Just a note to remind everyone that three different Ofcom consultations relevant to members of this site close this Thursday.  These can be found at www.ofcom.org.uk/consult/condocs/?sector=Telecoms&open=Yes

In roughly descending order of importance these are as follows:-

1. National Single Non-Emergency Number

The key issues are:-

(a) Why a single number now when the end of the lifetime of phone numbers and their replacement by names similar to email addresses via voip is in sight?  Also if this is such a good idea why wasn't it done in the 1970s and why were the Police encouraged to get single 0845 numbers for many years by www.pito.org.uk and why doesn't this consultation also therefore propose a single Voip contact name for non emergency calls to the Police?

(b) Proposing that these calls are charged for outside the normal charging system for 01/02 calls at 10p flat is completely unnecessary and quite outrageous just because a  short code is being used - it is also anticompetitive.  Ofcom is only just consulting on stopping some of the 084/7 call cost abuses so why is a new being proposed on 101.

(c) The standard European proposal for a non emergency number is 116 so why is a number proposed of 101 when 116 will in any case have to be introduced in in due course to comply with EU regulations

(d) That 101 should be a free and unbilled service like 999/112 because any member of a household having to call the Police on a non emergency basis on sensitive matters like sexual abuse or drugs use etc is likely to have the call spotted by the bill payer.  Also having 101 as a chargeable number makes this problem much, much worse since the short 101 code will be very visible on the bill compared to an 0845 or an 01 number for the Police.  So if 101 is introduced it must in fact be a free service

(e) That even if these 101 numbers are introduced there must still also be geographic alternative numbers for calling these contact centres so that people at work can call back to a home police force in another area and ditto for people on holiday in the  uk or who are overseas.

Send your response by email to elizabeth.greenberg@ofcom.org.uk

2. Changes to Premium Rate Services (PRS) Conditions

This proposes extending the PRS conditions to include scam rogue internet diallers of any kind regardless of the number called and to also include adult services regardless of the number used.  In addition any Premium Rate Service offered on a mobile phone is to come within the PRS conditions under the Ofcom proposal.  This means all these services will then also be regulated by ICSTIS.

The key point to make here is that we don't think Ofcom's proposals go far enough and that we believe that the 084/7 and 070 Number Translation Services codes should all be scrapped and all these revenue sharing services transferred to 09 access and regulated by ICSTIS.

Also ask Ofcom why it is running this consultation separately from the NTS Way Forward and Improved Information on Pricing of NTS and PRS services consultations that closed back on Dec 6th.  The running of adult services on 084/7, 070 and mobiles is in fact all part of one continuous issue of clandestine premium rate calls that Ofcom should have sought to resolve in one clear consultation on the whole topic.

Salami slicing up the different issues this way seems to benefit only Ofcom and the industry but not the consumer.

Send your response by email to gavin.daykin@ofcom.org.uk

3. Number Portability and Technology Neutrality

Ofcom is proposing far more flexibility in number portability than just the current existing mobile phone number portability arrangements so that for instance a geographic number can be ported on to a Voip service or a geographic number on to a mobile service.   Also a mobile service can be ported to a geographic or voip access number.

The points to make in responding to Ofcom are:-

1.  Why did Ofcom or its predecessor OFTEL not introduce this regime many years ago so that companies wanting complicated Number Translations Services (NTS) facilities in several different uk call centres could still do so using their old geographic number and at geographic call rates???

2.  Has Ofcom properly thought through the pricing implications of allowing a fixed line number to be ported for use on a mobile service or vica versa?  In such a circumstance the number called is going to give no clue as to the pricing level to be charged.

3.  Ofcom must therefore make it mandatory for all uk fixed line and mobile phone customers to have free of charge call price announcements for any number they call in the uk to overcome this problem and other similar problems with confusion over true price levels for calls to NTS and PRS services.

4.  Also since companies managed perfectly well in the past to move their geographic call centres to different NTS numbers etc is such total number portability proposed by Ofcom justified as it will totally undermine the objective of the NTNP (National Telephone Number Plan) which was to ensure that people had an idea of what a call may cost from the initial digits dialled.  So allowing total number portability is a complete change of culture that undermines the value of the NTNP.

Send your response by email to Elizabeth.greenberg@ofcom.org.uk who is also responsible for the 101 Non Emergency Number Consultation.

Sorry I know this will cut into xmas present buying time :o :-X

Tks NGM; I am typing as fast and, I hope, as accurately as I can.

Perhaps worth adding a note to each that an overall review of the previously excellent Numbering Conventions might be worth carrying out - (with sayno2 involvement  :) ). This would need to be long term, but probably necessary in order to ensure that such a flurry of piecemeal and suddenly urgent consultations does not occur quite so often.

The telecoms world is changing - the UK needs to have the optimum framework in place to enable and to protect the citizen-consumer.

Tanllan wrote on Dec 20^th, 2005 at 9:26am:

Tks NGM; I am typing as fast and, I hope, as accurately as I can. Perhaps worth adding a note to each that an overall review of the previously excellent Numbering Conventions might be worth carrying out - (with sayno2 involvement  :) ). This would need to be long term, but probably necessary in order to ensure that such a flurry of piecemeal and suddenly urgent consultations does not occur quite so often. The telecoms world is changing - the UK needs to have the optimum framework in place to enable and to protect the citizen-consumer.

