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A statement issued by the Director General of Telecommunications July 2000 Chapter 1 The issues Chapter 2 Responses to the consultation document Chapter 3 Developments since the end of the consultation period Chapter 4 Oftel's long term strategy Chapter 5 Oftel's conclusions Chapter 6 Future review of developments S1. This document summarises Oftel’s conclusions following consultation about the nature of the wholesale Pre-paid services offered to service providers by Vodafone and BTCellnet ("Pre-paid mobile services and the regulatory framework" July 1999). S2. The key purpose of the consultation document was to set out Oftel's current view on how the regulatory rules operate in this area. There were, however, considerable uncertainties about how far pre-paid functionality - principally the databases which manage customer credits - is, or needs to be, embedded in mobile networks and should therefore be an integral part of a wholesale service; or whether some of the functionality could equally be offered by service providers if they were able to receive a more basic underlying pre-pay service. Pre-pay "databases" S3. Pre-paid mobile services are reliant on systems ("databases") which record credits purchased by customers and which deduct credits as calls are made. When a pre-paid customer attempts to make or receive a call, the network interrogates the database to check that the customer has sufficient credit to do this. The consultation document addressed concern that wholesale Pre-paid services oblige independent service providers to use the operators’ databases, rather than allowing them to connect their own. It had been claimed that this restricted the ability of independent companies to offer innovative tariffs and services. Regulatory obligations S4. As operators with Market Influence, BTCellnet and Vodafone are obliged, by the terms of their licences, to offer wholesale services to independent service providers, who may then resell those services to end users. BTCellnet and Vodafone are prohibited from showing undue discrimination or exercising undue preference when supplying these wholesale services. An operator with Market Influence may be deemed to have breached those prohibitions if it favours to a material extent a business carried on by itself so as to place at a significant competitive disadvantage other companies competing with that business. Oftel’s long term strategy S5. Oftel’s overall goal is to achieve the best deal for consumers in terms of quality, choice and value for money. Whilst the consultation document was concerned with wholesale services and was addressed principally to service providers and operators, Oftel’s evaluation of comments received was undertaken with a primary concern for the impact which any regulatory intervention at the wholesale level might have on the retail market. The key issues S6. The consultation document asked for initial comments on the customer benefits which might be expected to flow from implementation of either (i) a complete separation between pre-pay functionality and the rest of the mobile networks or (ii) more flexible use by independent service providers of pre-pay functionality integrated with the networks. The consultation document also sought comments on the technical feasibility and likely overall cost of making a physical separation between pre-pay functionality and the rest of the network, and asked what might be the most efficient means of effecting that separation. Finally, the document also invited the industry to comment on whether any proposals for airtime to be offered to service providers in unstructured form should include airtime for pre-paid services. A separation between pre-pay functionality and the rest of a mobile network S7. Responses to the consultation document highlighted few tangible benefits which a full engineering separation might enable independent service providers to offer, over and above what could be achieved through other less disruptive means. Furthermore, none of the responses provided any quantified information about the likely cost of implementing a separation. Responses from mobile network operators emphasised that although, conceptually, the "databases" can be considered as self contained systems, in practice functionality is now dispersed across the networks. S8. To ensure consistency with its long term strategy, Oftel would be unlikely to intervene, ex ante, to require separation in the absence of reasonable evidence that the benefits of doing so would outweigh the costs. The responses to the consultation document did not provide evidence that this is the case. Therefore, Oftel does not intend, at this stage, to consult more widely with consumer groups and others with a view to requiring BTCellnet and Vodafone to implement this separation. Connection of independent pre-pay systems to the mobile networks S9. Nevertheless, Oftel recognises that some service providers may see merit in connecting their own stand-alone pre-pay systems to the mobile networks, in competition with the existing integrated systems, and recommends that these service providers should negotiate with the operators the access which they require. However, given the inconclusive nature of the responses made to the consultation document, Oftel does not believe, at present, that a case has been made for ex ante intervention requiring BTCellnet and Vodafone to design and offer a standard connection service in advance of specific requests being made by individual service providers. More flexible use of pre-pay functionality which is integrated with the networks S10. Here again, formal responses to the consultation document provided little information about the technical feasibility of allowing service providers more flexible use of or access to pre-pay functionality operated by BTCellnet and Vodafone as an integral part of their networks. However, subsequent discussion with the network operators, in public forum and privately with Oftel, has indicated that the operators could offer more flexible use of their own systems, though costs were not quantified. This Statement warns BTCellnet and Vodafone that, to avoid breaching the prohibitions on undue preference and discrimination, they must negotiate in good faith with independent service providers which make reasonable and specific requests for more flexible use of the databases operated by BTCellnet and Vodafone. S11. Oftel hopes that, in any event, agreements of this kind, and agreements to connect stand-alone pre-payment systems, may be negotiated through normal commercial channels, without the need for either party to rely on the regulatory framework. There are signs that the increasing level of competition in the mobile market is starting to create an environment where such negotiation is becoming, by necessity, more common. Price discrimination at the wholesale level between pre and post paid airtime S12. On the basis of the limited evidence submitted, Oftel sees some merit in the view expressed by some respondents that, where service providers might operate their own pre-payment systems and therefore would not require the use of the operators’ pre-payment functionality, it would be difficult to justify the imposition of contractual constraints on the ability of independent service providers to supply wholesale airtime to end users on either a pre-paid or post paid basis. Others argued that there appears to be little merit in creating arbitrage opportunities simply by unbundling the present bundled wholesale price for pre-pay functionality and airtime. In the circumstances, it appears that there is no need for any immediate regulatory intervention.
