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Ofcom consultation: Simplifying Non-Geo Nos 2010 (Read 150,793 times)
SilentCallsVictim
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #75 - Feb 20th, 2011 at 9:41pm
 
bbb_uk wrote on Feb 20th, 2011 at 8:36pm:
In my experience, OCP's go out of their way to hide the cost to of NTS numbers - even the most common 0845/0870.

At the moment they have to show the full table of bundled charges. Under the proposals they would have to show just one figure.

bbb_uk wrote on Feb 20th, 2011 at 8:36pm:
Can someone remind me if BT's prices on 084/087 (except 0845/0870) are still regulated?  If so, will the regulation be dropped with Ofcon's new proposals

Yes, including 0845.

Under the new proposals, OCPs will only control the Access Charge - a totally new system. The Service Charge will be defined and billed separately. BT will, for the first time, be able to levy an Access Charge.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #76 - Feb 21st, 2011 at 1:36pm
 
SilentCallsVictim wrote on Feb 20th, 2011 at 9:41pm:
bbb_uk wrote on Feb 20th, 2011 at 8:36pm:
Can someone remind me if BT's prices on 084/087 (except 0845/0870) are still regulated?  If so, will the regulation be dropped with Ofcon's new proposals

Yes, including 0845.

Under the new proposals, OCPs will only control the Access Charge - a totally new system. The Service Charge will be defined and billed separately. BT will, for the first time, be able to levy an Access Charge.
Then I anticipate that the cost of calling these NTS numbers will rise, especially 0844.

Most OCP's have their cost of calling NTS numbers like 0844 similar to BT's charge.  If this restriction is removed from BT then BT will in all honestly increase the cost (access charge as it will be known then) and other OCPs will just copy.  So a 5ppm call now is likely to cost more (when adding the access charge and service charge together).

A similar thing happened with the line rental.  Before BT's restriction on charging line rental was removed, other OCPs charged around the same as BT to obviously remain competitive.  After BT's line rental restriction was removed, BT obviously increased their line rental and has kept increasing it since - along with call charges and call setup fees and when BT increases their charges, other OCPs just basically copy.  Where is the competition in that?

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« Last Edit: Feb 21st, 2011 at 1:37pm by bbb_uk »  
 
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SilentCallsVictim
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #77 - Feb 21st, 2011 at 7:13pm
 
bbb_uk wrote on Feb 21st, 2011 at 1:36pm:
Then I anticipate that the cost of calling these NTS numbers will rise, especially 0844.

When a restriction introduced to encourage use of 084/087 numbers by making calls cheap is removed, then obviously the price would be expected to rise, even if the restriction only applied to the largest single provider. Those who make no money on originating calls to NTS numbers (BT by compulsion, others due to competing very directly with BT) must be inflating charges elsewhere in order to make a profit. Even if we will not see direct evidence of the cross subsidy being removed, I do not want this situation to continue. I certainly do not wish to see it extended by being applied to all telephone companies, so that the cost of calling NTS numbers falls, whilst other charges rise.

If it faces no competition, then please point out to BT that it is wasting shareholder's money on its marketing budget and by reducing the price of the unlimited anytime package. Price mirroring is what is seen in both a highly competitive market and a cartel. My local Sainsbury's proudly announces that even its own brand products are at the same price as Tesco! In a perfect market, a particular product or service (if identical) would be sold at the same price by all providers, as each would be compelled to match the others decreases, and increases could only occur when all were ready to follow.

The unfortunate truth is that in this sophisticated world there are rarely totally clean open markets nor total cartels. There is quite enough economic theory in Ofcom's papers to keep the most interested academic happy.

