This is the last part of my reply to the Ofcom consultation document  “NTS Options for the Future”   I am sending to Ofcom. 
It may be of interest.       Closing date 5pm 7th Jan 05.


Start quote .....

"A straightforward solution.

(1)   After a short notice period,  all 087X and 084X numbers should be charged and treated by all in precisely the same way as 01 and 02 prefix numbers, not excluded from any call options and open to all telecom providers on the same terms.  Revenue sharing would be prohibited in the “08” category.  Organisations not interested in revenue sharing need do nothing and would retain their number.  The need to regulate that category by ICSTIS would be removed.

(2)   Any organisation wishing to retain revenue sharing (and most claim not to be interested) would eventually change to a suitable “09” prefix number. In that category, which was designed for premium numbers, charges and the fact that revenue is shared would be transparent and the numbers would automatically come under the regulation of ICSTIS.

Any of the half way solutions proposed in the consultation papers, or anywhere else, would not be honest or transparent and would not solve the problem. Anomalies would continue to clutter the “08” classification, which was never designed to accommodate revenue sharing. Ofcom would have failed its obligations to implement a clear and transparent price structure and would be seen to have propped up a regime of hidden pricing and clandestine revenue sharing, when a simple solution is available.  This would be a grave charge for Ofcom to resist, especially when taken with Ofcom’s statement: “Ofcom exists to further the interests of citizen-consumers as the communications industries enter the digital age.”  (see web site: http://www.ofcom.org.uk/about_ofcom/) and having regard to its statutory duty".

..... End quote.


It is important to send a response to Ofcom, one way or the other, by 7 January 05.  A short response is better than none.

Your response can be sent to Ofcom, together with a “Consultation Cover Sheet” obtainable from the the Ofcom web site. 
By post: Ofcom, Riverside House, 2a Southwark Bridge Road, London SE1 9HA,
By fax 020 7981 3333,
By email  consult@ofcom.org.uk