1. |
BT welcomes the direction established in the 1996 Japanese
Telecommunications Council proposal of basic rules for
interconnection.
The creation of a clear and effective framework for
inter-operator payments is of profound importance in establishing
efficiency and effective competition in the market for
telecommunications services in any country.
BT's views below are those we espouse everywhere and are submitted as a contribution to debate.
|
2. |
BT is supportive of the general approach proposed by the Council.
The current interconnect tariffs in Japan are relatively high:
reductions to these tariffs are possible.
Maintenance of the current interconnection regime and price levels for a several years would damage the industry - the development of new operators would be stifled.
Customers would not gain the benefits promised, on price, innovation and industrial competitiveness.
|
3. |
To enable development of the telecommunications industry in any
market, BT considers it appropriate that the Ministry adopt interim
measures in an attempt to foster the key principles of the intended
framework for interconnect charging.
In the immediate term, are approach is to reduce interconnect tariffs to a level more
commensurate with the expected levels of charges based on
incremental costs acting via "proxy prices".
In addition, one could act to restructure tariffs in response to the need for charges based on unbundled network elements.
|
4. |
In evaluating the level of interconnect charges, there are
two basic tools;
- International benchmarking analysis of interconnect tariffs
- Accounting cost information from the main operators, adjusted
in recognition of levels of efficiency and the implications of a
change from the existing accounting basis (historic costs) to an
incremental cost basis for interconnect charges.
|
5. |
International benchmarking analysis suggests that Japan's rates are relatively high.
This might help set interim interconnect tariffs, for the period until the new proposals are fully implemented, or as MPT Study Group work continues.
|
6. |
BT's paper is in five sections.
First, we establish a basic set of
objectives against which a proposed interconnection charging
framework can be measured.
Second, we review the economic
principles that are needed to support an efficient interconnect
charging framework.
Third, we review the level of interconnect
tariffs around the world in different regulatory regimes in order to
add context.
We then evaluate the issues of charging structure, unbundling and accounting separation.
We conclude with a review of the Telecommunications Council's rules against the objectives.
Our views naturally take much input from the UK and European Union systems.
|
9. |
Many countries have benefited from the liberalisation of, and
subsequent development of competition in, their
telecommunications industries. It is clear that customers benefit
from competition through increased choice, service innovation and
reduced prices. In support of liberalisation, the fundamental
principles around which the Telecommunications Council
formulated its rules for interconnection were:
- The improvement of benefits for users
- The promotion of fair and effective competition
|
10. |
The need for regulation of interconnect prices comes about due to
the threat of exploitation of a dominant market position.
The role of the regulator should be to ensure that the main operator does not exploit its market position to derive excess profits.
A regulator will usually do this by attempting to "mimic" competitive
forces, typically through some form of price control designed to
regulate profitability and replicate equilibrium pricing conditions
that would prevail in a competitive market.
|
11. |
This role is of huge importance in defining the framework for
interconnect charging. An access line into a customer's premises gives the main operator a monopoly on the termination of all calls made to that customer.
This type of monopoly is usually referred to as a "bottleneck" monopoly. Interconnect prices define the terms on which competitors pay for use of the "bottleneck" monopoly service.
Prices should be set in such a way that they mimic competitive forces in the provision of this "bottleneck" monopoly service.
|
12. |
Fairness of course requires that a new entrant should be granted access to customers on the same terms as the main operator.
Such an operator conveys calls to its customers by building and operating, and therefore incurring the costs of, its own switching and transmission network.
