I don't think this has been posted before:

http://www.ofcomconsumerpanel.org.uk/advice/emergency_number/emergency_number.htm

referencing:

http://www.ofcomconsumerpanel.org.uk/advice/emergency_number/G1.pdf

http://www.ofcomconsumerpanel.org.uk/advice/emergency_number/G2.pdf

http://www.ofcomconsumerpanel.org.uk/advice/emergency_number/G3.pdf


From: Colette Bowe
Sent: 10 July 2005 19:30
To: Ed Richards
Cc: Stephen Carter; Julie Myers; Matt Peacock
Subject: Emergency in London: use of an 0870 number
Dear Ed

This is a formal communication from me as Chairman of the Consumer Panel.
I am addressing it to you and copying to Stephen because of the seriousness
with which I am viewing the issue, although I expect it is being dealt with
elsewhere in Ofcom. I am also copying in Matt, as I see there has been some
press coverage today (Sunday).

I was horrified to see on Thursday that the number to call for anxious relatives
etc was an 0870 number. This seems to be completely inappropriate, to put it
mildly. I recall from previous exchanges we have had on these nongeographic
numbers, that Ofcom does not have powers to circumscribe their
use – and the use made of them by governmental and other public sector
bodies is influenced only by some rather weak guidance from, as I recall, the
central procurement part of Whitehall, no doubt located some where in the
Cabinet Office.

This seems an appropriate moment to return to this issue. It seems to me that
the use of such a number (as distinct from the efficiency of the service which it
delivers) is a serious lacuna in the otherwise impressive emergency
arrangements that we saw activated on Thursday. The use of a revenue
sharing number rather than a free number in such a situation is offensive for
all the obvious reasons.

I would be most grateful for any initial thoughts from you or your team about
how this matter might be – or indeed is being - tackled.

Colette

***

From: Sally-Ann Kent On Behalf Of Ed Richards
Sent: 13 July 2005 12:07
To: Colette Bowe
Cc: Matt Peacock; Stephen Carter; Gareth Davies; Julie Myers
Subject: 0870 Numbering
Colette

Please find attached a note from the NTS team setting out the position in relation
to the 0870 number used after the bombings last week.

As I think it makes clear, the Ofcom stance on the use of 0870 numbers by public
services is clear. We have also made our position on the specific case in
question clear, both in public and private. We will continue to do this.

It is a matter for the Panel, but you do, of course, have powers to advise not only
to Ofcom but also the Government and others more generally where you believe
this is appropriate. The panel may wish to consider more direct communication
with the Cabinet Office and others in Whitehall in relation to this specific case
and indeed the use of 0870 numbers in the public service more generally.
Ed

***

Briefing on the use of Number Translation Services
(NTS) by public sector organisations
11 July 2005
Background
The NTS Project Team has been asked to provide an update on public sector use of
NTS numbers after it emerged that the Metropolitan Police are using an 0870
number for the emergency contact number for relatives of those affected by the 7
July bombings in London.

Ofcom view of public sector usage of NTS numbers

Ofcom has publicly stated its view that 087 numbers should not be used by public
sector organisations and is also aware of consumer concern about the use of
chargeable NTS numbers (and in particular 087 numbers) by public sector
organisations.

For reasons discussed in more detail below, the NTS Project team does not believe
that it is appropriate for Ofcom to use regulation to prevent the public sector from
using 087 (or other NTS numbers) and has instead:
· contributed to a revision of the public sectors guidelines on communications; and
· advises public sector bodies on an ad-hoc basis;

The Central Office of Communications (COI) provides advice and support to public
sector organisations on all aspects of communications. Amongst other things it
publishes ‘better practice guidance’ for Government contact centres. In 2004, The
NTS Project Team contributed to a revision of the better practice guidance that was
issued in January 2005. The revised guidance advises government departments not
to use 087 numbers for contact centres that are called by consumers and also
advises them to consider the cost to consumers of 084 numbers before deciding to
use an 084 number rather than a freephone or geographic number. (more detailed
description of the NTS guidance at the end of this note).

A limitation of the COI guidance is that it is best-practice guidance and is not binding
on public sector organisations; however public sector organisations are normally
expected to follow the recommendations unless they have very good reasons not to.

...

...

The Met’s Emergency Number

Apart from being insensitive, the selection of a 0870 number for the Met’s helpline
clearly contravenes the COI guidance. It is also surprising that an 0870 number was
selected given that the Met is advised by its own technology support agency (PITO)
which should have known that a 087 number was unsuitable for this particular
application.

The Policy Issues

The policy view is that NTS is a legitimate micro-payment mechanism and that
Ofcom should not restrict the types of service or organisation eligible to use this
payment mechanism. Instead it is a matter for the organisations concerned (and
ultimately the government in the case of public sector) to decide whether an NTS
number is appropriate for their particular application and if so which range is best
suited to the application. The Policy Executive has recently endorsed this view.
The NTS project team believes that the COI guidance is the best route to encourage
appropriate use of these numbers by the public sector. The NTS project team has
also been proactive and has contacted public sector organisations such as the
Department of Health to give advice.

