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Ofcom consultation: Simplifying Non-Geo Nos 2010 (Read 160,526 times)
Dave
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #15 - Dec 28th, 2010 at 5:11pm
 
loddon wrote on Dec 27th, 2010 at 7:10pm:
Could someone explain how the Ofcom proposals will simplify the current pricing complexity of non-geographic calls, because I cannot see in the Ofcom consultation document.   For example, if you want to find out the charge rate for any non-geo number from Virgin Media, you need to consult their pricing tables to be precise, here :---  http://allyours.virginmedia.com/pdf/uk_non-geographical_calls_a.pdf

Ofcom's proposal is the unbundling of charges imposed by telephone companies (those which originate calls) and Service Providers (the recipients of calls). At the present time, a single charge is published for calling any given number from any given originating provider.

Service Providers will then be able to give accurate pricing information: "Calls cost 5 pence per minute plus your telephone provider's network charge".
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nicholas43
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #16 - Dec 29th, 2010 at 8:40pm
 
Loddon's post on Virgin's opacity makes salutary reading. Do I understand correctly that the charge for a call to a non-geo number actually includes three elements, not two as Ofcom states?
1. The cost of delivering the call, which should normally be the same as the cost of delivering a call to an honest 01 or 02 number.
2. The revenue passed on to the recipient.
3. A markup or handling fee collected by the telecom provider.
I can't see any reference to 3 in the consultation.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #17 - Dec 29th, 2010 at 9:16pm
 
nicholas43 wrote on Dec 29th, 2010 at 8:40pm:
Loddon's post on Virgin's opacity makes salutary reading. Do I understand correctly that the charge for a call to a non-geo number actually includes three elements, not two as Ofcom states?
1. The cost of delivering the call, which should normally be the same as the cost of delivering a call to an honest 01 or 02 number.
2. The revenue passed on to the recipient.
3. A markup or handling fee collected by the telecom provider.
I can't see any reference to 3 in the consultation.

The cost of any call is set by the telephone provider that the caller subscribes to (that is, the originating provider). In order for the call to be connected, the originating provider must pay the receiver's telephone company (the terminating provider) a fee known as a termination charge.

The call charge therefore made up of the termination charge plus whatever mark-up the originating provider wishes apply. In an ideal world, the mark-up on a 084 call would be the same as on 01/02/03 calls and thus, the premium or subsidy to the called party would be transparent.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #18 - Dec 29th, 2010 at 10:03pm
 
nicholas43 wrote on Dec 29th, 2010 at 8:40pm:
Loddon's post on Virgin's opacity makes salutary reading. Do I understand correctly that the charge for a call to a non-geo number actually includes three elements, not two as Ofcom states?
1. The cost of delivering the call, which should normally be the same as the cost of delivering a call to an honest 01 or 02 number.
2. The revenue passed on to the recipient.
3. A markup or handling fee collected by the telecom provider.
I can't see any reference to 3 in the consultation.

If one is to get clever one could break out many other elements and also add other items such as the call connection charge and the line rental that one pays. The Ofcom proposal is that rather than there being a single rate per minute quoted by each originating telephone company for each type of number, there be two constant elements:

- an "Access charge"; set by the originating telephone company to apply to the selected tariff - this would be the same for all "Business Rate" and all "Premium Rate" calls, or perhaps one for each.
- a "Service charge"; which would be the same for each number, regardless of which telephone company originated the call, or under which tariff.

The "Access charge" need not be the same as the charge for calling a "Geographic Rate" (01/02/03) number.

It is not yet clear about how complex the structure of Service charges is to be. I suspect that it would have to reflect the status quo - subject only to some simplification covering rarely used types. I also believe that the system - i.e. the number blocks and the associated service charge rates would have to be published somewhere for reference, if not repeated by every telephone company. The obligation on "Service Providers" to advise of the "Service charge" would only apply to material that they published; this could not provide a valid source of reference for a billing dispute, as it is the telco that would actually levy the charge.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #19 - Dec 29th, 2010 at 10:16pm
 
Dave wrote on Dec 29th, 2010 at 9:16pm:
In an ideal world, the mark-up on a 084 call would be the same as on 01/02/03 calls and thus, the premium or subsidy to the called party would be transparent.

