From: http://www.ofcom.org.uk/media/news/2008/05/nr_20080502

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Ofcom today set out proposals to provide clarity about the price of calls to 0870 numbers and strengthen consumer protection on calls to 0871 numbers.

0870 numbers are used by many businesses and organisations for a wide range of services including road traffic advice, customer services and financial services. This consultation is part of Ofcom’s wider review of so-called “non-geographic” telephone numbers (those not assigned by location) following consumer concerns over the lack of transparency about the cost of calls.

Today’s consultation proposes that all calls to 0870 numbers should normally cost no more than calls to geographic numbers (01 or 02 numbers) and that 0870 calls should be included in communications providers’ call packages price plans on the same basis as geographic calls. This may significantly reduce the cost of calling these numbers.

Currently 0870 calls are priced at levels that enable businesses and organisations to share the revenue generated by per-minute call charges. Ofcom’s proposals would effectively end revenue sharing on 0870 numbers when combined with other proposed changes to non-geographic call regulation.

Communications providers that want to charge 0870 calls at rates above those for geographic numbers would be bound by strict rules about how prices are publicised and would be responsible for ensuring their customers know what 0870 calls cost. If communications providers do not comply with these rules, they could be subject to penalties including possible fines.

Ofcom aims to have the proposed changes in place by the autumn.

Extension of Premium Rate Services Regulation to other 087 numbers

Separately, Ofcom also published a consultation setting out proposals to improve consumer protection for calls to the most expensive 08 numbers (0871 numbers) by bringing these within the remit of the premium rate services regulator PhonepayPlus (formerly called ICSTIS).

Under PhonepayPlus rules, businesses would be required to publish the price of calls in their advertising and promotional materials and PhonepayPlus would also investigate complaints about excessively long call queuing times only after the complaint has first been referred to the service provider.

PhonepayPlus also has a range of powers that enable it to address scams quickly when they arise. Ofcom is now seeking views on the rules that PhonepayPlus will apply to 0871 numbers.

Ofcom aims to publish a decision in summer 2008 and PhonepayPlus will start to regulate these numbers by the end of the year.

The consultation on 0870 numbers can be found at: http://www.ofcom.org.uk/consult/condocs/0870calls/

The consultation on 0871 numbers can be found at: http://www.ofcom.org.uk/consult/condocs/087prs/
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Regards
Sunil

http://ukpress.google.com/article/ALeqM5goIiwhJKPJAUfTGOPMKeCdPUjqdg

PA

Ofcom 'to cut prices of 0870 calls'

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Regulator Ofcom has announced plans to cut the price of calls to 0870 numbers and introduce tighter regulations for 0871 lines.

The communications watchdog wants 0870 numbers to cost no more than calls to geographic numbers.

The proposals also improve protection for customers calling 0871 lines - the most expensive of the 08 numbers - by bringing them under the remit of premium rate services regulator PhonepayPlus.

The plans are part of Ofcom's wider review of "non-geographic" telephone numbers, or those not assigned by location, following consumer complaints over the lack of transparency about the cost of calls.

Many businesses and organisations use 0870 numbers to provide information including road traffic advice, customer service and financial advice.

The regulator said companies should provide 0870 lines on the same basis as geographic calls. The proposal is likely to significantly reduce the cost of calling such numbers.

Calls to 0870 numbers are currently priced in a way that allows organisations to share the revenue generated by per-minute call charges. Ofcom's proposals would effectively end this.

Businesses who wanted to charge higher rates for 0870 calls would be bound by strict rules about publicising prices, and would be responsible for making sure their customers knew the costs.

Ofcom said it hoped to have the proposed changes in place by autumn.

Businesses using 0871 numbers would have to publish the price of calls in their advertising under rules set down by PhonepayPlus.
>>

http://www.computeractive.co.uk/computeractive/news/2215793/ofcom-opens-consultations-rules

Ofcom opens consultations on new rules for two 08 numbers

Regulator wants clarity on costs and greater protection for consumers

Dinah Greek, Computeract!ve 02 May 2008

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Ofcom has proposed greater protection and clarity on prices for consumers when they use 0870 and 0871 numbers.

The move follows increasing public concern about the lack of transparency over the cost of calls to these so-called non-geographic phone numbers. They are often used by organisations or businesses for services such as customer helplines or traffic advice.

But the different tariffs that companies can charge are bewildering. Anger over the costs has lead to websites, such as Say No to 0870, that give consumers alternative numbers to call.

As part of a wider review of the pricing of all non-geographic telephone numbers (those not assigned by location) Ofcom has proposed ending revenue sharing on 0870 numbers.

At the moment 0870 calls are priced at levels that enable businesses and organisations to share the revenue generated by call charges. The regulator also wants the cost of these calls to be no more than calls to geographic numbers (01 or 02 numbers). If adopted this could significantly reduce the cost of calling these numbers.

It said in a consultation opened today that communications providers that want to charge 0870 calls at rates above those for geographic numbers would be bound by strict rules about how prices are publicised. They would be responsible for ensuring their customers know what 0870 calls cost.

If they do not comply with these rules, they could be subject to penalties including possible fines. Ofcom also said 0870 calls should be included in communications providers' call packages on the same basis as geographic calls.

It has opened a separate consultation on the more expensive 0871 numbers. The regulator said these should be brought under the remit of premium-rate regulator Phonepayplus.

Businesses would be required to publish the price of calls in their advertising and promotional materials and Phonepayplus would also investigate complaints about excessively long call queuing times – but only after the complaint has first been referred to the service provider.

Ofcom aims to publish its decisions this summer and, providing no significant changes are made, Phonepayplus will start to regulate 0871 numbers by the end of the year.
>>

http://www.marketingweek.co.uk/cgi-bin/item.cgi?id=60640&d=254&h=260&f=3

Ofcom to clamp down on 08 numbers

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Media regulator Ofcom has announced plans to tighten the rules on 08 telephone numbers. The regulator wants to provide greater clarity over the price of calls to 0870 numbers. It is also looking to clarify the cost of calls to 0871 numbers.

The consultation is part of a wider review into the cost of phone numbers not assigned to a specific geographical location, which the regulator says will be in place by this autumn.

Ofcom consumer panel chairman Anna Bradley says: "The continued high prices of calling 0870 numbers, particularly from mobile phones, is simply a scandal."

The regulator is proposing that the cost of calling 0870 numbers should be brought in line with 01 and 02 numbers. It also wants tariffs to be better displayed.

Bradley adds: "It is simply unacceptable that consumers are paying up to 25p a minute to call 0870 numbers from mobile phones, or 10p a minute from landlines, when compared to the lower costs of calling geographic numbers."

0870 numbers are currently used by businesses and organisations in sectors such as financial services, as well as for traffic advice.
>>

http://news.bbc.co.uk/1/hi/business/7380147.stm

Price cut plan for 0870 numbers

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The cost of calls to 0870 numbers will be cut under proposals by the regulator after complaints about price clarity.

The number is typically used by consumers when calling customer services departments or seeking advice such as traffic information.

Regulator Ofcom wants prices to come down from a typical daytime tariff of 6p to 10p per minute to 3p to 4p.

More expensive 0871 numbers would also be regulated by the premium-rate watchdog, under Ofcom's proposals.

The plans, which Ofcom wants in place by the autumn, are part of a wider review of so-called "non-geographic" numbers - which are not assigned by location.

Cutting prices

The 0870 numbers are used by a wide range of businesses and organisations offering anything from traffic information to financial services.

Consumers have complained to Ofcom about a lack of transparency in pricing.

On average these calls cost between 6p and 10p per minute in the daytime from a BT landline and 1p to 5p at other times.

Ofcom wants this to be reduced to around 3.5p a minute in the day and 1p to 1.5p a minute at other times - similar to "geographic" telephone numbers.

The proposals would effectively rule out companies or organisations sharing the revenue generated by the calls.

Those which wanted to charge more would have to abide by strict rules on how call charges were advertised.

'Scandal'

"The continued high prices of calling 0870 numbers, particularly from mobile phones, remains a shame and a scandal," said Ofcom Consumer Panel chairwoman Anna Bradley, who welcomed the proposals.

"It is simply unacceptable that consumers are paying up to 25p a minute to call 0870 numbers from mobile phones, or 10p a minute from a landline, when compared to the lower costs of calling geographic numbers."

In a separate decision, Ofcom announced plans to improve consumer protection for calls to more expensive 0871 numbers.

It wants these numbers to come under the remit of PhonepayPlus, the premium-rate regulator.

Under the watchdog's rules, prices would have to be published on any advert or promotional material for an 0871 number and excessively long call queuing times could also be investigated.
>>

Too weak, too late and too narrow. ...  But let us deal with what we have before us ...

The proposal is clearly predicated on BT’s announced intention to drop its rates for calling 0870 to those of geo calls, given that the on-going action in respect of termination charges comes out in its favour. BT must be urged to make a clear public (re-)statement of its position for the benefit of those proposing to respond to the consultation.

If the termination charges dispute comes out in favour of the TCPs, then the Ofcom proposal is dead in the water. Equally, if BT fails to take advantage of a judgement in its favour by treating 0870 in the same way as 03, then Ofcom’s hopes that this proposal will have any significant effect are also dead.


Whilst Ofcom cannot bind users of 0870 numbers (SPs) in any way in respect of how the charge for calling 0870 numbers is described, there is no reason why it cannot make a clear and bold recommendation in this respect.

If its aim relates only to the somewhat nebulous concept of consumer awareness, there is no reason why the final statement could not include such recommendations. Whilst not binding, those with a public reputation who are seen to disregard an Ofcom recommendation could readily be put under pressure to comply.


