Contents
Summary
Chapter
1 Background
Chapter
2 The Director’s proposal
Chapter
3 Representations
Annex
1 – BT’s Draft Notice
Annex
2 – Kingston’s Draft Notice
Annex
3 - Description of services by reference to BT’s Price List
Summary
BT’s request
S.1 British Telecommunication
plc (BT) has asked the Director General of Telecommunications ("the
Director") to remove the following services from the scope of BT’s Condition
43 which is a continued provision contained in Schedule 1 of the Continuation
Notice given to BT on 23 July 2003, and which took effect on 25 July
2003. BT has used the following terminology to describe the services
(Annex 3 to this consultation document states where in BT’s Electronic
Price List these services can be found);
- BTequIP;
- BTNet (including
BTNet Flex);
- CellStream;
- FrameStream;
- Metro VPN;
- Short Haul Data
Services;
- X.25 services.
- FeatureNet and
International FeatureNet.
- International
Facilities
- cable landing
stations;
- international
backhaul;
- satellite uplinks;
- International
Private Leased Circuits.
- Internet Protocol
Virtual Private Network (IPVPN) services, including IP Clear.
- Telex.
Continuation
of licence conditions
S.2 Although individual
licences made under section 7 of the Telecommunications Act 1984 have
now been replaced in part by General Conditions made under the Communications
Act 2003 ("the Act"), there were a number of specific conditions included
in some individual licences which cannot be replaced by new conditions
under the powers contained in the Act until the relevant market reviews
have been completed and implemented. Schedule 18, paragraph 9 of the
Act allows the Director to issue Notices to continue provisions in Licence
Conditions until such time he has reviewed the relevant market. BT’s
Condition 43 was made to continue in force by such a continuation notice
issued to BT on 23 July 2003 BT’s
Continuation Notice.
Market reviews
S.3 The European
Commission ("the Commission") has adopted a Recommendation on Relevant
Products and Services Markets (the "Recommendation") which lists a set
of markets in which ex ante regulation may be warranted. However, National
Regulatory Authorities ("NRAs") are able to regulate markets that differ
from those identified in the Recommendation where this is justified
by national circumstances. The Director is obliged to take the utmost
account of this Recommendation when defining markets appropriate to
national circumstances. In some instances the Director has exercised
his discretion to define markets other than those included in the Recommendation,
and he has notified these draft decisions to the Commission and other
NRAs.
S.4 The services
listed in paragraph S1 above are not included in the markets listed
in the Recommendation and, with the two exceptions detailed in paragraph
S.8 below, are not included in markets which the Director has exercised
his discretion to define as markets appropriate to national circumstances.
Condition
43
S.5 The continued
provision Condition 43 requires BT to provide telecommunications services
other than voice telephony services on request. Services which BT is
required, by Condition 43, to provide are also subject to continued
provision Conditions 57 and 58 which, respectively, prohibit undue preference
and undue discrimination and require publication of charges, terms and
conditions. These conditions too were continued in force by BT’s Continuation
Notice.
Removal of
regulatory obligations
S.6 Continued provision
Condition 43 applies except to the extent that the Director consents
otherwise, and BT initially asked the Director to grant such consent
in respect of the services listed in paragraph S1 above. The Director
considers, however, that it is more appropriate to discontinue Condition
43 in respect of the services which he agrees should no longer be subject
to that continued provision. The process and criteria which apply to
a discontinuation are different to those which apply where the Director
is granting a consent under Condition 43, but the practical outcome
is likely to be similar. Paragraph 3.20 of the Statement Continuing
Licence Conditions after 25 July 2003 published on 10
September ("the September Statement") reported that the Director had
indicated that he would consider whether the application of Condition
43 should be disapplied from particular services using the consent mechanism
contained in that condition. The Director now considers it more appropriate
to discontinue Condition 43 in respect of specific services, rather
than issue a consent under that condition.
Kingston Communications
(Hull) plc
S.7 Kingston Communications
(Hull) plc ("Kingston") is also subject to a continued provision Condition
43 which imposes the same obligations on Kingston as BT’s Condition
43 imposes on BT. Kingston’s Condition 43 was contained in Schedule
1 of a continuation notice given to Kingston on 23 July 2003
Kingston’s Continuation Notice
with effect from 25 July 2003.
