Ofcom has today launched a consultation in which it puts forward significant proposals aimed at making pricing of non-geographic numbers simpler.

The consultation is called Simplifying Non-Geographic Numbers and runs until 10 March 2011:

http://stakeholders.ofcom.org.uk/consultations/simplifying-non-geo-numbers/


The news release is here:

http://consumers.ofcom.org.uk/2010/12/tackling-consumer-confusion-over-call-charges/

Dave wrote on Dec 16^th, 2010 at 11:36am:

The consultation is called Simplifying Non-Geographic Numbers and runs until 10 March 2011:

Sorry to say I am already disappointed and dissatisfied with this Consultation and I haven't even opened it yet.

The title alone gives the game away --- a "Simplification...".  Not a proper fundamental re-axamination of this sector, a radical or intellectual review of the ethics and legitimacy of a very shady business which has been carried on for many years.  

The title of this CON--sultation indicates that the fundamentals of ripping-off the Great British Public are to be continued but perhaps simplified in some way.  The Banking, Insurance, Retail and other industries, even Government Departments and of course chiefly the Telecomms Industry itself will be given free rein to continue exploiting the public.  

The public have been conditioned over many years into thinking that taking money out of their telephone accounts and handing it over to all these avaricious industries is in some way a normal or legitimate business practice whereas it is in fact nothing but a massive scam to carry out daylight robbery from their accounts.

Will OfcoN address this fundamental issue and look at taking action to correct this wrongdoing?  Will it carry out its obligations to serve the public interest and protect telephone users from HARM, their euphemism for robbery?   No, it will look at ways of "Simplifying" the regime, making it easier for the scamming and rip-offs to continue.  What are we paying OfCoN for?????

There is perhaps one good thing which may emerge from this enormous failure by OfCoN -- and that is that the future need for SayNoTo0870.com will continue well onto the future.   Thank God and three cheers for  .... SayNo...!!!  :) :D ;D 8-)

Noting initial reactions and (relatively little) media coverage, proposing "simplification" is not an easy thing to do, it is most certainly not "simple". One has to address and understand the present complexities, before one can recognise that that proposed outcome is indeed a major step in the right direction, if not the place that one would have started from in an ideal world.

I do hope that we will have the opportunity to have a lively debate in this thread. The issues being addressed and the proposals outlined are fundamental to the matters that we discuss in this forum. All forum contributors should take pride in the fact that the views which they have presented over a long period have been noted and in many cases taken on board by Ofcom.

It is inevitable that some will reject the consultation without having even read it, believing that it is damned by virtue of its authorship. I hope that moderators will ensure that those who wish to express opinions such as those offered in reply #1 above are able to do so without disrupting serious objective consideration of the specific proposals. There are many who do not believe that Premium Rate Services, revenue sharing, Directory enquiries and other facilities, when provided at advertised rates, are fundamentally illegitimate and tantamount to robbery. Some of us believe that efforts to clarify the charges are worthy of support, not blind condemnation. There are however serious questions about whether the measures proposed are adequate and about how they will work in practice. I hope that it will be possible for us to discuss these questions properly in this forum.

From The Daily Telegraph
http://www.telegraph.co.uk/technology/mobile-phones/8207327/0800-numbers-should-be-free-to-call-from-mobiles-says-Ofcom.html



By Matt Warman, Consumer Technology Editor 5:31PM GMT 16 Dec 2010

Comment

Communications regulator Ofcom has launched a consultation that could force mobile phone companies to make calls to 0800 numbers free, as well as regulate the way call charges for directory enquiries and phone voting are advertised.

Ed Richards, Ofcom’s chief executive, said that the current environment was “opaque, confused and uncertain” as he announced that the regulator was proposing to make all calls from mobile and landlines to 0800 numbers free by 2012.

The regulator has also added that it would like to introduce a transparent system of pricing for all phone numbers. The move could mean, for instance, that phone voting on popular televisions shows such as The X Factor would display common symbols to indicate how much a call would cost.

Calls to 01, 02 and 03 numbers would be charged at standard “geographic” rates as they are currently. This means they are usually part of a mobile phone contract "bundle".

Research by Ofcom has suggested that the public routinely underestimate some costs to premium rate numbers beginning 09, while they overestimate the costs of calling 08 numbers from both mobiles and landlines.


Under new proposals, the regulator would force phone companies and service providers, such as banks and electricity companies, to indicate how much a call costs to make and how much the recipient charges. The result could be on-screen messages that tells users how much as call costs, and indicates that it was also subject to a mobile company’s “access charge”.

sherbert wrote on Dec 16^th, 2010 at 6:59pm:

From The Daily Telegraph ...

For the benefit of those who wish to follow media coverage of the consultation I have started a roughly presented feed, viewable at this url - http://tinyurl.com/DHMediaOfcom.

There are 5 items (from major media only) currently.

I have not included this as one of my (better presented) campaigning feeds, as many unrelated topics are covered. My primary focus from the announcement of the consultation is to utilise the immediate classification of 0845 and 0844 as "business rate" with a presented need for the currently inclusive "service charge" to be unbundled, to press demands for public bodies to switch to "geographic rate" numbers (including 03).

I have attempted to start a discussion on one highly publicised aspect of the proposals, often covered in this forum although not a core issue  - Making Freephone Free.

It is interesting that the January edition of Which? magazine has this as the main headline on the cover :---

"0870 0800 0845 Expensive phone numbers ...  ... and how to avoid them."

Inside is a 3 page article in which they state "As we went to press phone regulator Ofcom told Which? that UK phone numbering was a high priority and that it was looking to make changes.  We'll be working closely with them to make sure your best interests are at the heart of all the changes it makes."

It appears that Which? intends to have conversations with Ofcom during this consultation and they may well be influential.   I am a subscriber to Which? and I urged them to contribute to the previous Ofcom consultation but they seemed reluctant at that time.  I hope that this indicates a change of attitude for the better by Which? and that they will take the right approach to Ofcom this time.   I urge any other members of Which? to contact them now and add to the weight of opinion to support Which? in tackling Ofcom on this issue.

An excellent comment in The Telegraph which makes the point very succinctly that I have been promoting.

Pericles
12/17/2010 10:01  
All non-geographic numbers should cost the caller the same as from a land-line (01/02/03).

Where businesses, government departments &c. — for their own convenience or any other reason — choose to use a non-geographic number, any additional cost ought to be borne by those organizations, not by the caller.

Very well said, Pericles   ;) :) :)

Ofcom --- please take note.

http://www.telegraph.co.uk/technology/mobile-phones/8207327/0800-numbers-should-be-free-to-call-from-mobiles-says-Ofcom.html

Ofcom are proposing that 0843/4/5 and 0871/2/3 numbers be termed "Business Rate".

They propose that calls to these numbers are composed of two elements ---
--- the basic call cost, ie. the normal geographic rate charged by a callers service provider, and
--- the added charge for the business service provided by the non-geo number

This seems to be an excellent idea provided the caller pays only for the first element and the "Business" or organisation pays for the Business element.

loddon wrote on Dec 21^st, 2010 at 9:50am:

Ofcom are proposing that 0843/4/5 and 0871/2/3 numbers be termed "Business Rate". They propose that calls to these numbers are composed of two elements --- --- the basic call cost, ie. the normal geographic rate charged by a callers service provider, and --- the added charge for the business service provided by the non-geo number This seems to be an excellent idea provided the caller pays only for the first element and the "Business" or organisation pays for the Business element.

This is not the Ofcom proposal - the two elements exist at present, with the caller paying both. Ofcom proposes that the charge for the business element which is paid by the caller is presented as such - it is the presentation of the two elements as separate which is the key of the Ofcom proposal. This proposal treats "Business Rate" calls in exactly the same way as "Premium Rate".

What this means in practice is that those who are unable to present their numbers as including a passed on charge will have to cease using "Business Rate" numbers. We must also remember that every business will always have to recover its costs somehow - if not from telephone callers, it will be from the shareholders or taxpayers who fund it, or perhaps its customers. There will be shareholders, taxpayers and customers who think that callers should carry some of the cost of dealing with the calls they make. All that Ofcom is doing is proposing that when this happens, it is transparent.

---

(Noting the quoted comment from the telegraph)
I believe that Ofcom has taken note of this point. The requirement to state the added charge means that it must be justifiable.

Another interesting comment posted by "jdavidj" on The telegraph site :---

"jdavidj

I believe the consumer should only start paying for a call-centre call once an operator has been connected. Any time spent queuing, and listening to inane messages about being recorded, unexpectedly high demand etc., should be paid for by the call centre.

I don't pay for the time sitting in a restaurant, only for the food I came to eat - and it costs no more for a slow service. It should be the same for a call centre"

This illustrates one of the fundamental flaws with the design of the NGCS numbers and which it appears the proposals from Ofcom will not rectify.

loddon wrote on Dec 22^nd, 2010 at 11:47am:

Another interesting comment posted by "jdavidj" on The telegraph site :--- "jdavidj I believe the consumer should only start paying for a call-centre call once an operator has been connected. Any time spent queuing, and listening to inane messages about being recorded, unexpectedly high demand etc., should be paid for by the call centre. I don't pay for the time sitting in a restaurant, only for the food I came to eat - and it costs no more for a slow service. It should be the same for a call centre" This illustrates one of the fundamental flaws with the design of the NGCS numbers and which it appears the proposals from Ofcom will not rectify.

Given the present design of the telephone network, the flaw is in allowing call centres to hold queues of people waiting to speak to someone. This is based on the principle of having a number (whether geo or no-geo - it makes no difference) that does not connect to a single line. A proposal to ban such facilities under the present design of the network could be put forward, but is unlikely to achieve widespread support as this facility is valued by many callers.

A wholly new method of charging for telephone calls, so that the receiving party pays for the call whilst the caller is on hold is an interesting suggestion. It would be interesting to hear what proposals may be presented for how this could work and what regulations could be introduced to compel such a mechanism (once developed) to be deployed. Would I have to pay for the call whilst I asked my caller to wait so that I could move over to speak on another extension?

If metering of calls were to be deferred until live conversation were taking place, this would make calls to recorded information and answering services free of charge. This and other solutions that did not place the charge on the receiving party would simply make connected calls more expensive.


A more sophisticated approach, which is perhaps aligned to the point being made, is for the "service charge" element of a "Business" or "Premium Rate" call not to kick in until the service is actually being delivered. Again, it would be interesting to hear suggestions about how this could be achieved in practice and how the telcos should recover the cost of the sizable amount of development in metering and billing that would be required.

My own view is that when making such a call one has to judge whether the benefit being delivered is worthwhile for the total cost. The likely duration of the call, including waiting time, is obviously a factor affecting both the quality of the service and the cost. The same is true for a restaurant, even though the waiting time does not actually affect the cost. As with any chargeable service, that can only be matter to be resolved between the service provider and the service user.


I firmly believe that if the idea of "Business Rate" calls, with an identified service charge as part of the call cost gets properly established, then we will be able to look on such calls in a proper light. This must mean that many who presently use 084 numbers will have to move away to "Geographic Rate" (01/02/03) numbers.

---

There is of course another possible remedy.

Call centres could be compelled to stop answering calls if there is no agent available to speak immediately, or perhaps within a certain defined time limit. Imposing such a requirement is outside the scope of Ofcom's present powers, so new legislation would be required - from a government that has a ban on new regulations.

My preference is to encourage busy call centres to deploy the automated callback technology which many already use at busy times.

The Daily Mail reported on the Which? report (Jan 2010 edition) here:--

http://www.dailymail.co.uk/news/article-1340277/The-worst-centres-waiting-cost-fortune.html#ixzz18qPSSMD0

This story has generated 275 readers comments so far and many of them make salutary reading.   I recommend Ofcom to read every one of them and seriously reconsider their proposals because the proposals will do nothing to deal with bulk of callers complaints, as described in these comments, about use of 084/7 numbers.

Some of the comments:---
".... I pay BT for free calls 24 hrs a day which covers all 'geographical codes' and I resent having to pay exorbitant fees on top. One thing that really annoys me is that our GPs are also on an 0844 number...this should not be legal.
- BB, Poole, UK, 21/12/2010 5:32"

I have often thought that some companies have you 'held in a queue' for at least 20 minutes before they even find out what you need so they can generate the revenue for the staff from your call.

One particular call I waited 20 minutes to be answered and asked the teenager who was at the other end of the phone if they were busy and he said 'no, I've been sitting here for the last half an hour waiting to deal with anyone' . When I asked to speak to a supervisor about this the tone of the call changed completely and I was mysteriously lost in the system and cut off - thereby having to call again and wait another 25 minutes to be told how busy they were! Yeah, right
- Miss Mouse, Bedford, 21/12/2010 2:37


HMRC could have been named and shamed too, having waited eleven minutes the other day. They keep repeating some message about looking on the internet for the information, that is why I am phoning them because the information I need is NOT on the internet.
- MaryH, Maidenhead, 21/12/2010 2:19
13 minutes and 49 seconds to speak to someone at BT? Pah! That's nothing, I once waited 35 minutes to speak to someone at BT. And I bet that wasn't even the longest wait. Customer service in this country is diabolical. I sometimes wish I could reach down the phone line and grab somebody.
- Peter, Proud Englishman. Ex Royal Artillery., Manchester., 21/12/2010 1:56


sky deliberately make you wait first they filter your call ,if its to purchase movies,sport etc you are connected within seconds,if its to cancel some or all of your sky package you are made to wait ages in the hope you will give up and call back later or perhaps just forget to.A very good business strategy. If you do cancel ,by the time you do get through they have made a few quid off you ,if you forget or just give up they have retained a customer, win win i think
- david, newton aycliffe co durham, 21/12/2010 5:24


I would have thought that the Tax credits line just so you can request an Apllication form'' is one of the WORST!.......I waited 37 mins at a high cost just to order my form......When it didn't arrive after neasrly 3 weeks I had to phone again (25 mins waiting) to see where it was and they then ordered a new one for me.......Surely you should be able to request an Application form by the internet or through a bmore ''cost effective'' method......Or is it designed to put people OFF applying for something they are entitled too.
The current government said they were goingto make the tax laws simpler.....The sooner the better!!!
- Theresa, Used to be a Nation, 21/12/2010


I worked for a Health Insurance company - very popular and well-known. We were under strict instructions to keep members on the phone while we sorted out their query. You were not allowed to come off the phones to sort anything out. E.g. a member rang as they had received an advice that £7000 had been paid out on their policy for an operation which they never had. You had to keep them there while you 'got the drains up' to investigate our error. It could take up to an hour, but woe betide you if you offered to just rectify things and let them go. Your supervisor would be on top of you like a ton of bricks. In the meantime, the member had to wait for his/her evening meal, AND pay for the call. It wasn't even their fault or problem. That kind of 'service' is nothing short of scandalous. And they are all at it.
- Petew, Manchester, 21/12/2010 6:00"

The point here is that mostly these 084/7 numbers are not used for providing a value-added service but are simply for normal customer to business communication which could easily be done with an 01/02/03 number.   If the companies feel they need 084/7 numbers then they should be required by Ofcom to pay for them, that is , to pay for the Business element of the charge, while the caller is allowed to pay just for the access charge at a normal rate.  

Ofcom should note that their proposals are NOT "Simplifying" the call charges but are making the whole regime much more complicated.   People I have spoken to about this have said immediately that they don't like this idea and would find it harder to understand and they don't have the time to waste in going into detail with every phone call they make and then trying to work out how they should react.

In my view this illustrates the point.   These proposals just will NOT work.   Fundamentally the Ofcom proposals are seeking to continue forcing callers to pay for services that benefit the companies rather than the callers, and it is far too complicated.

Could someone explain how the Ofcom proposals will simplify the current pricing complexity of non-geographic calls, because I cannot see in the Ofcom consultation document.   For example, if you want to find out the charge rate for any non-geo number from Virgin Media, you need to consult their pricing tables to be precise, here :---  http://allyours.virginmedia.com/pdf/uk_non-geographical_calls_a.pdf

This document is 24 pages long and contains lists of non-geo numbers with the "chargeband" alongside.   You then need to look up the chargeband somewhere to find out the cost.   As you can see there are thousands of numbers and hundreds of chargebands and I wonder if anyone using this site, apart from Dave and perhaps a few other geniuses, have ever actually done this?

To provide just a flavour of what these tables are like I have copied a very small extract from page 6 of Virgin Media's document and pasted it below.  However, I do urge you to use the link and look at this document for yourselves.

The key question is --- will Ofcom's proposals lead to elimination of this sort of nonsense?

CODE         CHARGEBAND

079118       FW2
07937         MB1
079567       MB1
07978         FW5
079785       FW1
079788       FW3
0800           FREE
0808           FREE
083408        PG6
0843000       PG6
0843001      PG24
0843002         FF29
0843003      PG11
0843004       PG20
0843005       PG6
0843006        PG6
0843007        PG8
0843008       PG8
0843009       PG9
0843010        PG10
0843011        PG11
0843012         PG6
0843016       PG9

0843101 PG9
0843102 PG10
0843103 PG11
0843104 PG6
0843105 PG6
0843106 PG8
0843107 PG9
0843108 PG10
0843109 PG11
0843110 PG27
0843111 PG8
0843112 PG28
0843113 PG9
0843114 PG10
0843115 PG11
0843116 PG6
08440010 I22
08440011 I23
08440012 I24
08440013 I25
08440014 I26
08440030 I3
08440031 I4
08440032 I5
08440033 I8

loddon wrote on Dec 27^th, 2010 at 7:10pm:

Could someone explain how the Ofcom proposals will simplify the current pricing complexity of non-geographic calls, because I cannot see in the Ofcom consultation document.   For example, if you want to find out the charge rate for any non-geo number from Virgin Media, you need to consult their pricing tables to be precise, here :---  http://allyours.virginmedia.com/pdf/uk_non-geographical_calls_a.pdf

Ofcom's proposal is the unbundling of charges imposed by telephone companies (those which originate calls) and Service Providers (the recipients of calls). At the present time, a single charge is published for calling any given number from any given originating provider.

Service Providers will then be able to give accurate pricing information: "Calls cost 5 pence per minute plus your telephone provider's network charge".

Loddon's post on Virgin's opacity makes salutary reading. Do I understand correctly that the charge for a call to a non-geo number actually includes three elements, not two as Ofcom states?
1. The cost of delivering the call, which should normally be the same as the cost of delivering a call to an honest 01 or 02 number.
2. The revenue passed on to the recipient.
3. A markup or handling fee collected by the telecom provider.
I can't see any reference to 3 in the consultation.

nicholas43 wrote on Dec 29^th, 2010 at 8:40pm:

Loddon's post on Virgin's opacity makes salutary reading. Do I understand correctly that the charge for a call to a non-geo number actually includes three elements, not two as Ofcom states? 1. The cost of delivering the call, which should normally be the same as the cost of delivering a call to an honest 01 or 02 number. 2. The revenue passed on to the recipient. 3. A markup or handling fee collected by the telecom provider. I can't see any reference to 3 in the consultation.

The cost of any call is set by the telephone provider that the caller subscribes to (that is, the originating provider). In order for the call to be connected, the originating provider must pay the receiver's telephone company (the terminating provider) a fee known as a termination charge.

The call charge therefore made up of the termination charge plus whatever mark-up the originating provider wishes apply. In an ideal world, the mark-up on a 084 call would be the same as on 01/02/03 calls and thus, the premium or subsidy to the called party would be transparent.

nicholas43 wrote on Dec 29^th, 2010 at 8:40pm:

Loddon's post on Virgin's opacity makes salutary reading. Do I understand correctly that the charge for a call to a non-geo number actually includes three elements, not two as Ofcom states? 1. The cost of delivering the call, which should normally be the same as the cost of delivering a call to an honest 01 or 02 number. 2. The revenue passed on to the recipient. 3. A markup or handling fee collected by the telecom provider. I can't see any reference to 3 in the consultation.

If one is to get clever one could break out many other elements and also add other items such as the call connection charge and the line rental that one pays. The Ofcom proposal is that rather than there being a single rate per minute quoted by each originating telephone company for each type of number, there be two constant elements:

- an "Access charge"; set by the originating telephone company to apply to the selected tariff - this would be the same for all "Business Rate" and all "Premium Rate" calls, or perhaps one for each.
- a "Service charge"; which would be the same for each number, regardless of which telephone company originated the call, or under which tariff.

The "Access charge" need not be the same as the charge for calling a "Geographic Rate" (01/02/03) number.