I look forward to an interesting discussion about how best to deal with the situation we have now. I hope that any fully justifed comments about what a load a rubbish Ofcom is are accompanied by suggestions about how it might be persuaded to improve its act or compelled to do so. If Ofcom is shown to be wholly “unfit for purpose” then suggestions about how it might be replaced or re-formed will move the topic forward.

I knew Ofcom was going to remove the requirement for a pre-call announcement.

I have yet to read the whole consultation before making comments because Ofcom have been known to leave important information out of their brief description, instead burying it within the a very large consultation (over 100 pages in this consultation on 0870 alone).

http://www.mirror.co.uk/news/topstories/2008/05/03/rip-off-0870-phone-bills-face-cuts-89520-20403764/

Rip-off 0870 phone bills face cuts

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Rip-off charges for dialling 0870 numbers are to end, telephone watchdog Ofcom has declared.

They cost 10p a minute from landlines and 40p from mobiles - and companies with the numbers pocket up to 40 per cent.

Ofcom wants to cap costs at 3.5p a minute by autumn.

Firms which refuse, and those with even costlier 0871 prefixes, will have to publicise charges in ads.

Ofcom's Anna Bradley said: "The high price of calling 0870 numbers, particularly from mobiles, is a shame and a scandal."
>>

http://news.scotsman.com/uk/Watchdog-plans-0870-cost-cuts.4047988.jp

Watchdog plans 0870 cost cuts

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OFCOM has announced plans to cut the price of calls to 0870 numbers so they are no more expensive than geographic numbers.

Many firms use 0870 numbers for customer services. They can cost up to 10p a minute to call from a landline, or 25p from a mobile.
>>

http://www.thisismoney.co.uk/news/article.html?in_article_id=441110&in_page_id=2

Watchdog to cut the cost of 0870 numbers

Philip Scott, This is Money
2 May 2008, 5:44pm

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The cost of telephoning 0870 numbers is to be slashed under new proposals following gripes from consumers over high costs.

0870 numbers are used by many businesses and organisations for a wide range of services including road traffic advice, customer services and financial services.
This consultation is part of Ofcom's wider review of so-called 'non-geographic' telephone numbers (those not assigned by location) following consumer concerns over the lack of transparency about the cost of calls.

An Ofcom spokesman said: 'Our proposals are designed to protect the consumer. As a starting point we believe that 0870 numbers should normally cost no more than a call to an 01 or 02 number.

'Where they cost more, service providers should clearly advertise this so that consumers are fully aware of the costs.'

Presently 0870 calls are priced at levels that enable businesses and organisations to share the revenue generated by per-minute call charges.

Ofcom's proposals would effectively end revenue sharing on 0870 numbers when combined with other proposed changes to non-geographic call regulation. It is looking to have the plans implemented sometime in the second half of the year.

Typically calling 0870 numbers costs between 6p and 10p per minute during the day and between 1p and 5p during off peak hours.

But Ofcom is looking to have these cut back to circa 3.5p a minute for daytime calls and between 1p to 1.5p a minute at other times - similar to "geographic" telephone numbers.

In addition more expensive 0871 numbers would also be regulated by the premium-rate watchdog, PhonepayPlus, under Ofcom's proposals. Under PhonepayPlus rules, businesses would be required to publish the price of calls in their advertising and promotional materials.

PhonepayPlus would also investigate complaints about excessively long call queuing times only after the complaint has first been referred to the service provider.
>>

Four weeks to go until the deadline.

Dave wrote on May 19^th, 2008 at 7:51pm:

Four weeks to go until the deadline.

And a few responses:

http://www.ofcom.org.uk/consult/condocs/0870calls/responses/

http://www.ofcom.org.uk/consult/condocs/087prs/responses/

idb wrote on May 19^th, 2008 at 8:04pm:

And a few responses http://www.ofcom.org.uk/consult/condocs/0870calls/responses/

... which make some good points, but (sadly and predictably - I intend no criticism) do not seriously address the content of the consultation document. It is full of technical detail and requires an understanding of the vital context, in particular the outcome of the ongoing dispute about BT termination fees and the intentions of BT and others in respect of the options presented by Ofcom.

I would suggest that no member of the public is able to offer a meaningful response whilst these items are unknown and their significance unrecognised.

To avoid accusations that I am trying to make this more confusing than it really is, I am not going to make a long posting explaining exactly why, however ...

... the following Judgement from the Competition Appeals Tribunal means that Ofcom cannot go ahead with the proposals out to consultation: http://www.catribunal.org.uk/documents/Judgment_TRDs_200508.pdf

In lieu of a complete and necessarily lengthy explanation, I can refer readers to paragraph 2.30 of the consultation document and wish them good luck in reaching the understanding that this kills the proposals and renders the current consultation worthless, other than as a means of gauging general opinions.

I hope that someone in the media will be able to pick up on this story and get the following recognition into the public domain -

Ofcom's current attempts to "Say No To 0870" have again failed

So, nothing's changed, nothing's going to happen, there are now no meaningful proposals on the table and, in reality, all that has happened is the abusers have been given more time to quietly move to 0844, 0871 and 0872 numbers.

Further to my previous posting; this may not help much, but Ofcom has now acknowledged the relevance of the CAT Judgement to various (unspecified) disputes:

http://www.ofcom.org.uk/bulletins/comp_bull_index/other/disputeref/

Amongst those which are relevant is that referred to in para 2.29 of the consultation document.

I've emailed money@guardian.co.uk as follows:

"Any chance of Guardian Money exposing Ofcom's latest muddle? Ofcom is failing, for the umpteenth time, to curb the 0870 ripoff. The Competition Appeals Commission has just issued a judgment that roundly condemns Ofcom's bungling over disputes between BT and the mobile phone companies. This judgement should have been widely reported, but has presumably seemed too technical for the daily press.

http://www.catribunal.org.uk/documents/Judgment_TRDs_200508.pdf

Paragraph 128, page 57, on the brown eggs analogy, is an enticing foretaste, but you need to get one of your best reporters to read the whole thing!

It follows, as Ofcom admit (in their usual inpenetrable code) here:

http://www.ofcom.org.uk/bulletins/comp_bull_index/other/disputeref/

that the hugely complicated solution to the 0870 scam that Ofcom is currently 'consulting' on, won't work. See paragraphs 2.29 - 2.31 of the current 'consultation' document:

http://www.ofcom.org.uk/consult/condocs/0870calls/0870condoc.pdf

Ofcom will be unable to hold down the price of 0870 calls to be the same as calls to honest 01 02 and 03 numbers, because the Competition Appeals Commission would overrule them again, if they tried.

The UK's telephone numbers are heading towards a complete shambles.

Calls from a landline to honest 01 02 and 03 numbers are now so cheap, that anyone who shops around can get deals offering all such calls (including the flat charge misleadingly referred to as 'line rental') for around £15 to £20 a month. Once you have such a deal, or if you are calling from a mobile phone, 'free' 0800 numbers are pointless for the consumer, and just make money for the telcos. Calls to 0870 are, and because of Ofcom's bungling will remain, expensive: typically 8 pence per minute, much more from mobiles. 0845 is still relatively cheap from a BT landline, but pointless if you have an 'all honest calls' deal, and expensive from a mobile. Meanwhile a host of other rip-off numbers are gaining ground: 0844, 0871, 0872, 0873, and the out-and-out swindles on 09. No mere human can possibly keep track of what it costs to call these, and what cut the outfit you are calling is taking."

Obviously I don't really understand all this, so it would be good if people who do understand it also contact Money Guardian - or other suitable Organs.

nicholas43 wrote on Jun 3^rd, 2008 at 2:09pm:

Obviously I don't really understand all this, so it would be good if people who do understand it also contact Money Guardian - or other suitable Organs.

Nicholas,

You are clearly very informed and observant in all the interesting points you have made above about the Competition Appeals Tribunal but sadly the failure of Ofcom to tackle the great 084/7 calls ripoff is not the result of any form of ineptitude or incompetence on their part but is instead the result of the utter cynicism and clear contempt for the general public that has repeatedly been exhibited by its senior staff who have clearly secretly been following orders from the government not to shut down these scam numbers (many of which are run by important commercial friends of New Labour like Sky and Capita).  Unfortunately it would appear that Ofcom supremos Ed Richards and David Currie in fact seem to think that their principal duty is actually towards the future smooth acquisition of their respective knighthoods and peerages from New Labour rather than towards protecting the best interests of the UK citizen and the UK consumer (as Section 3 (i) of the Communications Act 2003 would appear to suggest to be their duty).

If you had been with us here for the last few years you would have come to the realisation by now that Ofcom is not incompetent or bungling.  Instead it is secretly executing a quite deliberate and utterly dastardly New Labour supported plan with the telcos to keep the multi billion pound 084/7 ripoff industry in business while giving a token and sham impression to the general public and so called journalists (who are so easily misled by Ofcom as for it to be quite shameful) of apparently being favour of bringing the scam to an end.

Note how Ofcom even still now allow 084 and 087 numbers to misleadingly be called Local Rate and National Rate on most domestic phone bills, even though this is not a matter they can fob off to the Advertising Standards Authority but is instead something for which they are directly responsible under their own General Conditions (which control all aspects of phone billing and phone bill content).