The Director’s
proposal
S.8 The Director
proposes that continued provision Condition 43 will cease to have effect
in respect of all of the services listed in paragraph S.1 above except
Short Haul Data Services and BT Net Flex, for the reasons set out in
Chapter 2. The Director also proposes that continued provision Condition
43 in Kingston’s Continuation Notice shall cease to have effect in respect
of the same services, to the extent that Kingston is obliged by its
continued provision Condition 43 to supply those services. Where BT
or Kingston is no longer obliged by its continued provision Condition
43 to supply a service, the continued provision Condition 57 prohibition
of undue preference and undue discrimination and the continued provision
Condition 58 obligation to publish charges, terms and conditions will
also cease to apply to that service. Draft discontinuation notices for
each of BT and Kingston are attached to this consultation document at
Annexes 1 and 2.
Consultation
S.9 Although the
Act does not require the Director to consult before discontinuing a
Continuation Notice, paragraph 5.20 of the September Statement announced
that the Director had decided that it would be appropriate to carry
out a public consultation on each proposal for discontinuation for a
short period only, and he stated that in most cases this would be for
a 14 day period. The present document is therefore inviting interested
parties to make representations within the 14 day period to 10 October
2003.
Chapter
1
Background
Continuing licence
conditions
1.1 On 10 September,
Oftel published a statement "Continuing Licence Conditions after 25
July". As the statement explained, when the new EU communications regime
was implemented in the UK in 25 July 2003, individual licences granted
under section 7 of the Telecommunications Act 1984 were replaced by
general conditions of entitlement which apply to all persons providing
electronic communications networks and services. Additionally, individual
providers may be subject to specific conditions, such as those imposed
as a result of a finding of Significant Market Power (SMP), Access Related
Conditions or conditions imposed as a consequence of a provider being
designated as a universal service provider.
1.2 The new Directives
seek to ensure that there is a coherent transition from the old regime
to the new regime and to ensure that there is no regulatory gap. The
Director has carried out already a number of consultations in relation
to the new regime such as consultations on the General Conditions, Universal
Service Conditions and Conditional Access Conditions. Also he has commenced
a number of market reviews proposing the imposition of SMP Service Conditions
along with consultations on the imposition of other Access-Related Conditions.
1.3 In order to
avoid a regulatory gap, the Directives permit and require Member States
to continue the existing regime until such time as each Member State
can complete its assessment of the imposition of the new SMP services
and Access-Related (other than Conditional Access) conditions. This
has been implemented in the United Kingdom by paragraphs 9 and 22 of
Schedule 18 of the Communications Act 2003 (the "Act"). Schedule 18
permits the Director to issue continuation notices which have the effect
of continuing certain Licence Conditions and Interconnection Directions
under the existing regime for a transitional period.
Condition 43
1.4 As was explained
in paragraphs 3.8 to 3.10 of the September Statement, one of the conditions
which was continued was condition 43, which requires BT and Kingston
to provide telecommunications services consisting in the conveyance
of messages other than voice telephony services on request.
1.5 Services which
are subject to this condition are also subject to continued provisions
in Conditions 57 and 58 of the licences granted to BT and Kingston which,
respectively, prohibit undue preference and undue discrimination and
require publication of charges, terms and conditions for those services
which BT and Kingston are obliged by continued provision Condition 43
to supply. Conditions 57 and 58 are also the subject of continued provisions,
continued by BT’s and Kingston’s Continuation Notices.
1.6 The continued
provision Condition 43 applies to BT and to Kingston except to the extent
that the Director consents otherwise. BT originally asked the Director
to grant consent, under the provisions of the condition itself, to the
continued condition not applying to the services which BT had specified.
The Director believes, however, that it is more appropriate to discontinue
the continued provisions in BT’s and Kingston’s Continuation Notice
for Condition 43 in respect of those services which the Director agrees
should no longer be subject to the provisions of that condition. Discontinuation
removes the old regime regulation in its entirety, either following
a market review or in the absence of a market review, as new regulation
can only be introduced following a market review in a way consistent
with the new regime. A consent granted under the terms of continued
old regime regulation could, however, be withdrawn. Although the process
and criteria which apply to these two distinct approaches are different,
the practical outcome is likely to be similar.
Process for discontinuing
continued provisions
1.7 As was explained
in chapter 5 of the September Statement, Schedule 18 paragraph 9(11)
of the Act requires the Director, as soon as reasonably practicable
after making the Continuation Notice, to take all steps necessary to
enable him to decide whether or not to set a condition for the purpose
of replacing the continued provision. That statement also explained
that Schedule 18 paragraph 9 (12) of the Act requires the Director to
give a notice that the continuation notice ceases to have effect, and
that he must do this as soon as reasonably practicable after taking
a decision to impose (or not to impose) conditions under the new regime.
