Direction to resolve a dispute between Telewest and BT over interconnect charges for origination of calls to freephone numbers - 14 August 2002

Contents

Direction

Explanatory Memorandum

Chapter 1 Summary

Chapter 2 Background

Chapter 3 History of the dispute

Chapter 4 Responses to the draft direction

Chapter 5 The Director’s decision and reasons

Annex A Schedule of operators in the Telewest Group of companies

Direction under the provisions of regulation 6(6) of the Telecommunications (Interconnection) Regulations 1997 of a dispute between Telewest Communications PLC and other operators in the Telewest group of companies as set out in annex A to this Direction ("Telewest" and British Telecommunications PLC ("BT") over interconnect charges for origination of calls to freephone numbers

WHEREAS:

A. The Secretary of State granted to British Telecommunications on 22 June 1984 a licence (the "BT licence") under section 7 of the Telecommunications Act 1984 ("the Act") for the running of telecommunications systems specified in that Licence;

B. By virtue of section 109 of paragraph 20 of Schedule 5 of the Act the BT licence has effect as if granted to British Telecommunications plc ("BT");

C. The Secretary of State has granted to Telewest Communications plc and the other operators in the Telewest group of companies as set out in Annex A to the direction on 14 January 1997 licences under Section 7 of the Act for the running of a telecommunications system as specified in the licence;

D. On 1 January 1998 the Interconnection Directive came into force and was implemented in the UK through the Telecommunications (Interconnection) Regulations 1997 (the "Regulations") and conditions in the licences of operators;

E. Regulation 6(6) of the Regulations provides that where there is a dispute concerning interconnection between organisations, the Director General of Telecommunications ("the Director") shall, at the request of either party, take steps to resolve the dispute within six months of the date of the request. The Determination which the Director makes to resolve the dispute must represent a fair balance between the legitimate interests of the parties, and must be notified to the parties in accordance with Regulation 8(3). The parties are entitled to a full statement of the reasons on which the Determination is based;

F. Telewest entered into an Interconnect Agreement with BT on 20 October 1997;

G. On 23 November 2001, Telewest issued an Operator Charge Change Notice ("OCCN") to BT. The OCCN sought an increase in the call origination charges payable to Telewest by BT for freephone traffic terminating on the BT network;

H. On 3 December 2001, BT rejected Telewest’s OCCN on the basis that it did not conform to the current NTS formula as determined by Oftel. Telewest and BT are unable to agree on this matter and are therefore in dispute;

I. On 14 February 2002, in accordance with the provisions of Regulation 6(6) of the Regulations, Telewest referred this dispute to the Director for determination;

J. The Director has a duty to encourage and secure adequate interconnection in the interests of all users in a way which provides maximum economic efficiency and gives maximum benefit to end-users;

K. The Director has considered, inter alia, the information provided by the parties and the matters set out in Regulation 6(8) of the Regulations. The principal points are summarised in the Explanatory Memorandum which accompanies, and is published with, this direction;

L. A draft of this direction and the Explanatory Memorandum was issued to interested parties on 26 June 2002. Comments were invited by 24 July 2002;

NOW, THEREFORE:

PURSUANT TO REGULATION 6(6) OF THE INTERCONNECTION REGULATIONS, AND HAVING CONSIDERED THE VIEWS OF THE PARTIES AND THOSE MATTERS SET OUT IN REGULATION 6(8) OF THOSE REGULATIONS, THE DIRECTOR MAKES THE FOLLOWING DIRECTION TO RESOLVE THE DISPUTE BETWEEN TELEWEST AND BT:

1. Telewest may propose its own price for the charge of originating a freephone call that originates on Telewest’s network and terminates on BT’s network.

2. The terms defined in this direction shall have the meaning so defined or described. All other words or expressions used in this direction shall have the same meaning as in the Directive, the Regulations, the Act or the Licence as appropriate.

3. This direction shall take effect on the date it is published.

Chris Kenny

Director of Compliance

A person authorised under paragraph 8 of Schedule 1 of the Telecommunications Act 1984

13 August 2002

Explanatory memorandum

Chapter 1

Summary

1.1 The Director General of Telecommunications (the ‘Director’) has issued a direction in accordance with the provisions of Regulation 6(6) of the Telecommunications (Interconnection) Regulations 1997 (the ‘Regulations’) for the resolution of a dispute between Telewest plc and the other operators in the Telewest group of companies as set out in Annex A to this direction (‘Telewest’) and British Telecommunications PLC (‘BT’).