If you had attended the recent joint question session for Messrs Currie and Richards by the Parliamentary Culture and Business & Enterprise Select Committees and witnessed the shamefully ineffective questioning of these individuals by the MPs on those Committees and then quietly followed the assembled Ofcom party (comprised of Currie, Richards and about four other senior Ofcom flunkies) out of the Committee Room after the meeting only to hear them loudly joke with each other about the Parliamentary "Toothless Tigers" they had just been questioned by then you would know by now the kind of utterly deceitful, unprincipled, careerist, salary grubbing and completely pro telco centric personnel at Ofcom with which you are actually dealing. :o >:( :'(

nicholas43, this is a very good point and one which means that 0870 being reduced to 01/02 rate may never come off (not soon anyway), even if BT and other telephone companies want to do so.

Contrary to what you might have read, the consultation itself isn't about forcing any telco to reduce its rates. It's more about providing conditions where they could do so.

The Competition Appeals Tribunal (CAT) judgement is about how much BT pays the mobile networks for calls from BT to mobiles. BT would like to reduce this and figures where decided, but the mobile networks didn't like them, so went to the CAT. The Judgement is that the way in which Ofcom decided on the figures was wrong.

The same issue surrounds the telephone companies operating the 0870 numbers. The amount BT pays to 0870 telcos is currently regulated and the proposals are to drop this and thus allow this termination payment to be reduced.


I will post a fuller explanation of how it works, the issues and the proposals soon.

To put something concrete on the table, may I offer my draft of a response to the 0870 consultation.

I recognise that some would think any response would be a waste of time, however I would be interested in any comments or suggestions.


Quote:

1: Do you have any comments on the pricing transparency options considered and Ofcom’s proposal to implement Option B? Ofcom itself declares that its stated objectives could only be achieved by implementation of Option A. So far as transparency is concerned, consumers may consult price lists when considering which supplier to use or which package to subscribe to, they would rarely do so when considering whether or not to make a call. This is why the obligation for price declaration falls on providers of “premium rate services”. If transparency of the premium rates levied for calls to all 08xx numbers is an issue (as Ofcom accepts that it is), then users of all such numbers (including 0800 numbers accessible from mobile networks) must also be seen as providers of "premium rate services" and subject to similar (if not identical) regulatory requirements. The true question is however not about what Ofcom’s policy should be, but about its capacity to implement either of the specified options without effective legal challenge. As Ofcom itself now believes that it would not be able to implement either, this whole consultation exercise is effectively meaningless. Paragraph 1.33 states that a measure which would be “effective in promoting price transparency and reducing consumer confusion over the pricing of 0870 calls” is seen to be “a comparatively intrusive regulatory intervention” that conflicts with Ofcom’s (apparently self-imposed) duty to “minimise the burden of regulation”. - This implies that Ofcom must only do that which is ineffective. - Most would believe that Ofcom should only do that which is necessary and likely to be effective. Whilst the consultation is meaningless in itself, it does however raise important questions about the nature and extent of Ofcom's statutory duties and powers. 2-6: Do you have any comments on the "draft notifications"? It is understood that Ofcom does not currently feel able to proceed with this inter-related package of measures because of threat of legal challenge. These should be presented for consultation at some possible future time when two conditions have been met, so that meaningful responses will be possible: Firstly, when Ofcom is able to make proposals unqualified by the need to await the unpredicted outcome of current legal proceedings. Secondly, when Ofcom is able to make some meaningful comment about which CPs have declared an intention to reduce their charges for calling 0870 numbers and which will be likely to take the alternative course of declaring prices. Without a detailed understanding of the relevant regulations, one must express surprise that a requirement to make an adequate declaration of prices is considered to be a "special" measure or a penalty for not following Ofcom's preferred course of action! 7: Do you have any further comments? It is a waste of public time and Ofcom’s resources to engage in a consultation when there is no clear indication of what the outcome is likely to be, nor even if Ofcom would be able to implement what is proposed. The rapid rate of change in the telecomms industry has made the prolonged (and now further delayed) process of addressing the issue of all 08xx numbers completely ineffective. There is much evidence to support claims from some that Ofcom has no true desire to address this matter properly, having sinister secret motives. Whilst others would wish to be reassured that delays are due to incompetence, citizens must be unhappy with either explanation.

These are my views and my words, placed here freely in the public domain. I am not a fan of "form responses" to consultations, prepared and agreed by committees. I would however be happy for anyone who shares my views and would wish to express theirs in similar terms to use any of the above (words, sentences, paragraphs, ideas ...), but without acknowledgement. I believe that views expressed must be truly held by consultation respondents in their own right, even if others may wish to express similar views in similar terms. Perhaps I am being arrogant in assuming that anyone would agree with any of the above!

(All the above is subject to the intervention of moderators.)

SilentCallsVictim wrote on Jun 8^th, 2008 at 3:22am:

The rapid rate of change in the telecomms industry has made the prolonged (and now further delayed) process of addressing the issue of all 08xx numbers completely ineffective. There is much evidence to support claims from some that Ofcom has no true desire to address this matter properly, having sinister secret motives. Whilst others would wish to be reassured that delays are due to incompetence, citizens must be unhappy with either explanation.

SCV,

I am interested to see that you finally appear to be beginning to acknowledge the legitimacy of some of the conclusion that other longstanding members of this forum, in particular myself and dorf, have previously reached over the motivations of the telecoms regulator.

The main problem in my view lies with how Ofcom have originally tried to tackle issue of premium priced calls by doing so only through call price announcements and only for calls to a particular number range (0870) charging a higher price than the minimum allowed to that range.

Had Ofcom instead tried to tackle the issue of NGN pricing quite differently at the outset by rounding up all phone numbers that involve any revenue share at all on to a code that makes this fact clear (either 09 or as a compromise the unused 06 for lower priced NGNs at 10p per minute and below) and then clearly educated the public on the meaning of phone number prefix codes and that only calls to numbers beginning 01,02 or 03 were normal priced landline calls then the issue could have been addressed without falling foul of the Competition Appeals Tribunal.  Especially since the current efforts of the 084/7 industry to make their numbers seems like normal rate phone numbers are actually blatantly anti competitive.

Unfortunately Ofcom instead came up only with the always absurd remedy of intervening on 0870 call prices whilst not intervening on 0844, 0845 and 0871 that raised precisely the same issues of lack of price transparency and hidden revenue share.  This was then always going to leave Ofcom open to claims of illogical, irrational and discriminatory intervention.  Whereas had Ofcom ended the illogical and meaningless separation of NTS and PRS calls in to two different categories and clearly rounded them all up in to one camp where the consumer was paying extra for the call with proper publicity of those number ranges (no need for call price announcements if it was as simple as all numbers beginnin 06 and 09) then the problem would have been satisfactorily addressed.

In part Ofcom's actions reflect incompetence but having dealt with OFTEL and Ofcom over a number of years I think allegations of them in effect cosying up to the telecoms industry and being heavily in the pocket of that industry in fact form a far larger part of the problem.

Despite my mistrust of Ofcom as an organisation I would not advocate that anyone with an interest in the matter does not respond to the consultation.  However based on past experience I would not encourage anyone who does respond to the consultation to expect Ofcom to take any notice at all of any views that they express (or at least not if they are responding as a private individual rather than as a representative of a major commercial entity in the telecoms field).  Nonetheless a response should be made by all private individuals with an interest in the matter to once again put on the record the extent to which Ofcom then takes absolutely no notice of what the public thinks of their proposals.  This may then one day become relevant when Ofcom's activities and utter ineffectiveness as a regulator are investigated by either the Parliamentary Ombudsman and/or the EU Commission.  Unfortunately by then Ofcom's current chief gravy train merchants will have moved on elsewhere with their peerages and knighthood and will no doubt avoiding any form of consequence or sanction for so utterly failing to fulfil the remit they were given by Parliament under the terms of Section 3 (i) of the Communications Act 2003.:o >:( :'(

I just posted the below as a reply in a thread about BBC call charges but I think it is far more appropriately posted here.

It looks like Ofcom have worn us down so far that the main people involved with this site have even lost heart about bothering to respond to Ofcom consultations. :'(

Can we please email all forum members and get something on the front page of the website about these consultations closing on June 16th within 24 hours.

Thank you:-


Quote:

Ouch I see these consultations both end on Monday 16th June.  I thought it would be much later than that.  They normally run consultations for 10 weeks.  Indeed they are supposed to unless they can find a good reason to make them shorter. I haven't seen any front banner ad on this website publicising the consultation or counting down the days to closure or any email from Daniel encouraging us to respond. I know we all feel all consulted out with Ofcom and ICSTIS and that they never ever listen to what we say but it is still important to send something to show the public are discontented and that Ofcom are ignoring them. Can Daniel get something out by email to all forum members by Thursday pointing out the closing date for responding is next Monday?  Also can a banner to an article with links and counting down be added today or tomorrow?

NGMsGhost wrote on Jun 10^th, 2008 at 5:45pm:

I haven't seen any front banner ad on this website publicising the consultation or counting down the days to closure or any email from Daniel encouraging us to respond. I know we all feel all consulted out with Ofcom and ICSTIS and that they never ever listen to what we say but it is still important to send something to show the public are discontented and that Ofcom are ignoring them. Can Daniel get something out by email to all forum members by Thursday pointing out the closing date for responding is next Monday?  Also can a banner to an article with links and counting down be added today or tomorrow?

In the past when this has been done it has linked to some pages on the site giving advice on how to respond. Discussion on these consultations has been small, as you can see from the length of this thread.

A agree with encouraging people to respond as we have done in the past.

NGMsG, It is not I think that "the main people involved with this site have even lost heart about bothering to respond to Ofcom's consultations..." as you suggest. Speaking for myself, I have not lost heart at all, but I do believe that continuing to respond to Ofcom sham "consultations" is playing into their hands, with their time wasting and parrying games.

