits of providing a universal service is needed and, if there is a net cost, whether this is an unfair burden. Scope of USO S.9 The future scope of universal service is a major issue as new products and services are launched. The fixed analogue network today gives 95 per cent of homes the potential to access the Internet. Innovative charging packages are emerging to promote Internet use. Oftel now seeks views on the minimum data speed required to ensure that all users have the potential for workable and reliable Internet connection. S.10 Oftel supports the goal of rolling out higher bandwidth communications networks. Equitable and affordable access remains at the heart of Oftel’s work to promote the interests of consumers. Oftel is developing a regulatory environment to encourage this. Oftel will keep the relationship between higher bandwidth services and the USO under close review. This will include further research into access to these services and the scope for other regulatory action. An extension of the USO would need to be discussed in the context of the emerging EC framework, impacts on investment, funding, cross-subsidies, consumer demand and means of supply. Oftel will work with Government, industry and consumers on these issues.
Introduction 1.1 The objective for universal service is to ensure that those telecommunications services which are used by the majority and which are essential to social and economic inclusion are made available to everybody upon reasonable request in an appropriate fashion and at an affordable price. This ensures that people on low incomes, in remote rural areas, with disabilities and other vulnerable groups do not miss the advantages of telephony. 1.2 To secure this, obligations are placed on BT and, for the Hull area, Kingston Communications, to ensure that they offer basic telephony services to everyone, upon request, at reasonable prices. These services are described below. 1.3 The current level of universal service was established in 1997 for a four-year period. In 1999 Oftel carried out a mid-term review. This document summarises responses and sets out the findings of the research by Oftel, BT and Kingston Communications. It draws conclusions, makes proposals for the future of the universal service regime and invites comments. 1.4 Since 1997 access to telephony has increased, albeit at a slower rate as universal phone ownership approaches. The growth in mobile phone ownership – over 30 million people now own a mobile phone in the UK – and particularly the pre-paid market means that lack of access to a fixed line need not mean lack of access to affordable telephony. On the other hand, the rise in demand for access to the Internet has emphasised the importance of access to a reasonable speed of data transmission. 1.5 For Oftel it is vital that those with special social needs and/or on low incomes are able to share the wider benefits competition brings with lower prices and more choice. Ensuring access for all, at affordable prices, to services in ways that minimise distortions of competition is central to Oftel’s consumer protection objective. What is universal service? 1.6 Within the framework of EU law, national regulatory authorities must place obligations on designated network operators to ensure that a defined minimum set of services of specified quality is available to all, independent of geographical location, at an affordable price. 1.7 In the UK the obligation is placed upon BT and Kingston Communications to provide:
All consumers should be:
The provision of universal service should be at geographically averaged prices. 1.8 In addition, Oftel has recommended an appropriate level of universal service to meet the needs of people with disabilities. Draft regulations to implement the relevant articles of the Revised Voice Telephony Directive (RVTD) have been published by the DTI and are described in Chapter 2. 1.9 The obligation to provide a connection at a geographically averaged price, as well as adequate public call box provision, falls on BT and Kingston Communications. Services such as free emergency calls and itemised bills are requirements placed on all telecoms operators offering direct residential services. In some cases, such as emergency calls, all operators must provide the service. In others, there is no need to impose a requirement on all providers as long as there is a universal service provider who has the obligation to customers or to an area. 1.10 Universal service providers are required to provide reasonable geographic access to public call boxes (PCBs) across the UK. BT is continuously assessing new locations for PCBs on a commercial basis. In practice some payphones situated in remote rural districts and in some urban areas, where mobile usage is widespread, are or will become uneconomic. Pressure on payphone business may increase as telephone penetration – fixed and mobile – increases. Payphones are of continuing importance for those who are unphoned or disconnected. In the 1997 consultation, BT agreed with Oftel to install up to 500 uneconomic PCBs over five years, subject to pre-agreed criteria. Further details are given in Chapter 2. Future developments 1.11 Technological developments impact on the USO. Mobile phone ownership has increased; about 50 per cent of the population now own a mobile phone. 25 per cent of households have access to the Internet and this will expand rapidly given market developments which make the UK one of cheapest countries in the world for residential consumers. 95 per cent of households in the UK with a fixed line have the potential to access the Internet 1.12 This raises questions about the existing scope, level and funding of universal service. The demand for fast and reliable Internet connection is examined in chapter 4. This chapter also debates the implications for the USO including its possible extension, arising from the rollout of higher bandwidth services and the opening up of BT’s local network to greater competition in 2001. The European framework 1.13 The framework for national rules on USO is set at European level. In July 2000 the European Commission published its proposals for a new framework for electronic communications services including a draft Directive on universal service and users’ rights. This is subject to approval by the Council and European Parliament. The Commission’s aim is to ensure the availability throughout the Community of good quality services via effective competition and choice and to deal with circumstances in which users’ and consumers’ needs are not satisfactorily provided by commercial means. The Directive defines a minimum set of services of specified quality to which all users and consumers have access in the light of specific national conditions at an affordable price. It aims to "adapt and modernise the existing measures on universal service so as to define the scope of the service, the rights of users and the measures for compensating providers of the service without distorting competition". It also aims to "create a process for reviewing the scope of universal service obligations". 1.14 The Commission’s aims are very much in line with Oftel’s strategy.
Review of existing universal service regime and affordability 2.1 In 1999 Oftel asked for comments on:
2.2 This led to further independent research into the demographics of those households without a telephone, and the reasons for not having a fixed line phone. Oftel has also reviewed operators’ credit management procedures and disconnection trends; and obtained additional information from BT and Kingston Communications about the takeup of existing special schemes. The findings are set out below: Homes without a fixed line phone 2.3 The survey of the unphoned in March 2000 (see http://www.oftel.gov.uk/cmu/research/unph0400.htm) found that an average of 5 per cent of the UK population live in homes that do not have a fixed line phone, a fall of 14 per cent since the early 1980s. This varies by geographic region (chart 1). 2.4 The unphoned are generally people with low annual incomes, the unemployed, non-skilled labour, small households (reflecting a high incidence of poorer pensioners and single parent families) and with many living in social housing.
