loddon wrote on Dec 30
th, 2010 at 11:11am:
Excoriator wrote on Dec 30
th, 2010 at 10:50am:
I see no reason whatsoever why these charges cannot be abolished overnight. It is a moral question - can charging callers extra money without telling them how much in return for nothing be justified- not one of market forces. It is not as if there are not other ways in which services such as premium rate calls can be paid for - typically with a credit or debit card.
A man after my own heart, Excoriator. I agree with your comments about this paper as well as the basic principle that charging callers for using 0843/4/5 and 0870/1/2 is basically a scam. Callers are not the customers of the phone companies, the organisations using 08 are, and it is those organisations who should pay for the special facilities and services provided by the 08 number services (NGC services as Ofcom call them).
It has long been established that Premium Rate Services can be provided, e.g. on 090, 118 and 070 numbers, given that the cost of calling is advised. This principle is embedded in the Communications Act 2003. It is however fair to argue that this facility should be withdrawn and that any necessary change to legislation be introduced by a government that stands firmly opposed to extending regulation of commercial activity.
Ofcom now believes that the way in which the cost is advised must be simplified and that this revised approach be extended to cover 084 and 087 numbers, under the title "Business Rate" and with a cap on the level of the "Service Charge".
The key proposal is that the "Service Charge" and "Access Charge" elements be unbundled. The former is to be advised by the service provider, remaining constant for each number regardless of how one calls. The latter is to be advised by the telephone company, to apply to all Business / Premium Rate numbers called under the terms of the relevant telephone service contract. Presently, the aggregated BT charge is all that can be reliably advised by service providers.
Ofcom has to secure the agreement and compliance of all stakeholders as it seeks to further the interests of consumers of telecoms services, including users of Premium and Business Rate numbers, and has to ensure and demonstrate that it is acting within the bounds of its limited regulatory powers. This is why the arguments have to be made at length. I concur with the view that the document is poorly presented, however I am more concerned with the outcome, than the fact that Ofcom falls well short of what we may wish to be.
There is no reason why responses that totally reject the underlying principles of the proposals could not be submitted. I sense however that the views being expressed go much deeper, addressing the whole nature of Ofcom's role and the legislation under which it operates.
For myself, I disagree with the views quoted above. I believe that it is perfectly proper for a caller to pay for services delivered by telephone through their telephone bill, if they are properly advised of the cost. Whether the caller is prepared to pay the price in return for whatever service is delivered is a matter between them and the person called. (I do not believe that this is necessarily related to the benefits of any particular technology, nor that any third party could make the necessary determination about what is a fair price for a particular service.)
I see Ofcom as seeking to improve the situation with "Premium Rate" numbers and to create such a situation where it has not previously existed, with "Business Rate" numbers. I wish to do all I can to see that this comes about effectively and properly. The published proposals are the only ones under consideration at present; I see a serious prospect of them delivering some good effect and am keen to make this as strong as possible. I accept that some wish to reject them out of hand.
It is for those who believe it is improper to use the revenue sharing mechanism as a means of causing those who use a service to contribute towards, or pay in full for, the cost of providing it to argue their case. I have always seen the issue as being about transparency of pricing, rather than the fundamental principle of charging for services through the telephone bill. I firmly believe that if the additional cost of calling certain numbers were made clear, then in cases where a charge was improper or could not be justified it would have to be withdrawn. I believe that if the Ofcom proposals were enacted then public services and most customer service lines would have to migrate to Geographic Rate numbers, so that the cost of these services would have to be met by taxpayers and customers in general.
I accept that there are issues with achieving transparency, however I believe that these are worth addressing and that the Ofcom proposals provide a sound basis for discussion of how this may be achieved. It may be helpful to our discussion if we could distinguish between those who argue that price transparency could not remedy the situation with NGCS and those who wish to discuss the Ofcom proposals.