Perhaps "very simple" would be better than "ideal". Those who benefit from inclusive packages covering "Geographic Rate" calls are perhaps pleased that telephone charges are not as simple as some may wish them to be.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #20 - Dec 29th, 2010 at 10:31pm
 
Many thanks, Dave and SCV. Could you provide a worked example? If I can't find an an honest alternative, and have to call a 5p/min 0844 number for say 5 minutes, then have I got the following right?
1. If I'm with BT, I pay BT 10p (or so) set-up plus 25p, total 35p. Of that, 6p goes in VAT. BT keeps (maybe?) 15p, and passes 14p to the operator of the 0844 number, who passes (maybe) 10p to the company I'm calling.
2. If I'm with Virgin, I pay Virgin heaven known what, say 60p. Of that, 10p goes in VAT. Virgin keeps 36p, and passes 14p to the operator of the 0844 number, who passes 10p to the company I'm calling.
If that's anything like right, then how would it change under Ofcom's proposal?
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #21 - Dec 29th, 2010 at 11:37pm
 
Trying to picture what's going off by simply considering how one's call charges are split between the parties leads to much misunderstanding. In the days when there was a single telecommunications network operator (BT or GPO) then that may well have been helpful.

Today's telecommunications system works by operators (communications providers or CPs) interconnecting with one another. A CP functions as an OCP (originating CP) or TCP (terminating CP), depending on whether its customer is the caller or receiver, respectively.

OCPs act in the interests of their customers (the callers) and TCPs act in the interest of their customers (the receivers).

OCPs charge the customers (callers) a retail price for calls and then pay OCPs the termination charge. Retail price is therefore set by with OCPs knowing that their outgoing is the termination charge.

TCPs receive a higher termination payment for 084 numbers than 01/02/03 ones, and what service(s) this goes on is up to the call recipient (the user of the number). Where the recipient is paid revenue directly, this is merely cash-back for that service(s).

Thus, revenue payments are just an effect and turning them down has no effect on the subsidy taken from one's callers. Indeed, anyone who operates a 084 number and declines any offer of such revenue is permitting its provider to keep it. That would be like being offered a discount on a particular product or service and then turning it down.

It is therefore the selection of a particular 08 number by the user that is the deciding factor in the benefit or subsidy that it derives from callers.

Thus, OCPs don't voluntarily (for want of a better word) share some of the call charges with the company being called (either directly or indirectly). If a single OCP doesn't wish to pay, then its customer won't be able to call the respective 08 numbers.


BT call charges for 084x (and 0871/2 and 09) numbers are regulated such that its retail prices are near enough equal to the amount it must hand over to TCPs. That is, it can only put a tiny mark-up on these calls and part of Ofcom's proposal is the removal of this regulation.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #22 - Dec 30th, 2010 at 10:50am
 
I looked at the Ofcom consultation paper and was faced with a 479 page tome of largely irrelevant waffle to plough through.

I tried to respond. All I wanted to say was that people should not be charged more for ringing these numbers, and if there is a charge for HAVING a non-geographical number it should be borne by the recipient.

But in order to respond at all, there is a list of questions resembling an examination paper based on this 479 page tome which you are expected to complete. It is full of acronyms and latin phrases like 'ex ante' and invitations to write essays on whether you think their market assessment is correct etc. Eventually I gave up. I have written to my MP about it instead.

Unfortunately I get the strong feeling that it is Ofcom's intention to sit on the fence for as long as possible and then do nothing. 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.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #23 - Dec 30th, 2010 at 11:11am
 
Excoriator wrote on Dec 30th, 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).

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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #24 - Dec 30th, 2010 at 11:13am
 
Excoriator wrote on Dec 30th, 2010 at 10:50am:
All I wanted to say was that people should not be charged more for ringing these numbers, and if there is a charge for HAVING a non-geographical number it should be borne by the recipient.



This is the key point.   Ofcom have not addressed this in their massive self-delusional report.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #25 - Dec 30th, 2010 at 1:12pm
 
loddon wrote on Dec 30th, 2010 at 11:11am:
Excoriator wrote on Dec 30th, 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.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #26 - Dec 30th, 2010 at 10:32pm
 
nicholas43 wrote on Dec 29th, 2010 at 10:31pm:
Many thanks, Dave and SCV. Could you provide a worked example? If I can't find an an honest alternative, and have to call a 5p/min 0844 number for say 5 minutes, then have I got the following right?
1. If I'm with BT, I pay BT 10p (or so) set-up plus 25p, total 35p. Of that, 6p goes in VAT. BT keeps (maybe?) 15p, and passes 14p to the operator of the 0844 number, who passes (maybe) 10p to the company I'm calling.
2. If I'm with Virgin, I pay Virgin heaven known what, say 60p. Of that, 10p goes in VAT. Virgin keeps 36p, and passes 14p to the operator of the 0844 number, who passes 10p to the company I'm calling.
If that's anything like right, then how would it change under Ofcom's proposal?

