“Connected Continent” – Telecoms Single Market regulation – Access Obligations,
Single Authorisation and BEREC
Views of BT Group plc
Introduction
More effective provision of cross-border services to businesses can help significantly boost productivity,
innovation and economic growth. This means that the proposals for effective and consistent regulation of
wholesale access inputs (‘European virtual broadband access products’) form one of the most important
parts of the proposed ‘Telecoms Single Market Regulation’.
In BT’s experience in the European market place, in particular in serving pan-European clients, the greatest
obstacle in serving this client base is the highly varied application of the existing regulatory framework (as
demonstrated in the vastly different regulatory outcomes of market reviews and their enforcement) and the
consequent variation in, for example, business grade wholesale access (Ethernet) products.
Wholesale Access Products
‘Virtual’ access products can provide similar functionality to physical unbundling, are more economically
efficient and allow higher levels of consumer choice and innovation through increased retail or service-level
competition. ‘Virtual’ access services also provide the opportunity for new entrants to roll out their own
networks closer to the end corporate customers in response to real customer demands where the business
cases of ‘physical’ access services tend to necessitate an immediate mass market demand for it to be
commercially viable; in the corporate market segment such intense local demand tends not to exist, as
corporate customers’ geographical locations are widely spread. As such, ‘virtual’ access services are often
the most pro-competitive and pro-investment regulated access service for corporate customers.
The requirement to provide business-grade wholesale reference offers should substantially help to address
the current non-availability and inconsistent regulation, particularly of wholesale Ethernet access (leased
lines), which is the key access input for business service provision, and of wholesale bitstream access which
can also support business usage.
While the proposals for more harmonized regulation of wholesale access inputs are very positive, the
potential use of delegated Acts for unspecified and potentially unlimited further detail on the specification /
reference offer for “European Virtual Access Products” inevitably causes business uncertainty. It is essential
that any eventual Acts ensure due proportionality and that national regulators have sufficient flexibility to
prevent the undermining of investments made in existing virtual access products where these already forms
the basis of mass-market deployment.


We support the amendments vote in the European Parliament Plenary in relation to “wholesale highquality access products allowing the provision of business communications services” but believe these
do not go far enough.
To make the EP proposal effective, there should be a requirement (where there is SMP) to provide a
reference offer based on the elements included in the Commission’s proposed Annex 1.
The veto over SMP remedies should be clarified as relating to SMP obligations for new access products in a
‘home’ country, which would be consumed by a “European electronic communications provider” from
another country, rather than obligations on the European electronic communications provider itself.
The proposal for a wholesale “Assured Service Quality connectivity product” is not sufficiently clear. BT
supports the right to offer services with a defined service quality but the obligation to provide access to a
specific product cannot be appropriate or proportionate where the definition is open to interpretation.
Single Authorisation
The ‘Single Authorisation’ for the provision of Electronic Communications networks and services may help
reduce unnecessary operational overheads. This would bring benefits to pan-EU providers but while it is
welcome, it should be noted that the resource associated with notification and compliance is not a material
obstacle to pan-European operations and does not substitute for addressing ineffective or inconsistent
treatment of access remedies. The Commission should look at developing an on-line system where pan
European operators can log their authorisation entitlements. This would allow local NRAs to verify
entitlement as well as the Commission to monitor any undue variations of regulatory burdens that the
various local regulatory regimes may cause.

We support the amendments voted in the European Parliament Plenary in relation to “a harmonised
and simplified notification system based on a harmonised template” .
BEREC
We believe that BEREC must be required to act as an independent authority and that therefore the
Commission cannot intervene in BEREC’s organisation.
BT Group plc
04/04/2014
BT is one of the world’s leading communications services companies, serving the needs of customers in the UK and in more than 170
countries worldwide.
Wholesale Access Products – BT suggestion to strengthen EP /ITRE Compromise Amendment 7
Proposal for an amended Article 17
Wholesale high-quality access products allowing the provision of business communications services
1. Providers of electronic communications services designated in accordance with article 16 of
Directive 2002/21/EC (Framework directive) as having significant market power in a relevant
market relating to the provision of wholesale high-quality electronic communications services shall
ensure the publication of a wholesale reference offer containing at least the elements listed in
Annex 1 and taking into account the BEREC guidelines referred to in paragraph 2.