1.2 Telewest referred this dispute to the Director on 14 February 2002. Telewest requested a determination from the Director that:

• Telewest should be able to set its own price for the charge of a freephone call which originates on Telewest’s network and terminates on BT’s network; and
  
• any such charge should be derived from a reasonable Telewest specific-cost estimate.

1.3 Therefore Telewest requested a determination by the Director on an issue of principle. The principle in question is whether Telewest should, in the context of the current NTS regime and the Standard Interconnect Agreement (‘SIA’), be allowed to issue an OCCN on BT which proposes Telewest’s own call origination charges.

1.4 Following this referral, the Director sought the views of the parties to the dispute and considered the submissions made by Telewest and BT. The Director issued a draft direction in respect of this dispute on 26 June 2002 to the industry as a whole for consultation. This draft direction stated that Telewest may propose its own price for the charge of originating a freephone call that originates on Telewest’s network and terminates on BT’s network. Comments were requested and have been taken into account in making a final direction.

1.5 The details of the submissions made in response to the draft direction, together with the Director’s reasons for making his decision, are set out in Chapters 4
and 5.

1.6 In summary, the Director concludes that Telewest should be able to propose its own price, via an OCCN, for the charge of a freephone call which originates on its network and terminates on BT’s network. The OCCN process is set out in paragraph 2.13. The Director does not consider that Telewest is in a position to enforce an unreasonable charge. As neither party to the dispute holds a position of market power in the relevant market, a reasonable charge will be achieved via negotiations between the parties. Therefore the Director is resolving this dispute by allowing Telewest to propose its own charge, as any charge consequently negotiated will be reasonable.

1.7 Furthermore, the Director considers that Telewest, and originating operators other than BT, should be able to set in place their own arrangements for originating freephone calls that terminate on all other networks, not just BT’s. Without fettering the Director’s discretion to take a different view in the light of circumstances, if a similar dispute were referred to Oftel in the future, the Director’s current view is that the outcome would be similar to the one that has been reached in the present dispute.

1.8 Having considered the facts specific to this dispute and the matters set out in Regulation 6(8) of the Telecommunications (Interconnection) Regulations 1997, this direction, in the opinion of the Director, represents a fair balance between the interests of the parties in each case, having regard to the Director’s wider duties to the development of the telecommunications industry in the UK and the encouragement of adequate interconnection in a way that provides maximum economic efficiency and gives the maximum benefit to end users.

Chapter 2

Background Call origination

2.1 The originating network is the network with access to the customer who makes a call.

Call termination

2.2 The terminating network is the network to which a customer who receives a call is directly connected.

2.3 Call termination of a geographic call has particular characteristics that arise from the call termination externality. An externality may be said to exist where the actions of an individual or organisation cause costs to be incurred by others (or benefits to be gained by others), but that the individual or organisation has no incentive to take such effects into account.

2.4 The externality in the termination of geographic calls arises because the retail price of a call is paid by the caller, not the call recipient. This is known as the ‘calling party pays’ principle. The price of call termination depends on the network that the receiving party resides on and the caller has no control over this. Consequently there is likely to be market power in call termination of a geographic call.

Description of number translation services

2.5 The term number translation services (‘NTS’) describes a range of specially non-geographic tariffed services, primarily used for telemarketing, which include freephone calls, 0845 Access (LCFA) and 0870 (NCFA). NTS calls are different from geographic calls, because the caller is generally accessing a service at the other end of the call.

New NTS

2.6 In December 1999, Oftel published its Statement on the Relationship between Interconnection Charges and Retail Prices for Number Translation Services (the ‘NTS Statement’). The NTS Statement followed a lengthy discussion and consultation exercise in response to a general industry view that the then existing NTS formula constrained the ability of terminating operators to exercise sufficient control over their NTS revenues.

2.7 The new regime was intended to give terminating operators sufficient flexibility in order that they could establish the price at which they would be remunerated for NTS calls. This price would then be added to BT's regulated call origination charge plus any transit charges to establish the retail price for their service.