The issues Industry consultation 1.1 In July 1999, Oftel published an industry paper "Pre-paid mobile services and the regulatory framework". The document was published in response to concern from independent mobile service providers that the mobile network operators were restricting their freedom to devise retail products for the Pre-pay market. To support this view, independent service providers had pointed to the fact that no independent company had been able to enter this market except as a distributor of an operator's branded retail product. 1.2 The key purpose of the consultation document was to set out Oftel's current view on how the regulatory rules operate in this area. There were, however, considerable uncertainties about how far pre-paid functionality - principally the databases which manage customer credits - is, or needs to be, embedded in mobile networks and should therefore be an integral part of a wholesale service; or whether some of the functionality could equally be offered by service providers if they were able to receive a more basic underlying pre-pay service. 1.3 The consultation document asked for initial comments on the customer benefits which might be expected to flow from implementation of either (i) a complete separation between pre-pay functionality and the rest of the mobile networks, or (ii) more flexible use by independent service providers of pre-pay functionality integrated with the networks. The consultation document also sought comments on the technical feasibility and likely overall cost of making a physical separation between pre-pay functionality and the rest of the network, and asked what might be the most efficient means of effecting that separation. Finally, the document also invited the industry to comment on whether any proposals for airtime to be offered to service providers in unstructured form should include airtime for pre-paid services. Earlier enforcement action 1.4 Shortly before publication of the consultation document, and following investigation of possible licence breaches, BTCellnet and Vodafone had both agreed to offer wholesale Pre-pay services on contractual terms which would allow third parties to act as service providers rather than distributors. As a consequence, independent service providers are now able to design their own retail products - selecting handsets, devising arrangements for retailing airtime credits, and packaging and branding the products and services. However, there remain some constraints on service providers' freedom to set retail tariffs for Pre-paid customers. This was the central concern of the consultation document. Retail pricing flexibility for service providers 1.5 The retail price of mobile services (Pre-paid or Post-paid) generally consists of two elements: (i) a "rental" charge for remaining connected to the network and capable of receiving incoming calls; and, (ii) a series of charges for making outgoing calls, which usually vary by time of day and destination. (Some tariffs do not require payment of a "rental" fee; the ability to receive in-coming calls is dependent on the purchase of outgoing call credits.) Wholesale prices generally reflect these structures. 1.6 In the case of Post-paid services, service providers have complete freedom to set their own retail prices for any "rental" element and for each call, as the amount which the customer must pay is determined by the invoice which is compiled by the service provider himself (based on itemised data received from the mobile network operator). This freedom is curtailed only to the extent that, overall, the retail tariff must generate sufficient revenue to cover wholesale costs and the service provider's operating costs. 1.7 In the case of Pre-paid services, the service provider's freedom to determine retail tariffs is more limited. Service providers buy blocks of call credit and, sometimes, wholesale "rental" time. These two elements, which can generally be bought independently of each other, are then apportioned to the service provider's customers. The service provider has freedom to determine how much, if anything, his customer must pay for "rental" and how much he must pay for each block of call credit. Thus, a service provider may choose to charge his customers more or less than a competitor for the "rental" element and/or for each block of call credit. However, the blocks of Pre-paid call credit are not call-type specific and what, in effect, the customer is buying is the right to make a series of calls to a specified total wholesale value. Credit is used up at different rates for different call types, but the relative cost of each call type is that set by the wholesale tariff structure, not by the service provider. The wholesale tariff structure is programmed into the Pre-payment management system by the network operator. 1.8 Service providers had argued that if they were able to connect their own Pre-payment management systems to the networks, or were given more flexible use of the operators' own systems, they would be able to vary the relative price level of each call type. In addition, some service providers have argued that if credits were held on their own Pre-payment management system, these could also be used to pay for other services, such as fixed network calls and e-commerce transactions.