For me, there is enough competition to make the fact that BT originates less than 25% of non-business telephone calls sufficient reason for its charges for calls to non-geographic numbers to be regarded as atypical and unsuitable for use as an illustration.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #78 - Feb 21st, 2011 at 7:58pm
 
SilentCallsVictim wrote on Feb 21st, 2011 at 7:13pm:
bbb_uk wrote on Feb 21st, 2011 at 1:36pm:
Then I anticipate that the cost of calling these NTS numbers will rise, especially 0844.
When a restriction introduced to encourage use of 084/087 numbers by making calls cheap is removed, then obviously the price would be expected to rise, even if the restriction only applied to the largest single provider. Those who make no money on originating calls to NTS numbers (BT by compulsion, others due to competing very directly with BT) must be inflating charges elsewhere in order to make a profit. Even if we will not see direct evidence of the cross subsidy being removed, I do not want this situation to continue. I certainly do not wish to see it extended by being applied to all telephone companies, so that the cost of calling NTS numbers falls, whilst other charges rise.
I know where you're coming from and I agree that cross-subsidy exists but going from past experience (aka line rental), the cost of line rental went up and up and others costs went up and up as well.  I have seen no evidence, obvious anyhow, that the cost for BT for line rental was cross subsidised and so when line rental went up, other costs didn't (ie no need to cross subsidy now that line rental restriction removed).

If we were in a perfect world then removing restriction on NTS numbers may mean a, for example, slight rise to NTS numbers but then no rise anywhere else like other call charges, line rental, etc because NTS numbers no longer has to be subsidised.  However, were not in a perfect world and I simply do not believe that removing restictions on NTS numbers and a subsequent price increases means other rises wont happen.

Competition, IMHO, just doesn't really exist for landline & calls like it does for mobiles.  For example, BT whom include calls to 0845 have to obviously pay for these calls despite so-called offering them free (for those on an appropriate tariff) so obviously BT have to cross-subsidise these costs from other areas and hence the increase after increase.

However, most other OCP's don't include calls to 0845 so when BT increases their costs pretty-much across the board there shouldn't be such a need (and rush in some cases) for these other OCPs to follow them.  However, they basically do.

Basically, there is no real perfect answer where everyone wins lol.

Quote:
For me, there is enough competition to make the fact that BT originates less than 25% of non-business telephone calls sufficient reason for its charges for calls to non-geographic numbers to be regarded as atypical and unsuitable for use as an illustration.
Last I noticed most OCPs (mobile providers excluded) generally charge around the same for calls to NGN so the, "calls to 0844 ... cost 5ppm from a BT landline, other providers may differ" to be as accurate one can get (at the moment).  Obviously the main difference is mobile OCPs like I mentioned and VirginMedia, who must be the UKs most expensive landline provider for calls to NGNs, and are an exception to the norm for landline providers.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #79 - Feb 22nd, 2011 at 4:54pm
 
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SilentCallsVictim
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #80 - Feb 22nd, 2011 at 5:58pm
 
catj wrote on Feb 22nd, 2011 at 4:54pm:

Interesting indeed.

What is worthy of note is that "03" is only mentioned as the penultimate word.

Awareness is built and consumer perceptions changed very slowly. Ofcom has a lot of work to do. Much of that has to be achieved by building alliances with those who can help in putting across the messages that it wishes to convey. If few providers are able to issue 03 numbers as part of attractive deals, then they will not be promoted by the "numbers" industry.

Ofcom has to recognise that it has a positive role as well as the negative role of a regulator. Its positive ideas should not be simply restricted to the way in which it formulates regulations.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #81 - Mar 7th, 2011 at 1:17am
 
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #82 - Mar 7th, 2011 at 10:43pm
 
Somewhat belatedly perhaps - I have published some simple notes reflecting a personal view on responding to the Ofcom consultation - http://tinyurl.com/dhtiny/doc/?CONSRESP.pdf.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #83 - Mar 8th, 2011 at 1:01am
 
Anyone have any knowledge of an organization by the name "The Telephone Company"? My limited web searches have yielded very little. It provides only a gmail address. Seems it isn't too impressed with this forum:

http://stakeholders.ofcom.org.uk/binaries/consultations/nongeo/responses/the-tel...
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As from November 21, 2013, I no longer participate in the forum and am unable to receive private messages.
 
