ROT methodology (7 November 1999) OFTEL has issued a Direction concerning BT's NTS Conveyance. This is an obscure title for something important; we've spent a great deal of time trying to understand the contents of the Direction and find the means, if not the end, disturbing. What the Direction means is a defeat for BT over how interconnect charges between it and other operators are calculated. The new arrangements have been hailed a as a 'path to unmetered'. Before getting excited we would like to demonstrate this ourselves ... but we cannot because the Direction, and the Explanatory Document to the Direction, surpass all comprehension. The Explanatory Document starts (paragraphs 2 to 4) with what looks like two simple formulae. Unfortunately two of the three quantities on the right-hand side of the formulae depend on factors such as an uplift to allow for retail costs, discounts charged by the originating operator and disaggregat[ion] into two rates. What uplift? What discounts? What rates? There is no indication of where these questions could be answered and Web searches by us have proved fruitless. In the rest of the document there are many statements such as will not discuss the merits of either view (paragraph 27, where the views appear to have some bearing on the contents of the Direction), was the best available at the time (paragraph 28), without any supporting evidence (paragraph 34), probably ... a more transparent means of calculation (paragraph 34), and the Rule of Thumb methodology (paragraph 36, which is another way of writing 'guess' and gives this news item an appropriate title). Finally, the 'straight-line fit' in the Appendix has been made by throwing away information on a graph ... so is not improved by the quotation of a formula immediately after it. BT doesn't come across well either - consider statements such as here again BT's charge had no supporting evidence (paragraph 18), unable to verify how BT's offer was calculated (paragraph 18), BT did acknowledge one or two minor errors in their calculations which were corrected (paragraph 22), their [BT's] inability to demonstrate this caused ... sceptic[ism] over the nature of their charges (paragraph 33) and so on. In summary, a crucial Direction by a regulator who is intended to represent your interests is ferociously hard to understand, even with an explanation: when the clouds occasionally lift it feels vague and unfinished.