Responses to the consultation document 2.1 Detailed comments on the consultation document were received from mobile network operators Vodafone, BTCellnet and One2One, from fixed network operators BT and Energis and from one mobile service provider, Cellcom. The Service Provider Interest Group also wrote to Oftel stating that those of its members which were mobile independent service providers concurred with the views expressed by Cellcom. Orange subsequently submitted a letter commenting on the responses which Oftel had made publicly available. All of these responses can be viewed at Oftel's offices. There was one further confidential response. 2.2 In general, the four mobile network operators and BT (then a joint owner of BTCellnet) argued that any requirement to unbundle Pre-pay functionality from the rest of the network would represent unwarranted regulatory intervention, particularly if implemented without first providing evidence of market failure and then carrying out a Cost Benefit Analysis of the proposed form of intervention. In fact, the consultative document had emphasised that Oftel did not intend to engage in ex ante intervention without first consulting consumer groups and others on the level of consumer choice in the mobile market. 2.3 Vodafone's response acknowledged that in principle, it would be possible for a service provider to take "ownership" of a Vodafone-developed PAM [Pre-payment Account Management system]. This would have the same functionality as all other physical PAMs and could be supported and upgraded as part of the Vodafone logical PAM. The company also confirmed that it had the capacity to introduce other tariff structures and credit denominations for pre-pay services (although this capacity is limited and there will be set-up costs associated with doing this). BTCellnet's response made little comment on the technical feasibility of such developments. 2.4 Energis argued that unbundling of pre-pay technology from basic conveyance would increase customer choice and value for money, particularly if the associated airtime was supplied on an unbundled and unbranded basis (an issue discussed in Oftel's review of the mobile market published in July 1999). 2.5 Cellcom highlighted what it saw as independent service providers' exclusion from the pre-pay market, arguing that independent service providers should be able to connect their own Pre-payment management systems to the networks via agreed signalling interfaces or, failing that, should enjoy flexible use of the platforms run by the network operators. Cellcom characterised this latter option as a "virtual" platform. Cellcom's response also expressed concern that wholesale prices for pre-paid services would not enable an independent service provider to compete against the operators’ in-house service providers. Vodafone too referred to the importance of price in this debate, arguing that this rather than technical unbundling was the major concern of independent service providers.
Developments since the end of the consultation period Commercial presentations 3.1 On 20 January 2000, Oftel hosted a meeting at which BTCellnet and Vodafone both presented their wholesale Pre-pay services to mobile service providers. The meeting was well attended by existing mobile service providers and others. 3.2 Vodafone outlined the wholesale service first launched in the summer of 1999, and drew attention to recent minor modifications to the service which were intended to provide further flexibility, particularly when offering customers goodwill airtime credits. 3.3 BTCellnet sketched, for the first time, new proposals which the company stated would be made available to service providers when BTCellnet had launched a new IN based Pre-pay service later in the year. This appeared to offer service providers a high degree of flexibility in specifying the criteria for crediting and debiting Pre-pay customers' accounts, and the system may approximate to the "virtual platforms" referred to in Cellcom's response to Oftel's consultative paper. BTCellnet invited service providers to make contact to discuss the development of this service. Service Provider entry into the market 3.4 So far as Oftel is aware, only one independent service provider (Advanced Communications) is offering customers its own Pre-pay mobile services over the Vodafone network, and no companies are doing so on the BTCellnet network. A number of independent service providers, including Virgin Mobile, Value Telecom (operated by Carphone Warehouse) and Advanced Communications are now offering Pre-pay services using One2One's network infrastructure, having negotiated commercial terms outside the regulatory framework.