The key point is that just in order to suit itself by dividing up work between different Ofcom teams of staff Ofcom have arbitrarily carried out no less than 6 consultations in two months on what is one issue.

Namely ensuring that the consumer can clearly differentiate Premium Rate Services from other services when making a call and have  a simple and easy means to always know what they are paying for any call.

Also combined with that issue that Ofcom's NTS and PRS systems should not work or be priced in such a way as to prevent normal market forces from the consumer driving prices down.  But as we all know this is exactly what goes on with especially NTS and to a lesser extent PRS services.

I don't think SayNoto0870 is quite the right title and as we know it is only the title of Daniel's site and discussion forum.

Perhaps we need the Camapign for Clearer Pricing Information for UK Telecoms Consumers or something suitably anodine that Ofcom could feel more comfortable about working with on a regular basis. As compared to a bunch of dangerous sounding radicals like SayNoTo0870. ;)

How about citizen-consumer.com?

Tanllan wrote on Dec 20^th, 2005 at 11:34am:

How about citizen-consumer.com?

No one else has responded to this thread despite my cunning links to it from the 20+ page NTS Way Forward thread.

I fear that they are all out at xmas lunches or panic xmas shopping.

I'm wading my way thru the response documents.

In relation to the Police 101 number, over here in NI, they have just launched a new 0845 number for non-emergency contact with the Police, with a huge marketing campaign. What a waste of money. http://www.psni.police.uk/index/phone-number.htm

Now I must trot off and check that the landline number for that is in the database. Gives me a break from reading :)

Cheers, Des.

oh l*rd - where do they get these people?

From Des' URL:

This new number will connect you directly to the police, who will put you in contact with the appropriate person in the Police Service.

0845 600 8000 will provide a number of benefits for you:
One number for everywhere in Northern Ireland Low cost calls charged at local rates
Easy to remember
Can be saved on a mobile for use anywhere in Northern Ireland This new single non-emergency number is the first step in a package of measures to make it easier for communities to contact the police and thus assist the Police Service of Northern Ireland in improving the quality of service to the public.
The new number will be used in conjunction with current numbers, so if you need to speak to a specific member of staff or station and already know the direct number, please use it. This will help police deal with other calls more quickly.
It is important to note that calls will be charged at local rates but mobile network charges may vary.
Calls to 0845 600 8000 from mobile telephones will be answered centrally within the Police Service of Northern Ireland and the call directed to the appropriate person.0845 600 8000 may not be available on non-UK mobile networks, for example in some border areas, but local station numbers will remain available.

So you may not be able to get through if your mobile has roamed at the border and if you do you may be paying over the odds.  Well done NI police!
Words fail me.

It is a very poor show, but I will put money on who is providing 'the service' to the Police, based in Belfast, and cosy with the BBC.

I can feel a FOI request coming on.

I have updated the database with a geographic number, but while it is verified, if anyone needs it, just message me.

Cheers, Des.

Here is a link to the BLANK Response cover sheet in word format:- http://www.ofcom.org.uk/consult/244504/condoc_cov_sheet.doc


Took me a minute to find it as I foolishly searched :)


Cheers, Des.

DesG wrote on Dec 20^th, 2005 at 1:14pm:

Here is a link to the BLANK Response cover sheet in word format:- http://www.ofcom.org.uk/consult/244504/condoc_cov_sheet.doc Took me a minute to find it as I foolishly searched :) Cheers, Des.

Personally I don't bother with the cover sheet and instead just put on Page 1 of my response that its non confidential and can be published under my name so long as it is published in full and not amended in any way by Ofcom.

If you send a Cover Sheet the Ofcom web publication types only then publish it as Page 1 of your response! ::)

It strikes me that along with hiding the email address for response in the middle of the document that the Cover Sheet is just one of Ofcom's many cunning tactics to put off as many members of the public as possible from responding.  As we know they really much prefer to only get feedback from their cronies in the telcoms industry. :-X

I've just rushed to get in replies to all three Ofcom consultations with response periods expiring today.

Having e-mailed the Changes to Premium Rate Services (PRS) Conditions response to the specified person, I've received an auto-response stating:

"Thank you for your e-mail. I am out out of the office now until Tuesday 3rd January 2006, and will respond to your e-mail on my return."

So why the XXX did they ask for responses before Christmas - or if they are so important, why the  don't the staff stay there to handle the responses!!!!

