NGMsGhost wrote on Jan 8^th, 2011 at 9:29pm:
One hopes that these comments may be balanced by reference to generally positive, if incomplete and inadequate, actions such as the removal of revenue sharing from 0870 and the introduction of 03xx.

NGMsGhost wrote on Jan 8^th, 2011 at 9:29pm:
There will undoubtedly be confusion about the degree of clarity which is required in statements about call charges, given the limits of Ofcom's statutory powers of regulation. I will personally be keen to hype up the effect of Ofcom's powers in the hope of achieving greater clarity; I recognise that others will be reassuring users of Business Rate numbers that they will not be under any absolute compulsion to be any clearer, and that their scams can continue.

NGMsGhost wrote on Jan 8^th, 2011 at 9:29pm:
My reading of the consultation document suggests that this point is already well taken and that there are no specific proposals regarding provision of call price announcements. The proposals clearly focus on the duty of the Service Provider to advise of their Service Charge, and this is extended from "Premium Rate" to "Business Rate" numbers.

NGMsGhost wrote on Jan 8^th, 2011 at 9:29pm:
The process of which this consultation is but one stage was well in place before the General Election. Having closely observed the relationship between the responsible Minister, Ed Vaizey, and Ofcom I think it quite likely that he is unaware that the consultation is even happening. He has not commented on it and I would doubthis ability to understand even the very basic principles of what is involved. It is very clear that the coalition government is firmly opposed to any increase in regulation or the power of regulators (notwithstanding Politically-motivated dealings with reference to Banks). The increased powers that will be granted to Ofcom in the Spring arise solely from an obligation to implement an EU Directive.


It would be foolish to expect that a few changes by a "light touch" regulator, in a political environment that is fundamentally hostile to regulation, will stop scams and deception. The limits of Ofcom's powers, not to mention the related weakness of its approach to every issue, cause serious doubts to be properly raised over the likely effectiveness of what is proposed. I firmly believe that intense and positive efforts by campaigners will be required to bring about successful achievement of the worthwhile proposals that are in the consultation document. Even at this stage there is valuable support for putting additional pressure on users of "Business Rate" numbers to cease the practice.

The past is littered with failures and disappointments and there will undoubtedly be many more in the future. I approach this consultation by looking to see what may be achieved from it and the actions that may follow in subsequent stages of the process. I do not expect 100% success, however I am keen to achieve as much as is possible. I regret the fact that strong and capable potential allies perhaps take a different view.

bbb_uk,

I am encouraged to see that you and I are of a like mind on these matters even if I do not seem to have been on the same wavelength of late as Dave.

It grieves me a a former local district councillor to say that people should not expect anything to change from responding to a consultation since consultations on some matters by local councils etc are often genuine and the views expressed do lead to real changes in the original proposals or even sometimes to a proposed change being scrapped.

However it is hard to have much faith in the main regulator OfCoN or even worse that devil's spawn offspring it created first called ICSTIS and now PhonePayPlus who ran a consultation on its proposals for 0871 numbers that was resoundingly rebuffed by nearly all of the several hundred members of the public who responded as being a quite useless proposed control regime that would not stop any of the scams or abuses only for the original proposals to be implemented completely unchanged.

OfCoN will only change its ways if it is under genuine political pressure to reform the NGN system.  So the real question is why did they bother launching this consultation now because on the face of it surely someone somewhere is badly upset about the total bankruptcy and illogicality of the current state of its National Telephone Number Plan (NTNP) for it to have bothered coming up with this consultation.

If Ofcom really does pamper to the whims of private companies which it is supposed to be regulating, then this would appear not to be confined to telecommunications. Radio stations have had the terms of their licences relaxed so as to allow them to network programmes across their stations. At one time this would have been unthinkable and all stations would have had to produce their output from within the area they serve.

Perhaps we need another thread in which to discuss the Politics of regulation, or the way in which members contribute to the forum. Alternatively, perhaps nobody is interested in discussing proposals for how calls to non-geographic numbers should be billed and the costs presented, so we may as well carry on the discussion that has developed here.

