My draft response:
Removal of BT price regulation in the retail telephone market is ideal, but only if true competition exists and that can only exist when true price transparency exists.
Price competition does exist for telephone calls to “01" and “02" UK telephone number and to calls to locations outside the UK. The call cost to any UK location using companies such as
www.18185.co.uk,
www.call18866.co.uk and
www.call1899.com are free, save for a small connection fee of 3 or 4p. Call to Australia, Brazil, Italy and USA (to name but a few) cost 1p per minute or less, using the above alternative companies.
The above, contrasts sharply with the cost of non-geographic revenue sharing numbers used in the UK. - that is, numbers beginning with “084x, 087x, 070 or 09".
Although full price transparency does not exist with the “09" range of numbers, consumers are aware that calls beginning with “09" are more expensive than normal and are not included in various call packages (like BT’s option 2 or 3) and are NOT less expensive if an alternative supplier is used. No real competition exists in the “09" range of telephone numbers, but at least the fact that they are different in cost (and treated differently) to a normal call is widely understood.
Again price transparency does not exist with numbers beginning with “084x, 087x and 070" and they are also not included in call packages etc.. In the above number ranges, lack of competition is more damaging to the consumer, as consumers are often deceived as to the true nature and cost of calls to those numbers. Few consumers realise that the numbers are revenue sharing. No significant competition exists, or is possible by the very nature and structure of 084x, 087x and 070 numbers; telecom companies push the use of the numbers as they can make hidden profits from their use.
Price transparency would exist if all revenue sharing number, without exception, had to be located within a suitable sub-range of “09". The “09" range can hold 1,000 million number combination. The sub-ranges could be prices from 1p to 150p/minute. A three second price announcement, would be ideal.
If Ofcom does approve deregulation of prices, ( it usually does what it likes, notwithstanding the results of consultations) then it should, in a short time scale, put forward measures to implement true price transparency and competition in revenue sharing numbers. Ofcom should also seek undertakings from BT that they will put in place measures that aid true price transparency and not make misleading statements to help organisations deceive consumers as to the true nature and cost of calls to 087x and 084x numbers.
Ofcom’s chosen option is based on assurances from BT, but before reliance can be place upon those assurances, Ofcom should ask itself if BT can be trusted to act in the spirit and the letter of any arrangement. All BT’s domestic customers are placed on either Option 1, 2 or 3 - Option 1 is the default option. Local and National calls cost the same for 99.9% of customers. BT retain the almost fictional destination between local and national call costs, and calls it “the standard call tariff”. Only the comparative small number of customers on BT’s special “low user scheme” pay the so called standard rate.
We have the undesirable situation in which BT’s “standard tariff” is not the standard tariff at all, and for all practical purposes all 01/02 calls coast 3p/min or less. The existence of the largely fictional “standard tariff”, which makes a distinction between local and national calls, allows organisations to claim that “0845 is only a local rate call”. When I recently complained about the call cost of my local HSBC branch converting to “0845", it required quite a complex letter of complaint. In reply, HSBC was able to say that “0845" was a “local rate call” and implied that they were doing me a favour in changing from a geographical number to “0845". The same is true for the pernicious “0844" numbers which telecom companies are increasingly persuading organisations to use, under the guise of “it’s only a local call” or is generally perceived as such. It is ironic, that it cost me 400% more to telephone my local HSBC branch on 0845, located 15 minutes away, than to address my enquiry to the New York branch of HSBC.
It is scandalous and indefeasible that a designated category exists (09) for the use of “above normal cost” telephone calls, but is sidestepped by the use of clandestine revenue sharing in other number ranges, especially 087x and 084x..
Ofcom should not accept BT’s assurances until BT behaves in an open and honest way. This could start with BT making an unequivocal statement that all UK calls (01/02) from landline cost the same, regardless of location, and that the distinction between “local” and “national” rate calls has been abolished. This statement, conspicuously repeated on all bills and web sites, until it is firmly lodged, could even make BT more money, from an increased use of the telephone by consumers calling distant parts of the UK.