Oftel's long term strategy 4.1 Oftel’s strategy during most of the 1990s was about promoting competition and protecting consumers, particularly where competition was not yet effective. The telecoms market is changing and there is increasing competition in many sectors of the market. The statement Oftel strategy statement: Achieving the best deal for telecoms consumers published in January 2000 set out its four new underlying objectives as follows;
4.2 These objectives are a refocusing of Oftel’s existing objectives but with the difference that they are now directed towards specific market outcomes rather than focusing on particular activities, such as promoting competition. In the case of "effective competition", the outcome sought is the benefits of effective competition (ie lower prices, higher quality, more choice of services for consumers) rather than competition for its own sake. The term ‘effective competition’ means that the competition is sustainable (ie does not depend on sector specific regulation to survive) and that consumers are able to exercise choice effectively. Where competition is increasing but not yet effective, promotion of competition is acceptable so long as competition is sustainable without regulation in the longer term and it does not create disincentives for new entrants or incumbents to invest in infrastructure or to innovate in the provision of new services. Regulation to promote competition or to protect consumers should become progressively lighter as the market gets near to effective competition, any regulatory action being focussed on where it is needed and proportionate to the circumstances. Competition in the mobile market 4.3 Oftel's review of the mobile market, published in July 1999 , found that although the mobile market (Post-paid as well as Pre-paid) was not yet not fully competitive, competition was continuing to develop. The review considered that continuation of the obligation, imposed on BTCellnet and Vodafone, to supply wholesale airtime to service providers raised fundamental questions about the nature of competition in the mobile market and whether a regulatory obligation to supply was necessary. The same issues arise in the narrower context of wholesale Pre-paid services. It might be argued that, as competition in the mobile market is strengthening, Oftel should remove regulatory controls now and allow all of the mobile network operators to judge for themselves whether, and on what terms, to supply mobile services or access facilities to service providers. However, shortage of spectrum imposes a barrier to entry into mobile network provision. This factor, combined with market developments which indicate increasing reliance on access to mobile networks by operators and service providers wishing to provide innovative services, suggests that Oftel should exercise caution before withdrawing regulatory controls. Oftel’s strategy, at present, is to continue to regulate where there is not effective competition but with an increasingly light touch as the market becomes competitive.
Oftel's conclusions A separation between pre-pay functionality and the rest of the mobile networks 5.1 Under this arrangement, each service provider, whether independent or owned by the operator, would connect its own Pre-payment management system to the networks using common interfaces and on the same terms. In theory, this might translate into increased innovation and, consequently, increased efficiency and choice offered to customers. The separation of network and Pre-payment functionality might, however, be costly to achieve and/or inefficient to operate. It is also possible that having implemented an engineering separation, the scale of innovation or market entry shown by independent service providers fails to meet expectations. 5.2 None of the responses to the consultation document provided any quantified information about the likely cost of implementing a separation. Responses from BTCellnet, Vodafone and One2One, including information provided by BTCellnet and Vodafone at subsequent meetings with technical staff, emphasised that, although, conceptually, the "databases" can be considered as self contained systems, in practice functionality is dispersed across the networks. Connection of the disparate parts of this functionality is reliant, in part, on C7 signalling which generates extra complexity when considering interfacing with resellers, in order that network integrity is not compromised. The provision of replacement stand alone technology would require significant reconfiguration of the systems which currently support Pre-paid services. 5.3 Neither did the responses identify any significant benefits which would accrue to customers from a complete separation of Pre-paid functionality from the rest of the network, which would not accrue to customers if, with less disruption, the operators continued to operate integrated Prepayment management systems while also providing alternative mechanisms which enabled independent service providers to connect their own databases to the networks or to enjoy more flexible use of databases owned and run by the network operators. A separation of Pre-payment functionality from the rest of the network might enable independent service providers to exert competitive pressure on a greater total cost base and, in theory, this could lead to some efficiency gains. Also, an obligation to replace an integrated system with a stand alone system might provide independent service providers with a "level playing field", and so might encourage market entry. It is difficult, however, to claim with any reasonable certainty that this would guarantee significant market entry where, to date, market entry has been minimal (see paragraph 3.4 above). Furthermore, responses to the consultation document did not indicate that an increase in the number of service providers offering Pre-paid services would, alone, guarantee an increase in the quality, choice or value for money enjoyed by customers. 