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Draft Direction under the provisions of licence condition 78.14 Regarding the regulatory Financial Statements of British Telecommunications plc Layout image
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download this documentContents

Draft Direction

Annex A – Definition of Network Business and Retail Narrowband Access Business

Annex B – Network Components

Annex C – Information to be provided by way of notes to the regulatory Financial Statements

Explanatory Memorandum

Summary

Chapter One – Introduction and background

Chapter Two – Regulatory context – requirements for financial information

Chapter Three – The investigation

Chapter Four – Options and regulatory option appraisal

Chapter Five – Detailed Proposals

Chapter Six – Conclusion

Chapter Seven – Consultation

Annex A – Granularity of regulatory financial information

Annex B – Accounting Documents and supporting methodologies

Annex C – Other accounting issues

Annex D – Statements by the Director General to the regulatory Financial Statements for 1999, 2000 and 2001

Annex E – Glossary


DRAFT DIRECTION UNDER CONDITION 78.14 OF THE PTO LICENCE GRANTED TO BRITISH TELECOMMUNICATIONS PLC

WHEREAS:

(i) The Secretary of State for Trade and Industry granted a licence (the "Licence") to British Telecommunications on 22 June 1984 under Section 7 of the Telecommunications Act 1984 (the "Act") for the running of telecommunications systems specified in Annex A to the Licence;

(ii) By virtue of Section 109 of, and paragraph 20 of Schedule 5 to, the Act, the Licence has effect as if granted to British Telecommunications plc ("BT");

(iii) BT, in accordance with condition 78 of the Licence, has an obligation to prepare and publish Financial Statements for each financial year in accordance with, amongst other things, the Accounting Documents;

(iv) Condition 78.14(a) of the Licence allows the Director General of Telecommunications ("the Director"), where he has reasonable grounds to believe that, amongst other things, any or all of the Accounting Documents or the Financial Statements are deficient, to investigate, assess, examine or review BT’s accounting records or accounting and reporting arrangements, systems or processes;

(v) Condition 78.14(b) of the Licence allows the Director, as a result of any such investigation, assessment, examination or review, and where he is satisfied that, amongst other things, any or all of the Accounting Documents or the Financial Statements are deficient, to direct BT to amend any or all of:

(A) the composition of any or all of the Businesses in terms of any or all of the revenues, costs and assets they respectively comprise;

(B) the manner in which any or all of the Businesses are disaggregated in terms of activities of the relevant Business;

(C) the form and content of any or all of the profit and loss account, the statement of mean capital employed, statements of costs and the additional information to be provided by way of notes comprised in the Financial Statements, the Restated Financial Statements or the Interim Financial Statements of any or all of the Businesses; and

(D) any or all of the Accounting Documents;

(vi) On publication of the Financial Statements prepared by BT pursuant to condition 78 of the Licence for the financial year 1998/1999, the Director had reasonable grounds to believe that those Financial Statements and the Accounting Documents were deficient. The Director therefore, in September 1999, commenced an investigation under condition 78.14(a) of the Licence into BT’s accounting records, accounting and reporting arrangements, systems and processes;

(vii) On publication of the Financial Statements prepared by BT pursuant to condition 78 of the Licence for the financial year 1999/2000, the Director had reasonable grounds to believe that those Financial Statements and the Accounting Documents were deficient. The Director therefore continued the investigation under condition 78.14(a) of the Licence commenced in September 1999 to include those Financial Statements;

(viii) On publication of the Financial Statements prepared by BT pursuant to condition 78 the Licence for the financial year 2000/2001, the Director had reasonable grounds to believe that those Financial Statements and the Accounting Documents were deficient. The Director therefore continued the investigation under condition 78.14(a) of the Licence commenced in September 1999 to include those Financial Statements;

(ix) As a result of the investigation under 78.14(a) of the Licence into the Financial Statements prepared and published by BT for the financial years 1998/1999, 1999/2000 and 2000/2001 and the Accounting Documents, the Director is satisfied that the Financial Statements and the Accounting Documents are deficient;

THEREFORE

Pursuant to condition 78.14(b) of the Licence, the Director makes the following direction:

Composition of the Network and Access Businesses

1. BT shall within 14 days of the making of this Direction amend the composition of:

a) the Network Business; and

b) the Access Business

such that each of the above Businesses are composed in accordance with Annex A to this Direction.

2. BT shall within 14 days of the making of this Direction amend the name of the Access Business to "Retail Narrowband Access Business", and, for the avoidance of doubt, from the date of the change of name, all references in the Licence, the Accounting Documents or this Direction to the "Access Business" shall be construed as a reference to the Retail Narrowband Access Business.

The manner in which any or all of the Businesses are disaggregated

3. BT shall within 14 days of making this Direction amend the manner in which the Businesses are disaggregated in terms of activities by creating activities of each relevant Business as follows:

a) for the Network Business, each of the components or parts (or groups of components or parts) listed at Annex B to this Direction shall constitute a disaggregated activity of that Business;

b) for the Mobile Business, each of the following product groups shall constitute a disaggregated activity of that Business:

(i) Mobile Business - Interconnect Services [G169/P440]
(ii) Mobile Business - Mobile Call Services – prepaid [G169/P441]
(iii) Mobile Business - Mobile Call Services-postpaid [G169/P442]
(iv) Mobile Business - Mobile Call Services – ISPs [G169/P443]
(v) Mobile Business - Value Added Services [G169/P444]
(vi) Mobile Business – PSRCS (BT Airwaves) [G169/P446]
(vii) Mobile Business – 3G (UK) [G169/P447]
(viii) Mobile Business – Other [G169/P448]
(ix) MobileBusiness – Radiopaging [G169/P658];

c) for the Apparatus Supply Business, each of the following product groups shall constitute a disaggregated activity of that Business:

(i) Other Data Applications [G164/P043]
(ii) Big & Large Switches [G164/P081]
(iii) Datacomms [G164/P088]
(iv) Business Voice Cabling [G164/P090]
(v) Residential Voice Cabling [G164/P091]
(vi) Data Cabling [G164/P092]
(vii) Other Voice Apps [G164/P094]
(viii) Local Area Networks [G164/P095]
(ix) Private Payphones – Apparatus [G164/P134]
(x) Mobile Phones [G164/P150]
(xi) Other Business Products [G164/P233]
(xii) Corded Telephones [G164/P392]
(xiii) Cordless Telephones [G164/P393]
(xiv) Telephone Ancillaries [G164/P394]
(xv) Answering Machines [G164/P395]
(xvi) Facsimilies – Apparatus [G164/P396]
(xvii) Medium and Small Switches [G164/P397]
(xviii) Managed Network Services (ASB) [G164/P601]
(xix) Visual Services (ASB) [G164/P609]
(xx) Syntegra Equipment Sales (ASB) [G164/P619]
(xxi) Mobile Business, Equipment Sales (ASB) [G164/P623]
(xxii) Converged Switch [G164/P398]
(xxiii) Ignite Solutions (ASB) [G164/P428];

d) for the Supplemental Services Business:

(i) each of the following product groups shall constitute a disaggregated activity of that Business:

(A) Fax Network Services [G165/P042]
(B) Managed Callstream [G165/P201]
(C) Concert Packet Service [G165/P280]
(D) Callminder SSB [G165/P287]
(E) Number Information Compilation [G165/P303]
(F) Directory Information [G165/P304]
(G) Pathfinder [G165/P305]
(H) Miscellaneous Number Information [G165/P306]
(I) DQ Number Information Inland [G165/P307]
(J) DQ Number Information International [G165/P308]
(K) OLO Number Information [G165/P309]
(L) Genie Internet – UK [G165/P338]
(M) Openworld - NBP – Consumer [G165/P341] [NBP?]
(N) Openworld - NBP – Advertising & E-Commerce [G165/P342]
(O) Virtual Internet Service Providers (VISPs) [G165/P344]
(P) Ignite Applications Services SSB [G165/P347]
(Q) Ignite Content Hosting [G165/P349]
(R) Openworld – NBP – Narrowband [G165/P357]
(S) Ignite Value Added Services [G165/P377]
(T) Managed Network Services [SSB] [G165/P602]
(U) Yellow Pages [SSB] [G165/P604]
(V) Message Services [SSB] [G165/P607]
(W) Visual Services [SSB] [G165/P610]
(X) Broadcast Services [SSB] [G165/P615]
(Y) Mobile Comms [SSB] [G165/P624];

and

(ii) that Business shall also be disaggregated into business and residential activities, each of which shall be further disaggregated according to the following customer classes:

A) for business activities:

1) Government eg civil and judiciary, civil and defence, local government and community development;
2) Major corporate clients;
3) Small and medium enterprises;
4) Internet service providers;
5) Calls and Access service providers; and
6) Other service providers;

and

(B) for residential activities:

1) Residential customers, each decile by total spend; and
2) Residential customers on BT’s Light User Scheme.

4. BT shall within 14 days of making this Direction amend the manner in which the Businesses are disaggregated in terms of activities by amending the current activities of each relevant Business as follows:

a) for the Retail Narrowband Access Business,

(i) the current business and residential activities shall be further disaggregated according to the following customer classes:

(A) for business activities:

1) Government eg civil and judiciary, civil and defence, local government and community development;
2) Major corporate clients;
3) Small and medium enterprises;
4) Internet service providers;
5) Calls and Access service providers; and
6) Other service providers;

and

(B) for residential activities:

1) Residential customers, each decile by total spend; and
2) Residential customers on BT’s Light User Scheme;

and

(ii) each of the following product groups shall constitute additional disaggregated activities of that Business:

(A) ISDN2 Connections [G250/P450]
(B) ISDN2 Rentals [G250/P451]
(C) ISDN30 Connections [G250/P452]
(D) ISDN30 Rentals [G250/P453]
(E) PSTN Business Connections (Std) [G250/P454]
(F) PSTN Residential Connections (Std) [G250/P455]
(G) Business Takeovers [G250/P456]
(H) Residential Takeovers [G250/P457]
(I) Business Other Telephone Charges [G250/P458]
(J) Residential Other Telephone Charges [G250/P459]
(K) Business Telephone Line Rentals [G250/P460]
(L) Residential Telephone Line Rentals [G250/P461]
(M) Featureline Conn & Conv [G250/P462]
(N) Featureline Rentals & OSPs [G250/P463]
(O) Business Highway Connections [G250/P464]
(P) Business Highway Rentals [G250/P465]
(Q) Home Highway Connections [G250/P466]
(R) Home Highway Rentals [G250/P467];

(b) for the Retail Systems Business:

(i) each of the current activities of that Business shall be further disaggregated according to the product groups and, in the case of Private circuit activities, geographical areas as follows:

(A) for Local calls activities:

1) BT-OLO Lo-call [G202/P313]
2) PSTN Local calls: Bus [G202/P316]
3) PSTN Local calls: Res [G202/P317]
4) ISDN2 Local calls [G202/P320]
5) ISDN30 Local calls [G202/P322]
6) Business Highway: Local [G202/P385]
7) Home Highway: Local [G202/P388];

(B) for National calls activities:

