INCA has submitted its response to Ofcom’s consultation on the second threshold calculation in the copper retirement framework.
We support the phased retirement of Openreach’s copper network. But we have told Ofcom that the test for the second threshold should be whether it maximises long-term benefits for consumers — not whether it makes Openreach’s transition easier to administer.
Our central argument is against the Fixed Percentage Approach as proposed. A single national percentage does not reflect how different local exchange areas actually are, and applied bluntly it risks disadvantaging the independent networks that have built competing infrastructure in those areas.
Instead we have recommended a hybrid: a Defined Exclusions Approach combined with a low Fixed Percentage Approach set at 3%. That combination recognises the real variation between exchange areas while still giving Openreach a workable path to retirement.
This matters for independent networks because the threshold determines where and when copper can be switched off — and a framework designed around the incumbent’s convenience would undermine the competition that has driven full-fibre build in the first place.