dorf wrote on Dec 18^th, 2007 at 12:29pm:

Clearly I have upset you. I originally said...
DonQuixote wrote on Dec 17^th, 2007 at 4:53pm:
This is not the same as calling you "completely wrong" is it?

But you then seemed annoyed at this and said...
dorf wrote on Dec 17^th, 2007 at 11:09pm:
So it was you that suggested that you were "completely wrong", not I.
I obviously shouldn't have agreed with you. Sorry for any offence. 

Finally, if you read the ITU recs that I referenced, you will see why Ofcom had no choice but to withdraw PCA's. They should never have suggested them, in the first place. Ofcom has just made a basic error of enormous proportions and have now fixed it in the only way possible.

DonQuixote wrote on Dec 18^th, 2007 at 5:23pm:


Does that also apply for PCAs in respect of 0870 calls too?

If so Ofcom could obviously address the problem and rectify their own glaring error by instead insisting all call carriers carry calls to 0870 numbers at geographic rates (as per 03 numbers) and at the same time also abolish the existence of revenue sharing arrangement possibilities on the 0870 number range.  There is then no need for any form of all price announcement before the 0870 call is connected.

A couple of months notice of such a change should be sufficient given that the conmen call centres in question have now had their snouts in the trough for the last 10 years and that this action is clearly the one that Ofcom tried to give journalists and the public the impression that it was taking in the first place.

NGM puts his finger on the only sane and practical solution to the “problem of price announcements”.

I sense that our discussion has come full circle.

When referring to UKCTA members who were not intending to drop their 0870 rates to those of geographic calls:

SilentCallsVictim wrote on Nov 2^nd, 2007 at 4:11am:

Ofcom has never actually "required" anyone to use PCAs. It had its own bizarre reasons for presenting an unacceptable alternative rather than simply prohibitting deviations from charging structure associated with the numbering plan.

Please stop bickering, I know less about this than any of you, and I am therefore willing to listen and learn. Ofcom has approached me to offer a briefing on certain aspects of this matter, which I hope to receive tomorrow. I will attempt to pass on anything which is not already known.

I agree with the points made here by Dave, bb_uk and NGM'sG about PCAs and the use of the 0870 and 070 PNS range of numbers for auto-dialing applications. These types of applications should never be on either of those number ranges. Any application using an auto-dialer is delivering a call to an underlying geographical number or series of underlying graphical numbers. They do not need the features of NTS on 0870 or 070 PNS in its true sense for this purpose. The only reason that they are using 0870 or 070 PNS numbers is solely to collect the Premium revenue out of total greed, since they are already being paid a subscription for the service provided to their customers! If they were not demanding the Premium revenue they could have continued to use 0870 charged at the geographic rate, and there would have been no PCA required under the Ofcom proposals, so auto-dialers could not have been affected in any way! The fact that Ofcom have therefore paid any attention whatever to their false pleas demonstrates what has really gone on and what Ofcom's hidden agenda really is!

In any case as a qualified Electronic Engineer with much Telecoms design experience including many automated and auto-dialing functions, I can assure you that the stuff Ofcom have stated is completely incorrect. This clearly is an invented reason to attempt to justify their complete change of direction. Particularly, there is no proper justification that PNS numbers would be or should be used for such services, since they are supposed to be solely for Personal communication with the holder of a Personal Numbering Service number. It is perfectly feasible to design PCAs so that they are made whilst dialing continues in the background, and any automated call would not then be affected particularly with any intelligent auto-dialer. Additionally a call-in-progress tone could be included within a PCA so that automated devices would detect that the call was proceeding, or as Dave has suggested a particular additional digit could be dialed by the auto-dialer to inhibit the PCA. There is no technical reason why PCAs cannot be used without any problem for properly designed auto-dialers even if they are dialing 0870 or 070 PNS series numbers. The fact that the ITU depreciate them is not entirely of relevance since other requirements made by the ITU are flouted by both Ofcom and BT continuously (as well as other EU states - e.g. Italy's dial tone), after all they are only "recommendations" not mandates, so why should this issue alone be a special case? Only to suit the cries of the industry collecting the revenues I suggest!