It is not yet clear about how complex the structure of Service charges is to be. I suspect that it would have to reflect the status quo - subject only to some simplification covering rarely used types. I also believe that the system - i.e. the number blocks and the associated service charge rates would have to be published somewhere for reference, if not repeated by every telephone company. The obligation on "Service Providers" to advise of the "Service charge" would only apply to material that they published; this could not provide a valid source of reference for a billing dispute, as it is the telco that would actually levy the charge.

Dave wrote on Dec 29^th, 2010 at 9:16pm:

In an ideal world, the mark-up on a 084 call would be the same as on 01/02/03 calls and thus, the premium or subsidy to the called party would be transparent.

Perhaps "very simple" would be better than "ideal". Those who benefit from inclusive packages covering "Geographic Rate" calls are perhaps pleased that telephone charges are not as simple as some may wish them to be.

Many thanks, Dave and SCV. Could you provide a worked example? If I can't find an an honest alternative, and have to call a 5p/min 0844 number for say 5 minutes, then have I got the following right?
1. If I'm with BT, I pay BT 10p (or so) set-up plus 25p, total 35p. Of that, 6p goes in VAT. BT keeps (maybe?) 15p, and passes 14p to the operator of the 0844 number, who passes (maybe) 10p to the company I'm calling.
2. If I'm with Virgin, I pay Virgin heaven known what, say 60p. Of that, 10p goes in VAT. Virgin keeps 36p, and passes 14p to the operator of the 0844 number, who passes 10p to the company I'm calling.
If that's anything like right, then how would it change under Ofcom's proposal?

Trying to picture what's going off by simply considering how one's call charges are split between the parties leads to much misunderstanding. In the days when there was a single telecommunications network operator (BT or GPO) then that may well have been helpful.

Today's telecommunications system works by operators (communications providers or CPs) interconnecting with one another. A CP functions as an OCP (originating CP) or TCP (terminating CP), depending on whether its customer is the caller or receiver, respectively.

OCPs act in the interests of their customers (the callers) and TCPs act in the interest of their customers (the receivers).

OCPs charge the customers (callers) a retail price for calls and then pay OCPs the termination charge. Retail price is therefore set by with OCPs knowing that their outgoing is the termination charge.

TCPs receive a higher termination payment for 084 numbers than 01/02/03 ones, and what service(s) this goes on is up to the call recipient (the user of the number). Where the recipient is paid revenue directly, this is merely cash-back for that service(s).

Thus, revenue payments are just an effect and turning them down has no effect on the subsidy taken from one's callers. Indeed, anyone who operates a 084 number and declines any offer of such revenue is permitting its provider to keep it. That would be like being offered a discount on a particular product or service and then turning it down.

It is therefore the selection of a particular 08 number by the user that is the deciding factor in the benefit or subsidy that it derives from callers.

Thus, OCPs don't voluntarily (for want of a better word) share some of the call charges with the company being called (either directly or indirectly). If a single OCP doesn't wish to pay, then its customer won't be able to call the respective 08 numbers.


BT call charges for 084x (and 0871/2 and 09) numbers are regulated such that its retail prices are near enough equal to the amount it must hand over to TCPs. That is, it can only put a tiny mark-up on these calls and part of Ofcom's proposal is the removal of this regulation.

I looked at the Ofcom consultation paper and was faced with a 479 page tome of largely irrelevant waffle to plough through.

I tried to respond. All I wanted to say was that people should not be charged more for ringing these numbers, and if there is a charge for HAVING a non-geographical number it should be borne by the recipient.

But in order to respond at all, there is a list of questions resembling an examination paper based on this 479 page tome which you are expected to complete. It is full of acronyms and latin phrases like 'ex ante' and invitations to write essays on whether you think their market assessment is correct etc. Eventually I gave up. I have written to my MP about it instead.

Unfortunately I get the strong feeling that it is Ofcom's intention to sit on the fence for as long as possible and then do nothing. I see no reason whatsoever why these charges cannot be abolished overnight. It is a moral question - can charging callers extra money without telling them how much in return for nothing be justified- not one of market forces. It is not as if there are not other ways in which services such as premium rate calls can be paid for - typically with a credit or debit card.

Excoriator wrote on Dec 30^th, 2010 at 10:50am:

I see no reason whatsoever why these charges cannot be abolished overnight. It is a moral question - can charging callers extra money without telling them how much in return for nothing be justified- not one of market forces. It is not as if there are not other ways in which services such as premium rate calls can be paid for - typically with a credit or debit card.

A man after my own heart, Excoriator.   I agree with your comments about this paper as well as the basic principle that charging callers for using 0843/4/5 and 0870/1/2 is basically a scam.   Callers are not the customers of the phone companies, the organisations using 08 are, and it is those organisations who should pay for the special facilities and services provided by the 08 number services (NGC services as Ofcom call them).

Excoriator wrote on Dec 30^th, 2010 at 10:50am:

All I wanted to say was that people should not be charged more for ringing these numbers, and if there is a charge for HAVING a non-geographical number it should be borne by the recipient.

This is the key point.   Ofcom have not addressed this in their massive self-delusional report.

loddon wrote on Dec 30^th, 2010 at 11:11am:

Excoriator wrote on Dec 30th, 2010 at 10:50am: I see no reason whatsoever why these charges cannot be abolished overnight. It is a moral question - can charging callers extra money without telling them how much in return for nothing be justified- not one of market forces. It is not as if there are not other ways in which services such as premium rate calls can be paid for - typically with a credit or debit card. A man after my own heart, Excoriator.   I agree with your comments about this paper as well as the basic principle that charging callers for using 0843/4/5 and 0870/1/2 is basically a scam.   Callers are not the customers of the phone companies, the organisations using 08 are, and it is those organisations who should pay for the special facilities and services provided by the 08 number services (NGC services as Ofcom call them).

It has long been established that Premium Rate Services can be provided, e.g. on 090, 118 and 070 numbers, given that the cost of calling is advised. This principle is embedded in the Communications Act 2003. It is however fair to argue that this facility should be withdrawn and that any necessary change to legislation be introduced by a government that stands firmly opposed to extending regulation of commercial activity.

Ofcom now believes that the way in which the cost is advised must be simplified and that this revised approach be extended to cover 084 and 087 numbers, under the title "Business Rate" and with a cap on the level of the "Service Charge".

The key proposal is that the "Service Charge" and "Access Charge" elements be unbundled. The former is to be advised by the service provider, remaining constant for each number regardless of how one calls. The latter is to be advised by the telephone company, to apply to all Business / Premium Rate numbers called under the terms of the relevant telephone service contract. Presently, the aggregated BT charge is all that can be reliably advised by service providers.

Ofcom has to secure the agreement and compliance of all stakeholders as it seeks to further the interests of consumers of telecoms services, including users of Premium and Business Rate numbers, and has to ensure and demonstrate that it is acting within the bounds of its limited regulatory powers. This is why the arguments have to be made at length. I concur with the view that the document is poorly presented, however I am more concerned with the outcome, than the fact that Ofcom falls well short of what we may wish to be.

There is no reason why responses that totally reject the underlying principles of the proposals could not be submitted. I sense however that the views being expressed go much deeper, addressing the whole nature of Ofcom's role and the legislation under which it operates.


For myself, I disagree with the views quoted above. I believe that it is perfectly proper for a caller to pay for services delivered by telephone through their telephone bill, if they are properly advised of the cost. Whether the caller is prepared to pay the price in return for whatever service is delivered is a matter between them and the person called. (I do not believe that this is necessarily related to the benefits of any particular technology, nor that any third party could make the necessary determination about what is a fair price for a particular service.)

I see Ofcom as seeking to improve the situation with "Premium Rate" numbers and to create such a situation where it has not previously existed, with "Business Rate" numbers. I wish to do all I can to see that this comes about effectively and properly. The published proposals are the only ones under consideration at present; I see a serious prospect of them delivering some good effect and am keen to make this as strong as possible. I accept that some wish to reject them out of hand.


It is for those who believe it is improper to use the revenue sharing mechanism as a means of causing those who use a service to contribute towards, or pay in full for, the cost of providing it to argue their case. I have always seen the issue as being about transparency of pricing, rather than the fundamental principle of charging for services through the telephone bill. I firmly believe that if the additional cost of calling certain numbers were made clear, then in cases where a charge was improper or could not be justified it would have to be withdrawn. I believe that if the Ofcom proposals were enacted then public services and most customer service lines would have to migrate to Geographic Rate numbers, so that the cost of these services would have to be met by taxpayers and customers in general.

I accept that there are issues with achieving transparency, however I believe that these are worth addressing and that the Ofcom proposals provide a sound basis for discussion of how this may be achieved. It may be helpful to our discussion if we could distinguish between those who argue that price transparency could not remedy the situation with NGCS and those who wish to discuss the Ofcom proposals.

nicholas43 wrote on Dec 29^th, 2010 at 10:31pm:

Many thanks, Dave and SCV. Could you provide a worked example? If I can't find an an honest alternative, and have to call a 5p/min 0844 number for say 5 minutes, then have I got the following right? 1. If I'm with BT, I pay BT 10p (or so) set-up plus 25p, total 35p. Of that, 6p goes in VAT. BT keeps (maybe?) 15p, and passes 14p to the operator of the 0844 number, who passes (maybe) 10p to the company I'm calling. 2. If I'm with Virgin, I pay Virgin heaven known what, say 60p. Of that, 10p goes in VAT. Virgin keeps 36p, and passes 14p to the operator of the 0844 number, who passes 10p to the company I'm calling. If that's anything like right, then how would it change under Ofcom's proposal?

The figures used are (admittedly) rough, however they serve to illustrate the point, so I will stick with them. Under the proposed changes:

• The Business Rate user in question will advise that there is a Service Charge of 5p per minute to call their number, in addition to the access charge levied by the caller's operator.
  
  
• If Virgin Media were to set an Access Charge of 10p + 5p per minute for Business Rate numbers, the relevant call would still cost 60p.
  
  
• It is possible that BT would retain an Access Charge of 10p + 1p per minute, however the latter (which is actually much smaller) is currently set at a minimal level by regulation, which would be lifted.

Whilst the cost of a call to a geographic number does not have to be used as the Access Charge, the present (non-inclusive) charges for daytime calls to geographic numbers may offer some indication of the level at which Access Charges will be set. For BT this is currently 10.5p + 6.5p per minute, for Virginmedia 12p + 8.5p per minute. Because both companies promote inclusive packages to cover calls to geographic numbers these should be thought of as "penalty charges" for calling outside the terms of the call plan / package in place, so one would expect the Access Charges for NGCS to be a little lower.

The key point is that BT alone is currently prohibited from adding an Access Charge (other than minimal cost recovery) to the Service Charge for calling NGCS numbers - the call setup fee escapes this regulation. BT is not regulated in its charges for calling Geographic Rate numbers. Other operators cannot currently be subject to any price regulation. - proposed new legislation in implementation of an EU Directive will enable this to be introduced, so that they will have to respect the Service Charge levels in addition to their advised Access Charge.

One hopes that the telcos will offer some indication of the levels at which they are likely to set their Access Charges as they respond to this consultation. All that Ofcom can do is demand that they publish and apply them - it cannot set the level, nor would it be wise to publish any forecast of what they are likely to be. The assumption is that the Service Charges would be set to broadly keep the revenue share at current levels, i.e. around the BT pence per minute rate.

(N.B. All charges will be adjusted from 4 January 2011, only some of the new rates have been published.)

Many thanks, SCV, for the only understandable explanation I've seen anywhere.

In principle, I think micropayments via telephone bills are a bad idea, because it is totally opaque who is paying whom how much to do what. Moreover, the user has no clear contract with the service provider, and no clear means of redress when the service screws up.

I take the point that, for example, conference calling via an 0844 number is a useful service. However, I think it would be better if access was via a geographic number, and users had to have an account with the service provider which they settled by other means. I even think that dupes who want to waste their money voting for X-factor etc should call a geographic number, and be transparently billed by the TV company. The same goes, as another example, for enquiries about visa applications, which often seem to be on an extremely expensive 09 number.

In practice (unless someone here knows better), Ofcom doesn't have the power to ban micropayments. So, in my opinion, constructive responses need to be focussed on making the regime as transparent as possible. I like the idea of forcing originating providers to state clearly the huge charge they make for calls to NGNs, compared to the marginal price of zero they all offer for calls to geographic numbers. I'm still muddled about forcing service providers to state the termination price, because it leaves opaque the split between the service provider and the provider of the NGN.

Suppose everyone calling (for example) an 0845 number is told, every time, something on the lines "We [BT] charge you 11p plus 2p a minute to call this number, and the outfit you are calling charges 5p a minute on top of that [which they have to share with the provider of the 0845 number?]". Consumer rage might lead more banks etc to use geographic numbers.

Does Ofcom envisage that the originating and terminating providers' charges must be explicitly itemised on bills? Can't see this mentioned in the consultation documents, but life is too short to read all of the documents!

nicholas43 wrote on Dec 31^st, 2010 at 2:22pm:

... In principle, I think micropayments via telephone bills are a bad idea, because it is totally opaque who is paying whom how much to do what. ... in my opinion, constructive responses need to be focussed on making the regime as transparent as possible. ... Consumer rage might lead more banks etc to use geographic numbers. ... Does Ofcom envisage that the originating and terminating providers' charges must be explicitly itemised on bills? Can't see this mentioned in the consultation documents, but life is too short to read all of the documents!

There are many who share the view that micropayments through telephone bills should be abolished. If opacity is the strongest argument against them, then introduction of a transparent regime would weaken, if not totally undermine, this position.

Each telephone company offers access to many different Business and Premium Rate services, and each service may be accessed from many different telephone tariffs.
For this reason, Ofcom proposes unbundling the respective elements of the charge and does indeed propose that they be shown separately on telephone bills.

As I see it there needs to be three points of publicity for the new charges:

• The "Access Charge (or charges)" must be prominently declared in all telephone tariffs. This is simply achieved by existing Ofcom regulations covering telcos.
  
  
• A table showing the level of "Service Charge" associated with each number range needs to be published. There will be only one such table, so there is no need for every telco to reproduce identical information, even though it forms part of their charging structure and will have to be loaded into their billing engines. This table is presently maintained by BT, because of its special regulatory position, however this would have to be passed over to Ofcom, as it would form the basis of a regulation of billing. It would be most helpful if Ofcom could publish this in an accessible form, perhaps with a nice on-line lookup feature.
  
  
• The key point is that service providers would have to show the "Service Charge" applicable to their numbers when those numbers were published. For PRS providers this is essentially required by existing regulation, although the terms would have to be modified to reflect the fact that a clear charge could be advised, as given in the Ofcom example.
  
  087 users are already covered by this requirement, even though these ranges are to be re-designated as part of Business Rate.
  
  There is an open question about whether and how 084 users are to be compelled to advise their Service Charge. For this to be made a regulatory requirement, enforced by Ofcom, the only mechanism currently available is to classify them as "PRS" and for the enforcement to be undertaken by PhonePay Plus. This is far from ideal, especially as the re-designation of 087 as Business, rather than Premium, Rate shows that Ofcom accepts that there is a considerable difference between users of 087, as against 090, numbers.
  
  I believe that the important point is to get the practice of Business Rate users advising their Service Charge established and accepted as the norm. Whilst tight regulation and vigorous enforcement is attractive, if the resources necessary to carry this out are not available then there is little point. I would not be unhappy if the necessary effect is achieved through a clear statement from Ofcom, acknowledged and applied by Trading Standards, the ASA and other relevant bodies, also endorsed and imposed as a requirement by the Cabinet Office to cover all of the public sector.
  
  I know that many will wish for Ofcom to make the requirement mandatory, but Ofcom's powers and resources are not necessarily equal to the task in practice. In my own dealings with users of Business Rate numbers I am happy to imply, infer and hint that Ofcom has already designated 084 numbers as "Business Rate" and will shortly be making declaration of the "Service Charge" mandatory. History shows that many will comply with "Ofcom regulations" when in fact there are no such regulations actually in force - there is often a lot of bluff involved (I am happy to discuss examples privately). One reason for the size of Ofcom's published documents is the need for the truth about the limits of its powers to be obscured.

I see the fear of potential consumer rage as being the most powerful weapon in getting Business Rate number users to cease the practice where it is inappropriate. I would suggest a message along the following lines to be sent to every inappropriate user of 084 numbers, now:


Quote:

Will you be happy to advise that you impose a Service Charge on calls to your 084 number, when compelled to do so? If not, adopt geographic or 03 numbers now, in your own time, whilst you can claim credit for taking the initiative, before you are embarrassed into changing by a regulatory deadline.

I will put in a response to this consultation listing all the numerous previous occasions when OfCoN promised action and then did nothing including most notoriously over 070 PNS numbers where they specifically committed to changing them to 06 numbers to stop the scammers making people think they were mobile numbers only to change their mind when the most important scammers no doubt leaned on a couple of good friends on the OfCoN board about all that lovely lolly they were about to lose.

However I will not expect any significant changes to be made as a result of this consultation that will stop any of the scams or make it more obvious what you are being charged to make a call.

I'm sure that FLEXTEL and their similarly slime like commercial allies are limbering up even now to run their previous arguments that it is far too difficult to reprogram burglar alarms and personal medical emergency buttons to these new simplified number ranges and/or that call price announcements for non standard priced numbers cannot be allowed because it will affect their automated dialling equipment.

So hence the current morally bankrupt status quo will remain in place after we have all worn ourselves our responding to yet another sham of an OfCoN consultation.  The only possible circumstance in which this will not take place and actual change will occur is if this consultation has actually become about due to pressure on OfCoN to hold it in the first place by ministers with the current coalition government.

NGMsGhost wrote on Jan 8^th, 2011 at 9:29pm:

... the numerous previous occasions when OfCoN promised action and then did nothing ...

One hopes that these comments may be balanced by reference to generally positive, if incomplete and inadequate, actions such as the removal of revenue sharing from 0870 and the introduction of 03xx.


NGMsGhost wrote on Jan 8^th, 2011 at 9:29pm:

I will not expect any significant changes to be made as a result of this consultation that stop any of the scams or make it more obvious what you are being charged to make a call.

There will undoubtedly be confusion about the degree of clarity which is required in statements about call charges, given the limits of Ofcom's statutory powers of regulation. I will personally be keen to hype up the effect of Ofcom's powers in the hope of achieving greater clarity; I recognise that others will be reassuring users of Business Rate numbers that they will not be under any absolute compulsion to be any clearer, and that their scams can continue.


NGMsGhost wrote on Jan 8^th, 2011 at 9:29pm:

... call price announcements for non standard priced numbers cannot be allowed because it will affect their automated dialling equipment.

My reading of the consultation document suggests that this point is already well taken and that there are no specific proposals regarding provision of call price announcements. The proposals clearly focus on the duty of the Service Provider to advise of their Service Charge, and this is extended from "Premium Rate" to "Business Rate" numbers.


NGMsGhost wrote on Jan 8^th, 2011 at 9:29pm:

... pressure on OfCoN to hold it in the first place by ministers with the current coalition government.

The process of which this consultation is but one stage was well in place before the General Election. Having closely observed the relationship between the responsible Minister, Ed Vaizey, and Ofcom I think it quite likely that he is unaware that the consultation is even happening. He has not commented on it and I would doubthis ability to understand even the very basic principles of what is involved. It is very clear that the coalition government is firmly opposed to any increase in regulation or the power of regulators (notwithstanding Politically-motivated dealings with reference to Banks). The increased powers that will be granted to Ofcom in the Spring arise solely from an obligation to implement an EU Directive.


It would be foolish to expect that a few changes by a "light touch" regulator, in a political environment that is fundamentally hostile to regulation, will stop scams and deception. The limits of Ofcom's powers, not to mention the related weakness of its approach to every issue, cause serious doubts to be properly raised over the likely effectiveness of what is proposed. I firmly believe that intense and positive efforts by campaigners will be required to bring about successful achievement of the worthwhile proposals that are in the consultation document. Even at this stage there is valuable support for putting additional pressure on users of "Business Rate" numbers to cease the practice.

The past is littered with failures and disappointments and there will undoubtedly be many more in the future. I approach this consultation by looking to see what may be achieved from it and the actions that may follow in subsequent stages of the process. I do not expect 100% success, however I am keen to achieve as much as is possible. I regret the fact that strong and capable potential allies perhaps take a different view.

