Clive Hillier
Ofcom
Competition Group – Floor 4
Riverside House
2A Southwark Bridge Road
London
SE1 9HA
5 December 2005
Dear Clive,
Centrica welcomed publication of the ‘Number Translation Services: A way
forward’ consultation on 28 September. We have subsequently considered
the Ofcom proposals in that document and provide our comments below.
For your ease of reference we have detailed our comments under two main
sections. The first section considers the NTS proposals from Centrica’s
perspective as an originating network, and the second section, contains our
observations on the NTS proposals more generally.
1. Centrica Telecommunications as an NTS originating network
Centrica Telecommunications provides fixed line telephony services under the
Onetel retail brand. Call origination is a significant aspect of our revenues,
and in addition, we also terminate NTS calls to a range of numbers directly on
our own network. The NTS traffic we terminate is predominantly for our own-
hosted services, which typically does not involve a termination payment being
made to a third party SP. The revenues we generate from NTS call
termination activities are significantly lower than those for call origination. The
NTS interconnect proposals made in this consultation therefore have a limited
impact on us as at the current time as an NTS terminating network.
However, in our capacity as an originating network we do have some
significant concerns with Ofcom’s NTS proposals. We, like a number of other
originating networks, are finding it increasingly difficult to recover our costs for
originating NTS calls which we subsequently handover for termination on
other networks. Ofcom’s proposals also have a number of other implications
for us in this regard, which are considered further below using a series of sub-
headings.
(i) National Telephone Numbering Plan and 0870
Ofcom’s proposal for 0870 is to restore the geographic linkage so that all
originating networks would be requir