It is therefore widely accepted that
competing operators should have access to the incumbent's network
facilities on the same terms as the incumbent - they should be
required to pay the incumbent an amount based on the costs
associated with the conveyance of calls from the point of
interconnect to the customer.
|
13. |
From a perspective of economic theory it is generally recognised
that in a competitive market prices will be set at levels equal to the
efficient long run marginal costs1 of provision of service. It is
simple to illustrate that allocative efficiency is maximised when this
condition holds. For example, if prices exceed the marginal cost of
the efficient operator - as is likely to be the case for an unregulated
monopoly - then both the producer and the customer are missing out
on the economic benefit associated with the supply of an extra unit
of output. A price above marginal cost fails to maximise allocative
efficiency.
|
14. |
This basic economic analysis might lead to the conclusion that, in
establishing interconnect charges, the regulator should set rates
equal to efficient long run incremental or marginal costs. There is a
problem with this proposition however. The creation of a tariff
structure that only allows the main operator to recover its
efficient marginal costs may, and indeed would in some areas of the
telecommunications industry, lead to it making a loss.
This will be the case if the main operator experiences increasing returns to scale - i.e. if an industry gives rise to a marginal cost that remains lower than the average cost of a unit of output (at all output levels).
There are significant scale economies in the usage of some parts of a telecommunications network.
This is most significantly the case in the provision of "bottleneck monopoly" usage services such as call termination.
If prices were set at marginal costs, then even if the firm was productively efficient - producing the given output at minimum possible cost - it would operate at a loss equal to the level of fixed and common costs (which do not vary with level of output).
|
15. |
In such instances it remains widely accepted that marginal costs
need to form the basis of an efficient set of prices. However, prices
need to be set in such a way as to recover the fixed and common
costs of operating the network. It can be shown that, subject to the
constraint that the firm break even, the most efficient allocation of
resources is attained if overall prices for services are set equal to
average cost - such that the efficient firm would make a zero profit.
|
16. |
The issue of mark-ups - the amount added to LRIC to allow the
efficient firm to recover its total costs (including fixed and common
costs) - must be addressed. Mark-ups can be applied on a uniform
basis. This is often referred to as the application of equal
proportionate mark-ups. However, many alternatives exist. One
popular alternative, involving the application of higher mark-ups to
services which exhibit lower price elasticity, is known as Ramsey
pricing. Such an approach would lead to demand levels (and hence
allocative efficiency levels) which are closer to those that result
from marginal cost pricing. Under a mechanism of Ramsey pricing,
interconnect charges for call transport would probably be lower than
under a system of equal proportionate mark-ups.
|
17. |
LRIC is a forward looking cost measure. By implication economic theory rejects the use of historic accounting measures of cost as
inefficient and inconsistent with allocative efficiency.
Similarly the
efficient equilibrium prices in a competitive industry reflect current
and forecast cost behaviours.
Because of this, historic costs form an inappropriate basis for interconnect tariffs. Tariffs should be set so that current costs are recovered. To this end mark-ups must also not be based upon historic cost accounts, but on current costs.
It should be re-iterated that the incumbent should not necessarily be entitled to recover its actual costs. Only those costs that would reasonably be incurred by a productively efficient operator should be reflected in interconnect tariffs. In a competitive market only a productively efficient operator would recover its costs. The regime should ensure that this is also the case in regulated industry.
|
18. |
Any form of cross subsidy can similarly be shown to produce an economically inefficient outcome. A cross subsidy introduces further deviation of prices away from true underlying marginal costs. Interconnect charges should therefore not incorporate elements which relate to cross subsidisation of any kind.
Such measures encourage ever more distant departure from
allocative efficiency and encourage entry by competitors into
"artificially" profitable areas. These consequences work to reduce
the total benefits generated by the industry. As such, cross
subsidies (such as those which involve setting artificially low
customer access line charges) should be discouraged and should not
be allowed to affect the level of interconnect charges.
|
19. |
The conclusion of the academic analysis is, that allocative
efficiency is best effected by the adoption of interconnect tariffs
based on efficient long run incremental costs, but set at levels that
allow the overall recovery of the efficient firm's total costs. Fixed
and common costs should be recovered in such a way as to
encourage consumption behaviour to mimic, as closely as is possible, the behaviour that would result if prices were set at
marginal costs. Also, if the firm is inefficient then interconnect
prices should not include any amount relating to excessive costs
incurred by the incumbent.
