My submission has also been sent.

I may publish it here in due course.

Continued/...

3) I would therefore like to object in the strongest possible terms to Ofcom's statement in Paragraph 9 of the proposed revised guidance that "examples of services that may not fit the traditional mode of personal numbering but which Ofcom considers to be legitimate uses of Personal Numbering Services include:-"numbers intended for use in internet chat rooms, numbers intended solely for the purposes of selling and numbers allocated to hospital patients so that they can have their own number for the duration of the stay".  The characteristic feature of all these attempts to vary PNS usage terms by Ofcom seems to me to be that although at the very moment they are used they do route calls directly to the personal number user they are not actually able to be retained by the end user or redirected by the end user to other mobile or fixed line numbers in the manner originally intended for personal numbers.  In fact the consequences of such a permission by Ofcom is to drive a coach and horses through the whole National Telephone Number Plan so that what we are faced with is higher priced Special Services numbers that should be controlled by ICSTIS but are instead allowed to be operated on the 070 number code without adequate awareness of or notification to those calling the numbers that they are charged at rates of up to £30 an hour.

4) For Ofcom to claim that this use of PNS is legitimate is for Ofcom to merely look for a way to rewrite its own acceptable use guidance so as to legitimise the activities of all existing 070 PNS number users, especially users providing access to hospital patients, that were in fact quite clearly outside the intentions for which 070 PNS numbers were originally set up.  And although those intentions are I think in hindsight themselves very questionable, and although all such uses could legitimately have been confined entirely to 09 premium rate numbers, if there was a legitimate use it was actually for individuals who intended to keep the numbers long term and reassign them to different fixed line and mobile phones regularly, under their own control and for their own convenience.

5) It is utterly clear to me that numbers assigned to hospital patients for simply the duration of their stay in hospital do not meet the spirit or  the letter of the intended original use of PNS, even when the number does at least lead to the bedside of the individual in hospital who needs to be called.

6) It is abundantly clear that by trying to draw a distinction between NTS numbers where the called party can share revenue and those that cannot share revenue in this way that Ofcom is not acting in the best interest of citizens and consumers but is instead acting to legalise the abuses of the National Telephone Number Plan perpetrated by certain parts of the telecoms industry.  In my opinion this is because too many staff at a senior level at Ofcom have recently worked in those industries and so are unable to adequately separate the best interests of the uk citizens and consumers Ofcom is supposed to protect from the best interests of telecommunications companies

7) In my opinion there are no circumstances that justify allowing those staying in hospital to only be given access to a monopoly fixed line phone service at the patient bedside at rates of up to 50p per minute that do not also justify such services being properly regulated by ICSTIS as Premium Rate and assigned 09 telephone numbers with all the requirements for cost disclosure that entails.

8 In my opinion because of the potential confusion of the 070 access number with being a mobile phone number and the likelihood of people calling such numbers on other mobile phones expecting to be able to use inclusive cross network minutes the whole concept of 070 personal numbers is now entirely wrong and flawed and the numbers should be reassigned to an 09 prefix code.  Whether or not a revenue share is involved to the end user is utterly immaterial to the caller who only cares about being made properly aware of what they are likely to have to pay for the call.

9) However even if one accepts for a moment the concept of legitimate personal number use these hospital services most certainly do not meet its requirements because the Personal Number is not under the control of the patient, is not permanently assigned to them so that they can use it when they come back to hospital a few months later in a different bed or even a different hospital. In addition the numbers cannot, as far as I know, be redirected to their mobile phone or landline when they eventually leave hospital as again would be expected of any legitimate 070 PNS use.

10) Ofcom does not seem to have thought through properly or logically the potentially appalling consequence of legitimising PNS use for such applications and an obvious next step would be to encourage numerous operators of fixed line telephone services to student rooms in student halls to attempt to offer the services on 070 numbers at up to 50p per minute instead of the 0844/0845/0870 and 0871 Special Service Numbers that they currently use at significantly lower call rates.

In summary this Guidance on Personal Number is not in the best interests of uk citizens and consumers for the reasons set out above and should be replaced by Ofcom with proposals for a revised guidance that is in the best interests of those uk citizens and consumers

Regards............

Several consumers have responded, including Dr Feltham. The sentiments of consumers' responses are generally the same, and the hospital uses figure highly.

The only PNS provider to respond is FleXtel. It suggests that price transparency is needed in the UK telecoms market, and suggests that telcos should provide call price announcements. A 1xx prefix would be used to turn this on or off.

Responses from TUFF (Telecommunications UK Fraud Forum) and VOPNS (Victims of PNS) mention the scams and AIT (artificial inflation of traffic) that takes place with 070 numbers.

Quote:

Oh, I responded. 

I recognise a few familiar names who are members on here.

The two Anons, they were very similar, just a bit reworded. Both refer to 07 personal numbers, as opposed to 070 personal numbers. I could be forgiven for thinking that they were written by the same person.