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NTS Focus Group Minutes - Sep 28, 2006 (Read 8,892 times)
idb
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NTS Focus Group Minutes - Sep 28, 2006
Nov 17th, 2006 at 10:45pm
 
http://www.ofcom.org.uk/telecoms/groups/nts_focus/notes/nts28sept06

NTS Focus Group - 28th September 2006 - 2.30 pm Ofcom


Meeting Notes & Actions
Agenda item (1) - Introductions
Attendance:
Andrew Wileman
Ntl:Telewest (Chair)

Marcus Rudkin
Band-X

Mark Amoss
BT

Kath Embleton
BT

Justin Hornby
Cable & Wireless

Laurent Pariat
Cable & Wireless

Toby Higho
Easynet

Will Goodall
Flextel

Tom Cairns
Gamma

Andy Martin
IV Response

Huw Saunders
Kingston Communications

Nic Green
Ofcom

Clive Hillier
Ofcom

Mike Barford
Tiscali

Anne McCardle
Verizon Business


Agenda Item (2): Review of minutes of previous meeting
Justin Hornby noted that the reference to the new adult number range was incorrect. The chair agreed to amend the minutes accordingly. No additional comments/concerns were raised. It was therefore agreed that the minutes, once amended, could be published on the Ofcom website.

Agenda (3): Update/progress report on the current 'live' NTS related consultations/investigations: (Ofcom/All)
Adult Services Consultation
Clive Hillier said that Ofcom hoped to publish the consultation on the extension of the Controlled Premium Rate Services definition to adult services operating on 08 ranges within the next month. Clive added that this publication was dependent on the issuing of the statement on ‘Conditions regulating Premium Rate Services’ which has also proposed a modification to the PRS Condition.

General Condition 14 Enforcement Programme
Clive advised that Ofcom had opened an own-initiative investigation into non-compliance with the amended General Condition 14 (NTS and PRS Codes of Practice) and was considering what action should be taken. Attendees were reminded that the amended Condition requires CPs (both fixed & mobile), to publish the relevant Codes of Practice and improve the visibility of NTS call prices in price lists, promotional materials and on websites, by the deadline set in the April 2006 Statement (19 August 2006). Clive advised that Ofcom had already received 2 complaints from stakeholders about the apparent failure by a number of OCPs to comply with the amended Condition. The Ofcom case leader for this investigation is Tanya Rofani.

Andrew Wileman enquired about Ofcom’s plans for a general review of premium rate services. Clive said that this would be encompassed within the wider review of the General Conditions.

Mark Amoss sought clarity around the powers that Ofcom had in instances of abuse of number ranges – in particular, could Ofcom withdraw numbering allocations? Will Goodall said that he believed that Ofcom had such powers and remarked that other EU countries have more stringent requirements around number allocation. Clive Hillier said that each case was considered on its individual merits and added that the subsequent initiatives generated by the numbering review would include the introduction of a consumer protection test for number allocation.

NTS call termination market review/NCCN 500 investigation
Clive Hillier said that Ofcom was still in the process of drawing the NCCN 500 investigation to a conclusion. He added that the intention was to circulate the preliminary findings to the parties to the dispute in October 2006.

The call termination market review remains on hold, pending the outcome of the NCCN 500 investigation.

Andrew Wileman said that the outcome of the call termination market review would likely need to be taken into account in the discussions around 0870 interconnect charges – and as such the need to have sight of Ofcom’s findings was critical. Clive said that Ofcom was aware of the linkage and recognised the timing challenges.

NTS: A Way Forward – Implementation Update
Clive said that the implementation steps were progressing to plan. In particular, Ofcom expected to issue a further consultation on the extension of PRS regulation to adult services currently provided on 08 ranges within the month (see above). The ICSTIS pre-consultation on the extension of its remit to cover 0871 services was due to close on 29 th September, following which a full consultation would be issued (by early 2007).

Following discussion at the previous NTS Focus Group in relation to the date of effect of the 0870 reforms, there had been some confusion about the agreed date. The official date of effect was 18 months from the date of publication of the Numbering Statement – this would be 28 th January 2008. However, there had been a suggestion that the date of effect/implementation should be rounded up or down to coincide with the nearest start of the month. Several attendees had favoured 1 st February in order to avoid the need for special billing arrangements resulting from a changeover at a time other than a month end. No objections to this proposal were raised, however Andrew Wileman suggested that views were sought from non-attendees prior to the proposal being accepted.

