For the avoidance of doubt, and to make sure that I am going down the same lines as other repliers, would you be kind enough to let me know if there are any other bits of information that I need to add, including the extra email addresses?

I have no wish to be verbose, but I do not want to miss any MAJOR points.

Number Translation Services: A Way Forward Consultation
Reply emailed to: nts@ofcom.org.uk and   and    and   and   and   and ???

Question 1: Do you agree with our proposal that revenue sharing should no longer be allowed on 0870 calls if the link between 0870 call prices and prices for 01 and 02 geographic calls is restored?
Answer 1: Yes.  I assume that calls to an 0870 number will be included in any carrier ‘tariff packages’ that include free calls to 01 and 02 numbers.

Question 2: In connection with Option B4 and B5, do you agree with Ofcom’s initial view that 0870 calls should be removed from the scope of the NTS Condition if the geographical link between 0870 calls and geographical calls is restored?
Answer 2: No

Question 4: What do you think of our proposal to extend the rules controlling premium-rate services using 09 numbers to include 0871 numbers?
Answer 4: I agree

Question 5: Do you agree we should insist that any adult entertainment services using 08 numbers have to move to the 09 numbers set aside for this type of content?
Answer 5: Yes, apart from freephone 0800 and 0808 numbers.

Question 7: Do you agree that the package of measures we propose to introduce will tackle most of the problems with Number Translation Services? If not, what else do you think we could do and why?
Answer 7: No.  It must be clear to a caller, before they make a call, to a 08, 07 or 09 number what the pence per minute rate will be.

Providing consumers with improved information about Number Translation Services (NTS) and Premium Rate Services (PRS)
Reply emailed to: Geoff.Brighton@ofcom.org.uk and   and    and   and   and   and ???

Question 1: Do you consider that these proposals are reasonable and are likely to be effective in improving the information available to citizens and consumers about Premium Rate Services (PRS)?
Answer 1: No.  It must be clear to a caller, before they make a call to a PRS number what the pence per minute rate will be.

Question 2: Do you consider that these proposals are reasonable and are likely to be effective in improving the information available to citizens and consumers about NTS (Number Translation Services - those numbers beginning 08x/09x) call prices?
Answer 2: No.  It must be clear to a caller, before they make a call to a PRS number what the pence per minute rate will be.

Question 3: Do you agree that there should be mandatory guidelines for codes of practice in dealing with consumer enquiries about Premium Rate Services (09x numbers) and Number Translation Services (084x/087x numbers)?
Answer 3: No.  If it is clear, before a call is made to a NGN, what the pence per minute rate is, then there is little need for dealing with consumer enquiries, as there will be no misunderstanding.

Question 4: Do you believe there are any other options Ofcom should have considered?
Answer 4: Yes.  Simple pricing, readily available, that users can know, so that they can make an informed decision about calling a NGN.

Question 5: Do you agree that landline and mobile network providers’ codes of practice should be available on request and free of charge to their customers?
Answer 5: Yes.

Question 6: Do you agree that the proposed modifications to the code of practice and Dispute Resolution and associated guidelines are sufficient to address the issues relating to NTS (084x/087x numbers) and PRS (09x numbers), described in this consultation?
Answer 6: No.

I don't know whether it's been mentioned yet, but Ofcom has published some research it carried out during the year, since the last consultation. This has been published in [yet another] Ofcom document covering nearly 40 pages. Why didn't it publish this with the consultation? Has anyone actually read this?

From what I've seen of the summary of research in Annex 6, it asks questions like what do consumers think of RS, and how much do they think the calls cost. Complete nonsense as the average consumer cannot understand the ins and outs; the size of the document tells you that!!!

So with those 40 pages, that's nearly 300 pages of consultation/information to read!! 

I've started a new thread on it here, this formatting of this research seems to be wrong. There is a blank page so that the contents is on the right, but no blank page between the contents and page 1. The numbering will be in the middle rather than at the edges of the pages.

