idb wrote on May 25^th, 2010 at 11:27pm:


-------------------------------------------------------

idb, your points are most telling and your summary of references to previous Ofcon Consultations is a salutary reminder of the lack of performance by Ofcon over the years.    Your interest in this issue and extent of knowledge is most impressive and we can all see why you and NGMsGhost must be so frustrated by the lack of adequate reaction by Ofcon and their utter failure as a regulator.  

It is especially annoying that in this current Consultation they have only allowed one month for responses to the most open consultation question they have probably ever raised.   There has not been enough time for people like me to fully think through my views and any possible proposals on the matter, nor much time for us to discuss and debate the issues, in fact these points have started to emerge during the last few days and we are running out of time as the consultation closes 30 May.

If you don't feel inclined to bother to respond this time in view of the pointlessness and ignorance shown by Ofcon I can well appreciate why you feel that way.   I would only suggest that you send a copy of this post of yours together with the lists  of references to other responses over the last six years so that at least Ofcon should look at your points again and it will require minimal effort on your part.

I will be responding along the lines I have indicated in earlier posts on this thread.  

I have always appreciated your contributions on this Forum.   Best wishes.   loddon.

---

SilentCallsVictim wrote on May 26^th, 2010 at 9:59am:
The consultation process has been ongoing for years with, largely, an apparent ignorance of consumers' views. This repeated process demonstrates, at least to me that the Ofcom-administered numbering plan is an abject failure, and is not fit for purpose. Tinkering with the plan is pointless when Ofcom seems to ignore the basic and fundamental issues and problems that NTS has delivered. The typical consumer is not the slightest bit interested in TCPs, OCPs, conveyance, transit and any other jargon that is trotted out as a convenient excuse. Years ago, a consumer could make a telephone call with reasonable certainty of understanding the cost of such a call. Charge bands L, a and b were simple to understand, and low cost B1 and B2 (?) bands further reduced the cost of long-distance calling on popular routes. Deregulation and increased competition followed - all well and good, leading to inclusive plans, unmetered calls and low-cost international calling. Unfortunately, the Ofcom NTS framework has resulted in the reduction of the benefits to the consumer of such advantages derived through competition, with the exclusion of many, perhaps most, numbers from a typical consumer calling plan. Any given business, agency, government department appears to now have a telephone number that is disadvantageous in terms of cost to the consumer. There is little point in having an inclusive plan where most of the numbers that a typical consumer would call are excluded from such plan. To determine the cost, inclusiveness (if any) and discount (if any) from, say a BT line, one has to wade through a multi-page pdf file or similar, and that is for just one carrier that tends to publish its tariffs in an easy to use format. This is simply too much aggravation for most people, in my opinion, and the lack of clarity is quite staggering.

It was pointed out, in previous consultations, that addressing the 0870 and 0845 problem would simply mean that numbers would migrate to 0871 and 0844. This is exactly what has happened, and was blindingly obvious to many contributors here.

I accept that some significant achievement has been made, indeed by a few regulars here. One can point to the introduction of 03 numbering, the police forces shifting away from 08, and the, hopeful, abandonment of 0844 within the NHS. Regulars here have made substantive contributions to these three activities. However there are still many scams and inconsistencies within the numbering framework, and these will remain while Ofcom is unable to accept that consumers do not want to call numbers that they have no understanding of the underlying cost, nor call typical 'day-to-day' numbers that are excluded from their plan. Ofcom will clearly not address this issue.

Campaigning can indeed take many years, however with Ofcom, there is always the feeling that one is up against the proverbial brick wall. Perhaps even the Berlin wall. Walls can come down, but this one is firmly entrenched.

idb wrote on Jun 2^nd, 2010 at 1:14am:


Hear Hear!! "Now tell us what additional public subsidy and contribution from unwilling and unwitting consumers it needs, in addition to that which it is able to earn through legitimate activities, in order for it thrive and invest."

The argument in favour of charging for public services is potentially legitmate as a form of highly regressive taxation to address the deficit. This must however be openly declared, which would probably make it politically unacceptable, unless a "tax on the poor" (noting the group which makes the greatest use of public services) is found to be more popular that a "tax on jobs". If, rather than relieving the deficit, at least part of the money is to provide financial support for a particular industry then that is a different matter. I would rather see public spending on support for business paid openly out of progressive taxation. I can understand why some would argue that it is better done "on the quiet", however one cannot countenance such an arrangement in open discussion.

A good discussion point indeed.

SilentCallsVictim wrote on Jun 2^nd, 2010 at 6:13am:
The wall is simply Ofcom's refusal to address the fundamental consumer objection - calling plans exclude numbers that a customer wants to call. This is very simple. Take a sample of responses from previous Ofcom engagements and this objections will generally be the primary and often only concern. I repeat, until Ofcom acknowledges the core problem, then little progress will be made.

As to any debate regarding pluralism, capitalism and totalitarianism, I suggest there are probably more suitable outlets for such comments than the sayno discussion board!

idb wrote on Jun 2^nd, 2010 at 10:36am:

It is not however so simple for the inevitable further consumer requests to be met. Callers doubtless wish to pay no more to have all manner of calls included in their plans. At the same time, users of revenue sharing numbers wish to receive subsidy, and would be delighted if this could be provided at no additional cost to callers.

If Ofcom were to be the body running a nationalised telephone service, then it would be able to drop its wall of objection and accede to these demands by using taxpayers' money to subsidise both sides. In fact, Ofcom is but the light-touch regulator of liberalised free market.


