In response to the points by Loddon.
loddon wrote on Nov 11
th, 2012 at 6:20pm:
I wonder why the term “business rate” has been dropped? Probably as a result of lobbying by the industry which doesn't want it described more closely for what it is.
The replacement "08" is totally meaningless. "Business Rate" was a perfectly acceptable proposal (in the absence of anything clearer). There is no good reason why it could not be adopted, once the final form of the proposals is presented. Ofcom has not yet engaged with representatives of the consumer side in its working groups - this must come along shortly!
loddon wrote on Nov 11
th, 2012 at 6:20pm:
“An easy way for Ofcom to protect the interests of the public would be to stipulate that the call charges for use of 084 and 087 numbers must be charged to the user Organisations and not to callers, in a similar way to the operation of 03 numbers.”
In effect, this is a proposal that use of the 084 and 087 ranges be regulated in the exactly same way as 03; there is no apparent distinction made. Ofcom proposes regulation to be essentially the same as that for the 09 ranges, although with lower limits on the level of the Service Charge and proportionately less regulation of the manner of use.
Ofcom claims that there is significant demand for numbers which offer a Service Charge of less than 10p (or perhaps 13p) per minute. I have my doubts, and believe that use of these ranges will diminish considerably once there is a recognised requirement to declare the Service Charge. (If that requirement may be evaded, then we are in a different situation!)
Ofcom has also stated that simplification is achieved by there being only one non-geographic range (03) which is guaranteed to be charged at the same rate as a call to a geographic number. This thinking probably influenced the decision not to re-classify 0845, and perhaps 0844/3, in the same way as 0870, although with greater force than was applied when 0870 was re-classified, before Ofcom acquired the stronger powers that it now holds. The principle of Simplification demands that all 084 and 087 ranges are treated in the same way. That is why 0870 is to be returned to its former position.
loddon wrote on Nov 11
th, 2012 at 6:20pm:
“Callers should still pay the proposed access charge but this charge should be no more than their normal geographic call charge, inclusive in packages, and similar to the access charges to 03 numbers.”
It is important to understand that the "Access Charge", as currently proposed, ONLY applies when there is also a Service Charge. This is not the term to apply to the call charge incurred when there is no Service Charge, even though some argue that the two should be equivalent.
We have yet to learn how the telcos will treat the Access Charge. There is a major battle going on over call set-up fees, which Ofcom wishes to outlaw. This begs the question about what Ofcom should do if it is able to succeed in respect of Access Charges, but not the penalty charges imposed for, otherwise inclusive, "out of plan" calls.
There is also the question over whether the fees for Call Plans and Packages should have to cover the Access Charge element of calls to numbers with Service Charges. This is especially relevant to the case of the higher cost 09 numbers, where it is proposed that the Access Charge covers the provision against the cost incurred by telcos having to write off disputed charges for calling Premium Rate Services.
There is a strong argument for saying that those who never call numbers with Service Charges should not have to pay for such calls through their Call Plan or Package subscription. I am not inclined to favour a provision which demands that they do so. It may well be that telcos end up following this approach, by making some or all Access Charges inclusive.
We still have some way to go, with Service Charges being treated as inclusive in some cases - thereby paid by all subscribers. This may eliminate premium charges, however it is hard to suggest that it is equitable for them to be simply distributed across the costs incurred by all.
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