Do respondents agree that the imposition of a notification procedure would be an unnecessary administrative burden?
2.2 The majority of respondents welcomed the proposal and agreed with the Directors proposal that regulatory burdens should not be imposed which are unnecessary. However a few respondents namely ntl, the Operators Group, AT&T and BT were concerned as to how the Director would know who would be subject to administrative charging in the absence of a notification procedure. It was proposed that a list of persons subject to the charge should be made publicly available in order to make the process transparent, to make the Director accountable, and to prevent payment avoidance. Only BT strongly expressed the view that the only legal way to maintain such a list was through the implementation of a notification procedure. BT was very concerned that the failure to implement a notification procedure would have serious implications for the effectiveness of regulation under the new framework and in particular for the efficient and impartial application of the charging regime and the undertaking of
