SilentCallsVictim wrote on Feb 20^th, 2011 at 9:41pm:
Then I anticipate that the cost of calling these NTS numbers will rise, especially 0844.

Most OCP's have their cost of calling NTS numbers like 0844 similar to BT's charge.  If this restriction is removed from BT then BT will in all honestly increase the cost (access charge as it will be known then) and other OCPs will just copy.  So a 5ppm call now is likely to cost more (when adding the access charge and service charge together).

A similar thing happened with the line rental.  Before BT's restriction on charging line rental was removed, other OCPs charged around the same as BT to obviously remain competitive.  After BT's line rental restriction was removed, BT obviously increased their line rental and has kept increasing it since - along with call charges and call setup fees and when BT increases their charges, other OCPs just basically copy.  Where is the competition in that?

SilentCallsVictim wrote on Feb 21^st, 2011 at 7:13pm:
I know where you're coming from and I agree that cross-subsidy exists but going from past experience (aka line rental), the cost of line rental went up and up and others costs went up and up as well.  I have seen no evidence, obvious anyhow, that the cost for BT for line rental was cross subsidised and so when line rental went up, other costs didn't (ie no need to cross subsidy now that line rental restriction removed).

If we were in a perfect world then removing restriction on NTS numbers may mean a, for example, slight rise to NTS numbers but then no rise anywhere else like other call charges, line rental, etc because NTS numbers no longer has to be subsidised.  However, were not in a perfect world and I simply do not believe that removing restictions on NTS numbers and a subsequent price increases means other rises wont happen.

Competition, IMHO, just doesn't really exist for landline & calls like it does for mobiles.  For example, BT whom include calls to 0845 have to obviously pay for these calls despite so-called offering them free (for those on an appropriate tariff) so obviously BT have to cross-subsidise these costs from other areas and hence the increase after increase.

However, most other OCP's don't include calls to 0845 so when BT increases their costs pretty-much across the board there shouldn't be such a need (and rush in some cases) for these other OCPs to follow them.  However, they basically do.

Basically, there is no real perfect answer where everyone wins lol.

Quote:
Last I noticed most OCPs (mobile providers excluded) generally charge around the same for calls to NGN so the, "calls to 0844 ... cost 5ppm from a BT landline, other providers may differ" to be as accurate one can get (at the moment).  Obviously the main difference is mobile OCPs like I mentioned and VirginMedia, who must be the UKs most expensive landline provider for calls to NGNs, and are an exception to the norm for landline providers.

catj wrote on Feb 22^nd, 2011 at 4:54pm:

Interesting indeed.

What is worthy of note is that "03" is only mentioned as the penultimate word.

Awareness is built and consumer perceptions changed very slowly. Ofcom has a lot of work to do. Much of that has to be achieved by building alliances with those who can help in putting across the messages that it wishes to convey. If few providers are able to issue 03 numbers as part of attractive deals, then they will not be promoted by the "numbers" industry.

Ofcom has to recognise that it has a positive role as well as the negative role of a regulator. Its positive ideas should not be simply restricted to the way in which it formulates regulations.

Somewhat belatedly perhaps - I have published some simple notes reflecting a personal view on responding to the Ofcom consultation - http://tinyurl.com/dhtiny/doc/?CONSRESP.pdf.

idb wrote on Mar 8^th, 2011 at 1:01am:

Fairish comment. There is no structure that justifies saynoto0870 being classified as a lobby group. It has a database of alternative numbers and an open discussion forum. It is run on a commercial basis supported by advertising.

I suspect that moderators would take exception to the suggestion that individuals post under different identities so as to manufacture dialogue, as they would probably seek to prevent this. It is however not an issue of any great consequence - it is an open forum - anyone can express whatever opinion they wish. Furthermore, I would totally defend the right of contributors to remain anonymous, if they wish.

The use of a personal number on the domain record is unfortunate, and just the sort of thing that many members would seize on as the basis for discrediting all that is published here. The general style of the comment in the consultation response is also not entirely unfamiliar to those who read these columns (although I am not suggesting anything improper). I think that Mr Wilson is indeed one of us, at least in spirit.

Perhaps Ofcom has a duty to check out possible use of spoof company names before publishing responses.

Can I take this opportunity to remind everyone that this consultation deadline has been extended to 31st March 2011 --- in 4 days time.  There is still time to have your say in the most important consultation issued by Ofcom to members and users of this website, I would have thought, because this website and campaign is all about non-geographic numbers, their use and misuse.

I urge all to respond now and reinforce our campaign.

I would also point out that my own response is published here http://stakeholders.ofcom.org.uk/binaries/consultations/simplifying-non-geo-numb...