The figures used are (admittedly) rough, however they serve to illustrate the point, so I will stick with them. Under the proposed changes:
  • The Business Rate user in question will advise that there is a Service Charge of 5p per minute to call their number, in addition to the access charge levied by the caller's operator.
  • If Virgin Media were to set an Access Charge of 10p + 5p per minute for Business Rate numbers, the relevant call would still cost 60p.
  • It is possible that BT would retain an Access Charge of 10p + 1p per minute, however the latter (which is actually much smaller) is currently set at a minimal level by regulation, which would be lifted.

Whilst the cost of a call to a geographic number does not have to be used as the Access Charge, the present (non-inclusive) charges for daytime calls to geographic numbers may offer some indication of the level at which Access Charges will be set. For BT this is currently 10.5p + 6.5p per minute, for Virginmedia 12p + 8.5p per minute. Because both companies promote inclusive packages to cover calls to geographic numbers these should be thought of as "penalty charges" for calling outside the terms of the call plan / package in place, so one would expect the Access Charges for NGCS to be a little lower.

The key point is that BT alone is currently prohibited from adding an Access Charge (other than minimal cost recovery) to the Service Charge for calling NGCS numbers - the call setup fee escapes this regulation. BT is not regulated in its charges for calling Geographic Rate numbers. Other operators cannot currently be subject to any price regulation. - proposed new legislation in implementation of an EU Directive will enable this to be introduced, so that they will have to respect the Service Charge levels in addition to their advised Access Charge.

One hopes that the telcos will offer some indication of the levels at which they are likely to set their Access Charges as they respond to this consultation. All that Ofcom can do is demand that they publish and apply them - it cannot set the level, nor would it be wise to publish any forecast of what they are likely to be. The assumption is that the Service Charges would be set to broadly keep the revenue share at current levels, i.e. around the BT pence per minute rate.

(N.B. All charges will be adjusted from 4 January 2011, only some of the new rates have been published.)
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #27 - Dec 31st, 2010 at 2:22pm
 
Many thanks, SCV, for the only understandable explanation I've seen anywhere.

In principle, I think micropayments via telephone bills are a bad idea, because it is totally opaque who is paying whom how much to do what. Moreover, the user has no clear contract with the service provider, and no clear means of redress when the service screws up.

I take the point that, for example, conference calling via an 0844 number is a useful service. However, I think it would be better if access was via a geographic number, and users had to have an account with the service provider which they settled by other means. I even think that dupes who want to waste their money voting for X-factor etc should call a geographic number, and be transparently billed by the TV company. The same goes, as another example, for enquiries about visa applications, which often seem to be on an extremely expensive 09 number.

In practice (unless someone here knows better), Ofcom doesn't have the power to ban micropayments. So, in my opinion, constructive responses need to be focussed on making the regime as transparent as possible. I like the idea of forcing originating providers to state clearly the huge charge they make for calls to NGNs, compared to the marginal price of zero they all offer for calls to geographic numbers. I'm still muddled about forcing service providers to state the termination price, because it leaves opaque the split between the service provider and the provider of the NGN.

Suppose everyone calling (for example) an 0845 number is told, every time, something on the lines "We [BT] charge you 11p plus 2p a minute to call this number, and the outfit you are calling charges 5p a minute on top of that [which they have to share with the provider of the 0845 number?]". Consumer rage might lead more banks etc to use geographic numbers.

Does Ofcom envisage that the originating and terminating providers' charges must be explicitly itemised on bills? Can't see this mentioned in the consultation documents, but life is too short to read all of the documents!

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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #28 - Dec 31st, 2010 at 4:26pm
 
nicholas43 wrote on Dec 31st, 2010 at 2:22pm:
... In principle, I think micropayments via telephone bills are a bad idea, because it is totally opaque who is paying whom how much to do what.
... in my opinion, constructive responses need to be focussed on making the regime as transparent as possible.
... Consumer rage might lead more banks etc to use geographic numbers.
... Does Ofcom envisage that the originating and terminating providers' charges must be explicitly itemised on bills? Can't see this mentioned in the consultation documents, but life is too short to read all of the documents!