Chart 1: Regional variations in percentage of households without a fixed line phone Impact of mobiles 2.6 In the March 2000 survey of the unphoned, 60 per cent of respondents without a fixed line said they owned a mobile telephone. In a survey in May 2000 this had risen to 70 per cent, which represents about five per cent of homes in the UK therefore relying on mobiles only. 2.7 The main reasons given for using a mobile were convenience and flexibility. Other reasons included:
2.8 50 per cent of mobile users had started using their mobile within the last year. Younger consumers (15 – 34) without a fixed line phone were more likely to use mobile phones (68 per cent compared with the average of 55 per cent). The average monthly spend of around £19.00 compares with fixed line bills of £17.81 per month (in 1998/99). 2.9 This suggests that mobile telephony may be addressing the needs of some of the unphoned. However, the March survey also found that around 20 per cent of the unphoned were dissatisfied with not having a fixed line phone. This suggests that around 500,000 adults without a fixed line phone would like to have one. In addition, there are regional variations in phone usage and satisfaction (see chart 2). Dissatisfaction is higher in Scotland and Wales, (around three per cent) and in East Anglia (two per cent). Households (see paragraph 2.29 below) may also move in and out of fixed line telephony as they are unable to cover costs. 2.10 Oftel has traditionally used the percentage of households with fixed line phones as a measure to test the effectiveness of special schemes. Responses to the consultation indicate that Oftel should retain as an objective increasing telephone penetration rates "until everyone who wants a phone has one". This might suggest the criteria might need to include both fixed and mobile phones. If so, the test as to whether the Universal Service Obligation is being met would need to take account of all forms of telephony (including payphones). 2.11 Oftel welcomes views on:
Special schemes for customers on low incomes BT’s In Contact Plus scheme 2.12 The current BT scheme (In Contact) allows incoming calls only, with outgoing calls barred except to emergency services, 150, 151 and 12822 (Ring me Free). The scheme was launched in April 1998 with a target of 300,000 users. By September 1999, only around 12,000 customers were using the scheme, ie only four per cent of the target figure. 29,000 have used the service to date but the high number of customers leaving the service indicates that for some an incoming calls only service is unattractive while for others it is a ‘stepping stone’ into a standard service.
2.13 BT began trials of a scheme, In Contact Plus, in September 1999 in the Coventry area. This uses a pre-paid card linked to In Contact. Using an access code and a PIN, customers can make outgoing calls, to local and national UK numbers only, at a flat rate of 15 pence per minute. All other calls are barred. The joining fee of £9.99 and quarterly rental of £9.25 are the same as the charges for In Contact. Pre-paid cards in £3 denominations can be purchased at selected outlets. 2.14 Takeup during the trial has been slow even though BT has made efforts to market the scheme. The call charge may be too expensive and there may be difficulties in purchasing cards. Oftel has asked BT to make changes to the scheme and BT intends to combine the In Contact scheme with its newly launched Phonecard Plus product. This will allow customers to use the prepaid card on any phone and at a lower per unit cost. Kingston Communications 2.15 Kingston Communications has developed two schemes, Basic Contact and Basic Call which are similar to BT’s schemes. Basic Contact is an incoming calls only scheme (with the exception of emergency calls and fault repairs) and Basic Call allows for outgoing calls by purchasing a prepaid card. Take up of both schemes has been negligible to date but there is potential for use as an alternative to disconnection and for residential customers who have failed a credit check and cannot afford a security deposit. An on-the-street survey undertaken by Kingston in December 1999 confirmed the attractiveness of prepaid schemes for some of the unphoned. Prepaid schemes – next steps 2.16 The take up of these schemes is very low. The schemes nevertheless meet the needs of some of the unphoned. For example, a survey of In Contact and In Contact Plus users in the trial area found that the key benefit of the pre-paid card was the ability to make outgoing calls, especially for emergencies or special situations. Moreover, the ability to control expenditure enables more customers not only to take on a phone but also to stay on the phone. 2.17 Oftel would welcome an early national rollout of BT’s pre-paid scheme. Oftel will continue to work with BT, Kingston and other government departments to make information about special schemes more accessible. The market may also develop social telephony initiatives and Oftel will ensure that consumers are made aware of these. 2.18 In the short term, the provision of new schemes may involve some additional cost. This should be recoverable through increased revenues from incoming calls and in the longer term as customers (many of whom may be experiencing temporary financial difficulty) move to the standard service, and/or take on additional value added services. Cost savings may result from using pre-paid schemes as a credit management tool. The prepaid approach provides an alternative method of payment for those on limited or fluctuating incomes, avoiding any risk of disconnection of service and associated costs. 2.19 Oftel proposes for pre-paid schemes:
Oftel invites comments. Special schemes for customers on low incomes: BT’s Light User Scheme (LUS) 2.20 The Scheme was launched in 1993 and currently has around 2.4 million customers. Normal rental charge and installation costs apply but users receive a rebate on the rental if call charges are less than £12.00 per quarter. For every 10p that the call charge is less than £12.00, the customer receives a rebate of 12.09p. The maximum rebate is £14.51 where no calls have been charged. If call charges exceed £10.72 on three consecutive bills, the customer will automatically be removed from the scheme but can rejoin if call charges fall back below £12.00 in three out of four successive quarters. 2.21 The LUS was created to ensure that customers on low incomes and other disadvantaged customers (who might be without telephone service in the absence of such a scheme) could be connected to the network at an affordable price. The Scheme is essentially below cost and involves a subsidy. As LUS targets low users rather than customers on low incomes, it is important to establish that the subsidy is effectively directed. 2.22 A survey in September 1999 found that 69 per cent of LUS users were pensioners; 38 per cent of respondents had incomes of below £8,000; 14 per cent had incomes between £8,000 and £15,000; 11 per cent had incomes above £15,000; and 38 per cent refused to answer. Over 70 per cent of those surveyed had been on the scheme for over two years. Few respondents understood the full workings of the Scheme and especially how higher call charges would lead to automatic removal. 2.23 The research suggests that LUS is continuing to serve the needs of those customers for whom affordability and accessibility are key issues. BT has suggested that it could meet its obligations in other ways, possibly by modifying LUS or replacing it with other schemes. In considering any such scheme, Oftel would need to be satisfied that it would meet the needs of:
