NGMsGhost wrote on Aug 18^th, 2007 at 2:28pm:
Well what would you realistically believe Ofcom would give-in to as a compromise bearing in mind Ofcom's reluctance to do anything at all to upset their teleco buddies and cosy meals?

bbb_uk wrote on Aug 18^th, 2007 at 10:10am:

As I have voted for option 3, I am obliged to comment.

I believe that because 084 is presently such a mess, Ofcom has decided to wait to see what happens as a result of the relatively simple provisions that it has put in place. I believe that it will come back to review 084 in the light of:

- How the telcos go about providing and supporting 03 numbers

- How much take up there is of 03 (taking away current 084 usage)

(these two are inter-related and largely outside Ofcom’s direct control)

- How quickly dial-up internet access (a major use of 084) dies, as broadband is universally adopted (an Ofcom objective).

- How well its subcontractor (ICSTIS) copes with the considerable growth in the scale and scope of its responsibilities caused by the reclassification of 0871.

- Representations received and a general perception of public attitudes


Ofcom and the government believe that the premium rate industry should be self-regulating. The Communications Act made specific provision for Ofcom to sub-contract the operational aspects of its statutory duty to ICSTIS. ICSTIS is made up of those who earn a living from premium rate services. There is no obvious affinity between such organisations and those, like the DVLA, who recover part of their call centre costs by imposing charges on callers through use of a 0870 number. The concept of a self-regulating industry cannot be extended beyond the realms of common interest.

It is also significant to note that Ofcom’s statutory powers to impose and enforce regulations may only be applied to those who provide telecommunications services. Whilst “chatline” providers fall within this definition, the DVLA does not (although if it switches to 0871 before next February, from then it would).


If Ofcom allows revenue-sharing (as distinct from “premium rate”) to remain, then I cannot see how it could enforce the transparency about the fee element (as opposed to the total cost) that we rightly seek. In the commercial sector there is some entitlement to commercial confidentiality regarding how an originating telco distributes the money it collects from its customers.

The telcos are already under a very strong obligation to be transparent about the total cost. (Users of non-premium rate NGNs cannot be made subject to such a requirement by Ofcom.) Any failure to comply with Ofcom’s requirements must be the subject of a formal complaint. Any competing telco would be very quick to endorse or even submit such a complaint.

Our right to demand information from public sector bodies is different. I wonder if anyone has considered a FOI request to the DVLA regarding the revenue it obtains by charging fees for calling its call centre. To obtain a resolution, we may have to address this with each public sector body separately, although assistance may be provided by the COI and the No 10 Delivery Unit, who are both involved.


If I have the opportunity to study these matters further I may be ready with suggestions about how Ofcom could address all of the issues that arise. For now I am focussed on the public sector and the NHS in particular. I therefore have to disappoint those who may wish to see a total answer.

I hope these observations are helpful to the discussion – that is my only objective here. My work to actually resolve the issues is taking place elsewhere.

David

I write the following in response to comments made about my point of view and accusations that I have a somewhat “myopic viewpoint”, which some view as being supportive of BT.

dorf wrote on Aug 18^th, 2007 at 8:05am:

That is because I post on here because I believe that the central issue is one of having decent telecommunications services in this country. Privatisation has allowed competition to be introduced and has also created the necessity for such companies to make money (for shareholders).

I do not see how a company like BT can reduce its market share (and revenue) whilst increasing profit and still having to maintain the network, regardless of how many subscribers it has. The point is that the network infrastructure is paramount to the country for telecommunications and therefore BT can't simply close bits down to reduce costs.

This is happening with the Post Office, where rural branches are closing, because in this “modern” time, the necessity to make profit is now being put before the necessity to have a telephone service or postal service. This was, presumably, not an issue when the networks were created.

Cable is an example of a network that has been built since privatisation and we can see that the providers only want to cable areas where they know they can get a return. On the other hand, companies like BT and Royal Mail, must provide a service to all places, whether they be urban or rural.