Hello

I admire your campaigns valiant attempt to save consumers money by alleviating the need to call 0870 numbers and advising of alternative geographic numbers.

But some issues need to be highlighted before tarring all sevices/numbers  with the same brush.
Some of these services actually provide content which will otherwise be unavailable at such a low rate in comparison to it's benefits. 0870's are not about revenue generation.

As has been suggested a simpler solution would be to have a timed limit or recorded message advising of call charges at beginnining of call and one at regular intervals every ten minutes or so to give consumers a choice rather than depriving them of the benefits of some of these services.

I understand that people should not be left on hold, but if the duration of their actual call is providing some benefit for a small out lay, ie information service, why shouldn't the number at least pay for the cost of producing/updating the service offered.
It seems it is only since the advent of reduced call charges that people have started to jump on the bandwagon and actively complain as they see a difference in the call charges now.

Admittedly there are some horror stories out there such as being on hold waiting for technical support. I agree this is wrong but this is down to problems with service levels which need addressing within the relevant departments( i know this from personal experience having worked in such a department) ,rather than anything intrinsically wrong with an 0870 numbers rates.

People did actually have a choice to pay a reduced charge monthly fee for broadband in exchange for paying more for their calls when technical support is required, and real premium rate calls are only charged when the caller is connected. Again due to the competitiveness of the telecom market, these charges are being replaced with 0845 numbers, and now I have actually received irate calls from customers who were annoyed at paying 3p per minute for support! God knows what happens when everyone is using VOIP and they have to call a standard geographic number.


So instead of rejoicing over the money they are saving  now due to the competitiveness of the telecom market, they are feeling ripped off. Only a few years ago when BT had a monopoly I was spending hundreds of pounds per quarter more than I am now,so the savings due to local loop unbundling etc have initiated a competitive market and effectively make any calls i may make to some very worthwhile 'premium rate' services 'Free'!

I do not actually derive any monetary benefit out of 0870 numbers at present, but had planned to offer a valuable information service using voice recognised technology,so that there would be NO waiting. However i will be unable to offer this service because organisations like saynoto0870  seem keen on cancelling out any potential return which may cover the cost of the technology involved to provide  and update the service. Either by elimination of revenue altogether or by a compulsory warning of 'National Premium Rate' which they are not. This will only confuse the customer.

All this whilst generating revenue yourselves on the saynoto0870.com website by advertising 0870 co's and their offers to make money on calls via their numbers on your website using google advertising.

A bit hypocritical don't you think ! (Below the send button on the contact page , believe it or not) http://www.saynoto0870.com/contact/

Best Regards

Peter Callender

Newcastle upon Tyne

And, Peter, the 'old chestnut' about advertising 0870 numbers on this site has been raised and discussed and explained on many posts.  Have a look.

Hi,

I'm new here and most impressed with your site/service and all this information.

I have a quick query about this consultation. I apologise if it's already been answered - I've been skimming through this 18-page thread and couldn't find it but I hope you'll appreciate it's a bit of a daunting reading task and let me off if I've overlooked it

I was just wondering, with respect to the proposed 0870 number changes (bringing their costs in line with geographical national numbers), if anyone knew approximately when this change would happen (if approved)? I think I saw it say there would be a one-year transition period but I wasn't sure when that would start (and therefore when it would end).

Apologies again if this is a silly/repeated question! Thanks in advance for any help you can offer.

I've been puzzling over this clause and I'm not sure I understand how it would work.

Could someone correct me if I'm wrong? The way I've understood this is that the decision about how to charge 0870 would rest with the phone operator ie BT, Telewest, Onetel, 1899. They could decide to continue charging at 8p per minute as long as they make an announcement about the cost.

Companies that use these 0870 numbers ie British Gas, DVLA, Alliance & Leicester and so on, will get a share of the revenue if the phone operator sticks at 8p and makes the announcement. But if another operator, such as 1899, cuts its charge for 0870 calls to the standard rate for geographic calls (ie 3p per call) there will be no extra revenue to pass on to the company called.