A draft notice is attached at Annexes 1 and 2 to the present consultation
document, notifying BT and Kingston that the continued provision Condition
43 in BT’s and Kingston’s Continuation Notice no longer applies to the
services set out at paragraph 2.4 below.
1.8 Although the
Act does not require the Director to consult before discontinuing a
Continuation Notice, the Statement published on 10 September announced
that the Director had decided that it would be appropriate to carry
out a public consultation on each proposal for discontinuation for a
short period only, and he stated that in most cases this would be for
a 14 day period. The present document is therefore inviting interested
parties to make representations within the 14 day period to[.... ]When
he has considered any representations, the Director will then decide
whether to discontinue the continued provision Condition 43 in BT’s
and Kingston’s Continuation Notices in respect of the services set out
in paragraph 2.4 below.
Chapter
2
The Director’s
proposal
2.1 The Director
proposes to discontinue continued provision Condition 43 in BT’s Continuation
Notice in respect of the services listed in paragraph S1 above except
for BTNet Flex and Short Haul Data Services. To the extent that
Kingston is also obliged to supply these services, the Director proposes
to discontinue continued provision Condition 43 in Kingston’s Continuation
Notice in respect of the same services, with the same exceptions.
2.2 The Director
is not proposing to include BT Net Flex and Short Haul Data Services
in the list in paragraph 2.4, as he is considering these services within
the context of his reviews of leased lines and wholesale symmetric broad
access and conveyance. The distinction between these two services and
the other data services is explained in paragraph 2.7 below.
2.3 Paragraph 9(11)
of Schedule 18 of the Act requires the Director as soon as reasonably
practicable after giving the Continuation Notice, to take all steps
necessary to enable him to decide whether or not to set a Condition
for the purpose of replacing the continued provision. Paragraph 9(12)
of Schedule 18 of the Act requires that he must then decide as soon
as reasonably practicable whether or not to exercise his power to set
a Condition within the categories set out in the Act.
2.4 In the case
of the services listed in paragraph S1 above, other than BT Net Flex
and Short Haul Data Services, the Director currently has no plans to
identify the relevant markets for the purpose of conducting market reviews,
and he believes, therefore, that it is appropriate to discontinue the
continued provision Condition 43 in respect of the following services:
(Further reasons for the Director’s proposed decision are given below.)
- BTequIP;
- BTNet (excluding
BTNet Flex);
- CellStream;
- FrameStream;
- Metro VPN;
- X.25 services.
- FeatureNet and
International FeatureNet.
- International
Facilities
- cable landing
stations;
- international
backhaul;
- satellite uplinks;
- International
Private Leased Circuits.
- Internet Protocol
Virtual Private Network (IPVPN) services, including IP Clear.
- Telex.
"Data services"
and IVPN services
2.5 Oftel is currently
reviewing the wholesale symmetric broadband call origination and trunk
segments markets, and also the retail leased lines markets. The consultation
document Review
of the retail leased lines, symmetric broadband origination and wholesale
trunk segments markets published on 11 April (the "April
consultation document"), sets out the Director’s initial view that retail
leased lines are in different economic market(s) to "other (symmetrical)
data products, such as symmetric broadband Internet access and VPNs".
2.6 The April consultation
document (paragraph 2.11) recognised that the outcome of the review
could affect a range of retail services, in addition to leased lines,
including "all retail services which use the wholesale input services
which are part of the relevant wholesale markets ie symmetric broadband
origination and trunk segments". Most of the "Data Services" and IVPN
services which BT has asked the Director to remove from the scope of
Condition 43 fall into this latter category. However, the document did
not attempt to define or review these retail markets; the analysis of
markets downstream from symmetric broadband origination and trunk segments
was restricted to consideration of the markets for retail leased lines.
The document went on to state that in relation to these services "the
Director believes that the most pertinent issue in the context of this
review is not whether they should be subject to retail regulation, but
ensuring that any dominance found to exist in the provision of the relevant
wholesale services cannot be exploited through charging excessive prices,
so raising the costs of the retail services to end users, or leveraged
into the provision of retail services to the detriment of consumers".
It is the Director’s view that when dealing with dominance at the wholesale
level, remedies should, where possible, be applied at that wholesale
level.
