I am pleased that you have re-opened consultation on the use of revenue sharing phone numbers. From contact with friends and colleagues it has become clear to me that there is a significant and increasing degree of concern about the use of these numbers. There is much concern with the exploitation of this facility by organisations that couple them with an understaffed call centre as a means of revenue generation from customers with no alternatives.

An extreme example of this insult to the citizens of this country was the use of an 0870 number as the contact number following the 7th July terrorist attacks in London. I contacted my MP and the Home Office on this occasion, and I am pleased to say that I received a reply from the Home Office stating that they would not be using 0870 numbers in future emergencies.

It is good to see that unlike the your original proposals the latest document goes much further in recognising and dealing with the concerns of telephone users. I welcome particularly your proposal that calls to 0870 numbers will in future be charged at the rate provided in the package the caller has contracted with his/her phone provider – this is especially good news as packages that provide free UK landline calls for the payment of a flat monthly charge are becoming more popular – it is an option I use myself.

I still do have some problems with your proposals though, detailed below:

I am greatly concerned that you suggest that organisations would still be allowed to charge premium rates for 0870 numbers so long as they notify the caller in advance. This is an enormous loophole that will be exploited immediately, with many organisations moving to this model. Essentially it preserves the status quo – a very attractive state of affairs for organisations that have become comfortable with a continuous revenue stream from callers. This option needs to be removed, or only allowed if a geographic number is offered as an alternative. If this is not done your proposals will be worthless in practice.

The lack of clarity as to what will happen to 0845 numbers after 2 years is troubling. It is probable that a significant number of organisations will switch their 0870 numbers
to 0845 ones. The revenue they receive will be less, but they still will get something, which will be in some measure attractive to them.

I note that in your consultation document you indicate that 0845 numbers are being treated more tolerantly as many internet dial-up services use these numbers. This may well be true, but I am sure you are aware that dial-up internet services are decreasing in number as more and more people use broadband. As a result this will be a diminishing problem. If you do have to make special arrangements for 0845 numbers I suggest you restrict this to internet dial-up services only and/or insist that a geographic alternative number is provided in all cases. If this is not done I am sure this loophole will be aggressively used by a large number of organisations.

While I appreciate that there needs to be time for service providers to adjust to the new regulated structure, I believe one year for 0870 numbers and two years for 0845 numbers is excessive. This is particularly true for 0845 where there is no proposal to fully address the issue at the end of the period.

Your remonstration in the document that public bodies should not use these numbers is nowhere near robust enough. Innumerable Government Departments and Agencies use these numbers and the BBC seems to use nothing else. Even their consumer affairs programs use 0870 numbers which is at the very least ironic! In spite of public protest I can detect no evidence of revenue-sharing number use diminishing – quite the contrary in fact. There needs to be a much stronger form of words in your final proposal with an insistence that public bodies do not use these numbers unless they can provide a convincing case to you. In other words, shift the burden of justification.

I hope these comments are of use to you. I will be copying them to my MP and other interested parties. I look forward greatly to reading the regulations you ultimately produce