APPENDIX 64
Memorandum submitted by Energis Plc
Energis has been extremely proactive in its
campaign for business and consumers to have access to affordable
broadband. Energis instigated a complaint to Oftel to stop the
incumbent BT pricing broadband interconnection services excessively.
After eight months of deliberation the Telecommunications
Regulator has now issued a draft direction that mandates BT to
provide Asymmetric DSL and Symmetric DSL ATM interconnection—but
fails to tackle excessive pricing.
Energis welcomes the determination to mandate
BT to provide high speed internet access to operators, so that
we may offer services to business and consumers, as a step in
the right direction. However, Energis strongly believes that in
order to deliver the vision of Broadband Britain interconnection
must be offered under reasonable terms, using cost orientated
pricing as the appropriate methodology.
In the absence of cost orientated pricing and
appropriate service level agreements and service level guarantees,
competition will be stifled both in terms of alternative network
provision and content development.
I thought you may wish to receive our response
to Oftel, along with two reports that Energis has commissioned.
The first report by Dr Chris Doyle at Charles Rivers Associates,
examines the economic merits of Oftel's pricing methodology proposal.
The second is a report outlining the methodology that could be
employed to create a cost orientated model for the ATM interconnection
product portfolio by Richard Cadman at Beaufort International.
Energis hopes that you are able to support our
submissions in whatever way you are able. We would be delighted
to discuss the content of our response and explain or elaborate
on any of the points made.
25 January 2002
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