2. By X/X/2015 BEREC shall, after consulting stakeholders and in cooperation with the Commission
lay down guidelines specifying which further elements could be included in the reference offer.
BEREC shall review these guidelines regularly in light of market and technological developments.
ANNEX I
MINIMUM PARAMETERS FOR OFFERS OF EUROPEAN HIGH-QUALITY ACCESS PRODUCTS FOR
THE PROVISION OF PAN-EUROPEAN BSUINESS COMMUNICATIONS SERVICES
1. OFFER 1: Fixed network wholesale access product offered at Layer 3 of the
International Standards Organisation seven layer model for communications protocols
('Network Layer'), at the IP level bit-stream level with handover points offering a higher degree of
resource aggregation such as at national and/or regional level
1.1 Network elements and related information:
(a) the characteristics of the connection link provided at the handover points (in terms of
speed, Quality of Service, etc.);
(b) a description of the broadband network connecting the customer premise to the handover
points, in terms of backhaul and access network architectures;
(c) the location of the handover point(s); and
(d) the technical specifications for interfaces at handover points.
1.2 Network functionalities:
Ability to support different quality of service levels (e.g. QoS 1, 2 and 3) with regard to:
(i) delay;
(ii) jitter;
(iii) packet loss; and
(iv) contention ratio.
1.3 Operational and business process:
(a) eligibility requirement processes for ordering and provisioning;
(b) billing information;
(c) procedures for migration, moves and ceases; and
(d) specific time scales for repair and maintenance.
1.4 Ancillary IT Systems:
Specifications for access to and use of ancillary IT systems for operational support systems,
information systems and databases for pre-ordering, provisioning, ordering, maintenance and
repair requests and billing, including their usage restrictions and procedures to access those
services.
2. OFFER 2: Wholesale terminating segments of leased lines with enhanced interface for the exclusive
use of the access seeker providing permanent symmetric capacity without restriction as regards usage
and with service level grade agreements, by means of a point-to-point connection and with Layer 2 of
the International Standards Organisation (ISO) seven layer model for communications protocols ('Data
Link Layer') network interfaces.
2.1 Network elements and related information:
(a) a description of the network access to be provided, including technical characteristics
(which shall include information on network configuration where necessary to make effective
use of network access);
(b) the locations at which network access will be provided;
(c) the different speeds and maximum length offered;
(d) any relevant technical standards for network access (including any usage restrictions and other security
issues);
(e) details of interoperability tests;
(f) specifications of equipment allowed on the network;
(g) network-to-network (NNI) interface available;
(h) maximum frame size allowed, in bytes.
2.2 Network and product functionalities:
(a) uncontended and symmetrical dedicated access;
(b) service-agnostic connectivity, enabling control of traffic speed and symmetry;
(c) protocol transparency, flexible allocation of VLANs based on common technical
specification;
(d) Quality of Service parameters (delay, jitter, packet loss) enabling business-critical
performance.
2.3 Operational and business process:
(a) eligibility requirement processes for ordering and provisioning;
(b) procedures for migration, moves and ceases;
(c) specific time scales for repair and maintenance;
(d) changes to IT systems (to the extent that it impacts alternative operators); and
(e) relevant charges, terms of payment and billing procedures.
2.4 Service level agreements
(a) the amount of compensation payable by one party to another for failure to perform
contractual commitments, including provisioning and repair time, as well as the conditions for eligibility to
compensations;
(b) a definition and limitation of liability and indemnity;
(c) procedures in the event of alterations being proposed to- the service offerings, for
example, launch of new services, changes to existing services or change to prices;
(d) details of any relevant intellectual property rights;
(e) details of duration and renegotiation of agreements.
2.5 Ancillary IT systems:
specifications for access to and use of ancillary IT systems for operational support systems,
information systems and databases for pre-ordering, provisioning, ordering, maintenance and
repair requests and billing, including their usage restrictions and procedures to access those
services.