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SilentCallsVictim
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #84 - Mar 8th, 2011 at 1:40am
 
idb wrote on Mar 8th, 2011 at 1:01am:

Fairish comment. There is no structure that justifies saynoto0870 being classified as a lobby group. It has a database of alternative numbers and an open discussion forum. It is run on a commercial basis supported by advertising.

I suspect that moderators would take exception to the suggestion that individuals post under different identities so as to manufacture dialogue, as they would probably seek to prevent this. It is however not an issue of any great consequence - it is an open forum - anyone can express whatever opinion they wish. Furthermore, I would totally defend the right of contributors to remain anonymous, if they wish.

The use of a personal number on the domain record is unfortunate, and just the sort of thing that many members would seize on as the basis for discrediting all that is published here. The general style of the comment in the consultation response is also not entirely unfamiliar to those who read these columns (although I am not suggesting anything improper). I think that Mr Wilson is indeed one of us, at least in spirit.

Perhaps Ofcom has a duty to check out possible use of spoof company names before publishing responses.
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SilentCallsVictim
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #85 - Mar 12th, 2011 at 1:43am
 
SilentCallsVictim wrote on Mar 8th, 2011 at 1:40am:
Perhaps Ofcom has a duty to check out possible use of spoof company names before publishing responses.

Whether for this or some other reason, the response in question has been removed from publication.

The deadline for responses has been extended to 31 March. Members may be interested to browse the other responses that have been published. This may inspire or encourage them to make a contribution. Nobody has yet attempted to answer all of the questions posed; some have simply made brief free format comments by email.

(See http://stakeholders.ofcom.org.uk/consultations/simplifying-non-geo-numbers/ - a button to "Show Responses" is towards the bottom of the right hand panel.)
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #86 - Mar 28th, 2011 at 9:43am
 
Can I take this opportunity to remind everyone that this consultation deadline has been extended to 31st March 2011 --- in 4 days time.  There is still time to have your say in the most important consultation issued by Ofcom to members and users of this website, I would have thought, because this website and campaign is all about non-geographic numbers, their use and misuse.

I urge all to respond now and reinforce our campaign.

I would also point out that my own response is published here http://stakeholders.ofcom.org.uk/binaries/consultations/simplifying-non-geo-numb...

Regular readers of this Forum will be aware that I have been pressing the point for quite a long time now that 0843/4/5 and 0870/1/2/3 numbers are fundamentally a giant rip-off of the public and callers in general because the costs for such numbers are imposed quite wrongly, unethically and illegitimately on callers and not the companies and organisations which exploit and benefit from these numbers.    While I have had some moderate support for this point of view from a few contributors to this Forum I have felt that not many people entirely get it or yet support this point of view.   It has  heartened me to discover that at least one responder to the consultation agrees and has expressed their views in this response which I urge everyone to read and perhaps be inspired to submit their own response   ----  http://stakeholders.ofcom.org.uk/binaries/consultations/simplifying-non-geo-numb...

Antelope Consulting appear to be an authority on these matters given their profile of providing advice and consultancy on  this type of issue in 60 countries around the world to both Governments and Telecomms Authorities.

Again I urge everyone to take this unique opportunity to influence Ofcom while you still have the chance.  If some feel that they agree with or sympathise with my point of view and that of Antelope Consulting, then a response reinforcing that would be greatly appreciated.
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« Last Edit: Mar 28th, 2011 at 9:43am by loddon »  
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #87 - Mar 28th, 2011 at 9:54am
 
I quote below a few extracts from the response by Antelope Consulting which I see as important :---


In particular, we favour requiring the access charge [to 084/7 numbers] to be no greater than the charge for a call to a geographic or mobile number; all non-geographic numbers other than free-to-caller numbers could then be described by one set of rules (as an 03 number would simply be tariffed with the access charge and have a service charge of zero)2. Alternatively, the access charge could be required to have a particularly simple form, such as being per call.