It is clear by now that Ofcom have no intention whatsoever of paying any attention to the opinions expressed by Citizen Consumers to their "consultation" points. To them it is all a game, a delaying tactic, an excuse for not yet having to do anything objective about the anomalies which they are only too well aware exist.

Nothing whatsoever will be accomplished by responding to any further Ofcom or PhonepayPlus sham "consultations". Recently you more or less indicated that you had now faced the fact that only action via parliament and the EU would ever now force Ofcom to fulfil their primary duty - which is to protect and represent the interests of the Citizen Consumer.

Any effort should be expended in that direction in my opinion; not wasted in responding to any further pointless Ofcom sham "consultations".

dorf wrote on Jun 11^th, 2008 at 12:03am:

It is clear by now that Ofcom have no intention whatsoever of paying any attention to the opinions expressed by Citizen Consumers to their "consultation" points. To them it is all a game, a delaying tactic, an excuse for not yet having to do anything objective about the anomalies which they are only too well aware exist. Nothing whatsoever will be accomplished by responding to any further Ofcom or PhonepayPlus sham "consultations". Recently you more or less indicated that you had now faced the fact that only action via parliament and the EU would ever now force Ofcom to fulfil their primary duty - which is to protect and represent the interests of the Citizen Consumer. Any effort should be expended in that direction in my opinion; not wasted in responding to any further pointless Ofcom sham "consultations".

dorf,

I do not believe any great effort in terms of time or number of words should be invested in responding to these consultations.

However I do think we should respond to point out that all their NTS/PRS consultations are a sham and cannot be taken seriously and that whatever we the public say Ofcom will ignore us.  As they have to publish the responses on their website they won't like having lots of responses saying those kinds of things about Ofcom.

I agree it would be pointless to respond in any great detail to their proposals.  The key point in responding is to point out all the other consultations in which they and ICSTIS have previously ignored the public and that they still fail to achieve even their most basic duties like ensuring that the cost of 0845 and 0870 calls are accurately described on phone bills even though these are governed by their own General Conditions rather by ASA Advertising Rules.

I think it would be a mistake not to respond at all as they will then say everyone must be happy with their proposals.

I agree with your point NGM'sG,

So long as responses are just a statement of position only, and do not enter into any discussion of the pointless issues which Ofcom regurgitate as a smoke screen all over again.

Perhaps something along the lines of:

"There is no point whatever in a Citizen Consumer giving their views again on the issues which you regurgitate, since Ofcom have proven conclusively and continuously their contempt for Citizen Consumers in their "consultations" and that they pay no attention whatever to the views of Citizen Consumers, despite it being Ofcom's principal duty under the Acts to protect the interests of the Citizen Consumer. Indeed it is clear that the principal reason that Ofcom has it's incessant plethora of "consultations" on these issues is to delay and avoid taking the regulatory action which they know they should take under the Acts!

I therefore make no response whatever to your detailed points herein, since I am not prepared to play your games any longer. Citizen Consumers have stated their position over and over again to you already. It is quite clear that you will not take the regulatory action which you are required to take by law, to protect the Citizen Consumer, until you are forced to do so by Parliament or the EU Commission."

I shall submit my response in that form forthwith.

Dorf

dorf wrote on Jun 11^th, 2008 at 11:34am:

I agree with your point NGM'sG,

I believe we have a modestly-sized consensus on this issue. I make essentially the same argument in my draft response, although I offer detail for the benefit of those who may read it when it is published.

Just one point. The term "citizen-consumer" is an Ofcom construction that improperly conflates its two distinct and potentially conflicting duties, as detailed in Section 3 of the Communications Act. Subsections 3 (7-9) highlight the fact that 3 (1) (a and b) are separate.

Ofcom's duty to further the interests of consumers applies to all consumers of telecommunications services. This includes public and private sector organisations who benefit from using revenue sharing numbers and call centres who make Silent Calls. Only those who offer defined "premium rate services" move over to join the telcos in the role of provider rather than consumer, and thereby fall subject to Ofcom's regulatory powers. Ofcom has no specific duty to further the interests of consumers of services provided using revenue sharing numbers, nor any specific powers to use to do so.

Ofcom is responsible for having fudged the nature of its duties, partly because this gives it a get-out when challenged for not discharging them, by protesting that its powers are inadequate. This is one of the many ways in which it fails to discharge its actual statutory duties.

This is not worth a big debate and fall-out, when we are generally agreed. I would however suggest that use of the term "citizen-consumer" actually gives unnecessary comfort to Ofcom.

(If we need to settle differences on this point, this may best be done by PM.)

I've responded as follows:
Quote:

Question 1: Following the Competition Appeals Tribunal's decisions in the dispute between BT and the mobile firms, it appears unlikely that Ofcom can do anything effective to stop the 0870 ripoff. However, only option A would have fulfilled Ofcom's statutory duty to protect consumers.

Quote:

Question 7: Yes. Ofcom should fulfil its statutory duty to impose a rational and transparent link between prefixes and pricing. As more and more consumers have inclusive calls to 01 02 and 03 (either from a landline or a mobile) 0800 is becoming pointless, and should be phased out. 0845 is pointless if BT can hold their current prices for calling it, and should also be phased out. 0870 always was pointless, except as a ripoff, and should be phased out (maybe with exceptions, if there really are still appallingly badly designed burglar alarms and the like which can't be re-programmed.) 0844 is a disgraceful mess, but probably beyond correction. Therefore, organisations using 0844 and 087x should be required to state in all publicity, in letters as big as the number, "Calls cost x pence per minute, plus a connection charge of y pence, from a [BT/talktalk/Virgin/...] landline, and typically z pence per minute from a mobile. Of this, we receive q pence per minute." The reference to BT/talktalk/Virgin should rotate, say, monthly, on a schedule laid down by Ofcom.

nicholas43 wrote on Jun 12^th, 2008 at 12:56pm:

" ... Of this, we receive q pence per minute."

Bravo - this is the key point.

The base charge for calls to a particular network is a matter between the caller and their chosen supplier, not the person they are calling. Unless Ofcom fixed all these prices, there is no way that someone advertising a number may know what they may be when the number is called.

The uplift used to provide income or subsidy to the person called is the key point on which transparency is required in the context of this issue. If they are content for some of this to be retained by their telephone service provider, then that is a matter for them. The value must be expressed inclusive of VAT, as this is part of the cost incurred by the caller.

Transparency of the base prices is surely a matter beyond dispute. If some operators impose additional charges, over their base price, for calling revenue sharing numbers then this too must be declared. The same principle also applies where, e.g. in the case of BT and 0845 currently, there is a discount off the base price at some times.

Transparency and simplicity are sadly often contradictory.

SilentCallsVictim wrote on Jun 12^th, 2008 at 1:22pm:

The base charge for calls to a particular network is a matter between the caller and their chosen supplier, not the person they are calling. Unless Ofcom fixed all these prices, there is no way that someone advertising a number may know what they may be when the number is called.

Assuming they know what their network supplier is charging them to call 084/7 numbers but in many cases (especially Pay As You Go Mobiles with no access to call cost history of any kind and with 084/7 prices still not being given equal prominence on their websites and in their literature) the reality is that they do not.  And now Ofcom has decided that call price pre-announcements are not possible either...................

SilentCallsVictim wrote on Jun 12^th, 2008 at 1:22pm:

nicholas43 wrote on Jun 12th, 2008 at 12:56pm: " ... Of this, we receive q pence per minute." Bravo - this is the key point. The base charge for calls to a particular network is a matter between the caller and their chosen supplier, not the person they are calling. Unless Ofcom fixed all these prices, there is no way that someone advertising a number may know what they may be when the number is called. The uplift used to provide income or subsidy to the person called is the key point on which transparency is required in the context of this issue. If they are content for some of this to be retained by their telephone service provider, then that is a matter for them. The value must be expressed inclusive of VAT, as this is part of the cost incurred by the caller. Transparency of the base prices is surely a matter beyond dispute. If some operators impose additional charges, over their base price, for calling revenue sharing numbers then this too must be declared. The same principle also applies where, e.g. in the case of BT and 0845 currently, there is a discount off the base price at some times. Transparency and simplicity are sadly often contradictory.

I have suggested something similar to this before. My idea doesn't require the amount the SP is paid to be declared, but distinguishes between the "underlying network charge" made by the OCP and the premium, of which the SP takes a cut.

All service providers should say the call is charged at x pence per minute plus a y pence per minute network charge plus connection fee z p.

Thus, y varies between OCPs and makes it far easier for the caller to know how much they are paying. Each OCP says "Network charge for 0844 is 3 pence per minute, network charge for 090 is 10 pence per minute" etc

NGMsGhost wrote on Jun 12^th, 2008 at 1:48pm:

Assuming they know ....

Exactly. The present situation is totally unacceptable.

Perhaps we are getting ahead of ourselves by discussing how much better it should be. Maybe we should deal with just one thing at a time, although then we get into a, perhaps worthless, argument about which is the most important, or most easily correctable, matter.

Dave wrote on Jun 7^th, 2008 at 10:08pm:

I will post a fuller explanation of how it works, the issues and the proposals soon.

To explain how the dispute between the telephone companies has come about and why this is likely to affect changes to 0870, I will first explain what happens when you make a call and how the call charges are split. To recap, the current dispute is between BT and the five main mobile providers (O2, Vodafone, Orange, T-Mobile and 3).

