-------- Original Message --------
Subject:      Response to BIS Consultation on Proposed New Duties of Ofcom
Date:      Fri, 25 Sep 2009 23:59:28 +0100
To:      rachel.clark@bis.gsi.gov.uk, john.brumwell@bis.gsi.gov.uk, simon.moseley@bis.gsi.gov.uk
CC:      luffp@parliament.uk, whittingdalej@parliament.uk, bottomleyp@parliament.uk, stephen.timms@bis.gsi.gov.uk, ben.bradshaw@culture.gsi.gov.uk

Dear Sirs,

Response to BIS Consultation on Proposed New Duties of Ofcom (www.berr.gov.uk/files/file52538.pdf)

As a relatively informed consumer of telecoms services and a longstanding campaigner against Ofcom's quite grotesque failure to prevent major anti-competitive distortions being introduced in to the UK telephony marketplace via the plague growth of covert revenue share NTS numbers and also the subsequently increasingly anti-competitive massive price increases in per call charges for fixed line phone calls by BT (since its pricing was de-regulated) the very words Ofcom fill me with a combination of both despair and contempt towards one of the two most singularly failed so called regulatory bodies in any major western nation today, the other one also being British and called OFGEM.  It appears to me that the higher and more ludicrously out of proportion to normal civil service pay salaries the pay of the top executives of these out of control super regulators is made the more they attract in untrustworthy sharks from the industries that they are suppose to be tasked with regulating on behalf of the public.  These overpaid ambitious careerists are not usually actually interested at all in protecting the interests of the consumers they purport to protect but are usually instead only interested in cosying up to the New Labour government in the hope of another well paid later appointment from that government and then usually also in due course picking up a peerage and/or a knighthood.

I do not intend to make my response to this consultation particularly long because I have made that mistake before in my responses to 10 or more Ofcom consultations, two ICSTIS (now PhonePayPlus) consultations and a recent consultation by the Department of Health, surprise surprise once again on the scourge of over priced NTS numbers that now plague the health service, all thanks to Ofcom and its equally incompetent and telecoms industry infiltrated predecessor, OFTEL.

You say in your report that Ofcom's previous principal duty to "further the interests of consumers of communications services where appropriate by promoting competition" has tended to put the emphasis on short term cost reduction rather than longer term investment in future infrastructure and I would agree with that observation but would then add that Ofcom also has not ever succeeded in introducing real competition in to the telecoms marketplace but instead only sham competition where a number of new entrants have been allowed to land grab customers with call packages that promise low per minute call charges along with apparently cheap inclusive broadband and line rental but then also try to hide from customers that they then become locked in to long contract terms where they soon discover they are subject to numerous other anti-competitive and extremely unreasonable charges for calling NTS (084/7) numbers of companies of whom they are already captive customers.   And in order to let these companies and their accountants guarantee their revenue streams Ofcom has presided over a veritable orgy of anticompetitiveness in the last three or so years (since it de-regulated BT retail prices) in which first basic phone line rental (then called BT Standard but now called BT Unlimited Weekend Calls Plan) was allowed to be hiked up by over 50% and consumers forced to pay for a base BT calls package, even if they did not make calls with BT,  and then in Phase 2 of this abusive alteration to price structures the minimum call charge for calls to 01/02/03 numbers not within inclusive call plans has been hiked 180% by BT in four years (from 5p to 14p).  The reason this has been done is clearly to keep the accountants of these large blue chips happy and so that most customers are now blackmailed in to taking Anytime fixed price call plans, instead of paying as they go per call.  These Anytime call plans are clearly good value for families but for single elderly people not making many calls at all and young single people mainly using a mobile and who are out not at home for most of the day (many of whom only have their landline for broadband) they have seen a vast increase in the cost of their fixed line telephony services.  One presumes that apart from guaranteeing income streams that customers being blackmailed in to having take a conventional POTS fixed line calls package is also helpful to the large telcos in preventing any growth of small competitor voip telephony services over broadband as an alternative to conventional dialled telephone calls on handsets.  However this is hardly good news for the consumer.