|
20. |
An (efficient) LRIC basis for interconnect charging has been adopted in the UK and becomes effective in October 1997. A LRIC basis has been used for the reforms initiated by the FCC in the 1996 US Telecommunications Act and has stimulated a number of fundamental changes to the structure of interstate access charging which are currently underway. LRIC also forms a central part of the European Interconnect Directive and associated European Commission guidelines which define the framework for telecommunications liberalisation in Europe.
|
21. |
It is BT's view that regulators should set prices based on the LRIC of an efficient operator, with an appropriate markup to cover fixed and common costs. The markup should probably be lower for
interconnect conveyance services than for other parts of the network
operated by the main operator. Any charges relating to cross
subsidy within the telecommunications industry (such as an access
deficit) should not be included in interconnect transport charges.
|
22. |
The assessment of LRIC is important. Two basic methods can be
used to estimate LRIC values:
- "Bottom Up" - In which engineering estimates of the
cost of building a network to meet different levels of
demand and for different services are used to develop
views on the incremental cost behaviours
- "Top Down" - In which the incremental cost
behaviours by eliminating 'fixed and common' costs
from the total costs of the firm
Both types of model were studied in the UK, and a reconciliation of
the results undertaken. In the US it would appear that the bottom up
approach is favoured. In Europe the EC advocates use of the
bottom up model with the top down model used as a check.
|
23. |
In all countries, regardless of the model adopted, the construction
and analysis required to support estimates of LRIC is significant.
There continues to be extensive disagreement over the results
generated by LRIC analysis. This clearly gives rise to a need for
transparency. BT has advocated that the process for
development of LRIC estimates should recognises inputs from a
wide range of industry participants and interested parties.
|
24. |
An OVUM analysis of July 1997 essentially develops a
representative "average" interconnect price for a number of
operators in different countries. OVUM defines a representative
basket of interconnect traffic comprising calls of different distances,
at different times of day and on different days of the week. Based
on this basket of traffic OVUM develops estimates of the average
per minute rate paid by an interconnecting operator in each case.
The analysis takes account of failed calls, call setup charges and
minimum fees as well as the "headline" per minute rates for
interconnect charges. The results are shown below:
OVUM's analysis is revealing. At July 1997, the interconnect rates
charged in Japan were more than 140% higher than the lowest
available interconnect rates in the sample. The interconnect rates in
Japan were 75% higher than the average of the "best three" sets of
rates.
|
25. |
The rates to be implemented in the UK in October 1997 - as a consequence of the adoption of LRIC - are more than 25% lower than the rates shown in the graph. Also, the rates shown for the US are based on prices from before the implementation of the planned access restructuring. The US access restructuring will significantly reduce the per minute charges applicable to interconnect services, particularly once court action is settled.
|
26. |
BT is not fully familiar with how interconnect charges are derived
in Japan. It is, however, possible to make an estimate of the likely
effects of the adoption of the rules proposed by the
Telecommunications Council. Given the similarity of the Telecommunications Council's proposed rules to the rules that are
now applied in the UK, one would expect Japanese interconnect
rates to fall significantly, and relatively rapidly. BT believes that it is important to assess 'proxy prices' as a way to move forward until such sufficient - and published - accounting information is available from the main operator.
|
27. |
It is of critical importance that the level of interconnect charges is
correctly established. However, the structure of charges is similarly important in creating appropriate incentives for efficiency. This is
the basis of the need for unbundling. Currently, interconnect charges in Japan do not appear to recognise network elements in any detail. Technical interconnection occurs at defined points in the network. This has the effect of removing some of the incentive for the efficient establishment of infrastructure. Such incentives are maintained in the case of unbundled (element based) charges.
