CJT-80 wrote on Mar 28^th, 2011 at 8:54pm:

You can write it as a Word file and send it. Download a cover sheet from Ofcom.

CJT-80 wrote on Mar 28^th, 2011 at 10:08pm:

I send my responses as Word files, making the Coversheet the first page.

It's up to you whether you want to structure your response as answers to the questions or not.

bazzerfewi wrote on Mar 29^th, 2011 at 9:39am:

The Ofcom Coversheet can be downloaded from the website:

http://stakeholders.ofcom.org.uk/consultations/consultation-response-coversheet/

If you already have some of your response, you can insert it at the beginning of it (you may need to add a page break after the coversheet). Tick the appropriate box(es) for not withholding or withholding your personal details.

Details on how to respond (including e-mail address to which to send Word format responses) is here:

http://stakeholders.ofcom.org.uk/consultations/simplifying-non-geo-numbers/howto...

loddon wrote on Mar 28^th, 2011 at 8:43am:

Thanks for pointing this out. They make some good points. I think it's a well-balanced response and they refer to the externalities which Ofcom mentioned in the consultation document. I think these externalities hit the nail on the head.

My understanding of economics and business is small, but it has seemed obvious to me that this is the case.

I have long believed that there are issues which are fundamental to having inter-connecting providers that are permitting these rip-offs.

If every party was made to see and accountable for the services it receives, then we would have a much fairer telecoms market.

Dave wrote on Mar 29^th, 2011 at 4:30pm:

All of this nonsense about further splitting of the service charge is just opening up all sorts of potential for further fudging and confusion.

Many (including Antelope) see publication and billing of two charges as being unnecessary complication. I cannot see how adding a third item helps anyone.

Callers pay a Service Charge of 5p to call the TfL line - plus the Access Charge added by their telco. I cannot think what more information is of any use to the caller. We know the rates, because BT is prohibited from adding an Access Charge at present and its cost retentions are modest, to the point of insignificance for our purposes. The current Service Charges are the BT rates.

Those concerned with the financing of TfL (or any other 084 user) may want to get a breakdown of how it pays for its telephone service - the portion of the Service Charge retained by its telephone service provider is one of the factors. The other service charges paid to various providers and the nature of the services delivered must however also be vitally important to any such consideration. The full details of the distribution of the Service Charge would also doubtless be of interest. In most cases these details, even the split of the Service Charge, would be properly subject to commercial confidentiality. Compelling partial transparency is probably worse than nothing as it simply provides a distorted view of the truth, indeed it provides an incentive for distortion.

This is all a great red herring. We have no need to go beyond the level of Service Charge paid by the caller.

If Service providers only had to declare the portion of the Service Charge that passes through their accounts (e.g. 1.8p per minute for TfL) then they would doubtless get up to all manner of nonsense, with TCPs offering free outbound calls, disaster recovery facilities etc. so as to eliminate any declarable "revenue share". That would be a "fudge"! We have been battling against this for ages - we do not want it strengthened!

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loddon wrote on Mar 28^th, 2011 at 8:54am:

Worse than that, they mean that any package which includes geographic calls must include access charges for Business (and perhaps Premium) Rate calls also. This means that every package subscriber must pay the Access Charge for these calls whether they make them or not (just like all BT customers pay for 0845 calls at present). They also mean that the charge for calls to Geographic Rate (01/02/03) numbers cannot be less than the Access Charge for calls to Business (and perhaps Premium) Rate numbers.

I strongly disagree with this suggestion. I also disagree with the suggestion that the bad debt provision should be covered by a separate Access Charge for 09 calls (It should be a retention from the Service Charge by the OCP, so that a simple single Access Charge may apply.)

Antelope is also way ahead of the game in looking forward to the time when calls to mobiles are priced at the same rate as calls to geo numbers. I believe that this will come, however we do not want Ofcom to hold back for another few years until this point has been reached. This is another good reason why charges associated with NGCS should not be linked to charges for calls to Geographic Rate numbers by regulation. I believe that the necessary linkages will probably occur naturally, especially once we get common standard call charges, including to mobiles.

Response submitted.

I noted that Bristol CAB submitted a response them selves : Here as did Chorley and South Ribble CAB and one from just CAB. I only read the Bristol one and was interested to note that they hightlighted the cost of calling NGN's from a mobile.  When I went on their site to look into their service I note they have an 0844 number to contact them!

Now that's what I call hypocrisy

CJT-80 wrote on Mar 30^th, 2011 at 6:27pm:

To quickly deal with CABx.

Each CAB is a separate charity funded independently. There is a central coordinating body, called "Citizens Advice", to which they all belong. CA supports their work and organises common services. CA sent around a suggested draft response to the Ofcom consultation which each bureau tailored and added their own bits. Each CAB response does include some different comments and various elements in common with others. I think that this is perfectly legitimate.

They have got themselves into a terrible mess with telephones, having signed up for a service that they cannot afford to fund without contributions from callers. In common with many other charities they use Business Rate numbers, yet are reluctant to admit to levying a charge for their services.

The one positive aspect of the Ofcom "unbundling" proposals is that this would drag them out into the open. I have argued to everyone who claims to support the Ofcom proposals that they must therefore see the logic of themselves voluntarily making the call cost declaration that they wish to be imposed on themselves and others by regulation.