It's interesting that Ofcom is continuing with the local/national rate distinction. It's proposal for the 03 prefixed numbers will allow for local and nationally charged numbers, for tariffs that differentiate. What concerns me, is why would any organisation wish to charge so-called national rate over local rate?

There must be something in it for the receiving party, else it will be a pointless exercise. Will the terminating telcos charge more to terminate national calls? If so, will this force up the cost of calls as a whole? Going back to the days when it cost more to call longer distance, is this going to create an artificial [virtual] distance/cost barrier?

If the terminating (NGN) provider charges the same, then it will be originating telcos (principally BT from people on Light User Scheme) that will pocket.

gdh82 wrote on May 21^st, 2006 at 6:08pm:

Yes, I have wondered what are the legal implications. For example, imagine a provider that charges its national rate for national 03 numbers and its local rate for local 03 numbers. Now, what happens if this provider charges local rate for local geographical calls, but also charges local rate for national calls?

Legally can it do this? Or will the 'rules' as set out in the National Telephone Numbering Plan that dictate that the price a telco charges for national calls and the price it charges for 03 national must be the same, unless an announcement is given.

I'm no legal expert, but could a telco go to court and claim that it does charge local and national rates for 03, but chooses, as a concession to its customers to 'sell' national calls for the price of it charges for local calls? It may be described as "commercial discretion" or an "ongoing promotion."

Dave wrote on May 21^st, 2006 at 6:27pm:


Another valid point, Dave.  I'm afraid I'm not able to give much of an answer but other more experienced members may be better placed.  This wouldn't be an issue, however, if Ofcom agreed to finally do away with this local/national distinction as this is what seems to be happening in practice anyway.  And if it doesn't and the numbering plan doesn't clarify matters then confusion will reign as it does today 

At this late stage it may be of some use to make a few comment about the consultation.  Ofcom evidently did not like the outcome of the previous NTS consultation and aims to bury its outcome with a further obfuscating consultation.  The consultation questions are often loaded and seek to guide you down avenues which I suspect most reader do not wish to travel.  Keep focussed and don’t be sidetracked by some of the questions.  If you don’t like a question, ignore it, or repeat your position on the 084x and 087x travesty.  You may wish to ignore the questions entirely or prefix them with some general comments.  

For what its worth, I have reproduced the first part of my response.

Comments About the Consultation.

This is yet another consultation relating to telephone numbering and although wider in scope than previous consultations, it again covers much the same ground. The previous consultation on NTL numbering had an unprecedented response (well over 1000), but as that consultation produced the “wrong conclusions”, in being critical of Ofcoms failure to properly regulate revenue sharing in the “08" range (084x and 087x). Ofcom have resorted to the device of producing an over complex consultation document, which will deter most from responding. Ofcom generally ignore consultation responses.

The primary aim of a number plan should be to produce telephone number ranges that are readily recognised both in function and cost by the vast majority of callers. The proposals outlined by Ofcom fail in that aim. The function of “01”, “02” and the proposed “03”, appear clear, but time will tell. If  “03” emerges as described (treated in all respects like the current 01/02 numbers and revenue sharing prohibited), that range should not present any problem to consumers. Removing “070” (so called personal numbers) from the rest of the mobile numbers is also to be welcomed.

The remainder of the proposals keep and perpetuate the current problems and make matters worse. The proposals keep the mix of revenue sharing numbers (087x and 084x) together with free-phone numbers. The current “08” range is a fertile ground for scams, deceits and half truths, practiced by telecom companies and organisations.

The only honest and transparent reform is to confine all revenue sharing and “above normal” tariff numbers to one single designated range. That range is the “09” range which can accommodate 1,000,000,000 number combinations. Prices in a reorganised and reformed “09” range could run from 1p to 150p/minute, so “low cost” revenue sharing numbers can be accommodated as well as more expensive numbers.

We should have a simple and transparent rule: If the number to be dialled (apart from mobiles) is revenue sharing and/or not included in the normal schemes and tariffs then it must be places in an appropriate sub range of “09”. The only reason for not adopting that simple coherent solution is to aid organisations and telecom providers that wish to make hidden charges to consumers.


My Response in a Nut Shell.

“01 & 02"   This range should be left as it is.
“03"           It is proposed that this range should be non-geographic and non revenue sharing. This is fine provided 03 is treated in the same was as 01/02 as regards inclusion in various call schemes.  This range should only have one set of tariffs, the idea that “03" could be split into “national” and “local call” rate is nonsense and flies in the face of the reality of call costing in the 01/02 range, which to all intents and purposes has one universal rate.
“04"          Reserved
“05"          No change
“06"         This range should be reserved.  All revenue sharing should be confined to a suitable sub-range of “09".  The proposal to remove the 070 (personal numbers) range is fine, but it should not be moved to the “06" range.  This will provide another fertile ground for various scams. “070" should be moved to an appropriate sub-range in “09".  For example, “097" can hold over 99 million numbers.
“07"        The proposal to confine this range to mobile telephones only, is to be welcomed.

“08"        Should be free-phone only.
084x and 087x should migrate to "09" or "03", depending on price structure required.  Keeping parts of the 08 range for revenue sharing would be to continue and make worse the scope for scams and deceitful practices.  I can not see any logical objection to the number plan being transparent - all land line numbers that cost more than normal or are excluded from the various call packages should be places in an appropriate sub-class of “09" .

“09"      Any land-line number which cost more than the normal rate and/or is excluded from a consumers call options at 0p/min, should be placed into this range. With charges ranging from 1p/min to 150p/min. So that so called “low cost” revenue sharing numbers can be accommodated into the “09" range. A three second, pre announcement as to cost, should be made.

The 11 digit “09" class can be split into 090, 091, 092, 093, 094, 095, 096, 097, 098 and 099 sub-classes, each sub-class having 99,999,900 different numbers (allowing for, say, 100 unusable combinations). The total capacity of the full “09" range would be up to 1,000,000,000. number combinations.

For example:

continued  .........

Thanks KK.  I'm still working on my submission but it will have much in common with yours  .   Personally I find it very helpful when other forum members share their responses like this - cheers 

Expect yet another consultation reviewing the 'service definitions' used within the numbering plan. 
Quote:

The suggestion of charging for numbers is mentioned, and different methods are put forward for deliberation. Such examples include charging for numbers on allocation and annually. It also suggests that the cost could be varied depending on the service type (i.e. number prefix) or when numbers are more scarce.

As a consumer, I have no idea how this would actually effect the industry. So will it mean higher telephone bills for us?

And by charging more for areas/prefixes with fewer free blocks, I think it will actually serve to drive out competition [does it really exist anyway? ] in those areas. Ofcom's first priority should be to make sure that there's a plentiful supply and that they're not wasted.

Dave wrote on May 23^rd, 2006 at 9:17pm:
I believe it will mean higher costs in some areas for landline owners.  It will also impact businesses/gov depts/organisations, etc because chances are their underlying teleco will pass the cost on to the business/gov dept/organisation which will then pass it on to us by higher costs in products, etc.

Ultimately, I believe it will be passed on to us end users/consumers in some way or another.

As for competition? - I also can't see there being any except for businesses that may fight over "gold" type numbers but then they end up using NGN's anyhow!