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The Met’s Emergency Number

Apart from being insensitive, the selection of a 0870 number for the Met’s helpline
clearly contravenes the COI guidance. It is also surprising that an 0870 number was
selected given that the Met is advised by its own technology support agency (PITO)
which should have known that a 087 number was unsuitable for this particular
application.

The Policy Issues

The policy view is that NTS is a legitimate micro-payment mechanism and that
Ofcom should not restrict the types of service or organisation eligible to use this
payment mechanism. Instead it is a matter for the organisations concerned (and
ultimately the government in the case of public sector) to decide whether an NTS
number is appropriate for their particular application and if so which range is best
suited to the application. The Policy Executive has recently endorsed this view.
The NTS project team believes that the COI guidance is the best route to encourage
appropriate use of these numbers by the public sector. The NTS project team has
also been proactive and has contacted public sector organisations such as the
Department of Health to give advice.

The NTS project team also thinks that Ofcom would have difficultly implementing a
restriction on public sector use of NTS numbers. The most likely mechanism to
implement such a restriction would be via the National Telephone Numbering Plan
(NTNP). Ofcom has powers to set conditions in the NTNP relating to the use of
telephone numbers. However, the NTS project team believes that Ofcom would have
difficulty satisfying the necessary legal tests to use these powers to prevent public
sector organisations from using some or all NTS number ranges. When setting
conditions relating to the use of numbers, the Communications Act requires that
Ofcom fulfil a number of legal tests. These are that the conditions must be objectively
justifiable, non-discriminatory, proportionate and transparent. The NTS project team’s
view is that restricting the availability of NTS numbers to public sector organisations
whilst allowing private sector organisations to continue to use them would be
discriminatory and would not be objectively justifiable. It is also arguable that it would
not a proportionate response to the problem.

Assuming that Ofcom was able to use the NTNP to restrict public sector use of NTS
numbers there would likely be some practical difficulties since the NTNP applies to
the communications provider that is allocated the number range rather than the
organisation using the number. Although the communications providers are required
to take reasonable steps to ensure that numbers are utilised in accordance with the
NTNP relying on communications providers to enforce these conditions might not be
a particularly satisfactory way of ensuring compliance.

The NTS Framework Re-examination

Ofcom consulted on changes to the regulatory regime supporting NTS in October
2004. Responses indicated a lack of consensus in favour of Ofcom's preferred option
and therefore additional research has been undertaken.
A second consultation with revised proposals is being prepared. The project team
have presented the key issues to the Policy Exec and Board recently and will return
later this month for approval of the preferred approach. Dates are PE 18 July, Board
26 July.

The NTS Project will be presenting to the Consumer Panel on 21 July.

For Reference

Further details of the COI Guidance

In January 2005, the COI reissued the ‘cost to the citizen’ section of the contact
centre guidance as an addendum pending completion of the revised document. This
section provides guidance to government departments on amongst other things the
selection of telephone numbers for government contact centres. The revised
guidance raises awareness of the cost of calling 084 and 087 numbers and describes
how the local and national rate terms have become outdated. The revised guidance
recommends that:
· freephone numbers (0800, 0808) numbers should be used where callers might be
deterred by the cost of the calls or where the objective is to encourage as many
people to call as possible;
· geographic numbers or 0844/0845 numbers should be considered as an
alternative to freephone numbers, but recommends that government departments
consider the cost to the consumer particularly of 0844 numbers;
· 0870 and 0871 numbers should not be used for contact centres called by
consumers;
· 0870 and 0871 numbers should be used with caution for contact centres called by
businesses since call charges are higher than for geographic calls;
· alternative contact mechanisms such as geographic numbers or postal
mechanisms should be offered alongside or as an alternative to 0870 and 0871
numbers; and
· 09 premium rate numbers should never be used for public services.

NTS Call Charges

In last weekend’s press articles, 0870 call charges have been listed as up to 10p per
minute from landlines and up to 50p per minute from mobiles. Whilst these figures
are probably factually correct they don’t reflect the price typically paid by consumers.
For BT customers on the BT Together discount packages calls to 0870 numbers
cost:
· 7.51p per minute during the daytime
· 3.75p per minute during the evening
· 1.5p per minute at weekends.

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Plenty more Ofcom Consumer Panel advice to Ofcom at

http://www.ofcomconsumerpanel.org.uk/advice/

Although I had been carrying out my own private war against 0870/0845 numbers and received a substantial refund from BT for the cost of my 0870 back in August 2002 calls (because I could demonstrate I had been mislead as to the cost) it was the London Bombings that bought me to this site. I was just so angry at the use of the 0870 number for people who would be so desperate for information.

I complained vigorously to OFCOM and their response was there is nothing they could do. They were not in the slightest bit interested. In my view they only took an interest when it became apparent their was considerable anger.