Oftel invites comments and views on possible criteria for any alternative scheme. 2.24 BT wants to avoid abuse of its social telephony schemes. It is a contractual term of LUS that those who use it cannot use another operator’s services, including indirect access (IA) and mobile telephony. BT estimates that around 15 per cent of LUS customers use a chargecard, indirect access service or a mobile phone. 2.25 Oftel has been informed that some Indirect Access operators are encouraging their customers to use the Scheme, despite the fact that they are likely to know that this would be in breach of the contract between the customer and BT. Oftel has stated that this is not an acceptable practice. Similar considerations apply to the carrier pre-selection facility (CPS). The obligation on BT to provide this facility is absolute and BT is not therefore legally in a position to limit the provision of CPS. Oftel however, accepts that it is reasonable that customers should not combine CPS with LUS. Oftel has made it clear that customers must be properly informed in order that they may choose. 2.26 BT also estimates that only one per cent of mobile users are also LUS customers. Oftel’s research shows growing use of mobile phones as an alternative to a fixed line for the unphoned, particularly those in lower income brackets. A mobile phone will not, of course, be permanently accessible to all members of a household in the way that a fixed line is. Oftel welcomes views on whether access to LUS should be withdrawn for people with mobiles; and if so, how. Disconnection trends and policies 2.27 In 1997, Oftel set BT a target of a 50 per cent reduction in disconnection rates over two years, failing which Oftel would reconsider the need for formal regulatory intervention. This objective has not been met. Nevertheless, a comparison of data for 1998 and 1999 reveals that when the size of the customer base is taken into account, both USO providers have lower disconnection rates than their competitors. Click here for disconnection data
2.28 BT and Kingston seek to avoid disconnection of service, but they reserve the right to do so if customers fail to pay without good reason within the time period specified. Oftel supports this approach. The flowchart below illustrates the credit management process, as detailed in BT’s Code of Practice for Consumers introduced in September 1997.
2.29 Consumer groups have concerns about rates of disconnection. As illustrated in the graph above, the level of disconnections for non-payment for BT customers was higher in 1999 than in 1997. There are many ‘multiple disconnections’ with some customers being disconnected and reconnected several times throughout the year. Operators believe that a rising level of disconnection of service occurs as a result of consumers being able to switch between competitors more easily and not pay final bills, often before the competitor is aware of non-payment problems. Evidence suggests that the number of customers who have no intention of paying their bills has increased. The success of policies to encourage wider takeup (including, for example, not requiring a deposit) may increase the number of customers who are unable to budget for their telephony costs. 2.30 Following the 1999 consultation, more detailed information has been sought on the underlying causes for disconnection, the impact of market ‘churn’ and whether more vulnerable customers were disproportionately affected. 2.31 A ‘mystery shopping’ exercise was undertaken by Oftel to assess the availability of codes of practice. The results were poor; only two of the operators could supply the document to the customer on request. This breaks the voluntary agreement made in 1997 and is unsatisfactory in the context of co- and self-regulation. Oftel also examined operators’ debt management procedures. All the operators had procedures to avoid customers running up large debts. The use of outgoing calls barred (OCB), as part of, and as an alternative to disconnection of service was widespread. The other licensed operators (OLOs) were found to have a shorter time lag between OCB and disconnection than BT and Kingston Communications. All operators had experienced a significant rise in the number of new accounts (ie of less than one year) terminated due to non-payment. In many cases customers had paid nothing at all and/or had continually defaulted on agreed repayment packages. 2.32 A possible cause of multiple disconnection of customers in genuine need, could be their agreement to an inappropriate repayment plan (either too little or too much) at the OCB stage. Oftel believes that more action could be taken at the initial point of sale to advise customers of various options available to avoid incurring debt and disconnection. For example, BT could ensure all customers are aware of its pre-payment card, enabling payments to be made on account in any denomination (minimum £2) at either a Post Office or a Paypoint outlet. All customers should be aware of the selective call barring facility, especially to limit expensive calls to premium rate numbers and mobile phones. 2.33 Some operators have not fully taken on board the importance of industry taking responsibility for ensuring that voluntary initiatives protect consumer interests. Customers who are genuinely in need and are willing to pay should not be disconnected. More needs to be done by operators to establish confidence in the operation of their disconnection procedures. It is essential that codes of practice, setting out clearly the operator’s policy on disconnection, are publicised and made available to customers on demand. 2.34 Oftel proposes that a co-regulatory group is established, comprising industry representatives, consumer groups and Oftel with the specific task of revising the voluntary codes of practices (CoPs). The CoPs would include procedures to allow customers to budget in advance for their telephone costs. The group would also advise on ensuring widespread publicity and easy availability of the codes; and would also monitor adherence on a regular basis. The group would also be responsible for ensuring that EU guidelines were adhered to. Oftel would review the effectiveness of this work and consider the need for further action as part of the next periodic review of USO in 2003. The alternative would be a mandatory licence amendment. Oftel invites views on these conclusions and invites proposals for ways of ensuring the effective updating and monitoring of codes of practice. Services for people with disabilities 2.35 Ensuring access to telephony to those with special needs is an important part of universal service. Research into homes without a fixed phone in March 2000 identified several specific problems experienced by the elderly and people with disabilities. Some elderly and disabled users felt that their special needs were not being fully taken into account. In general, respondents felt there should be special advice and/or assistance, particularly in the event of payment difficulties. There was a low level of awareness of existing specialised services, such as the Text Relay service, Typetalk, and products featuring volume control for the hearing impaired. 2.36 A survey in West London during March/April 2000 found that 35 per cent of hearing impaired respondents were aware of Typetalk although only 13 per cent had actually used it. Over 40 per cent knew of the facility to receive bills in a different format but only five per cent used the facility. Less than 50 per cent knew about special equipment and only around 12 per cent used it. Less than 20 per cent were aware of special textphone prices and only six per cent were aware of and used them. These findings demonstrate the need for operators to increase awareness of existing products. 2.37 Oftel is therefore supporting Ricability’s research and information project to establish a comprehensive record of the services provided for older and disabled users by fixed, mobile and indirect access operators. The findings will be used to compile a consumer fact sheet to include details of provision of such things as information in alternative formats, priority fault repair, free directory enquiries, access to text relay services and rebates on textphone services. The fact sheet would also include details of the numbers of payphones that are wheelchair accessible, have textphone, hearing aid coupling and amplification. 2.38 All goods and service providers are required under Part III of the Disability Discrimination Act 1995, which came into effect on 1 October 1999, "to take reasonable steps to change any policies, procedures or practices which make it impossible or unreasonably difficult for disabled people to make use of a service." In addition to any statutory requirements there are good practice guidelines and recommended practices which operators will wish to follow. 2.39 Regulations to implement the requirements of Article 8 of the Revised Voice Telephony Directive (98/10/EC) are expected to become law by October 2000 and will insert a new condition, Services for Disabled Persons, into the operating licences of fixed line operators. Mobile service provision is largely outside its scope. 2.40 For most parts of the regulations, the compliance date will be one year after the Regulations come into force, and will require fixed operators:
2.41 Progress has been made in the provision of textphones in PCBs. BT and disability organisations are consulting on siting of PCBs. PCB operators are experiencing some practical difficulties. PCBs with text phones are under utilised. Some potential users are worried about security while users without disabilities prefer to use conventional PCBs. BT is currently developing a scheme for the provision of rental textphones, which should help overcome some of the practical difficulties experienced by users. 2.42 BT is also planning to upgrade its current text relay service, Typetalk, with the launch of the Virtual Text Network (VTN) (branded as TextDirect) in October. It will be possible for other operators to meet their future licence obligations to offer customers access to a text relay service by interconnecting with the VTN rather than developing their own service. BT currently subsidises text relay services as part of its USO at a cost of around £12 million per annum. Continued BT funding will remain part of the new arrangements. 2.43 Oftel welcomes the proposed regulations, and the voluntary agreement of mobile phone operators to offer a parallel set of services. Oftel is working with operators to ensure that awareness of existing specialised services is increased. The problems of affordability for people with disabilities needs to be considered further and appropriate schemes may need to be put in place for those experiencing payment difficulties. When developing new products or services all operators should ensure that they follow guidelines for best practice. Views are sought on how to improve accessibility to and use of existing specialist services and to ensure that takeup is maximised. In particular, Oftel welcomes the views of potential users of textphones of ways or measures that might be taken to encourage their use. Geographic averaging of prices 2.44 The provision of universal services at geographically averaged prices exists to facilitate the affordability of basic telephony services. BT is currently required to average geographically its prices for Public Switched Telephone Network (PSTN) services. This means that such services are charged at the same price throughout the UK even where there are differences in the cost of provision. Geographic averaging delivers the benefits of competitive price levels nationally, rather than in geographic areas where competition is strongest. Also, it ensures that telephony is affordable in areas where the high costs of provision would otherwise disadvantage groups of customers. 2.45 In its March 2000 consultation on the price control review, Oftel proposed the retention of geographically averaged prices. Responses to the consultation support this proposal. Therefore Oftel does not intend to remove the current requirement. Meeting the requirement to provide telephony upon reasonable request 2.46 There is a statutory obligation on BT (and on Kingston) to meet all reasonable requests for connection to the fixed public telephone network. Reasonableness is a question of fact in particular circumstances. 2.47 Reasonable requests have been considered in conjunction with the ‘100 man-hour rule’. Where more than 100 man-hours of work is involved in a new fixed line connection, an extra charge is made. A specific rule is less flexible than a test of reasonableness. In some circumstances customers may be unreasonably excluded from telephony services, which would be contrary to the Revised Voice Telephony Directive (RVTD). 2.48 BT states that most new single line connections in rural areas can be completed in less than 100 hours (but that a small number of truly remote locations could take longer). Data on requests for service where more than 100 man-hours’ work was required showed that of the 309 cases recorded between August 1999 and February 2000, only 29 related to residential installations. (The data may exclude customers in remote areas who have previously been told of the likely high cost of connection). 2.49 Consumer groups have proposed an alternative means of determining whether a request for installation is ‘reasonable’, including a test based on the monetary cost of installation; installation at standard charge where the customer had satisfied a minimum period of residence; and allowing customers to select an approved contractor to undertake the installation on BT’s behalf, etc. Any proposal must be functional and equitable, for example it may not be reasonable to cross-subsidise the installation of phone lines into holiday homes. Oftel welcomes views on the proposal for guidelines, and specifically on the equity and feasibility of alternative schemes to allow BT to charge for the extra costs of installation. Provision of uneconomic payphones 2.50 BT agreed in 1997 to install up to 500 uneconomic Public Call Boxes (PCBs) over 5 years. This is a voluntary target and not a legal obligation. Some 100 uneconomic payphones have been installed since the scheme began. During 1999/2000 it is expected that a further 30 new payphones that would not otherwise have been installed will have been put in place. 2.51 The criteria by which BT decides whether an uneconomic PCB should be installed were agreed by Oftel:
2.52 The criteria favour more densely populated areas but are flexible. The acceptance rate of applications for 1999/2000 was 30 per cent; this is an increase on previous years. Requests are more likely to be refused where there are already public payphones in the area and low levels of usage. Where applications are refused the applicant has recourse to the Director General who may consider the reasonableness of the refusal. No refusals have been referred to Oftel. 2.53 The low number of installations is not in itself an indicator that requests to BT are being refused. It is quite possible that it reflects the demand for additional ‘uneconomic’ payphones. There is a possibility that the number of requests indicates a lack of awareness of the provision. Oftel will continue to liase with local authorities (the main channel for requests to BT) to promote awareness of the criteria. 2.54 The Oftel survey of the unphoned looked in some detail at alternatives to fixed line phones. The most popular alternative was a mobile phone, followed by payphones, which were used by about a third of respondents. The most important advantage for unphoned users of payphones was the ability to control costs. Set against this were concerns expressed about general safety issues, lack of privacy, the cost of calls, unpleasant environment, location etc. Even so, PCBs will continue to be essential for those who remain unphoned, away from home and without a mobile (or out of range) or who are temporarily disconnected from service whether due to payment difficulties or because of a fault on their line at home. 2.55 Oftel is therefore not proposing any change to the current regime for the provision of public call boxes but proposes to review the requirements and criteria in 2001 in the light of developments in the payphone market generally. Views are invited. Review of Existing Schemes: Summary