It is clear therefore that, as I posted previously, the real reasons for Ofcom's change of direction with both 0870 and 070 PNS are quite different from the reason which they give; I believe in fact that they have probably already decided to allow Premium revenue collection to continue with 0870 numbers, and that this is all part of their new strategy, which is eventually to move all the existing NGNs being used as disguised Premium numbers over to PhonepayPlus, as they are doing firstly with 0871, so that they will then be able to classify them formally as Premium numbers, but with per minute charged call queuing permitted, without any restrictions.

DonQuixote, I accept your apology. Clearly you had indeed upset me, but after your apology I have ceased to be upset.

Dave, I think what NGM'sG meant was that DonQuixote's post: Quote:

implied that he was agreeing with what NGM'sG had posted concerning Ofcom and their senior management?

SilentCallsVictim wrote on Dec 18^th, 2007 at 9:43pm:
It did by implication.

The OCP's (retailers) are not in control of the wholesale price for 0870 as set by a TCP. Therefore if a wholesaler set its cost above Geographic, then the retailer was forced to use PCAs or operate at a loss.

This was an unintended consequence of Ofcom's well-intended intervention. Ofcom should have seen this coming in its impact assessment.

DonQuixote wrote on Dec 19^th, 2007 at 12:52am:


Well three SayNoTo0870 campaigners who attended an Ofcom meeting for consumer groups in Nov 2005 were certainly aware that Ofcom's willingness to allow carriers to charge more than geographic rate provided they had PCAs would be a Trojan Horse that could undermine Ofcom's entire alleged course of action on 0870s.

But when this was put to Ofcom Partner Sean Williams he simply poo-pooed this because he claimed no one would want to charge any more than geographic rate to 0870 after 1st Feb 2008 as Ofcom was scrapping the entire revenue sharing apparatus for 0870 calls.  But it seems from what you tell us that Ofcom was lieing and/or the shameless greed of certain telecoms operators in taking the view that because the public are now used to paying more for 0870 then it must be allowed to carry on has got the better of them.

The bottom line is that all of Ofcom's proposals for reforming 084 and 087 numbers were irrational and illogical.  They should have insisted the 08 being returned only to Freephone numbers and that after a period these 084 and 087 numbers must move either to 03 if they no longer wished to revenue share or to 09 or alternatively possibly to say unused 04 or 06 if we subscribe to the view that lower cost premium rate numbers must be somehow not be associated with the high cost connotations of 09 for marketing reasons.

Instead I believe Ofcom all along deliberately misled the public knowing full well that its only real intended solution was introducing 03 numbers and getting organisations who did not want to extra to callers to move there while leaving everything else intact.  I am sure it was quietly planned in various undocumented conversations from the outset that these last minite excuses over ITU rules and burglar alarm systems were always going to be used to completely scupper any actual change in charging or revenue sharing on all 084 and 087 number ranges.

SilentCallsVictim wrote on Dec 19^th, 2007 at 1:43am:


But Ofcom Competition Partner Sean Williams specifically told a meeting for consumer stakeholders that the whole revenue share system on 0870 was being abolished and thus even though Ofcom was allowing OCPs to go on charging more than geographic rate if they added a Pre Call Ancouncement of the price after 1st Feb 2008 he did not anticipate any reason for any OCP needing to do so since as revenue share was no longer possible there would be no reason for TCPs to charge OCPs more than for 01/02 calls.

When pressed on why Ofcom would allow the Pre Call Announcement at all Williams muttered about European competititon legislation etc but still claimed that in the real world no one was going to be using these announcements or charging extra for the calls.

Now as Sean Williams has fled Ofcom to the OFT perhaps his successors can again turn round as Ofcom staff did after it changed from OFTEL and say they know nothing of how Mr Williams ever came to give these assurances and they are only new kids on the block etc, etc, etc

The fact of the matter is that Ofcom is in fact engaged in a deliberate high level conspiracy with the telecoms industry to preserve revenue share on NGNs but is going to quite unbelievable lengths to try and hoodwink the public and the press to pretend that this is not what it is doing.