2.8 The NTS statement confirmed that that these arrangements do not apply to originating operators other than BT. Paragraph S.4 of the NTS Statement stated the following:

"These arrangements do not apply to originating operators other than BT. These operators are free to set their own originating charges and it is up to them to negotiate with terminating operators the payments required for access to their services".

Freephone calls

2.9 As indicated in paragraph 2.5, a freephone call is an NTS service. For freephone calls, the called party pays the charge, including the charge for the call origination service that is provided by the originating operator. For other NTS calls, the calling party pays the charge for originating the call.

2.10 In light of the fact that the called party pays the charge for originating a freephone call, it has to be considered whether the externality that exists in the termination of a geographic call is present in the case of freephone call origination. If the competitive conditions in freephone call origination are sufficiently similar to those in call termination for a geographic call, then the externality may also be present in freephone call origination, and the operator originating freephone calls might possess market power. However, if call origination for freephone calls has the same characteristics as call origination generally, operators originating freephone calls (apart from BT) would not possess market power.

Reciprocity

2.11 The reciprocity principle states that for services that are provided reciprocally, charges should also be reciprocal. The Director supports the principle of reciprocity for the termination of geographic calls, as it is the calling party and not the called party that pays for call termination, thus creating diminishing incentives for terminating operators to reduce the cost of terminating a call on their network. Higher costs are likely to be passed on to retail customers. Therefore reciprocity minimises the distorting effects of this externality.

2.12 As set out in paragraph 2.10, if the origination of a freephone call is sufficiently similar to the termination of a geographic call, this might place the operator originating the freephone call in a position of market power. If this was the case, the arguments for reciprocity that are relevant in the context of geographic call termination might also apply to the origination of freephone calls by originating operators other than BT.

The OCCN process

2.13 Clause 13 of BT’s SIA describes the process used by Operators, including BT, for offering and amending charges in payment for access to another Operator’s services. For example, where an originating operator proposes to change the price paid to the terminating operator for terminating calls, it issues an Operator Charge Change Notice ("OCCN") to the terminating operator. The operator receiving the OCCN has 14 days to decide whether to accept or reject the new charge and to notify the originator of the OCCN. Failure to notify within 14 days signals a rejection of the proposal. Where the proposal is rejected, both operators have a further 14 days to settle the resultant dispute. If after this second period the dispute remains unsettled, either operator may refer the dispute to the Director.

Chapter 3

History of the dispute

3.1 On 23 November 2001 Telewest issued an OCCN to BT. The OCCN sought an increase in the call origination charges payable to Telewest by BT for freephone traffic terminating on the BT network.

3.2 For the purposes of the OCCN, Telewest calculated that 18 per cent of Telewest originated freephone calls involve a Tandem leg before delivery to BT. Thus a factor of 18 per cent of Double Tandem Short was added to the existing BT Single Tandem rate to produce a Telewest specific figure.

3.3 On 3 December 2001, BT rejected Telewest’s OCCN. The explanation given by BT for rejection of this OCCN was that:

"BT rejects this proposed charge change, which applies to a BT charge, because it does not conform to the current NTS formula as determined by Oftel".

3.4 Telewest referred this dispute to the Director in a letter of 14 February 2002. In this letter, Telewest stated that the dispute with BT concerned Telewest’s ability to set its own call origination charge under the SIA with BT, with the aim of recovering its justifiable and reasonable costs in originating freephone calls to BT.

3.5 Telewest further stated that it should be able to set its own price for the charge of originating a call on Telewest’s network, and that any such charge should be derived from a reasonable Telewest specific-cost estimate.

3.6 Telewest sought a determination from the Director on whether Telewest should, in the context of the current NTS regime and the SIA, be allowed to issue an OCCN on BT which sets Telewest’s own call origination charges.

Chapter 4

Responses to the draft direction

BT

4.1 BT stated that it has always maintained that an originating operator should be able to recover its reasonable costs for call origination. BT stated that any negotiations undertaken by the parties in this regard must be on the basis of reaching an agreement on a charge which is premised on a reasonable Telewest-specific cost estimate. However, BT did raise certain issues which it argued the Director would need to consider further. These issues will now be set out.

Service status

4.2 In response to the draft direction, BT elaborated on its argument that a call to a freephone number terminating on BT’s network is a Standard Service, and as such should be set by BT. BT stated that calls from operators to the BT 0800 service have been treated as Standard Services in interconnect terms since 1997. BT argued that charges for Standard Services have to be changed under Licence via BT issuing a Network Charge Change Notice (‘NCCN’).

