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Ofcom consultation: Simplifying Non-Geo Nos 2010 (Read 150,795 times)
CJT-80
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #90 - Mar 28th, 2011 at 9:54pm
 
Loddon how did you manage to have a reply like that on Ofcom's site?

All I got was boxes to fill in, with question numbers next to them.

It's very confusing for me

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Dave
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #91 - Mar 28th, 2011 at 10:59pm
 
CJT-80 wrote on Mar 28th, 2011 at 9:54pm:
Loddon how did you manage to have a reply like that on Ofcom's site?

All I got was boxes to fill in, with question numbers next to them.

It's very confusing for me

Sad

You can write it as a Word file and send it. Download a cover sheet from Ofcom.
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« Last Edit: Mar 28th, 2011 at 11:02pm by Dave »  
 
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CJT-80
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #92 - Mar 28th, 2011 at 11:08pm
 
Dave wrote on Mar 28th, 2011 at 10:59pm:
CJT-80 wrote on Mar 28th, 2011 at 9:54pm:
Loddon how did you manage to have a reply like that on Ofcom's site?

All I got was boxes to fill in, with question numbers next to them.

It's very confusing for me

Sad

You can write it as a Word file and send it. Download a cover sheet from Ofcom.



So you compose a word file with the responses (or as close to the exact ones as possible) attach it and the cover sheet and e-mail it to Ofcom?

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Dave
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #93 - Mar 28th, 2011 at 11:12pm
 
CJT-80 wrote on Mar 28th, 2011 at 11:08pm:
Dave wrote on Mar 28th, 2011 at 10:59pm:
CJT-80 wrote on Mar 28th, 2011 at 9:54pm:
Loddon how did you manage to have a reply like that on Ofcom's site?

All I got was boxes to fill in, with question numbers next to them.

It's very confusing for me

Sad

You can write it as a Word file and send it. Download a cover sheet from Ofcom.



So you compose a word file with the responses (or as close to the exact ones as possible) attach it and the cover sheet and e-mail it to Ofcom?

I send my responses as Word files, making the Coversheet the first page.

It's up to you whether you want to structure your response as answers to the questions or not.
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bazzerfewi
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #94 - Mar 29th, 2011 at 10:39am
 
Hi Dave

I started completing the ofcom form with all the boxes, I also found it very confusing and drawn out, I part completed it and sent it anyway.

If you have formatted a document I would appreciate a copy and I will also send it to the relevant department if you enclose contact details
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #95 - Mar 29th, 2011 at 11:37am
 
bazzerfewi wrote on Mar 29th, 2011 at 10:39am:
Hi Dave

I started completing the ofcom form with all the boxes, I also found it very confusing and drawn out, I part completed it and sent it anyway.

If you have formatted a document I would appreciate a copy and I will also send it to the relevant department if you enclose contact details

The Ofcom Coversheet can be downloaded from the website:

http://stakeholders.ofcom.org.uk/consultations/consultation-response-coversheet/

If you already have some of your response, you can insert it at the beginning of it (you may need to add a page break after the coversheet). Tick the appropriate box(es) for not withholding or withholding your personal details.

Details on how to respond (including e-mail address to which to send Word format responses) is here:

http://stakeholders.ofcom.org.uk/consultations/simplifying-non-geo-numbers/howto...
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #96 - Mar 29th, 2011 at 1:13pm
 
Submissions by a simple email should be sufficient and accepted. Identify yourself, indicate whether or not you wish the response to be published, and if so, whether your name should be published.

I personally make their life easier by sending my responses as a pdf file, along with their completed cover sheet, both attached to an email in which I ask for an acknowledgement of receipt.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #97 - Mar 29th, 2011 at 4:35pm
 
loddon wrote on Mar 28th, 2011 at 9:43am:
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.

Thanks for pointing this out. They make some good points. I think it's a well-balanced response and they refer to the externalities which Ofcom mentioned in the consultation document. I think these externalities hit the nail on the head.

My understanding of economics and business is small, but it has seemed obvious to me that this is the case.

I have long believed that there are issues which are fundamental to having inter-connecting providers that are permitting these rip-offs.

If every party was made to see and accountable for the services it receives, then we would have a much fairer telecoms market.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #98 - Mar 29th, 2011 at 5:30pm
 
loddon wrote on Mar 28th, 2011 at 10:07am:
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. …

Where the split-tariff approach is given the thumbs down, then is this merely because of the dislike of these (084/087) numbers?

If the charge by the phone company (TCP - the telco operating the number) were published, then that the cat would be out of the bag. We would be able to see that TfL allows its 0843 number provider retain around 3 pence per minute (after giving 1.8 pence per minute to TfL in direct payment).