New Action Sep06_01: Objections to the proposal that the 0870 reforms should commence on 1st February 2008 to be communicated to the chair by 31 st October

...
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Re: NTS Focus Group Minutes - Sep 28, 2006
Reply #1 - Nov 17th, 2006 at 10:46pm
 
...

Agenda (4): Update on arrangements for call termination payments under new 0870 regime
Andrew Wileman provided an overview of the workshop that had been held on the morning of 28 th September. Attendees had discussed the lists of issues generated by industry and BT (both included with the distribution of these minutes). The issues identified were broadly consistent and it was agreed that a framework for taking discussions forward should be put in place. Given that timing was a critical factor, attendees agreed that a timetable for discussion should be drawn up, to include relevant milestones. This would ensure that issues were resolved and rates were in place in time for the ‘go live’ date of 1 st February 2008. Attendees agreed that a negotiated agreement was the preferred outcome, however it was suggested that the worst-case scenario should be planned for (i.e. a dispute/referral to Ofcom). In such a situation, any referral would need to occur in the summer of 2007 in order for Ofcom to reach a conclusion by early 2008. Working back from this date, BT would need to issue pricing letters/OCCNs by 31 st May 2007. On that basis, it was suggested that the following timetable should be used as a framework against which discussions would take place:

Now – Dec 2006: Discussion/agreement of principles

Jan 2007 – May 2007: Negotiation/agreement of rates

May 2007: Issue by BT of pricing letters/OCCNs

Summer 2007: Potential referral to Ofcom (if a dispute arises)

1st Feb 2008: Implementation of new interconnect rates (either as a result of agreement or via Ofcom ruling)

While a number of issues had been identified, no clear suggestions for a potential way forward had materialised, save for that informally tabled by BT at the August NTS Focus Group. It was suggested that this be used as a starting position. This proposal entailed preserving the existing BT contractual arrangements – and such perpetuation of the legacy situation would also be applied to technical/routing aspects. Mark Amoss suggested that removing the need for contractual changes would simplify the transition and would mean that industry discussions would, in the main part, need only to focus on the termination charges. Attendees were reminded that this proposal was made on an informal basis and did not have BT’s official endorsement at this stage.

Attendees agreed that this would be a constructive way forward. It was noted that the proposal was to be used purely as a starting point to stimulate discussion. There was no implication that such an arrangement would necessarily prevail, and CPs remained free to suggest alternative approaches.

Andrew Wileman agreed to arrange a further workshop for CPs in the near future. The output of this group would then be communicated back to the NTSFG.

New Action Sep06_02: Andrew Wileman to arrange a second 0870 charging workshop

Will Goodall said that he believed it would be difficult to achieve a consensus among such a diverse group of organisations. CPs had very different business plans and priorities which in many instances conflicted with one another. Nobody could know what the impact was on each business, as the details of each business model where unknown. He suggested that this was the first time in the UK that the Regulator had attempted to change the charging focus of a service (i.e. effectively changing the responsibility for payment of routing intelligence/functionality from the ‘Calling’ to the ‘Called’ party). Only now are the Commercial implications of this and the impact on established and complex porting arrangements being teased out. Will elaborated that FleXtel does not have a billing system and therefore has very low overheads and very low collection risk. The change of charging focus will have a greater impact on FleXtel’s and similar CPs’ business models, than on some other CPs.

Andrew Wileman said that while everyone hoped that a negotiated outcome could be reached, the proposed timetable had factored in the prospect of a dispute arising, so contingencies were in place.

Discussion turned to the charging arrangements for 03. It was recognised that there were very clear parallels between the (future) interconnect charging arrangements for 0870 and those for the 03 number range – to the extent that they may ultimately prove to be identical. Several CPs suggested that whatever arrangements were put in place for 03 could set a precedent for the 0870 range. Attendees were reminded that the 03 range was due to go live early in the new year – and the establishment of interconnect charges was therefore required with some urgency. It was suggested that the scope of the forthcoming 0870 charging workshop be broadened to include the issue of charging for the 03 range

...
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Re: NTS Focus Group Minutes - Sep 28, 2006
Reply #2 - Nov 17th, 2006 at 10:46pm
 
...