Regular readers of this Forum will be aware that I have been pressing the point for quite a long time now that 0843/4/5 and 0870/1/2/3 numbers are fundamentally a giant rip-off of the public and callers in general because the costs for such numbers are imposed quite wrongly, unethically and illegitimately on callers and not the companies and organisations which exploit and benefit from these numbers.    While I have had some moderate support for this point of view from a few contributors to this Forum I have felt that not many people entirely get it or yet support this point of view.   It has  heartened me to discover that at least one responder to the consultation agrees and has expressed their views in this response which I urge everyone to read and perhaps be inspired to submit their own response   ----  http://stakeholders.ofcom.org.uk/binaries/consultations/simplifying-non-geo-numb...

Antelope Consulting appear to be an authority on these matters given their profile of providing advice and consultancy on  this type of issue in 60 countries around the world to both Governments and Telecomms Authorities.

Again I urge everyone to take this unique opportunity to influence Ofcom while you still have the chance.  If some feel that they agree with or sympathise with my point of view and that of Antelope Consulting, then a response reinforcing that would be greatly appreciated.

Some extracts from my own submision :---

083/4/5 and 0871/2/3 Numbers
Regarding 0843/4/5 and 0871/2/3 numbers the problem is that they are wrong in concept and wrong in design . They are fundamentally unethical and are quite rightly distrusted by the public. I believe the new Ofcom proposals will not rectify this distrust because the proposals do not address the ethics of the concept.
Concept
As I understand it the concept of 084 and 087 numbers is that they provide for certain benefits to the organisation using them such as re-routing and redirecting calls, call management, collection of varied call statistics, geographical anonymity or geographical ubiquity and, some may say, a certain amount of prestige. These are all benefits to the Organisation concerned and not of benefit directly to the caller. As an aside, there is a contention that these claimed benefits are not exclusive to 084 and 087 because technical features such as re-routing, call management and statistics can equally well be obtained if geographical numbers are used. 03 numbers of course can equally provide all the same benefits.
084 and 087 numbers also provide for micro-payments through the telephone system, which means that Organisations can collect revenue from callers. At present this is entirely unethical because no phone contract that I am aware of sets
out the contractual basis for collecting this money, deducting it from the callers account and paying it over to the third party. All contracts are essentially between the caller and his service provider: there is no third party.
The Problem
The problem with this concept is that while the benefits of 084 and 087 accrue to the called Organisation it is the caller who is billed and must pay. (This is done through the higher charges that are made, which in turn are based on the internal accounting procedures which operate between phone companies handling the calls. There are exceptions currently due to legacy regulations, but I understand that Ofcom propose to remove these regulations and to allow equable competition between all phone companies.) The Organisation receives the benefits but the caller must pay for them. This surely is wrong and unethical from every normal business transaction standpoint. He who receives the benefit should pay for the service.

Where businesses, government departments or any Organisation for their own convenience or for any reason choose to use a non-geographic number any additional cost should be borne by those Organisations and not the caller. This is what happens currently when 03 numbers are used, as Organisations can negotiate with the phone service providers on method and how much they must pay for the benefits of the 03 numbers they choose, while the caller pays only his normal geographic call cost with inclusion in any call package. The Organisations have buying power and leverage when negotiating, whereas individual callers have no negotiating power nor, critically, any negotiating opportunity. Callers are effectively left with no choice when confronted with 084 or 087 numbers, they must either pay whatever it costs or not make the call at all. When choosing a calls supplier the matter of charges for this type of call is often invisible, not presented and not usually considered.
Inefficiency

Another aspect of this concept and design is that the longer a call takes the more revenue the called Organisation receives. Therefore the Organisation has no incentive to keep calls as short and efficient as possible. Indeed the incentive is directly opposite and there must be some temptation to cause calls to last longer and so to increase the revenue. Long winded recorded messages, extensive menus, long call queues all have this effect without costing the Organisation anything as they are zero cost once set up. Queues can be unlimited in length. The phone service companies also do not mind longer calls at premium rates because this provides additional revenues. There are many examples in the public domain of people complaining of long queues while calling 084 numbers. This used to be a problem with 0870 but is curtailed somewhat with 0871/2/3 by regulation although the regulation could be more strict and more rigorously enforced. The idea of “light touch” regulation in this regard is totally unacceptable from a callers point of view.
The deliberate or incidental extension of call lengths leads to considerable waste of time by callers which when multiplied by the millions of calls to 084 and 087 numbers every day must add up to a massive cost to the national economy. The telephone system and numbering infrastructure is a national asset and should be designed as far as possible to help improve efficiency in the country and not to hinder it. The current Ofcom proposals would be better if they addressed this issue instead of ignoring it.
So are these problems of (a) charging the caller instead of the user Organisation for the benefits (b) revenue collection through the telephone system and c) inefficiency addressed by the Ofcom Proposals? Sadly the answer is NO.

Continued in next post.