SilentCallsVictim wrote on Jan 8^th, 2011 at 11:43pm:

NGMsGhost wrote on Jan 8th, 2011 at 9:29pm: ... the numerous previous occasions when OfCoN promised action and then did nothing ... One hopes that these comments may be balanced by reference to generally positive, if incomplete and inadequate, actions such as the removal of revenue sharing from 0870 and the introduction of 03xx.

I have to agree with NGMGhost here.  We have had so many consultations and yet nothing really happened despite some overwhelming support to end the idea of hidden revenue sharing numbers but Ofcom took the easy way out, after many, many consultations, with 0870 and this took years to happen despite their previous consultations and responses.

There were things like they would look into doing the same with 0845 as they did with 0870 but I firmly believe that nothing will happen over 0845 like it did with 0870.

In a previous consultation, Ofcom said it would force teleco's to stop claiming these numbers were either local or national rate and insist on prices being made more public on these numbers.  Despite many emails from me informing them of teleco's that ignored this new General Condition, or if they did comply then the prices were hidden in hard to find places of websites, etc and not on same page as price of geographical calls, they basically did nothing for absolutely ages and then just told them off.  Last I looked, I don't believe that many teleco's actually fully comply with GC14.2.

Even when I mentioned to Ofcom that GC14.2 may bring awareness to the cost of these calls, it doesn't stop the teleco's that provide NGN numbers from still claiming NGN's are either local/national rate, I got no real helpful response from Ofcom.

I have yet to see Ofcom take the side of consumers and what they want rather than what their stakeholder's want.  I realise that they are sometimes bound by rules and regulations but in my personal opinion I believe Ofcom have not shown that they actually want what is best for consumers rather than what their cosy little stakeholder's want.

This is just my opinion  ;D

bbb_uk,

I am encouraged to see that you and I are of a like mind on these matters even if I do not seem to have been on the same wavelength of late as Dave.

It grieves me a a former local district councillor to say that people should not expect anything to change from responding to a consultation since consultations on some matters by local councils etc are often genuine and the views expressed do lead to real changes in the original proposals or even sometimes to a proposed change being scrapped.

However it is hard to have much faith in the main regulator OfCoN or even worse that devil's spawn offspring it created first called ICSTIS and now PhonePayPlus who ran a consultation on its proposals for 0871 numbers that was resoundingly rebuffed by nearly all of the several hundred members of the public who responded as being a quite useless proposed control regime that would not stop any of the scams or abuses only for the original proposals to be implemented completely unchanged.

OfCoN will only change its ways if it is under genuine political pressure to reform the NGN system.  So the real question is why did they bother launching this consultation now because on the face of it surely someone somewhere is badly upset about the total bankruptcy and illogicality of the current state of its National Telephone Number Plan (NTNP) for it to have bothered coming up with this consultation.

bbb_uk wrote on Jan 9^th, 2011 at 7:25pm:

SilentCallsVictim wrote on Jan 8th, 2011 at 11:43pm: NGMsGhost wrote on Jan 8th, 2011 at 9:29pm: ... the numerous previous occasions when OfCoN promised action and then did nothing ... One hopes that these comments may be balanced by reference to generally positive, if incomplete and inadequate, actions such as the removal of revenue sharing from 0870 and the introduction of 03xx. I have to agree with NGMGhost here.

I am not sure that there is really two sides to an argument here.

Ofcom is disgracefully ineffective in much that it tries to do and there is much that it tries to do with which we all disagree. The point for me is about whether there is anything in the consultation that may help to improve the situation and ways in which such good effect can be maximised either by Ofcom itself or by campaigners seeking to influence decision makers to stop using Business Rate numbers when this is not appropriate.

It is fair enough for one to conclude that there is nothing in the consultation, or that may emerge, which is, or will be, of value. I would have thought that such a conclusion would have to be based on what is proposed, rather than purely on the basis of Ofcom having failed to intervene in the past. Ofcom is not by nature a highly interventionist body, it seeks to lay out a regulatory position on the assumption that there will generally be compliance.

Ofcom is itself influential. Its utterances are taken seriously by those who would wish to be seen to be complying - that is why I am so furious about its continuing explicit approval of the practice of making Silent Calls. I personally see the proposed new structure for NGCS charging as a major step in the right direction - the mechanisms of adoption and enforcement are an important and complex issue; they are separate from the proposals in concept.

There are points on which I do perhaps agree totally. If we sit back and leave Ofcom to get on with it, then very little will happen. If we expect all of our wishes and desires to be met if we get involved, we will end up being very disappointed.

If Ofcom really does pamper to the whims of private companies which it is supposed to be regulating, then this would appear not to be confined to telecommunications. Radio stations have had the terms of their licences relaxed so as to allow them to network programmes across their stations. At one time this would have been unthinkable and all stations would have had to produce their output from within the area they serve.

Dave wrote on Jan 9^th, 2011 at 8:15pm:

If Ofcom really does pamper to the whims of private companies which it is supposed to be regulating, then this would appear not to be confined to telecommunications. Radio stations have had the terms of their licences relaxed so as to allow them to network programmes across their stations. At one time this would have been unthinkable and all stations would have had to produce their output from within the area they serve.

And when I have seen some of those radio licence consultations by Ofcom I have responded briefly with something to the effect of:-

"Inevitably Ofcom will rubber stamp this as they have done all the previous ones as they only seem to care about the commercial welfare of the broadcasters and not the public still having a diverse choice of stations to listen to".

I believe that Ofcom is also currently proposing massively longer commercial breaks on tv as yet another example of pandering to whatever the telecoms and broadcasting industry wants (unless of course abuse of porn broadcasting regulations is involved when they mysteriously suddenly find a Mary Whitehouse or should that be a Harriet Harman like need to crack down very hard with huge fines never seen for any normal NGN telecoms scammers).

And as to SCV's bee in his bonnet about silent calls (which I admit are something of a nuisance but not as much as being ripped off to call companies that you are a customer of or otherwise in a relationship with, especially as Silent Calls normally only seem to happen between 9 and 5 and not overnight when they would be a real nuisance) why exactly does he expect Ofcom to behave any better in regulating his favourite pet area by not siding with commercial interests there (as he naively seems to expect for Silent Calls while not expecting Ofcom to ignore vested commercial interest elsewhere) whilst frequently telling us that business is dirty and we can't expect things to go on and services still to be provided that don't still make a thumping profit for the businesses concerned in almost all the rest of his analysis in the forum (of which there is far, far too much for just one person).

Perhaps we need another thread in which to discuss the Politics of regulation, or the way in which members contribute to the forum. Alternatively, perhaps nobody is interested in discussing proposals for how calls to non-geographic numbers should be billed and the costs presented, so we may as well carry on the discussion that has developed here.

The problem with Ofcom's powers in relation to Silent Calls is that they are not designed for light-touch general regulation, which is Ofcom's style in operation. Ofcom simply refuses to properly discharge its statutory duties in this area, as the first stage of its use of the powers is an intervention in a specific case, with the imposition of specific enforceable regulatory requirements as the second stage. Ofcom prefers to pretend to hold general regulatory powers that it does not possess. It is for this reason that, in the context of the "bonfire of the Quangos", I have proposed that administration of the relevant powers be handled by a different body. I do not expect Ofcom to change its nature.

Following representations from myself, it was the relevant government minister who, on behalf of all members of a parliamentary committee conferred an expectation on Ofcom "We expect you to use your powers to eradicate the nuisance of Silent Calls" - I frequently quote this expectation, and echo it; that is the only basis on which I hold such an expectation.

As for business being "dirty", I would more commonly be expected to refer to it being amoral. Most businesses would wish to be seen to be clean, which is how positions adopted by Ofcom can be valuable in setting a standard to which many will respond. There will however always be a fringe of downright dirty players who will only occasionally attract the attentions of regulators.

I hope that moderators will edit contributions to the forum based on the content, rather than the authorship.

---

I had understood the approach of the coalition government to matters of regulation to be extremely "liberal". (I use this word with a small "l" to refer to the orange wing of the LibDems and the drier wing of the Conservatives.) This suggests that there would be no enthusiasm for addressing anything with the word "Plan" in its title, such as the NTNP, other than to abolish it. I see the fact that Ofcom survived the quango reorganisation with its regulatory role in relation to telecoms intact as being down to the wet Maude at the Cabinet Office and the yellow Cable at BIS, in addition to it having not ever having been seen to give industry a particularly hard time.

It is important to note that Ofcom is accountable to parliament, not to the Government. Under the previous administration an unduly close relationship developed, seen not least by the appointment of a past Chief Executive as a "goat" - an ennobled minister in the relevant department. There is every indication that this close relationship is being continued with the current government. I see this as improper and dangerous. The former because it undermines proper accountability; the latter because the government may find itself with an unreliable friend who can assert its independence whenever doing so may suit its purposes.

If anyone has a clear insight on relevant matters of government policy it would be interesting to hear this explained.

Quote:

This suggests that there would be no enthusiasm for addressing anything with the word "Plan" in its title, such as the NTNP, other than to abolish it.

Ofcom has a legal obligation to produce and publish a National Telephone Numbering Plan. The current document does, however, appear to be littered with a fairly large number of errors and inaccuracies.

catj wrote on Jan 21^st, 2011 at 11:30pm:

Ofcom has a legal obligation to produce and publish a National Telephone Numbering Plan. The current document does, however, appear to be littered with a fairly large number of errors and inaccuracies.

The quoted comment was in response to the development of the Political aspects of the topic in a previous posting. It remains to be seen whether, with the drier Jeremy Hunt now wholly responsible for Ofcom, we should await removal of this obligation from Ofcom as the government policy of abolishing regulation and removing red tape is pursued. Perhaps consortia of telcos would be in a better position to know what their customers want!

Because Telcos currently have an absolute duty to comply with the terms of the plan as published, I will refer to "misleading and irrelevant references" in agreeing with the point made.

The options outlined in Section 6 of the consultation document imply proposals which will be implemented partly through revisions to the NTNP. As there are no concrete proposals at this stage, there are no specific proposed revisions to the terms of the NTNP.

Perhaps others would share my view that the questions at the end of section 6 (pdf page 106) read more like an examination paper than a serious attempt to engage stakeholders.

SilentCallsVictim wrote on Jan 22^nd, 2011 at 12:36am:

Perhaps others would share my view that the questions at the end of section 6 (pdf page 106) read more like an examination paper than a serious attempt to engage stakeholders.

Ofcom's consultation questions never serve any useful purpose for the consultation Respondent and are usually only there to try and extract the answers that Ofcom wants to hear in order to justify the course of action proposed in their consultation.  I therefore usually ignore their questions entirely and respond only in a freehand email to those points in the consultation that I consider worthy of comment.

NGMsGhost wrote on Jan 22^nd, 2011 at 1:58am:

Ofcom's consultation questions never serve any useful purpose for the consultation Respondent and are usually only there to try and extract the answers that Ofcom wants to hear in order to justify the course of action proposed in their consultation.  I therefore usually ignore their questions entirely and respond only in a freehand email to those points in the consultation that I consider worthy of comment.

On this occasion it is precisely that type of response which is invited, from those who simply do not wish to signify approval of what is stated. The problem arises because the terms of valid responses are specifically restricted to comments on very lengthy dissertations on particular issues.

The major problem from my perspective is that the focus is on a perceived failure in the market for telecommunications services. Misuse of Business Rate numbers by public bodies is a matter relevant to Ofcom's primary principal duty, to further the interests of citizens in relation to communications matters. That duty demands nothing more than the truth about 084 numbers being clearly exposed and understood - it has nothing to do with Ofcom's separate secondary principal duty to regulate markets in the interests of consumers and encourage competition.

NHS Direct, HMRC and DWP Agencies are not providers in the market for telecommunications services, nor, in my opinion, should they be classified as such, so as to join providers of "adult" chat services within the self-regulatory scope of PhonePay Plus. It may be that the government wishes for these public services delivered by telephone to be open to competition, as Boots is now competing with NHS Direct on the internet through its branding of WebMD, however Ofcom is unduly extending its role if it believes that it has a duty to promote such competition.

SilentCallsVictim wrote on Jan 22^nd, 2011 at 12:36am:

... with the drier Jeremy Hunt now wholly responsible for Ofcom ...

(WARNING: This posting is strictly for fellow anoraks amongst us.)

If anyone doubted the authority for the quoted statement, I have now found the official announcement -

Transfer of responsibilities from BIS to DCMS


Departmental responsibility for the telecoms aspects of Ofcom's work has been transferred from BIS to DCMS, where that for broadcasting has always resided. (N.B. The "O" in "DCMS" is invisible, like the "D" in "BIS". The former avoids a change in 2012, the latter is a hang over from a reluctance to have the previous BERR look like "database error".)

As a NDPB (quango), Ofcom is accountable to parliament - not to the government. Previously this accountability has been primarily exercised by both the BIS and CMS Commons Select Committees. I await news of the corresponding change in the functions of these committees. Although this would be convenient, it is not strictly essential.

SilentCallsVictim wrote on Jan 26^th, 2011 at 3:07am:

SilentCallsVictim wrote on Jan 22nd, 2011 at 12:36am: ... with the drier Jeremy Hunt now wholly responsible for Ofcom ... (WARNING: This posting is strictly for fellow anoraks amongst us.) If anyone doubted the authority for the quoted statement, I have now found the official announcement - Transfer of responsibilities from BIS to DCMS Departmental responsibility for the telecoms aspects of Ofcom's work has been transferred from BIS to DCMS, where that for broadcasting has always resided. …

Perhaps this should have a thread of its own.

Dave wrote on Jan 26^th, 2011 at 10:42am:

Perhaps this should have a thread of its own.

This thread moved onto addressing Politics some postings back - they have been left in place.

I wonder if anyone has managed to plough their way through the document yet - so as to be able to offer comment on the consultation and its specific proposals. This is the most radical attempt we have seen for some time to address the issues that concern us in this forum.

SilentCallsVictim wrote on Jan 26^th, 2011 at 10:57am:

I wonder if anyone has managed to plough their way through the document yet - so as to be able to offer comment on the consultation and its specific proposals. This is the most radical attempt we have seen for some time to address the issues that concern us in this forum.

Surely you at least must have done so SCV even though I must confess to only so far having read the bullet point summary of what is proposed.

NGMsGhost wrote on Jan 26^th, 2011 at 11:04am:

Surely you at least must have done so SCV even though I must confess to only so far having read the bullet point summary of what is proposed.

I admit to having trawled through to see what is there. I find the essence of what is proposed to be essentially sensible, given the way in which Ofcom approaches these matters. There are however many important issues that should have been addressed and have not. In particular no serious thought has been given to important questions about how this may be implemented, whereas some implementation issues have been addressed in inappropriate detail.

I hope that this thread will enable many members to express their views on the key issues; e.g. the three call types, the future of 0870, the unbundled approach and the maximum retail price option. I see these and other issues as worthwhile topics for discussion.

I have done my best to read some of the details, but at 482 pages long I am struggling to read all of it!

I also had a look at some of the "attachments" given with the main link, and they range from 30 pages onwards, hardly tea time reading.. :-(

From what I have read here are my observations:

Ofcom and the call providers still would expect US to know how much it is to call X number, unless a: it's a pre set charge across ALL networks and ALL telecoms types (Mobile/Landline/Call Box), or b: every call to a NON Geographic (01/02/03) number has a Pre Call Announcement (PCA).

From what I can also gather the PCA would STILL require US to establish part of the call cost invloved in making the call, unless the PCN was wordered as follows " You will be charged a maxium of X pence per minute in total for the call" - source here page 22 section 4.2.

On this basis I would suggest Ofcom and ALL call providers impliment 2 parts to this consultation:

A maxium ALL network/call provider charge (per minute) and a PCN detailing it as per my notes above.

I will post a seperate response as to why I recommend these.

CJT-80 wrote on Feb 6^th, 2011 at 9:54pm:

I have done my best to read some of the details, but at 482 pages long I am struggling to read all of it!

It is indeed a nightmare. I am reluctant to try to be authoritative myself, as I have not read every line, but I will have a go at addressing the points made above.

The key element of the "unbundling" (or disaggregating) proposal is that the "Access Charge" levied by the caller's telco (known as the OCP) be advised and billed separately from the "Service Charge" levied by the "Service Provider" (SP) and their telco (TCP).


The idea is that the OCP has a fixed "Access Charge" for all NGCS calls which it advises to its subscribers. It may be that there are different access charges for various call plans, but the point is that they are fixed, regardless of the "Service Charge" that applies to a particular number range.

Ofcom proposes that advising the "Service Charge" is the responsibility of the Service Provider. There is already such a requirement for PRS numbers, however it is vague and is generally met by quoting BT rates. The idea is that this would be covered by a statement in the form

Quote:

This call/text will cost you X pence per minute plus your phone company charge.

As with the present system, specific Service Charge levels would be associated with blocks of numbers. There would have to be a central place where this information was recorded, so that telcos could bill correctly and for reference in cases where the SP was not able to provide the Service Charge information, e.g. if their number was quoted by someone else. This would be similar to the lengthy tables that presently clutter the BT price list (and others) - but there would be only one, giving the Service Charge applied to any particular number by every telco.

All that telco's price lists would have to show is the applicable "Access Charge", with the vital comment that a "Service Charge", selected by the SP, would be added.

I believe that the table of Service Charges would have to be published (probably by Ofcom) on the internet and available in hard copy also. Other ways of accessing this information could be considered. The point for me is that if a Service Provider is levying a "Service Charge" for a service, it is their primary responsibility to see that the price is advised to those who are to pay it.


The Analysis Mason document appended to the consultation was looking at the mechanics of achieving the unbundled (or "disaggregated" as it calls it) approach. One of the options being considered was the possibility of advising Access and Service Charges by free PCA.

PCAs are very difficult in the context of an "unbundled approach" as there are two components to the call cost. The document discusses this at length. The possibility of different callers on the same network having different "Access Charges" in effect raises another potential problem.

I am personally opposed to the use of PCA's as a primary means of advising call cost. The decision to make a telephone call is made, with an awareness of the likely cost, before dialling the number. The only significant benefit to be derived from a PCA is a decision to abandon the call. Unless it has that effect then it is probably just a time-wasting annoyance. The only justification I see for PCA's is where the likely expected cost is much less than what will actually be charged. The emphasis should be (totally in my view) on proper cost awareness when taking out telephone service and when being invited to call particular numbers. The existence of PCA's can remove that responsibility altogether.

A worthwhile PCA must surely give the total cost basis for the call in cash terms. If it failed to do so, perhaps only covering one of the two elements of the cost of the call, many would see this as a waste of time. I think it highly unlikely that this could be achieved, not least because the necessary sophistication would make such a system very expensive - do not forget that costs always end up falling on the customer, unless Ofcom used taxpayers' money to pay for this. If the PCA idea were to be pursued, there would undoubtedly be a compromise, which would probably make the exercise pointless - Ofcom sees its role as being to deliver compromises.

(I continue with comments on the "Maximum price" option in the consultation, and conclude ...)

(... Further to my previous posting)

I also oppose financial intervention in the market to set a maximum price for NGCS calls. It is the alternative of the unbundled approach which provides the essential clarity that I see as being the proper solution.

The Service Charge would be fixed, within ranges applicable to each type of number, as at present (e.g. 084 up to 5p per minute, 087 up to 10p per minute). Telcos would have the freedom to set their Access Charge at whatever level they wish. If they decided to charge £1 per minute for all calls to NGCS numbers, then I see no reason why Ofcom should intervene to prevent this - given that it was properly declared on their price list. (Those who wish to see an end to use of NGCS numbers as a way of making money would probably celebrate such a move as it would kill the market!)

The major problem with the maximum total price approach is that it would have to consider the most expensive means of telephone service provision - currently payphones. The maximum set would therefore be totally meaningless in respect of normal charges for other types of provision.

(I have not read Ofcom's thoughts on the subject of maximum prices - I fear that this will get into levels of economics which are well beyond me. Maximum prices are seen as one option available to regulators to deal with "market failure", which is repeatedly referred to. The point is that there is no "market failure"; it will only be when prices are unbundled that markets will exist: for Telcos with their "Access Charges" and for SPs with their "Service Charges". The present mess enables each to assign responsibility to the other. I believe that, if there were transparency, then the "market" would work.)

I hope this is helpful.


