John Russell
Compliance Directorate
Oftel
50 Ludgate Hill
London EC4M 7JJ

17 July 2000

Public consultation on quality of service standards for BT's Calls and Access product

The Service Provider Interest Group, SPIG, represents the interests of communications services providers and seeks a fair competitive environment for communications service provision. SPIG's membership and views can be seen on the SPIG website, www.spig.org.uk.

SPIG would like to endorse the response to Oftel's consultation made by the Calls and Access Interest Group, CAIG, which is attached.

CAIG has worked in a robust and effective way to draw together the views and issues of Calls and Access Service Provider businesses (both active and prospect businesses) and has faced considerable problems from the outset with the Calls and Access product. In our view, this has clearly demonstrated that the product was not ready for sale to SPs. CAIG has also remonstrated with both BT and Oftel on a number of key concerns including pricing and processing problems and continues to face with an aggressive and inappropriate winback policy by BT to its own retail business. This has hampered Service Providers in their aim to provide good quality of service to their customers.

We believe the lack of progress suggests that, fundamentally, BT does not appear to have a vision for working in partnership with SP businesses, where this is required, and is using its market dominance to favour its own retail business thus directly affecting competition in the Calls and Access market.

SPIG believes that Oftel has a continuing role to oversee and act to ensure fair competition in this market. In particular we recommend that:

• Oftel gains agreement from BT not to undertake any "Save" activity during the customer transfer process;
• Oftel supports SPs in seeking to remove clauses in the BT SP contract that permit BT a unilateral right to amend the contract without SP agreement;
• Oftel acts to ensure cost based prices for SPs are put in place as proposed in Oftel's Price Review, March 2000.

Yours sincerely

Phil Sayer
Chairman, SPIG