The NTS project team also thinks that Ofcom would have difficultly implementing a
restriction on public sector use of NTS numbers. The most likely mechanism to
implement such a restriction would be via the National Telephone Numbering Plan
(NTNP). Ofcom has powers to set conditions in the NTNP relating to the use of
telephone numbers. However, the NTS project team believes that Ofcom would have
difficulty satisfying the necessary legal tests to use these powers to prevent public
sector organisations from using some or all NTS number ranges. When setting
conditions relating to the use of numbers, the Communications Act requires that
Ofcom fulfil a number of legal tests. These are that the conditions must be objectively
justifiable, non-discriminatory, proportionate and transparent. The NTS project team’s
view is that restricting the availability of NTS numbers to public sector organisations
whilst allowing private sector organisations to continue to use them would be
discriminatory and would not be objectively justifiable. It is also arguable that it would
not a proportionate response to the problem.

Assuming that Ofcom was able to use the NTNP to restrict public sector use of NTS
numbers there would likely be some practical difficulties since the NTNP applies to
the communications provider that is allocated the number range rather than the
organisation using the number. Although the communications providers are required
to take reasonable steps to ensure that numbers are utilised in accordance with the
NTNP relying on communications providers to enforce these conditions might not be
a particularly satisfactory way of ensuring compliance.

The NTS Framework Re-examination

Ofcom consulted on changes to the regulatory regime supporting NTS in October
2004. Responses indicated a lack of consensus in favour of Ofcom's preferred option
and therefore additional research has been undertaken.
A second consultation with revised proposals is being prepared. The project team
have presented the key issues to the Policy Exec and Board recently and will return
later this month for approval of the preferred approach. Dates are PE 18 July, Board
26 July.

The NTS Project will be presenting to the Consumer Panel on 21 July.

For Reference

Further details of the COI Guidance

In January 2005, the COI reissued the ‘cost to the citizen’ section of the contact
centre guidance as an addendum pending completion of the revised document. This
section provides guidance to government departments on amongst other things the
selection of telephone numbers for government contact centres. The revised
guidance raises awareness of the cost of calling 084 and 087 numbers and describes
how the local and national rate terms have become outdated. The revised guidance
recommends that:
· freephone numbers (0800, 0808) numbers should be used where callers might be
deterred by the cost of the calls or where the objective is to encourage as many
people to call as possible;
· geographic numbers or 0844/0845 numbers should be considered as an
alternative to freephone numbers, but recommends that government departments
consider the cost to the consumer particularly of 0844 numbers;
· 0870 and 0871 numbers should not be used for contact centres called by
consumers;
· 0870 and 0871 numbers should be used with caution for contact centres called by
businesses since call charges are higher than for geographic calls;
· alternative contact mechanisms such as geographic numbers or postal
mechanisms should be offered alongside or as an alternative to 0870 and 0871
numbers; and
· 09 premium rate numbers should never be used for public services.

NTS Call Charges

In last weekend’s press articles, 0870 call charges have been listed as up to 10p per
minute from landlines and up to 50p per minute from mobiles. Whilst these figures
are probably factually correct they don’t reflect the price typically paid by consumers.
For BT customers on the BT Together discount packages calls to 0870 numbers
cost:
· 7.51p per minute during the daytime
· 3.75p per minute during the evening
· 1.5p per minute at weekends.

...

...

Other communications providers don’t have significant market power and are free to
set their own charges. In practice most major fixed line providers have slightly higher
prices during the daytimes (typically up to 8p per minute) and prices up to 5p per
minute at evenings and weekends.
Charges from mobile phones vary according to the talk plan package and are
normally highest with prepaid packages. Charges for calls to 0870 numbers are not
always as high as those quoted in the press. For instance Orange charges are:
· Postpaid plans – Same charges as for geographic calls
o 10p per minute at all times of day
· Prepaid plans – same charges as for geographic calls
o e.g. 20p per minute for the fixed rates all day plan
o e.g. 35p per minute peak, 10p per minute off-peak for the Off-peak
caller plan

[END]

Plenty more Ofcom Consumer Panel advice to Ofcom at

http://www.ofcomconsumerpanel.org.uk/advice/

idb wrote on Oct 7^th, 2006 at 12:17am:

Plenty more Ofcom Consumer Panel advice to Ofcom at http://www.ofcomconsumerpanel.org.uk/advice/

And almost invariably ignored if following it would impede the next career move or peerage or knighthood prospects of the Ofcom CEO ;)

Although I had been carrying out my own private war against 0870/0845 numbers and received a substantial refund from BT for the cost of my 0870 back in August 2002 calls (because I could demonstrate I had been mislead as to the cost) it was the London Bombings that bought me to this site. I was just so angry at the use of the 0870 number for people who would be so desperate for information.

I complained vigorously to OFCOM and their response was there is nothing they could do. They were not in the slightest bit interested. In my view they only took an interest when it became apparent their was considerable anger.

Keith wrote on Oct 7^th, 2006 at 5:05pm:

I complained vigorously to OFCOM and their response was there is nothing they could do. They were not in the slightest bit interested. In my view they only took an interest when it became apparent their was considerable anger.

Ofcom senior staff seem to be selected only on the basis that they are out and out self serving careerists who will do whatever their New Labour lord and masters like Tessa Jowell secretly tell them they want to be done without even a shred of conscience.

Their only motivation is to stick their corporate snouts as deep as possible in the Ofcom salary trough and suck out as much salary and pension scheme benefits as they possibly can before the whole sorry regime is inevitably scrapped by the next Tory government.