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Ofcom consultation: Simplifying Non-Geo Nos 2010 (Read 49,923 times)
SilentCallsVictim
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #30 - Jan 8th, 2011 at 11:43pm
 
NGMsGhost wrote on Jan 8th, 2011 at 9:29pm:
... the numerous previous occasions when OfCoN promised action and then did nothing ...
One hopes that these comments may be balanced by reference to generally positive, if incomplete and inadequate, actions such as the removal of revenue sharing from 0870 and the introduction of 03xx.

NGMsGhost wrote on Jan 8th, 2011 at 9:29pm:
I will not expect any significant changes to be made as a result of this consultation that stop any of the scams or make it more obvious what you are being charged to make a call.
There will undoubtedly be confusion about the degree of clarity which is required in statements about call charges, given the limits of Ofcom's statutory powers of regulation. I will personally be keen to hype up the effect of Ofcom's powers in the hope of achieving greater clarity; I recognise that others will be reassuring users of Business Rate numbers that they will not be under any absolute compulsion to be any clearer, and that their scams can continue.

NGMsGhost wrote on Jan 8th, 2011 at 9:29pm:
... call price announcements for non standard priced numbers cannot be allowed because it will affect their automated dialling equipment.
My reading of the consultation document suggests that this point is already well taken and that there are no specific proposals regarding provision of call price announcements. The proposals clearly focus on the duty of the Service Provider to advise of their Service Charge, and this is extended from "Premium Rate" to "Business Rate" numbers.

NGMsGhost wrote on Jan 8th, 2011 at 9:29pm:
... pressure on OfCoN to hold it in the first place by ministers with the current coalition government.
The process of which this consultation is but one stage was well in place before the General Election. Having closely observed the relationship between the responsible Minister, Ed Vaizey, and Ofcom I think it quite likely that he is unaware that the consultation is even happening. He has not commented on it and I would doubthis ability to understand even the very basic principles of what is involved. It is very clear that the coalition government is firmly opposed to any increase in regulation or the power of regulators (notwithstanding Politically-motivated dealings with reference to Banks). The increased powers that will be granted to Ofcom in the Spring arise solely from an obligation to implement an EU Directive.


It would be foolish to expect that a few changes by a "light touch" regulator, in a political environment that is fundamentally hostile to regulation, will stop scams and deception. The limits of Ofcom's powers, not to mention the related weakness of its approach to every issue, cause serious doubts to be properly raised over the likely effectiveness of what is proposed. I firmly believe that intense and positive efforts by campaigners will be required to bring about successful achievement of the worthwhile proposals that are in the consultation document. Even at this stage there is valuable support for putting additional pressure on users of "Business Rate" numbers to cease the practice.

The past is littered with failures and disappointments and there will undoubtedly be many more in the future. I approach this consultation by looking to see what may be achieved from it and the actions that may follow in subsequent stages of the process. I do not expect 100% success, however I am keen to achieve as much as is possible. I regret the fact that strong and capable potential allies perhaps take a different view.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #31 - Jan 9th, 2011 at 7:25pm
 
SilentCallsVictim wrote on Jan 8th, 2011 at 11:43pm:
NGMsGhost wrote on Jan 8th, 2011 at 9:29pm:
... the numerous previous occasions when OfCoN promised action and then did nothing ...
One hopes that these comments may be balanced by reference to generally positive, if incomplete and inadequate, actions such as the removal of revenue sharing from 0870 and the introduction of 03xx.
I have to agree with NGMGhost here.  We have had so many consultations and yet nothing really happened despite some overwhelming support to end the idea of hidden revenue sharing numbers but Ofcom took the easy way out, after many, many consultations, with 0870 and this took years to happen despite their previous consultations and responses.

There were things like they would look into doing the same with 0845 as they did with 0870 but I firmly believe that nothing will happen over 0845 like it did with 0870.

In a previous consultation, Ofcom said it would force teleco's to stop claiming these numbers were either local or national rate and insist on prices being made more public on these numbers.  Despite many emails from me informing them of teleco's that ignored this new General Condition, or if they did comply then the prices were hidden in hard to find places of websites, etc and not on same page as price of geographical calls, they basically did nothing for absolutely ages and then just told them off.  Last I looked, I don't believe that many teleco's actually fully comply with GC14.2.

Even when I mentioned to Ofcom that GC14.2 may bring awareness to the cost of these calls, it doesn't stop the teleco's that provide NGN numbers from still claiming NGN's are either local/national rate, I got no real helpful response from Ofcom.

I have yet to see Ofcom take the side of consumers and what they want rather than what their stakeholder's want.  I realise that they are sometimes bound by rules and regulations but in my personal opinion I believe Ofcom have not shown that they actually want what is best for consumers rather than what their cosy little stakeholder's want.