Presumably this is what Ofcom call 'Customer Care'
:'(

Or "light touch" regulation?

trevord wrote on Dec 22^nd, 2005 at 1:36am:

Having e-mailed the Changes to Premium Rate Services (PRS) Conditions response to the specified person, I've received an auto-response stating: "Thank you for your e-mail. I am out out of the office now until Tuesday 3rd January 2006, and will respond to your e-mail on my return." So why the XXX did they ask for responses before Christmas - or if they are so important, why the  don't the staff stay there to handle the responses!!!! Presumably this is what Ofcom call 'Customer Care' :'(

The same thing happened with Ofcom's disgraceful consultation lasting only 2 weeks rather than their normal 10 weeks for 070 PNS numbers that closed in November.  In that case I got an auto responder from Ruth Gibson saying she was on holiday for the whole of the following week!  So why was it so crucial to cut down responses to only 2 weeks on this issue?  Because Ofcom wanted as few people as possible to spot it and have time to respond to Ofcom's continued signing off of the 50p per minute 070 PNS abuses by Patientline.

Obviously its completely stupid that any of these consultations close today when people who need to respond are busy with other things and when Ofcom won't do anything with the responses until the week starting 3rd January.  But that's Ofcom for you.  They are supposed to be there for the citizen and consumer but in fact seem to be there mainly for themselves and their telecoms industry cronies.  And if one tries to improve things by applying for membership of their Ofcom Consumer Panel or Ofcom Advisory Committee for England as I have recently done one does not even get called for interview.  No Cronies here unfortunately.

Anyhow you will at least have the pleasure of being one of perhaps say only 20 or so respondees to each of these three consultations so at least your comments will have far more impact and be more visible than when you were one of 1,000 as with NTS Way Forward.  So in many ways your efforts here have been far more valuable.  Thanks very much for responding I  must get my comments in by the end of today.

Following my earlier message about having received an auto-response from Gavin Daykin saying he was out of the office until 3 Jan, I sent an e-mail to him about the discrepancy between the response date and his absence, and actually got a reply:

"Trevor,

Thank you for your response to Ofcom's consultation document on
modifying the PRS Condition. For information, I'm not the person who is
collating and going through responses. My colleagues have access to my
e-mail account, and will ensure that all comments are taken intro
account in formulating our final decision.

Gavin

:: Gavin Daykin
   Consumer Policy Manager
   Strategy & Market Developments
   Tel: 020 7981 3859
   Fax: 020 7981 3806
   E-mail: gavin.daykin@ofcom.org.uk

:: Ofcom
  Riverside House
  2a Southwark Bridge Road
  London SE1 9HA
  020 7981 3000
 www.ofcom.org.uk
"

It is of course completely unprofessional that formal responses to a consultation are sent to a private email account of an individual member of staff.

They should all have an email address specific to that consultation that any of the relevant members of staff working on the consultation can access.

But that's Ofcom for you.  Not a very professional outfit but certainly a very well paid bunch of people. :o >:(

My "101" response sent a week ago, but can’t find a list of respondents on the Ofcom web site. Does a list exist?

kk wrote on Dec 22^nd, 2005 at 1:48pm:

My "101" response sent a week ago, but can’t find a list of respondents on the Ofcom web site. Does a list exist?

Send an email to matt.peacock@ofcom.org.uk complaining and he will get it sorted out as he is Communications Director and the web publication team report to him.

They never bother publishing any responses on a Consultation at Ofcom until after they have had complaints that Responses are not being published.

Its much less work for them to wait till the Consultation has closed and then publish them all at once but obviously this is much less helpful to the other respondents to the consultation.

The Responses to all three of these consultations have now been published.  We had to wait a while for the Premium Rate consultation responses to finally appear.

If I may say so somewhat immodestly I still think that I wrote by far the best response to the National Single Non-Emergency Number Consultation.  No one else even seems to have even thought about the problem of needing to call a Police force or council in another area or questioned why the council services listed as being callable on this service are more important than various other crisis management services run by local councils.  Also no one else has mentioned the failure to set up a Single National Non Emergency voip (computer to computer) address for contacting the Police.  It also seems little short of a disgrace that only one uk police force responded to this consultation whereas they have practically all responded to a Home Office consultation proposing the abolition and amalgamation of many existing uk Police forces.

Here are the Responses to these three consultations:-

National Single Non-Emergency Number

www.ofcom.org.uk/consult/condocs/snen/responses/

Conditions Regulating Premium Rate Services

www.ofcom.org.uk/consult/condocs/prsconditions/responses

Number Portability and Technology Neutrality

www.ofcom.org.uk/consult/condocs/numport/responses/

Apart from NGM’s own splendid response, BT's own response to the consultation,

      National Single Non-Emergency Number    www.ofcom.org.uk/consult/condocs/snen/responses/  
      (See NGM’s post above)

is well worth a read, especially “Tariffing for Callers” paragraphs 16 to 24 and Annex A.

The response in an indication of BT’s thinking on other related matters.

Yes a pretty thoughtful and intelligent response from BT taking on board the problems of 101's prominence and identifiability if it was chargeable and also pointing out that for 101 to cost more than many customers pay for geographic 01/02 phone calls by the time it is introduced would be a major issue.

They don't however tackle the problem of calling from overseas or out of area and how one can get to the same call centre(s) without using 101.  Of course strictly speaking the consultation brief from the Home Office doesn't ask these questions but why not and where else has the Home Office indicated that it actually understands or comprehends those issues. [smiley=undecided.gif]

So yes a good response by BT but still not quite as comprehensive as my own. ;)