CJT-80 wrote on Feb 6^th, 2011 at 9:54pm:

... I would suggest Ofcom and ALL call providers impliment 2 parts to this consultation: A maxium ALL network/call provider charge (per minute) and a PCN detailing it as per my notes above. I will post a seperate response as to why I recommend these.

I look forward to reading the arguments in favour of PCAs and maximum prices.

Hello again, I have read through your response at great length, and hopefully I can now give a better answer.

Maxium Call Costs

For this I will give 2 examples which I have read today, one for 0844 and one for 0871.  They are 2 companies who were both featured in a National Paper today,

Company 1 provides holidays and has an 0844 number to contact them, Company 2 provides plants mail order and uses an 0871 number to contact them. For reference Company 1 will be called HC and 2 will be called PC.

HC has an advert asking callers to dial an 0844 number, at NO point during the advert (in print) does it advise ANY cost of calling this number. How am I to know how much it would cost to call that number? Dial my network (BT for landine/O2 for mobile), go on the internet, ask someone? What if I didn't have the internet? What if I was not sure who to call? These are ALL questions Ofcom and companies need to think about, they may only make a SMALL profit, but someone somewhere still makes money out of my call.

PC has an advert asking callers to dial an 0871 number and advises "calls cost a maximum of 10p per minute from a BT landline, mobile networks vary", which is a way is good advice, or is it?

What if I am not with BT, what if I am dialing from a mobile, how much will it cost? Also it's MORE then 10p per minute with the VAT increase, and NO mention was made of the "connection" charge BT makes (currently 11.5p).

So whilst HC made NO mention of the call cost, PC did no better as it provided very basic info.

Why should anyone set the call costs?

Simply because I should NOT be penalised for calling a number from any provider I choose, just because they are allowed to charge more! If Ofcom set the rate which included the set up fee for malking the call, and which everyone had to charge (landline/mobile/payphone) then not only would the company you were calling be able to correctly advise the charge but you would know how much it would cost to ring that number, and you would be confident in it's cost!

This should apply to ALL 08 (including 0845/0870) numbers excluding FOC (0500/0800/0808) calls - which is a seperate subject all together!

I want to know how much it WILL cost me in total before I call that number, and it's unfair that one provider can charge 11p per minute, whilst another charges 35p per minute!

What effect would this have on the cost of the calls overall?

In honestly I don't know, but there is NO suggestion that the network would charge the FULL rate for the call, they are at liberty to charge less, all that has to be advised is "calls will cost a MAXIUM of X pence per minute inc network charges, regardless of your call provider" - It's that simple! (not being rude there)

PCA's

If the above system was inplimented, then PCA's would not be required, and would save all the companies in question money overall!

--------------------------------------------------------------------

If anyone needs more info or clarification on what I have said, please let me know.

:)

CJT-80 wrote on Feb 7^th, 2011 at 1:03pm:

Hello again, I have read through your response at great length, and hopefully I can now give a better answer.

Under the Ofcom proposals each telephone provider would have to set an "Access Charge" for calls to all NGCS numbers from 0845 to 09.

Ofcom proposes a single pence per minute rate that applies to all such calls. That would be as much part of what you know about your telephone tariff as any other feature, e.g. the daytime rate for calling geographic numbers.

The two newspaper adverts would both have to say:

"Calls cost x per minute plus your telephone company's access charge."

That is an improvement in both cases. The access charge would almost certainly be greater if you were calling from a PAYG mobile than from a landline.

SilentCallsVictim wrote on Feb 7^th, 2011 at 2:53pm:

The two newspaper adverts would both have to say: "Calls cost x per minute plus your telephone company's access charge." That is an improvement in both cases. The access charge would almost certainly be greater if you were calling from a PAYG mobile than from a landline.

Forgive as I have only very quickly scanned the consultation but where would OCP mention this 'access charge' and would it differ depending on type of call - ie 0845 access charge is different than 0871?

SCV,

my issue with that method is the fact it's 2 charges! Yes it's broken down, but the call cost would still differ if: the access charge was different per telco or number, or if the X pence per minute charge was different per telco or number.

My idea was simple, ONE set charge per minute based on Access and Service charges. At the end of the day the end user is most likely wanting to know exacly how much it WILL cost them from their call provider before they make the call, and with as little complication as possible.

One set fee per minute / number (inc ALL charges) reglardless if what network the call is made from, is by far the fairest method of charging.

Same charge for BT/TalkTalk/Virgin - and O2/Orange/T-Mobile/Voda/3 - Contract OR PAYG!

In the market of choice, I should NOT be penalised for calling a NGN from a mobile.

bbb_uk wrote on Feb 7^th, 2011 at 8:01pm:

Forgive as I have only very quickly scanned the consultation but where would OCP mention this 'access charge' and would it differ depending on type of call - ie 0845 access charge is different than 0871?

The "Access Charge" for NGCS would be declared in the same way that other key features of the tariff have to be declared, i.e. on price lists and in marketing material.

The Ofcom idea, for the moment, is that there would only be ONE NGCS "Access Charge" per tariff and that it would only be levied as a pence per minute rate, i.e. no setup fee.

At least one further consultation will take place later before any specific proposal is implemented - there are other options covered by the Consultation, although clearly this is what Ofcom prefers. Ofcom does distinguish between "Business Rate" (084 / 087) and "Premium Rate" (09) numbers. I could see the possibility of different access charges at this level, but not any lower (i.e. all 084 and 087 would only have one access charge per tariff). There is no specific Ofcom proposal to prohibit use of setup fees, so it may well be that the Access Charge could be a fixed fee, a rate per minute, or both.

CJT-80 wrote on Feb 7^th, 2011 at 9:18pm:

my issue with that method is the fact it's 2 charges!

It is two charges because two different parties earn income from NGCS calls, remember that this includes all of the Premium Rate ranges as well.

The call recipient earns the same amount regardless of how or where the call is originated. Many people think it right that this amount should be clearly declared, so that callers know what they are earning. They chose the precise amount they will receive by selecting a particular type of number - apart from 0845, each range is broken into many sub-ranges.


CJT-80 wrote on Feb 7^th, 2011 at 9:18pm:

My idea was simple, ONE set charge per minute based on Access and Service charges. At the end of the day the end user is most likely wanting to know exacly how much it WILL cost them from their call provider before they make the call, and with as little complication as possible.

To achieve this degree of simplicity someone would have to decide how much every telco may charge for connecting a call to a NGCS number. At present they are free to offer different types of service; i.e. landlines and mobiles, with different deals; e.g. credit contract / PAYG, bundled / pay per call. There are multiple competing providers in each market so prices are supposedly kept low by competition. Public payphones introduce a further complication, because the economics there are different.

Ofcom could determine what is an economic cost for provision of the service - it has to do so for BT at present - this produces rates for the most expensive 0844 and some 0871 numbers that are less than the penalty rates for non-inclusive geographic calls. It could however add on a modest margin to these landline BT cost rates to give a figure. Should this be the fixed price?

If it were, then mobile providers would probably cease to allow calls to NGCS numbers. Under the present arrangements mobile providers do not charge line rental, unlike landline providers, so they recover the costs of maintaining the network through call charges which are higher than those charged for calls from landlines. Without a contractual commitment, rates for PAYG calls are naturally higher still, so it is even more likely that PAYG callers would be stopped from calling NGCS numbers if a fixed rate based on the cost of originating calls from landlines were applied.

Perhaps Ofcom should do the job the other way around then, starting with the PAYG providers, perhaps the least efficient and therefore most expensive. Should this be the fixed price? - The implications for BT's profitability are clear to see. NGCS users would be in total revolt at this forced over-pricing of the cost of calling them.

Despite acquiring new powers of price regulation from May this year, Ofcom would probably end up in court, being accused of misusing them, however it set the prices.

If the economic cost of a call from a public payphone were used to set the price for all calls then the system would collapse totally. If a fair price for landline calls were applied to public payphone calls then every public payphone would be removed because it was not economic.


My analysis may be a little over-simplistic and the dangers could be exaggerated. (I have not addressed the possibility of cross-subsidy, which nobody ever admits to because it is too complicated to consider. BT at present is not permitted to make a margin on NGCS calls, it is only permitted to recover its costs. Given that BT does produce a return for its shareholders, it may be argued that some other charges, somewhere, must be too high.)

Whilst Ofcom's economists may relish the task of setting prices, price fixing is foreign to Ofcom's proud role as a light-touch regulator of a competitive market. I cannot, offhand, think of any occasion when any one of the "Of-" regulators has set a fixed retail price.

More complex arguments are needed to set against the Ofcom proposal for maximum pricing, which it offers as an alternative to the unbundled approach.

CJT-80 wrote on Feb 7^th, 2011 at 9:18pm:

my issue with that method is the fact it's 2 charges! Yes it's broken down, but the call cost would still differ if: the access charge was different per telco or number, or if the X pence per minute charge was different per telco or number. My idea was simple, ONE set charge per minute based on Access and Service charges. At the end of the day the end user is most likely wanting to know exacly how much it WILL cost them from their call provider before they make the call, and with as little complication as possible. One set fee per minute / number (inc ALL charges) reglardless if what network the call is made from, is by far the fairest method of charging. Same charge for BT/TalkTalk/Virgin - and O2/Orange/T-Mobile/Voda/3 - Contract OR PAYG! In the market of choice, I should NOT be penalised for calling a NGN from a mobile.

In a free market, it is to be expected that providers offer different (and the same) services for different prices. That is what we have now.

This appears to be an argument in favour of full price regulation; or perhaps nationalisation.

Having landline and mobile networks charging the same would be like offering fuel to those with gas guzzlers at a lower (pence per litre) rate than those with vehicles that use less fuel. This would then even out the "pence per mile" that everyone paid.


The Access Charge would vary between tariff, just as call charges vary between tariffs now and a Service Charge will be fixed for a particular 08/09 number.

SilentCallsVictim wrote on Feb 7^th, 2011 at 11:00pm:

It is two charges because two different parties earn income from NGCS calls, remember that this includes all of the Premium Rate ranges as well. The call recipient earns the same amount regardless of how or where the call is originated. Many people think it right that this amount should be clearly declared, so that callers know what they are earning. They chose the precise amount they will receive by selecting a particular type of number - apart from 0845, each range is broken into many sub-ranges.

Ok, so how does anyone justify the difference between the cost of a call from a Landline and the cost of the call from a Mobile?

Lets take Virgin Media a call to an 0844 800 number is PG6 which is rated @ 10.41p per minute plus a 12.24p connection/network fee.
O2 Paymonthly is 20.4p per minute with no connection/network fee.

a 5 minute call to this Number on Virgin costs - £5.34 (rounded up) and on O2 costs £10.50 that's almost twice the cost!

Can you justify that? I am sorry I cannot.

What if they only telephone option someone had was a mobile, do you feel it's "fair" to charge them more?


SilentCallsVictim wrote on Feb 7^th, 2011 at 11:00pm:

Ofcom could determine what is an economic cost for provision of the service - it has to do so for BT at present - this produces rates for the most expensive 0844 and some 0871 numbers that are less than the penalty rates for non-inclusive geographic calls. It could however add on a modest margin to these landline BT cost rates to give a figure. Should this be the fixed price? If it were, then mobile providers would probably cease to allow calls to NGCS numbers. Under the present arrangements mobile providers do not charge line rental, unlike landline providers, so they recover the costs of maintaining the network through call charges which are higher than those charged for calls from landlines. Without a contractual commitment, rates for PAYG calls are naturally higher still, so it is even more likely that PAYG callers would be stopped from calling NGCS numbers if a fixed rate based on the cost of originating calls from landlines were applied.

Perhaps you would kindly indicate where BT charge lower for an 0844/0871 call then to a Geographic non inclusive call? Have I not already pointed out it was a the difference of aound 1p per minute?

I hardly think that's a fair or justified comparison personally.

Which mobile provider does not charge line rental, and to whom? I have a pay monthy account where I pay a montly rental charge, for which I get a set number of X network and Landline minutes, and "unlimited" texts and on network minutes. I would gladly pay a "add on" charge to include or greatly reduce the cost of calling 08 numbers!

What figure per minute do you feel is "fair" to call an NGN?

Dave wrote on Feb 8^th, 2011 at 2:54pm:

In a free market, it is to be expected that providers offer different (and the same) services for different prices. That is what we have now. This appears to be an argument in favour of full price regulation; or perhaps nationalisation. Having landline and mobile networks charging the same would be like offering fuel to those with gas guzzlers at a lower (pence per litre) rate than those with vehicles that use less fuel. This would then even out the "pence per mile" that everyone paid. The Access Charge would vary between tariff, just as call charges vary between tariffs now and a Service Charge will be fixed for a particular 08/09 number.

Dave I am at a loss as to how we managed to compare Fuel usage to Sevice charges and NGN's.

What service exactly are you comparing? Is the Gas guzzler a Moblile or Landline, is it PAYG or Contact for the mobile?

If I go out and buy a 2 litre Merc I expect to pay the same per litre of fuel, but I won't expect to get the same MPG as apposed to a Fiat 500 Twin Air. I'd also be expecting to pay higher Road Fund Licence as I "polute" more, sadly I cannot compare this to making a call to a NGN.

Am I correct that the aim on SNT0870 is to avoid calling NGN's and finding ways to avoid this?

If I am correct may I ask WHY we are avoiding calling them? I would assume it's down to the cost compared to Geographic calls?

I look forward to your reply.

:)

None of this complicated discussion about complex NGNs would be necessary if the principle that the beneficiary of a service should pay for that service applied.   The correct regime for 08 numbers should be that callers should pay the "access charge" and the business "owner" of the 08 number should pay the "service charge".    Simple.

Competition would exist between callers' Telcos and competition would also exist between receivers' Telcos.   The receivers Telcos would be competing on the basis of their charges to the "owners" of the 08 numbers and those "owners" would be in a position to negotiate with those Telcos over Terms, charges and services (something which callers are unable to do and therefore should not be forced to pay those extra charges).

If there is to be a charge for HAVING a 08 non-geographical number it should be borne by the recipient not the caller.

loddon wrote on Feb 8^th, 2011 at 11:51pm:

If there is to be a charge for HAVING a 08 non-geographical number it should be borne by the recipient not the caller.

This points to the absolute essence of the argument, and I would completely agree with this statement. This Ofcom consultation is, sadly, yet another pointless exercise designed as a smokescreen to simply re brand certain numbers as the warm and fluffy term 'business rate'. When did the need to have a 'business rate' number actually arise? There never used to be any discrimination, from the perspective of a caller, between the telephone line/number at the NatWest at 123 High Street, Anytown and the one at Mr Jones' apartment above at 123A High Street, so why is there a need now? There isn't. Never has been. Unless and until Ofcom addresses the fundamental concept relating to this absurdity of the UK numbering plan, then the consumer will always end up being shafted.

If a given business wants a fancy schmancy telephone system, then it should fund it. It would be preposterous for me to pay an additional call charge to contact, say, Bank Of America, simply in order to fund its telecom operation. It should not cost any more for me to call FPL in Miami than it does to call a residential consumer in the same street block. It doesn't. Ofcom will not address the main issue, and that is why the UK has such a convoluted and inappropriate telephone numbering system.

I was in the UK only last week, and was shocked to see the extent of NGN use. I had to call my airline due to a flight change. The absurdity of the UK system meant that it was (far) cheaper for me to call its call center in the US as opposed to the UK provided number. I know about this, but only because I have an active interest in telecomms. I suggest that a significant proportion of the UK public would be oblivious to such a nonsensical charging scheme.

No one over on this side of the ocean would assume that it would be more financially beneficial to call British Airways in the United Kingdom than use its American call center. Sadly the same does not apply for the opposite scenario.

I will try to summarise certain questions, as I understand them, and respond.

This first posting addresses Call Originating Telephone Companies. The second addresses Service Providers and offers some personal views in conclusion.

---

Why does BT charge more for a Geographic Rate (01/02/03) call than a 0844 / 0871 call?

The current BT rates for calling all NGCS numbers (except for 0845, which is regulated slightly differently, so I will leave this out for now) are set at fixed levels by regulation. The level is equal to the "Service Charge" paid on to the other party, plus a modest allowance to cover some BT costs. This regulation applies only to BT landlines. Ofcom proposes to remove it.

BT offers calls to Geographic Rate numbers as inclusive in the Call Plan selected by the caller to cover the times when they use the telephone. Calls made outside these times attract what I refer to as "Penalty Rates". BT charges for line rental, call plans, the call set up fee and the rates for Geographic Rate calls are no longer regulated.

Whilst call plan charges have remained constant (and the primary plan rate will fall in April) the "penalty" charge for non-inclusive weekday daytime Geographic Rate calls has been increasing at around 30% per annum throughout the last few years. This overtook the charge for the most expensive 0844 calls in October 2010. It has now overtaken some 0871s. Evening rates for non-inclusive Geographic Rate calls are lower, whereas for NGCS (excluding 0845) they remain the same.

---

Do mobile companies charge line rental?

The fact that they do not is most clearly seen by the issuing of SIMs and numbers for free. The absence of a line rental charge explains the need to levy significant termination fees on incoming calls - all network revenue is derived from usage charges.

Monthly mobile fees may include payment for a handset; apart from this they cover bundled amounts of usage (calls, texts, data). Landlines now commonly have call plans, however these are in addition to a line rental charge. Landline call charges are generally lower than those for mobiles because a line rental charge is paid separately.

If anyone can show an example of what is clearly a line rental charge from a mobile provider, then I would be prepared to accept that there may be an exception and may even be forced to reconsider my understanding on this point.

---

Should telephone companies be prohibited from levying "Access Charges" on NGCS calls?

One option to achieve the fixed price approach and to address other points made would be to totally disallow "Access Charges". This would essentially put all Telcos into the same position that BT is in at present. This has not been considered previously, because it would not have been legal, however the new powers which Ofcom will be acquiring could perhaps allow it.

The status of call setup fees for non-inclusive calls may have to be considered very seriously in this context (as it would anyway).

Without any "Access Charge" many NGCS calls would be cheaper than non-inclusive Geographic Rate calls for all providers - not just BT, as at present. This would make for a completely absurd situation with PAYG and indeed in other cases where non-inclusive Geographic Rate calls were not seen as a rare exception.

If SayNoTo0870 has the objective of making it cheaper to call NGCS numbers, then that objective could be said to have been advanced if such a proposal were to be adopted. The site would perhaps have to re-focus its efforts to also provide NGCS alternatives to geographic numbers, for those who paid to call geographic numbers. Perhaps it would need to be re-branded as SayNoTo010203 and to campaign for non-inclusive geographic calls to be made cheaper.

If telcos were to remain profitable, then the removal of any revenue from calls to NGCS numbers would have to be covered by price increases elsewhere.

---

Should telephone companies be allowed to set their own prices?

The principle of a free market allows providers to charge whatever they wish for the services they choose to provide. One could say that there is a cost difference between placing a call from a mobile phone as against a landline to justify a difference in price. This does not however answer the point because there are call charge differences between different landline providers and between different mobile providers.

Ofcom has a statutory duty to encourage competition between providers in the market for communications services, in the interests of consumers. Ofcom would be in breach that duty if it were to allow, let alone require, price fixing.

There is much evidence to show that there is competition in the market for telephone services in general. There are cases where a lack of clarity impedes this at present, e.g. charges for calls to NGCS numbers. Ofcom does however have a good proposal on the table to address this. The NGCS "Access Charge" will be as visible as any other element of a telephone tariff; far more so than the rates for calling NGCS numbers at present.

I continue to summarise certain questions, as I understand them, and respond. The previous posting covered Call Originating Telephone Companies; here I address Service Providers and offer some personal views in conclusion.

---

Should businesses be allowed to charge for people calling them?

It is currently established that they can. The situation is however confused by the fact that BT alone is prohibited from adding its own charge (to the pence per minute rate) for such calls. Furthermore the breakdown between the "Service Charge" and what other telephone providers themselves charge (the "Access Charge") is not revealed.

This applies from the most expensive 09 number down to the humble 0845. Ofcom now proposes to essentially treat all such cases in the same way.

Ofcom proposes to put BT in the same position as other providers. The "unbundling" proposal forces the split nature of the charge into the open. I suspect that when (if) they are forced to show what is happening, some will cease use of "Business Rate" numbers. If they advertise a charge that people knowingly pay, then it is hard to say that such practice should not be tolerated.

