There have been hints in the forum that this was coming. I offer some random thoughts.

We may have doubts about how far Ofcom is truly open to suggestions, however the stated terms of this exercise deny us the opportunity to claim that those who contribute to the forum were not asked to present their ideas. The way the suggested questions are framed suggests that Ofcom is well aware of where the concerns lie.

I must remind readers and members of the forum that there is no formal group in existence which would be naturally responsible for presenting a response on behalf of saynoto0870.

There is the possibility that someone could be asked (or could choose) to collect together many of the ideas posted in the forum and present them as a collection of anonymous ideas. Presenting a specific set of opinions as being representative of the members of the forum in general is a more difficult task, as this would require some expression of consent to be valid. (Prior publication with the opportunity to register dissent over a reasonable period could be deemed adequate.)

More difficult yet is the idea of presenting specific proposals for action that Ofcom could take. Ofcom exists by statute and it cannot shut itself down, which makes a highly popular suggestion unfeasible. Whilst it is independent of government, Ofcom is open to political pressure and it could face near abolition under proposals presented by one party currently hoping to form the next government. The strong bias against increased regulation, which has been pressed by the (for the moment) current government, is echoed or exceeded by those likely to participate in a possible new government. This is reflected in the comments quoted above. Very few of the votes likely to be cast next Thursday will be counted as being in favour of increased regulation.

Those who wish for services to be withdrawn or for wholly new regulations (within the scope of Ofcom's powers) to be introduced, must state their case, or express their opinion. I would however suggest that there may be more purpose in suggesting achievable alternatives. Proposals for action outside the scope of Ofcom's powers will doubtless be received and may be passed on, but they would perhaps be better directed appropriately.

The comments suggest that the specific proposals that will emerge from Ofcom's work will themselves be presented for consultation where this is thought appropriate. It must be understood that Ofcom already has many ideas, but wishes to take this opportunity to test the strength of public opinion and to invite insiders to present their views in public.

If members feel that there should be some collective action on behalf of "saynoto0870" to either present some type of collective response, or perhaps attempt to engage the media to encourage widespread public response on any specific point, then volunteers will need to become engaged to lead and to undertake this work.

Any offers?

I have just looked at this consultation, and I was surprised to find that the full consultation document only runs to seven pages, the meat of which covers just four pages. So it can be read in full quickly unlike many others.

I would like members to post their thoughts here. The deadline for receipt of responses by Ofcom is Friday 28^th May 2010.

Your proposals, SCV, are pointing in the right direction but do not go far enough nor reach their logical conclusion.

I approach this question of "what should be done about non-geographic numbers" from the starting point that Ofcom is the regulator and as such its primary duty is to protect the consumer from scams and rip-offs.   Ofcom, I understand, is charged with ensuring and encouraging an open, competitive marketplace but it must also define the rules to ensure that companies do not mislead or take unfair advantage of the consumer.

The problem is that 084 and 087 numbers are wrong in fundamental concept and are unethical by design.    The concept of all 084 and 087 numbers contravenes normal business practice, conventions, ethics and common sense.    I say this because the wrong person pays for the 084 and 087 product -- they are rip-offs by design.   They are designed to mislead the consumer who does not get what he pays for.   The consumer is required to pay for the features and facilities from which another person or entity benefits.   The consumer does not get what he pays for, someone else does.

Why do I say this?   Because the point about 084 and 087 numbers is that they are non-geographical and they enable certain claimed functions and facilities which the "user" (i.e. the company using the number) may choose to use or select from a product choice such as :
call forwarding and diverting
network queueing
call menus of options for callers
call monitoring and statistics
prestige,status and kudos, national image
etc
The point is that these functions and facilities are primarily of benefit to the "user" and not the caller.   Some may argue that the caller gets some benefit in terms of access to the "user" organisation and I can see there may be a small element of that but I see the overwhelming benefit accruing to the "user" in that he is managing the route of access into his organisation for his benefit.    Therefore I say it is the "user" who should pay for these functions and facilities and not the caller.    It is the "user" who is buying the service, choosing who his supplier will be, deciding whether or not he is satisfied with the service and deciding when to enter and terminate contracts for the supply of the 084/7 number -- and not the callers (consumers) who have no decision options or choice about who provides the number and its associated facilities.  

I see three parties involved here -- the telephone service supplier who provides the 084/7 number and the network facilities, the "user" who is the customer of the telephone service supplier, and the consumer or member of the public who wishes to call the "user" company.    So in normal business terms the User engages in a contract with the phone company for supply of a service to them, the phone company supplies the 084/7 number and associated service and the contract and payments are between them.   This part of the business transaction is between the -phone company and the "user" company/organisation and is nothing to do with the consumer or caller.

So my contention is that the "user" company/organisation should pay for the service and the caller/consumer should pay for his call at his normal rate to his telephone service supplier, in other words at his geographic rate.   This would mean that "revenue sharing" is banned.    This would remove all the problems with 084/7 numbers which have frequently been described in Parliament as "rip-offs".    It would remove the danger of all sorts of scams, primarily the practice of making callers wait in a supposed queue so that the "user" company can accumulate revenue from the calls.    This is a major problem because the 084/7 system is designed to encourage companies to increase the delays for callers because they earn money from delays.   This is contrary to all common sense and good ethical business practice and it should not be allowed.    Ofcom have failed the general public and consumers over the years by allowing this scam to continue and increase and Ofcom should now put an end to it.    I was told just a few days ago that one of our largest banks, part publicly owned and whose name begins with L, have a standard practice of making all callers wait for a minimum of 9 minutes just in order to ensure they earn a certain amaount of revenue.   This is a disgrace, it is daylight robbery of their customers, it should be illegal and Ofom should stop it happening.   Just one example of many thousands I am sure.

