loddon wrote on May 1^st, 2013 at 3:48pm:

I am inclined to largely agree with this statement, although I believe that it has to be tested so that those who claim that there is such demand can be put in their place.

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I am concerned about the case of a (hypothetical, for now) organisation which would rather that all interactions with consumers took place on-line, rather than through a much more costly telephone call centre. It could feel that a modest charge for telephone calls would help offset its costs and provide a sufficient incentive for on-line contact. To avoid having to deal with the CRD provisions, let us say that these are one-off transactions. At present "Premium Rate Services" are defined by the level of the "Service Charge", so if this organisation wanted to charge only 5p per minute it would not be classified as offering a "Premium Rate Service".

If this were the only basis on which the organisation was prepared to offer telephone access, are we content that it should be prohibited from doing so? Many organisations already do not offer telephone access.


I will offer one other (again hypothetical) example which concerns me.

A charitable enterprise offers a helpline service whereby calls are automatically switched around using a fairly costly bit of technology. A shortage of outside funding causes it to use a 0845 number so that the line and the switching technology is paid for by callers at the cost of 2p per minute. It declares this charge and advises that callers will also incur an Access Charge from their telephone company.

Should it be stopped, or forced to charge more than 13p per minute?


Because my energies are focussed on improper use of Service Charges, I have not undertaken the research necessary to identify specific cases, however I do not believe that the ideas are wholly fanciful. One could mention other potential (and perhaps many actual) cases where a low Service Charge is not obviously improper - The Land Registry is one actual case.

I do not invite specific answers to these questions, but urge those who make sweeping statements to ensure that they have considered the whole of the issue that they are addressing, not just the obvious and frequently discussed cases, even though they are the most important. I would also urge a stricter distinction between one's personal situation and experience (no matter how relevant and valid) and the considerations that have to be made by those who set public policy.

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It is very easy to highlight cases of inappropriate application of Service Charges and there is no disagreement in this forum about the fact that they should be eliminated. We can argue about whether transparency will be sufficient and whether campaigning groups are strong enough in mobilising consumer power to ensure that it does its job.

We face the argument that there are cases where a Service Charge of less than 13p per minute can be justified. We can easily show that there are many present cases where the Service Charge cannot be justified, but that does not fully address the issue. Ofcom has determined that this issue must be resolved in the real world.


Smart readers of the Ofcom consultation document should be aware that it (like most "consultation" documents at the firm proposal stage) is drafted primarily as a defence against legal challenge of the action proposed. One needs to read very deeply between the lines if hoping to determine the motivation behind the actual proposals, as against the way in which it has been deemed necessary to present them.

SilentCallsVictim wrote on May 1^st, 2013 at 6:38pm:


As noted above, does this mean Fair Telecoms and it's supporters will now be focussing on DWP to convince them to switch to 01/02/03 numbers instead of "ripping off" their callers with the continue use of 0845 numbers?

I for one at this present time, have had to call DWP on a few occasions from home, and am VERY glad that at this present time I get inclusive calls to 0845 numbers.

CJT-80 wrote on May 1^st, 2013 at 9:02pm:

Very much so, although not exclusively. Apart from supporting, and using information obtained by, John Healey MP, including this item on Money Box (see the link above), we see the DWP as being a major target in our "Big Question" campaign. Further activities are planned; support and suggestions are welcome from fellow campaigners.

SilentCallsVictim wrote on May 1^st, 2013 at 6:35pm:

As a hypothetical exercise this might have been helpful if Ofcom had posed it within one of their consultations.   We are in danger of trying to design the whole solution as a free service for Ofcom, however, my inclination would be to say that if Ofcom would decide that the Access charge could be no more than the price of a normal geographic call within that callers tariff and must be included within the tariff  package (something which I suggested previously as a possible solution) then this could be a justifiable case.

loddon wrote on May 1^st, 2013 at 9:38pm:

It is true that some are proposing radical alternatives to what Ofcom has already done, for the purposes of discussion. I have only raised a case which I believe is fully covered by the Ofcom approach, as it leaves the legitimacy of the Service Charge to be determined in each particular case.

I do not see the level of the Access Charges, the rates for calling geographic numbers or any connection between them as being of any relevance to the legitimacy of a Service Charge. The whole point of the unbundled tariff is that it separates the caller's two relationships, with the Service Provider and with their own telephone company.


, however, my inclination would be to say that if Ofcom would decide that the Access charge could be no more than the price of a normal geographic call within that callers tariff and must be included within the tariff  package (something which I suggested previously as a possible solution) then this could be a justifiable case. [/quote]

idb wrote on May 5^th, 2013 at 10:55pm:


This piece from the Surgery Line site states :---

"Frequently Asked Questions

Why would a practice change to 03 or even a local intelligent number?