When you make a call from one telephone provider to another, not only must the call be carried from one to the other, but one pays the other, in the same way as you pay your provider when you make (originate) that call.

The telephone company that the caller is with is known as the originating communications provider or OCP. The telephone company that the receiver is with is the terminating communications provider or TCP.

For example, if someone makes a call from a Vodafone mobile to an Orange one, the OCP in this case is Vodafone and the TCP is Orange. If someone on Orange calls someone on Vodafone, then Orange is the OCP and Vodafone the TCP. The same is true of landline providers and any combination when calling from fixed line to mobile and vice versa.

Calls are originated or made from OCPs and terminated with TCPs. The payment an OCP makes to a TCP is known as a termination payment.

The dispute surrounds the amount BT pays the Orange, Vodafone and 3 (the TCPs) for calls made to them from its fixed lines. BT would like to reduce the amount it charges callers and to do this it must reduce the termination payment. These mobile TCPs aren't happy with this.

Different 0870 numbers are provided by different telcos, and they don't accept the new rates BT has proposed it will pay them for calls originated by BT or passed to BT by another OCP for termination on the their networks. For more details, see the Competition Bulletin from Ofcom here.

The Competition Appeals Tribinal's judgement on the dispute between BT and the mobile providers is that Ofcom didn't use a fair method when determining the new rate. We are awaiting the next step and it will not be until this has all been cleared up until the wheels will go into motion to change the call rate of 0870, if ever.

Dave wrote on Jun 13^th, 2008 at 11:37pm:

We are awaiting the next step and it will not be until this has all been cleared up until the wheels will go into motion to change the call rate of 0870, if ever.

And even if 0870 revenue share were ever scrapped all the scammers would by then have moved to 0844, 0845 or 0871..........

The essence of the "proposals" in this consultation are as follows (see page 19):


Quote:

Section 3 Proposed Changes 3.1 As indicated in Section 2, Ofcom has decided to: • repair and extend the linkage between 0870 calls charges and charges for calls to geographic numbers so that calls to 0870 numbers will be charged at the same rate as national calls to geographic numbers from all fixed and mobile phones, including payphones. Where an OCP chooses to charge more for 0870 calls than for a geographic call, they will be required to comply with new strict and precise guidelines setting out how their charges for 0870 calls should be brought to their consumers’ attention; and • remove the regulatory support for revenue sharing from 0870 calls.

The first sentence of the first bullet says that all will be resolved and that calls to 0870 from all (and it does say "all") lines will be charged at geographical rate. But the second sentence contradicts this and says that OCPs may charge more, but must comply with "new strict and precise" guidelines.

The truth of the matter is that call charges should be clear, regardless. Quite why it needs a consulation to determine whether price declaration is in the interests of consumers is another matter. The current regulations were introduced two years ago and require clear pricing information for "NTS Calls" (Number Translation Services) and "PRS" (Premium Rate Services) number ranges.

The proposals to reduce 0870 will result in it being removed from the group of numbers officially classed as NTS Calls. This is despite the fact that technically speaking it will be NTS. This means that the regulations will not then apply and will effectively need to be modified so that they do re-apply.

So they don't seem to be "new" as Ofcom would have use believe. Same goes for them being "strict"; some telcos still are happy to use the terms like "local rate" with respect to 0845.

For those interested in looking into what the proposed changes are, they are summarised below. I must emphasise that you don't need to understand these to respond and therefore you may like to skip this post.


1. A Revised Designation for 0870 Calls in the Plan (paras 3.3 to 3.10)

The current National Telephone Numbering Plan (NTNP) says that 0870 numbers are charged "BT's Standard National Call Retail Price for BT Customers". The "standard" rate is effectively the "pre-competition" rate which applied before the free competition we see today pushed down the price of national calls.

The suggested replacement text says that 0870 will be the same as a geographical call, "except where the extent of charges have been published in accordance with General Condition 14.2". See below for more on what General Condition 14.2 is about.


2. A Modification to the Application Form for Special Services Numbers (paras 3.11 and 3.12)

This is of little interest to general consumers and really only affects telephone companies who are likely to apply for telephone numbers.


3. A Modification to General Condition 17 (paras 3.13 to 3.15)

This is so that the proposed modification of the designation of 0870 in the NTNP referred to above in point 1 applies to all telephone companies. General Condition 17.12 already covers 03 numbers; meaning that its designation in the NTNP applies to all telephone providers.


4. A Modification to the SMP Condition in the Market for Call Origination on Fixed Public Narrowband networks (paras 3.16 to 3.20)

The NTS Condition controls how much BT can retain and thus how much of the call charges it must pass on to a TCP when calls are originated from its lines or another OCP and passed to BT for termination. Ofcom proposes to remove 0870 from the scope of the NTS Condition by removing it from the definition of "NTS Calls".


5. A Modification to General Condition 14

This relates to the "Code of Practice" with respect to pricing informing obligations for NTS Calls. As it is envisaged that 0870 will be removed from this group (see point 4 above), this part of the proposals simply re-applies these regulations so that they apply to "NTS and 0870" rather than just "NTS". As I said above, these requirements for pricing information cannot be regarded as "new" (in Ofcom's words).

Having given up on sham consultations by OFCOM and Westminster, i think the only way forward is the EU and I have contacted Commissioner Redings team. They are non committal other than confirming we can make representations about big competition issues. I think defective domestic regulation / possible collusion is a big competition issue. Anyway its the only show in town.

I am awaiting FOIA replies from OFCOM re uptake of 0844 etc nos and possible consultation on citizen/consumer interests in relation to OFCOMs duties.
May I pick the collective brains ?
What is the detail behind 'citizens/consumers' referred to by SilentCallsVictim on 11 June?
Has anyone asked directly about OFCOMs relationship with government, the industry and the public? (when I first contacted - I presume- the old OFTEL team just after the change to OFCOM they were open and gung-ho about making 0870 nos also offer a geo number. The subsequent change in policy and culture was marked.)    
How did the EU force EU Roaming charges down?
How does Europe deal with 0844/0870/0871 etc (or equivalent) nos?
How strong is the evidence of collusion/bias?
How reliant on is this website on companies showing geo numbers to call from abroad? ( Last year the Guardian reported Cmr Reding as wanting 0870 etc nos diallable across the EU and I think I have recently seen an 0844 no as an international number?)
Anything else?

Thanks all DF
 

Dick_Fowler wrote on Jun 14^th, 2008 at 7:29am:

May I pick the collective brains ? What is the detail behind 'citizens/consumers' referred to by SilentCallsVictim on 11 June?

Some useful reference is found in the Consultation on "Ofcom's Consumer Policy" and the published response that is referred to and summarised here. Although relevant to the general citizen/consumer point, the response reflected concern about a quite different issue, which is not relevant here.

(Detailed forum discussion of this and other valid points may warrant separate threads).

Can I join others in urging members to submit a response to the 0870 consultation, stressing its pointlessness, whilst making whatever other loosely relevant points they think appropriate. Responses are published and can therefore be valuable as part of the public record in future, even if they do not directly influence policy decisions at the time.

Ofcom admits that CPs and SPs still mislead on 0870 being "national rate":


Quote:

5.12 Despite these differences providers of services using 0870 numbers commonly advertise calls to their services as national rate. TCPs selling 0870 numbers also sell them on the basis that services can be charged for at the national rate. This practice is entirely misleading but continues despite efforts by Ofcom, the Advertising Standards Authority and Trading Standards authorities to prevent it.

What is Ofcom doing about this?

Dave wrote on Jun 14^th, 2008 at 6:26pm:

Ofcom admits that CPs and SPs still mislead on 0870 being "national rate": What is Ofcom doing about this?

With SPs all that Ofcom can do is brief the ASA, Trading Standards and the NCC so that they can advise consumers and take action swiftly and effectively wherever necessary.

With CPs, Ofcom should conduct an own-initiative investigation into the breaches that it is aware of and take action itself to enforce the regulation that is being breached. If there is no such regulation, then it must introduce one, as it clearly believes this to be necessary.

The quoted statement is in justification of the action proposed in the consultation.
As this cannot now be taken - the answer to the question is "nothing at all".

N.B. THE CONSULTATION CLOSES at 5.00 PM on MONDAY 16 JUNE

Well I sadly caused myself quite needless pain and many wasted hours by responding to both these consultations.  Unfortunately I found I could it not keep it down to just a few paragraphs and felt it necessary to spend considerable time slicing through the many elaborate lies used by Ofcom in these documents to justify their and PhonePayPlus's latest plans.

Suffice it to say that they have been left in no doubt that they are not fulfilling their principal duty under Section 3(i) of the Communications Act 2003.

To paraphrase my several pages of comments as follows:-

(a) 0870 changes are a complete joke that totally betray all of Ofcom's previous promises and will have no effect because almost everyone on 0870 will move to 0844 or 0871 in any case.  This will then leave 0870 as a small rump operation for the odd technologically backward burglar alarm dialler or idiots who were persuaded that 0870 gave them a jazzy national image even though they get no revenue share.  And even though there will be no revenue share OCPs (telcos especially mobile cos) will be allowed to charge more than 01/02 ratem, even though they now have no reason to do so.

(b) 0871 proposals are a complete disgusting joke that are all about claiming 0871 is subject to premium rate regulation when there is no ban on call queuing and no requirement to play a message with the cost per minute before the call is connected (traditional premium rate control).  As a result most 0870 numbers can be expected to move to 0871 (for the more greedy companies who think they can't make enough from 0844) making Ofcom's claims to have slain the 0870 dragon even more of a joke than they already are given that your telco can still charge you what they like for 0870 as long as they send you a leaflet with their higher charge for 0870 than 01/02 printed somewhere in it.  Also most consumers won't realise 0871 is premium rate anyway as PhonePayPlus does not require traditional premium rate warnings to be given and 0871 numbers will inevitably be misperceived as National Rate due to the longstanding association of 087 with the National Rate lie.

