SilentCallsVictim wrote on Jul 1
st, 2012 at 2:46am:
What T-Mobile is doing is not only unfair in itself, it also further impedes the difficult process of getting the status quo to be understoodWe see this understanding as being most important, in particular so that implementation of the "Unbundled Tariff" can be recognised for what it is - nothing more than opening up what is happening at present.
There will inevitably be changes to aggregate call costs resulting from the imperative need to make the new full regime as clear and easy to understand as is possible. I see no evidence to show that these will have to be increases. The fact that both telcos and their customers are short of money, and are likely to remain so for a few years, will undoubtedly have an effect as adjustments take place, but this could apply in either direction. If telcos start to feel the pinch, as they probably will, there is no guarantee that they will risk their position by imposing higher charges on hard-pressed customers. Rounding up and taking every opportunity to impose price increases is natural in a generally inflationary environment, however it may be a little soon to make confident predictions about the state of the economy in two years time!
The business of making one payment which goes to two organisations in respect of two distinct services is inherently complex anyway. If the invalid uses of 084/087 numbers are flushed out by transparency (combined with the forthcoming provisions of the Consumer Rights Directive) we are left with those who choose to provide a chargeable service by telephone and are prepared to state their charge.
If they find this to be an effective way of doing business and the telcos are happy to go along with this, whilst also declaring their charges, then it is difficult to object in a free economy. The present environment makes it difficult for them to behave properly and far too easy to behave improperly, often because they have failed to notice how much has changed over the last 10 years.
The way in which T-Mobile has sought to simplify the situation may be seen by some to be desirable. It has set the same rate for calls to geographic numbers as for the bundled (Access plus Service) Charge for all 084 / 087 numbers - 40p per minute after the inclusive allowance has been used up. Do we cheer the absence of a premium?
Attempting to remove the "line rental" element and the fixed value of the inclusive texts and T-mobile minutes from the plans suggests a rate for inclusive calls of around 2p per minute. (When comparing the higher priced options, 300 minutes are added for £5, with other features unchanged.)
It may be reasonable to offer some discount to heavy users who are able to enter into a long term commitment to high call volumes. 95% does however seem to be a little over-generous!
The general position taken by T-Mobile is incomprehensible. I see an Access Charge of 38p per minute for non-inclusive calls to 0845 numbers, whereas for inclusive calls to some 0871 numbers it is -8p per minute. (The present equivalent Service Charges are roughly 2p per minute and 10p per minute respectively.)
Some respondents to the Ofcom consultations have called for the greater simplicity offered by having only maximum prices declared. I fear that with T-Mobile we are looking at what happens when the principle of simplicity is taken too far - so that it fails to reflect the reality of the underlying situation. T-Mobile has set a maximum of 40p per minute for what should be the most expensive calls and (perhaps for the sake of simplicity) other charges have been set at the same level.
Those who see the future regulated situation, under Ofcom's proposals, as more complicated may be happy with the over-simplified position adopted by T-Mobile. Alternatively, they are thinking back to the past, when BT had an overwhelming share of the market, so regulation could apply to it alone.
The current situation is still based on the assumption that BT (now only partly regulated) sets prices that are fair and that these must be followed by all others. In both cases, this is a false assumption. BT's share of the non-business calls market is now below 25%. It is still the largest individual provider, although it does not operate at all in the mobile calls market, which is around 50% of the total. The key point is that BT is deemed to no longer holds the degree of "Significant Market Presence" which is required for Ofcom to be able to subject it to special regulation.
Ofcom therefore has to remove the present regulatory structure. We are pleased that it is taking the opportunity to attempt to introduce something that is much fairer, in that it closely reflects the reality of the current situation, in the simplest way possible. It appears to be sustainable, but we cannot say for certain what may develop over the longer term.
Those who wish to return to the past century will have to persuade the government (probably that of 2015-20) to re-nationalise the telecoms industry. I see another industry where the case for it being taken into public ownership is much stronger. That would however have to be on a multi-national basis, where we have no democratic institutions.