(Telecompaper) BT has made its final submission to Ofcom's Digital Communications Review. BT argues that it is vital for the digital future of the UK that Openreach remains part of the wider BT Group as this will enable it to continue to benefit from BT's capital as well as the around GBP 500 million a year BT spends on R&D. BT wants Openreach to continue providing regulated services to all companies on an equal basis as this model has served the UK very well over the past decade. BT insists that rivals have failed to make a convincing and evidence based case for change. It cites independent data that shows the UK currently leads the EU 'big five' for superfast broadband coverage, take up and competition. BT's submission outlines the regulatory changes needed for the UK, including long-term commitments from Ofcom to provide certainty and clarity; support for consolidation when it benefits competition and brings investment; a better regulatory balance between service quality and price; a level playing field particularly with regard to pay-TV; and simplification of current regulations with duplication removed where possible.