1) BT-OLO Nationalcall [G203/P314]
2) BT-OLO Valuecall [G203/P315]
3) PSTN National calls: Bus [G203/P318]
4) PSTN National calls: Res [G203/P319]
5) ISDN2 National calls [G203/P321]
6) ISDN30 National calls [G203/P323]
7) Business Highway: National [G203/P386]
8) Home Highway: National [G203/P389];

(C) for Calls to mobile activities:

1) BT Calls to Mobile Bus [G204/P240]
2) BT Calls to Mobile Res [G204/P241];

(D) for International calls activities

1) Outgoing PSTN Calls IDD Business [G206/P014]
2) Outgoing PSTN Calls IDD Residential [G206/P017]
3) PSTN IDD Calls to O’seas Mobile: Bus [G206/P020]
4) PSTN IDD Calls to O’seas Mobile: Res [G206/P021]
5) Operator Assistance: International Outgoing (155) [G206/P054]
6) Business BT Chargecard: International [G206/P101]
7) Residential BT Chargecard: International [G206/P102]
8) Operator BT Chargecard: International [G206/P103]
9) Operator Assistance International Incoming [G206/P105]
10) ISDN 30 International Calls: outgoing [G206/P259]
11) ISDN 2 International Calls: outgoing [G206/P261]
12) Business Highway: International (outgoing) [G206/P387]
13) Home Highway: International (outgoing) [G206/P390];

(E) for Public payphone activities:

1) Public Payphones - Inland Calls [G207/P138]
2) Public Payphones - IDD Calls [G207/P139];

(F) for Private circuit activities:

1) Private Services: Extension Keyline [G208/P061]
2) Speech/KeyLine: Connections [G208/P063]
3) Speech/KeyLine: Rentals [G208/P064]
4) Kilostream N64 Connections [G208/P065]
5) Kilostream N64 Rentals [G208/P066]
6) Kilostream: Connections [G208/P067]
7) Kilostream: Rentals [G208/P068]
8) Megastream: Connections [G208/P069]
9) Megastream: Rentals [G208/P070]
10) International Analogue Private Circuits [G208/P071]
11) International Digital Private Circuits [G208/P072]2) Flexible Bandwidth Services (FBS) [G208/P288]
13) Shorthaul Data Service (SHDS) [G208/P294
14) Internal Sales of Private Circuits [G208/P297];

and each of the activities at F(1) to (14) above shall be further disaggregated by geographical area as follows:

(a) Activities undertaken within the city of London zone or areas allocated telephone numbers beginning with 0207;

(b) Activities undertaken outside of the city of London zone or areas allocated telephone numbers beginning with 0207;

(G) for Other Retail Systems Business activities:

1) Telex [G209/P044]
2) Operator Assistance: Inland (100) [G209/P053]
3) Linkline (BT Terminating) [G209/P056]
4) Value Call BT Terminating [G209/P059]
5) Solutions Basic Service [G209/P073]
6) FeatureNet 1000 (VPN) [G209/P076]
7) FeatureNet 5000 (VPS) [G209/P077]
8) Other Advanced Services [G209/P078]
9) Business BT Chargecard: Inland [G209/P098]
10) Residential BT Chargecard: Inland [G209/P099]
11) Repayment Works [G209/P140]
12) Aeronautical & Maritime [G209/P142]
13) Transit [G209/P143]
14) Admin Leases [G209/P145]
15) Other N&IS Network Products [G209/P146]
16) Other Group Network Products [G209/P148]
17) SMDS (Switched Multimegabit Data Services) [G209/P149]
18) International FeatureNet (IFN): outgoing [G209/P257]
19) LinkLine International: outgoing [G209/P263]
20) RedCare [G209/P267]
21) Prime Service [G209/P270]
22) Number Portability - Set-up Costs [G209/P277]
23) Non Network Small Products [G209/P285]
24) Select Services [G209/P290]
25) CellStream/ATM [G209/P292]
26) Framestream [G209/P296]
27) Callmapping [G209/P302]
28) DQ Number Information Network [G209/P310]
29) Surf Products [G209/P340]
30) BTnet Services –Fixed Access [G209/P345]
31) BTnet Services –Dial Access [G209/P346]
32) Ignite Miscellaneous – SB [G209/P380]
33) BTnet (SB) [G209/P427]
34) Broadband (ADSL) [G209/P430]
35) Visual Services [SB] [G209/P608]
36) Broadcast Services [SB] [G209/P614]
37) Global Satellite Services [SB] [G209/P618]
38) Incoming IDD Other Services [G209/P258]
39) IP Dial Plus [G209/P350];

and

(ii) that Business shall be disaggregated into additional business and residential activities, each of which shall be further disaggregated according to the following customer classes:

(A) for business activities:

1) Government eg civil and judiciary, civil and defence, local government and community development;
2) Major corporate clients;
3) Small and medium enterprises;
4) Internet service providers;
5) Calls and Access service providers; and
6) Other service providers;

and

(B) for residential activities:

1) Residential customers, each decile by total spend; and
2) Residential customers on BT’s Light User Scheme.

Amendments to form and content

5. BT shall within 14 days of the making of this Direction amend to the satisfaction of the Director the form and content of the additional information to be provided by way of notes comprised in the Financial Statements so as to include, where relevant, information in accordance with Annex C to this Direction.

Amendments to the Accounting Documents

6. BT shall by 28 October 2002 amend each of the Accounting Documents such that they require the Financial Statements and the Standard Service Statements to be prepared such that a reasonably competent qualified accountant recognised by a member of the Consultative Committee of Accountancy Bodies or a registered auditor would be able to understand and interpret those Accounting Documents, the Detailed Attribution Methodology, the Detailed Valuation Methodology, and the Long Run Incremental Cost (Relationships and Parameters) to a level that would allow that accountant or auditor to plan, specify and build systems (whether or not similar to those used by BT), including any Intermediate Systems, which, if populated with the Source Data available to BT, would generate outputs not materially different from those presented in each of the Financial Statements and the Standard Service Statements actually prepared by BT.