This response begs the question, what approach should be taken for 09 numbers? What about the split-tariff approach for 09 Premium Rate Service numbers?
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SilentCallsVictim
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #99 - Mar 29th, 2011 at 9:54pm
 
Dave wrote on Mar 29th, 2011 at 5:30pm:
... If the charge by the phone company (TCP - the telco operating the number) were published, then that the cat would be out of the bag. We would be able to see that TfL allows its 0843 number provider retain around 3 pence per minute (after giving 1.8 pence per minute to TfL in direct payment).

All of this nonsense about further splitting of the service charge is just opening up all sorts of potential for further fudging and confusion.

Many (including Antelope) see publication and billing of two charges as being unnecessary complication. I cannot see how adding a third item helps anyone.

Callers pay a Service Charge of 5p to call the TfL line - plus the Access Charge added by their telco. I cannot think what more information is of any use to the caller. We know the rates, because BT is prohibited from adding an Access Charge at present and its cost retentions are modest, to the point of insignificance for our purposes. The current Service Charges are the BT rates.

Those concerned with the financing of TfL (or any other 084 user) may want to get a breakdown of how it pays for its telephone service - the portion of the Service Charge retained by its telephone service provider is one of the factors. The other service charges paid to various providers and the nature of the services delivered must however also be vitally important to any such consideration. The full details of the distribution of the Service Charge would also doubtless be of interest. In most cases these details, even the split of the Service Charge, would be properly subject to commercial confidentiality. Compelling partial transparency is probably worse than nothing as it simply provides a distorted view of the truth, indeed it provides an incentive for distortion.

This is all a great red herring. We have no need to go beyond the level of Service Charge paid by the caller.

If Service providers only had to declare the portion of the Service Charge that passes through their accounts (e.g. 1.8p per minute for TfL) then they would doubtless get up to all manner of nonsense, with TCPs offering free outbound calls, disaster recovery facilities etc. so as to eliminate any declarable "revenue share". That would be a "fudge"! We have been battling against this for ages - we do not want it strengthened!

{hr]
loddon wrote on Mar 28th, 2011 at 9:54am:
...
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.

Worse than that, they mean that any package which includes geographic calls must include access charges for Business (and perhaps Premium) Rate calls also. This means that every package subscriber must pay the Access Charge for these calls whether they make them or not (just like all BT customers pay for 0845 calls at present). They also mean that the charge for calls to Geographic Rate (01/02/03) numbers cannot be less than the Access Charge for calls to Business (and perhaps Premium) Rate numbers.

I strongly disagree with this suggestion. I also disagree with the suggestion that the bad debt provision should be covered by a separate Access Charge for 09 calls (It should be a retention from the Service Charge by the OCP, so that a simple single Access Charge may apply.)

Antelope is also way ahead of the game in looking forward to the time when calls to mobiles are priced at the same rate as calls to geo numbers. I believe that this will come, however we do not want Ofcom to hold back for another few years until this point has been reached. This is another good reason why charges associated with NGCS should not be linked to charges for calls to Geographic Rate numbers by regulation. I believe that the necessary linkages will probably occur naturally, especially once we get common standard call charges, including to mobiles.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #100 - Mar 30th, 2011 at 12:52pm
 
SilentCallsVictim wrote on Mar 29th, 2011 at 9:54pm:
Dave wrote on Mar 29th, 2011 at 5:30pm:
... If the charge by the phone company (TCP - the telco operating the number) were published, then that the cat would be out of the bag. We would be able to see that TfL allows its 0843 number provider retain around 3 pence per minute (after giving 1.8 pence per minute to TfL in direct payment).

All of this nonsense about further splitting of the service charge is just opening up all sorts of potential for further fudging and confusion.

Indeed.

I believe that we need to accept the fact that there is a Demarcation Point between calling and receiving parties in any call. In this diagram, it is represented by
[X]
:
    [Caller]---[Caller's Telco]=
[X]
=[Receiver's Telco]---[Receiver, aka "Service Provider"]

Responsibilities: The Caller is responsible for the leg of the call before
[X]
and the Receiver is responsible for the leg after it.

Whilst this has always been the case, since the introduction of different communications providers, with the present way call pricing information is given (and perhaps the way in which calls are billed), we have no clear indication of the Demarcation Point.

It is frequently the case that:
  • Receivers quote the price Callers who are customers of one particular Caller Telco.
  • Receivers talk about, or perhaps more commonly, deny receipt of direct payments from their Telcos.

These obfuscate the benefit that Receivers are getting, irrespective of Caller's Telco. I cannot understand why any member of this campaign would not wish for a system whereby this sort of nonsense was seen for what it is.


Charges: The Access Charge is the amount it costs to transport the call from Caller upto point
[X]
. The Service Charge is the charge to pass the call from point
[X]
to the Receiver (or to phrase it a different way, it is the 'toll' for the call to pass point
[X]
and go onwards to its destination).

