Interesting article at
http://www.ofcom.org.uk/telecoms/groups/nts_focus/notes/nts7apr05Includes:
Gareth Davis said that NTS issues topped the list of topic raised with Ofcom’s contact centre. NTS issues also featured heavily in the letters sent to Ofcom by Members of Parliament.
Following the completion of the consumer market research, Ofcom will be looking into the policy options available. Price misperceptions/misleading advertising
ASA/CAP guidance
Is that sufficient? What else could operators do?
Revenue sharing on calls to essential/public services
Central Office for Information best practice guidance to Govt. Contact Centres, advises against use of 087
Dept of Health has moved to stop use of 087 by GPs
More general commercial use of 0845/0870 as an alternative to geographic numbers
Should not be an issue where consumers have a choice
But where consumers are “locked in”, there is an issue about whether NTS is an appropriate payment mechanism
Aim is use research to assess potential scale of any consumer detriment
Call centre waiting times
Looking for evidence rather than anecdote on likely impact of revenue share
Gareth Davies said that Ofcom had received a big consumer response to the NTS Policy consultation, but it wasn’t going off to ban revenue sharing. The work undertaken by Ofcom would try to look into:
How much consumer harm is there today?
What solutions are available and how effective would they be?
How much collateral damage would any of the solutions cause?
Following the consultation on the original 5 options, Ofcom's initial thoughts were that Option 3 could be discarded (seen as too difficult to implement) and option 5 might be too extreme to implement in the first instance. Option 1 wasn’t really going to take the issue forward.
Option 4 was still being seriously considered along with Option 2 (although there was no real support for this option from respondents). Ofcom was therefore considering a further 4 options:
UKCTA’s Proposal:
Key features
As in Option 2, except single retail price points for 0845 and 0870
Aims to avoid consumer price confusion and problems of number portability
Requires NTS retail market review
Initial comments
May not be a sustainable long term solution – no objective basis for determining revenue share
May be feasible as an interim measure
Retail market review not an attractive approach, given legal/economic issues and timescales involved
We are exploring other mechanisms as an alternative to a retail market review, however we can not set retail prices via the Numbering Plan
Caroline Wallace said that timescales involved in the retail market review were very long. Mike Barford asked what other mechanism could be used to agree a price for 0845 / 0870. Caroline Wallace said that other mechanism that might be possible would be the provisions for 0844 and 0871 services. Mike Barford said that an upper and lower limit could be set (very close together). Caroline Wallace said that could be seen as price fixing.
Chris Pace said that much of the problem with NTS charging related to the mobile operators who charged up to 300% mark-up on calling NTS numbers.
BT’s proposal:
Key features
Remove NTS arrangements from 0845/0870
Allow 0845/0870 users to migrate to 0844/0871
Require OCPs to make tariff pre-announcement if 0845/0870 retail prices differ from their local/national geographic charges
Initial comments
Risk that consumer problems would just shift to 0844/0871, as SPs (including ISPs) on 0845/0870 who wish to retain a revenue share would have to migrate
Implementation/policing pre-announcement proposal would be costly
Would require a change to the NTS Call Origination Condition and possibly market reviews for the retail origination and wholesale termination markets into which the new 0845/0870 services would be supplied
Colin Annette said the pre-call announcement only related to instances where operators don’t charge the standard retail price (eg. The mobile freephone announcements) and was seen by BT as an optional add-on to their proposal rather than an integral part.
Ofcom’s Variant X:
Key features
No revenue sharing on 084 or 087 except for ‘accredited’ ISPs who could continue to use existing 084 (or 087) numbers
Option 2 multiple price points for ISPs on 0845/0870
Initial comments
Would involve voice Service Providers moving off 08 ranges or staying on 08 ranges with no revenue sharing
Consumer concerns addressed without ISP disruption
Raises a number of legal, operational and policy issues that need to be explored
Ofcom’s Variant Y:
Key features
Ban revenue sharing on 087 after minimum reasonable period of notice
12-18 months warning of revenue sharing ban on 0845
Revenue sharing remains on 0844, so voice SPs and ISPs have 12-18 months to migrate
Initial comments
Addresses consumer concerns which centre primarily on 087, whilst avoiding discriminatory features and operational difficulties of Variant X
Risk that consumer problems would just shift to 0844, as SPs on 0845/087 who wish to retain a revenue share would have to migrate