Perhaps I should have sent just the above response rather than the much longer response I actually sent slating in detail Ofcom cosying up to the telcos and failing to fulfil its principal duty. >:(

I can honestly say I've not submitted a response.

This may anger a few forum members but I've lost all hope with Ofcom as they are just useless and I wonder just how independent they actually are, and of their abilities to be a regulator when this consultation made me aware that not only did ofcom ignore responses from their previous consultations on 0870 but also that they did not seem to be able to think that automated things like burglar alarms, and faxes may not work due to the initial proposed pre-announcement.

This consultation proposes to ensure that us consumers are aware of call charges to NGNs but this is already covered by GC14.x (not sure which one) but even with this GC, most communication providers still go out their way to hide the cost of calling a NGN.

I believe Ofcom should be investigated for its failings.

(moan  >:( over - lol)

bbb_uk wrote on Jun 16^th, 2008 at 5:36pm:

I believe Ofcom should be investigated for its failings.

Here, here.

However unfortunately if the last performance of the questioning of Messrs Currie and Richards by the Parliamentary Culture + Business and Enterprise Select Committees a few weeks ago is anything to go by there is precious little hope of that.

A total and utter farce in which half the members of the two committees were absent and most of those there were from the regions (Scotland, Wales and Northern Ireland) and blathered on about when they could get broadband that was as fast and as cheap as in a large English town centre or if S4C could have money to make a few more programs in Welsh.  Not one of them held Ofcom to account on their postponement of 0870 call price reductions or Ofcom deliberately misleading the press about what it was up to on 0870.  This was in spite of detailed briefing note by myself sent to all the committee's members.

Then to make matters worse as the Ofcom party walked away from the Committee Room down the corridor with me closely in toe (but unbeknownst to them) they were heard laughing with each other about the miserable performance of the MPs, after which one of them loudly exclaimed about Parliament's "Toothless Tigers".  This shows the totally abusive mindset towards Parliamentary accountability of those at the top of Ofcom.

Our only hope would be a complaint through someone's MP that Ofcom has failed to satisfactorily investigate a complaint about its own regulatory failings on 084/7 and that thus that we wished to have the matter investigated by the Parliamentary & Health Service Ombudsman (who you can only approaching by going via your MP).  Or alternatively persuading Madame Viviane Reding and her colleagues at the EU to investigate Ofcom's general failure to abide by EU competition law and price price disclosure and misleading advertising laws.  Ms Reding is already on record as accusing Ofcom of cosying up to the telcos.

I understand why you could not muster the energy to reply to the consultations bbb_uk but I still think it is a pity you did not and that the forum management also did not even promote responding to these consultations by the usual means (a countdown message on the home page and emails to all forum members) as unfortunately Ofcom will simply take this as a sign that we have given up and that they can now do exactly as they please. :o >:( :'(

NGMsGhost wrote on Jun 16^th, 2008 at 6:39pm:

bbb_uk wrote on Jun 16th, 2008 at 5:36pm: I believe Ofcom should be investigated for its failings. Here, here.

Here, here, here.

My efforts to get something done about the failure over Silent Calls confirm the fact that this is unlikely.

The failure to get Ofcom's duties covered by "Consumer Voice" is a further indication that all politicians are hung up on the idea that competitive markets are the answer to everything. The relative success of competition in Telecomms, as against other privatised industries, suggests that Ofcom is a success when compared with the other "Of"s.

There will also be many who will cheer at the fact that BT was unable to use its SMP against the interests of its competitors on this issue.

Perhaps someone would like to start a thread on serious proposals for how Ofcom could be reformed, replaced, abolished or perhaps itself made subject to competition.

SilentCallsVictim wrote on Jun 16^th, 2008 at 8:29pm:

Perhaps someone would like to start a thread on serious proposals for how Ofcom could be reformed, replaced, abolished or perhaps itself made subject to competition.

I could only imagine it being swallowed up by a Pan European telecoms body as being a possible solution.

Unfortunately Ofcom's overpaid staff seem to have been inculcated from the outset by Stephen Carter and his henchmen with a culture of almost supreme contempt for the UK citizen and the UK consumer where Carter, Currie, Richards and co were/are clearly working to a master plan that is supported by the powers be in New Labour and they are unwilling to let any form of negative consumer feedback change their original planned course of action.

The scale of their utter contempt for this saynoto0870 group and consumers in general is demonstrated by the fact that they have never decided to try and take any members of this group permanently in to their confidence by trying to explain to us privately at briefing meetings why they cannot do all we would like them to.  Yet they meet monthly with the telecoms industry at their NTS Focus Group but their only interaction with the consumer is through carefully orchestrated focus groups who are asked carefully spun questions designed to produce only the answers that Ofcom wants to hear.

The content of some of Ofcom's just closed consultation about 0871 PRS regulation is very distressing as much of it is full of slogans claiming that 0871 numbers provide an extensive range of value added consumer services that would not otherwise exist.  Most of its content appears to have been written by some sort of focus group of NTS call centre PR people and the views of the 600+ individuals who responded to the PhonePayPlus (ICSTIS) consultation document have been completely and utterly ignored by Ofcom.  They are not even referred to in the document.   It is hard to feel anything other than that those who work at Ofcom are only interested in promotion and pensions and that anyone who got a job there who was imbued with one iota of conscience that made them stick up for the rights of uk citizens and uk consumers would probably be ushered out of the front door within a matter of days of starting work. :o >:(

EU.

Sorry folks. I jumped the gun. It was not my intention to deter those who wished to reply to the consultation, so I kept quiet for a few days.

My aim is to open up a new (?) approach via the EU. No matter what you think of the EU, it is the only way I can see to outrank this apparent odious alliance of government and regulator. Has anyone actually tried the Parliamentary Ombudsman which has been discussed on this forum?
I
very much need the forums expert help for this. I studied Silent Call Victims material re Citizen/Consumers. How do OFCOM do it?  A lot of words to disguise a subtle shifting away from the key issue. Whatever happened to 'best possible service at lowest possible price.' which is the professional buyers mantra.

Should I now shift this to a new thread?

NGMsGhost wrote on Jun 16^th, 2008 at 6:39pm:

...Ofcom will simply take this as a sign that we have given up and that they can now do exactly as they please. :o >:( :'(

It seems to me that they do as they please (or shall I say as the teleco's want) anyhow.

I firmly believe that if it wasnt for the fact that they have to have consultations then there wouldnt be any where they would be frightened of responses from us consumers!

Dick_Fowler wrote on Jun 17^th, 2008 at 7:09am:

EU. Sorry folks. I jumped the gun. It was not my intention to deter those who wished to reply to the consultation, so I kept quiet for a few days. My aim is to open up a new (?) approach via the EU. No matter what you think of the EU, it is the only way I can see to outrank this apparent odious alliance of government and regulator. Has anyone actually tried the Parliamentary Ombudsman which has been discussed on this forum? I very much need the forums expert help for this. I studied Silent Call Victims material re Citizen/Consumers. How do OFCOM do it?  A lot of words to disguise a subtle shifting away from the key issue. Whatever happened to 'best possible service at lowest possible price.' which is the professional buyers mantra. Should I now shift this to a new thread?

I believe this is our only way.

There is already a thread on this here.

Dick_Fowler wrote on Jun 17^th, 2008 at 7:09am:

My aim is to open up a new (?) approach via the EU. No matter what you think of the EU, it is the only way I can see to outrank this apparent odious alliance of government and regulator. Has anyone actually tried the Parliamentary Ombudsman which has been discussed on this forum? I very much need the forums expert help for this. I studied Silent Call Victims material re Citizen/Consumers. How do OFCOM do it?  A lot of words to disguise a subtle shifting away from the key issue. Whatever happened to 'best possible service at lowest possible price.' which is the professional buyers mantra. Should I now shift this to a new thread?

I always meant to take matters up via the Parliamentary & Health Service Ombudsman but never quite got round to it.  The difficult thing with Ofcom is that since one is not a customer or patient it is hard to ever reach deadlock with them.  Their most senior staff generally avoid all attempts to engage in correspondence so it is hard to reach deadlock with them.  Their main technique is to suggest that they Ofcom are not responsible for anything and that your resolution lies with your telecoms company, Otelo (telecoms ombusman) or anyone but them in terms of making a complaint.

I was a little pessimistic about the Parliamentary and Health Service Ombudsman's likely attitude on the matter given that she still uses an 0845 telephone number for contact in spite of the recent blandishments of Sir David Varney's report and the Central Office of Information's Better Practice Guide For Government Contact Centres plus Ofcom's launch last Autumn of 03 numbers.

See www.ombudsman.org.uk/contact_us/index.html

It usually takes a lot of energy to follow through one of these complaints with an ombudsman and the process usually goes on for many months or years.  I also have some personal issues about having to get my MP involved on this as I know him for other reasons and he would probably see this as a petty matter as he has no record of ever speaking up against the misuse of 084 and 087 numbers.

People should consider approaching both their MP and their MEPs over this matter.  MEPs are often rarely approached by constituents (so are not overwhelmed with work) and you have a choice of between around 7 and 10 (depending which area you are in and your own party political affiliations) so you might be able to find one covering your constituency who is hot on competition matters.  An MP should be able to introduce your complaint to the Ombudsman and an MEP should be able to escalate matters within the EU Commission if they see your complaint as legitimate.