2.7 The Director
remains of the view that, with the exception of Short Haul Data Services
and BT NetFlex, it is unlikely that it will be appropriate to identify
and review these further retail markets in addition to the retail markets
defined in Oftel’s review of the retail leased lines and wholesale symmetric
broadband origination/trunk segments markets. The Data Services and
IVPN services are constructed using symmetric broadband origination
and, in many cases, trunk segments and are therefore in markets that
are downstream from these markets. The exceptions are retail Short Haul
Data Services (otherwise known as LAN Extension Circuits or LESs) and
BT NetFlex which cannot economically, and, in some cases, technically
be constructed using conventional SDH/PDH leased lines, as these services
use Ethernet presentation. The services will be considered in the Explanatory
Statement and draft Notification on retail leased lines markets and
wholesale symmetric broadband origination and trunk segments markets
which the Director expects to publish later this year.
2.8 As the remainder
of these services, ie BT equIP, BTNet (but excluding BTNet Flex),
Cellstream, Framestream, Metro VPN, X25 and Internet Protocol Virtual
Private Network ("IVPN") services including IPClear, do not fall within
markets included in the Commission’s Recommendation on relevant product
and services markets, and as the Director has decided, for the time
being, not to identify and review the relevant markets for these services,
it is appropriate that regulation continued in respect of these services
should be disapplied.
2.9 The Director
proposes, therefore, to discontinue continued provision Condition 43
in BT’s and Kingston’s Continuation Notices in respect of these services.
As continued provisions Conditions 57 and 58 only apply in cases where
the service being provided is a service which BT and Kingston are obliged
to provide, they will cease to have effect in respect of all of the
services which are intended to be the subject of this discontinuation
as soon as the discontinuation takes place. In the Director’s view,
no other continued conditions have a bearing on these services
International
Facilities
2.10 In Chapter
6 of the Explanatory Statement Wholesale
International Services Markets, which was published on
26 August, the Director explained that he had not identified or reviewed
the market(s) in which cable landing stations, international backhaul
and satellite uplinks fall and, should a dispute arise, he would consider
identifying and analysing the relevant market and, if necessary, regulate
that market under his relevant powers. Given this decision not to identify
and review relevant markets at this point, the Director’s initial view
is that regulation continued in respect of these services pending an
assessment of the need for regulation under the new regime, should now
be disapplied.
2.11 Therefore,
the Director proposes to discontinue continued provision Condition 43
in BT’s Continuation Notice in respect of these services. As has been
explained in preceding paragraphs of this document, continued provisions
Conditions 57 and 58 will, therefore, no longer apply. The Director
believes that there are no other continued conditions which relate to
these services.
Telex, Featurenet,
International Featurenet and International Private Leased Circuits
2.12 Telex, Featurenet,
International Featurenet and International Private Leased Circuits do
not fall within markets which are included in the Commission’s Recommendation
on markets susceptible to ex ante regulation, and the Director
currently has no plans to identify and review the relevant markets.
He is proposing, therefore, to discontinue continued provision Condition
43 in BT’s Continuation Notice in respect of these services. Therefore
continued provisions Conditions 57 and 58 will no longer apply to these
services. In the Director’s view, no other continued conditions have
a bearing on these services.
Summary of
proposals
2.13 Subject to
this consultation and consideration by the Director of any responses
to it, the Director proposes that Condition 43, which is a continued
provision contained in Schedule 1 of the continuation notices given
to BT and to Kingston on 23 July 2003, will cease to have effect in
respect of the services set out in paragraph 2.4 above.
Future consultation
2.14 The present
proposal to discontinue continued provision Condition 43 in BT’s Continuation
Notice and Kingston’s Continuation Notice in respect of the services
listed in paragraph 2.4 above merely reflects the fact that the Director
currently has no plans to review the markets in which these services
fall and, therefore, it is no longer appropriate to maintain continued
regulation in force. For the avoidance of doubt, the Director wishes
to emphasise that he retains the discretion under the new regime to
identify and review any markets in which these services fall at any
time in the future. This includes at any time during the present reviews
of wholesale and retail markets, though the Director’s present expectation
is that this is unlikely.
Chapter
3
Representations
3.1 The Director
has stated in the Statement "Continuing Licence conditions after 25
July", published on 10 September, that, in the majority of cases, before
discontinuing any provisions of any Continuation Notice, he would consult
on the matter for at least 14 days. The Director is publishing this
consultation document to allow interested parties to make any representations.