Re-evaluation of the costs and benefits of USO 3.1 This chapter examines the costing and funding of universal service: whether being a universal service provider places an unfair burden on BT and Kingston. This is in the context of European law, which requires that there must be a net cost that imposes an ‘unfair burden’ on the operator with the USO before a Fund can be established. Directives also give detailed guidance for calculating costs and benefits. Background 3.2 In 1997 Oftel concluded that there was a net benefit arising from the obligation for BT as a result of its USO and that the question of funding did not, therefore, arise. This position was based on an estimate of the costs incurred and benefits gained by BT as a result of its USO. 3.3 The four benefits identified were:
3.4 Taken together Oftel estimated in 1997 that these benefits to BT amounted to between £102 and 151m per annum. 3.5 In 1999 Oftel updated the original calculation, taking account of changes in methodology and cost drivers. This showed BT continued to benefit from brand enhancement and corporate reputation, ie the tangible benefit of being seen publicly to provide service to uneconomic areas and customers. Oftel also remained of the view that BT gains a benefit from serving uneconomic call boxes. Oftel accepted that the methodology for calculating benefits to BT from ubiquity and life cycle effect led to an overestimation. The revised calculation of benefit to the universal service provider reduced to around £61m. 3.6 The 1997 costs included uneconomic areas, uneconomic customers and payphones, estimated at £45m – £65m. The main cost was the LUS tariff. 3.7 In 1999, Oftel estimated the cost of uneconomic customers to be £53 – 73m. In summary, Oftel’s revised estimated suggested the following net cost/benefit:
3.8 The calculations exclude factors placing downward pressure on the cost of the USO, including greater efficiency by BT. 3.9 On the basis of the recalculations in 1999, Oftel concluded that this obligation was not an unfair burden and that therefore a more thorough costing exercise was not justified. Benefits: responses and analysis 3.10 BT and Kingston have argued that there is a significant net cost and undue burden. Most other responses either supported Oftel’s conclusions or suggested that Oftel was underestimating benefits from ubiquity, life cycle and brand enhancement. 3.11 BT’s response included market research to measure the impact of the USO on customers’ choice of fixed line operator and argued that the benefit from brand image is overestimated. Oftel believes that the research should have considered the benefit if BT were to fully exploit its position as the USO operator and taken account of benefits in terms of the choice between BT and indirect access or CPS operators. In Oftel research on customers’ rights, there was a significantly higher level awareness of the right to be supplied by BT than in the BT research. 3.12 BT also argued that Oftel has overestimated the benefit to BT arising from uneconomic public call boxes (PCBs). BT argued that future revenues from uneconomic phone boxes should not be included as a benefit. Oftel has not in fact included future revenues but looked at whether there are a number of call boxes that are uneconomic during the year that BT would retain even in the absence of the USO. BT also argued that Oftel had overestimated the benefit to BT from advertising through PCBs. However Oftel does not accept that potential advertising from call boxes is solely from PCBs located in city centre areas and believes that payphone advertising and potential revenue is comparable with advertising on bus shelters. 3.13 Oftel welcomes the research as providing additional information to the debate and notes BT’s arguments. However, Oftel does not believe BT has established that there is no benefit to the universal service provider from the obligation. Moreover, Oftel recognises that the points made in other responses that any future evaluation of costs and benefits will need to take account of the benefits arising from a full exploitation of universal service provision. It would also need to take account of the current numbers of customers on the Light User Scheme, which have fallen since the 1999 estimates. Costs: responses and analysis 3.14 Operators – other than BT and Kingston – suggested that greater efficiency and better targeting of uneconomic customers by BT would lead to a reduction in costs. BT argued that Oftel’s calculations of the cost of uneconomic areas and customers were unsound because of the use of averages, and that more information on costs, which was unavailable at the time of the initial assessment, could be provided. Kingston also indicated its willingness to discuss with Oftel information on net costs. 3.15 Oftel has expressed concern about the lack of detailed information from BT and Kingston. Oftel therefore welcomes the indications from BT and Kingston that they are now able to provide data. Given that Oftel believes that the data produced by BT establishes that the benefits of USO provision are significant, the calculation of costs is important. Conclusions 3.16 Oftel believes that the USO is not an unfair burden on BT and Kingston. However, Oftel accepts that, given that the data of the initial costing exercise could be improved, continued discussions with BT and Kingston will take place to establish what further information can be made available. A recosting exercise will only be undertaken if BT and Kingston are able to provide enough information to improve significantly the initial estimate of the net cost of the USO. If Oftel were to undertake such an exercise on costs, it would also re-examine the benefits from the USO in order to take account of new developments in the market or new thinking on this issue. The reassessment of costs and benefits would be made on the basis of BT and Kingston as efficient operators, fully exploiting cost savings and benefits. 3.17 Only if the first stage establishes a net cost, Oftel would assess whether the burden on BT and Kingston was unfair. In determining this, Oftel would take into account the extent to which BT is unable to recover its costs of serving uneconomic customers from the profit it makes from economic customers. Oftel’s view is that, on BT’s current return on capital and within the current price control, a net cost within the range of estimates we have seen to date is unlikely to be seen as an unfair burden. 3.18 If this process established an undue burden on BT and Kingston, Oftel would propose to set up a fund with the costs of universal service shared between operators. An Industry Working Group was set up following the 1997 Statement to consider how such a fund should operate. Future Developments 3.19 If Oftel decides that a full reassessment is appropriate, it is likely that this analysis would include issues such as:
3.19 Initial analysis suggests that the impact of these changes will be broadly neutral on the costs of USO. Competitive delivery of universal service 3.20 The Working Group on USO Funding also considered changes to the method of delivery of universal service should a fund be established. The group felt that if a universal service funding mechanism were put in place, there should ideally be provision for other operators (including, in principle, mobile operators) to compete in the provision of universal service and receive appropriate payments. Operators would have the option of paying into the fund to compensate the universal service provider or of providing some elements of universal service themselves and thereby reducing or eliminating the payments that they would otherwise need to make into the fund. In principle, operators could compete in the provision of service to individual uneconomic customers, areas or public call boxes. 3.21 Considerably more work would be needed before competitive arrangements could be introduced under any USO joint funding arrangements, once a significant net burden had been established. However, Oftel supports the principle that a jointly funded USO should be open to competitive delivery.