Another example is with mobile telecommunications, where we have four principal GSM networks. The technical aspects of getting the best coverage should be paramount for mobile telecommunications. However, what we have is the completely crass solution of having four competing providers who each go and build their own networks which cover the same areas!

There are other areas that either have no coverage at all, or aren't served by all providers. Thus, whether I can get a signal or not is not defined by the whether any signal is present in my current location, but whether my provider covers that area.

I introduce this into the topic because it illustrates the difference between BT, the state run service which covered everywhere and the cable and mobile networks which have been built from square one by private finance. The better way of, creating/running the infrastructure at least, is surely the GPO/BT one, or at least to have one body that works as one. This has been proven to be the case with the railways.

There was talk about 'inefficiencies' and that competition and privatisation would drive these out. But all the extra mobile phone masts because each operator must have its own to cover the same area, I think is a sure sign that inefficiencies remain!

dorf wrote on Aug 18^th, 2007 at 8:05am:

But the point is surely one of introducing competition to the market versus the SMP that wishes to keep/increase its market share. If we imagine that the ex-government operated telecommunications network has been run in a ‘Tesco-like’ manner since privatisation, what difference would this make with regards to introducing competition?

With 084/087 NTS numbers, BT only retains a small amount (on cost basis) for originating the calls. The amount left is paid to the NTS provider, as decided by the regulator. But NTS providers have no interest in reducing the price to callers. It is this which is the reason for saying no to 0870, along with the “local rate” et al lies which emanate from some telcos when marketing these numbers.

The scales are improperly balanced, whereby there are many providers who terminate calls but don't originate them. This is not the case with 01/02 calls and may help explain how the prices of these has been driven down. To me, this is the key sticking point and why calls to 0845 and 0870 remain high at (broadly speaking) the same as local and national rate when there was only BT.

Continued....

SilentCallsVictim wrote on Aug 18^th, 2007 at 4:01pm:

How can a such a line between these two types of service be drawn? Where do you put it?

I refer to a previous post of yours:
SilentCallsVictim wrote on Aug 15^th, 2007 at 5:35pm:

These two seem to contradict one another.

Perhaps the next bit helps to explain:
SilentCallsVictim wrote on Aug 18^th, 2007 at 4:01pm:

So what you’re saying is that Ofcom (under the law, i.e. Communications Act) must make this distinction?

SilentCallsVictim wrote on Aug 18^th, 2007 at 4:01pm:

Currently, quite a few telcos don’t provide pricing information for 084/087 NGNs alongside that for 01/02, as decreed by Ofcom following the consultation last year. Why would a telco put in a complaint against another? All that will happen is that they will all put in complaints against one another. When they want to, they stick together and, in this case, they keep schtum.

SilentCallsVictim wrote on Aug 18^th, 2007 at 4:01pm:

This has already been addressed and has been discussed in parliament. See the Parliamentry Update thread, specifically this post where it can be seen that the DVLA ‘earned’ £2,894,284 during 2006/07.

I thought Ofcom had connived with its subcontractor ICSTIS to come up with a Consultation document on 0871 that suggests that there is not enough consumer detriment to bother to ban call queuing on these up to £6 per hour numbers.

At least I distinctly recall responding to such a consultation recently at quite some length.

So it sounds to me like Ofcom has recanted on the idea that call queuing is not allowed on Premium Rate numbers.  Bearing in mind that ICSTIS is the premium rate regulator.

Dave wrote on Aug 18^th, 2007 at 9:47pm:


I don't think they liked what most of the responses had to say about their proposals.

Perhaps they are having urgent internal talks with Ofcom about what to do before they publish them and the press get hold of the total numbers against their proposals and the strength of that opposition. We may yet see a limitation on the length of call queues to 0871 numbers.

NGMsGhost wrote on Aug 18^th, 2007 at 11:04pm:
I would love to see that but I think the lack of responses online is because ICSTIS only has a limited number of staff (compared to Ofcom) so maybe they haven't had time to go through all the responses and mark down what they need to before it going online.  If I remember correctly it took ICSTIS a while to do the pre-consultation which only had a few responses most of which by the industry.