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Responses to Ofcom consultation hit 1,159 (Read 235,259 times)
NonGeographicalMan
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Re: Read the public's 422 comments to Ofcom here..
Reply #105 - Nov 16th, 2005 at 7:07pm
 
dorf wrote on Nov 16th, 2005 at 7:01pm:
You can see the inextricable commonality between Ofcom and BT can you not? They have the same style of small print and deliberate misinformation. The similarities are far too great to be just coincidence.


I think I am right in saying that several members of the Ofcom Board and quite a few of its senior employees once used to work for BT.  So surely the similarities in approach come as no surprise. Roll Eyes
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dorf
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Re: Read the public's 422 comments to Ofcom here..
Reply #106 - Nov 16th, 2005 at 8:17pm
 
No, they certainly do not NGM and they clearly very overtly continue without any shame or embarrassment whatever.
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Ofcom are completely ineffectual
 
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andy9
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Re: Read the public's 422 comments to Ofcom here..
Reply #107 - Nov 17th, 2005 at 12:10am
 
apologies for going back a bit to the man from C&W
Quote:
As Marketing Manager at Cable & Wireless in the mid 90's, I was the first to introduce such a revenue share scheme as part of the "TeleBusiness Addvantage" pricing package for non-geographic numbers.

It was my view at the time, and still is, that in industries where the customer and competition is increasingly driving down costs of products and services, that some of that 0870 revenue should be returned to the company who was ultimately generating it (the corporate user).


What has never been explained, and perhaps never will be properly, is that BT rates stayed at 8p/min for national calls for years, whilst other providers like C&W and Energis opened up the use of 0870 numbers which they were able to route for around 3p/minute but charge more.

Someone better at history than me may be able to say when other providers came into the corporate market, and how much later into retail. This is the true moment when 0870 mispricing was born, even though it stayed latent for years longer, until national rate was dropped to 3p/min.

That is the trouble with the whole argument - like asking for directions in another country, and the reply "If I was you I wouldn't start from here". The market was deregulated only in irregular steps; the re-numbering was cocked up; other countries have a range of non-geographic numbers that at least give some indication of tariffs, like France and Austria.

There is a place for some non-geographic numbers, like call-through to international, or internet access, as long as the tariffs are clearer. I don't think that they need to move all numbers to 09... ; a transition to a wider range of 08 numbers as mentioned above would be fine.


Incidentally, about Energis, possibly the first 08706 provider - I read on their website recently a press release that they and Siemens had jointly won a contract with the BBC for telephone distribution. I intended to post it around here somewhere, but their site is now defunct after the C&W takeover. I don't know if this supersedes the Capita deal that others have mentioned or complements it ...
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« Last Edit: Nov 17th, 2005 at 3:20am by andy9 »  
 
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dorf
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Re: Read the public's 422 comments to Ofcom here..
Reply #108 - Nov 17th, 2005 at 9:14am
 
Andy9 I am afraid I could not disagree more about your implied belief that it is acceptable for some non-09 NGN uses such as connections to ISPs and call-through international providers to continue to be Revenue Sharing (used as disguised Premium numbers).

You ask for the history of it. Well, when the National Telephone Numbering Plan (NTNP) was introduced one of the key concepts was to move all Revenue Sharing (Premium) numbers, which previously had been littered within various unidentifiable code blocks to 09 by decree. From then on no Premium use was to have been allowed in any other block, and all call queuing was prohibited on Premium numbers. The purpose of this was to ensure that the Citizen Consumer could thenceforth easily identify and know which numbers were Premium numbers, and to protect the Citizen Consumer from the inevitable abuses which had already then occurred with queuing.

I think you will find that it was BT who first commenced abusing other NGN blocks and using them as disguised Premium numbers. The first abuse I recall was with ISPs. Oftel went to sleep, or more likely were encouraged directly to accept it, and did nothing to cease or prohibit this first abuse of the NTNP by BT. BT thus encouraged then began to similarly abuse other blocks in the same way and Oftel did nothing. The term "Revenue Sharing" was in fact invented by BT and Oftel when the questions began to be asked about the abuses, to attempt to conceal the fact that these were direct abuses of the NTNP with other NGNs being used as Premium numbers. Oftel claimed that "Revenue Sharing" was completely different to Premium use, whereas the mechanism and the effect is identical.

