Domain name:
        payzone.co.uk

     Registrant:
        Alphyra UK Ltd

     Registrant type:
        UK Limited Company, (Company number: 3102137)

     Registrant's address:
        Alphyra UK Ltd
        22 Ridge Way
        Donibristle Industrial Estate
        Dalgety Bay
        Dunfermline
        Fife
        KY11 9JN
        GB

Thanks so much for taking the time to reply, though unfortuantely I still fail to understand the main reasoning for using an 0870 for mPark in Edinburgh. Your main reasoning is that you require a non geographic number (NGN) as you have a national presence in the UK. This would make some sense if you have a centralised number, but for each of your 3 UK locations you list a different 0870 number in anycase. In the past NGN's have sometimes been justified as callers from outside a particular geographical area code may be discriminated against in having to make a 'long distance call', however in your specific case I can assure you that all of the calls to your specific 0870 840 1000 will be coming from Edinburgh only. Moreover, as the system is designed to be exclusively used from mobile phones, it is a well known fact that mobiles do not differentiate rates between different geographic are codes. In addition you have stated it is a mandatory requirement to use an NGN for a business such as yours. I have been assured by OFCOM that this is most certainly not the case.

I also still fail to understand why in other countries the system does not use a high rate number as here in the UK. You may be right about 10% surcharges in Australia, USA etc. but I also mentioned your home market in Dublin where you clearly operate a normal Dublin area code number. In addition unlike what you have told me, there is no further surcharge on parking via mPark in Dublin as it states clearly on your website!

I fail to see why UK users are being discriminated against by having to pay higher charges to access the service? Moreover you state that the phone call should cost no more than 10p. I can prove to you that there are several tariffs that have a 1 minute minimum call charge and where calls to 0870's can cost upto 40p/min and so in some cases can actually cost more than the cost of the parking. Unfortunately the vast majority of this additional income will no be going to either Edinburgh council or indeed to mPark as it will be taken by the line operator. It will clearly have no benefit to improving services in this city.

I have therefore also taken the matter up with the city council. I am primarily interested in knowing if there is an equivalent geographic number that can also be called to access the service. In any case, you may be aware that in the next few months, new OFCOM regulations come into play regarding 0870 numbers, which will diminish the revenue share on these, and operators will be likely to instead incurr incoming charges on these. Unless you change these numbers to a true premium number, it may be in mParks interest to circulate geographic numbers.

Thank you for you very detailed response.  I am disappointed that you still have a difficulty with the 0870 number.  I can tell you that you have made several assumptions which are incorrect.  I hope the explanation below will assist you further.

NGN’s are used for 2 purposes.  One you accurately describe in your mail in great detail.  The other is when you are offering a service in many locations and the terminating number is in one central location.  You are also working on the assumption that the IVR equipment is within the Edinburgh area code, which it isn’t.

Also, we have several failover sites which automatically reroute the 0870 number in the case of a problem, of capacity issue.  Security considerations are also a concern.

I would welcome any reports, or actions taken by OFCOM with the mobile operators on charging structures, but I assure you they will have no difficulty with any aspects of the mPark operation.

In your research, you should have noticed that Edinburgh is one of only 2 councils in the UK who do not charge a premium for mobile phone parking in the UK .  It is standard for other cities to charge 20p or 30p for the service.

In Ireland you are correct, there is a local Dublin number.  If this could easily be changed it would.  It has limited greatly our flexibility in upgrading the service and has resulted in many calls from customers in other cities looking for a local number for them.  

To summarise, I am disappointed that you didn’t accept the earlier explanation and I hope this explains a little further the background to the choices that are made with regard to 0870 usage.  I hope it doesn’t deter from the use of the service.  Please also remember that using mPark is an option, and the cash facility is still there in all parking zones.