In a system of unbundled charging, the interconnecting operator
pays only for the network elements that it. If the operator is able to self provide some of the network elements and can do so at lower cost than the main operator then it is rational for him to do this.
|
28. |
For example, an operator may be in a situation where he
can either interconnect at the DMSU level and pay 2 Yen or
interconnect at the local exchange level and pay 1 Yen. If he can
deliver the call to the local exchange for less than 1 Yen more than
it costs him to get the same call to the DMSU then he will do this.
Overall his costs have fallen. The cost reductions will eventually
accrue to end users through reduced prices.
|
29. |
An unbundled charging system might consequently identify three
basic types of interconnection service. These charges recognise the
different levels at which an entrant might choose to hand calls to the
incumbent:
- Local Exchange
- Single Tandem
- Double (+) Tandem
An entrant will be charged the Local Exchange rate if he hands the
call over at the local exchange which serves the customer for whom
the call is destined. If he hands the call over at the tandem exchange
on which this local exchange is parented, he will pay a Single
Tandem charge. If he hands the call over anywhere else he will pay
the Double (+) Tandem rate. Thus the different charges relate to the
different levels at which operators may choose to interconnect.
|
30. |
UK interconnect charges follow such a structure. Within the
different levels there may be a further distance based "deaveraging".
Such a deaveraging exists within the Double Tandem service in the
UK. Some network configurations may lead to different element
based charging structures. For example they may require more than
two tandem switching stages under certain circumstances.
However, the critical feature of unbundled charges is that entrants
are free to choose the level at which they wish to interconnect and
are charged accordingly. They are therefore able to design their
network in such a way that they achieve the lowest cost mechanism
of getting traffic to and from their customers. Unbundled
interconnect charges are, in the UK, explicitly derived from
detailed, published accounting data which give unit costs (per
minute) for all main network elements. The unit costs for network
components reflect the usage sensitive costs of network components
only. They do not reflect any costs associated exclusively with the
retail activities of the incumbent, or any costs which are insensitive
to usage (e.g. costs of customer access lines).
|
31. |
The interconnect charges are calculated by taking the unit costs for different components and multiplying them by "usage factors". These usage factors represent the "consumption" of different physical network elements by different services. Similar calculations are performed to assess the unit costs of retail services, and these costs are "charged" to an accounting entity which reports the retail activities of the incumbent. By this mechanism non-discrimination is demonstrated. The network costs attributed to interconnect services are calculated on an identical basis to the network costs attributed to the incumbent's own retail business.
|
32. |
The relationship between the three entities established within BT's
separated accounts can be effectively summarised by the diagram
below.

- Arrows show payment flows
- Interconnect Charges and (Intra-PTT) Network Charges are caluculated using consistent element based methodology
- Network Accounts identify individual unit costs for each network element
- Services (retail and wholesale) are costed on the basis of usage of different network elements multiplied by unit cost
A copy of the BT Financial Statements for 1996/97 is available on request. Also available is a copy of the Accounting Documents which give the principles and accounting rules upon which the BT Financial Statements are based.
|
33. |
The Telecommunications Council rules recognise the need for unbundled charges. BT supports this change in any jurisdiction. The MPT will of course need to ensure that the possible efficiency gains associated with unbundling are realised. This requires that the costs of establishing physical interconnect at the various levels do not prove prohibitive and do not discourage infrastructure investment by new entrants.
|
34. |
The Telecommunications Council has proposed two sets of rules:
- Basic Rules (for Type I Carriers)
- Special Rules (for operators of essential facilities)
BT is supportive of the basic rules and does not believe that these raise any major concerns for the industry. The special rules established by the Telecommunications Council are intended to ensure that benefits to users are maximised and are not adversely affected by behaviour of operators with a dominant, or monopoly, market position. BT believes that the special rules should be used to set interconnect tariffs for all operators of bottleneck facilities - not only those with high market shares. It does not require significant market share for an operator to be in such a position. The special rules should govern the interconnect prices for any operator who is in such a position. BT sees a need to extend of the scope of some of the special rules to all operators of access lines. An alternative to this, requiring a change to the basic rules, is to set standard charges for particular services (access to bottleneck monopoly facilities) that apply throughout the industry.
