Yet again I find myself responding to an unnecessarily complex and prolix Ofcom Consultation Document, written in such away as to deter most readers from responding; ever if they are aware of its existence.  Before release, drafts of these consultation documents are clearly sent to a special “Ofcom Obfuscation Department”, who remove any hint of brevity, clarity and logical thought.  Some parts of the documents are untrue. Ofcom have appointed a “Consultation Champion”,  I would ask him to collect together a random selection of  Ofcom employees and give them a few consultation documents to respond to. The results should be interesting.  

At the time of writing, even the email (consult@ofcom.org.uk) and response fax number (020 7981 3333) are well hidden on the Ofcom site.  

Ofcom’s states: “Ofcom exists to further the interests of citizen-consumers as the communications industries enter the digital age.”  (see web: http://www.ofcom.org.uk/about_ofcom/)

Quoting from the OFCOM document: “NTS – Options for the future –A summary”
“Industry Concerns.       ….  From time to time, BT changes its local and national retail call prices to stay competitive with other phone companies. When BT changes these retail call prices, it must also change its prices for 0845 and 0870 calls. This is because, under our current rules, 0845 calls must be priced (before call packages and discounts) at BT’s standard local retail price for BT customers. The price of 0870 calls is linked in a similar way to the price of a national call for BT customers. When BT reduces the prices of 0845 and 0870 calls, there is less money to share with the terminating operator and the NTS service provider. This is especially serious for internet service providers whose services are paid for entirely from call revenues and who are finding their profits squeezed by falling prices.”

This plainly is an untrue statement and the argument illogical. Local and National rate calls are combined and both cost the same, the BT UK Universal Rate is 3p/min.  0870 calls cost 7.5 p/min and did not change to 3p when the BT UK Universal Rate changed.

Sir Walter Scott (1771 – 1832) may well have had the equivalent to an Ofcom consultation document and the “08” numbering system in mind when he wrote:
“O what a tangled web we weave, When first we practice to deceive.”

The solution to “Industry Concerns” (above) is to prohibit all revenue sharing from the 08 category completely. All 08 numbers should be put on the same footing as 01 and 02 numbers.  Organisation not interested in revenue sharing would continue to use their existing 08 number which would cost callers from 3p to 0p/min depending on their telecom provider.  Organisations who have to have a share of the revenue to exist, should move to an appropriate 09 category, where call charges could be set in the range 1p to 150p/min.  The costs to the consumer would be transparent for all to see, if the cost was set too high, market forces would decide who survived.  The 09 classification was set up for revenue sharing and ICSTIS regulation would automatically apply.  

Note: consultation response to be sent to Ofcom by 5pm 7 Jan 05

Completely aggree kk.

If Ofcom created 0844/0871 to provide TCPs and SPs revenue certainty, why have they not moved over, as Ofcom competition theory states? Simple, number changes should not be necessary and businesses (and consumers) don't like them.

So what they are doing (by proposing option 2) is admitting that it [the need to change number to vary price] doesn't really work and are forcefully introducing this 0844/0871-type framework!

KK
I have been to the OFCOM website.
How the devil (I'll put it mildly) do you send a response to a consultation document?
Can you send an email and if so what do you have to put in the email and where do you send it?
And why, oh why, do they have to make it so difficult. Anybody would think they don't want any responses and that can't be right, CAN IT? ;D

You can send your response by email to Ofcom at: consult@ofcom.org.uk (or by fax or by post).   If possible, you should include an Ofcom cover sheet, which you can get from the Ofcom web site, or paste it into a WORD document and send it as an attachment by email.

Alternatively “copy” and “paste” the cover document I have reproduced below into your email, add details such as your name, address and title of the response then add your response below it.  Indicate if you wish to keep anything confidential.

The two response titles are:

1    NTS – Option for the future.
2    NTS – Call termination Market review.

If you have time you can response in detail to the many issues raised in both document, but as the consultation documents are overcomplicated and impenetrable, it may be wise to respond in general terms and tell them what you think of 0870 and 0845 numbers etc.
A short response is better than none.  You could send the same response to both titles 1 and 2 above.

If you have a problem, send me an email at: kbkearney@hotmail.com

-------------------------------------------------------------------
Cover sheet for response to an Ofcom consultation

BASIC DETAILS

Consultation title:  

To (Ofcom contact):

Name of respondent:

Representing (self or organisation/s):  

Address (if not received by email):  


CONFIDENTIALITY

What do you want Ofcom to keep confidential?  

Nothing

Name/address/contact

Details/job title          

Whole response

Organisation                                        

Part of the response
                         
If there is no separate annex, which parts?  


Note that Ofcom may still refer to the contents of responses in general terms, without disclosing specific information that is confidential. Ofcom also reserves its powers to disclose any information it receives where this is required to carry out its functions. Ofcom will exercise due regard to the confidentiality of information supplied.


DECLARATION

I confirm that the correspondence supplied with this cover sheet is a formal consultation response. It can be published in full on Ofcom’s website, unless otherwise specified on this cover sheet, and I authorise Ofcom to make use of the information in this response to meet its legal requirements. If I have sent my response by email, Ofcom can disregard any standard e-mail text about not disclosing email contents and attachments.

Ofcom seeks to publish responses on receipt. If your response is non-confidential (in whole or in part), and you would prefer us to publish your response only once the consultation has ended, please tick here.  

Name

Signed (if hard copy)
---------------------------------------------------------------------


.......( End of cover sheet - remove this note and the dots, and start typing your response here)

Hi Stewart,

I hope the above is of some use.

KK

KK
Thanks very much!
Now I know what to do.
Will have to send a complaint to Ofcom about their website.

Hi Stewart,

That is the whole point of the campaign site facility for sending responses. It provides response templates for you to use, and gives you the correct e-mail address which Ofcom ask you to send your responses to - not the one which kk gives, which is not the one Ofcom specify.  It therefore makes it easier, since you do not even have to read these wretched Ofcom verbose documents unless you particularly want to. You can just edit the templates to easily produce a response to each of the two consultations, deleting anything you don't want in the template for your response.

The significant thing is that Ofcom have set certain questions in each consultation. This is something of a trap and if you send a general statement as kk suggests it will not be taken seriously, because you will not have answered the specific questions. The templates allow you easily and quickly to do that. There are only 2+ days left to get your responses in by e-mail to nts@ofcom.org.uk. The site which makes it easier is: http://www.freeweb.telco4u.net/rachelf

The consultation info is here, along with the Word cover sheet:
http://www.ofcom.org.uk/consult/   ;)

Options for the future consultation is here including some responses which have already been published which you may be interested in.

The other consultation, NTS call termination market review is here.

Dorf and Dave both make valid points.  I am assured that either using Consult@ofcom.org.uk or nts@ofcom.org.uk will get to the correct place in Ofcom. nts@ofcom.org.uk does look better. As to the approach in responding I have taken a mixture of general comments and a few point by point responses.  Sir Brian Crowe, in his lucid and comprehensive response document, appears to favour the more general approach (as I do) and eschews the point by point rebuttal approach.  

Each to his own.

Thanks everybody.
Have sent two responses by email.