One of the most interesting points is that many Labour backbench MPs are now very exercised indeed on this matter over things like the DWP's Jobcentre Plus service using 0845 numbers but still nothing is done about it.  It still seems more important to the new Labour supremos not to upset their commercial allies and benefactors like Sky and Capita. :o >:( :'(

Updated responses at http://www.ofcom.org.uk/consult/condocs/0870calls/responses/

The response http://www.ofcom.org.uk/consult/condocs/0870calls/responses/ShersbyMrJ.pdf has been "scissored" by Ofcom.

idb wrote on Jun 25^th, 2008 at 12:44pm:

Updated responses at http://www.ofcom.org.uk/consult/condocs/0870calls/responses/

Intersting bunch. All informed respondents (no disrespect intended to non-experts) are critical in one way or another.

BT appears to be restating its desire to drop its rates to match those for geo numbers and also expresses a desire to do the same with 0845.
The UKCTA expresses the views of BT’s competitors who clearly show their intention not to take this option as they only quibble over how their premium prices will be declared.


idb wrote on Jun 25^th, 2008 at 12:44pm:

The response http://www.ofcom.org.uk/consult/condocs/0870calls/responses/ShersbyMrJ.pdf has been "scissored" by Ofcom.

Could we open a competition to guess the redacted words or phrases?
I would offer “larcenous” and “intending to profit from the confirmed levels of consumer ignorance that Ofcom so helpfully brings to their attention”.

If you dial 141 in front of these non geo numbers, how is it possible for the 'receiver' able to charge you for the call. I am probably a bit naive here and I am sure SCV will have an answer for me!!!!!!!!!!!

sherbert wrote on Jun 25^th, 2008 at 2:23pm:

If you dial 141 in front of these non geo numbers, how is it possible for the 'receiver' able to charge you for the call. I am probably a bit naive here and I am sure SCV will have an answer for me!!!!!!!!!!!

I am sure that many others could have explained that it is your telephone company that charges you a premium for calling "revenue sharing numbers. It then shares this revenue with the receiver's telephone company through the higher "termination rates" referred to in the consultation. This extra money is either used to provide discounted services to the receiver or handed over as cash.

Thanks for reminding us that many who follow the forum are not fully "in the know". It is a sign of intelligence, not naivety, to have the courage to ask what some may see as a stupid question.

I thought there had to be a simple answer and I really appreciate your reply to my question.

Many thanks.

Please could one of you experts fill in some big gaps in my understanding too?

Is it true that
(a) Number Translation is a service that honest companies can reasonably want, but there was and is no technical reason for fronting it by special numbers? They could (maybe actually can?) get it fronted by an 01 or 02 number, but obviously they would then have to pay the market price for whatever NT they require -  as they will on the new 03 numbers?
(b) the historic 0345 was well-intentioned, in the days when people paid more for non-local calls? (Companies using it had to pay to receive calls, didn't they?)
(c) Once 0345 morphed to 0845, 0845 and 0870 were sold as numbers companies could rely on keeping, while Oftel/Ofcom fooled around changing 01 to 071 to 020 7 (etc etc) By that time, there was such a huge profit margin in the retail price of landline to landline calls, that Telcos were able to sell 0870, and latterly also 0845, numbers to large users with cutprice NT technology, or cash rebates, or both.
(d) Ofcom failed to spot, or deliberately overlooked, that allowing revenue sharing on 0870 and 0845 would fossilize their high prices. Meanwhile, the market price of call from a landline to an honest 01 or 02 number has dropped to 5 pence (most of which goes on logging the call, sharing the pitiful revenue, and putting your itemised bill on line?

Nicholas

SilentCallsVictim wrote on Jun 25^th, 2008 at 2:14pm:

idb wrote on Jun 25th, 2008 at 12:44pm: The response http://www.ofcom.org.uk/consult/condocs/0870calls/responses/ShersbyMrJ.pdf has been "scissored" by Ofcom. Could we open a competition to guess the redacted words or phrases? I would offer “larcenous” and “intending to profit from the confirmed levels of consumer ignorance that Ofcom so helpfully brings to their attention”.

On the plus side it would appear that this consultee's response has actually had the rare privilege of being read with a fine toothcomb by senior Ofcom staff (not to mention their senior lawyers) rather than simply ignored (the normal fate of consultation responses provided to Ofcom).

I think one should regard being subject to Redaction by Ofcom as a badge of honour.  It does show what a sad load of paranoid and wholly anally retentive people they clearly all are though.  They clearly believe in the same tactics as Robert Mugabe or Saddam Hussein for dealing with views from the opposition that they do not care for the sound of.  My previous understanding of Redaction by Ofcom is that the content of consultations or other documents was only Redacted at the request of the owner of that document when it fell under the heading of commercial confidentiality etc.

When I have a moment I will dig out the scissored quotes and post them for others to judge whether there was any possible justification for their redactions (use of the fashioned censor's blue pencil in layman's speak).

nicholas43 wrote on Jun 25^th, 2008 at 4:10pm:

Is it true that (a) Number Translation is a service that honest companies can reasonably want, but there was and is no technical reason for fronting it by special numbers? They could (maybe actually can?) get it fronted by an 01 or 02 number, but obviously they would then have to pay the market price for whatever NT they require -  as they will on the new 03 numbers?

Yes it is true all the same facilities can be provided on 01/02.  The Foreign & Commonwealth Office has an 020 based phone system with all the features you suggest on a geographic phone number or numbers.


Quote:

(b) the historic 0345 was well-intentioned, in the days when people paid more for non-local calls? (Companies using it had to pay to receive calls, didn't they?) (c) Once 0345 morphed to 0845, 0845 and 0870 were sold as numbers companies could rely on keeping, while Oftel/Ofcom fooled around changing 01 to 071 to 020 7 (etc etc) By that time, there was such a huge profit margin in the retail price of landline to landline calls, that Telcos were able to sell 0870, and latterly also 0845, numbers to large users with cutprice NT technology, or cash rebates, or both.

I think OFTEL allowed the whole system to come in to being always knowing that it was a wonderful opportunity to separate retail phone call pricing from business phone call pricing and protect phone company margins by cutting headline retail call prices while allowing calls to businesses to become ever more expensive protecting telco revenues.  I campaigned against 0990/0870 and 0845/0345 as long ago as 1998 and it was clear even that they cost me more to call than other numbers and that OFTEL was fully in bed with the telecoms industry to orchestrate this scam even at that stage.  The numbers were marketed to the Police etc by the telecoms companies knowing full well it was a way to earn hidden revenue share on the numbers.


Quote:

(d) Ofcom failed to spot, or deliberately overlooked, that allowing revenue sharing on 0870 and 0845 would fossilize their high prices. Meanwhile, the market price of call from a landline to an honest 01 or 02 number has dropped to 5 pence (most of which goes on logging the call, sharing the pitiful revenue, and putting your itemised bill on line?

By the time Ofcom came in to existence the problems with 084/7 ripoffs were blatant and widespread and should have been dealt with by their predecessors OFTEL.  Ofcom has persistently failed to act against these scam numbers under pressure from powerful friends of New Labour like Sky and Capita that they do not wish to see profitable 084/7 revenue share scamming brought to an end.  Ofcom consut, consult and consult and the end result is no action and the consumer still being blatantly ripped off and subjected to misleading price indications.  084/7 numbers even continue to be misdescribed as Lo-Call/Local Call and National Rate on phone bills, even though Ofcom's General Conditions govern what must be shown in phone bills. :o >:(

http://www.guardian.co.uk/business/2008/jun/27/telecoms.regulators

This article in today's Guardian suggests that the dispute over termination rates on calls to mobiles may suffer from a further intervention. It also suggests that no resolution is expected until "the Autumn". Regardless of what may happen from the EU, the latter comment shows that Ofcom's proposed "Changes to 0870" are dead for a long time to come.

[edit]Further investigation shows that there are many other articles covering this announcement and that there is a EU consultation on regulation of termination rates in general, not just those from landlines to mobiles. Members may be interested to read this. (I have not done so yet.)

One must note that this raises significant issues for the UK telecomms market in general as much of what we see is based on cross-subsidy, rather than cost-based pricing. Free mobile handsets are the most obvious example, but there is also the rates charged by BT for calling 0845 numbers.

(Perhaps discussion in this thread should be restricted to implications for the Ofcom proposals put out to consultation.)[/edit][timestamp=1214553206]

[edit]Yet further research finds the press release and Q&A issued by the EU - happy reading!![/edit][timestamp=1214555173]

I see that the top man at Ofcom is going next year

sherbert wrote on Jun 27^th, 2008 at 8:49am:

I see that the top man at Ofcom is going next year

No suggestion of that on a Google News search for "Ed Richards" and no admission from Ofcom itself to that effect in any of their Update emails.

What exactly are you basing your comments on?

NGMsGhost wrote on Jun 27^th, 2008 at 6:08pm:

What exactly are you basing your comments on?

David (Lord) Currie is stepping down as Chairman next Easter - http://www.ofcom.org.uk/media/news/2008/06/nr_20080625

SilentCallsVictim wrote on Jun 27^th, 2008 at 7:07pm:

David (Lord) Currie is stepping down as Chairman next Easter - http://www.ofcom.org.uk/media/news/2008/06/nr_20080625

I wonder what useless QUANGO he is about to head up next! ::)

More of the same....

http://www.guardian.co.uk/media/2008/jun/25/ofcom.mediabusiness?gusrc=rss&feed=media

To my shame I have to admit that I have neglected this website for some time with the result that I was unaware of yet another "consultation".  