There may be situations where a consumer has entered into a relationship with a provider and then finds that unacceptable charges are imposed as that relationship continues (e.g. premium rate charges for enquiries / complaints by telephone). This is obviously unfair practice, which could equally well apply to any other aspect of a continuing business relationship. There should be remedies for such situations, although these may only apply if the telephone is the only means of contact offered. It is hard to see how the potential for NGCS telephone numbers to be used in this way provides a sufficient reason to affect the way in which Ofcom uses its powers to regulate their use.

---

Should "Service charges" only be allowed above a certain level?

Some may argue that it is OK for a chat line or some other telephone based service to charge at a high rate (on a 09 number), but not for a call centre to obtain a relatively modest subsidy of its costs (using a 084 number).

Starting from where we are now, there is a clear difference between the two cases. The former is under an obligation to make some (if insufficient) call cost declaration, whereas the latter is not. The cost involved with the former is understood to be high, whereas with the latter it is muddled up with the cost of calls to Geographic Rate numbers - in the case of the biggest single provider and some others. This is unacceptable.

In making its proposals, Ofcom recognises a continuing demand for relatively modest subsidy from callers and does not propose to withdraw this option. It will be interesting to see if that demand is sustained when a requirement to declare the "Service Charge" is threatened or imposed. The level at which telephone companies set their "Access Charge" will also have a bearing. It could be that the modest benefit obtained from the lower levels of "Service Charge" will not be thought worthwhile when it has to be declared as a charge (possibly where any charge for calling would be seen as improper) and where callers may incur a significant supplementary "Access Charge".

I do not believe that Ofcom is going about this is in the best way, as it will not engage with the major users of 0845 numbers to find out what the position really is. With its squinting approach I cannot see how it could set a minimum level for the "Service Charge" so as to effectively rule out the price bands covered by the 084, or even 087, ranges.

As stated above, I do not rule out the possibility that use of the 084 range will die naturally if the "unbundled" proposal is adopted properly. 087 has already been sustained after being classified as PRS and therefore subject to (inadequate) price declaration. I think it likely that use of 087 will continue, even with a clearer price declaration requirement in place.

Those who wish to propose that "Service Charges" should be set at a minimum level of over 10p per minute (thereby ruling out "Business Rate") may have an argument to advance. The case for Ofcom withdrawing an option that is presently available and is widely used may however need to be put with some weight. Suggestions about what to do with the present 084 and 087 number ranges will also be required.

---

In conclusion

I am reluctant to take a strong moral stance on any of these points because I see business as essentially amoral. It is the matter of transparency that is most lacking. The problem is that the truth is not always simple in a sophisticated world.

A clear understanding is difficult, if not impossible, for the consumer, who may want to take the time to get to the bottom of why they have to pay certain prices for certain items. Opacity may suit the provider, however consumers may not thank them for making a situation complicated.

Unfortunately Ofcom thinks that all of this is far too complicated for anyone to understand, so it has no hesitation in presenting its proposals in a totally inaccessible form.

CJT-80 wrote on Feb 8^th, 2011 at 8:51pm:

Dave wrote on Feb 8th, 2011 at 2:54pm: In a free market, it is to be expected that providers offer different (and the same) services for different prices. That is what we have now. This appears to be an argument in favour of full price regulation; or perhaps nationalisation. Having landline and mobile networks charging the same would be like offering fuel to those with gas guzzlers at a lower (pence per litre) rate than those with vehicles that use less fuel. This would then even out the "pence per mile" that everyone paid. The Access Charge would vary between tariff, just as call charges vary between tariffs now and a Service Charge will be fixed for a particular 08/09 number. Dave I am at a loss as to how we managed to compare Fuel usage to Sevice charges and NGN's. What service exactly are you comparing? Is the Gas guzzler a Moblile or Landline, is it PAYG or Contact for the mobile? If I go out and buy a 2 litre Merc I expect to pay the same per litre of fuel, but I won't expect to get the same MPG as apposed to a Fiat 500 Twin Air. I'd also be expecting to pay higher Road Fund Licence as I "polute" more, sadly I cannot compare this to making a call to a NGN. Am I correct that the aim on SNT0870 is to avoid calling NGN's and finding ways to avoid this? If I am correct may I ask WHY we are avoiding calling them? I would assume it's down to the cost compared to Geographic calls? I look forward to your reply. :)

The mobile phone is the gas guzzler.

Consider another analogy: A can of fizzy drink can cost £1 in an airport or railway station, yet the exact same product costs a fraction in a supermarket. That is the way it is.

Making such a statement is not an expression of one's own opinion, but an explanation of the way it works (principles at work).

The question of what will happen with the levels of "Access Charge" has been raised in a number of places.

The present situation, where T-Mobile imposes an Access Charge of 39p per minute on calls to 0845 numbers, whereas BT has an Access Charge of -2p per minute, in both cases for callers on an inclusive call plan, is highlighted in this Daily Mail article - £3.70 to phone NHS Direct but free number for patients is axed. (The "free number" is a simplified reference to the fact that with call plans and packages in place, most contract customers would not pay a call charge to call 0345 4647.)

The equivalent "Access Charges" for a 0871 (type g7) number are: 30p per minute from T-Mobile and a setup fee of 11.5p from BT. "A complete mess".

I quote comments posted in another thread:


loddon wrote on Feb 10^th, 2011 at 6:59pm:

... The main problem is that Tfl, for example, cause their mobile callers (which group I have already said are probably the majority) to pay between 20 and 40 million pounds extra for every 1.5 million pounds in revenue which they collect from using the 0843 number. ...

SilentCallsVictim wrote on Feb 10^th, 2011 at 8:02pm:

... another important point, which has not been discussed at any length - the level of the "Access Charge". This same point applies equally to 084, 087 and 09 call charges. Because of the present bundled situation, along with special conditions relating to BT, we currently have a complete mess. The status quo is indefensible. Ofcom admits this, although rather than beating itself up with guilt over its responsibility for it, Ofcom tries to move on by proposing radical measures. We may get some idea about how telcos will deal with the "Access Charge" issue in their responses to the consultation. I am reluctant to guess, however there is an interesting possibility, which is linked in with another situation that will be changing over the coming years. It is not impossible that telcos will be taking all of their income through packages covering calls to geographic rate numbers, mobile numbers and the access charge element of calls to Business and Premium Rate numbers. This will leave the only call charges on the telephone bill as the Service Charges associated with calls to Business and Premium Rate numbers. There is a strong preference for packages, as many telcos have indicated that mobile call inclusive packages will be offered when the excess termination rates disappear. I am not an expert on PAYG deals, however top-up packages and bundles, rather than simply a cash credit against fixed charges, seem to be increasing as a feature in this market. The situation has to change; TfL has taken a bad decision given the current realities. ...

loddon wrote on Feb 11^th, 2011 at 11:06pm:

... I am not convinced that Ofcom is "proposing (sufficiently) radical measures" to clear up the mess and gain popular support.   I don't think the Ofcom proposals will address the two main problems of excessive cost to callers and cynical exploitation by "owners" of 08 numbers.   ... BmiBaby, in similar action to their industry competitors, insist on using a rip-off 0844 number while offering toll-free and benign normal numbers to their customers in other countries.   Their representative has had the audacity to start a thread on this site and yet will not respond to reasonable questions nor explain or attempt to justify BmiBaby's rationale in insisting on using 08 numbers.   Do BmiBaby have no confidence at all in their position such that they are not prepared to explain and justify their position?  This intransigence by Companies only fuels the public perception that they are only interested in ripping-off the British public, while they would never dare in other countries.  This is an issue which Ofcom should address. The other big issue which I have aluded to is the ludicrous and exploitative design of the system which forces callers to pay excessive call costs while the companies are claiming to be making fair charges for services but in fact are receiving a mere 10% or less of the charges.  This charging structure will be no different under the proposed regime.

Under the "unbundled" proposal the structure would be different, because "Access Charges" will be at fixed levels for each caller, rather than varied across the various "Service Charge" levels. This is not true of the proposed "maximum price" option.

Whatever the injustice, I am not sure how far it falls within Ofcom's remit to regulate the way in which airlines participate in discussion forums or even in the types of telephone number which they select for particular purposes. Ofcom certainly has a duty to ensure clarity and transparency in relation to charges for telephone calls. It has been failing badly, but has now proposed improvements.

wrote on Feb 12^th, 2011 at 12:59am:

Whatever the injustice, I am not sure how far it falls within Ofcom's remit to regulate the way in which airlines participate in discussion forums or even in the types of telephone number which they select for particular purposes. Ofcom certainly has a duty to ensure clarity and transparency in relation to charges for telephone calls. It has been failing badly, but has now proposed improvements.

You have highlighted a presentation error on my part which I must now correct.   The sentence "This is an issue which Ofcom should address" was misplaced.  :-[

Of course, I do not think that Ofcom should regulate discussion forums.  What I was clumsily trying to say was that Ofcom should address the issue I had mentioned earlier in that post and also in the Tfl thread.   Namely that Ofcom should address the issue of excessive cost to callers, particularly callers with packages.  (Bear in mind that the industry is trying to push all customers into packaged products and it is probable that currently the majority of callers do have a package).   I am referring to the fact that companies using 08 numbers are depriving callers of the opportunity to make use of pre-paid minutes and therefore the true extra cost of calling an 08 number is the total cost of the 08 number and not just the "service charge" levied by the company.  The suggestion by Ofcom that a statement such as "This call will cost you X pence per minute plus your phone company’s access charge" will not tell a caller with a package the real extra cost.

The example which had come up was that of Tfl where it was revealed by a FoI request that Tfl receive 1.5 pence per minute from their 08 numbers.   It is suggested that this results in an additional cost to callers of 5ppm whereas the real cost to callers , considering the inability to use their pre-paid minutes, is from 5ppm up to 41ppm (though some sources say that some telcos charge up to £1.50pm and even £2.50pm).   This is the issue which I would like to see Ofcom address.   I had suggested a more satisfactory solution in another post  where I said " ... if a system could be found which would allow Tfl to apply their charge of 1.5 ppm on top of the callers "normal" call cost then we may have a more acceptable solution  ...".   This is what I would like Ofcom to address.

loddon wrote on Feb 12^th, 2011 at 10:20am:

The example which had come up was that of Tfl where it was revealed by a FoI request that Tfl receive 1.5 pence per minute from their 08 numbers.   It is suggested that this results in an additional cost to callers of 5ppm whereas the real cost to callers , considering the inability to use their pre-paid minutes, is from 5ppm up to 41ppm (though some sources say that some telcos charge up to £1.50pm and even £2.50pm).   This is the issue which I would like to see Ofcom address.   I had suggested a more satisfactory solution in another post  where I said " ... if a system could be found which would allow Tfl to apply their charge of 1.5 ppm on top of the callers "normal" call cost then we may have a more acceptable solution  ...".   This is what I would like Ofcom to address.

In the case in question TfL has selected a number which imposes a Service Charge of 5p per minute on callers. If its arrangements include 3.5p per minute being retained by TfL's telco, in lieu of charges that would otherwise be met by TfL, that point of detail is of no consequence to callers.

Under the "unbundled" proposal, how the NGCS "Access Charge" relates to what could be considered as the caller's "normal" cost is a matter to be determined between callers and their respective telephone companies. The existence of inclusive packages and penalty charges for calling outside the terms of the package makes it impossible to make any general determination of what is a "normal" call cost.

This is not a simple issue, as I will try to explain with two examples. If providers were to be required to cover the "Access Charge" element of NGCS calls along with 01/02/03 calls in inclusive "unlimited" packages, then the price for such packages would "undergo upward pressure" (possibly increase) as more calls would qualify. If, alternatively, providers were to be required (or expected) to set the level of the Access Charge at the same level as the penalty charge for making otherwise inclusive calls, then it would probably be higher than it would be otherwise, disadvantaging both callers and users of NGCS numbers.

The important feature of the "Access Charge", as proposed, is that this is a single figure which applies to all NGCS calls. Unlike the present situation, where it is variable and undeclared, this figure would be as visible as any other feature of a tariff. This means that it would be as likely to be known as any other fact about the caller's costs in using the telephone and therefore subject to the effects of competition.

I comment further on this, quoting myself in reply #63.

There are many issues regarding the way in which the unbundled proposal will or could be implemented, however the concept addresses the issues.

To keep "on topic", I respond here to relevant comments exchanged in another thread.


idb wrote on Feb 12^th, 2011 at 2:46am:

For [a] UK-based airline to use telephone numbers that have variable international acceptance is, in my view, simply unacceptable. ... I have little interest in how the cost of a NTS call is described if I cannot connect to it in the first place.  Ofcom should be doing all within its remit to prevent such abuse of telephone numbering yet it is entirely passive. It is aware of the problems. It is aware of the solutions yet it exhibits such pathetic behavior.

SilentCallsVictim wrote on Feb 12^th, 2011 at 5:55am:

... Ofcom sees a justifiable benefit in use of telephone numbers that generate subsidy or income for the person called. It concludes ... that the problem is with the visibility of the charges. If one could argue that there is no way that this problem could ever be satisfactorily overcome, then one could oppose its proposal that use of NGCS may continue. There is no question that the present situation is utterly unacceptable.

idb wrote on Feb 12^th, 2011 at 2:07pm:

The correct role for the regulator is to act upon previous representations to its numerous prior consultation exercises and realize that, for most engaged with this issue, the matter of whether a call is described as costing 45p per minute or (15+30)p per minute or 15p+30p per minute or indeed any other 'transparency issue' is secondary to the existence of these numbers in the first place. My understanding of previous consultation responses is that there is a overwhelming preference from the 'end user (ie caller)' for the 08 numbering regime to be simply abolished. This is the position that I would maintain. I accept that some will take an alternative position. ... It is the regulator's responsibility to create a numbering framework that is fit for purpose. ... For the sake of disclosure, if a business wishes to obtain a payment stream through the telephone system, then it must use premium rate numbering. There must be adequate redress and opt-out facilities, and there must be certain exclusions and constraints on some classes of premium users. For everyday calls, it is unacceptable, to me,  to have a fee collected through the telephone system.

I do not believe that there is any dispute about the present numbering structure, and the way it is able to be used, as being unsatisfactory, nor that Ofcom carries the blame.


Ofcom undoubtedly considered the interests of all those who use 084, 087 and 090 numbers and the views expressed by respondents to consultations, notably the "call for input", when deciding that all of these ranges should continue to deliver income or subsidy to users.

As suggested, Ofcom proposes that all be formally classified as providers of "Premium Rate Services", although with the manner of charging being changed: to unbundle the Service Charge - to the benefit of the Service Provider, from the "Access Charge" - to the benefit of the originating telco.

We already see the extent of the regulation applied being proportionate to the level of Service Charge. This would surely continue as further lower rate (084) ranges are added.


If by "everyday calls" one means those with a Service Charge of up to 5p per minute (084) or 10p per minute  (087), then one is effectively calling for a minimum level to be set for the Service Charge.
How else can Ofcom make any such distinction?


Ofcom cannot itself regulate which types of number are used by particular persons for particular purposes. That is the responsibility of those who regulate or set standards for specific industries or markets. PhonePay Plus does this for the "phone-paid services" industry. This industry does not include those who use NGCS simply to obtain subsidy towards the cost of providing services that are mainly funded in other ways.

(This distinction may be of little concern to callers, but is highly significant in terms of the role of a regulator.)

Apart from many statutory and voluntary industry regulators, there is also a role in this for the Cabinet Office in respect of all public bodies, for the Trading Standards Institute to cover all business and for the Committee on Advertising Practice, which sets the rules enforced by the ASA. In my view, Ofcom should be closely engaged with all of these bodies to ensure that its proposals provide them with a suitable basis for the imposition of proper regulation to cover use of numbers and declaration of Service Charges by NGCS users. Ofcom's narrow approach, focussed only on its own powers, is improper.

It is ultimately for consumers of the services of users of NGCS numbers to make a decision about a Service Charge. Access Charges are set by the telephone service providers, therefore a feature of the consumer's relationship with them. It is for Ofcom to ensure that all is in place for this to work; only some of that falls within its powers to impose and enforce regulations.

SilentCallsVictim wrote on Feb 12^th, 2011 at 12:59am:

Under the "unbundled" proposal the structure would be different, because "Access Charges" will be at fixed levels for each caller, rather than varied across the various "Service Charge" levels. This is not true of the proposed "maximum price" option. .

Where does it say this in the Ofcom proposals?   And does it make clear that the current  situation where numerous rates can be applied by each Telco, will be prevented and that only one "access charge" rate will apply to an 08 or 09 number?   I raised this question in Post #14 on this thread with --- "Could someone explain how the Ofcom proposals will simplify the current pricing complexity of non-geographic calls, because I cannot see in the Ofcom consultation document.   For example, if you want to find out the charge rate for any non-geo number from Virgin Media, you need to consult their pricing tables to be precise, here :---  http://allyours.virginmedia.com/pdf/uk_non-geographical_calls_a.pdf  

This document is 24 pages long and contains lists of non-geo numbers with the "chargeband" alongside.   You then need to look up the chargeband somewhere to find out the cost.   As you can see there are thousands of numbers and hundreds of chargebands ..."

The following posts did not clarify to me that the nonsense where Virgin Media currently charge hundreds of different rates for calls to 0843 numbers will be prohibited.   For example their charge for calling an 0843001xxx number is on the "PG24" scale whereas a call to an 0843002xxx number is on the "FF29" scale.   Can you assure me that under the proposed scheme VM and all the others will only be allowed to charge a single access charge rate to all 0843 numbers?

loddon wrote on Feb 14^th, 2011 at 10:14pm:

Where does it say this in the Ofcom proposals?   And does it make clear that the current  situation where numerous rates can be applied by each Telco, will be prevented and that only one "access charge" rate will apply to an 08 or 09 number?

The Ofcom consultation document makes the Virgin Media price list (and the equivalents from all other providers) appear to be the essence of simplicity and brevity!

A simple summary of the unbundled option is given starting at section 1.30 (pdf page 11).

I recommend section 6.74 (pdf page 86), which addresses the specific point raised, by explaining the difference between the Access Charge and the current situation with OCP price lists. Surrounding sections outline the various regulatory options being considered for the unbundled approach in more detail.

For the detailed arguments one should review the sections for the specific ranges as follows:

• starting at A7.198 (pdf page 384) for 0845
  
  
• starting at A7.315 (pdf page 407) for 0844
  
  
• starting at A7.349 (pdf page 414) for 0871
  
  
• starting at A7.392 (pdf page 422) for 09

The consultation is on strategic options at this stage. Further consultations will have to occur when specific regulatory proposals are advanced.

Ofcom is however very clear about what it is looking for from the Access Charge, which it refers to in the singular:


Quote:

Provided the Access Charge is structured simply, it potentially provides a price that consumers can readily take into account when selecting which OCP to subscribe to and which callers can easily remember.

---

The Service Charge

Ofcom proposes that the "Service Provider" should carry the responsibility for declaring its Service Charge whenever its number is advised - in the same way as currently applies to providers of PRS. It proposes a much clearer message that refers to the telco-specific Access Charge but explicitly states the Service Charge, which will apply regardless of how the number is called.

Although the structure of the table of Service Charges, related to number ranges, would remain essentially the same as at present, this provision means that callers would not normally need to access it.

There would only be one such table, but the complexity referred to would remain if one needed to discover, or verify, the level of "Service Charge" associated with calling a particular number. This could apply if querying the Service Charge raised on a bill, if doubting the information given by a Service Provider or if made aware of a NGCS number to call by a third party (perhaps a friend), who could not be made subject to a regulatory requirement to include the price declaration statement.


I suggest that Ofcom would have to accept the responsibility for maintaining and publishing this table for the benefit of consumers - it would have to do so for OCPs anyway, so as to ensure that they could bill accurately and answer customer enquiries. As well as hard copy versions that could be distributed by all OCPs on request and an on-line "full print" version, I would suggest that an on-line lookup facility be provided.

If, as has been suggested, 084 numbers are added to the definition of PRS, then some of this work could be sub-contracted to PhonePay Plus.

SilentCallsVictim wrote on Feb 15^th, 2011 at 3:30am:

I suggest that Ofcom would have to accept the responsibility for maintaining and publishing this table for the benefit of consumers - it would have to do so for OCPs anyway, so as to ensure that they could bill accurately and answer customer enquiries. As well as hard copy versions that could be distributed by all OCPs on request and an on-line "full print" version, I would suggest that an on-line lookup facility be provided.