7. BT shall, by 28 October 2002, amend the Regulatory Accounting Principles as follows:

(a) Principle 5 (Consistency of Treatment) shall be amended so as to include the following additional text:

"Any such restatements shall be prepared in accordance with the version of the Accounting Documents used to prepare the Financial Statements for the current year. Where BT wishes to use an alternative method of preparation of the restatements (for example, previous versions of the Accounting Documents), it shall obtain the Director’s prior written approval, and shall highlight each such restatement accordingly."

(b) a new Principle 6 shall be inserted as follows:

"Principle 6 – Use of UK GAAP

Unless expressly provided for, generally accepted accounting principles and practices in the United Kingdom are to be followed."

(c) current Principle 6 (Transparency) and Principle 7 (Sampling) shall be renumbered Principle 7 and Principle 8 accordingly; and

(d) Principle 7 (Transparency) shall be amended so as to include the following additional text:

"Transparency will be achieved where a reasonably competent qualified accountant recognised by a member of the Consultative Committee of Accountancy Bodies or a registered auditor would be able to understand and interpret those Accounting Documents, the Detailed Attribution Methodology, the Detailed Valuation Methodology, and the Long Run Incremental Cost (Relationships and Parameters) to a level that would allow that accountant or auditor to plan, specify and build systems (whether or not similar to those used by BT), including any Intermediate Systems, which, if populated with the Source Data available to BT, would generate outputs not materially different from those presented in each of the Financial Statements and the Standard Service Statements actually prepared by BT.

In these Accounting Documents,

‘Intermediate Systems’ are systems and procedures which capture and process relevant Source Data to produce the intermediate documents or records (not themselves being either Source Data, a Financial Statement, or a Standard Service Statement) directly or indirectly necessary to produce Financial Statements, and the Standard Service Statements which comply with the requirements of Condition 78 of BT's licence. Examples of such intermediate documents may include engineering surveys, price indexation and trend models, engineering support systems, network design systems, product billing systems, marketing surveys;

‘Source Data’ are data relating to BT’s operations and are derived directly from and/or collected directly as a result of the day-to-day operations of BT's business or taken from relevant external sources. Such data is processed to provide information to be used by BT in preparing the Financial Statements. Examples of Source Data may include product prices and volumes, survey inputs (such as engineering records), business activity analyses, employee timesheets, contract prices, stock counts, fault reports, invoices, payroll records, ledgers;

and

‘Outputs’ includes, but is not limited to, the individual numbers that appear in the Financial Statements and Standard Service Statements."

8. BT shall, by 28 October 2002, amend the Attribution Methods, the Transfer Charging System, the Accounting Policies and the Long Run Incremental Cost Methodology such that each of those Accounting Documents includes a preamble comprising the following text:

"This Accounting Document has been prepared in accordance with and so as to implement Principle 7 (Transparency) of the Regulatory Accounting Principles."

9. BT shall, by 28 October 2002, amend the Accounting Policies as follows:

(a) a new paragraph 4.2 shall be inserted, such paragraph to set out the definition of each product group which constitutes a disaggregated activity of any Business, such definitions to be in accordance with, where relevant:

(i) the document titled "Product Definitions 2000/2001" which was provided to the Director by BT on 26 April 2002; and

(ii) any definitions of any component, customer class or geographic area which may be provided to BT by the Director on or before 28 September 2002; and

(b) paragraph 4.2 (Principles of Valuation of Fixed Assets in the Current Cost Financial Statements) shall be renumbered paragraph 4.3, and all following paragraphs shall be renumbered accordingly.

10. BT shall, by 28 October 2002, amend the Attribution Methods such that a new paragraph 2.3.3.4 shall be inserted as follows:

"2.3.3.4 Regulatory Cost Exclusions

BT shall exclude all redundancy items from the Financial Statements for the Network Business and all such excluded amounts are to be treated as reconciling items between the Financial Statements and BT’s consolidated financial statements."

11. BT shall, within 14 days of the making of this Direction, amend all of the Accounting Documents such that they clearly indicate which parts of each Accounting Document, and which parts of each of the Detailed Attribution Methodology, the Detailed Valuation Methodology, and the Long Run Incremental Cost (Relationships and Parameters) constitute

(a) a ‘principle’; and/or

(b) a ‘procedure’

for the purposes of the audit report required pursuant to conditions 78.7(c) and 78.7A(b) of the Licence.

12. For the purposes of this Direction,

(a) ‘Intermediate Systems’, ‘Source Data’ and ‘Outputs’ shall have the meaning as set out in 7(d) above;

and

(b) words and phrases in this Direction shall have the meanings ascribed to them in the Licence or the Act as appropriate.


ANNEX A

[Pursuant to paragraph 1 of this Direction, BT shall amend the composition of the Network and Access Business in accordance with this Annex.]

"Network Business" means the Business which includes the revenues, costs and assets derived from or used in activities related to Interconnection taken together.

(a) The revenues are:

(i) the amounts due from Operators for Standard Services;

(ii) the amounts due from Operators for Access Network Facilities;

(iii) other amounts due from Operators for use of any of the network components or parts (groups of network components or parts) listed at Annex B to the Director General’s Direction under the provisions of licence condition 78.14 regarding the regulatory financial statements of British Telecommunications plc published on [date to be inserted];

(iv) the amounts attributable by the Licensee from the other Businesses in respect of any of the network components or parts (groups of network components or parts) listed at Annex B to the Director General’s Direction under the provisions of licence condition 78.14 regarding the regulatory financial statements of British Telecommunications plc published on [date to be inserted];

(v) the amounts due from International Operators in respect of the delivery of incoming international calls; and

(vi) other revenues relating to the costs in (b)(i) to (vii) below.