The only way that a busy practice will EVER eliminate the engaged tone is to use an intelligent 03 or intelligent geographic number ..........."


So now we have it, at last, from the arch-villains who have made all sorts of untrue claims in the past about geo versus non-geo numbers.   They have finally admitted and confirmed what we have said for many years -- that everything that is claimed as capability on non-geographic numbers is equally available with geographic numbers -- except revenue sharing or micro-payments as Ofcom like to call them.  This proves that there is absolutely no need for non-geographic numbers at all and as we have said they have always been a RIP-OFF. We campaigners are quite happy to make an exception, however, for 03 numbers which must be charged at the same rate as geographic numbers.

One strange statement by Surgery Line "intelligent 03 number"; what do they mean by this?   When is an 03 not intelligent?  (Rhetorical of course.)  

This plainly shows that this consultation and all the consultations from 2010 onwards have been a vast waste of time and money.  Ofcom didn't need to force us to go through all this pain and expenditure because we know that we never needed 084/7 numbers anyway and we don't want them now.

Further to my earlier post in this thread which quotes Surgery Line as stating ;---

"The only way that a busy practice will EVER eliminate the engaged tone is to use an intelligent 03 or intelligent geographic number ....."

We should realise that Surgery Line have not entirely reformed their tendency to mislead, be economical with the truth and over-exaggerate things till they become untrue.   As ever they say that "The only way that a busy practice will EVER ...."  which is obviously untrue because there are other ways to achieve that objective.   They hint at the option to increase the number of lines, or the practice could make use of ISDN lines.   The cost/benefit analysis of alternative approaches would need to be evaluated of course.    A practice can also change its policies to avoid peak call times by NOT refusing to allow patients to book appointments more than a day ahead thereby causing a mad panic, and peak calls, first thing in the morning; and there could be other policy moves and actions which could be taken.

Let us hope that Surgery Line will in time become more honest and truthful.

loddon wrote on May 6^th, 2013 at 1:18pm:

This is where I find myself in fundamental disagreement with Loddon (and perhaps others).

There may be the possibility of Ofcom tweaking the situation, for example by intervening to address excessive Access Charges that may be imposed. The likelihood of it removing the scheme after it has been introduced, due to public dissatisfaction, will surely be seen as very small. If I genuinely believed that the scheme would inevitably be found to be unsatisfactory, I would be opposing it now with all possible vigour, whilst there was some prospect of doing good, rather than waiting to "concentrate dissatisfaction" to little purpose. Is this the difference between campaigning and moaning?

I see my campaigning role as being to continue to press dissatisfaction with the imposition of Service Charges (and the consequent incurring of Access Charges) in all cases where it cannot be justified. I believe that this has been effective and is likely to be so in many more cases.That is NOW and it is helped by the fact that the "unbundled tariff" represents exposure of what is happening at present.

The fair telecoms campaign seeks to do this through "The Big Question", on which more will follow very shortly.

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Ofcom acknowledges the Magrathea proposal regarding mandatory inclusion of Access Charges (at 9.42) and concludes its remarks on this point (at the foot of 9.43) by stating

Quote:

see http://stakeholders.ofcom.org.uk/binaries/consultations/simplifying-non-geo-no/s....

Discussion of the related issue of a cap on the Access Charge follows, beginning at 9.47. Again Ofcom remains open to the possible need for intervention, based on what develops.


Given the amount of attention which Ofcom shows in responding to an extensive, contradictory and sometimes bizarre series of proposals from Magrathea in section B and the annexes to Section B, I cannot agree that its approach may be fairly characterised as dismissive.


The suggestion that Ofcom is actually determined to avoid "real effective regulation" implies that we are indeed wasting our time by discussing these matters. This may have been hyperbole, however there may be some confusion about the powers and duties held by the body, as against how it chooses to use them. For example, Ofcom cannot direct the DWP not to impose a Service Charge on callers.

It could perhaps aim to achieve this effect by, as proposed, imposing a minimum Service Charge of greater than 10p per minute. As the regulator of a market, rather than the director of a state controlled sector, Ofcom has a duty to allow "market mechanisms" to function unless it can clearly demonstrate failure.

It is perhaps not strictly true to describe public demand for claimants to be relieved of the need to pay a charge when enquiring about their benefits, being set against pressures to minimise DWP spending, as a "market mechanism". Ofcom must however leave this to be decided by resolution of these competing positions. Until one points out that the genuinely disabled, genuine job-seekers, those in need of Child Support and all pensioners fall within the affected group, the balance of public demand could be open to question!