It is important to give reasons why you hold the views you do. Hopefully Ofcom will read the Yes/No answers and see no reasoning doesn't give firm basis that the person writing it understood or even thought about the question, and so the answer should be treated dubiously.

An Interesting and much more intelligent response from Totem Communications who appear to be a TCP and say that 65% of their income is derived from Terminating call payments to 08 numbers before any revenue share is handed to the Service Provider (presumably implying that 09 numbers are significantly less profitable for them due to the much lower level of use).  They say that 90 to 95% of their income comes from NTS numbers sold by resellers and that their largest reseller for such numbers is the rather less intelligent Windsor Telecom Ltd.

See www.ofcom.org.uk/consult/condocs/nts_forward/responses/sz/TotemCommunicationsLtd...

They say the changes suggested by Ofcom would have a serious impact on their business model.

But to do them credit they don't suggest its all a fuss about nothing and there is no need for Ofcom to change anything.

Mind you on the Page 9 they were expecting Ofcom not to publish on the website they do disclose "that those who make the most noise" (i.e. this website and its members) may "ruin a perfectly good business model" for them.

But I respect a company that at least in its public view is inclined to express its views in a relatively intelligent way.  And Page 9 does make very interesting reading for so long as it remains there.  I think I have captured most of it above as and when it disappears.

See Mr Velissarides' response from Rapport Telebusiness Consulting:
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He finds it acceptable to have competition drive down prices, but to get some of that 'lost' revenue back through 0870 numbers!

Meanwhile, read the Preston Travel Centre's response. They don't need to use 0870 but they have to call companies they work with on 0870!

Dave wrote on Dec 10^th, 2005 at 4:31pm:

How many tens of thousand dollars did Mr V pay for his last PC? 

The world's successful businesses have innovated, become more efficient and lowered prices. 

In Mr V's world, why should the market be distorted by price-fixing to years-out-of-date tariffs? And why should lazy complacency be subsidised?

Coming back to Totem Communications they basically admit that nearly all their income as a business is derived from the TCP Payments of the 070, 08 and 09 numbers they sell in their own name (the vast minority) and the numbers sold on their behalf by NTS number revendors.  They don't get any income at all it seems from terminating conventional 01/02 number traffic.

So with that being the case how can Ofcom claim that they don't think that money and financial reward is involved as a significant motivation in the use of these numbers and that companies mainly only want to have a national presence, call re-routing facilities etc, etc, blah de blah.

Although I accept that the call centres/service providers don't derive anything like all their income from the NTS revenue share its clear that the TCPs who terminate these calls and sell the numbers do get nearly all their income this way.  And it is this fact that has led to a whole pointless industry being spawned dedicated to foisting as many as possible of these unnecessary numbers on to businesses who don't need them and don't even really benefit from them (given that they are then also caught by the con when they need to make outgoing calls).  As usual Ofcom have been economical with the truth by selecting the facts that support their own apparent determination to keep as much as possible of this wholly worthless scam industry going.

You accuse my submissions to Ofcom of being lengthy Dave but when you are dealing with Ofcom who produced over 300 pages of consultation document and who cannot be given any wriggle room whatsoever then explaining at length why all of Ofcom's attempts to rationalise the use of these numbers are nonsense is in fact essential.  It is those people who have just said Yes, Yes, Yes who will be able to have their views completely manipulated in the way that Ofcom wants.

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This is my point. These companies cherrypick the most lucrative 'services', as you would when running a private business. With telcos offering 'inclusive' call packages, and driving down geographical prices in general, there can hardly be much leeway for profit.

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Well, remember that it's the TCPs who make their money from these numbers. So they 'sell' the likes of 0870 by offering incentives like revenue and services, which they could not offer (financially, anyway) on geographical numbers.

So the only innovation that exists in today's telecom's market is that of how to get more money out of the public, rather than devising new services which provide benefits, and charging a reasonable fee for them.

bbb_uk wrote on Dec 13^th, 2005 at 5:19pm:


I suspect Onetell care slightly more about decent customer service than the likes of Tele2 or TalkTalk.  For instance when they started charging for their 118111 formerly free directory enquiry service they did add a message warning people before the call was connected.  Now can you imagine TalkTalk or a Finarea call brand doing such a thing?  No they would con you with free DQ for a while and then start charging you 50p a shot without telling you.  The first you would know would be on your phone bill.

I feel sure TalkTalk and Vodafone will only ever display NGN call costs with equal prominenence if it is made a legal obligation for them to do so with big fines for non compliance.

And a further very telling and revealing late submission by the Internet Service Providers Association (ISPA).

www.ofcom.org.uk/consult/condocs/nts_forward/responses/gl/ISPA.pdf

This states "ISPA welcomes the significant amendment of Ofcom's initial proposals on the future of NTS.  ISPA has consistently highlighted concerns that the use of 0845 numbers provide an important entry level product for ISPs in the Internet Market..... This response should be read in conjunction with the Position Paper that ISPA submitted to Ofcom in June 2005"

What a shame therefore that the rest of us don't have access to that Position Paper following smoke filled room talks between ISPA and Ofcom that appear to have taken place behind closed doors.

Am I the only one to think that Ofcom's original version of NTS Way Forward proposed also returning 0845 to geographic rates after 12 months at the same time as 0870.  Me thinks ISPA has friends in important places (eg Tony's Cronies) and has got at the original draft version of the NTS Way Forward document to which they obviously seem to have been given unfair special access.

So no wonder we had to wait until mid September instead of early summer for this consultation.  All the while ISPA must have been badgering their contacts to get two more years or more of revenue sharing on 0845.  And no wonder the final cosnsultation proposal to end 0870 revenue share but let it carry on with 0845 looks so mad.

0845 entry level for internet acccess!!!!!  What about 1p per minute 0845 numbers.  And what about £5 per month unlimited dialup with www.v21.co.uk