I do agree that it is important that Ofcom gets responses, even though we know they are ignored.  

Would it be possible to notify members of consultations so that the less active amongst us do not miss the opportunity?

Thank you.

Fabian Olins

Fabian wrote on Jun 28^th, 2008 at 8:19pm:

To my shame I have to admit that I have neglected this website for some time with the result that I was unaware of yet another "consultation".   I do agree that it is important that Ofcom gets responses, even though we know they are ignored.   Would it be possible to notify members of consultations so that the less active amongst us do not miss the opportunity? Thank you.

Fabian,

I did indeed suggest this to the site owner and forum administrators a few days before the consultation closed but sadly they refused to play ball.

I wonder how many people who would have otherwise responded to this consultation have not done so because they did not know about it. :-/

Needless to say Ofcom did not advise anyone who had responded to previous 084/7 consultations about it. :o >:( :'(

Fabian wrote on Jun 28^th, 2008 at 8:19pm:

Would it be possible to notify members of consultations so that the less active amongst us do not miss the opportunity?

When the consultation was published that was the intention, but it never happened. There are 36 responses and I think it's fair to say that there would have been more had this been done.

It is interesting to see what the industry thinks of OFCOM when reading some of their replies. It makes us look quite timid. And we have issues in common. Flextel's response was quite interesting particularly the judgement on objectives - fail, fail, fail, fail....

Dave wrote on Jul 2^nd, 2008 at 12:05am:

When the consultation was published that was the intention, but it never happened. There are 36 responses and I think it's fair to say that there would have been more had this been done.

This was even though I reminded the forum moderators that the deadline was coming up several days before the consultation closed.

At the end of the day it will just become part of the pile of consultations Ofcom have ignored on 084/7.  I think the only difference here is that in this consultation most respondees felt more justified in making it clear that they are no longer prepared to play ball with Ofcom because it is totally incompetent and incoherent in its approach to this matter.

Isn't this one of the most important threads on the board - nothing updated since 2nd July ?

What is the latest on this consultation... are we ever going to see an end to 0870 revenue sharing or not ?  And when do you think this will be ?

If the Ofcom proposals were serious and likely to be effective, this would indeed be one of the most important threads.

There are doubts about whether Ofcom was ever serious in making its proposals, however nothing will happen now for some considerable time. The reasons are rather complex.

Ofcom is awaiting the outcome of a dispute before the Competition Appeals Tribunal about termination rates for calls to mobile networks from BT lines. The basis it used when proposing a method of settling this dispute has been challenged and the Tribunal has accepted this argument and will itself be proposing an alternative method of determining what is reasonable.

The same basis was used by Ofcom to propose a settlement of a dispute about termination rates for 0870 calls from BT lines to other networks, in the event that the Ofcom proposals for 0870 came into effect. If it attempted to enforce this resolution Ofcom would anticipate a similar challenge through the CAT to be upheld. Ofcom is therefore waiting to see what happens to the other dispute before deciding how to revise its resolution of the 0870 termination rates dispute.

Depending on what comes back from the CAT, BT will either be able to comply with Ofcom's preferred option of reducing the charges for calling 0870 numbers, or will have to take the alternative of providing announcements of higher than normal charges. All other providers have indicated that they will take this less-preferred option. If no-one is going to drop their charges then the whole exercise is a complete waste of time.

Please forgive the complexity of this explanation, it is the best I can do. There are references and links to the relevant matters in earlier postings in this thread.

As things stand, we are awaiting developments in the CAT case before anything more will happen.

Thanks CSV - so we're basically saying that businesses can continue to use 0870 numbers and can continue to receive revenue share on calls for the foreseeable future... and (the poor old) callers will just continue to pay inflated 'national' rate charges for 0870 calls @ around 8ppm until something changes / if ever.

Why doesn't Ofcom come out and make a statement to this effect / clarify matters ?  And at least give some sort of guidline on when / if ever they will be able to push forward with this or stick the whole thing in the bin ?

lucasmcp wrote on Jul 24^th, 2008 at 6:31pm:

Why doesn't Ofcom come out and make a statement to this effect / clarify matters ?  And at least give some sort of guidline on when / if ever they will be able to push forward with this or stick the whole thing in the bin ?

The summary of my lengthy explanation is spot on.

In answer to the question, let us assume for the moment that Ofcom had the best of intentions but made a complete mess of it. Would you step forward to make a statement that you had b****ed it up and had no idea what you were going to do next? The official answer would be that the outcome of the CAT is awaited - this was referred to in the consultation.

I just want to let everyone know about a good idea I had.

I have made myself an 0870 number that is redirected to my home number and everytime a company asks for me for my home number to be able to contact me I give them my 0870 number.

MEAUSURE FOR MEASURE, IF WE WOULD ALL START DOING THIS THEY WILL VERY QUICKLY START GETTING THE MESSAGE, THAT CALLING 0870 HURTS.

Ofcom Update: Update on Ofcom review of 087 numbers

On 2 May 2008, Ofcom published two consultations as part of its ongoing review of 087 numbers. This notification gives an update on the proposed timing of any changes to the rules on 087 numbers.

0870

In May, Ofcom consulted on proposals on charges for calls to 0870 numbers. These included the proposal that all calls to 0870 numbers should cost no more than calls to geographic numbers (01 or 02 numbers) unless communications providers comply with rules on publicising higher prices.  At the time, Ofcom aimed to announce its conclusions on this by autumn 2008.

However, Ofcom’s work on this consultation needs to take place alongside an ongoing dispute on wholesale termination rates, the rates that operators charge each other to end 0870 calls on each others’ networks. Work on this had been suspended pending the recent judgement of the Competition Appeals Tribunal on mobile termination rate disputes which was published recently, and as a result this work has now restarted.

Ofcom continues to assess the proposals in its May 2008 consultation and the responses to that document in light of these developments. Ofcom aims to publish a further statement on implementing any changes to 0870 policy by the end of the year.  

087 numbers

Ofcom aims to publish a statement on its proposal to bring the most expensive 087 numbers (including 0871, 0872 and 0873 numbers) within the remit of PhonepayPlus, in the autumn.

idb wrote on Oct 6^th, 2008 at 11:22am:

Ofcom Update: Update on Ofcom review of 087 numbers

A review of the situation surrounding this email update (I have not yet found any published statement on the Ofcom website), leads me to the following conclusions.

Ofcom will now be resuming its efforts to resolve the dispute over the termination rates to be paid by BT in the event that revenue sharing is removed from 0870. This open dispute is covered by the bulletin published here, although at the time of writing there is no update since 21 December 2007.

There is no reason to suspect that Ofcom's view has changed in any way since the proposals that were originally due to come into effect in February 2008. OCPs other than BT retain their intention not to reduce the cost of calling 0870 numbers and BT is likely to join them should it not be possible to reduce the termination rates paid to others to the levels it has sought.

Nothing has been done to resolve the problems with faxes and alarm systems encountering caller announcements, which caused progress to be suspended last Autumn.

The CAT judgement on mobile termination rates did not even provide Ofcom with a sure and guaranteed method that would enable an unchallengeable resolution of the 0870 dispute. There can therefore be no assurance that the current efforts on this will be successful. Even if that were to be achieved, we will come back to the issue of the alarms.

My prediction is that the further statement, which Ofcom "aims" to make before the end of year, will not reflect any further progress than has been seen for the last 12 months.

I've been having a think what can be done about automated systems such as alarms. This is what I came up with.

If operators charge the same for 0870 as for 01, the calls work as normal. If, however, they charge a premium, they have to play a pre-call announcement of the cost, which mustn't be charged for. The announcement should also apply to 084 numbers.

There would be a new prefix that suppresses call announcements, just as 141 stops caller ID. Providers must also provide a free service in which they will suppress all announcements if, and only if, the customer requests it, again just as there is for caller ID. If the customer has an alarm that starts to play up, they make a call to the phone provider and ask to have the announcement removed on that line. Most people won't need this, so hopefully the fact that the vast majority of consumers hear messages saying "you are being ripped off" whenever they call an NGM will be a big deterrent for companies trying to use those numbers.

I've been reading all these threads since they started on 0870 but hadn't replied, but I doubt there are really any technological barriers to burglar alarms or any other of the automated equipment, but are the dying efforts of the companies to use any possible reason to keep the status quo.

However, even if 0870 was banned as originally intended but 0845 and 0844 etc remained firms would simply change the numbers and keep fleecing the public and this site would continue as before with alternative geographical numbers. Unless the government decide revenue sharing is immoral and should be discontinued not a word of this story is relevant as nothing will change.

David_H wrote on Dec 6^th, 2008 at 4:25pm:

However, even if 0870 was banned as originally intended but 0845 and 0844 etc remained firms would simply change the numbers and keep fleecing the public and this site would continue as before with alternative geographical numbers. Unless the government decide revenue sharing is immoral and should be discontinued not a word of this story is relevant as nothing will change.

In fact, this has already happened, in anticipation of a ban on revenue sharing on 0870. Many organisations have switched either to 0844 or 0871, both of which are more expensive in many cases.

What many of the contributors here would like to see is a ban on revenue sharing on any 08 numbers. All revenue sharing should be done via 09 premium rate numbers, as that's exactly what such services are, with the full regulation that's applied to premium rate numbers, including a ban on queueing. Companies might think twice about using 09 numbers, which are more recognisable to customers as rip-off numbers, which would give the company a bad image (in the way that 08 numbers do to people here and others in the know!)