This has been a most worthwhile discussion.
It is interesting that X-On have been identified as champions of 03. As Speedy comments, they promote a
03 based system for NHS providers. It would be good for someone from X-On to come forward to take a strong role and perhaps receive some (implicit) endorsement from campaigners. Maybe someone would like to approach them to discuss this.
When Ofcom announces its firm proposals for new regulation of 084/087 numbers, in the next few months, this will be an ideal time for it to strongly draw attention to the ability of users to migrate to 03. This is what all those who need the benefits of a non-geographic number, but will not be prepared to declare a "Service Charge" on callers, will have to consider.
Ofcom cannot direct providers as to how they must promote their services, nor are they bound to offer migration. The fact is that they are able to, and they do.
There is no complex process to be defined, the user asks the provider, the provider applies to Ofcom for the 034 / 037 number and (assuming that they own the 084/087 equivalent) it all goes ahead smoothly. Where the 084/087 number has been ported from the original owner, there can be complications as the original owner has to be engaged. The fact that many such cases have been resolved satisfactorily means that these processes should now be much easier than when they were being encountered for the first time.
On the wider issue of attaching a premium to the cost of a telephone call, there are perhaps three distinct situations.
1. Where the user of the number wishes to benefit from the use of advanced telephone technology at no cost to themselves.
2. Where the user wishes to discourage use of the telephone as a means of contact and also wishes to recover some of the cost of handling telephone calls from those who make them, rather than from customers in general.
3. Where the phone call itself represents use of a chargeable service - e.g. directory enquiries, cricket scores.
The first of these, where the user claims to receive no financial benefit, is what has long been associated with 0845 numbers. There was a genuine desire to encourage the development and use of advanced network services on non-geographic numbers. Oftel / Ofcom price regulation (which could, until very recently, only apply to BT) has ensured that it is BT customers in general who bear the cost, rather than those who actually call 0845 numbers. Because there can be no assurance that other call providers will respect the spirit of this regulation on BT (and because it is dodgy anyway and the technical development issue is no longer relevant) this will shortly come to an end. In effect there will be no difference between this and the second case.
The second case, which is largely what has been discussed above, is the most difficult on which to form a clear judgement as to its acceptability. I take the view that it is totally unacceptable for providers of public services which are funded out of taxation to use this method of subsidising costs to the taxpayer. The vital point is that the charge imposed on the caller must be declared by the beneficiary. This introduces a complication because there are two beneficiaries (the telco and the person called), i.e. two elements to the charge. This is however what is happening ("behind the scenes") at present and if it is to continue, then it must be made transparent, even if at the expense of simplicity.
The third case is more straightforward. The problem with the present regime for "Premium Rate Services" is the fact that the differential charges imposed by the various telcos cannot be readily declared by the provider of the service. They will therefore naturally refer only to the cheapest (currently regulated) rate offered by BT. If we accept that there is to be a diversity of types of telephone call provision and providers, then there must be some freedom for telcos to set their own charges. Given that this freedom will shortly be extended to BT, there is again no alternative other than to have the "unbundled" approach, whereby the service provider declares their "Service Charge" and the telco their "Access Charge".
Ofcom had muddied the waters by defining the 0871/2/3 range as being used for "Premium Rate Services" when it belongs in the second of the categories given above, along with 084/3 numbers. This however reflected a problem that Ofcom had with the application and enforcement of regulation. It now defines all 084 and 087 numbers as "Business Rate" reflecting the (merged) first and second of my categories. The problem with application and enforcement of regulation does however remain and we will have to wait to see how Ofcom proposes to get around that.