(b) The costs are:

(i) the capital and running costs of:

(aa) the traffic and non-traffic sensitive portion of the switching, transmission and other apparatus and systems used in providing Network Services consisting in the conveyance of Messages;

(bb) operator centres to the extent that they are used for the provision of call assistance and emergency services and any other facilities or services; and

(cc) the land, cables, ducts, poles, plant and facilities associated with the activities and services described in subparagraph (b) (i) (aa) and (bb);

including, without limitation, the costs of planning, installing, removing, moving, adjusting, maintaining, monitoring and controlling, and undertaking any other necessary operations in respect of, these things and the costs of the equipment and facilities used in undertaking these activities;

(ii) the costs of dealing and communicating with Operators, International Operators and others who convey messages for which payments are made, including, without limitation, the costs of rendering bills to, and collecting payments from, Operators in respect of the activities and services described in subparagraph (b)(i);

(iii) payments to:

(aa) Operators in their capacity as Operators; and

(bb) others in respect of the conveyance of Messages;

(iv) the costs of improving and developing the facilities, equipment, systems, processes and procedures used in providing the activities and services described in subparagraph (b)(i);

(v) the costs of bad debts incurred in connection with the revenue described in subparagraph (a);

(vi) the costs of any overheads and any other appropriate costs attributed to the activities causing the costs described in subparagraph (b)(i) to be incurred;

(vii) the cost of capital incurred in connection with the activities and services described in subparagraph (b)(i) to (vi) inclusive being the product of the applicable rate of return (as notified by the Director to the Licensee from time to time) and the capital employed, which shall cover all the fixed assets, including, without limitation, the facilities and equipment, and current assets less any current liabilities, associated with those costs; and

(viii) costs relating to any of the items in (a)(i) to (iv) above.

(c) The assets are all of the facilities and equipment which cause the costs described in subparagraph (b) to be incurred plus the debtors of the Network Business less any creditors of the Network Business.

"[Retail Narrowband] Access Business" means the Business which includes the revenues, costs and assets as follows:

(a) Revenues, net of low user rebate, are:

(i) the amounts due from customers in respect of periodic charges imposed directly and indirectly by the Licensee for the use and maintenance of Switched Narrowband Lines; and

(ii) the amounts due from customers in respect of charges imposed by the Licensee for connection of Switched Narrowband Lines and for shifting and changing Network Terminating Points, and other similar charges.

(b) The costs are:

(i) the capital and running costs of dealing and communicating with customers in respect of Switched Narrowband Lines, including, without limitation, the costs of rendering bills to, and collecting payments from, those customers in respect of the activities and services described in subparagraph (a)(i) above;

(ii) the costs of any relevant overheads and any other appropriate costs attributed to the activities causing the costs described in subparagraph (a) (ii) to be incurred; and

(iii) transfer charges, including those for Standard Services and Network Services, from other Businesses.

(c) The assets are all of the facilities and equipment which cause the costs described in subparagraph (b)(i) and (ii) to be incurred plus the debtors of the [Retail Narrowband] Access Business less any creditors of the [Retail Narrowband] Access Business.

For the purposes of these definitions, "Switched Narrowband Lines" are lines used to provide switched telephony or ISDN calls providing for connections up to 128 kilobits per second.

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ANNEX B

[Pursuant to paragraph 3(a) of this Direction, BT shall amend the manner in which the Network Business is disaggregated in terms of activities by creating the following new activities for that Business. The items on this list are network components and parts (or groups of network components and parts). These items also form part of the definition of Network Business at Annex A. Gaps have been placed in the list solely to assist the reader.]

1. Local exchange concentrator
2. Local exchange set up
3. Local exchange call set up
4. Main exchange set up
5. Main exchange call duration
6. Remote-local transmission link
7. Remote-local transmission length
8. Local-tandem transmission link
9. Local-tandem transmission length
10. Inter-tandem transmission link
11. Inter-tandem transmission length
12. Product management, policy & planning for PSTN/ISDN
13. National operator assistance
14. International operator assistance
15. Emergency operator assistance
16. Outpayments: geographic calls
17. Outpayments: non geographic calls
18. Outpayments: calls to mobile
19. Outpayments: CNS (formerly Concert)
20. Outpayments: other
21. Public payphones operation
22. Public payphones line
23. International network
24. Copper access lines
25. Fibre access lines
26. Fibre access paths over SDH
27. Network terminating equipment for PSTN/LLU
28. CWSS network terminating equipment & serving exchange equipment
29. DWSS network terminating equipment & serving exchange equipment
30. PDH multiplexors as customer premises equipment
31. SDH multiplexors as customer premises equipment
32. SDH (MSH) multiplexors as customer premises equipment
33. ATM network terminating equipment
34. PDH multiplexors
35. SDH mutliplexors
36. SDH cross connection/grooming equipment
37. Tributary card for SDH
network by size
38. SDH (MSH) mutliplexors
39. SDH (MSH) cross connection/grooming equipment
40. Tributary card for SDH (MSH) network by size
41. Transmission links over fibre
42. Transmission links over radio
43. Inbuilding links
44. ATM switches
45. Customer facing ATM tributary cards by size
46. Network facing ATM tributary cards by size
47. Signalling links
48. Development switching
49. Guarantee schemes
50. Returns of infrastructure etc (eg drop/multiplexors) paid for upfront to BT
51. PSTN specific (line cards, pair gain equipment etc)
52. Passive optical network
53. ISDN 2 specific
54. ISDN 30 specific
55. Phonebooks etc
56. Number Portability Data Amendments
57. Number Portability Set-up Costs
58. Carrier Pre Selection System Set-Up
59. Carrier Pre Selection Operator Set-Up
60. Carrier Pre Selection Customer Set-Up
61. Carrier Pre Selection in life management
62. ASU switches (Featurenet)
63. DDSN switches
64. Universal card platform (for cashless services)
65. IN platform - basic services
66. IN platform - advanced services
67. Copper loop line information & testing
68. Copper cabling within exchange buildings
69. Copper cabling from within exchange buildings to outside
70. Comingling – electricity
71. Comingling - accomodation
72. Comingling - other
73. Colocation
74. Bespoke network build - copper
75. Bespoke network rearrangement - copper
76. Other LLU
77. Product management, policy & planning for LLU/ANFs
78. Private circuit specific: equipment (eg DPCN, test systems)
79. Product management, policy & planning for partial private circuits
80. Shorthaul data/LAN extension specific
81. Flexible bandwidth specific
82. Frame Relay specific (frame relay switches)
83. SMDS specific
84. xDSL specific (eg DSLAMS and CPE)
85. Product management, policy & planning for LLU/ANFs
86. Edge IP routers
87. Core IP routers
88. IP dial up
89. IP fixed access
90. IP broadband
91. IP virtual private networks
92. Voice over IP
93. IP international peering (outpayments)
94. Telex specific
95. Broadcast specific
96. Aeronautical & maritime specific
97. Satellite specific
98. DMS100 call centre