I strongly oppose the suggestion that Ofcom should mandate the content of packages, which I read in a number of published consultation responses.
One of the "Highlights" of my own response to the consultation is the following comment: Quote:

I firmly believe that the terms of any package is a matter to be determined between each provider and its customers. Ofcom has many responsibilities which I urge it to fulfil, most notably ensuring transparency. It must encourage, rather than restrict, a proper relationship between consumers and competing providers in a market. I do not believe that Ofcom should compel package subscribers to pay for things that they may not want, in the way that some propose. I do however acknowledge that there may be exceptional cases where it is justifiable to limit consumer choice in this way.

If Ofcom were to act in the way that is suggested, it would face a terrible dilemma. Should it force Virgin Media to include 0845 calls in all of its "unlimited" packages, so as to increase the cost of those packages, or force BT to exclude them, so as to reduce the cost of its packages? It is thought that if BT were to include 0844/3 calls in its "unlimited" packages, then the consequent cost of the package would mean that very few would choose to subscribe. Even if revenue sharing were removed from 084 calls, one must still expect to pay more for a package through which more calls were made.

An alternative approach would be for Ofcom to force those who pay for calls as they make them to subsidise those who subscribe to inclusive packages - this is effectively what is happening with BT at present. It may be that this is what those who argue for greater inclusion (probably themselves package subscribers) actually want. I do not believe that Ofcom has any proper role in intervening to deliberately shift the balance of consumer interest in this type of way. It has to regard the consumer interest in the most general balanced terms, not seeking to take up the case of any particular group. (At the same time, Ofcom must recognise that it will always be seen, perhaps fairly, as having taken the wrong side on any issue. Furthermore, Ofcom must carry responsibility for the ultimate effect of any intervention, or failure to intervene, regardless of what its intentions may have been.)

idb wrote on Jun 2^nd, 2010 at 10:36am:

I believe that it was fair enough for a contributor to make reference to the Berlin Wall, if they felt that it was relevant. I would however tend to agree that it was probably not.

idb wrote on Jun 2^nd, 2010 at 10:09pm:


I agree with you, idb, on this particularly.   I think that the concept of revenue sharing is flawed and unethical.   It is largely a long running scam on the public because most people have no idea that by calling an 084/7 number they are in part paying revenue to the called party and they are subsidising that organisation.   This is a rip-off perpetrated on the general public.   In addition the companies and organisations using these numbers are incentivised to be inefficient in answering calls and even to delay calls to increase their revenue take from the callers.   This is really a totally fraudulent activity and Ofcon should ensure that it is stopped immediately.

loddon wrote on Jun 2^nd, 2010 at 10:43pm:
I would support this view in totality. Simply put, why should calling PC Plod, Dr Smith's surgery, British Airways, HMRC, The Samaritans, the CAB and John's Plumbing be treated any differently than calling one's friend in the next city? It shouldn't. There should be an immediate prohibition on any commercial, government, non-profit or indeed any individual using any number that is outside the scope of a typical consumer calling plan. Such plans must cover all general purpose everyday calls. Revenue-sharing should be limited to those situations where there is clear added-value on offer (teleconferencing, fax services and similar) above a normal general consumer type call. Sure, defining such calls is not always clear, but, as you state, this rip-off has been on-going for far too long. Constant dithering and inaction has made the likelihood of prohibition to be close to zero.

I will pose a question or two to those who support the continuance of CPP model. Why should a UK consumer have to pay a premium to call BA to book a flight? BA is a large corporate body. It will factor in to its budget and overheads the cost of maintaining a call center, an essential operational aspect of running an airline business. In 1995, one did not pay a premium, so why now? What exactly has changed? Why should it cost less for a UK consumer to call, in certain circumstances, the BA call center in the United States than calling the one in the United Kingdom when the calls may well terminate to the same location?

idb wrote on Jun 2^nd, 2010 at 10:09pm:

The subsidy has not gradually increased from zero. It is the revenue share payments made directly to number users which have increased as a natural result of competition, in the same manner as retail prices for calls have been driven down by competition.

It was Oftel that decided this subsidy should be available.


To understand this, we must go back to the time when the majority of telecommunications services were provided by BT. Indeed, consider the situation when there was only BT. The caller was billed by BT for the call and BT delivered the call to the recipient.

Now imagine competitors stepping into the ring. It's no longer a case of the company that bills the caller making the connection to the recipient. The receiving party's telco charges that of the caller for connecting the call to the destination. For calls to landlines and 03 numbers, this is about 0.5 pence per minute during the daytime.

With revenue sharing/premium numbers, the outpayment from the caller's telco to the receiver's is related to BT's retail call prices. The current regulations that govern them were introduced in 2003, although I'm not sure how it worked prior to that. Basically, the outpayment to the receiver's telco is the BT retail call price minus a tiny amount for BT to keep. Remember, most calls were made from BT lines (or that was the reason given).

Let's look at 0845 numbers which were charged at the same rate as a local call from BT's pre-competition tariffs). For a local geographic call to a number operated by another provider, it would cost BT 0.5 pence per minute (or whatever exact figure was applicable at that time). For a call to an 0845 number operated by another provider, BT would hand over the vast majority of the call charges to have the call connected to its destination.

Where calls are made from providers other than BT, those providers incur roughly the same interconnection charges as BT. So it didn't take a rocket scientist to work out that increased competition would drive down the cost of calling geographic numbers, but not 0845 (and other premium-carrying numbers) due to the far greater margin on the former call type. Hence, in reality, 0845 was never going to stay local rate.

The revenue share payments to number users are merely as a result of the increased competition in providers of these numbers. It should be thought of as cash-back to entice custom and comes out of the subsidy (which is there by design).


The providers of these numbers, understandably, do not wish to give up the inter-operator payments they receive in addition to a normal call (0.5 pence per minute).

I say that anything above this 'normal' inter-operator charge is a premium.