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https://www.saynoto0870.com/cgi-bin/forum/YaBB.cgi Main Forum >> Geographical Numbers Chat >> Ofcom consultation - Review of non-geo calls 2010 https://www.saynoto0870.com/cgi-bin/forum/YaBB.cgi?num=1272746772 Message started by idb on May 1^st, 2010 at 9:46pm

Title: Ofcom consultation - Review of non-geo calls 2010
Post by idb on May 1^st, 2010 at 9:46pm

<<
Ofcom today published a call for inputs which seeks initial stakeholder views on its review of non-geographic phone numbers (03, 070, 08, 09 and 118).

The document can be found here: http://www.ofcom.org.uk/consult/condocs/ngnservices/
>>

1.1 We are reviewing the rules governing non-geographic calls services delivered to consumers using telephone numbers beginning with 03, 070, 08, 09 and 118.

1.2 Under the Communications Act, Ofcom creates and defines these number ranges through our responsibility for the maintenance and development of the National Telephone Numbering Plan and responsibilities with respect to telecommunication systems regulations and dispute resolution.

1.3 Using these telephone numbers, a wide range of services are offered to callers (consumers) and to public and private organisations who receive calls. Delivering these services involves a diverse set of participants , joined in complex commercial relationships that have been shaped by, amongst other things, regulation.

1.4 We want to consider whether and if so how regulation might need to be adapted or reduced, in the interests of consumers. We want any reform to enhance (or at least preserve) the features consumers value, and encourage new services for the benefit of consumers.

1.5 This 'Call for Inputs' asks for views, from all interested parties including consumers, about the main issues relating to non-geographic numbers before developing our detailed options and proposals. The responses we receive will help us identify the issues and frame our thinking and approach to addressing them. We, therefore, urge all respondents to be as full and frank as possible in responding to this call for inputs.

1.6 As well as calling for inputs, we are reviewing existing approaches (our own and others) and surveying consumers (callers) to understand how and why they value (or do not value) these services. We are also gathering information on the technical and financial structure of the markets via requests for information through our formal powers and targeted questions to stakeholders at different points in the value chain.

1.7 Once we have reviewed all the information and views, we plan to publish our analysis and our proposals, in the autumn.

Questions

To help you in deciding what points you wish to make, we have suggested some questions below. We will consider all the views set out and information provided with responses, not only those focused on these questions.
Consumer experience

* Does today's market for non-geographic call services work well for consumers (callers)?
* Are the services satisfactory in terms of value for money, quality and range of services?
* Are consumers able to access the services with confidence and with sufficient understanding of what is being provided and what are the terms of the sale?

If not:

* What aspects of it do not work well?
* What are the observed outcomes or characteristics of the services that you think demonstrate that the market is not working well?
* What do you consider to be the cause of those negative impacts?
* Are there particular concerns with respect to specific number ranges?
* What changes would you suggest? How would these address the issues you have raised?
* Is there a requirement for changes to the National Telephone Numbering Plan in terms of changes to the definition or controls over the number ranges?
* Are the ways the services are currently provided and charged for equitable, in that do they treat different types of consumers fairly or are some types of consumers disadvantaged in terms of access to services or the costs of services?

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on May 1^st, 2010 at 11:34pm

There have been hints in the forum that this was coming. I offer some random thoughts.

We may have doubts about how far Ofcom is truly open to suggestions, however the stated terms of this exercise deny us the opportunity to claim that those who contribute to the forum were not asked to present their ideas. The way the suggested questions are framed suggests that Ofcom is well aware of where the concerns lie.

I must remind readers and members of the forum that there is no formal group in existence which would be naturally responsible for presenting a response on behalf of saynoto0870.

There is the possibility that someone could be asked (or could choose) to collect together many of the ideas posted in the forum and present them as a collection of anonymous ideas. Presenting a specific set of opinions as being representative of the members of the forum in general is a more difficult task, as this would require some expression of consent to be valid. (Prior publication with the opportunity to register dissent over a reasonable period could be deemed adequate.)

More difficult yet is the idea of presenting specific proposals for action that Ofcom could take. Ofcom exists by statute and it cannot shut itself down, which makes a highly popular suggestion unfeasible. Whilst it is independent of government, Ofcom is open to political pressure and it could face near abolition under proposals presented by one party currently hoping to form the next government. The strong bias against increased regulation, which has been pressed by the (for the moment) current government, is echoed or exceeded by those likely to participate in a possible new government. This is reflected in the comments quoted above. Very few of the votes likely to be cast next Thursday will be counted as being in favour of increased regulation.

Those who wish for services to be withdrawn or for wholly new regulations (within the scope of Ofcom's powers) to be introduced, must state their case, or express their opinion. I would however suggest that there may be more purpose in suggesting achievable alternatives. Proposals for action outside the scope of Ofcom's powers will doubtless be received and may be passed on, but they would perhaps be better directed appropriately.

The comments suggest that the specific proposals that will emerge from Ofcom's work will themselves be presented for consultation where this is thought appropriate. It must be understood that Ofcom already has many ideas, but wishes to take this opportunity to test the strength of public opinion and to invite insiders to present their views in public.