So take an example where BT sticks to 8p but 1899 reverts to its 3p per call with no time charge, as for its geographic calls. If you use BT and you call British Gas you'll be paying 8p per minute and British Gas will take a cut. But if you use 1899 and you call British Gas, you'll be paying a fixed 3p and British Gas will get nothing.

So if you care about how much you pay for this type of call you'll pretty soon switch away from BT and use 1899 instead. The resulting loss of business will eventually (about 10 years if competition from Mercury in the 1990s is anything to go by!) force BT to cut its prices to match 1899.

Is this right? Or have I misunderstood how this would work?

Regarding Ofcom’s  two sets of proposals for consultation.

“Number Translation Services: A Way Forward” and
“Improved Consumer Information about NTS & PRS”

For each consultation, Ofcom have produced a full consultation document, a summary “in plain English” and a set of consultation questions.

The full consultation documents, by their length and complex construction are unintelligible to most readers unless they are willing to spend a week or so poring over the document and related references. When I read them, I was left wondering if I has lost my sense of reason.

The short summary “in Plain English”  leaves out vital information as to the general thrust and intent of the full document, and can not claim to be a summary, but a misleading statement of Ofcom’s true intentions. This is the document on which most will rely as an aid to answering the consultation questions.

The consultation questions, which Ofcom will use to support its findings, are misleading and are designed to produce answers compatible with Ofcom’s proposals.

Question 1: (from “NTS:  A Way Forward”)  Do you agree with our proposal that revenue sharing should no longer be allowed on 0870 calls if the link between 0870 call prices and prices for 01 and 02 geographic calls is restored?

On the face of it, the obvious answer is “yes”.  But few respondent (except the well informed) will realise that Ofcom’s intends to allow 0870 to continue to be charged at 7p, or so, provided the organisation makes an announcement as to cost. This will negate the whole purpose of the proposal and the absence of the mention of this essential loophole in both the summary document and the questionnaire, renders the consultation pointless and bogus.      

Why is an “if” needed in the middle of the question - it should be an “and”.

Does  “... link between 0870 call prices and prices for 01 and 02 geographic calls is restored?”  mean that customers using “BT Option 3" or “Call1899" etc. will be charges 0p/min for the call, or will they be charged 3p/min.

My short comments on the rest of the proposals:

0871 should be changed to an “09" premium number, as should ANY number which charges more than the consumers normal rate.  

0845 should be restored to the same pricing as 01 and 02. (0p/min for Option 3 etc).

0844 should be restored to the same pricing as 01 and 02 (0p/min for Option 3 etc).  
(0844 numbers cost more than 0870 numbers during off peak periods and cost more than 0870 numbers, at all times, from a pay-phone and are just as evil, or more so, than 0870 numbers).

The fact that some 084x numbers are used for internet dial-up, should not be used as an bogus excuse for failing to moving 084x (voice) numbers to the 01 and 02 class of call charges.  The sets of 084x  numbers used for internet dial-up could continue to be an exception to the general rule.

As for the consultation on “Improved consumer Information about NTS and PRS” the solution is simple and clear.  

All calls that charge more than a customers normal rate ("normal rate" including Option 3 etc at 0p/min) should be reclassified as a premium rate numbers and be consigned to the  “09" classification, with a pre announcement and warning as to cost.  Keep it simple.

If you have sent Ofcom a response to the Ofcom Proposals, and after further consideration you feel that you have further comments to make,  

KK                        

Hi Dave

Re my post #267 and your comment #268

Your comment may well be true, but an organization wishing to charge for 0870,  only needs to change to, or join, a telecom provider that offers that service to maintain the scam.  In effect it is the organisation who decides.  Your comment does have force, if all telecom providers refuse to offer revenue sharing on 0870.