Should the level of universal service be revised? Introduction 4.1 Internet and higher bandwidth services – and the services developed as a result of them – will play an increasingly important role in economic and commercial life, in education and health and in personal life. The Government wants universal access to the Internet by 2005 and it intends to make most Government services accessible online. Rapid rollout of high bandwidth communication networks, providing fast ‘always-on’ connections directly to business premises, homes and public access points in libraries and similar community institutions is also a key e-commerce objective for Government. 4.2 There is evidence that some regions and groups are being left behind by the general increase in home Internet use. The possible further widening of this digital divide as higher bandwidth services become available is clearly a significant concern for government policy on social exclusion. 4.3 This chapter considers the future scope of the USO and other regulatory action in the context of these objectives. It looks at whether the level of universal service should be revised to include mobile and narrowband ISDN services, to enhance the ability to access Internet services and to cover higher bandwidth services (services provided at speeds greater than 384kbits/s). 4.4 Barriers to takeup of Internet access and higher bandwidth services caused through factors such as cost of equipment or unfamiliarity with the technology are outside the scope of this paper. Existing Framework 4.5 The rationale for the USO is to ensure that those telecommunications services which are essential to social and economic inclusion are made available to everybody upon reasonable request in an appropriate fashion and at an affordable price. The USO is a safety net, used where the market has not been able to deliver. It ensures that services that are used by the majority are available to all. Responses to the consultation supported this approach and definition. 4.6 ‘Universal service obligation’ therefore has a particular meaning. First, it involves imposing requirements on commercial companies to serve customers who they might not otherwise have served at prices that they may not have chosen commercially. Second, it involves special funding arrangements with the costs incurred in meeting the obligation met by the telecom companies involved. This subsidy has an important economic rationale termed the ‘network externality’. The externality occurs because all customers receive benefits when others join the network. Because these benefits cannot be reflected directly in individual transactions or met on strict commercial terms, there is a role for Government in ensuring that the network is as extensive as is feasible at appropriate prices. 4.7 European legislation sets the framework for both the USO and how it can be financed. Currently there is a minimum level of universal service set in European Directives together with rules for costing and establishing, if necessary, any fund paid for by telecom companies to meet the costs of providing this minimum level. Member States are free to set a higher level of service financed by government through taxation revenues. Contributions from telecom consumers via a levy on operators to a fund cannot be mandated to meet the costs of a USO above the current level. 4.8 Following the 1999 Review, the Commission’s proposals for new legislation endorse the same approach. The Commission considers that the current level of the Universal Service Obligation does not need to be revised to include higher bandwidth services at present. But the Commission does propose a mechanism to allow the issue to be regularly reviewed. The Commission proposes that should Member States choose to set a level of universal service higher than the present level, the cost of such an extension should be financed from general taxation. Mobile telephony and narrowband ISDN 4.9 Oftel asked for views on extending the Universal Service Obligation to two other services: narrowband ISDN and mobile telephony. 4.10 Responses did not support extending the Obligation to include narrowband ISDN. This is not a service used by the majority or which is essential to social and economic inclusion. Moreover, there was also a concern that adding ISDN to the Obligation could result in picking the wrong technology. Respondents considered it likely that services in the future would utilise other technologies rather than narrowband ISDN. 4.11 Operators and most other respondents also considered that there was not a need to extend the obligation to mobile services. While accepting that it is now a service used by 65 per cent of households, they argued that it is not clear that mobile telephony is ‘essential’ for social and economic inclusion, given the existence of fixed line alternatives. It was also felt that mobile telephony already provided universality by allowing anyone to buy a mobile phone and, with the establishment of the pre-pay market, at reasonable costs. However, some consumer groups, primarily representing rural areas, argued for the inclusion of mobile in the obligation to ensure that the service was available in these areas. 4.12 Oftel supports the objective of wider geographic coverage and the increasingly competitive mobile marketplace has been delivering broader mobile coverage (98 – 99 per cent of the population), and will continue to do so. Oftel will work with the industry to extend coverage. Oftel therefore does not propose an extension of the Obligation to include either narrowband ISDN or mobile services. Internet The market today 4.13 Telecommunications delivers ubiquitous Internet access with services provided over the infrastructure of competing telecoms operators. Considerable progress has already been made in achieving widespread Internet access. 4.14 98 per cent of all Internet access is over the existing fixed telephone network using copper analogue lines. 95 per cent of homes have fixed telephone lines. Almost all the population now has the possibility of Internet access provided they have the necessary equipment. 25 per cent of the UK adult population has Internet access through a home, work or college computer, although there are significant differences between regions and social class. Digital TV and mobile phones using wireless application protocol (WAP) technology are also now beginning to offer Internet access and e-mail. Digital TV services now cover almost one-fifth of the population and are forecast to have approximately 8.4m subscribers by 2002/3 – around one-third of households. 4.15 The cost of Internet access has reduced considerably with innovative charging packages emerging, including below local rate and unmetered tariffs. For off-peak Internet access the UK is now one of the cheapest countries in the OECD. Some people may choose or need to access the Internet from a public access point rather than the home or the workplace. Oftel has taken a role in helping public institutions to work together to reduce the price of Internet access as well as encouraging the telecommunications industry to provide special tariff packages for Internet access for schools, public libraries, FE colleges, Citizens’ Advice Bureaux and University for Industry learning centres. The telecommunications industry has responded positively. A number of companies offer special tariffs for these public institutions, allowing them to connect to the Internet at lower prices. 