You may say that what I propose would make 084/7 numbers work in exactly the same way as 03 numbers -- and I would reply YES.

My comments on 0800, 07 and 09 numbers will appear in my next post.

Loddon

Some brief points in response to your well-argued comments. Some of these extend my own comments.

• Ofcom has to represent the interests of consumers of telephone services. Users of 084 numbers are part of that group. If they wish to be able to subsidise the costs they incur in providing additional facilities at the expense of callers then Ofcom has a duty to enable them to do so. With charities and public services, if the "consumer" does not pay, then it is the donor or taxpayer. In the private sector, a business has to cover its costs by income, so the "consumer" always ends up paying in one way or another. The issue of "who pays" for a benefit is ultimately a matter of shifting costs from one of these groups to another.
• In principle we agree about 084/7. 0871/2/3 is already classified as PRS. I propose that 0845 and 0870 should be essentially treated in the same way as 03. 0844/3 is the snag; as I do not see it as being able to be treated as PRS, although I demand that it be designated in some way that makes it recognisable as essentially the same. In an ideal world 0844/3 and 0871/2/3 (and 070) would be moved to 09 to provide greater clarity, however I do not see that as achievable.
• 070 is the remnant of what may have seemed to be a good idea at the time - a "personal number" to contact someone wherever they may be. This never took off and has been horribly abused.
• I believe that resolution of the 080 from mobiles issue will have to await the outcome of moves to transfer the additional cost of mobile calls to users of mobile phones. Whilst this premium remains in place I do not support the idea of those who are not prepared to pay it being prevented from offering free calls from landlines by using a 080 number. If the premium were set to remain then there would be an argument for opening a separate range for those who wish to offer "free from landline only" calls. The present scheme under which the mobile telcos waive their charges for 080 calls to registered "helplines" is a valuable exceptional arrangement, which should not be compromised.

Many thanks (and also to CJT-80) for airing your thoughts, It would be great to hear some other views.

Is it not now the time to campaign for “freephone” calls from all mobile numbers to be exactly that – FREE !!  Something for "saynoto0870" to take up?

I’m involved with a business line and we have BT’s OneBill Plus.  Calls to land lines are capped at 5p for one hour and calls to mobile numbers are capped at 20p for the same time.  Therefore, the costs of taking a call from a mobile number should not be excessive.  We also have a number of BT mobile phones.  The service allows us to divert calls to any phone number.  If the diversion is to another number in the group, there is no charge, either for the diversion or the call.

As an aside, calls to 0845 and 0870 numbers are still charged by the minute unlike private BT customers and the bill differentiates between "local" and "national" calls.

Kiwi_g wrote on May 21^st, 2010 at 1:44pm:

Thanks for reminding us that the world is different for business users - including the retention of distinct rates for local/national calls, which do apply on some tariffs, if not on yours. The BT "giveaway" to residential customers on 0845 and 0870 numbers, by making them inclusive, is also seen for the exceptional measure that it is. One could also point out that BT residential customers are being forced to pay for inclusive 0845 and 0870 calls, whether or not they want them. This means that all residential BT customers with inclusive packages are subsidising users of 0845 numbers.

If the cost of paying for mobile calls is four times that of landline calls, I cannot quite see where the suggestion that the difference is "not excessive" comes from. I respond to the point about campaigning for "free to caller" in my preceding contribution.

derrick wrote on May 22^nd, 2010 at 9:07am:

A fair point. This is indeed perhaps the difference for the recipient between having redirection facilities on a 03, rather than a 01/02 number. It is of course wrong to say that there is "no cost for incoming calls" on 01/02 numbers - it is part of the monthly charge (indeed that is one of the options for mobile providers as they lose the ability to collect this fee from callers).

The charge for a redirection facility on 01/02 numbers may indeed be reflected in a monthly fee, rather than on a per-call basis. That is what I was referring to when I said "03 may provide the necessary redirection more readily". I was thinking of those cases where there is not a simple one-to-one relationship between a 0800 and an underlying number, i.e. "where the underlying number cannot simply be released for direct dialling". I am sorry if I did not make that clear.


When I said "It does not however provide 'free' calls, as many mobile users pay for 01/02/03 calls" I should have made it clear that by "free" I was referring to there being no marginal cost for the call. The marginal cost may indeed be less for 01/02/03 calls than 0800, but it is not necessarily nil.

I fully support efforts to get 080 users to offer suitable 01/02/03 alternatives for mobile callers, under the present regime. I suggest however that we should not let this modest advance, and our concern about terminology, cause us to lose sight of the interests of those who may wish for mobile users to call them (other than on a registered helpline) whilst incurring no marginal cost for the call. These are people who want to subsidise the caller's costs!

I am personally happy with this latter arrangement being described as "free to caller". I see this as a suitable abbreviation of "free of any marginal call cost to the caller". I do however acknowledge the repeated concerns of those who do not, but hope they recognise that the disagreement on this particular point is essentially a semantic debate on the validity of this particular interpretation.

I see severe dangers in a, fully worthy, campaign for the use of 01/02/03 alternatives becoming confused with a campaign for "freephone" calls from mobiles to be FREE. If we expect others to be clear in what they refer to as "free", we must surely do the same ourselves.