After considering any such representations, the Director will, if appropriate,
issue the notice of discontinuation in respect of the service specified
in this document. Representations must arrive at Oftel no later than
close of business on 10 October 2003.
3.2 Where possible,
comments should be made in writing and sent by email to michael.richardson@oftel.gov.uk.
However, copies may also be posted or faxed to the address below. If
any parties are unable to respond in one of these ways, they should
discuss alternatives with:
Michael Richardson
Oftel
50 Ludgate Hill
London
EC4M 7JJ
tel: 020 7634 8916
fax: 020 7634 8847
Further copies
of this document
3.3 This document
can be viewed on Oftel’s website, www.oftel.gov.uk. Paper copies and
more accessible formats such as large print, Braille, disc and audio
cassette can be made available on request. Please contact Oftel’s Research
and Information Unit by telephoning 020 7634 8761 or by sending an e-mail
to infocent@oftel.gov.uk.
Publication of
representations
3.4 On this occasion,
the Director will not be inviting interested parties to comment on the
representations made by others. However, in the interests of transparency,
all representations will be published, except where respondents indicate
that a response, or part of it, is confidential. Respondents are therefore
asked to separate out any confidential material into a confidential
annex which is clearly identified as containing confidential material.
Oftel will take steps to protect the confidentiality of all such material
from the moment that it is received at Oftel’s offices. In the interests
of transparency, respondents should avoid applying confidential markings
wherever possible.
3.5 Non-confidential
representations can be viewed on Oftel’s website in the Publications
section under Responses to Oftel consultations. They can also be viewed
at Oftel’s Research and Information Unit. Appointments must be made
in advance by telephoning 020 7634 8761 or by sending an e-mail to infocent@oftel.gov.uk
Annex 1
Proposed
notice that certain continued provisions set out in the continuation
notices given to British Telecommunications plc on 23 July 2003 will
cease to have effect from the […]
1.
The Director General of Telecommunications (‘the Director’), in accordance
with Paragraph 9(12) of Schedule 18 to the Communications Act 2003 (‘the
Act’) hereby gives notice to British Telecommunications plc ('BT’) that
certain continued provisions contained in Schedule 1 of the continuation
notice given to BT on 23 July 2003, which had effect from 25 July 2003,
('the Continuation Notice'), will cease to have effect to the extent
set out in Schedule 1 to this notice (‘the Discontinued Provisions’)
from the […].
2.
In giving this notice, the Director has, in accordance with Paragraph
9 (11) of Schedule 18 to the Act, taken all steps necessary for enabling
him to decide whether or not to set a condition under Chapter 1 of Part
2 of the Act for the purpose of replacing the continued provisions and
whether or not to exercise his power to set a condition under that Chapter
for that purpose.
4.
All directions, determinations, consents and other provisions which
were continued under the Continuation Notice by virtue of Paragraph
9(8) of Schedule 18 to the Act will also cease to have effect from […]
to the extent that they were given or made for the purposes of the Discontinued
Provisions.
5.
To the extent that the Continuation Notice does not cease to have effect
under Paragraph 1 of this notice, the Continuation Notice shall continue
to have effect until the Director has given a further notice to BT in
accordance with Paragraph 9(2) of Schedule 18 to the Act that it shall
cease to have effect.
6.
The Director issued a consultation as to his proposals to discontinue
the provisions on […] and requested comments by […]. The Director has
taken into account the comments he received during that consultation.
7.
In this notice, except as otherwise provided or unless the context otherwise
requires, words or expressions shall have the meaning assigned to them.
For the purposes of interpreting this notice, headings and titles shall
be disregarded.
DAVID
ALBERT EDMONDS
DIRECTOR
GENERAL OF TELECOMMUNICATIONS]
[Date]
Schedule 1
Continued
provision Condition 43, which is contained in Schedule 1 of the continuation
notice given to BT on 23 July 2003 and which took effect from 25 July
2003, will cease to have effect in respect of the services set out below
from the […].
- BTequIP;
- BT Net (excluding
BT NetFlex)
- CellStream;
- FrameStream;
- Metro VPN;
- X.25 services.
- FeatureNet and
International FeatureNet.
- cable landing
stations;
- international
backhaul;
- satellite uplinks;
- International
Private Leased Circuits.
- Internet Protocol
Virtual Private Network (IPVPN) services, including IP Clear.
In
this Schedule, except as otherwise provided or unless the context otherwise
requires, words or expressions shall have the meaning assigned to them
and otherwise any word or expression shall have the same meaning as
it has in the Act or if it has no meaning there in BT's price list.