Some OCP's now only publish their prices for NGN's in hard-to-find areas which is going against GC14.2.  It took Ofcom two tries and getting OCP's to comply with GC14.2 and BT doesn't do it now.

So with this in mind, what would Ofcom do to ensure that OCP's provide a look-up table of somekind when Ofcom has trouble getting OCP's to comply with a GC?  ;)

bbb_uk wrote on Feb 15^th, 2011 at 1:31pm:

... what would Ofcom do to ensure that OCP's provide a look-up table of somekind when Ofcom has trouble getting OCP's to comply with a GC?

The whole point of the "unbundled" approach is that it avoids this problem.

OCPs would only be responsible for advising their Access Charge. Advising the Service Charge would primarily be the responsibility of the Service Provider.

In the section from which my quote was taken, I was referring only to the need for a fall back to cover situations where the information provided by the Service Provider was being verified or was unavailable, e.g. when querying a billed charge or dealing with a number provided by a third party.

In the present situation, even when an OCP provides the information in the clearest possible form, the structure is so complex that it is effectively inaccessible anyway (this point is well made above).

Given that the opportunity to impose Service Charges is to remain largely as it is, I strongly believe that the "unbundled" approach represents the best way forward. There are however many points of detail about the manner of the implementation to address.

A number of members have commented on the difficulty of reading the Ofcom document.

It is too big to read start to finish and there is no usable index that provides any guide to the content of sections. I have made appropriate representations to the Ofcom "consultation champion".

For my own purposes, I have prepared an "indexed" version, using a standard feature available when creating a pdf document from MS-Word. As the published versions of all Ofcom consultation documents are prepared in this way, I can see no good reason why this feature is not used generally.

My version, which stops at the end of the material subject to consultation, has been subjected to manual editing so there may be errors, the pagination is different and some graphics have not survived the out and in conversion process. I cannot therefore formally publish this as an "alternative" version. I do however keep a copy on the internet for easy reference. Members may be interested to know that it can be accessed via this short url - http://tinyurl.com/dhtiny/ofcon.

SilentCallsVictim wrote on Feb 18^th, 2011 at 6:02am:

For my own purposes, I have prepared an "indexed" version, using a standard feature available when creating a pdf document from MS-Word.....Members may be interested to know that it can be accessed via this short url - http://tinyurl.com/dhtiny/ofcon.

Thanks for this.
If Ofcon insists on it's preferred way then I would prefer a name like 'Lower Premium Rate Service (LPRS) instead of the use of Business Rate.  That way, the description alone informs us consumers that it is a premium rate number albeit a lower charged one than the normal PRS 09x numbers.

Ofcon would also have to do more to ensure that consumers were informed of the 'Access' charge.  Landline OCP's change their prices that often now that a table of Access charges held by Ofcon would most likely be out of date within a short period.

OCPs should be made to ensure Access charges are in a easy to read format on the same page where it mentions geographical call costs.  As I mentioned in an earlier post, GC14.2, was meant to ensure just this but Ofcon, as per usual, doesn't actively enforce it and actually fine OCPs for not complying instead of a constant 'light-touch regulation' hence why it took 2 tries to enforce the new GC14.2 on price transparency and to date BT at least doesn't actively comply.

bbb_uk wrote on Feb 19^th, 2011 at 9:49pm:

Thanks for this. If Ofcon insists on it's preferred way then I would prefer a name like 'Lower Premium Rate Service (LPRS) instead of the use of Business Rate.

Thanks for the positive input to the discussion.

I can see two points of merit in use of the term "Business Rate", given that there is any validity in making some distinction from "Premium Rate". It is important to remember that for the caller, there is no fundamental difference; the "Access Charge" and the need for price declaration are identical.

The way I see the difference is that "Business Rate" (084 and 087) numbers are used by businesses, other than those who are providers of telephone services, to obtain subsidy towards the cost of their business operations in whatever field they occupy. I doubt that anyone would set up a 087 number, where they did not otherwise receive telephone calls, simply as a means of generating fresh revenue. There simply would not be enough money in it, given that the calls were actually going to be handled in some way (scams are different).

As an alternative to using a "Geographic Rate" (01/02/03) number for the same operation, the cash or discount benefit is seen by some as worthwhile, even when offset against a directly corresponding cost to callers. That is a business decision to be made, and a much clearer decision in a more transparent environment. I hope that when faced with this clearer decision, businesses will think carefully about whether they wish to openly impose charges on callers. Some will decide that they do not, others will be required to present clear justifications without being able to blame telephone companies.

The term "Business Rate" suggests a valid connection with "Business Class", as used by airlines and hotels. It is not the top of the scale, but it is conveys some sense of unnecessarily extravagant expenditure to many people. It also reflects the fact that there is some commercial motive behind its use.


The concept of a "Lower" "Premium Rate" has been understood for some time, as it provides the only justification for the use of the awful term "Lo-call". The "Lo" simply means lower than other premium rates. The phonetic connection with "local" is a most transparent deceit.

I fear the suggestion that LPRS calls were cheaper than Premium Rate calls being used to imply they may not always be more expensive than Geographic calls. "How much lower?" is the obvious question, to which answers will be expected to be predictable. Campaigners will be expected to say "not much", users will be expected to say "lots". Longstanding confusion will continue.

There is the even greater danger that, as is common, terms get shortened in regular use, missing out a vital element. "Lower Rate" would be a most convenient shorter version for the term "Lower Premium Rate Services"! As with "lo call" the implication would be that the rate is low with reference to rates in general, rather than just to some very high rates.


With my focus on the public services, I feel that the term "Business Rate" would be more uncomfortable than "Lower Premium Rate" for service providers to use. A primary purpose of these proposals must be to get those who should not be using 084 numbers away from them and onto 01/02/03. If, as Ofcom believes, there are a large number of people who would be happy to justify their use of 084 numbers, they need to be set the fairest possible test.


bbb_uk wrote on Feb 19^th, 2011 at 9:49pm:

Ofcon would also have to do more to ensure that consumers were informed of the 'Access' charge.  Landline OCP's change their prices that often now that a table of Access charges held by Ofcon would most likely be out of date within a short period.

When I have referred to a table held by Ofcom, I was speaking about the large and complex table of "Service Charges". The "Access Charge" is part of the normal commercial relationship between a telephone service provider and their customer. Ofcom has no need to be involved in keeping records of what these are.

Ofcom is adamant that "Access Charges" must be very simple - one rate per customer / contract is suggested. OCP price lists would no longer have to include the complex tables of rates for UK NTS calls, which are commonly larger than the sections covering the rest of the world - in time rats for calls to UK mobiles will become simpler too.

I cannot think why the Access Charge for Business / Premium Rate calls would ever be presented anywhere other than on the first page of calling rates, as one of the first half dozen figures quoted in a call charges price list. It is perhaps too early to judge whether this charge will be something that OCPs would wish to hide, or whether they would want to be quick to show that when one is paying £1.50 a minute to call a premium rate number, only a few pence of this is going to them.

It is also important to remember that under the unbundled proposal, every advert for a Premium Rate Service or announcement of a Business Rate number will contain a reference to "your telephone company's access charge". Every viewer of some of the most popular television shows will see this on the screen and hear it announced, even if they have no thought of calling themselves. Customers will want to know what this is. Those who have paid their provider for all of their calls will understand that they have to p

SilentCallsVictim wrote on Feb 20^th, 2011 at 5:23pm:

I cannot think why the Access Charge for Business / Premium Rate calls would ever be presented anywhere other than on the first page of calling rates, as one of the first half dozen figures quoted in a call charges price list. It is perhaps too early to judge whether this charge will be something that OCPs would wish to hide, or whether they would want to be quick to show that when one is paying £1.50 a minute to call a premium rate number, only a few pence of this is going to them.

In my experience, OCP's go out of their way to hide the cost to of NTS numbers - even the most common 0845/0870.  That's why Ofcon finally decided to enforce it via a GC although it took them several tries.

Can someone remind me if BT's prices on 084/087 (except 0845/0870) are still regulated?  If so, will the regulation be dropped with Ofcon's new proposals because if so then I can see price rise after price rise because all that happens now is that when one OCP increases prices the others just basically follow (although some may not increase to exactly the same as their competitors - just drop slightly short like a penny).

bbb_uk wrote on Feb 20^th, 2011 at 8:36pm:

In my experience, OCP's go out of their way to hide the cost to of NTS numbers - even the most common 0845/0870.

At the moment they have to show the full table of bundled charges. Under the proposals they would have to show just one figure.


bbb_uk wrote on Feb 20^th, 2011 at 8:36pm:

Can someone remind me if BT's prices on 084/087 (except 0845/0870) are still regulated?  If so, will the regulation be dropped with Ofcon's new proposals

Yes, including 0845.

Under the new proposals, OCPs will only control the Access Charge - a totally new system. The Service Charge will be defined and billed separately. BT will, for the first time, be able to levy an Access Charge.

SilentCallsVictim wrote on Feb 20^th, 2011 at 9:41pm:

bbb_uk wrote on Feb 20th, 2011 at 8:36pm: Can someone remind me if BT's prices on 084/087 (except 0845/0870) are still regulated?  If so, will the regulation be dropped with Ofcon's new proposals Yes, including 0845. Under the new proposals, OCPs will only control the Access Charge - a totally new system. The Service Charge will be defined and billed separately. BT will, for the first time, be able to levy an Access Charge.

Then I anticipate that the cost of calling these NTS numbers will rise, especially 0844.

Most OCP's have their cost of calling NTS numbers like 0844 similar to BT's charge.  If this restriction is removed from BT then BT will in all honestly increase the cost (access charge as it will be known then) and other OCPs will just copy.  So a 5ppm call now is likely to cost more (when adding the access charge and service charge together).

A similar thing happened with the line rental.  Before BT's restriction on charging line rental was removed, other OCPs charged around the same as BT to obviously remain competitive.  After BT's line rental restriction was removed, BT obviously increased their line rental and has kept increasing it since - along with call charges and call setup fees and when BT increases their charges, other OCPs just basically copy.  Where is the competition in that?

bbb_uk wrote on Feb 21^st, 2011 at 1:36pm:

Then I anticipate that the cost of calling these NTS numbers will rise, especially 0844.

When a restriction introduced to encourage use of 084/087 numbers by making calls cheap is removed, then obviously the price would be expected to rise, even if the restriction only applied to the largest single provider. Those who make no money on originating calls to NTS numbers (BT by compulsion, others due to competing very directly with BT) must be inflating charges elsewhere in order to make a profit. Even if we will not see direct evidence of the cross subsidy being removed, I do not want this situation to continue. I certainly do not wish to see it extended by being applied to all telephone companies, so that the cost of calling NTS numbers falls, whilst other charges rise.

If it faces no competition, then please point out to BT that it is wasting shareholder's money on its marketing budget and by reducing the price of the unlimited anytime package. Price mirroring is what is seen in both a highly competitive market and a cartel. My local Sainsbury's proudly announces that even its own brand products are at the same price as Tesco! In a perfect market, a particular product or service (if identical) would be sold at the same price by all providers, as each would be compelled to match the others decreases, and increases could only occur when all were ready to follow.

The unfortunate truth is that in this sophisticated world there are rarely totally clean open markets nor total cartels. There is quite enough economic theory in Ofcom's papers to keep the most interested academic happy.

For me, there is enough competition to make the fact that BT originates less than 25% of non-business telephone calls sufficient reason for its charges for calls to non-geographic numbers to be regarded as atypical and unsuitable for use as an illustration.

SilentCallsVictim wrote on Feb 21^st, 2011 at 7:13pm:

bbb_uk wrote on Feb 21st, 2011 at 1:36pm: Then I anticipate that the cost of calling these NTS numbers will rise, especially 0844. When a restriction introduced to encourage use of 084/087 numbers by making calls cheap is removed, then obviously the price would be expected to rise, even if the restriction only applied to the largest single provider. Those who make no money on originating calls to NTS numbers (BT by compulsion, others due to competing very directly with BT) must be inflating charges elsewhere in order to make a profit. Even if we will not see direct evidence of the cross subsidy being removed, I do not want this situation to continue. I certainly do not wish to see it extended by being applied to all telephone companies, so that the cost of calling NTS numbers falls, whilst other charges rise.

I know where you're coming from and I agree that cross-subsidy exists but going from past experience (aka line rental), the cost of line rental went up and up and others costs went up and up as well.  I have seen no evidence, obvious anyhow, that the cost for BT for line rental was cross subsidised and so when line rental went up, other costs didn't (ie no need to cross subsidy now that line rental restriction removed).

If we were in a perfect world then removing restriction on NTS numbers may mean a, for example, slight rise to NTS numbers but then no rise anywhere else like other call charges, line rental, etc because NTS numbers no longer has to be subsidised.  However, were not in a perfect world and I simply do not believe that removing restictions on NTS numbers and a subsequent price increases means other rises wont happen.

Competition, IMHO, just doesn't really exist for landline & calls like it does for mobiles.  For example, BT whom include calls to 0845 have to obviously pay for these calls despite so-called offering them free (for those on an appropriate tariff) so obviously BT have to cross-subsidise these costs from other areas and hence the increase after increase.

However, most other OCP's don't include calls to 0845 so when BT increases their costs pretty-much across the board there shouldn't be such a need (and rush in some cases) for these other OCPs to follow them.  However, they basically do.

Basically, there is no real perfect answer where everyone wins lol.


Quote:

For me, there is enough competition to make the fact that BT originates less than 25% of non-business telephone calls sufficient reason for its charges for calls to non-geographic numbers to be regarded as atypical and unsuitable for use as an illustration.

Last I noticed most OCPs (mobile providers excluded) generally charge around the same for calls to NGN so the, "calls to 0844 ... cost 5ppm from a BT landline, other providers may differ" to be as accurate one can get (at the moment).  Obviously the main difference is mobile OCPs like I mentioned and VirginMedia, who must be the UKs most expensive landline provider for calls to NGNs, and are an exception to the norm for landline providers.

Interesting related discussion.
http://www.ukbusinessforums.co.uk/forums/archive/index.php/t-161712.html

catj wrote on Feb 22^nd, 2011 at 4:54pm:

Interesting related discussion. http://www.ukbusinessforums.co.uk/forums/archive/index.php/t-161712.html

Interesting indeed.

What is worthy of note is that "03" is only mentioned as the penultimate word.

Awareness is built and consumer perceptions changed very slowly. Ofcom has a lot of work to do. Much of that has to be achieved by building alliances with those who can help in putting across the messages that it wishes to convey. If few providers are able to issue 03 numbers as part of attractive deals, then they will not be promoted by the "numbers" industry.

Ofcom has to recognise that it has a positive role as well as the negative role of a regulator. Its positive ideas should not be simply restricted to the way in which it formulates regulations.

This Thursday (10 March) is the deadline for responses to the Ofcom consultation on expensive telephone numbers

Somewhat belatedly perhaps - I have published some simple notes reflecting a personal view on responding to the Ofcom consultation - http://tinyurl.com/dhtiny/doc/?CONSRESP.pdf.

Anyone have any knowledge of an organization by the name "The Telephone Company"? My limited web searches have yielded very little. It provides only a gmail address. Seems it isn't too impressed with this forum:

http://stakeholders.ofcom.org.uk/binaries/consultations/nongeo/responses/the-telephone-company.pdf

idb wrote on Mar 8^th, 2011 at 1:01am:

Seems it isn't too impressed with this forum: http://stakeholders.ofcom.org.uk/binaries/consultations/nongeo/responses/the-telephone-company.pdf

Fairish comment. There is no structure that justifies saynoto0870 being classified as a lobby group. It has a database of alternative numbers and an open discussion forum. It is run on a commercial basis supported by advertising.

I suspect that moderators would take exception to the suggestion that individuals post under different identities so as to manufacture dialogue, as they would probably seek to prevent this. It is however not an issue of any great consequence - it is an open forum - anyone can express whatever opinion they wish. Furthermore, I would totally defend the right of contributors to remain anonymous, if they wish.

The use of a personal number on the domain record is unfortunate, and just the sort of thing that many members would seize on as the basis for discrediting all that is published here. The general style of the comment in the consultation response is also not entirely unfamiliar to those who read these columns (although I am not suggesting anything improper). I think that Mr Wilson is indeed one of us, at least in spirit.

Perhaps Ofcom has a duty to check out possible use of spoof company names before publishing responses.

SilentCallsVictim wrote on Mar 8^th, 2011 at 1:40am:

Perhaps Ofcom has a duty to check out possible use of spoof company names before publishing responses.

Whether for this or some other reason, the response in question has been removed from publication.

The deadline for responses has been extended to 31 March. Members may be interested to browse the other responses that have been published. This may inspire or encourage them to make a contribution. Nobody has yet attempted to answer all of the questions posed; some have simply made brief free format comments by email.

(See http://stakeholders.ofcom.org.uk/consultations/simplifying-non-geo-numbers/ - a button to "Show Responses" is towards the bottom of the right hand panel.)

Can I take this opportunity to remind everyone that this consultation deadline has been extended to 31st March 2011 --- in 4 days time.  There is still time to have your say in the most important consultation issued by Ofcom to members and users of this website, I would have thought, because this website and campaign is all about non-geographic numbers, their use and misuse.

I urge all to respond now and reinforce our campaign.

I would also point out that my own response is published here http://stakeholders.ofcom.org.uk/binaries/consultations/simplifying-non-geo-numbers/responses/Kennedy_Mr_M_G.pdf

Regular readers of this Forum will be aware that I have been pressing the point for quite a long time now that 0843/4/5 and 0870/1/2/3 numbers are fundamentally a giant rip-off of the public and callers in general because the costs for such numbers are imposed quite wrongly, unethically and illegitimately on callers and not the companies and organisations which exploit and benefit from these numbers.    While I have had some moderate support for this point of view from a few contributors to this Forum I have felt that not many people entirely get it or yet support this point of view.   It has  heartened me to discover that at least one responder to the consultation agrees and has expressed their views in this response which I urge everyone to read and perhaps be inspired to submit their own response   ----  http://stakeholders.ofcom.org.uk/binaries/consultations/simplifying-non-geo-numbers/responses/Antelope_Consulting.pdf

Antelope Consulting appear to be an authority on these matters given their profile of providing advice and consultancy on  this type of issue in 60 countries around the world to both Governments and Telecomms Authorities.

Again I urge everyone to take this unique opportunity to influence Ofcom while you still have the chance.  If some feel that they agree with or sympathise with my point of view and that of Antelope Consulting, then a response reinforcing that would be greatly appreciated.

I quote below a few extracts from the response by Antelope Consulting which I see as important :---


In particular, we favour requiring the access charge [to 084/7 numbers] to be no greater than the charge for a call to a geographic or mobile number; all non-geographic numbers other than free-to-caller numbers could then be described by one set of rules (as an 03 number would simply be tariffed with the access charge and have a service charge of zero)2. Alternatively, the access charge could be required to have a particularly simple form, such as being per call.

The consultation document also expresses concerns about whether the revised EU framework provides an adequate legal basis for having a maximum access charge. The concern is hard to understand, when the framework explicitly permits maximum prices for consumer protection and the maximum access charge is intended for exactly this purpose.

Because of the problems with absolute bounds (other than zero) on prices, we prefer relative bounds where possible, such as requiring the access charge to be no greater than the charge for a call to a geographic or mobile number.

They don't specifically state but I assume that by recommending that the access charge to 084/7 numbers be related to the cost of normal geographic numbers that they mean that access charges would always be included in packages.

Some extracts from my own submision :---

083/4/5 and 0871/2/3 Numbers
Regarding 0843/4/5 and 0871/2/3 numbers the problem is that they are wrong in concept and wrong in design . They are fundamentally unethical and are quite rightly distrusted by the public. I believe the new Ofcom proposals will not rectify this distrust because the proposals do not address the ethics of the concept.
Concept
As I understand it the concept of 084 and 087 numbers is that they provide for certain benefits to the organisation using them such as re-routing and redirecting calls, call management, collection of varied call statistics, geographical anonymity or geographical ubiquity and, some may say, a certain amount of prestige. These are all benefits to the Organisation concerned and not of benefit directly to the caller. As an aside, there is a contention that these claimed benefits are not exclusive to 084 and 087 because technical features such as re-routing, call management and statistics can equally well be obtained if geographical numbers are used. 03 numbers of course can equally provide all the same benefits.
084 and 087 numbers also provide for micro-payments through the telephone system, which means that Organisations can collect revenue from callers. At present this is entirely unethical because no phone contract that I am aware of sets
out the contractual basis for collecting this money, deducting it from the callers account and paying it over to the third party. All contracts are essentially between the caller and his service provider: there is no third party.
The Problem
The problem with this concept is that while the benefits of 084 and 087 accrue to the called Organisation it is the caller who is billed and must pay. (This is done through the higher charges that are made, which in turn are based on the internal accounting procedures which operate between phone companies handling the calls. There are exceptions currently due to legacy regulations, but I understand that Ofcom propose to remove these regulations and to allow equable competition between all phone companies.) The Organisation receives the benefits but the caller must pay for them. This surely is wrong and unethical from every normal business transaction standpoint. He who receives the benefit should pay for the service.

