idb wrote on Jun 24
th, 2012 at 6:40pm:
One alternative view is to revert to the situation prior to the introduction of numbering that has only disadvantaged the consumer; a situation that is of the regulator's making.
So far as 0845 is concerned, we cannot easily return to the situation where BT is a near monopoly provider with distinct local and national rates. It was in this situation that the option to have national calls at local rates whilst also providing subsidy to service providers to enable investment in enhanced telephony was introduced.
BT is no longer a near monopoly provider, so the NTS condition cannot be sustained. The end of BT Standard has meant that the concept of subsidy to SPs without cost to callers cannot be resuscitated. We must move forward. The way in which we return to the desired position must however take account of where we are now. This means that it cannot be as direct as we may wish.
It is my belief that the obligation to declare any service charge will ensure that calls to most businesses, govt agencies, health services and non-profits will become included in standard call bundles. I am thinking of those who have a genuine need for a non-geographic number. Ofcom has decided that this should be achieved by having only one range of non-geographic numbers (03) which are charged at geographic rates, thereby requiring many number changes - although only one digit of the number needs to change.
The proposed alternative approach, of having only range to which premiums may be applied (09, notwithstanding some other particular cases) has been rejected. One possible justification for this is the distinction between a premium which serves to simply offset the costs of a Service Provider, as against that which delivers income.
No operator of a contact centre with a 084 or 087 number hears the cash register ring when the phone rings. They have simply taken what seems to be the best option offered by a telephone service provider, often based on false statement about what callers pay to call. (There may be some who can handle incoming calls at a cost of less than 10p per minute, e.g. dialup ISPs and some other providers of particular telecoms services, but I do not believe that they are the main focus of our concern here.)
Providers of "Premium Rate Services" on 09 numbers understand that they must declare the cost of their service and offer value for money to their callers. Although this could never work in the same way for most users of 084 and 087 numbers (because the cost incurred by the caller is way short of the cost of the service) it does no harm to subject them to the same discipline in terms of cost declaration.
Ofcom states a belief that there will continue to be demand for 084 and 087 numbers when the cost is made transparent. It will take some time to see if this is true, however it is my belief that there will be mass migration to 03.
The fact that many have remained on 0871/2/3 numbers after them being designated as PRS suggests that I may be wrong, however I believe that this owes something to the general degree of confusion and misunderstanding. If a general move to 03 takes place, then it is likely that many present 087 users will get drawn into it.
I repeat, it will take time for these effects to be seen.
Ofcom is shifting the problem, but I believe that it is right to make it an issue between the Service Provider and their caller, with a relatively minor role for the telco. It is for the coop bank to decide whether the cost of its contact centre operations is met fully as an overhead, reducing the profit that it distributed to its members, or if it is to ask for a contribution from those who call them. The effective level of this contribution should not depend on who the caller chooses as a telephone service provider, albeit that their other telephone costs must do so.
I accept that many believe Ofcom should deny the coop bank, and others, the opportunity to be able to make this decision, or to somehow decide who is and is not able to make such a decision. In very many cases the option to make this decision will be withdrawn by the implementation of Article 21 of the Consumer Rights Directive.
It may be that, by a somewhat devious route, we will be able to return to a golden past age.