Even though Ofcom now change the NTNP increasingly frequently to justify and allow the increasing abuses as they are asked by telcos, at present the NTNP still defines clearly that all Premium use must be within the 09 category only and that call queuing is prohibited. Ofcom have in effect now introduced a major conflict in the NTNP, and the position is entirely similar to the commandments written on the barn wall in Orwell's "Animal Farm". They get changed each night to permit the latest round of abuses which the telcos want to be able to perpetrate! Clearly none of this is in the interest of the Citizen Consumer.

So I must completely disagree with you on this point. The root of the problem is that as that as Ofcom  have played their game of deceit they have become hoisted by their own petard, just like the Pigs. They have altered part of the NTNP one night to allow the abuses, but they have overlooked the fact that since they did not alter the definition for the 09 category, since this could hardly be done in any suitable way which would not be completely blatant and outrageous, there is now a foundational conflict in the NTNP. The only true way in which they are in reality forced to address this is to move all revenue sharing uses where they belonged in the original NTNP and even within the Pigs currently mutilated NTNP. All Revenue Sharing numbers must be in the category 09 according to the NTNP, and call queuing must be prohibited.
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« Last Edit: Nov 17th, 2005 at 4:12pm by dorf »  

Ofcom are completely ineffectual
 
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NonGeographicalMan
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Re: Read the public's 422 comments to Ofcom here..
Reply #109 - Nov 17th, 2005 at 10:10am
 
dorf wrote on Nov 17th, 2005 at 9:14am:
Ofcom have in effect now introduced a major conflict in the NTNP, and the position is entirely similar to the commandments written on the barn wall in Orwell's "Animal Farm".

The root of the problem is that as that as Ofcom  have played their game of deceit they have become hoisted by their own petard, just like the Pigs. The only true way in which they are in reality forced to address this is to move all revenue sharing uses where they belonged in the original NTNP and even within the Pigs currently mutilated NTNP


dorf,

I think your Animal Farm analogy is especially appropriate for Ofcom.  But of course I believe Animal Farm can also be applied to New Labour, although it is so many years since I read it that I forget who exactly would be Snowball or Napoleon within the New Labour apparatus.
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Kiwi_g
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Re: Read the public's 422 comments to Ofcom here..
Reply #110 - Nov 17th, 2005 at 11:56am
 
I too think that there is a place for revenue sharing on 08xx numbers in respect of call-through to international, or internet access numbers.

My employer bars access to 09xx premium and international numbers (yes, I know that it’s short-sighted as calls to mobiles cost more than some international numbers).  I have also been known to use an 0844 call-through number to access a UK number so as to hide the number I am contacting (sneaky, I’m afraid).

Has this problem been considered?
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NonGeographicalMan
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Re: Read the public's 422 comments to Ofcom here..
Reply #111 - Nov 17th, 2005 at 12:27pm
 
Kiwi_g wrote on Nov 17th, 2005 at 11:56am:
I too think that there is a place for revenue sharing on 08xx numbers in respect of call-through to international, or internet access numbers.

My employer bars access to 09xx premium and international numbers (yes, I know that it’s short-sighted as calls to mobiles cost more than some international numbers).  I have also been known to use an 0844 call-through number to access a UK number so as to hide the number I am contacting (sneaky, I’m afraid).

Has this problem been considered?


In my view if all revenue share calls (even at 1p per minute) had to move to 09 there would be a fundamental shift of attitude by people such as your employers and they would have to allow access to all 09 numbers charging up to say 10p per minute.  The 09 codes are allocated in such a way in terms of price that this should be possible.

Once 09 numbers were not just sex chat lines but also some legitimate services at up to 10p or even 20p per minute they would have to focus more effort on just banning the high priced 09 games and sex chat lines.

If you have an employer who monitors your phone calling patterns the best solution is to get a cheap mobile phone with inclusive minutes such as those available for very little with Three.
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bbb_uk
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Re: Read the public's 422 comments to Ofcom here..
Reply #112 - Nov 17th, 2005 at 12:42pm
 
I agree NGM except not sure about PAYG dial-up but really PAYG dial-up should have been allocated it's own number anyhow same as dial-up for schools.