This is just my opinion  Grin

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NGMsGhost
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #32 - Jan 9th, 2011 at 8:01pm
 
bbb_uk,

I am encouraged to see that you and I are of a like mind on these matters even if I do not seem to have been on the same wavelength of late as Dave.

It grieves me a a former local district councillor to say that people should not expect anything to change from responding to a consultation since consultations on some matters by local councils etc are often genuine and the views expressed do lead to real changes in the original proposals or even sometimes to a proposed change being scrapped.

However it is hard to have much faith in the main regulator OfCoN or even worse that devil's spawn offspring it created first called ICSTIS and now PhonePayPlus who ran a consultation on its proposals for 0871 numbers that was resoundingly rebuffed by nearly all of the several hundred members of the public who responded as being a quite useless proposed control regime that would not stop any of the scams or abuses only for the original proposals to be implemented completely unchanged.

OfCoN will only change its ways if it is under genuine political pressure to reform the NGN system.  So the real question is why did they bother launching this consultation now because on the face of it surely someone somewhere is badly upset about the total bankruptcy and illogicality of the current state of its National Telephone Number Plan (NTNP) for it to have bothered coming up with this consultation.
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SilentCallsVictim
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #33 - Jan 9th, 2011 at 8:10pm
 
bbb_uk wrote on Jan 9th, 2011 at 7:25pm:
SilentCallsVictim wrote on Jan 8th, 2011 at 11:43pm:
NGMsGhost wrote on Jan 8th, 2011 at 9:29pm:
... the numerous previous occasions when OfCoN promised action and then did nothing ...
One hopes that these comments may be balanced by reference to generally positive, if incomplete and inadequate, actions such as the removal of revenue sharing from 0870 and the introduction of 03xx.
I have to agree with NGMGhost here.

I am not sure that there is really two sides to an argument here.

Ofcom is disgracefully ineffective in much that it tries to do and there is much that it tries to do with which we all disagree. The point for me is about whether there is anything in the consultation that may help to improve the situation and ways in which such good effect can be maximised either by Ofcom itself or by campaigners seeking to influence decision makers to stop using Business Rate numbers when this is not appropriate.

It is fair enough for one to conclude that there is nothing in the consultation, or that may emerge, which is, or will be, of value. I would have thought that such a conclusion would have to be based on what is proposed, rather than purely on the basis of Ofcom having failed to intervene in the past. Ofcom is not by nature a highly interventionist body, it seeks to lay out a regulatory position on the assumption that there will generally be compliance.

Ofcom is itself influential. Its utterances are taken seriously by those who would wish to be seen to be complying - that is why I am so furious about its continuing explicit approval of the practice of making Silent Calls. I personally see the proposed new structure for NGCS charging as a major step in the right direction - the mechanisms of adoption and enforcement are an important and complex issue; they are separate from the proposals in concept.

There are points on which I do perhaps agree totally. If we sit back and leave Ofcom to get on with it, then very little will happen. If we expect all of our wishes and desires to be met if we get involved, we will end up being very disappointed.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #34 - Jan 9th, 2011 at 8:15pm
 
If Ofcom really does pamper to the whims of private companies which it is supposed to be regulating, then this would appear not to be confined to telecommunications. Radio stations have had the terms of their licences relaxed so as to allow them to network programmes across their stations. At one time this would have been unthinkable and all stations would have had to produce their output from within the area they serve.
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NGMsGhost
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #35 - Jan 9th, 2011 at 8:31pm
 
Dave wrote on Jan 9th, 2011 at 8:15pm:
If Ofcom really does pamper to the whims of private companies which it is supposed to be regulating, then this would appear not to be confined to telecommunications. Radio stations have had the terms of their licences relaxed so as to allow them to network programmes across their stations. At one time this would have been unthinkable and all stations would have had to produce their output from within the area they serve.


And when I have seen some of those radio licence consultations by Ofcom I have responded briefly with something to the effect of:-

"Inevitably Ofcom will rubber stamp this as they have done all the previous ones as they only seem to care about the commercial welfare of the broadcasters and not the public still having a diverse choice of stations to listen to".

I believe that Ofcom is also currently proposing massively longer commercial breaks on tv as yet another example of pandering to whatever the telecoms and broadcasting industry wants (unless of course abuse of porn broadcasting regulations is involved when they mysteriously suddenly find a Mary Whitehouse or should that be a Harriet Harman like need to crack down very hard with huge fines never seen for any normal NGN telecoms scammers).

