Letter to OTA2 from David Clarkson, Ofcom.

To OTA2

I am writing to you to request that OTA2 establishes an industry group to coordinate the development of products and processes to support sub-loop unbundling.

In the UK BT is required to provide sub-loop unbundling and this requirement stems from the Wholesale Local Access (WLA) market review, published 16 December 2004(-1-). In addition, in the Undertakings BT has committed itself to offering sub-loop unbundling within a reasonable time of a request being made. Further, if Openreach were to supply any part of BT with sub-loops then BT (through Openreach) is committed to making the products and processes available on an EoI basis.

Whilst sub-loop unbundling has been available for several years, to date there has been little interest in it and this has resulted in limited product and process development. However, there are signs that interest in sub-loop unbundling is increasing.

There is however a risk that the lack of proven sub-loop unbundling products and processes may deter interest, which in turn would hold back development of the products and processes.

To break this circularity Ofcom believes that industry should be given the opportunity to experiment with different sub-loop arrangements. However, to ensure that the wider industry is able to benefit from these trials, details about the arrangements being adopted and the terms and conditions offered need to be available for assessment.

To this end Ofcom would like OTA2 to initiate an industry sub-loop unbundling coordination group. The purpose of this group would be to establish what the collective industry demand for sub-loops is likely to be and to develop suitable products and processes to support this demand by comparing and contrasting the effectiveness of different arrangements and terms and conditions.

David Clarkson

Ofcom

Footnotes:

1.- See www.ofcom.org.uk/consult/condocs/rwlam/statement