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,
send in a second amended response.
KK