This introduces the clarity that is so lacking today. Access Charges and Service Charges have always been combined, which is why we are where we are now.


This is grass roots stuff. In order to have a multi-provider system, they must interconnect with one another. So where Caller can choose from Telcos A, B, C etc, in all cases, the Receiver is with the same Telco. So any one call must be delivered to Receiver by the same Telco (irrespective of what provider Caller subscribes to). Thus, all Telcos incur much the same toll to get past point
[X]
.
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« Last Edit: Mar 30th, 2011 at 12:58pm by Dave »  
 
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CJT-80
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #101 - Mar 30th, 2011 at 7:27pm
 
Response submitted.

I noted that Bristol CAB submitted a response them selves : Here as did Chorley and South Ribble CAB and one from just CAB. I only read the Bristol one and was interested to note that they hightlighted the cost of calling NGN's from a mobile.  When I went on their site to look into their service I note they have an 0844 number to contact them!

Now that's what I call hypocrisy

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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #102 - Mar 30th, 2011 at 7:52pm
 
I'm reading the consultation document and the bit about making freephone numbers free from mobiles.

If it is to be the case that users of 0800 numbers will have to pay more to receive calls from mobile phones than they do for landlines, then this may result in some blocking calls from mobiles.

Where this is so, the mobile providers could perhaps allow a free to caller message giving out an alternative geographic or 03 number that a SP can be called on. It's not ideal, but if some numbers are to be barred (by the SPs themselves), then it might be an option they'd like to explore.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #103 - Mar 30th, 2011 at 8:32pm
 
CJT-80 wrote on Mar 30th, 2011 at 7:27pm:
Now that's what I call hypocrisy

To quickly deal with CABx.

Each CAB is a separate charity funded independently. There is a central coordinating body, called "Citizens Advice", to which they all belong. CA supports their work and organises common services. CA sent around a suggested draft response to the Ofcom consultation which each bureau tailored and added their own bits. Each CAB response does include some different comments and various elements in common with others. I think that this is perfectly legitimate.

They have got themselves into a terrible mess with telephones, having signed up for a service that they cannot afford to fund without contributions from callers. In common with many other charities they use Business Rate numbers, yet are reluctant to admit to levying a charge for their services.

The one positive aspect of the Ofcom "unbundling" proposals is that this would drag them out into the open. I have argued to everyone who claims to support the Ofcom proposals that they must therefore see the logic of themselves voluntarily making the call cost declaration that they wish to be imposed on themselves and others by regulation.
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SilentCallsVictim
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #104 - Mar 30th, 2011 at 9:15pm
 
Dave wrote on Mar 30th, 2011 at 12:52pm:
...
[X]
...

I believe you are saying that when the caller's money goes past
[X]
it is none of their business to know what happens to it; that responsibility must be carried by the "Service Provider" who is wholly accountable for it. We could draw a much more complex picture with money flying off in all directions; but this is immaterial, at least to the caller.

Ofcom uses the term "Access Charge" purely to distinguish it from the "Service Charge" component of a call which has two charge elements. Many (notably Antelope) are tempted to think of Geographic Rate calls as having only the same "Access Charge" as a single component. This idea, which is reinforced by the illustration, leads to the suggestion that the "Access Charge" must be the same as the charge for a Geographic Rate call.

Whilst there is a natural tendency for the two to come together, to compel this would actually move things on a step. Ofcom proposes that the Access Charge component of calls that also have a Service Charge be much simpler than the present system of charging for Geographic Rate calls. I would argue that each tariff should have two Access Charges that apply at all times. A rate per call that applies when the Service Charge is expressed as a rate per call, and a rate per minute that applies when the Service Charge is a rate per minute.

Rates for Geographic calls currently vary depending on various factors, including: usage of a pre-paid bundle, time of day, day of the week, duration of the call and in some cases the actual number being called. This is very complex. The application of penalty charges for Geographic Rate calls made outside the terms of a package is one particular issue that many struggle to come to terms with. There will doubtless be further complications when calls to mobiles start to be charged at similar or identical rates to calls to Geographic numbers.

Obviously it would be simpler if Ofcom were to prohibit cheap calls at weekends, discounts for calls to frequently called numbers, packages that were not fully comprehensive etc. Some (notably Antelope) even suggest that Ofcom should prohibit calls to landlines being cheaper than calls to mobiles under the present circumstances. I am not sure that this is the type of simplicity that we really want.


P.S. Silly me, I forget to mention call setup fees. - Would anyone like to defend the present system of charging for geographic calls as being a model of simplicity, so as to commend itself as the basis for the Access Charge component of a "simplified" structure for non-geographic calls.
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« Last Edit: Mar 30th, 2011 at 9:21pm by SilentCallsVictim »  
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