4.3 As the draft direction stated that Telewest could issue an OCCN and propose a different charge, BT argued that the Director must consider that a call to BT’s 0800 service is therefore not a Standard Service. BT further argued that the Director should remove such a call from the list of Standard Services, or else BT could potentially find itself in breach of the obligation under Condition 69.1 of its licence which states that "charges offered, payable or proposed to be offered or payable by an Operator to the Licensee for each Standard Service are reasonably derived from the costs of providing the Service based on a forward looking incremental cost approach…".

Technical issues and reciprocity

4.4 BT stated that it would not expect a single tandem call to be equivalent to a BT double tandem call of any description. Furthermore, BT argued that any principle of "equal efficiency" has never been established or accepted. As a result, BT argues that it would expect that any potential inefficiency in Telewest’s network would need to be accounted for.

4.5 BT requested that it must be allowed the ability to ensure as far as possible that any calls are delivered to BT at the switch where the call originates on the Telewest network. BT also stated that it is currently configuring its interconnect arrangements so that BT interconnects at the Telewest DLE, and that as a result would expect that in the vast majority of cases calls would be charged by Telewest at its to be agreed equivalent of a DLE call origination rate. BT concluded that it would not expect to pay anything greater that a single tandem origination charge when measured on a per call basis.

4.6 Finally, BT argued that in light of these technical issues the Director should direct that any new charge could not be implemented until either the aforementioned work had been completed or following a six-month window, whichever is earlier.

Implementation

4.7 BT considered that there are issues surrounding the complexity of implementing the proposals outlined in the draft direction. BT stated that although the proposals apply only to Telewest sending a freephone call for BT to terminate, the argument could be extended to other NTS calls and also transit scenarios for all originating and terminating operators.

4.8 BT argued that the consequent growth in the administrative burden for BT and the potential growth in the volume of Carrier Price List entries would significantly increase BT’s costs. BT further argued that for transited calls the terminating operator would be unaware of the originator and so would be unable to verify any settlements for transit traffic. BT also stated that non-trivial changes to billing systems would also be required.

Telewest

4.9 Telewest welcomed the Director’s draft direction that it should be able to set its own price for a freephone call which originates on the Telewest network and terminates on BT’s network. Telewest considered that the principle that non-dominant operators should be able to set their own charges has been previously set out in the Director’s 1999 Statement on The Relationship between Interconnect Charges and Retail Prices for Number Translation Services.

4.10 Telewest also agreed that the Director need not mandate a particular approach to the setting of actual origination charges, as Telewest intends to negotiate appropriate charges with BT by issuing an OCCN on BT.

4.11 Telewest stated that it may in the future consider the extent to which the general principles outlined in the draft direction should be extended to the origination of other types of NTS calls.

4.12 Telewest concluded by stating that it strongly disagrees with the principal arguments made by BT against Telewest’s views on this issue.

Cable & Wireless

4.13 Cable & Wireless supported the Director’s draft direction, and stated that it brought clarity to NTS issues involving non-dominant players and should result in more successful commercial negotiations.

4.14 Cable & Wireless stated that the underlying principles behind the draft direction should apply to freephone traffic originating on any originator and terminating on any terminator and any NTS traffic originating on any originator and terminating on any terminator.

4.15 Cable & Wireless stated that the draft direction is consistent with the Director’s ‘new’ NTS regime. Cable & Wireless argued that BT’s continued setting of NTS termination rates for access to its NTS services, including freephone, on the basis of BT’s own regulated origination charges is not acceptable. Cable & Wireless stated that, most fundamentally, non-BT networks are not regulated.

Chapter 5

The Director’s decision and reasons

5.1 Before responding to the points that were made in response to the draft direction, it is necessary to set out exactly what the Director was asked to determine. The matter in question is whether Telewest should be able to propose a charge to BT for originating a freephone call which originates on Telewest’s network and terminates on BT’s network. Arguments pertaining to this matter that were submitted in response to the draft direction will need to be considered for the purposes of issuing a final direction. The Director’s response to these arguments can be found in paragraphs 5.4 – 5.19.

5.2 Certain other arguments were submitted to the draft direction that concern issues on which the Director was not asked to issue a determination. References to these arguments can be found in paragraphs 5.20 – 5.25.