Agenda Item (5) – Telephoning Numbering: Safeguarding the Future of Numbers – Overview/Discussion (Ofcom/All)
Nic Green provided a brief overview of the recently published Statement. Nic said that Ofcom had received 17 responses to the original consultation, the majority of which had been from CPs.

Several attendees asked for clarification around the 03 allocation process and implementation timescales. Nic said that Ofcom was intending to publish guidance on the 03 allocation process in the next 2-3 weeks, following which numbers would become available for allocation (likely to be mid November). Nic added that 0300 and 0303 numbers within the 03 range would be allocated first.

Andy Martin sought clarity around the allocation process for CPs that had equivalent or ‘mirror’ codes in other ranges. Nic said that 03 ranges would be offered in the first instance to those CPs that had been allocated parallel codes on, for example, the 0845 and 0870 ranges. Mark Amoss asked if 03 ranges would still be reserved in instances where the allocatee of the 0871 parallel range had persistently offended. Nic said that would be something for Ofcom to consider within the consumer protection tests proposed in the Numbering Statement.

Will Goodall asked why Ofcom had not withdrawn number ranges from persistent offenders, as he believed that Section 61 of the Communications Act had always afforded it the power to do so. Will said that he was disappointed that Ofcom’s allocation procedures had hitherto seemingly been less stringent than other EU countries, even though Section 58 and 59 of the Act had always provided Ofcom with these powers. Nic Green said that while Ofcom had never taken the step of withdrawing numbers, he anticipated that the newly proposed consumer protection test for number allocation would prevent allocation in the first place and would afford Ofcom greater discretion around the prospect of withdrawing allocations in the future.

Will suggested that Ofcom should require those applying for numbers to produce a business plan – as is the case in certain other EU member states. He added that he believed Ofcom should vet applicants more thoroughly and withdraw number ranges from miscreants.

Mark Amoss said that fraud/ AIT remained a big issue and was exacerbated by the apparent lack of stringency in the number allocation and policing process (particularly, the apparent absence of vetting of prospective allocatees). As an example, Mark said that the failing of the industry and Ofcom to adequately address fraud issues had contributed to the fact that international access to 0871 was not generally available.

Several attendees asked if Ofcom attended TUFF. Nic Green was not clear if this was the case, however Ofcom would instigate stakeholder discussions to consider consumer protection issues (resulting in part from the proposals in the Numbering Statement). Nic agreed to confirm the Ofcom lead for this forum.

New Action Sep06_03: Nic Green to confirm the Ofcom lead for the consumer protection forum

Will Goodall expressed concern at what he perceived to be a disconnect between the Numbering Statement and the NTS: A Way Forward Statement. He said that he believed the proposed reforms to the 0870 range were now unnecessary given the implementation of the 03 range and he emphasised that, although Ofcom had consulted on the need for 03 in the light of the 0870 NTS proposals, Ofcom had failed to consult on the need for the 0870 changes in the light of the 03 proposals being confirmed. Will drew the meeting’s attention to the COI August update, which advises Government departments not to use 0870, but to migrate to 0300 to avoid criticism. Furthermore Early Day Motion 622 had been completely satisfied by the introduction of 03 and the COI advice. Clive Hillier said that the changes to 0870 aimed to address several policy issues that would not be addressed by the introduction of 03 numbers.

Will explained that certain CPs had, over 10 years, built their complex business models around the existing 0870 regime and they, and their customers, were facing significant disruption as a result of the planned changes. Indeed in order to minimise costs and maximise efficiency FleXtel did not have a billing system and hence it, and its mostly SME customer base, were facing a complex change in commercial arrangements. Will reminded Ofcom of its duty under Section 6 of the Act, to keep under review regulatory burdens that have become unnecessary e.g. 0870 in the light of the new 03 programme, which he believed was an issue Ofcom has yet to consult on.

He added that Flextel was considering challenging the Numbering Statement as a result of this and was looking for financial support, from larger CP’s, to effect this activity. Will asked if other attendees had similar concerns. Several CPs said that they had disagreed with the draft proposals in their responses to the consultations.

...
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Re: NTS Focus Group Minutes - Sep 28, 2006
Reply #3 - Nov 17th, 2006 at 10:48pm
 
...

Discussion turned to the issue of international access to the 03 range. Mark Amoss said that CPs requiring their 03 codes to be accessible from overseas should tick the appropriate box on the DMA form. This would ensure that BT would configure its systems for receipt of internationally originated traffic, but would not guarantee that overseas CPs would open the ranges on their networks. Attendees were reminded that when overseas CPs had previously been asked to open UK codes, such implementation had taken up to 18 months.

