Yet again I find myself responding to an unnecessarily complex and prolix Ofcom Consultation Document, written in such away as to deter most readers from responding; ever if they are aware of its existence. Before release, drafts of these consultation documents are clearly sent to a special “Ofcom Obfuscation Department”, who remove any hint of brevity, clarity and logical thought. Some parts of the documents are untrue. Ofcom have appointed a “Consultation Champion”, I would ask him to collect together a random selection of Ofcom employees and give them a few consultation documents to respond to. The results should be interesting.
At the time of writing, even the email (consult@ofcom.org.uk) and response fax number (020 7981 3333) are well hidden on the Ofcom site.
Ofcom’s states: “Ofcom exists to further the interests of citizen-consumers as the communications industries enter the digital age.” (see web:
http://www.ofcom.org.uk/about_ofcom/)
Quoting from the OFCOM document: “NTS – Options for the future –A summary”
“
Industry Concerns. …. From time to time, BT changes its local and national retail call prices to stay competitive with other phone companies. When BT changes these retail call prices, it must also change its prices for 0845 and 0870 calls. This is because, under our current rules, 0845 calls must be priced (before call packages and discounts) at BT’s standard local retail price for BT customers. The price of 0870 calls is linked in a similar way to the price of a national call for BT customers. When BT reduces the prices of 0845 and 0870 calls, there is less money to share with the terminating operator and the NTS service provider. This is especially serious for internet service providers whose services are paid for entirely from call revenues and who are finding their profits squeezed by falling prices.”
This plainly is an untrue statement and the argument illogical. Local and National rate calls are combined and both cost the same, the BT UK Universal Rate is 3p/min. 0870 calls cost 7.5 p/min and did not change to 3p when the BT UK Universal Rate changed.
Sir Walter Scott (1771 – 1832) may well have had the equivalent to an Ofcom consultation document and the “08” numbering system in mind when he wrote:
“O what a tangled web we weave, When first we practice to deceive.”
The solution to “Industry Concerns” (above) is to prohibit all revenue sharing from the 08 category completely. All 08 numbers should be put on the same footing as 01 and 02 numbers. Organisation not interested in revenue sharing would continue to use their existing 08 number which would cost callers from 3p to 0p/min depending on their telecom provider. Organisations who have to have a share of the revenue to exist, should move to an appropriate 09 category, where call charges could be set in the range 1p to 150p/min. The costs to the consumer would be transparent for all to see, if the cost was set too high, market forces would decide who survived. The 09 classification was set up for revenue sharing and ICSTIS regulation would automatically apply.
Note: consultation response to be sent to Ofcom by 5pm 7 Jan 05