The problem with Ofcom's powers in relation to Silent Calls is that they are not designed for light-touch general regulation, which is Ofcom's style in operation. Ofcom simply refuses to properly discharge its statutory duties in this area, as the first stage of its use of the powers is an intervention in a specific case, with the imposition of specific enforceable regulatory requirements as the second stage. Ofcom prefers to pretend to hold general regulatory powers that it does not possess. It is for this reason that, in the context of the "bonfire of the Quangos", I have proposed that administration of the relevant powers be handled by a different body. I do not expect Ofcom to change its nature.

Following representations from myself, it was the relevant government minister who, on behalf of all members of a parliamentary committee conferred an expectation on Ofcom "We expect you to use your powers to eradicate the nuisance of Silent Calls" - I frequently quote this expectation, and echo it; that is the only basis on which I hold such an expectation.

As for business being "dirty", I would more commonly be expected to refer to it being amoral. Most businesses would wish to be seen to be clean, which is how positions adopted by Ofcom can be valuable in setting a standard to which many will respond. There will however always be a fringe of downright dirty players who will only occasionally attract the attentions of regulators.

I hope that moderators will edit contributions to the forum based on the content, rather than the authorship.

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I had understood the approach of the coalition government to matters of regulation to be extremely "liberal". (I use this word with a small "l" to refer to the orange wing of the LibDems and the drier wing of the Conservatives.) This suggests that there would be no enthusiasm for addressing anything with the word "Plan" in its title, such as the NTNP, other than to abolish it. I see the fact that Ofcom survived the quango reorganisation with its regulatory role in relation to telecoms intact as being down to the wet Maude at the Cabinet Office and the yellow Cable at BIS, in addition to it having not ever having been seen to give industry a particularly hard time.

It is important to note that Ofcom is accountable to parliament, not to the Government. Under the previous administration an unduly close relationship developed, seen not least by the appointment of a past Chief Executive as a "goat" - an ennobled minister in the relevant department. There is every indication that this close relationship is being continued with the current government. I see this as improper and dangerous. The former because it undermines proper accountability; the latter because the government may find itself with an unreliable friend who can assert its independence whenever doing so may suit its purposes.

If anyone has a clear insight on relevant matters of government policy it would be interesting to hear this explained.

catj wrote on Jan 21^st, 2011 at 11:30pm:

The quoted comment was in response to the development of the Political aspects of the topic in a previous posting. It remains to be seen whether, with the drier Jeremy Hunt now wholly responsible for Ofcom, we should await removal of this obligation from Ofcom as the government policy of abolishing regulation and removing red tape is pursued. Perhaps consortia of telcos would be in a better position to know what their customers want!

Because Telcos currently have an absolute duty to comply with the terms of the plan as published, I will refer to "misleading and irrelevant references" in agreeing with the point made.

The options outlined in Section 6 of the consultation document imply proposals which will be implemented partly through revisions to the NTNP. As there are no concrete proposals at this stage, there are no specific proposed revisions to the terms of the NTNP.

Perhaps others would share my view that the questions at the end of section 6 (pdf page 106) read more like an examination paper than a serious attempt to engage stakeholders.

NGMsGhost wrote on Jan 22^nd, 2011 at 1:58am:

On this occasion it is precisely that type of response which is invited, from those who simply do not wish to signify approval of what is stated. The problem arises because the terms of valid responses are specifically restricted to comments on very lengthy dissertations on particular issues.

The major problem from my perspective is that the focus is on a perceived failure in the market for telecommunications services. Misuse of Business Rate numbers by public bodies is a matter relevant to Ofcom's primary principal duty, to further the interests of citizens in relation to communications matters. That duty demands nothing more than the truth about 084 numbers being clearly exposed and understood - it has nothing to do with Ofcom's separate secondary principal duty to regulate markets in the interests of consumers and encourage competition.

NHS Direct, HMRC and DWP Agencies are not providers in the market for telecommunications services, nor, in my opinion, should they be classified as such, so as to join providers of "adult" chat services within the self-regulatory scope of PhonePay Plus. It may be that the government wishes for these public services delivered by telephone to be open to competition, as Boots is now competing with NHS Direct on the internet through its branding of WebMD, however Ofcom is unduly extending its role if it believes that it has a duty to promote such competition.

SilentCallsVictim wrote on Jan 26^th, 2011 at 3:07am:

Perhaps this should have a thread of its own.

SilentCallsVictim wrote on Jan 26^th, 2011 at 10:57am:


Surely you at least must have done so SCV even though I must confess to only so far having read the bullet point summary of what is proposed.