5.4 To ensure consistency with its long term strategy, Oftel would be unlikely to intervene, ex ante, to require separation in the absence of reasonable evidence that the benefits of doing so would outweigh the costs. As the preceding paragraph explained, the responses to the consultation document did not provide evidence that a complete separation would deliver significant additional benefits which would not be delivered by the other options discussed. It also seems clear that to implement a separation would incur substantial costs to the operators. On this basis, we conclude that any benefits to be derived would be exceeded by the costs. Therefore, Oftel does not intend, at this stage, to consult more widely with consumer groups and others with a view to requiring BTCellnet and Vodafone to separate pre-payment functionality from the rest of the network. Connection of independent pre-pay systems to the mobile networks 5.5 Oftel recognises that some service providers may wish to connect their own stand-alone pre-pay systems to the mobile networks, in competition with the existing integrated systems. This approach may be particularly attractive where, for example, it allows the service provider to exploit economies of scale or offer customers a pre-payment facility which may be used to pay for services other than mobile telephony. This might translate into increased innovation by some independent service providers, while allowing others, and the operators’ own service provision interests, to make use of any efficiencies inherent in the existing integrated approach. However, given the inconclusive nature of the responses made to the consultation document, Oftel does not believe that a case has been made for ex ante intervention requiring BTCellnet and Vodafone to design and offer a standard connection service in advance of specific requests being made by individual service providers. 5.6 Service providers which wish to connect their own Pre-payment management systems to a mobile network should specify to the mobile network operator the precise nature of the access required. Oftel believes this negotiated approach, driven by market demand, is more likely to deliver quality, choice and value for money to customers than the alternative, regulator driven, approach of requiring the operators to design a connection service to meet a perceived regulatory obligation. 5.7 Where negotiation fails to secure the access required from mobile operators with Significant Market Power, independent service providers may wish to consider whether the specific requirement can be pursued through the special network access provisions of the Interconnection Directive. Oftel has determined that BTCellnet and Vodafone have Significant Market Power under the Interconnection Directive, and conditions 45 and 48 of their operating licences, therefore, oblige those operators to meet reasonable requests for special network access. 5.8 Oftel’s consultation document "Open access to communications networks: Ensuring competition in the provision of services", published in May 2000, describes the economic tests which Oftel proposes to apply when deciding whether an operator of a communications network should be required, for reasons of competition, to supply access to its network to other companies. Oftel's Guidelines on Special Network Access, published in July 2000 summarise, more specifically, the procedures for seeking special network access and the criteria which Oftel believes should be used to judge whether a request for special network access is reasonable. As with the assessment of complaints about undue discrimination, the reasonableness of a request for special access will depend, in part, on whether there are other technically and commercially viable alternatives. More flexible use of pre-pay functionality integrated with the networks 5.9 Formal responses to the consultation document provided little specific information about the commercial merits or technical feasibility of allowing service providers more flexible use of or access to pre-pay functionality operated by BTCellnet and Vodafone as an integral part of their networks. However, subsequent discussion with the network operators, in public forum and privately with Oftel, has indicated that the operators could offer more flexible use of their own systems, though costs were not quantified. BTCellnet indicated at a public forum hosted by Oftel in January 2000 that its new IN based Pre-payment systems would enable independent service providers to set their own retail tariffs. 5.10 Oftel hopes that agreements of this kind, and agreements to connect stand-alone pre-payment systems, may be negotiated through normal commercial channels, without the need for either party to rely on the regulatory framework. There are signs that the increasing level of competition in the mobile market is starting to create an environment where such negotiation is becoming, by necessity, more common. However, operators with Market Influence, BTCellnet and Vodafone, are still prohibited from showing undue preference or exercising undue discrimination. Oftel expects these companies to negotiate in good faith with independent service providers which make reasonable and specific requests for more flexible use of the pre-payment systems which have been integrated with their networks. Regulatory guidance 5.11 The consultation document set out Oftel’s view on how the regulatory rules operate in this area. The following paragraphs set out in more detail Oftel’s view on the obligations currently imposed on BTCellnet and Vodafone to entertain reasonable requests from independent service providers. Evidence of preferential treatment of service providers within the operators' groups 5.12 As is the case with wholesale Post-paid services, the wholesale tariffs for bundled Pre-pay technology and airtime closely reflect the retail tariffs of service providers within the network operators’ groups. Indeed "wholesale" prices are often expressed in terms of retail tariffs minus a specified wholesale discount. It has been argued that the retail tariffing plans of service providers within the operators' groups heavily influence the nature of the wholesale packages. It would, perhaps, be surprising if this was not the case and Oftel has no plans to require the creation of "Chinese walls", regulating commercial contact between the wholesale and service provision divisions of mobile operators with Market Influence, such as are required of the dominant fixed network operator BT. Nevertheless, Oftel recognises the advantage which this may give to service providers within an operators' group. 