back to contents 


ANNEX C

[Pursuant to paragraph 5 of this Direction, BT shall amend the additional information to be provided by way of notes to the Financial Statements to include information in accordance with this Annex.]

Notes

All information provided by way of notes is on a CCA fully allocated cost basis unless otherwise indicated.

BT’s SFR sectors relate to its Standard Financial Report sectors. These sectors are themselves a broad aggregation of costs from account codes within BT’s accounting general ledger.

Additional information to be provided by way of notes

Purpose

Oftel Ref

Cost category (as used within regulatory LRIC model) analysis for network components, increments and relevant layers of common cost

(LRIC basis)

 

  • review the outputs of BT’s LRIC model for the whole BT group by cost category and components, increments and layers of common costs
  • identify all relevant layers of common costs separately within BT group
  • enable trend analysis of this breakdown to be undertaken
  • enable assessment of cost-volume relationships
  • provide input into network price control reviews
  • ensure LRIC model reconciles to BT group’s total cost and asset & liability base

1a

Summarised account code (i.e. BT’s SFR sectors) for network components, increments and relevant layers of common cost

(LRIC basis)

 

  • review the outputs of BT’s LRIC model for BT’s Network Business by account code and components, increments and layers of common costs
  • identify all relevant layers of common costs separately within BT’s Network Business
  • enable trend analysis of this breakdown to be undertaken
  • provide input into network price control reviews
  • ensure LRIC model reconciles to the total cost and asset & liability base for BT’s Network Business

1b

Cost category (as used within regulatory LRIC model) analysis for international network subcomponents

(LRIC basis)

  • similar to 1a but in respect of the international network

1c

Cost category (as used within regulatory LRIC model) analysis for inland private circuits network subcomponents and relevant layers of common cost

(LRIC basis)

  • review the outputs of BT’s LRIC model for inland private circuits by cost category and network subcomponents and relevant layers of common costs
  • enable trend analysis of this breakdown to be undertaken
  • enable assessment of cost-volume relationships
  • provide input into network price control reviews and market reviews of leased lines
  • ensure LRIC model reconciles to inland private circuits network component’s costs and mean capital employed

1d

Summarised account code analysis (i.e. BT’s SFR sectors) for international network subcomponents

(LRIC basis)

  • similar to 1b but in respect of the international network

1e

Cost category (as used within regulatory LRIC model) analysis for network components and increments

 

  • similar to 1a but on a fully allocated cost basis

 

 

1f

Summarised account code (i.e. BT’s SFR sectors) analysis for network components and increments

  • similar to 1b but on a fully allocated cost basis

1g

Cost category (as used within regulatory LRIC model) analysis for international network subcomponents

  • similar to 1f but in respect of the international network

1h

Cost category (as used within regulatory LRIC model) analysis for inland private circuits network subcomponents

  • similar to 1d but on a fully allocated cost basis

1I

Summarised account code (i.e. BT’s SFR sectors) analysis for international network subcomponents

  • similar to 1e but on a fully allocated cost basis

1j

Analysis by asset category and network components, disaggregated activities & Businesses of the depreciation charge for the year and impact of CCA valuation adjustments on costs for the year: -

e.g.

  • HCA depreciation
  • CCA supplementary depreciation
  • Holding gain
  • Other CCA adjustments
  • impact on profit and loss cost base of the application of CCA methodologies
  • enable trend analysis of this breakdown to be undertaken
  • provides subanalysis (for the cost/gain line items left) of the asset movement statement (4a) in relation to network components, disaggregated activities and Businesses
  • provide input into network price control reviews

 

3

CCA fixed asset movement statement (i.e. a) gross replacement costs brought forward, additions/disposals/transfers, holdings gains/(loss), gross replacement costs carried forward and b) gross depreciation brought forward, HCA depreciation charge, supplementary CCA depreciation, disposals/transfers/other movements, holding gains/(loss), gross depreciation carried forward)

by asset category for BT Group

plus reconciliation to HCA fixed assets movement statement in the group statutory accounts

  • review the breakdown of asset costs between principal asset categories and how such CCA asset values have moved in the year
  • enable trend analysis of CCA asset values to be undertaken
  • provide input into network price control reviews