Agenda item (6) – Review of remaining outstanding actions
As result of the meeting room being required for a subsequent booking, the majority of the outstanding action points were not discussed. An update has therefore been provided via these minutes, where possible. Feedback and additional input is welcomed.

Action Aug06_01: Mark Amoss to communicate the outcome of BT’s additional considerations around the charging arrangements for 0870 post reclassification. Discharged – List of considerations distributed with these minutes.

Action Aug06_02 : Andrew Wileman to arrange an 0870 charging workshop for the morning of 28 th September. Discharged.

Action Aug06_03 : Nic Green to be invited to the next NTSFG meeting. Discharged.

Action Aug06_04 : Geoff Brighton to provide clarification around the classification and governing principles applying to the 03 number range. Discharged – The below response from Geoff was distributed via email with the minutes of the previous meeting:

“Annex 3 of the July 06 Numbering Statement designates the 03 range as being for 'UK-wide services' where:

a 'UK-wide Number' means a Telephone Number for a service charged at the rates set out in Part A (of the Statement) where:

    (i) the Numbering Plan of the Communications Provider offering the service has no geographic significance;

    (ii) the location of the Customer's Apparatus identified by a given Telephone Number at the time of use is not necessarily permanently associated with a particular Network Termination Point;

    (iii) number translation to a Geographic Number is involved; and

    (iv) the service is not a Mobile Service.

Item (iii) seems to imply the these may be classed as NTS but this is not the case and this wording will be amended in the statement that follows the current consultation, to remove any ambiguity. Ofcom has not stated that the NTS call origination condition will be extended to include 03 calls. This means that OCPs and TCPs are free to negotiate their own interconnection and routing arrangements. Services will be non-revenue-sharing, as per the following exclusion - B3.6.1:

"Those who adopt or otherwise use 03 numbers shall not share with any End user any revenue obtained from providing a service on those numbers"

Origination from 03 numbers will be possible and the new 03 numbers will be available as soon as Ofcom publishes the statement for which the current target date is mid/late October.

Nic Green has agreed to attend the next NTS FG on 28 September (2:30pm

Action Aug06_05 : Geoff Brighton to provide clarification around the timescales for the introduction of the 03 number range. Discharged – See response to AP Aug06_04 above.

Action Aug06_06 : CPs to feed back reasons for OCCN rejection/dispute to Mark Amoss. Ongoing – Mark said that he had received no feedback to date.

Action Aug06_07 : Mark Amoss to confirm BT’s approach to future reviews of NTS formula components at the next NTSFG. Ongoing – not discussed due to early conclusion of the meeting.

Action Aug06_08 : Andrew Wileman to forward Mike Barford’s comments on BT’s amended NTS formula review position to NTSFG members. Discharged – email distributed with minutes of previous meeting.

Action Aug06_09 : Porting differential issue to be added to the agenda of the first NTSFG meeting of 2007. Ongoing.

Action Aug06_10 : Andrew Wileman to confirm the position of the NTSFG in respect of SNEN discussions to the chair of the Telecom Advisory Group. Ongoing – Position to be confirmed.

Action Aug06_11 : Geoff Brighton to confirm the date by which CPs must be compliant with the amended General Condition 14, and the potential action to be taken by Ofcom in instances of non-compliance. Discharged – The below response from Geoff was distributed via email with the minutes of the previous meeting:

“Ofcom has already received 2 complaints from stakeholders about the apparent failure by a number of OCPs, including mobiles, to publish the relevant Codes of Practice and/or improve the visibility of NTS call prices in price lists and on websites, by the deadline set in the April 2006 Statement of 19 August 2006. As a result Ofcom has opened an enquiry into these complaints and is currently considering what action may be required.”

Action Aug06_12 : Geoff Brighton to clarify arrangements for the BT Click number ranges once the reforms to the general 0870 range come in to effect. Discharged – The below response from Geoff was distributed via email with the minutes of the previous meeting:

...
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Re: NTS Focus Group Minutes - Sep 28, 2006
Reply #4 - Nov 17th, 2006 at 10:49pm
 
...

