There are different types of access, namely the analogue access (mainly used by residential subscribers), the basic ISDN access (required by residential and business final clients) and the primary ISDN access (specially used by business subscribers). It must be taken into account that in the business segment the competition level is more emphasized that in the residential segment. On the other hand, simplification of the relationship with the SP may be more relevant in the residential market. Thus, the establishment of different priority degrees as to the SLRO implementation, according to the type of access line, is a possibility ? having regard to the expected results of competition development, to the short and medium term benefits for the consumer and to the procedural and to the technical swiftness of the different solutions to be adopted.
In case of a phased introduction, the SLRO may turn out to constitute an obligation for PTC, being an entity with SMP in the market of the fixed subscribers networks and/or fixed telephone services, as regards the analogue line, in which case its extension to the ISDN lines shall be assessed according to the expected demand level for that offer. Concerning the primary accesses, the existence of alternative means and technologies that allow licensed operators to present offers that compete with those of PTC must be particularly examined.
In this respect, it must be mentioned that OFTEL and ComReg determined, on 11/03/03 and 12/02/03, respectively, the inclusion of the ISDN lines in the wholesale subscriber line offers to be made available by British Telecom and Eircom, respectively.
The existence of a set of additional services/service facilities, possibly of a residual character, provided by PTC, must also be considered and its integration in the SLRO must be assessed. At present, some of these services may be the following: services relating to the calling line identification, namely the presentation and/or restriction of calling number identification; services relating to call management, such as call forwarding and barring; intelligent network services, such as calls to non-geographic numbers, particularly freephone services and shared cost call services; services for the consultation and management of the voice mailbox; billing and collecting mechanisms of the Internet access services, according to the provisions established in the Reference Internet Access Offer (RIAO)1https://www.anacom.pt/render.jsp?contentId=55129; the short messaging service (SMS); and the leasing of terminal equipment.
Having PTC the right to charge the final client for the provision of additional services/service facilities, these may have a residual character, and, per si, do not justify the billing by PTC, as far as efficiency and simplification of relationship with the final client are concerned. Thus, in a scenario where PTC is obliged to make the SLRO available, it seems appropriate, alternatively, that PTC is given the right to charge the final client for those services through the SLRO beneficiary, at the retail prices established by PTC. Without prejudice to the afore-mentioned, the beneficiary may be remunerated for the costs incurred in the billing and collecting of the additional services/service facilities.
It must be noted that the existence of a bill with a tendency to be single depends, for a large part, although not exclusively, on the extension of the range of non-geographical services eligible for the indirect access. This issue is currently under analysis, namely within the scope of a public consultation on carrier pre-selection to be carried out by ANACOM, the result of which shall be taken into account as regards the SLRO.
On your opinion, over what type of access is the existence of the SLRO appropriate, namely having regard to the benefits for final clients, the possibility of substitution on the supply side, and the simplification and swiftness of implementation? Do you find it necessary/appropriate to include in the SLRO the additional services/service facilities provided by PTC, on the resold network lines? Please identify the services and solutions you deem appropriate.
1 See http://www.ptcomunicacoes.pt/operadoreshttp://www.ptcomunicacoes.pt/operadores/