4a

CCA fixed asset movement statement (i.e. a) gross replacement costs brought forward, additions/disposals/transfers, holdings gains/(loss), gross replacement costs carried forward and b) gross depreciation brought forward, HCA depreciation charge, supplementary CCA depreciation, disposals/transfers/other movements, holding gains/(loss), gross depreciation carried forward)

by asset category

for Mobile Business

  • review breakdown of Mobile Business asset costs between principal asset categories and how such CCA asset values have moved in the year
  • enable trend analysis of CCA asset values to be undertaken
  • assist in the calculation of mean capital employed during 2001/02 (demerger of MMO2 in November 2001)

4b

Operator assistance combinatorial test (i.e. costs and revenues for 5 regions of the world)

(LRIC basis)

  • enable the testing of whether national, international and emergency operator assistance transfer charges cover at least the LRIC costs plus related common costs of providing these services

10

Analysis of BT Only Other network subcomponents' costs (and associated volumes), transfer charges and mean capital employed across disaggregated activities

  • review how BT Only Other subcomponent costs and transfer charges map onto, for example, retail product groups
  • review the impact of the basis of transfer charging for BT Only Other subcomponents on, for example, retail product group results
  • disclose costs and revenues for individual BT Only Other subcomponents
  • provide information for market reviews of certain retail product groups and wholesale (i.e. service provider) products relating to the BT Only Other component
  • assist in dealing with investigations

12

Costs, including transfer charges, and revenues (and associated volumes) for the Directory Enquiry (DQ) activities cascade within the SSB

  • review the basis of transfer charging within the Supplemental Services Business (SSB)
  • disclose the revenues and costs for each of the DQ activities
  • provide information for market reviews of wholesale and retail DQ products
  • reconcile to product group results where appropriate

13

Analysis of Multifunction Platform (MP) subcomponents' costs (and associated volumes), transfer charges and mean capital employed across disaggregated activities

  • review how MP subcomponent costs and transfer charges map onto, for example, retail product groups
  • review the impact of the basis of transfer charging on, for example, retail product group results
  • disclose costs and revenues for individual MP subcomponents
  • provide information for market reviews of certain retail product groups and wholesale (i.e. service provider) products relating to the MP component
  • assist in dealing with investigations

 

14

Total mean capital employed and summarised account code (i.e. BT’s SFR sectors) analysis for all network components

  • review network component costs
  • enable trend analysis of these breakdowns to be undertaken
  • provide input into price control reviews
  • assist in dealing with investigations
  • ensure summarised account code analysis reconciles to BT’s Network Business’s total profit and loss cost base

21b

Revenues, total mean capital employed and summarised account code (i.e. BT’s SFR sectors) analysis by product group/customer class and for each of the Businesses

  • review costs, for example, for product groups
  • review retail costs for narrowband product groups by activity (e.g. customer class)
  • enable trend analysis of these breakdowns to be undertaken
  • provide input into retail price control reviews
  • provide input into NTS retail uplift determinations
  • assist in dealing with investigations
  • ensure summarised account code analysis, together with 21b, reconciles to BT group’s total profit and loss cost base

21c

Analysis by type of product group and by type of OLO of costs, mean capital employed and transfer charges to disaggregated activities (and associated volumes) in relation to outpayments to other licensed operators (OLOs)

  • review how outpayments are accounted for within Accounting Separation
  • review fast growing segment of wholesale call market
  • review the impact of outpayments on BT’s network cost base, for example, for different call types
  • enable trend analysis of outpayment costs and volume breakdowns to be undertaken
  • assist in dealing with investigations

22a

Analysis of Network Business revenues (other than relating to Standard Services) from other licensed operators (e.g. outpayments made by OLOs to BT) and related costs & mean capital employed and associated volumes

  • review how revenues from OLOs (other than those relating to Standard Services) are accounted for within Accounting Separation
  • review fast growing segment of the wholesale call market
  • review the impact of these network receipts (other than those for Standard Services) on BT’s Network Business costs and revenues
  • enable trend analysis of these revenues, costs and volumes to be undertaken
  • provide input into price control reviews

22b

Summarised account code (i.e. BT’s SFR sectors) mean capital employed analysis for all network components

 

  • a mean capital employed equivalent of 21b
  • ensure summarised account code analysis reconciles to BT’s Network Business mean capital employed

 

24b

Summarised account code (i.e. BT’s SFR sectors) mean capital employed analysis by product group/customer class and for each of the Businesses

  • a mean capital employed equivalent of 21c
  • ensure summarised account code analysis, together with 24b, reconciles to BT’s group mean capital employed

24c

Gross call revenues, discounts & option fees by tariff option for each disaggregated activity containing call revenues

  • review the impact of discount schemes on net telephony revenues, including inclusive call allowances and accounting issues arising therefrom
  • enable trend analysis of discounts to be undertaken
  • provide input into retail price control reviews
  • provide input into NTS discount rate determinations
  • assist in dealing with investigations
  • provide a reconciliation to revenues figures appearing in the CCA Financial Statements

26a

Gross revenues, discounts & option fees by customer option for each disaggregated activity in respect of non-call revenues where discount scheme(s) apply

  • as per 26a but in respect of services other than telephony (e.g. leased lines and other data services)

26b

Analysis of revenues & volumes (split between sales to OLOs and BT’s RSB), costs & mean capital employed by individual Standard Service, retail stick, intermediate service, and other types of services within BT’s Network Business

 

  • evaluate the return on capital employed for both individual Standard Services and Network basket groups
  • enable trend analysis to be undertaken
  • provide input into network price control reviews
  • act as a control total for further breakdowns for the other types of services provided by BT’s Network Business. See, for example, BT Only Other (#12), Multifunction Platform (#14), Outpayments (#22a)/Receipts (#22b) and interconnect services (#55)
  • ensure breakdown reconciles to figures appearing within the Network Business Statement of Costs