The consultation document also expresses concerns about whether the revised EU framework provides an adequate legal basis for having a maximum access charge. The concern is hard to understand, when the framework explicitly permits maximum prices for consumer protection and the maximum access charge is intended for exactly this purpose.

Because of the problems with absolute bounds (other than zero) on prices, we prefer relative bounds where possible, such as requiring the access charge to be no greater than the charge for a call to a geographic or mobile number.


They don't specifically state but I assume that by recommending that the access charge to 084/7 numbers be related to the cost of normal geographic numbers that they mean that access charges would always be included in packages.
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« Last Edit: Mar 28th, 2011 at 9:59am by loddon »  
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #88 - Mar 28th, 2011 at 10:04am
 
Some extracts from my own submision :---

083/4/5 and 0871/2/3 Numbers
Regarding 0843/4/5 and 0871/2/3 numbers the problem is that they are wrong in concept and wrong in design . They are fundamentally unethical and are quite rightly distrusted by the public. I believe the new Ofcom proposals will not rectify this distrust because the proposals do not address the ethics of the concept.
Concept
As I understand it the concept of 084 and 087 numbers is that they provide for certain benefits to the organisation using them such as re-routing and redirecting calls, call management, collection of varied call statistics, geographical anonymity or geographical ubiquity and, some may say, a certain amount of prestige. These are all benefits to the Organisation concerned and not of benefit directly to the caller. As an aside, there is a contention that these claimed benefits are not exclusive to 084 and 087 because technical features such as re-routing, call management and statistics can equally well be obtained if geographical numbers are used. 03 numbers of course can equally provide all the same benefits.
084 and 087 numbers also provide for micro-payments through the telephone system, which means that Organisations can collect revenue from callers. At present this is entirely unethical because no phone contract that I am aware of sets
out the contractual basis for collecting this money, deducting it from the callers account and paying it over to the third party. All contracts are essentially between the caller and his service provider: there is no third party.
The Problem
The problem with this concept is that while the benefits of 084 and 087 accrue to the called Organisation it is the caller who is billed and must pay. (This is done through the higher charges that are made, which in turn are based on the internal accounting procedures which operate between phone companies handling the calls. There are exceptions currently due to legacy regulations, but I understand that Ofcom propose to remove these regulations and to allow equable competition between all phone companies.) The Organisation receives the benefits but the caller must pay for them. This surely is wrong and unethical from every normal business transaction standpoint. He who receives the benefit should pay for the service.

Where businesses, government departments or any Organisation for their own convenience or for any reason choose to use a non-geographic number any additional cost should be borne by those Organisations and not the caller. This is what happens currently when 03 numbers are used, as Organisations can negotiate with the phone service providers on method and how much they must pay for the benefits of the 03 numbers they choose, while the caller pays only his normal geographic call cost with inclusion in any call package. The Organisations have buying power and leverage when negotiating, whereas individual callers have no negotiating power nor, critically, any negotiating opportunity. Callers are effectively left with no choice when confronted with 084 or 087 numbers, they must either pay whatever it costs or not make the call at all. When choosing a calls supplier the matter of charges for this type of call is often invisible, not presented and not usually considered.
Inefficiency

Another aspect of this concept and design is that the longer a call takes the more revenue the called Organisation receives. Therefore the Organisation has no incentive to keep calls as short and efficient as possible. Indeed the incentive is directly opposite and there must be some temptation to cause calls to last longer and so to increase the revenue. Long winded recorded messages, extensive menus, long call queues all have this effect without costing the Organisation anything as they are zero cost once set up. Queues can be unlimited in length. The phone service companies also do not mind longer calls at premium rates because this provides additional revenues. There are many examples in the public domain of people complaining of long queues while calling 084 numbers. This used to be a problem with 0870 but is curtailed somewhat with 0871/2/3 by regulation although the regulation could be more strict and more rigorously enforced. The idea of “light touch” regulation in this regard is totally unacceptable from a callers point of view.
The deliberate or incidental extension of call lengths leads to considerable waste of time by callers which when multiplied by the millions of calls to 084 and 087 numbers every day must add up to a massive cost to the national economy. The telephone system and numbering infrastructure is a national asset and should be designed as far as possible to help improve efficiency in the country and not to hinder it. The current Ofcom proposals would be better if they addressed this issue instead of ignoring it.
So are these problems of (a) charging the caller instead of the user Organisation for the benefits (b) revenue collection through the telephone system and c) inefficiency addressed by the Ofcom Proposals? Sadly the answer is NO.