Annex
2
Proposed
notice that certain continued provisions set out in the continuation
notices given to Kingston Communications plc on 23 July 2003 will cease
to have effect from the […]
1.
The Director General of Telecommunications (‘the Director’), in accordance
with Paragraph 9(12) of Schedule 18 to the Communications Act 2003 (‘the
Act’) hereby gives notice to Kingston Communications plc ('Kingston')
that certain continued provisions contained in Schedule 1 of the continuation
notice given to Kingston on 23 July 2003, which had effect from 25 July
2003, ('the Continuation Notice'), will cease to have effect to the
extent set out in Schedule 1 to this notice (‘the Discontinued Provisions’)
from the […].
2.
In giving this notice, the Director has, in accordance with Paragraph
9 (11) of Schedule 18 to the Act, taken all steps necessary for enabling
him to decide whether or not to set a condition under Chapter 1 of Part
2 of the Act for the purpose of replacing the continued provisions and
whether or not to exercise his power to set a condition under that Chapter
for that purpose.
4.
All directions, determinations, consents and other provisions which
were continued under the Continuation Notice by virtue of Paragraph
9(8) of Schedule 18 to the Act will also cease to have effect from […]
to the extent that they were given or made for the purposes of the Discontinued
Provisions.
5.
To the extent that the Continuation Notice does not cease to have effect
under Paragraph 1 of this notice, the Continuation Notice shall continue
to have effect until the Director has given a further notice to Kingston
in accordance with Paragraph 9(2) of Schedule 18 to the Act that it
shall cease to have effect.
6.
The Director issued a consultation as to his proposals to discontinue
the provisions on […] and requested comments by […]. The Director has
taken into account the comments he received during that consultation.
7.
In this notice, except as otherwise provided or unless the context otherwise
requires, words or expressions shall have the meaning assigned to them.
For the purposes of interpreting this notice, headings and titles shall
be disregarded.
[DAVID
ALBERT EDMONDS
DIRECTOR
GENERAL OF TELECOMMUNICATIONS]
[Date]
Schedule 1
Continued
provision Condition 43, which is contained in Schedule 1 of the continuation
notice given to Kingston on 23 July 2003 and which took effect from
25 July 2003, will cease to have effect in respect of the services set
out below from the […].
- BTequIP (Kingston
equivalent);
- BTNet (excluding
BTNetFlex) (Kingston equivalent);
- CellStream;
- FrameStream;
- Metro VPN;
- X.25 services.
- FeatureNet and
International FeatureNet.
- cable landing
stations;
- international
backhaul;
- satellite uplinks;
- International
Private Leased Circuits.
- Internet Protocol
Virtual Private Network (IPVPN) services, including IP Clear.
In
this Schedule, except as otherwise provided or unless the context otherwise
requires, words or expressions shall have the meaning assigned to them
and otherwise any word or expression shall have the same meaning as
it has in the Act or if it has no meaning there, in BT's price list
to the extent Kingston offers services which are substantially the same.
Annex 3
Description
of services by reference to BT’s Price List
As many of the services
named in BT’s request are BT-specific products, rather than generic
product types, Oftel is including in this annex a table of references
to these products (provided by BT) contained in BT’s Electronic Price
List (which is available on-line at http://www.serviceview.bt.com/list/homepage.htm).
This list contains all of the services included in BT’s request, with
the exception of the International Facilities. Oftel’s definition of
those services can be found in chapter 6 of the Explanatory Statement
"Wholesale International Services Markets", which was published on 26
August.
Oftel recognises
that where Kingston supplies the services which have been listed by
reference to BT’s price list, such services may be referred to by other
product names.
Product name Entry
in Electronic Price List
BTequip: section
28, part 3
BTnet (including
BTnet Flex) section 28, parts 5 to 16 inclusive (see also
note 1 below)
Cellstream section
35
Framestream section
38
MetroVPN section
28, part 18
Short Haul Data
Services section 12, part 10
X.25 services section
13
FeatureNet and International
FeatureNet section 21
International Private
Leased Circuits section 25
IPVPN services,
including IP Clear section 47 except
the third item in
part 2, which is a Dial
Telex section
8, parts 1 and 8
Note 1: Listed at
part 4 of section 28 is another product which for
historical reasons
has a "BTnet" name, BTnet Dial IP. This product
is not covered by
BT’s formal request.
|
