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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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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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idb wrote on Nov 17^th, 2006 at 10:46pm:
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.

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Sounds normal for Ofcom.  Even persistent offenders flouting rules/regulations are never punished by Ofcom, instead they continued to allocate numbers when asked.

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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!!!

lucaltmann wrote on Feb 2^nd, 2007 at 11:01am:


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

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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?