|
35. |
Notwithstanding this issue, BT has reviewed the special rules and has the following points to make, in light of issues raised and views expressed in earlier sections:
- Unbundling of Tariffs
On the basis of the stated regulatory objectives BT would reinforce the Telecommunications Council assertion that there is a need to develop a system of unbundled interconnect tariffs which recognise the basic elements of the telecommunications network. Such a system is the only way in which effective cost based interconnection - and appropriate incentives for network operators - can be implemented. A system of unbundled tariffs - supported by appropriate accounting statements and offering a suitable range of interconnection services - meets the objectives of transparency, simplicity and provides a firm foundation for economic efficiency.
- Facilitating the benefits - Freedom of Entry
A critical requirement associated with the above, is that interconnecting operators are free to choose the technical point in the network at which interconnection occurs. This freedom is critical to the realisation of the benefits of unbundled tariffs and should not be hampered by high costs associated with the establishment of points of interconnection. Regulators should act to ensure that such costs are kept to a minimum and shared on a reasonable basis between industry operators.
- Disclosure of Accounting Information
BT thinks that the detail underlying the special rules on interconnect accounting should be clarified. The process for agreement of the form and content of appropriate financial statements took a significant amount of time in the UK. We support the proposals for separation of essential facilities and sales activities. However, BT would also advocate that the essential facilities are broken down into access and network facilities. The fundamental differences in the drivers behind the costs of these facilities mean that it is necessary to separate the activities entirely in order to develop transparency in the calculation of interconnect charges. Such transparency is critical in order to develop industry confidence in the resulting charges.
- Non-discrimination
The objective of non-discrimination requires that charges should be the same for all operators, published and derived from financial statements for the main operators businesses and activities. The financial statements should make the division between access, retail and network activities. Interconnect charges should be based on network costs alone. To this end, BT again supports the accounting rules proposed by the Telecommunications Council, but re-asserts the need for development of clarity on detailed aspects of how the (separated) interconnect accounting process will work. A framework based on unbundled charges - known as element based charges (EBC's) - has existed in the UK for some years. The UK interconnection regime has been effective in the stimulation of competition and is - in some quarters - regarded as one of the most effective interconnection framework in the world. BT believes that many of the characteristics featured within the UK framework for interconnect charging and financial reporting could be a useful input to the work in Japan.
- Long Run Incremental Costs
The consideration of long run incremental costs (LRIC) as a basis for interconnect charging is also welcomed. BT is firmly of the view that LRIC based charges, recognising the costs of an efficient operator should be adopted. The two most extensive interconnect regimes in the world - the UK and US - have recently signalled the adoption of LRIC as the basis for interconnect charging. Other countries, notably member states of the European Union, have followed. Economic analysis shows that LRIC provides the most effective basis for the encouragement of truly efficient economic behaviour and resource allocation within the telecommunications industry and provides the incumbent operator with an appropriate level of cost recovery.
- Timetable
BT believes that the timetable proposed by the Council could be accelerated in the interests of consumers. BT does not believe that the move to LRIC based charges need take as long as two to three years. The development of models and industry consultation associated with the use of long run incremental models as the basis for interconnect charges took around two years in the UK. It is reasonable to expect that other regimes can draw from the UK, US and other experiences to develop similar tools in less time. BT believes that MPT could aim to introduce separated accounting within one year, and long run incremental cost estimates in under two years.
The implications of LRIC are reasonably well understood through experiences in other countries. BT proposes that, some form of interim interconnect rate reduction be considered immediately. A change could be based upon a prudent assessment of the likely implications of the anticipated move to unbundled, LRIC based charges. In time, once the development activities have delivered useful accounting and LRIC information, prices can be set with a greater degree of accuracy and confidence.
|