5.3 The draft direction set out the Director’s proposed findings in relation to Telewest’s request for a determination. The draft direction also outlined the points that the Director made in support of this proposed finding. If respondents did not submit argument in relation to a point made in the draft direction, the Director’s position on this point remains as set out in the draft direction.

Service status

5.4 BT argued that this service is a Standard Service, the charge for which should therefore be set by BT. The Director’s provisional opinion on this argument was set out in the draft direction, which stated that Telewest should be able to issue an OCCN in order to seek a change in the price that it is seeking to charge to BT for originating a freephone call. BT provided an amplified version of its argument in response to the draft direction.

5.5 The Director does not dispute that a freephone call terminating on BT’s network is a Standard Service. As such it is governed by Condition 69 of BT’s licence, which requires that charges for this service should be cost orientated on a Long Run Incremental Cost basis.

5.6 Section 13 of the SIA provides a contractual mechanism for an Operator to request from BT a variation to a charge for an Operator service or facility. This contractual mechanism is an OCCN (see paragraph 2.13).

5.7 Although, among other things, Condition 69 of BT’s licence outlines the requirement for BT to issue an NCCN, the Director does not consider that Condition 69 prevents an operator from issuing an OCCN in respect of a Standard Service.

5.8 Therefore the only remaining issue to be considered is whether, as a result of Telewest proposing its own charge, there is any reason why BT should not be in a position to comply with the requirement in Condition 69 of its licence to ensure that the amount that it pays Telewest is reasonably derived from the costs of providing this service based on a forward looking incremental cost approach. The Director’s draft direction analysed the respective market positions of the parties to this dispute, and found that neither Telewest nor BT held a position of market power. In light of this finding, the Director considers that this decision does not prevent BT from complying with Condition 69 of its licence, as the parties should be able to agree a reasonable charge. The Director’s market analysis will now be set out.

Market analysis

5.9 Telewest is originating freephone calls, and if the origination of freephone calls were analogous to call termination for a geographic call, Telewest would hold a position of market power. However, if call origination for freephone calls has the same characteristics as call origination generally, Telewest would be operating in the wider call origination market, and Telewest would not hold a position of market power. These two potential markets will now be considered further.

5.10 For freephone calls, the call recipient pays the charge, including the charge for the call origination service provided by the originating network. It could be argued that this scenario is analogous to the situation for call termination of a geographic call. In geographic call termination, the terminating operator has market power because the caller would have no choice but to pay whatever is charged by the terminating operator.

5.11 If this argument was accepted, the rationale for regulatory intervention in call termination of a geographic call might also apply to the origination of a freephone call, as an excessive charge set by originating operator (in this case Telewest) would have to be paid by the terminating operator (in this case BT).

5.12 However, the Director does not consider that call origination for a freephone call is equivalent to call termination for a geographic call. For a normal call, the caller is wishing to contact a particular person, and the caller has no choice about which network to use. The caller is obliged to use the network chosen by the call recipient, or not make the call at all. The caller would not have sufficient knowledge to identify the network that the recipient was on, and the charges for calling that network.

5.13 In the case of freephone calls, recipients are seeking to receive calls from a number of callers unknown to them. If an originating operator (which does not hold a position of market power in call origination) attempts to propose an unreasonable charge, recipients could identify the originating network that is charging excessively, and choose not to receive calls from that network. This would prevent customers on that originating network from making freephone calls, which would, in turn, induce that network to reduce the charges to the competitive level. As a result, the externality that is present in call termination is not considered to be present in the case of freephone call origination.

5.14 Therefore the Director considers that call origination for a freephone call is not sufficiently similar to call termination for a geographic call. Instead, freephone call origination has the same characteristics as call origination for a geographic call. Given that this is the case, Telewest’s market share in wholesale call origination (the relevant economic market) can be proxied by its market share by volume of calls, which gives a figure of 6.5 per cent (source: Oftel Market Information) for 2001/02 Q3. Telewest is not dominant in this market. BT has a market share of 24.8 per cent (source: Oftel Market Information) in the NTS call termination market for 2001/2 Q3, so it is unlikely to be dominant in this market. In addition, Oftel’s statement on effective competition in the NTS market confirmed that the market for retail voice NTS is effectively competitive.

