The Ofcom consultation on
Simplifying Non-Geographic Numbers proposes a change that has long been called for in this forum - 080 and 0500 to be "free to caller" in all cases.
The question of who is to pay the extra cost involved in originating "freephone" calls from mobiles does however need to be resolved.
The Ofcom consultation appears not to address the question of what is to happen as a result of the steadily reducing levels of termination payment for calls to mobiles. It has always been my view that there should be a single answer to both questions.
Ofcom does not state a preference, however its arguments weigh heavily towards replicating the equivalent of the present termination rate premium, i.e. passing the additional cost to the person who is paying for the call anyway - the service provider in the case of Freephone calls.
This seems to me to be counter-intuitive, especially in a situation where Ofcom is seeking to remove external subsidy for the cost of mobile telephony.
Whilst there may have been an argument for external subsidy to get the mobile networks up and running and there remains a social argument for continuing to subsidise the availability of a telephone connection for those of lesser financial means, the former has expired and the latter is poorly answered by a subsidy to all mobile users.
I would argue strongly for there to have to be some equivalent of a "line rental" charge for mobile services. This would (as with landlines) meet the costs associated with receiving incoming calls and also be sufficient to enable services such as Freephone to be provided on the same terms (to service providers) as calls originated from landlines.
I therefore favour the option for Freephone service providers to incur no additional cost for receiving calls from mobiles. The consequences of any alternative approach are likely to be contrary to the objectives of the simplification project.
It is for the mobile providers to determine how their customers pay to meet the costs of the services they offer. They are already facing a much larger issue with the reduction of the incoming termination fees. I believe that the additional costs of not being fully reimbursed for originating Freephone calls should be addressed in the same way, whatever that may be. If they are to continue to rely on call revenues to cover all network operations then call and package charges will have to be increased to meet both situations.
Ofcom has noted that the increased call volumes generated as a result of making Freephone free could cause some Freephone service providers to withdraw altogether, or modify their offering. I see such an effect as unavoidable. The possibility of some seeking to block calls from mobiles because of an additional cost should be avoided. In the context of a "simplification", it would not make sense for Ofcom to propose an alternative range for "free to landline caller" numbers, although having two different classes of Freephone would have to be considered if there were to be two different cost structures. Had the issue not been raised in the context of "simplification", then it could have been proper for Ofcom to offer the idea for consideration.
I hope that other who have contributed to discussions on this topic will add their views.
It will also be interesting to hear 0800Buster and others celebrate success for their campaign! - or perhaps bemoan the shutting down of their business.