There are many who share the view that micropayments through telephone bills should be abolished. If opacity is the strongest argument against them, then introduction of a transparent regime would weaken, if not totally undermine, this position.

Each telephone company offers access to many different Business and Premium Rate services, and each service may be accessed from many different telephone tariffs.
For this reason, Ofcom proposes unbundling the respective elements of the charge and does indeed propose that they be shown separately on telephone bills.

As I see it there needs to be three points of publicity for the new charges:
  • The "Access Charge (or charges)" must be prominently declared in all telephone tariffs. This is simply achieved by existing Ofcom regulations covering telcos.
  • A table showing the level of "Service Charge" associated with each number range needs to be published. There will be only one such table, so there is no need for every telco to reproduce identical information, even though it forms part of their charging structure and will have to be loaded into their billing engines. This table is presently maintained by BT, because of its special regulatory position, however this would have to be passed over to Ofcom, as it would form the basis of a regulation of billing. It would be most helpful if Ofcom could publish this in an accessible form, perhaps with a nice on-line lookup feature.
  • The key point is that service providers would have to show the "Service Charge" applicable to their numbers when those numbers were published. For PRS providers this is essentially required by existing regulation, although the terms would have to be modified to reflect the fact that a clear charge could be advised, as given in the Ofcom example.

    087 users are already covered by this requirement, even though these ranges are to be re-designated as part of Business Rate.

    There is an open question about whether and how 084 users are to be compelled to advise their Service Charge. For this to be made a regulatory requirement, enforced by Ofcom, the only mechanism currently available is to classify them as "PRS" and for the enforcement to be undertaken by PhonePay Plus. This is far from ideal, especially as the re-designation of 087 as Business, rather than Premium, Rate shows that Ofcom accepts that there is a considerable difference between users of 087, as against 090, numbers.

    I believe that the important point is to get the practice of Business Rate users advising their Service Charge established and accepted as the norm. Whilst tight regulation and vigorous enforcement is attractive, if the resources necessary to carry this out are not available then there is little point. I would not be unhappy if the necessary effect is achieved through a clear statement from Ofcom, acknowledged and applied by Trading Standards, the ASA and other relevant bodies, also endorsed and imposed as a requirement by the Cabinet Office to cover all of the public sector.

    I know that many will wish for Ofcom to make the requirement mandatory, but Ofcom's powers and resources are not necessarily equal to the task in practice. In my own dealings with users of Business Rate numbers I am happy to imply, infer and hint that Ofcom has already designated 084 numbers as "Business Rate" and will shortly be making declaration of the "Service Charge" mandatory. History shows that many will comply with "Ofcom regulations" when in fact there are no such regulations actually in force - there is often a lot of bluff involved (I am happy to discuss examples privately). One reason for the size of Ofcom's published documents is the need for the truth about the limits of its powers to be obscured.

I see the fear of potential consumer rage as being the most powerful weapon in getting Business Rate number users to cease the practice where it is inappropriate. I would suggest a message along the following lines to be sent to every inappropriate user of 084 numbers, now:

Quote:
Will you be happy to advise that you impose a Service Charge on calls to your 084 number, when compelled to do so?
If not, adopt geographic or 03 numbers now, in your own time, whilst you can claim credit for taking the initiative, before you are embarrassed into changing by a regulatory deadline.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #29 - Jan 8th, 2011 at 9:29pm
 
I will put in a response to this consultation listing all the numerous previous occasions when OfCoN promised action and then did nothing including most notoriously over 070 PNS numbers where they specifically committed to changing them to 06 numbers to stop the scammers making people think they were mobile numbers only to change their mind when the most important scammers no doubt leaned on a couple of good friends on the OfCoN board about all that lovely lolly they were about to lose.

However I will not expect any significant changes to be made as a result of this consultation that will stop any of the scams or make it more obvious what you are being charged to make a call.

I'm sure that FLEXTEL and their similarly slime like commercial allies are limbering up even now to run their previous arguments that it is far too difficult to reprogram burglar alarms and personal medical emergency buttons to these new simplified number ranges and/or that call price announcements for non standard priced numbers cannot be allowed because it will affect their automated dialling equipment.

So hence the current morally bankrupt status quo will remain in place after we have all worn ourselves our responding to yet another sham of an OfCoN consultation.  The only possible circumstance in which this will not take place and actual change will occur is if this consultation has actually become about due to pressure on OfCoN to hold it in the first place by ministers with the current coalition government.
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