The above-mentioned technical complexity requires a clear and precise definition of the offer. Therefore, the subscriber line resale offer hereby proposed1https://www.anacom.pt/render.jsp?contentId=55129 consists in a wholesale offer, at a determined price, of the right to bill the telephone line2https://www.anacom.pt/render.jsp?contentId=55130 of PTC. The SLRO is supposed to allow the beneficiaries to establish their own retail offer that integrates the line resale along with other services.
Without prejudice to the already registered positive evolution, several NRAs have developed new ways of stimulating competition in the FTS, namely taking the view that the introduction of the ULL and the indirect access are still insufficient. Among those ways, the obligation to offer a subscriber line resale by operators with significant market power (SMP) may be highlighted. This type of provision has been developed in Ireland, Denmark, Norway and the United Kingdom, whereas in several other Member States of the EU is it still being studied.
To clarify the SLRO concept, the telecommunications services may be divided conceptually in two levels: (a) the network operations, such as interconnection and access, wherein the relationships between public network operators (NOs) are established, and (b) the retail services, comprising the provision of services to the final client by other service providers (SPs). In this scope, the NOs produce services at the level of network operations only, namely services relating to call origination, traffic and termination, whereas service providers carry out activities at the level of retail services, namely providing sales and promotions services, service creation, contracts with clients, billing and collecting.
Picture 1 ? Present situation
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Picture 2 ? SLRO
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On the other hand, the SLRO allows customers that adhere to a certain service provided over the subscriber line the possibility of receiving in the same bill the amount relating to the network line subscription and the charge for services provided by the operator concerned, who shall determine both retail prices, as shown in Picture 2. However, one should bear in mind that, although for the subscribers in general SLRO is sufficient for the existence of a single bill, there may be cases where this situation might not occur, as some subscribers shall still have available the indirect access3https://www.anacom.pt/render.jsp?contentId=55131 and Internet functionalities, which shall be billed and collected by the respective entities, unless they agree something otherwise with the beneficiary of the SLRO. Likewise, the subscriber may also use services that are not within the scope of the SLRO, a situation examined in point 2.2.
According to the proposed definition, the maintenance and repair of the network line and related infrastructure are still incumbent upon PTC. However, when the SLRO is put in operation, it shall be incumbent upon the final client to contact the beneficiary of the SLRO and inform it of aspects concerning the service quality. The beneficiary shall then contact PTC, that must ensure service quality levels in appropriate and non-discriminatory conditions.
Within this context, the development of an offer such as the SLRO grants its beneficiary the possibility of developing its own retail offers, adding value to the final client through the creation of innovative services, and competing with the offers of PTC that aggregate, in optional plans, the access price and the telephone traffic price.
| Question 2 Do you consider the SLRO, as presented in this document, to be an appropriate solution for the promotion of competition in the market of fixed communications? Do you identify other wholesale offers for the subscriber line that best achieve the goals above-mentioned, namely the creation of the appropriate conditions for the development of competition and of innovative offers? Discuss the impacts of this solution on the development of further offers, assessing the advantages and drawbacks thereof. |
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1 Hereinafter referred to as ?SLRO?.
2 Value to be given for the item ?telephone line?, included in the ?monthly subscription? heading of the FTS bill of PTC.
3 Regardless of the SLRO, it is still possible for the subscriber to opt for more than one pre-selected operator (according to the type of eligible traffic), for the call-by-call selection and for the alteration of its pre-selected operator, in case the subscriber has already adhered to that functionality.
