The Importance of the link with Geographical Call Rates Quote:3.28 Many organisations (including not-for-profit bodies whose functions are often closely associated with equity issues) would therefore be deterred from migration by the prospect of different OCPs taking different approaches to whether their 03 prices should match 01 and 02 prices. Whilst SPs could, in theory, enable the public to call them on different types of numbers (eg 03 or 0800) according to the OCP involved, this is a significantly worse option and a formidable marketing challenge.
This has been the case with freephone numbers being chargeable (often above geographical rates) from mobiles. We may end up with 03 numbers being cheaper to call from mobiles than 0800s! I note that no provision has been made for migration (or for a ‘tandem’ approach where SPs would be contactable on both) from 0800 and 0808 to 0300 and 0308, respectively. Of course, having both available is just plain confusing to the general consumer.
Therefore rules must be brought in to ensure that 0800 is not charged above 03 rates from mobiles. This will be especially necessary if Ofcom forces 03 to be charged inline with 01/02 with no possibility of higher rates with a pre-call announcement.
At present, the Plan puts obligations on the TCPs on how they use their allocated numbers. Ofcom will look at ways of bringing in rules that apply to all OCPs. If many OCPs charge more their respective 01/02 rate for 03 numbers, then it will undermine the Plan. I think the same thing is true with freephone numbers from mobiles and I hope that something will be done about this.
In paragraph 3.56 Ofcom considers it necessary to make a formal obligation on all OCPs in respect of the designations of 03 (and 070) in the Plan. 3.58 goes on to say that there will be another consultation on extending this to other number ranges.
Waterbed Effect Quote:3.34 Separately, some stakeholders have argued that the ‘waterbed effect’ – through which limiting one set of prices may be compensated for by a change in other retail prices – is very strong. To the extent that this effect applies, it would suggest that OCPs would tend not to lose out financially from SPs migrating from 08 to 03 numbers. Also, the volume of migrating 08 traffic would be much lower than the volume of 01 and 02 traffic, and this limits the degree to which 01 and 02 prices may have to change to offset any first-order financial impact on OCPs. The first-order impact will also be limited in the early stages of 03 - and therefore easier to adjust for - because migration from 08 numbers will not all happen overnight. The absence of existing interconnection contracts for 03 also avoids initial inflexibility in setting 03 retail prices.
At the end of the day, telcos entice subscribers by promoting their geographical rates. The lack of enforcement of rules that require price disclosure of 084 and 087 NGNs only compounds the issue.
The nation’s telephone consumers are being over-charged for calls to companies anyway. And it’s all covert, so what some argue as the ‘waterbed effect’ is in fact the removal of the market distortion that exists at the moment.
SPs’ views on Pre-call Announcements Quote:3.38 The ability to provide a pre-call announcement has been argued to be a more proportionate way to meet Ofcom’s objectives. However, it is apparent to Ofcom from consumers’ and SPs’ feedback that a pre-announcement would not deliver the certainty that consumers want nor the confidence in, and SP migration to, the 03 range. This is particularly the case were a pre-call announcement to be generic in nature, as one OCP has suggested to Ofcom as a possibility, rather than giving the specific price for each 03 call.
But pre-call announcements will promote openness. I wonder whether those consumers who were questioned were, in general, under impression that 0845 and 0870 numbers were ‘good’ because many businesses used them and that charges were ‘reasonable’. With that in mind, such consumers would not have had time to consider the implications, i.e. that is not “just a few pence extra”. Thus, by introducing pricing announcements it may make people think (perceive) that prices are high and unreasonable because they inherently believe that they are fair now.
It’s almost like they believe that the introduction of pricing announcements is giving the green light to price rises. It’s the old chestnut that the 0845 ‘local rate’ lie has been told that many times that people cannot think in terms of this not being the case.
Legal IssuesParagraphs 3.41 through to 3.47 discuss some potential legal issues which some CPs, including Vodafone and T-Mobile, raised. They suggest that Ofcom cannot include price designations in the National Telephone Numbering Plan. Ofcom rejects this and says:
Quote:3.42 […] Where it appears to Ofcom that any of its duties conflict with each other in a particular case (both in relation to its duties to fulfil the Community obligations and Ofcom’s general duties), Ofcom is required to secure that the conflict is resolved in the manner it considers most appropriate in the circumstances. In the event there is a conflict between fulfilling the Community duties and Ofcom’s general duties, the Community duties prevail.
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Ofcom Info & Consultation on New 03 Number Range (Read 62,551 times)
