The provision of services in a subscriber line may generally involve the following agents:
a) PTC, that provides the direct access service, and therefore the rental of the subscriber line and related traffic, as well as the additional services/service facilities;
b) OLL(s), that provide pre-selection services for national calls and/or pre-selection services for international calls and/or call-by-call selection services and/or broadband services; and
c) ISP(s), that provide broadband services and/or Internet dial-up services and/or voice over Internet services.
The determination of the entities that may benefit from the SLRO must be carried out based on the purposes established for that offer and on its potential advantages. In that scope, it is appropriate to ensure that all agents providing services on a certain subscriber line, and only these, benefit from equivalent possibilities of aggregating services, so that they may compete in the same conditions.
The FTS providers seem, in principle, the first entities that benefit with the SLRO, having regard to its relationship with the final client. In this context, it must be pointed out that the operator pre-selection functionality allows operators without their own infrastructure to provide FTS, thereby making them direct competitors of PTC as far as that service is concerned. On the contrary, the sporadic character of the bond between an operator that only provides a call-by-call selection and its client leads to a non-representative weight of the traffic of that type of operator in the total traffic of the client. Thus, if an operator that only provides a call-by-call selection is a beneficiary of the SLRO, the advantages related to the offer shall not be enjoyed fully. In an extreme situation, the entity under consideration could bill the subscriber line without having provided any communications service in the respective period.
Moreover, operators without their own infrastructure generally also provide broadband services, competing with entities that provide that type of services only. Thus, the latter should have the possibility of making available to their clients the aggregation of the subscriber line and the broadband services in the same bill. The definition of a specific wholesale offer that allows to aggregate, at retail level, an Internet service supported in ADSL technology and the access to the FTS, is a way to surpass the indissociability verified in practise between the ADSL service and the FTS, which, in the opinion of several entities, is an important obstacle to the development of the ADSL service, at least in those cases where the client does not show any interest in the FTS service. Furthermore, the voice service may also be provided by ISPs, whether in the dial-up regime or in the broadband regime, although with different service quality levels, in addition to the offer of other telecommunication services.
Bearing in mind the purposes and advantages related to the SLRO, which are the entities that in your opinion should be beneficiaries of the subscriber line resale offer?