5.15 Given this market analysis, the Director considers that Telewest should be able to propose its own charge for the cost of originating freephone calls, as the conditions of competition are such that neither party is in a position to enforce an unreasonable charge. Therefore appropriate charges will be achieved via commercial negotiation between originating operators (other than BT) and terminating operators.

Resolution of disputes between non-dominant operators

5.16 The analysis set out in paragraphs 5.9 – 5.15 has shown that neither party to this dispute holds a position of dominance in the relevant economic market. In this case, and as demonstrated above, the parties have a commercial incentive to reach agreement on the matter in dispute. BT has, however, rejected Telewest’s proposed charge on the basis that the proposal does not accord with the NTS regime. As a result, the parties are in dispute, and Telewest has referred the matter to the Director for resolution. The Director is therefore required to issue a direction as to whether Telewest can propose its own charge under the NTS regime.

5.17 On 24 April 2002 a number of new EC Directives came into force, and these must be implemented into UK law by 25 July 2003. The way the Director resolves disputes between operators will be amended, in line with the provisions of Article 20 of Directive 2000/21/EC on a common regulatory framework for electronic communications networks and services ("Framework Directive"). Article 20 of the Framework Directive sets out the obligations of Member States in relation to dispute resolution between undertakings. The Director is currently considering how disputes and casework will be handled following the implementation of the new EC Directives.

5.18 It is the Director’s intention to ensure that disputes between non-dominant operators can be resolved as efficiently as possible. He does not believe that the resolution of such disputes should be a priority in terms of resource allocation within Oftel and considers that non-statutory dispute resolution is likely to be a more appropriate means of resolving the issue. The Director is seeking to ensure that if there is a commercial incentive for operators to reach agreement on a particular issue, the dispute resolution procedure that is adopted should reflect this. The Director will be consulting on dispute resolution in the context of the new EU framework, including the use of mediation and other forms of alternative dispute resolution in relation to cases involving non-dominant operators.

Technical issues and reciprocity

5.19 The Director set out certain technical differences between Telewest’s network and BT’s network in the draft direction on this issue. The Director undertook this analysis in order to ensure that due regard had been given to the legitimate interests of both parties when considering the matter before him. The Director’s positions on these factors remain the same.

5.20 In its response to the draft direction, BT reconciled its arguments regarding the configuration of Telewest’s network with what it considered might be a reasonable Telewest charge. The Director does not propose to comment on these arguments, as Telewest did not ask for a determination as to what constitutes a reasonable charge.

Implementation

5.21 In response to the draft direction, BT stated that the principles espoused in the draft direction raise concerns for BT regarding the implications that this would have for firstly, other originating operators and secondly, other types of NTS traffic. Telewest and Cable & Wireless also commented on these issues in their responses to the draft direction.

5.22 As with BT’s comments regarding what might constitute a reasonable Telewest charge, the Director will not formally direct on these issues for the purposes of the current determination request. However, the Director’s position on these issues, as set out in the explanatory document to the draft direction, remain the same.

5.23 The Director considers that Telewest, and originating operators other than BT, should be able to set in place their own arrangements for originating freephone calls that terminate on all other networks, not just BT’s. Without fettering the discretion of the Director to take a different view in the light of circumstances, if a similar dispute was referred to the Director in the future, the Director’s current view is that the outcome would be similar to the one that has been reached in the current dispute.

5.24 In the absence of direct interconnection between originating operators and terminating operators, freephone traffic will need to be transited between each operator’s network. The Director is aware of technical issues associated with billing for transit calls, but believes that the appropriate mechanisms are being discussed that will enable the costs of originating freephone calls to be recovered.

5.25 If in the future a dispute were referred to the Director regarding the ability of an originating operator (other than BT) to propose its own charge for the origination of non-freephone NTS traffic, the Director’s discretion to take a different view in light of circumstances could not be fettered. In resolving an interconnection dispute the Director must take into account the criteria set out in Regulation 6(8) of the Regulations, inter alia, the interests of users, and the desirability of stimulating innovative market offerings and of providing users with a wide range of telecommunications services.

The Director’s decision

5.26 Having considered the arguments for and against Telewest’s request, the Director directs that Telewest may propose its own price for the charge of originating a freephone call that originates on Telewest’s network and terminates on BT’s network.

Annex A to the direction

Schedule of Operators in the Telewest Group of companies