“BT asked about whether any special arrangements will continue to apply to the 08709 and 087018 ranges after January 2008. The answer is that all 0870 ranges will be treated identically under the new arrangements. Consequently TCPs/SPs wishing to continue revenue sharing at a retail price equivalent to local rate plus 1ppm will need to migrate to an appropriate 0871 number range.”

Agenda item (7) – Any Other Business
Not discussed due to early conclusion of the meeting.

Date of Next Meeting:
Tuesday 7 th November 2006– 2:00pm Ofcom – Riverside House, London

Summary of New and Outstanding Actions:
Aug06_06
CPs to feed back reasons for OCCN rejection/dispute to Mark Amoss

Aug06_07
Mark Amoss to confirm BT’s approach to future reviews of NTS formula components at the next NTSFG

Aug06_09
Porting differential issue to be added to the agenda of the first NTSFG meeting of 2007

Aug06_10
Andrew Wileman to confirm the position of the NTSFG in respect of SNEN discussions to the chair of the Telecom Advisory Group

Sep06_01
Objections to the proposal that the 0870 reforms should commence on 1st February 2008 to be communicated to the chair by 31 st October 2006

Sep06_02
Andrew Wileman to arrange a second 0870 charging workshop

Sep06_03
Nic Green to confirm the Ofcom lead for the consumer protection forum

[end]
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Re: NTS Focus Group Minutes - Sep 28, 2006
Reply #5 - Nov 18th, 2006 at 4:35pm
 
idb wrote on Nov 17th, 2006 at 10:46pm:
Andy Martin sought clarity around the allocation process for CPs that had equivalent or ‘mirror’ codes in other ranges. Nic said that 03 ranges would be offered in the first instance to those CPs that had been allocated parallel codes on, for example, the 0845 and 0870 ranges.
That means that gov bodies could migrate to very similar number ranges on the 03x.  This is good for us consumers as it may mean only one or two digits will change.

Quote:
Will Goodall asked why Ofcom had not withdrawn number ranges from persistent offenders, as he believed that Section 61 of the Communications Act had always afforded it the power to do so. Will said that he was disappointed that Ofcom’s allocation procedures had hitherto seemingly been less stringent than other EU countries, even though Section 58 and 59 of the Act had always provided Ofcom with these powers. Nic Green said that while Ofcom had never taken the step of withdrawing numbers, he anticipated that the newly proposed consumer protection test for number allocation would prevent allocation in the first place and would afford Ofcom greater discretion around the prospect of withdrawing allocations in the future.
Sounds normal for Ofcom.  Even persistent offenders flouting rules/regulations are never punished by Ofcom, instead they continued to allocate numbers when asked.

Quote:
He added that Flextel was considering challenging the Numbering Statement as a result of this and was looking for financial support, from larger CP’s, to effect this activity. Will asked if other attendees had similar concerns. Several CPs said that they had disagreed with the draft proposals in their responses to the consultations.
That is proof that the money earned on these numbers is significant for a CP like Flextel to consider challenging Ofcom's decision on 0870 numbers instead of just migrating to other number ranges.  I have grave concerns if this was ever challenged!!!
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Re: NTS Focus Group Minutes - Sep 28, 2006
Reply #6 - Feb 2nd, 2007 at 11:01am
 
can anyone tell me what is special about 08709 and 087018 number ranges ?
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Re: NTS Focus Group Minutes - Sep 28, 2006
Reply #7 - Feb 2nd, 2007 at 11:59am
 
lucaltmann wrote on Feb 2nd, 2007 at 11:01am:
can anyone tell me what is special about 08709 and 087018 number ranges ?


They are currently charged at a lower rate than other 0870 numbers but won't be after 1st Feb 2008 when they will all be charged at the same rate as 01/02 numbers.

This is mentioned at www.ofcom.org.uk/telecoms/groups/nts_focus/notes/nts28sept06

Quote:
“BT asked about whether any special arrangements will continue to apply to the 08709 and 087018 ranges after January 2008. The answer is that all 0870 ranges will be treated identically under the new arrangements. Consequently TCPs/SPs wishing to continue revenue sharing at a retail price equivalent to local rate plus 1ppm will need to migrate to an appropriate 0871 number range.”


Are you still having trouble working Google or is the point of your questions to find out how well informed people in this group are? Undecided
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Re: NTS Focus Group Minutes - Sep 28, 2006
Reply #8 - Feb 2nd, 2007 at 12:06pm
 
Thanks
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