5.13 The advantage is potentially more significant with Pre-paid services than with Post-paid. This is because reliance on the operators' Pre-payment management systems means that all service providers must adopt a retail tariff structure in which the relative level of prices for each call type matches that of the wholesale product (which is programmed into the Pre-payment management system). Independent service providers’ ability to offer customers innovative new Pre-paid tariffs, which may more closely meet their needs, may therefore be constrained. With post paid services the service provider has complete freedom to charge his customers any price he wishes for any component of the service. Refusal to offer more flexible use of existing Pre-payment management systems 5.14 Failure to programme Pre-payment management systems to support new retail products which independent service providers wish to offer might therefore have an adverse effect on competition. If independent service providers wish to offer retail tariff structures which are not supported by the operators' Pre-payment management systems they should discuss their specific needs with the mobile network operators. If mobile operators with Market Influence refuse to discuss these requirements, or they offer terms which service providers believe are unduly discriminatory, a complaint may be made to Oftel. Oftel will then consider whether the operator's unwillingness to take into account the retail plans of the service provider amounts to undue discrimination when compared with evidence of responsiveness towards the retail plans of service providers within the operator's group. Where Oftel finds evidence of undue discrimination it may take enforcement action against the operator concerned. Price discrimination at the wholesale level between pre and post paid airtime 5.15. Respondents to the consultation document were invited to comment on whether any proposals for airtime to be offered to service providers in unstructured form should include airtime for pre-paid services (an issue discussed in Oftel's review of the mobile market published in July 1999). The ability to purchase wholesale airtime without committing to supply this to end users on any particular basis, pre or post paid, would have most practical value where the service provider is able to use his own pre-payment (or post-payment) systems to manage the supply of that airtime to end users. In these circumstances, as Cellcom and Energis argued, any restriction on whether wholesale airtime may be supplied to end users on a pre or post-paid basis is unlikely to be justified. It should be acknowledged, however, that there is currently no evidence that BTCellnet or Vodafone would seek to impose such restrictions in these circumstances. Conversely, as Vodafone argued, there appears to be little merit in simply creating arbitrage opportunities by unbundling the present bundled price for wholesale pre-pay services, offering one price for the airtime and another for the pre-payment functionality, when, currently, independent service providers have no option but to buy both components from the mobile network operator. In the circumstances, it appears that there is no need for any immediate regulatory intervention.
Future review of developments 6.1 The commercial reality that only one independent service provider has chosen to enter the Pre-pay market using the wholesale services of Vodafone may indicate that the wholesale services introduced in the summer of 1999 are not commercially viable, except in very specific circumstances. The low level of activity by independent service providers contrasts starkly with the commercial success of the operator’s own retail Pre-pay services. However, the absence of market entry by independent service providers cannot be read as prima facie evidence of anti competitive behaviour by the network operators. 6.2 Furthermore, no independent service provider has been able to enter the market using the wholesale Pre-pay service offered by BTCellnet. Given the reliance, until recently, of BTCellnet’s Pre-pay systems on specially modified phones, this is perhaps not surprising. Oftel will watch with close interest the launch of BTCellnet’s new IN based Pre-pay systems and associated wholesale products. 6.3 Conversely, the wholesale arrangements negotiated outside the regulatory framework by One2One may indicate that the increasing level of competition in the mobile market is starting to create an environment where such negotiation is becoming, by necessity, more common. These arrangements appear to have increased, to a significant extent, the choices open to customers seeking pre-paid mobile services. 6.4 Competition in the provision of mobile services (Pre-paid and Post-paid) will be reviewed during Oftel's 2000 Review of mobile markets. By this time, BTCellnet's new wholesale Pre-pay service may have been assessed by the market and Vodafone’s stated willingness to support the retail tariffing plans of independent service providers put to the test. In the event of continuing concern about the strength of competition in the retail Pre-pay market, Oftel may, after consulting customers, consider other structural options for improving the quality, choice and value for money available to customers. Oftel has no plans, however, to make changes to the regulatory framework at this stage.
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