27

Graphs over time of the various raw indices, index weightings & composite indices used by BT to revalue assets onto a current cost basis

  • evaluate the price trends for composite elements of BT’s asset revaluation indices
  • evaluate the weightings within individual asset revaluation indices
  • evaluate the trend of individual asset revaluation indices
  • provide input into price control reviews and determinations

28

Statement of transfer charges broken down by transfer charge type between Businesses and disaggregated activities

  • review the nature and scale of inter-business transfers
  • enable trend analysis to be undertaken
  • provide input into network and retail price control reviews

35

Revenues split between BT and non-BT service providers, costs& mean capital employed (broken down by individual components and usage factors applied, both on a unit and total basis) and volumes for the various Directory Information products and services

 

  • review the costs and revenues for individual Directory Information services as accounted for within Accounting Separation
  • demonstrate cost-orientation of charges for Directory Enquiry (DQ) Standard Services
  • demonstrate non-discrimination in the costing of DQ Standard Services
  • enable trend analysis to be undertaken
  • provide information for market reviews of Directory Information
  • assist in dealing with investigations

37

Commentary on disaggregated activity results by BT

 

  • enable Oftel to understand individual disaggregated activity results and changes in these results from one year to the next

38c

Estimated economic useful lives, valuation and depreciation basis, survey used for valuation or index used to revalue , historical cost accounting (HCA) & current cost accounting (CCA) depreciation, gross book values (GBV) by year of acquisition, gross replacement costs (GRC) & net replacement costs (NRC) across asset categories

  • review the nature and relative distribution of BT’s asset base
  • evaluate BT’s chosen asset lives for individual asset categories
  • review the relationship between gross HCA and CCA valuations
  • evaluate the appropriateness of the CCA valuation basis for each asset category
  • evaluate the appropriateness of the CCA depreciation methodology for each asset category
  • review the impact of CCA accounting on the cost base
  • enable trend analysis of CCA costs to be undertaken
  • provide input into network price control reviews

42

Marketing expenditure analysis of the top ten campaigns in the financial year, including advertising copy, video and audio tape of the advertising campaigns.

  • enable a review to be undertaken of the attribution to disaggregated activities of the most significant campaigns
  • enable trend analysis to be undertaken
  • assist in dealing with investigations
  • provide input into retail price control reviews
  • provide input into NTS retail uplift determinations

43

Total operating costs & mean capital employed costs (and associated volumes) for each plant group & intermediate activity group and their individual exhaustion, including the disclosure of relevant usage factors, onto each network component & subcomponent

  • review the breakdown of costs to all the different components and subcomponents within BT’s Network Business network (which forms a key element of Accounting Separation)
  • enable trend analysis of this breakdown to be undertaken
  • provide input into network price control reviews
  • ensure total plant group and intermediate activity group costs reconcile to the cost base for BT’s Network Business

44

Fixed fee revenues (including line rental) by tariff package & associated network costs

 

  • review how tariffs are accounted within Accounting Separation
  • review recent tariff developments within telephony market
  • check for the possible mismatch of costs & revenues
  • provide input into retail price control reviews
  • assist in dealing with investigations

 

45

Analysis of profits/(losses) on asset transfers to and from BT (e.g. to/from Concert) plus analysis of such assets transferred

  • assess the profitability of such transactions and the implications they have for BT’s regulatory cost base

46

Charges made to related parties of BT (e.g. Concert) for outsourcing services and the underlying cost to BT of providing these services, by individual service provided

  • assess the level of profitability on these services and the impact this has, where relevant, on the related party’s cost base (e.g. Concert)
  • provide input into network and international price control reviews (where not deemed competitive)

47

Revenues, associated volumes and analysis of purchases from BT’s Network Business (i.e. by individual Standard Service, outpayment type, retail stick, intermediate service, interconnect service and any other transfer charges) in respect of each product within a product group and direct costs

  • to provide gross and net margin information for individual products (or product subgroups) within each product group
  • make an initial assessment as to whether like products are grouped together within product groups
  • enable an assessment of what falls within each product group and how this has changed from one year to the next
  • assess the robustness of BT’s product group disaggregated activities results
  • review compliance with C78 and European directives
  • enable trend analysis to be undertaken
  • assist in dealing with investigations
  • provide a starting point information for market reviews of retail products and services
  • ensure the analysis of transfer charges reconciles to figures disclosed within the CCA Financial Statements

52

Analysis of costs & revenues of each MDF site where LLU offered

  • show revenues and costs of each MDF site, and within each site, breakdown of service profitability (basis of determining service profitability yet to be decided)
  • provide information for market reviews of, for example, colocation and comingling services
  • assist in dealing with investigations and price determinations

53

Revenues, costs & mean capital employed (broken down by individual components and usage factors applied, both on a unit and total basis) and volumes for the various Interconnect basket Standard Services

  • a sub-analysis of #27 in respect of Interconnect basket Standard Services
  • demonstrate cost-orientation of Interconnect Basket Standard Services
  • demonstrate non-discrimination in the costing of Interconnect Basket Standard Services

54

Statement of costs and revenues for interconnect services (which are not Standard Services) i.e. by individual components and usage factors applied, both on unit basis and on a total basis (in the latter case with volumes and revenues split between OLOs and BT’s RSB)

  • provide costs and revenues for each individual interconnect service, for example, in relation to xDSL interconnection at the ATM switch
  • demonstrate non-discrimination in the costing of these services vis a vis other services including Standard Services

55

CPS set up costs and their recovery over time on a discounted cash flow basis