And as to SCV's bee in his bonnet about silent calls (which I admit are something of a nuisance but not as much as being ripped off to call companies that you are a customer of or otherwise in a relationship with, especially as Silent Calls normally only seem to happen between 9 and 5 and not overnight when they would be a real nuisance) why exactly does he expect Ofcom to behave any better in regulating his favourite pet area by not siding with commercial interests there (as he naively seems to expect for Silent Calls while not expecting Ofcom to ignore vested commercial interest elsewhere) whilst frequently telling us that business is dirty and we can't expect things to go on and services still to be provided that don't still make a thumping profit for the businesses concerned in almost all the rest of his analysis in the forum (of which there is far, far too much for just one person).
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« Last Edit: Jan 9th, 2011 at 8:32pm by NGMsGhost »  

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SilentCallsVictim
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #36 - Jan 10th, 2011 at 1:38am
 
Perhaps we need another thread in which to discuss the Politics of regulation, or the way in which members contribute to the forum. Alternatively, perhaps nobody is interested in discussing proposals for how calls to non-geographic numbers should be billed and the costs presented, so we may as well carry on the discussion that has developed here.

The problem with Ofcom's powers in relation to Silent Calls is that they are not designed for light-touch general regulation, which is Ofcom's style in operation. Ofcom simply refuses to properly discharge its statutory duties in this area, as the first stage of its use of the powers is an intervention in a specific case, with the imposition of specific enforceable regulatory requirements as the second stage. Ofcom prefers to pretend to hold general regulatory powers that it does not possess. It is for this reason that, in the context of the "bonfire of the Quangos", I have proposed that administration of the relevant powers be handled by a different body. I do not expect Ofcom to change its nature.

Following representations from myself, it was the relevant government minister who, on behalf of all members of a parliamentary committee conferred an expectation on Ofcom "We expect you to use your powers to eradicate the nuisance of Silent Calls" - I frequently quote this expectation, and echo it; that is the only basis on which I hold such an expectation.

As for business being "dirty", I would more commonly be expected to refer to it being amoral. Most businesses would wish to be seen to be clean, which is how positions adopted by Ofcom can be valuable in setting a standard to which many will respond. There will however always be a fringe of downright dirty players who will only occasionally attract the attentions of regulators.

I hope that moderators will edit contributions to the forum based on the content, rather than the authorship.


I had understood the approach of the coalition government to matters of regulation to be extremely "liberal". (I use this word with a small "l" to refer to the orange wing of the LibDems and the drier wing of the Conservatives.) This suggests that there would be no enthusiasm for addressing anything with the word "Plan" in its title, such as the NTNP, other than to abolish it. I see the fact that Ofcom survived the quango reorganisation with its regulatory role in relation to telecoms intact as being down to the wet Maude at the Cabinet Office and the yellow Cable at BIS, in addition to it having not ever having been seen to give industry a particularly hard time.

It is important to note that Ofcom is accountable to parliament, not to the Government. Under the previous administration an unduly close relationship developed, seen not least by the appointment of a past Chief Executive as a "goat" - an ennobled minister in the relevant department. There is every indication that this close relationship is being continued with the current government. I see this as improper and dangerous. The former because it undermines proper accountability; the latter because the government may find itself with an unreliable friend who can assert its independence whenever doing so may suit its purposes.

If anyone has a clear insight on relevant matters of government policy it would be interesting to hear this explained.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #37 - Jan 21st, 2011 at 11:30pm
 
Quote:
This suggests that there would be no enthusiasm for addressing anything with the word "Plan" in its title, such as the NTNP, other than to abolish it.

Ofcom has a legal obligation to produce and publish a National Telephone Numbering Plan. The current document does, however, appear to be littered with a fairly large number of errors and inaccuracies.
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SilentCallsVictim
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #38 - Jan 22nd, 2011 at 12:36am
 
catj wrote on Jan 21st, 2011 at 11:30pm:
Ofcom has a legal obligation to produce and publish a National Telephone Numbering Plan. The current document does, however, appear to be littered with a fairly large number of errors and inaccuracies.

The quoted comment was in response to the development of the Political aspects of the topic in a previous posting. It remains to be seen whether, with the drier Jeremy Hunt now wholly responsible for Ofcom, we should await removal of this obligation from Ofcom as the government policy of abolishing regulation and removing red tape is pursued. Perhaps consortia of telcos would be in a better position to know what their customers want!

Because Telcos currently have an absolute duty to comply with the terms of the plan as published, I will refer to "misleading and irrelevant references" in agreeing with the point made.

The options outlined in Section 6 of the consultation document imply proposals which will be implemented partly through revisions to the NTNP. As there are no concrete proposals at this stage, there are no specific proposed revisions to the terms of the NTNP.