If ofcom aren't going to do nothing about 0844 (which we all know they wont) then they should, at the very least, prohibit call queuing on these numbers in the interim.  So all those companies that are going to migrate over to these numbers will not gain any money from us for queuing for 20+ mins and only when we actually speak to a human will we be charged.  I've found that the queuing is generally longer than the time you are on the phone speaking to a human.
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NonGeographicalMan
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Re: Read the public's 422 comments to Ofcom here..
Reply #113 - Nov 17th, 2005 at 1:02pm
 
bbb_uk wrote on Nov 17th, 2005 at 12:42pm:
I agree NGM except not sure about PAYG dial-up but really PAYG dial-up should have been allocated it's own number anyhow same as dial-up for schools.

If ofcom aren't going to do nothing about 0844 (which we all know they wont) then they should, at the very least, prohibit call queuing on these numbers in the interim.  So all those companies that are going to migrate over to these numbers will not gain any money from us for queuing for 20+ mins and only when we actually speak to a human will we be charged.  I've found that the queuing is generally longer than the time you are on the phone speaking to a human.


bbb,

what are you in effect saying is that Ofcom's proposals should also have put 0844 under ICSTIS control which is a point all of us should be making in our submissions to Ofcom.

But in my view any revenue sharing number under ICSTIS control should be on an 09 code.  However there could of course be a separate number prefix starting say 04 for revenue sharing numbers controlled by ICSTIS at say 15p per minute or less.  Perhaps this would get over the call barring problem for dial though call access services etc whilst not having the negative connotations that ISPs fear if they had to start using an 09 code.  Although to be honest by the time these proposals come in during mid 2007 you are sure to be able to get some flavour of broadband for £7.50 per month and the need for dialup wil be ever diminishing.
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dorf
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Re: Read the public's 422 comments to Ofcom here..
Reply #114 - Nov 17th, 2005 at 2:36pm
 
But NGM that would still defeat the purpose and spirit of the NTNP. The purpose was that all revenue sharing numbers should be moved to 09 and queuing prohibited. The foundational reason was so that Citizen Consumers can easily recognise which numbers are revenue sharing numbers. To speak of having other number blocks which may have revenue sharing for different purposes is a retrograde step, and a reversion to the confusion and disparity which the NTNP plan was designed originally to end.

I see no reason that sub-categories of the 09 bank cannot be provided at different cost rates for all of the applications which you mention, and I believe that is the only way for the true interests of the Citizen Consumer to be met.
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Ofcom are completely ineffectual
 
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NonGeographicalMan
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Re: Read the public's 422 comments to Ofcom here..
Reply #115 - Nov 17th, 2005 at 2:56pm
 
dorf wrote on Nov 17th, 2005 at 2:36pm:
But NGM that would still defeat the purpose and spirit of the NTNP. The purpose was that all revenue sharing numbers should be moved to 09 and queuing prohibited. The foundational reason was so that Citizen Consumers can easily recognise which numbers are revenue sharing numbers. To speak of having other number blocks which may have revenue sharing for different purposes is a retrograde step, and a reversion to the confusion and disparity which the NTNP plan was designed originally to end.

I see no reason that sub-categories of the 09 bank cannot be provided at different cost rates for all of the applications which you mention, and I believe that is the only way for the true interests of the Citizen Consumer to be met.


Dorf,

I mostly agree with your stand of principle on only using 09 for revenue share and I would of course make 070 PNS illegal and force it to move to 09 for that very reason.

However knowing how the Ofcom mind works I can see that they would say that forcing lower cost revenue sharers to use the very negatively associated 09 prefix might destroy their business and these calls might then be barred by corporate switchboards etc for historic reasons.  And surely you would agree that having a second 04 revenue share access whilst eliminating all 08 revenue share might be a better outcome than allowing revenue share to continue on 0871 and 0844 as Ofcom propose.

I would actually take up a suggestion made by idb and somehow make the 0870 and 0845 codes themselves start 01 and 02 (even if it meant a new access code for all these numbers) once they were returned to geographic pricing and I would retain the 08 prefix for freephone calls alone as was clearly originally intended.

But realistically the useless fudging, compromising and in the pocket of telcos Ofcom won't do any of these things and will make the minimum change possible to least disadvantage its telco chums.  And then soon we will be faced with the whole different problem of Voip to Voip only services that want to charge callers for the privilege.  So the game will start all over again.
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dorf
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Re: Read the public's 422 comments to Ofcom here..
Reply #116 - Nov 17th, 2005 at 4:09pm
 
Yes of course you are correct with the realities of these things NGM, and what Ofcom will actually do; and of course you are completely correct with regard to 070 PNS. However I sense that you do in fact essentially agree with my point about the NTNP.