4.16 Speed and reliability of access is an important element in relation to Internet access. Users of the Internet want data speeds which allow workable access to the Internet. The minimum data speed currently set by European legislation, and the subject of an obligation on BT and Kingston, is 2.4 kbits/s. However, in practice information from operators indicates that most UK users – around 90 per cent – experience much faster speeds of 28kbits/s from the end user to the Internet service provider. Such rates should provide adequate speeds for reliable access to e-mail services and many current uses of the Internet. Oftel is currently seeking further information from BT and Kingston about data speeds being achieved by the remaining users – around 10 per cent of customers. Refining the current obligation 4.17 While recognising that the user’s modem speed and the capability of the service provider will affect the data speeds experienced by the Internet user, Oftel believes that appropriate data speeds for networks should be set within the USO in line with the Government’s goals of universal Internet access. The UK’s submission to the European Commission’s 1999 review of European legislation proposed that Member States should be given greater flexibility in setting minimum data speeds. In the draft Directives, the Commission has proposed removing the minimum data speed requirement from legislation allowing Member States to set levels appropriate to their own circumstances. Oftel welcomes this proposal although considers there is a need for an upper ceiling for national minimum data speeds to ensure that regulators do not impose undue burdens on industry. 4.18 Oftel also recognises that the minimum data speed needs to reflect technical limitations of networks. For instance, where there are long connections between the exchange and the customer’s premises, speeds in excess of 14.4kbit/s may be difficult to achieve without significant network upgrades. The minimum would need to reflect such circumstances and be based on what is practicably achievable across the network. In addition to a minimum standard therefore, it may be appropriate to ensure that BT responds to all reasonable requests for non-voice services including data telephony in accordance with condition 43 of its licence. 4.19 Oftel therefore concludes that the market and the regulatory regime are already making considerable progress towards delivering the Government’s objective for universal Internet access by 2005 based on high levels of penetration, as well as affordable tariff packages for Internet access from the home and public institutions. More work is needed ensure that reliable data speeds providing workable Internet access are available to all customers. Oftel invites views on this conclusion and on the minimum data speed to be set on USO providers that would be required to ensure workable Internet access for all, or other ways in which workable speeds can be delivered for Internet access over the PSTN to those who wish it. Higher bandwidth services Market developments 4.20 The market for higher bandwidth services is beginning to develop. BT, Kingston and cable operators have started to introduce higher bandwidth services using ADSL technology and cable modems. Some estimates suggest that between 70 and 80 per cent of households would potentially have access to higher bandwidth networks by the end of 2002 on the basis of these developments. Increasing competition in the market, particularly after local loop unbundling (LLU), should further spur rollout and reduce the price of these services making them more affordable for all consumers. 4.21 BT launched its ADSL service in June 2000. Under its licence BT is required to offer its ADSL products on wholesale terms to competing operators and service providers. A number of service providers have been involved in BT’s ADSL trial and have launched commercial services. 4.22 BT is required under a new condition in its licence to provide to other operators unbundled loops and co-location in its local exchange buildings, introducing competition into the upgrade of the local access network. Oftel, BT and the industry have been working to implement local loop unbundling and have agreed on most of the operational issues. BT will start taking orders for co-location from operators on 1 September 2000 and the first unbundled loops should be provided early in the New Year. Oftel expects that, with the completion of BT’s automated ordering system, unbundled loops should be available in volume by mid-2001. 4.23 Cable operators ntl/CWC and Telewest are also rolling out cable modem services which allow them to offer speeds comparable to ADSL. ntl launched their service in August 1999 in Surrey and Hampshire and it is now available in franchises in Nottinghamshire, Bedfordshire, Hertfordshire, Cambridgeshire, Wales and Northern Ireland. It plans to have this available in all franchises by the end of 2000. Telewest launched its cable modem service in March 2000 and again plans to have this available in all franchise areas by the end of 2000. Between them ntl/CWC and Telewest cable networks pass approximately 50 per cent of households. If the cable companies’ rollout plans are achieved then 50 per cent of households will have a cable modem service available to them by the end of 2000. 4.24 The period 2000 to 2002 is likely to see other significant developments in terms of higher bandwidth services. The issue of licences for third generation higher bandwidth mobile radio will be followed by the rollout of services from 2002. Auctions for fixed higher bandwidth radio spectrum are due to take place in September 2000. Higher bandwidth satellite systems can be expected to make a significant contribution to providing coverage outside metropolitan areas. Satellite service providers say they will provide basic tier Internet service (ISDN plus) and higher speed downloads (up to 4Mbits/s at present) at prices competitive with the fixed network from late 2000 on a national basis. Regulatory Activity 4.25 Oftel is already taking steps to encourage the rollout of higher bandwidth services. Oftel regulates, as appropriate, to promote competition in the market to increase choice and reduce prices thereby encouraging increased demand. This should help create a virtuous circle where demand gives rise to an increasing range of services, which in turn drives more demand, thereby reducing costs and prices. 4.26 Where markets appear to be failing to deliver wide rollout and affordable access to higher bandwidth services through competition, Oftel will take appropriate action. On BT’s ADSL plans, Oftel has been monitoring rollout to ensure compliance with BT’s legal obligations under the Competition Act 1998 and the terms of its licence. BT must not, for example, unduly prefer its own Service Provider business. Oftel will continue with this monitoring exercise to ensure a competitive marketplace and will intervene if appropriate. Local loop unbundling, as explained above, will allow operators to install their own equipment in direct competition to BT’s ADSL products. The process is already well advanced with the legal framework in force. The first unbundled loops should be supplied to competitors from the start of 2001. 4.27 Continuing the practice established with narrowband Internet services, Oftel monitors and publishes market data on higher bandwidth services in order to increase transparency in the market and assist policymaking. Specifically, Oftel’s aim is to:
4.28 Oftel is also working with operators on Learning Society access issues. In November 1999 the Government announced a £50 million programme to encourage the rollout of high speed links to the Internet in schools and other learning institutions. The funding is earmarked for higher bandwidth consortia projects. Local education authorities, in partnership with other agencies, were invited to form regional consortia and submit innovative proposals for the introduction of higher bandwidth services for schools and other learning institutions. The initiative on schools is part of the National Grid for Learning (NGfL) with the Government objective that all schools are online and able to benefit from the Grid by 2002. Consortia are already in place to cover around 30 per cent of the UK with the expectation that around 90 per cent coverage will be achieved during 2001. Following discussions with Oftel, BT now offers a special tariff for broadband access for schools and other eligible public institutions – Learning Stream, a 2Mbits/s service using HDSL technology. Other initiatives 4.29 In addition to the market rollout, it is expected that local initiatives will support rollout of higher bandwidth facilities into areas where operators may not currently plan to offer such services because sparse population levels make a reasonable commercial return unlikely. For example, in Wales the Pathway Project, run jointly by Powys County Council and the Welsh Development Agency, and supported by EU Structural Funds, aims to upgrade the telecommunications infrastructure in rural areas to allow access to advanced telecommunications services by the end of 2001. Other Assisted Areas may be in a position, within European investment rules, to assist in the provision of higher bandwidth services to rural and remote communities, eg to public access points, schools and businesses. In very remote rural areas, initiatives would need to work within technical constraints associated with the delivery of higher bandwidth services. The Universal Service Obligation and higher bandwidth services 4.30 Oftel’s consultation raised the question of what part the Universal Service Obligation might play in the future, alongside these other policy instruments, in ensuring the availability of affordable higher bandwidth services. Applying the traditional USO model to higher bandwidth services would mean giving all consumers a right to a telecommunications connection above a stated (higher) data speed on reasonable demand at affordable prices. 4.31 Responses showed considerable interest in this area but there was no clear consensus as to whether the obligation should be extended. Among those who argued for such an extension, there was no consensus on whether immediate action should be taken or whether the issue should be re-examined in the light of market developments. The following paragraphs set out the key factors that will have to be considered in deciding on the way ahead. 4.32 A key determinant of the availability of affordable higher bandwidth services will be developments in the marketplace. There are potentially several competing routes to the provision of higher bandwidth services: for example ADSL, cable modems, mobile services and satellite. Regulatory intervention to support a particular delivery mechanism could be damaging. It is important that customers are the ultimate arbiter of which type of service they wish to use. For example, a service obligation utilising ADSL alone might lead to other technologies and delivery routes not being developed thereby restricting both consumer choice and the UK’s e-commerce development. 4.33 Another issue is the practical one of how to deliver higher bandwidth services to consumers wherever they may be. A requirement on BT to supply, for example, ADSL to every household that reasonably demands such a service, would require a substantial upgrade of BT’s network. The copper loops supplying about 20 – 30 per cent of households are too long to be reached by ADSL technology. Thus, supplying higher bandwidth services to every household in the UK, regardless of location, is likely to necessitate the laying of fibre and the construction of new infrastructure. This will require very considerable investment. Decisions on whether there should be public funding or some form of incentive for private investment are for Government. 4.34 The price of higher bandwidth services is key. As the market develops over the next few years, increased competition should result in price reductions making higher bandwidth services affordable for most of the population. 4.35 There may however, be a minority of the population (and it may well be a sizeable minority at least in the short term) who find the cost of such services beyond them. To avoid social exclusion, it may be necessary to find new ways of providing higher bandwidth services to those on low incomes. The current methods of targeting such people in relation to the USO, ie low use schemes, are unlikely to be useful in the context of services whose benefits derive from being ‘always on’. This may mean that the best solution would be for some form of targeted intervention. 4.36 It will also be appropriate to consider separately the level of the universal service and its delivery. Such a change would be increasingly relevant if the USO were to be expanded to cover higher bandwidth services. Conclusions Oftel supports the goal of rolling out higher bandwidth communications networks. Equitable and affordable access remains at the heart of Oftel’s work to promote the interests of consumers and Oftel is committed to developing actively a regulatory environment which encourages this. Oftel will therefore continue to keep the issue under close review, for example through further research into access to higher bandwidth services broken down by region and social class, and will look positively at the scope for other regulatory action in support of this goal. High-bandwidth services do not at present meet the primary test for consideration as part of the USO requirement, because they are not yet services used by the majority. But they are very rapidly developing. This progress needs to be kept under review alongside other factors relevant to the future of the USO, including the emerging EC framework, impacts on investment, funding, cross-subsidies, consumer demand and means of supply. Oftel will work with Government, industry and consumers and contribute positively to wider policy discussions on these issues alongside its broader efforts to promote equitable and affordable access.
Consultation details Oftel is seeking comments on the questions raised in this document. The initial consultation period will run until 4 December 2000. There will then be a further period to 18 December 2000 during which comments are invited on any submissions made to Oftel during the initial period. Written comments should be sent to: David Parsons Tel: 020 7634 8746, Fax: 020 7634 8893 or e-mail Written comments will be made publicly available in Oftel’s Research & Intelligence Unit unless confidential. Respondents are therefore asked to separate out any confidential material into a clearly marked annex, which is clearly marked as such. In the interests of transparency, respondents are asked to avoid confidentiality markings wherever possible. All written submissions may be viewed on request at Oftel’s Research and Intelligence Unit, and can be arranged by calling 020 7634 8761. Oftel would like to set up a link between this document on Oftel’s pages and any responses placed on respondents’ own Internet pages. Please contact Jo Hamilton at Oftel on 020 7634 8755 or e-mail web.oftel@gtnet.gov.uk to arrange this. Confidential responses should not be sent via the Internet. Oftel documents are available in alternative formats. A large print version of the summary section of this document is available. Copies of this document are also available on disk. Braille and tape formats of the summary can also be provided on request. Please contactor by e-mail at infocent.oftel@gtnet.gov.uk or call textphone 020 7634 8769 for more information. A Welsh summary
of the document is also available on request from the Oftel Research
and Intelligence Unit on Oftel has a free e-mail based mailing list to help people stay informed about the work that Oftel is doing. Each time an Oftel document is published and placed on our website, subscribers to the list receive an e-mail informing them about the title of the document and its location on the site. If you would like to join then please use the electronic form on the website to add yourself to the list. There is a link to the form from the What’s new section on the site. Oftel intends to follow this consultation with a Statement in spring 2001 setting out the level of Universal Service from September 2001.
List of Respondents to the July 1999 Consultative Document
CCE (Consumer Communications for England) DIEL (ACT for disabled and elderly people) NIACT (Northern Ireland Advisory Committee on Telecommunications) SACOT (Scottish Advisory Committee on Telecommunications) WACT (Welsh Advisory Committee on Telecommunications)
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