Delivering the Broadband Universal Service BT’s Response to Ofcom’s consultation published on 5 December 2018 13 February 2019 Comments should be addressed to: BT Group Regulatory Affairs, BT Centre, London EC1A 7AJ
[email protected] 1 Executive summary 3 2 BT Response to Ofcom’s Consultation Questions 8 3 Additional Observations on Cost Recovery 32 4 Other Issues 39 2 1 Executive summary 1.1 BT supports the objective of Ofcom and the Government to bring decent broadband connectivity to all UK citizens. We are ready to play our part in delivering this as a Universal Service Provider (‘USP’). The Universal Service Obligation (‘USO’) will address some of the most challenging areas of the UK and the scheme must be designed in a way that effectively balances the speed, quality and cost effectiveness of the service provision in these areas. 1.2 We are also committed to delivering the best possible customer experience, ensuring that we provide the right information to eligible customers, set expectations appropriately, process orders efficiently and effectively, and deliver a service that closes the gap between those who do not yet have access to decent broadband connectivity and those that do. 1.3 However, BT remains concerned with some elements of Ofcom’s proposals which we consider run contrary to the interests of consumers: Timelines. The proposed timelines for implementation, and particularly the requirement for fixed network build within 12 months, are not achievable in all cases. We need Ofcom’s proposals to be more flexible, recognising that in a minority of cases build will take longer than 12 months.