What Ofcom want to do is to have their cake and eat it so to speak. It was the regulators who implemented the NTNP (the plan). They are supposed to be the regulators which means they are supposed to "regulate" the telcos. Instead they have allowed the exact opposite to occur, and instead of regulating according to the regulations, their remit and the NTNP they have allowed the telcos to drive a coach and horses through all of it, and then in addition have changed the regulations and the NTNP bit by bit to whatever the telcos demand that they want to do.

That is not regulation. That is conspiracy!

I do not see that one subdivision of the 09 category could not be allocated for all these lower cost uses, and treated by the telcos differently for Premium call banning purposes on subscriber's services. In other words there should be two levels of Premium call banning operated by telcos: one which bans all except the lower cost category calls (thus not banning ISPs etc. on the equivalent of the present 0845) and another which bans ALL 09 calls. I would myself have the one banning ALL 09 calls, and at present I have 09 banning.
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« Last Edit: Nov 17th, 2005 at 4:10pm by dorf »  

Ofcom are completely ineffectual
 
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Re: Read the public's 422 comments to Ofcom here..
Reply #117 - Nov 17th, 2005 at 7:22pm
 
Quote:
what are you in effect saying is that Ofcom's proposals should also have put 0844 under ICSTIS control which is a point all of us should be making in our submissions to Ofcom.
Yes that's my point.  They obviously don't have any plans on 0844 at all really so the very least they could do is put them under ICSTIS control.

0844 aren't that common as yet simply because businesses are probably unaware of them but they are all familiar with 087x, 0845.  An 0844 can cost more than a 0845 so ofcom should do something more like putting them under ICSTIS control especially as I suspect those companies like Sky, etc that use nothing but 0870 purely for the revenue will just move to 0844 and if ofcom don't do nothing now then that means another couple of years (going by ofcom's standards for getting things done) before 0844 is put under ICSTIS control or remove revenue sharing from it.  They need to think ahead more instead of thinking very, very short-term.

The number of responses ofcom have received so far should be a good idea of the scale of consumer dissatisfaction of these numbers but as with anything else unless everyone complains to ofcom they claim they don't know the level of dissatisfaction so they'll leave it alone.

As for 09x numbers, I believe confidence in them has dropped due to all the scams.  ICSTIS tries it's best but the scams earn that much that the pathetic fines they get are just equivalent to a days intake (or even a couple of hours depending on the scam).  The fines should either be unlimited or a percentage of the income received from these scams.
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NonGeographicalMan
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Re: Read the public's 422 comments to Ofcom here..
Reply #118 - Nov 17th, 2005 at 7:35pm
 
bbb_uk wrote on Nov 17th, 2005 at 7:22pm:
[quote author=NonGeographicalMan link=1129806310/105#113 date=1132232567]As for 09x numbers, I believe confidence in them has dropped due to all the scams.  ICSTIS tries it's best but the scams earn that much that the pathetic fines they get are just equivalent to a days intake (or even a couple of hours depending on the scam).  The fines should either be unlimited or a percentage of the income received from these scams.


None of these 09 scams would happen if 09 numbers were deactivated by default on a subscriber line and could only be used by the subsciber requesting a PIN number that had to be entered before any 09 call.  It would then be the subscriber's choice as to whether they shared the PIN number with anyone else in the household.  If this was combined with compulsory price announcement the rogue dialler scams could not happen and people's kids and cleaners could not dial these numbers knowing that they don't have to pay the bill.

But Ofcom have permitted a system that deliberately allows the scams of their friends in the telecoms industry to continue totally unchallenged.  Ofcom are seemingly on the side of and secretly condone almost all forms of telecoms scamming because they claim all of this as valuable economic activity it would be a shame to lose.  Don't forget that for very 09 scammer who operates a part of the proceeds are usually also going into the pocket of BT for routing the calls. Roll Eyes
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AJR
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Re: Read the public's 422 comments to Ofcom here..
Reply #119 - Nov 18th, 2005 at 7:47am
 
No new submissions on the Ofcom website since Nov 15.
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