I submitted the following comment to accompany this article.

As it has not yet appeared, I will share my thoughts here:

Quote:


To add a little on the tricky subject of 080 calls.

I can see why, when the costs of mobile telephones are met properly, the cost of all 080 calls should be met by the called party.

The mobile companies themselves waive the cost of 080 calls to charities registered with the Helplines Association scheme.

Public bodies have three options when choosing a non-geographic number:

1. To meet all the costs of the call themselves. [080]

2. To impose a Service Charge on the caller. [084 / 087 etc.]

3. To allow the caller to pay for the call under the best terms available from their provider. [03]

Deliberately treating service users differently according to the type of phone service they use, their provider or their type of arrangement is totally unacceptable. The fact that some callers are able to evade the imposition of a Service Charge should not be allowed to distort the argument.

DWP has shown that where 080 numbers are used under present regulations it is necessary to make arrangements with the mobile providers to ensure that the cost is passed on properly. I believe that mobile providers have been persuaded to waive charges for calls to some public service 080 numbers e.g. when the National Pandemic Flu Service helpline was in operation. Use of 080 numbers under other circumstances is wholly unacceptable.


Where a Service Charge is imposed, it must be declared and justified. That is a duty that falls on public bodies (and private ones also) regardless of whether Ofcom attempts to impose such a duty by regulation. Much as we may wish it, Ofcom does not have the powers to prohibit any specific body (government department, agency or public service contractor) from using Business Rate numbers.

Similarly with 080 numbers, if a public body wishes to meet callers costs then it must do so without discrimination. It is not Ofcom's job to direct them in this respect. I hope that Ofcom is waiting for the situation with the reduced termination charge to resolve itself before diving in with further regulations concerning calls to 080 numbers from mobiles. Attempting to do so whilst the situation regarding who meets the costs of mobile telephony is in flux would be a little foolish.

Heinz wrote on Sep 5^th, 2011 at 12:48pm:
Good point.

The danger of making the change at present is that the current high termination fees carried by those who pay for calls through the mobile network would have to be carried by call recipients in the case of 080 (reverse charge) calls, if this cost were not carried by the caller. Once the cost of connection to the mobile network is met in ways other than through call charges, there will be a level playing field for 080 calls to be treated in the same way for both landlines and mobiles.

The implications of the proposed change for those who's callers currently benefit from a discretionary charge waiver (i.e. charities in the Helplines Association scheme and some others) would be disastrous. Unless they could persuade their own telephone service providers not to pass on the full cost of their 080 calls, they would end up seriously out of pocket. The mobile companies clearly have some reason to sign up to this scheme, as their generosity in waiving charges on the caller is visible. The service providers to the charities have no such reason.

The increased cost to all users of 080 numbers may well cause some to withdraw them altogether.

Yes this would be more fair and in principle this should have been the situation with 080 throughout. Given that there may be a better opportunity to make a long overdue correction a little later, I would argue that it is best to wait. I am not even aware of the "essential helplines", on 080 numbers that are not free to call from mobiles, referred to by the article. The only specific cases mentioned (apart from the DWP 0800's) are on 084 and 03 numbers.

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My drafted brief comments (published above) did not address every point. I could have also mentioned the following.

The unattributed suggestion that 0845 numbers are charged at "local rates" from landlines and "often" attract far higher rates from mobiles, is factually inaccurate and somewhat misleading. The essential point that 084 numbers are unacceptable does however stand. (It might have been helpful to mention that Citizens Advice does not hold this view, neither for itself nor HMRC or DWP.)

I know of no case where a "Local number" can be cheaper than a 03 number to call from a mobile. It should have been mentioned that where calls to "landlines" are free, calls to 03 numbers are also free.

The quote from SayNoTo0870.com - "... There is nothing to stop you ...", fails to point out that although you can dial the "international alternative" number, your call may not be connected if it is recognised as coming from the UK.