Continued in next post.
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« Last Edit: Mar 28th, 2011 at 10:20am by loddon »  
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #89 - Mar 28th, 2011 at 10:07am
 
Extracts continued  :---

Simplicity
The proposals offer a little more transparency in the pricing of calls but they do nothing to address the fundamental issues. They also do not simplify call tariffs because working out the price of a call will become much more complicated in future. If Ofcom want to increase the use of the phone system and expand the industry then the key would indeed be simplicity, and that means in my view, simplicity in charging structures and tariffs which would also allow callers to easily compare service and price offerings from competitive phone service suppliers rather than the complicated half hidden price structures of today.
Charges for using 084 and 087 number
The idea of splitting the call price to the caller into two elements service charge and access charge is a fudge. The service charge is comprised of two main elements the revenue passed on to the Organisation using the 084 or 087 number and the phone company charge for using that number. This split would still be invisible to the caller and is a major problem because the phone service charge is usually the largest element, often by a long way. For example, Transport for London (TFL) recently revealed in response to a FoI request that they paid only £23 for their new 0843 number; NOT £23,000 or £230,000 but £23. They also said that they receive 1.8 pence per minute from every call. This is obviously a very good deal from the TFL perspective. But it is catastrophic from both the callers' and national perspectives. 0843 numbers are excluded from all call packages, and in my view so they should be under the current numbering design. 0843 numbers cost from 5p to 10p (approx) per minute from various landline service providers and from 20p to 41p (approx) from competing mobile providers. This means that for every £1.8m that TFL receives the cost to landline callers is between £5m and £10m and for mobile callers it costs up to £41m. Cost of £41m to generate
£1.8m revenue is a highly inefficient way of collecting revenue and if all the callers were a single entity they would very quickly be negotiating or taking other action to reduce their costs. This is merely one example but this must be multiplied by many thousands if not millions across the 084/087 industry.
Because callers cannot act as a single or a small number of entities we, the public, rely on Ofcom to protect us from harm, look after our interests and regulate so that this type of extortion cannot happen.
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. 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.
Revenue Share
This would leave the question of the revenue share payable to the user Organisation. I am generally against this in concept, but if it were to be retained then it should not necessarily be related to the length of the call which could still tempt call lengthening for revenue earning purposes. It may be better to make this a fixed price per call, to be set by the Organisation. This would provide true transparency and enable callers to make clear decisions prior to committing to a call because they would know in advance their access charge (or its basis) and they would know how much they are paying for the service and that the whole cost is going to the Organisation called. The Organisation would be in a position to influence the
cost of use of the 084 number and realistically to negotiate. This would address the question of overall efficiency because the Organisations would have an incentive to keep their service calls efficient. The question of simplicity for callers would also be addressed with this design because callers would only need to know the service price declared and they would already be aware of their access charge or package.
None of this improvement would happen under the Ofcom proposed scheme, because although the callers would be, for the first time aware of revenue generation for the called Organisation, they would not be aware of just how much of that is going to the phone company and how little to the Organisation called. The Organisations would still have little interest in reducing the call costs and in more efficient call management issues, like reducing call queues because the longer the call queues the more they earn.
An option which Ofcom might consider in the event of rejecting my proposals, but which I would not otherwise favour, is stipulating that any Organisation which uses 084 or 087 numbers must offer alternative 01, 02 or 03 numbers at all times and alongside all published numbers. This would allow callers to exercise choice and create a marketplace for competition to control 084 and 087 charges.

Continued in next post.
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« Last Edit: Mar 29th, 2011 at 12:48am by loddon »  
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