Where businesses, government departments or any Organisation for their own convenience or for any reason choose to use a non-geographic number any additional cost should be borne by those Organisations and not the caller. This is what happens currently when 03 numbers are used, as Organisations can negotiate with the phone service providers on method and how much they must pay for the benefits of the 03 numbers they choose, while the caller pays only his normal geographic call cost with inclusion in any call package. The Organisations have buying power and leverage when negotiating, whereas individual callers have no negotiating power nor, critically, any negotiating opportunity. Callers are effectively left with no choice when confronted with 084 or 087 numbers, they must either pay whatever it costs or not make the call at all. When choosing a calls supplier the matter of charges for this type of call is often invisible, not presented and not usually considered.
Inefficiency

Another aspect of this concept and design is that the longer a call takes the more revenue the called Organisation receives. Therefore the Organisation has no incentive to keep calls as short and efficient as possible. Indeed the incentive is directly opposite and there must be some temptation to cause calls to last longer and so to increase the revenue. Long winded recorded messages, extensive menus, long call queues all have this effect without costing the Organisation anything as they are zero cost once set up. Queues can be unlimited in length. The phone service companies also do not mind longer calls at premium rates because this provides additional revenues. There are many examples in the public domain of people complaining of long queues while calling 084 numbers. This used to be a problem with 0870 but is curtailed somewhat with 0871/2/3 by regulation although the regulation could be more strict and more rigorously enforced. The idea of “light touch” regulation in this regard is totally unacceptable from a callers point of view.
The deliberate or incidental extension of call lengths leads to considerable waste of time by callers which when multiplied by the millions of calls to 084 and 087 numbers every day must add up to a massive cost to the national economy. The telephone system and numbering infrastructure is a national asset and should be designed as far as possible to help improve efficiency in the country and not to hinder it. The current Ofcom proposals would be better if they addressed this issue instead of ignoring it.
So are these problems of (a) charging the caller instead of the user Organisation for the benefits (b) revenue collection through the telephone system and c) inefficiency addressed by the Ofcom Proposals? Sadly the answer is NO.

Continued in next post.

Extracts continued  :---

Simplicity
The proposals offer a little more transparency in the pricing of calls but they do nothing to address the fundamental issues. They also do not simplify call tariffs because working out the price of a call will become much more complicated in future. If Ofcom want to increase the use of the phone system and expand the industry then the key would indeed be simplicity, and that means in my view, simplicity in charging structures and tariffs which would also allow callers to easily compare service and price offerings from competitive phone service suppliers rather than the complicated half hidden price structures of today.
Charges for using 084 and 087 number
The idea of splitting the call price to the caller into two elements service charge and access charge is a fudge. The service charge is comprised of two main elements the revenue passed on to the Organisation using the 084 or 087 number and the phone company charge for using that number. This split would still be invisible to the caller and is a major problem because the phone service charge is usually the largest element, often by a long way. For example, Transport for London (TFL) recently revealed in response to a FoI request that they paid only £23 for their new 0843 number; NOT £23,000 or £230,000 but £23. They also said that they receive 1.8 pence per minute from every call. This is obviously a very good deal from the TFL perspective. But it is catastrophic from both the callers' and national perspectives. 0843 numbers are excluded from all call packages, and in my view so they should be under the current numbering design. 0843 numbers cost from 5p to 10p (approx) per minute from various landline service providers and from 20p to 41p (approx) from competing mobile providers. This means that for every £1.8m that TFL receives the cost to landline callers is between £5m and £10m and for mobile callers it costs up to £41m. Cost of £41m to generate
£1.8m revenue is a highly inefficient way of collecting revenue and if all the callers were a single entity they would very quickly be negotiating or taking other action to reduce their costs. This is merely one example but this must be multiplied by many thousands if not millions across the 084/087 industry.
Because callers cannot act as a single or a small number of entities we, the public, rely on Ofcom to protect us from harm, look after our interests and regulate so that this type of extortion cannot happen.
An easy way for Ofcom to protect the interests of the public would be to stipulate that the call charges for use of 084 and 087 numbers must be charged to the user Organisations and not to callers, in a similar way to the operation of 03 numbers. Callers should still pay the proposed access charge but this charge should be no more than their normal geographic call charge, inclusive in packages, and similar to the access charges to 03 numbers.
Revenue Share
This would leave the question of the revenue share payable to the user Organisation. I am generally against this in concept, but if it were to be retained then it should not necessarily be related to the length of the call which could still tempt call lengthening for revenue earning purposes. It may be better to make this a fixed price per call, to be set by the Organisation. This would provide true transparency and enable callers to make clear decisions prior to committing to a call because they would know in advance their access charge (or its basis) and they would know how much they are paying for the service and that the whole cost is going to the Organisation called. The Organisation would be in a position to influence the
cost of use of the 084 number and realistically to negotiate. This would address the question of overall efficiency because the Organisations would have an incentive to keep their service calls efficient. The question of simplicity for callers would also be addressed with this design because callers would only need to know the service price declared and they would already be aware of their access charge or package.
None of this improvement would happen under the Ofcom proposed scheme, because although the callers would be, for the first time aware of revenue generation for the called Organisation, they would not be aware of just how much of that is going to the phone company and how little to the Organisation called. The Organisations would still have little interest in reducing the call costs and in more efficient call management issues, like reducing call queues because the longer the call queues the more they earn.
An option which Ofcom might consider in the event of rejecting my proposals, but which I would not otherwise favour, is stipulating that any Organisation which uses 084 or 087 numbers must offer alternative 01, 02 or 03 numbers at all times and alongside all published numbers. This would allow callers to exercise choice and create a marketplace for competition to control 084 and 087 charges.

Continued in next post.

Loddon how did you manage to have a reply like that on Ofcom's site?

All I got was boxes to fill in, with question numbers next to them.

It's very confusing for me

:(

CJT-80 wrote on Mar 28^th, 2011 at 8:54pm:

Loddon how did you manage to have a reply like that on Ofcom's site? All I got was boxes to fill in, with question numbers next to them. It's very confusing for me :(

You can write it as a Word file and send it. Download a cover sheet from Ofcom.

Dave wrote on Mar 28^th, 2011 at 9:59pm:

CJT-80 wrote on Mar 28th, 2011 at 8:54pm: Loddon how did you manage to have a reply like that on Ofcom's site? All I got was boxes to fill in, with question numbers next to them. It's very confusing for me :( You can write it as a Word file and send it. Download a cover sheet from Ofcom.

So you compose a word file with the responses (or as close to the exact ones as possible) attach it and the cover sheet and e-mail it to Ofcom?

CJT-80 wrote on Mar 28^th, 2011 at 10:08pm:

Dave wrote on Mar 28th, 2011 at 9:59pm: CJT-80 wrote on Mar 28th, 2011 at 8:54pm: Loddon how did you manage to have a reply like that on Ofcom's site? All I got was boxes to fill in, with question numbers next to them. It's very confusing for me :( You can write it as a Word file and send it. Download a cover sheet from Ofcom. So you compose a word file with the responses (or as close to the exact ones as possible) attach it and the cover sheet and e-mail it to Ofcom?

I send my responses as Word files, making the Coversheet the first page.

It's up to you whether you want to structure your response as answers to the questions or not.

Hi Dave

I started completing the ofcom form with all the boxes, I also found it very confusing and drawn out, I part completed it and sent it anyway.

If you have formatted a document I would appreciate a copy and I will also send it to the relevant department if you enclose contact details

bazzerfewi wrote on Mar 29^th, 2011 at 9:39am:

Hi Dave I started completing the ofcom form with all the boxes, I also found it very confusing and drawn out, I part completed it and sent it anyway. If you have formatted a document I would appreciate a copy and I will also send it to the relevant department if you enclose contact details

The Ofcom Coversheet can be downloaded from the website:

http://stakeholders.ofcom.org.uk/consultations/consultation-response-coversheet/

If you already have some of your response, you can insert it at the beginning of it (you may need to add a page break after the coversheet). Tick the appropriate box(es) for not withholding or withholding your personal details.

Details on how to respond (including e-mail address to which to send Word format responses) is here:

http://stakeholders.ofcom.org.uk/consultations/simplifying-non-geo-numbers/howtorespond/

Submissions by a simple email should be sufficient and accepted. Identify yourself, indicate whether or not you wish the response to be published, and if so, whether your name should be published.

I personally make their life easier by sending my responses as a pdf file, along with their completed cover sheet, both attached to an email in which I ask for an acknowledgement of receipt.

loddon wrote on Mar 28^th, 2011 at 8:43am:

Regular readers of this Forum will be aware that I have been pressing the point for quite a long time now that 0843/4/5 and 0870/1/2/3 numbers are fundamentally a giant rip-off of the public and callers in general because the costs for such numbers are imposed quite wrongly, unethically and illegitimately on callers and not the companies and organisations which exploit and benefit from these numbers.    While I have had some moderate support for this point of view from a few contributors to this Forum I have felt that not many people entirely get it or yet support this point of view.   It has  heartened me to discover that at least one responder to the consultation agrees and has expressed their views in this response which I urge everyone to read and perhaps be inspired to submit their own response   ----  http://stakeholders.ofcom.org.uk/binaries/consultations/simplifying-non-geo-numbers/responses/Antelope_Consulting.pdf Antelope Consulting appear to be an authority on these matters given their profile of providing advice and consultancy on  this type of issue in 60 countries around the world to both Governments and Telecomms Authorities.

Thanks for pointing this out. They make some good points. I think it's a well-balanced response and they refer to the externalities which Ofcom mentioned in the consultation document. I think these externalities hit the nail on the head.

My understanding of economics and business is small, but it has seemed obvious to me that this is the case.

I have long believed that there are issues which are fundamental to having inter-connecting providers that are permitting these rip-offs.

If every party was made to see and accountable for the services it receives, then we would have a much fairer telecoms market.

loddon wrote on Mar 28^th, 2011 at 9:07am:

The idea of splitting the call price to the caller into two elements service charge and access charge is a fudge. The service charge is comprised of two main elements the revenue passed on to the Organisation using the 084 or 087 number and the phone company charge for using that number. This split would still be invisible to the caller and is a major problem because the phone service charge is usually the largest element, often by a long way. …

Where the split-tariff approach is given the thumbs down, then is this merely because of the dislike of these (084/087) numbers?

If the charge by the phone company (TCP - the telco operating the number) were published, then that the cat would be out of the bag. We would be able to see that TfL allows its 0843 number provider retain around 3 pence per minute (after giving 1.8 pence per minute to TfL in direct payment).

This response begs the question, what approach should be taken for 09 numbers? What about the split-tariff approach for 09 Premium Rate Service numbers?

Dave wrote on Mar 29^th, 2011 at 4:30pm:

... If the charge by the phone company (TCP - the telco operating the number) were published, then that the cat would be out of the bag. We would be able to see that TfL allows its 0843 number provider retain around 3 pence per minute (after giving 1.8 pence per minute to TfL in direct payment).

All of this nonsense about further splitting of the service charge is just opening up all sorts of potential for further fudging and confusion.

Many (including Antelope) see publication and billing of two charges as being unnecessary complication. I cannot see how adding a third item helps anyone.

Callers pay a Service Charge of 5p to call the TfL line - plus the Access Charge added by their telco. I cannot think what more information is of any use to the caller. We know the rates, because BT is prohibited from adding an Access Charge at present and its cost retentions are modest, to the point of insignificance for our purposes. The current Service Charges are the BT rates.

Those concerned with the financing of TfL (or any other 084 user) may want to get a breakdown of how it pays for its telephone service - the portion of the Service Charge retained by its telephone service provider is one of the factors. The other service charges paid to various providers and the nature of the services delivered must however also be vitally important to any such consideration. The full details of the distribution of the Service Charge would also doubtless be of interest. In most cases these details, even the split of the Service Charge, would be properly subject to commercial confidentiality. Compelling partial transparency is probably worse than nothing as it simply provides a distorted view of the truth, indeed it provides an incentive for distortion.

This is all a great red herring. We have no need to go beyond the level of Service Charge paid by the caller.

If Service providers only had to declare the portion of the Service Charge that passes through their accounts (e.g. 1.8p per minute for TfL) then they would doubtless get up to all manner of nonsense, with TCPs offering free outbound calls, disaster recovery facilities etc. so as to eliminate any declarable "revenue share". That would be a "fudge"! We have been battling against this for ages - we do not want it strengthened!

{hr]

loddon wrote on Mar 28^th, 2011 at 8:54am:

... They don't specifically state but I assume that by recommending that the access charge to 084/7 numbers be related to the cost of normal geographic numbers that they mean that access charges would always be included in packages.

Worse than that, they mean that any package which includes geographic calls must include access charges for Business (and perhaps Premium) Rate calls also. This means that every package subscriber must pay the Access Charge for these calls whether they make them or not (just like all BT customers pay for 0845 calls at present). They also mean that the charge for calls to Geographic Rate (01/02/03) numbers cannot be less than the Access Charge for calls to Business (and perhaps Premium) Rate numbers.

I strongly disagree with this suggestion. I also disagree with the suggestion that the bad debt provision should be covered by a separate Access Charge for 09 calls (It should be a retention from the Service Charge by the OCP, so that a simple single Access Charge may apply.)

Antelope is also way ahead of the game in looking forward to the time when calls to mobiles are priced at the same rate as calls to geo numbers. I believe that this will come, however we do not want Ofcom to hold back for another few years until this point has been reached. This is another good reason why charges associated with NGCS should not be linked to charges for calls to Geographic Rate numbers by regulation. I believe that the necessary linkages will probably occur naturally, especially once we get common standard call charges, including to mobiles.

SilentCallsVictim wrote on Mar 29^th, 2011 at 8:54pm:

Dave wrote on Mar 29th, 2011 at 4:30pm: ... If the charge by the phone company (TCP - the telco operating the number) were published, then that the cat would be out of the bag. We would be able to see that TfL allows its 0843 number provider retain around 3 pence per minute (after giving 1.8 pence per minute to TfL in direct payment). All of this nonsense about further splitting of the service charge is just opening up all sorts of potential for further fudging and confusion.

Indeed.

I believe that we need to accept the fact that there is a Demarcation Point between calling and receiving parties in any call. In this diagram, it is represented by [X]:

[Caller]---[Caller's Telco]=[X]=[Receiver's Telco]---[Receiver, aka "Service Provider"]

Responsibilities: The Caller is responsible for the leg of the call before [X] and the Receiver is responsible for the leg after it.

Whilst this has always been the case, since the introduction of different communications providers, with the present way call pricing information is given (and perhaps the way in which calls are billed), we have no clear indication of the Demarcation Point.

It is frequently the case that:

• Receivers quote the price Callers who are customers of one particular Caller Telco.
  
• Receivers talk about, or perhaps more commonly, deny receipt of direct payments from their Telcos.

These obfuscate the benefit that Receivers are getting, irrespective of Caller's Telco. I cannot understand why any member of this campaign would not wish for a system whereby this sort of nonsense was seen for what it is.


Charges: The Access Charge is the amount it costs to transport the call from Caller upto point [X]. The Service Charge is the charge to pass the call from point [X] to the Receiver (or to phrase it a different way, it is the 'toll' for the call to pass point [X] and go onwards to its destination).

This introduces the clarity that is so lacking today. Access Charges and Service Charges have always been combined, which is why we are where we are now.


This is grass roots stuff. In order to have a multi-provider system, they must interconnect with one another. So where Caller can choose from Telcos A, B, C etc, in all cases, the Receiver is with the same Telco. So any one call must be delivered to Receiver by the same Telco (irrespective of what provider Caller subscribes to). Thus, all Telcos incur much the same toll to get past point [X].

Response submitted.

I noted that Bristol CAB submitted a response them selves : Here as did Chorley and South Ribble CAB and one from just CAB. I only read the Bristol one and was interested to note that they hightlighted the cost of calling NGN's from a mobile.  When I went on their site to look into their service I note they have an 0844 number to contact them!

Now that's what I call hypocrisy

:(

I'm reading the consultation document and the bit about making freephone numbers free from mobiles.

If it is to be the case that users of 0800 numbers will have to pay more to receive calls from mobile phones than they do for landlines, then this may result in some blocking calls from mobiles.

Where this is so, the mobile providers could perhaps allow a free to caller message giving out an alternative geographic or 03 number that a SP can be called on. It's not ideal, but if some numbers are to be barred (by the SPs themselves), then it might be an option they'd like to explore.

CJT-80 wrote on Mar 30^th, 2011 at 6:27pm:

Now that's what I call hypocrisy

To quickly deal with CABx.

Each CAB is a separate charity funded independently. There is a central coordinating body, called "Citizens Advice", to which they all belong. CA supports their work and organises common services. CA sent around a suggested draft response to the Ofcom consultation which each bureau tailored and added their own bits. Each CAB response does include some different comments and various elements in common with others. I think that this is perfectly legitimate.

They have got themselves into a terrible mess with telephones, having signed up for a service that they cannot afford to fund without contributions from callers. In common with many other charities they use Business Rate numbers, yet are reluctant to admit to levying a charge for their services.

The one positive aspect of the Ofcom "unbundling" proposals is that this would drag them out into the open. I have argued to everyone who claims to support the Ofcom proposals that they must therefore see the logic of themselves voluntarily making the call cost declaration that they wish to be imposed on themselves and others by regulation.

Dave wrote on Mar 30^th, 2011 at 11:52am:

... [X] ...

I believe you are saying that when the caller's money goes past [X] it is none of their business to know what happens to it; that responsibility must be carried by the "Service Provider" who is wholly accountable for it. We could draw a much more complex picture with money flying off in all directions; but this is immaterial, at least to the caller.

Ofcom uses the term "Access Charge" purely to distinguish it from the "Service Charge" component of a call which has two charge elements. Many (notably Antelope) are tempted to think of Geographic Rate calls as having only the same "Access Charge" as a single component. This idea, which is reinforced by the illustration, leads to the suggestion that the "Access Charge" must be the same as the charge for a Geographic Rate call.

Whilst there is a natural tendency for the two to come together, to compel this would actually move things on a step. Ofcom proposes that the Access Charge component of calls that also have a Service Charge be much simpler than the present system of charging for Geographic Rate calls. I would argue that each tariff should have two Access Charges that apply at all times. A rate per call that applies when the Service Charge is expressed as a rate per call, and a rate per minute that applies when the Service Charge is a rate per minute.

Rates for Geographic calls currently vary depending on various factors, including: usage of a pre-paid bundle, time of day, day of the week, duration of the call and in some cases the actual number being called. This is very complex. The application of penalty charges for Geographic Rate calls made outside the terms of a package is one particular issue that many struggle to come to terms with. There will doubtless be further complications when calls to mobiles start to be charged at similar or identical rates to calls to Geographic numbers.

Obviously it would be simpler if Ofcom were to prohibit cheap calls at weekends, discounts for calls to frequently called numbers, packages that were not fully comprehensive etc. Some (notably Antelope) even suggest that Ofcom should prohibit calls to landlines being cheaper than calls to mobiles under the present circumstances. I am not sure that this is the type of simplicity that we really want.

---

P.S. Silly me, I forget to mention call setup fees. - Would anyone like to defend the present system of charging for geographic calls as being a model of simplicity, so as to commend itself as the basis for the Access Charge component of a "simplified" structure for non-geographic calls.

Dave wrote on Mar 30^th, 2011 at 6:52pm:

I'm reading the consultation document and the bit about making freephone numbers free from mobiles. If it is to be the case that users of 0800 numbers will have to pay more to receive calls from mobile phones than they do for landlines, then this may result in some blocking calls from mobiles. Where this is so, the mobile providers could perhaps allow a free to caller message giving out an alternative geographic or 03 number that a SP can be called on. It's not ideal, but if some numbers are to be barred (by the SPs themselves), then it might be an option they'd like to explore.

but I thought the mobile providers said it was too costly to introduce free to caller messages so I cant see them doing this.  Plus, mobile providers (OCPs) don't have a list of any underlying numbers that 080x are translated to so they would have to rely on the SPs themselves to provide an alternative number.