Perhaps others would share my view that the questions at the end of section 6 (pdf page 106) read more like an examination paper than a serious attempt to engage stakeholders.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #39 - Jan 22nd, 2011 at 1:58am
 
SilentCallsVictim wrote on Jan 22nd, 2011 at 12:36am:
Perhaps others would share my view that the questions at the end of section 6 (pdf page 106) read more like an examination paper than a serious attempt to engage stakeholders.


Ofcom's consultation questions never serve any useful purpose for the consultation Respondent and are usually only there to try and extract the answers that Ofcom wants to hear in order to justify the course of action proposed in their consultation.  I therefore usually ignore their questions entirely and respond only in a freehand email to those points in the consultation that I consider worthy of comment.
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SilentCallsVictim
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #40 - Jan 22nd, 2011 at 2:40am
 
NGMsGhost wrote on Jan 22nd, 2011 at 1:58am:
Ofcom's consultation questions never serve any useful purpose for the consultation Respondent and are usually only there to try and extract the answers that Ofcom wants to hear in order to justify the course of action proposed in their consultation. I therefore usually ignore their questions entirely and respond only in a freehand email to those points in the consultation that I consider worthy of comment.

On this occasion it is precisely that type of response which is invited, from those who simply do not wish to signify approval of what is stated. The problem arises because the terms of valid responses are specifically restricted to comments on very lengthy dissertations on particular issues.

The major problem from my perspective is that the focus is on a perceived failure in the market for telecommunications services. Misuse of Business Rate numbers by public bodies is a matter relevant to Ofcom's primary principal duty, to further the interests of citizens in relation to communications matters. That duty demands nothing more than the truth about 084 numbers being clearly exposed and understood - it has nothing to do with Ofcom's separate secondary principal duty to regulate markets in the interests of consumers and encourage competition.

NHS Direct, HMRC and DWP Agencies are not providers in the market for telecommunications services, nor, in my opinion, should they be classified as such, so as to join providers of "adult" chat services within the self-regulatory scope of PhonePay Plus. It may be that the government wishes for these public services delivered by telephone to be open to competition, as Boots is now competing with NHS Direct on the internet through its branding of WebMD, however Ofcom is unduly extending its role if it believes that it has a duty to promote such competition.
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SilentCallsVictim
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #41 - Jan 26th, 2011 at 3:07am
 
SilentCallsVictim wrote on Jan 22nd, 2011 at 12:36am:
... with the drier Jeremy Hunt now wholly responsible for Ofcom ...

(WARNING: This posting is strictly for fellow anoraks amongst us.)

If anyone doubted the authority for the quoted statement, I have now found the official announcement -

Transfer of responsibilities from BIS to DCMS


Departmental responsibility for the telecoms aspects of Ofcom's work has been transferred from BIS to DCMS, where that for broadcasting has always resided. (N.B. The "O" in "DCMS" is invisible, like the "D" in "BIS". The former avoids a change in 2012, the latter is a hang over from a reluctance to have the previous BERR look like "database error".)

As a NDPB (quango), Ofcom is accountable to parliament - not to the government. Previously this accountability has been primarily exercised by both the BIS and CMS Commons Select Committees. I await news of the corresponding change in the functions of these committees. Although this would be convenient, it is not strictly essential.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #42 - Jan 26th, 2011 at 10:42am
 
SilentCallsVictim wrote on Jan 26th, 2011 at 3:07am:
SilentCallsVictim wrote on Jan 22nd, 2011 at 12:36am:
... with the drier Jeremy Hunt now wholly responsible for Ofcom ...

(WARNING: This posting is strictly for fellow anoraks amongst us.)

If anyone doubted the authority for the quoted statement, I have now found the official announcement -

Transfer of responsibilities from BIS to DCMS


Departmental responsibility for the telecoms aspects of Ofcom's work has been transferred from BIS to DCMS, where that for broadcasting has always resided.

Perhaps this should have a thread of its own.
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SilentCallsVictim
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #43 - Jan 26th, 2011 at 10:57am
 
Dave wrote on Jan 26th, 2011 at 10:42am:
Perhaps this should have a thread of its own.

This thread moved onto addressing Politics some postings back - they have been left in place.

I wonder if anyone has managed to plough their way through the document yet - so as to be able to offer comment on the consultation and its specific proposals. This is the most radical attempt we have seen for some time to address the issues that concern us in this forum.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #44 - Jan 26th, 2011 at 11:04am
 
SilentCallsVictim wrote on Jan 26th, 2011 at 10:57am:
I wonder if anyone has managed to plough their way through the document yet - so as to be able to offer comment on the consultation and its specific proposals. This is the most radical attempt we have seen for some time to address the issues that concern us in this forum.


Surely you at least must have done so SCV even though I must confess to only so far having read the bullet point summary of what is proposed.
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