If SPs do decide to block calls from 080x numbers then the end company being called is more inclined to provide a geographical/alternative number on their own website I'd have thought (well hope lol).

bbb_uk wrote on Mar 31^st, 2011 at 11:58am:

Dave wrote on Mar 30th, 2011 at 6:52pm: I'm reading the consultation document and the bit about making freephone numbers free from mobiles. If it is to be the case that users of 0800 numbers will have to pay more to receive calls from mobile phones than they do for landlines, then this may result in some blocking calls from mobiles. Where this is so, the mobile providers could perhaps allow a free to caller message giving out an alternative geographic or 03 number that a SP can be called on. It's not ideal, but if some numbers are to be barred (by the SPs themselves), then it might be an option they'd like to explore. but I thought the mobile providers said it was too costly to introduce free to caller messages so I cant see them doing this.  Plus, mobile providers (OCPs) don't have a list of any underlying numbers that 080x are translated to so they would have to rely on the SPs themselves to provide an alternative number.

Reading back what I put, I don't think I explained what I'm thinking well.

It would be the SP's operator (TCP) that would play the message, and not the OCP (mobile network). The OCP would have to keep the line open for long enough so as to let the caller hear the message. This will be (assuming that it can be enforced by regulation) free to caller and will (I assume) work on much the same principle as the network based number change announcements (those that give out a party's new number).



bbb_uk wrote on Mar 31^st, 2011 at 11:58am:

If SPs do decide to block calls from 080x numbers then the end company being called is more inclined to provide a geographical/alternative number on their own website I'd have thought (well hope lol).

If they do provide parallel freephone and 01/02/03 numbers, then they really should promote the 01/02/03 number for mobile callers. The announcement I'm talking about will be intended as a way of informing those who don't know about (or don't appreciate why) the 01/02/03 number is given. So SPs won't simply promote the 0800 number, leaving mobile callers to hear the message.

bbb_uk wrote on Mar 31^st, 2011 at 11:58am:

Dave wrote on Mar 30th, 2011 at 6:52pm: I'm reading the consultation document and the bit about making freephone numbers free from mobiles. If it is to be the case that users of 0800 numbers will have to pay more to receive calls from mobile phones than they do for landlines, then this may result in some blocking calls from mobiles. Where this is so, the mobile providers could perhaps allow a free to caller message giving out an alternative geographic or 03 number that a SP can be called on. It's not ideal, but if some numbers are to be barred (by the SPs themselves), then it might be an option they'd like to explore. but I thought the mobile providers said it was too costly to introduce free to caller messages so I cant see them doing this.  Plus, mobile providers (OCPs) don't have a list of any underlying numbers that 080x are translated to so they would have to rely on the SPs themselves to provide an alternative number. If SPs do decide to block calls from 080x numbers then the end company being called is more inclined to provide a geographical/alternative number on their own website I'd have thought (well hope lol).

I am struggling to get my head around this one.

The mobile companies already have to provide free PCAs on 0800 calls, unless they are waiving the charge to caller. Surely this obligation would be taken away, not introduced!

I believe that once the business of inflated termination rates and who pays for mobile network access is resolved, there will be no essential difference between the cost of receiving a 0800 call from a mobile as against any particular landline - the whole thing is averaged out anyway.

The problem for 0800 users will be in the increased volume of calls, and perhaps a change in the quality of the calls. That is where the cost will bite.

I cannot see what the refusal message has to do with the mobile companies. Why cannot the user of the 0800 number not give out the message when declining to answer any call that they wish not to receive. This would surely be much cheaper than paying each mobile company to host a "free to caller" call redirect message for their customers when they dial a particular number.

Dave wrote on Mar 31^st, 2011 at 1:05pm:

Reading back what I put, I don't think I explained what I'm thinking well.

It makes a little more sense in the revised form, but I still cannot see why the mobile companies need to treat these cases differently from any other. They should just connect the call and leave it to the recipient to decide what to do with it. I cannot think why someone worried about cost would want to pay for calls to their number to be handled differently by originators.

Network based number change announcements are given out to all incoming callers, not after calls have been filtered at the discretion of the recipient.

I am now yet more confused on reading about the promotion of 01/02/03 numbers to mobile callers. This is a workaround for the present situation where 0800 numbers are not free to caller. For those who retain 0800 numbers after they become free to call from mobiles, there will be no issue.

Once landline and contract mobile users catch on to the fact that geographic rate numbers are free to call, if they choose the correct package, then the need for 0800 numbers will diminish. They will however be needed for those on PAYG mobiles - assuming that PAYG mobiles (in the sense of pay per call as you go) survive the upcoming change to mobile charging!

Very interesting response to the consultation by the BMA GPC. It appears that Dr Buckman is living in a fantasy world and wishes Ofcom to make it true for him. I do hope that Ofcom will respond to his request for information and bring him down to earth with a bump.

This sort of "rubbish" makes my blood boil (the BMA response).

It appears the author of the letter wouldn't know a "local call" if it walked up to him and smacked him in the face.  Pity for him that a "local call" technically does not exist.

The sooner Ofcom/DH/NHS and anyone else stops spouting about the cost of a "local call" the better off we shall all be, and we can start to properly educate people on call costs.

The Telegraph has a feature today :---
"Consumers' most hated little rip-offs"
http://www.telegraph.co.uk/finance/personalfinance/8577427/Consumers-most-hated-little-rip-offs.html?image=1

Of all the numerous rip-offs which prey on us and spoil our daily lives it is hated phone numbers which are second highest in the public list of most hated rip-offs.  Second worst for generating anger in the opinion of the general public are rip-off phone numbers  --- something Ofcom should take note of and ensure they take action upon.   According to a consumer Poll by MSN Money it is these that make people angriest.   Although there is no definition of what they mean by premium rate numbers there can be little doubt that it is the most common numbers, the 0843/4/5 and 0870/1/2/3 ranges that are the problem, rather than the 09 numbers.

This is the text as published :---

"Premium rate phone numbers came in second place, with 16% of the vote. Simon Ward, Senior Editor of MSN Money, commented: “At a time when every penny counts, it’s clear that most of us are fed up of these little rip-offs, which ultimately all add up. While some are avoidable, many are not, which makes them all the more galling.”

For those enthusiasts for this type of information this is the list of top ten most hated rip-offs :---

Being charged extra for not paying bills by direct debit
Rip-off phone numbers
The price of food and drink at cinemas
Hidden/additional flight fees
Ticket booking fees
Automatically added tips/service charges
charges for petrol station air pumps
foreign transaction fees on overseas spending
Charges for using public toilets
Temporary ‘bonus’ savings rates

loddon wrote on Dec 21^st, 2010 at 9:37am:

An excellent comment in The Telegraph which makes the point very succinctly that I have been promoting. Pericles 12/17/2010 10:01   All non-geographic numbers should cost the caller the same as from a land-line (01/02/03). Where businesses, government departments &c. — for their own convenience or any other reason — choose to use a non-geographic number, any additional cost ought to be borne by those organizations, not by the caller. Very well said, Pericles   ;) :) :) Ofcom --- please take note. http://www.telegraph.co.uk/technology/mobile-phones/8207327/0800-numbers-should-be-free-to-call-from-mobiles-says-Ofcom.html

jakmar wrote on Sep 23^rd, 2011 at 9:59am:

loddon wrote on Dec 21st, 2010 at 9:37am: ...

There are very many situations where it is wholly inappropriate or improper for a caller to incur a "Service Charge" from the person being contacted by telephone. This applies to almost all public service providers and many enquiry services from commercial organisations.

I suspect that the comment does not relate to "Premium Rate Services", which would simply not exist if not paid for by the caller, although this point is not made. I suspect that the comments are only intended to address "Business Rate" numbers.


It is argued that there are some cases where it is appropriate for the caller to make a contribution towards the cost of handling their call, rather than this being carried entirely by customers in general or taxpayers - who ultimately fund "the organisation". I personally have my doubts about whether there are that many cases where a contribution of up to 10p per minute is worthwhile, given that the call originating telephone company will add an access charge. At this level, the "Service Charge" would never cover the full cost of handling the call, and so would seem to be a little pointless.

I am however prepared to accept that if there is a significant demand for this facility then Ofcom must allow it to continue. The obvious rider is that the "Service Charge" must be declared by the "Service Provider" and the "Access Charge" declared by the telephone company. If both are prepared to accept this essential condition, then I see no reason why the practice should be outlawed.


I believe that the demand for this facility, under these conditions, may be much less than Ofcom believes. Given Ofcom's present understanding of what consumers of telephone service want, we will have to wait to see what happens once these conditions have been imposed.

The fact that some "Business Rate" numbers - 0871/2/3 - are currently subject to the present cost declaration requirements for "Premium Rate Services" could be seen as an indication that users are content to declare a "Service Charge". This is however potentially misleading, as the price declaration requirements allow them to refer only to the cost of calling via BT, whilst BT is prohibited from adding an "Access Charge". When this prohibition is lifted and it becomes necessary to refer to the additional cost of an "Access Charge", the situation may change.


It could be that "Business Rate" will become a rarely used facility, which may mean that the objective suggested (if I understand it correctly) will have largely been achieved. One benefit of this indirect route to the same point is that it avoids what some would describe as an unwarranted regulatory intervention.

Members may be interested to read the following from the Ofcom Draft Annual Plan 2012/13 on pages numbered 28 and 29 (31/32 of the pdf).


Quote:

Implement new regulatory framework for non-geographic calls 5.11 Non-geographic calls are those made to 03, 05, 070/076, 080, 0845, 0870, 083/4, 0871, 09, 116 and 188 numbers. Consumers use these numbers to call businesses and government agencies, to get information, make payments for services and vote on radio and television shows. In 2010/11, we proposed a simpler approach to non-geographic calls, including exploring the option of simpler number ranges and more standardised charges. We will be publishing a detailed proposal for regulation in early 2012 and will take forward this work into the next financial year, subject to consultation. 5.12 Alongside a new approach to the regulation of non-geographic calls, we also intend to consult during 2012/13 on a specific set of regulatory rules for non-geographic calls. We will work with industry to implement these rules as quickly as reasonably possible, so that consumers can benefit from a simpler, clearer regime.

For those looking for the difference between the two consultations, and potential regulations, it is found in the second requiring the involvement of "industry". Ofcom itself can regulate the telecoms providers and, through PP+, users of numbers that are classified as being used for PRS. I believe, and have argued strongly, that to get effective cost declarations in place for 084 calls, this is better done through alternative channels of regulation, direction and standard setting.

I may be premature, we will see what happens in the new year.

bbb_uk wrote on Mar 31^st, 2011 at 11:58am:

Dave wrote on Mar 30th, 2011 at 6:52pm: I'm reading the consultation document and the bit about making freephone numbers free from mobiles. If it is to be the case that users of 0800 numbers will have to pay more to receive calls from mobile phones than they do for landlines, then this may result in some blocking calls from mobiles. Where this is so, the mobile providers could perhaps allow a free to caller message giving out an alternative geographic or 03 number that a SP can be called on. It's not ideal, but if some numbers are to be barred (by the SPs themselves), then it might be an option they'd like to explore. but I thought the mobile providers said it was too costly to introduce free to caller messages so I cant see them doing this.  Plus, mobile providers (OCPs) don't have a list of any underlying numbers that 080x are translated to so they would have to rely on the SPs themselves to provide an alternative number. If SPs do decide to block calls from 080x numbers then the end company being called is more inclined to provide a geographical/alternative number on their own website I'd have thought (well hope lol).

I have read with interest the result from Ofcom in regard to the use of 08 numbers and I am now totally confused.
When I took part in the survey earlier this year I was under the impression that we were addressing the use of 0800/0808 numbers to mobiles and their cost implications. I thought the main reason for the survey was to enable callers to be charged the same when using an 0800/0808 number for both mobile calls and landline calls.
This is very confusing for me because it appears that this is not the case, I would appreciate it if members could clarify this matter as I do not fully understand what has happened.

SilentCallsVictim wrote on Dec 8^th, 2011 at 7:52pm:

Members may be interested to read the following from the Ofcom Draft Annual Plan 2012/13 on pages numbered 28 and 29 (31/32 of the pdf). Quote: Implement new regulatory framework for non-geographic calls 5.11 Non-geographic calls are those made to 03, 05, 070/076, 080, 0845, 0870, 083/4, 0871, 09, 116 and 188 numbers.

If that was a verbatim quote, there are errors.

083/4 - I assume this is meant to say 0843 and 0844?

0871 - what about 0872?

188 - Is this meant to be 118?

Minor detail perhaps, but it is not particularly engouraging to see that the Ofcom minions can't even type a simple list of eleven number ranges without making three errors.

catj wrote on Dec 9^th, 2011 at 3:09pm:

If that was a verbatim quote, there are errors.

Indeed so. We can have a lot of fun with this.

I quote the opening phrase of the Foreword to the Consultation last year.


Quote:

Non-geographic calls are those made to 03, 05, 070/076, 080, 0845, 0870, 083/4, 0871, 09, 116 and 118 numbers. People use these numbers to call businesses and Government agencies, to get information, make payments for services and vote on TV shows.

It looks as though "188" was a typo in copying the previous document, which itself contained a typo in omitting a "4" from "0843/4". 0871 is intended to include 0872 and 0873, although "0871/2/3" would have been clearer.

Is there not a rule which says that proof-checkers will only spot errors that are insignificant!

These errors do look bad for Ofcom, however luckily they do not seriously distort what is being said, for those who understand or look further. I hope that nobody seriously believes that 0843/4, 0872/3 or 118 are not to be covered, as they were fully addressed by the earlier consultation.

If I find good reason to make a substantive response to the consultation, I will point out these typos. Others are free to do the same.

There has been a further development, indicating that a further statement and consultation by Ofcom is imminent. It also provides a valuable clue as to what the consultation is going to include.

PhonePay Plus has issued a Call for inputs around the extension of PhonepayPlus regulation to remaining revenue-sharing ranges.

N.B. Readers of this document should note that references to 087x exclude 0870, and that the term 08xx often means only 084x[/b] - there is no intention to include 080x within the definition of PRS!

This covers one of the possible ways that Ofcom could use to achieve enforcement of the requirement for Service Providers to state the level of "Service Charge" involved in a call to their 084 number, as part of the unbundled approach. This will be addressed by Ofcom in the second of its forthcoming consultations, as I highlighted above -


SilentCallsVictim wrote on Dec 8^th, 2011 at 7:52pm:

Quote: ... 5.11 ... We will be publishing a detailed proposal for regulation in early 2012 and will take forward this work into the next financial year, subject to consultation. 5.12 Alongside a new approach to the regulation of non-geographic calls, we also intend to consult during 2012/13 on a specific set of regulatory rules for non-geographic calls. We will work with industry to implement these rules as quickly as reasonably possible, so that consumers can benefit from a simpler, clearer regime.

The first of these will address the (potential) implementation of the unbundled approach by direct regulation on telecoms providers, using clear powers available to Ofcom. The second will cover users of non-geographic numbers, especially those using 084 numbers, who are not currently within the scope of Ofcom regulation.


Members may have different views on whether it is appropriate for Ofcom to classify 084 numbers as being used for "Premium Rate Services". It is only by their inclusion within the definition of providers of "Premium Rate Services" that Ofcom itself, through its agent PhonePay Plus, may regulate users of telecoms services.

(Moderators may think it appropriate for discussion of this specific issue to be the subject of a separate thread. This may depend on how many members wish to contribute their views on this particular topic.)


Given that alternative, more effective ways of achieving the desired result may be used, I do not advocate this approach for 084, or indeed 087, users.

The proper nature of PP+ is as the self-regulator of those who earn revenue from expensive telephone numbers, rather than those who simply use them to offset the costs incurred in providing services. In the "call for inputs", PP+ acknowledges this important difference, and the fact that 084 and 087 users fall into the second of these categories. It claims however that the experience of having had its remit (improperly) extended to cover 087x numbers has been more successful than expected.

I take issue with the basis on which this determination is made and do not believe that there is any reason why equal "success" would be experienced if it were extended to apply to 084x numbers. PP+ is quite entitled to view the provision of paid-for services by telephone as a market and to look on that "market" in isolation from other markets. In the case of 087 and 084 numbers however, callers are not paying-for but simply subsidising the cost of providing the service as part of a much wider relationship with the person called. PP+, quite rightly has no interest in this full relationship and the impact of a charge for telephone access as part of it.

PP+ also indicates a possible degree of reluctance to get involved with 0845 numbers, even though the latest  published Ofcom proposals cover these as well as 0844/3. The tiny nature of the revenue share, along with the relatively vast number of users / uses would make the current funding structure of PP+ inappropriate. The probability of mass migration from the 0845 range once unbundled charging and proper Service Charge declaration would make it very difficult for PP+ to plan in the way that is necessary for its charge determination to be made. This would upset all of the operations of PP+.

I hope that other respondents to the "call for inputs" will join me in highlighting these points as reasons why PhonePay Plus should not be involved in the regulation of users of 084 and 087 numbers.

On purely pragmatic grounds however, I acknowledge that compliance with cost declaration requirements for 087x numbers is not so poor as some may have expected, and I am not sure that a strong case could be made for removing 087x from the scope of PRS.

I would be delighted to hear the arguments that may be set against my views, as I am very ready to change my position.


There are further clues about Ofcom's intentions which are found in the PP+ document. I cover them below.

SilentCallsVictim wrote on Dec 17^th, 2011 at 5:35pm:

... PhonePay Plus has issued a Call for inputs around the extension of PhonepayPlus regulation to remaining revenue-sharing ranges. N.B. Readers of this document should note that references to 087x exclude 0870, and that the term 08xx often means only 084x[/b] - there is no intention to include 080x within the definition of PRS! ... There are further clues about Ofcom's intentions which are found in the PP+ document. I cover them below.

It is hinted that if 0844/3 is made subject to "unbundling", 0845 may not.

Ofcom has made it very clear that retaining the status quo is not an option. The other option for 0845 is to treat it in the same way as 03, by removing the possibility of revenue share and requiring call costs not to exceed those of geographic rate calls.

Ofcom had previously indicated that the demand for the benefits of revenue sharing on 0845 and the confusion that may arise from having multiple ranges treated identically (03 / 0845 / 0870) caused it not to prefer this approach. I have however always questioned whether that demand would be sustained under the terms of the cost declaration requirements of the unbundled approach.

The clarity achieved by having distinct ranges for distinct purposes is obviously highly desirable. Avoiding the confusion that would result from mass migrations away from 0845 and the difficulties of enforcing call cost declarations may however outweigh the benefits of having only one non-geographic range that is guaranteed to be charged at no more than geographic rate.

My approach to 0845 has continued to be based on Ofcom's declared preferred approach. If Ofcom has perhaps found that the demand for declared Service Charges on 0845 numbers is perhaps not so great as it had thought, then I am very ready to accommodate this change of view.



The PP+ document suggests that 0870 could be a candidate for "unbundling".

This would be rather odd, now that revenue sharing has been prohibited. The Service Charge would be zero under the present arrangements. Ofcom's preferred approach, noting that usage of the range has fallen dramatically, is to withdraw it from the numbering plan.

If 0870 is to be retained, essentially as it is, then Ofcom would need to use its newly acquired powers to complete the work it was unable to complete previously. It can now impose a clear requirement that call costs may not exceed those of a geographic rate call. The current regulations suggest that this should be the case, however need not be, given that suitable exceptional advice of this variation from the norm is included in published tariffs. Compliance with this requirement may be said to be somewhere between poor and totally absent. It is those who do charge for 0870 calls in the same way as geographic calls who see the need to highlight an exception!

The PP+ document maybe hints at the possibility that 0870 could be resurrected to become part of 087x. I have to say that this must be unlikely given that present users of 0870 numbers must by now have got used to the idea of operating without revenue share. Those who have gone through the cost and confusion of migration to another range would be furious to learn that they could have stayed where they were. There is no shortage of potentially available numbers for "higher business rate" as 0871/3 could readily be extended to 0871/9.

The miserable 0870 should now be finally put out of its misery, with a clear and absolute statement - NO 0870.