If members feel that there should be some collective action on behalf of "saynoto0870" to either present some type of collective response, or perhaps attempt to engage the media to encourage widespread public response on any specific point, then volunteers will need to become engaged to lead and to undertake this work.

Any offers?

Title: Re: Ofcom consultation - Review of non-geo calls
Post by CJT-80 on May 3^rd, 2010 at 5:13pm

In reply to IDB, I followed all the links given by Ofcom, and repsonded to their consultation request..

below is my reponse:

"Depending which service you deal with depends on whether the use of a NGN is justified or not.

For example the continued use of these numbers in the Health Service, such as Dr's Surgeries or the NHS Direct line is un justified and nothing more then a percieved money making exercise. NGN numbers with a standard 01/02 charging rate already exist.. so these should already be used where an 01/02 number cannot. The general public should NOT pay for access to these services.

This has been allowed to go on for longer than it should, party due to the clever marketing campaigns and mis-information given over the cost of calling such numbers.. eg calling an 0844 number on BT cost around 15p for the 1st minute alone!

If these numbers are allowed to be in use in general, they need tighter regulation, including CLEARER call charges regardless of if you use a Landline or Mobile. Currently most quoted call charges relate to the use of a BT line only!

Also the sheer amount of numbers in each catergory
adds to the confusion. ie 0843/0844/0845, and equally 0870/0871/0872. The confusion this causes only serves to benefit the companies who use these numbers, and has a detrimental cost effect on the end using calling these numbers.

Overall BETTER and Clearer pricing info needs to be implimented ASAP! Simply saying "local rates" is no longer enough or even factual.

Ofcom also needs to make sure this consultation is made available to as wider audience as possible."

I feel the more people who are told of this consulation the better the potential feedback to Ofcom.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by Dave on May 5^th, 2010 at 11:16pm

I have just looked at this consultation, and I was surprised to find that the full consultation document only runs to seven pages, the meat of which covers just four pages. So it can be read in full quickly unlike many others.

I would like members to post their thoughts here. The deadline for receipt of responses by Ofcom is Friday 28^th May 2010.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on May 19^th, 2010 at 3:48pm

It is perhaps disappointing that there has been no extensive discussion in this thread on what action Ofcom should now be taking.

Do we want action to be taken on this issue for the benefit of all, or are we content to moan about it whilst offering alternative numbers wherever we can?

I offer below a brief summary of my own proposals. I remain very keen to hear what other suggestions members may have, and to engage in serious discussion on any considered points.

1. Revenue sharing on 0845 must be ended, in the same way as for 0870. BT is clearly ready to do the job for Ofcom in the same way as it did for 0870.

2. 0844/3 must be designated in some way that makes them recognisable as being similar to PRS, but without the nonsense of formally classifying them as such, for now. Phonepay Plus could not cope, and it is quite ridiculous to classify those who draw a modest subsidy from revenue sharing in the same group as those who use it as their primary source of income.

There are many problems and complications with these ranges. Some form of proper designation is however essential.

3. The "NTS condition" must be removed from BT, as it is no longer justified. This must be replaced with use of the wider powers of price regulation which Ofcom now holds.

Use of these powers must be based on some meaningful definition of the price of a "standard" call (i.e. that to a 01/02/03 number) for each tariff. This may be tricky where such calls are inclusive in packages, however it has to be done. There is normally an equivalent non-inclusive package which could provide the basis for the setting of such a standard.

4. In place of the set rates applied under the NTS condition, regulation should apply a limit to the surcharge over the "standard" rate that may be applied to each type of NTS number.

Users of NTS numbers will be able to quote the cost of calling as being the "standard" rate plus no more than the relevant limit.

Users must be strongly discouraged from quoting the rates (by name or value) as used by any specific provider. Ofcom must demand that users recognise its success in achieving a plural market (i.e. not BT plus a few others). The relevant authorities (e.g. Phonepay Plus, the ASA and Trading Standards) should be encouraged to outlaw the practice of quoting particular example rates, with the qualification that others may vary.

5. In the case of 0845 the surcharge limit should be zero, so that in effect it is generally placed in the same class as 03. I do not however see any need to demand that 0845 calls be made part of inclusive packages; market pressure may achieve that effect anyway and compulsion would provide an excuse to increase the price of inclusive packages due to the additional call volume.

Now that the new price control powers are held, the situation with 0870 should be regularised to work in the same way.

6. There will need to be a period of transition during which these changes come into effect. There will then need to be a review of what has been achieved and the way that the market has reacted. There will also need to be consideration of further steps, notably with 0844/3.

This proposal is on the basis that we are starting from where we are now, not from where we should have been if Ofcom had previously been able to deploy the wisdom of Solomon. It is intended to be practical and achievable, rather than being a declaration of principles and utopian dreams. The latter would be perfectly valid responses to this current consultation.

I believe that this will greatly aid visibility, as not only will it remove the nonsense of no rate being given for the majority of callers (i.e. those not using BT) but it will also give an indication of the financial benefit being received by the call recipient.

I will be publishing my full submission in due course.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by loddon on May 20^th, 2010 at 7:06am

Your proposals, SCV, are pointing in the right direction but do not go far enough nor reach their logical conclusion.

I approach this question of "what should be done about non-geographic numbers" from the starting point that Ofcom is the regulator and as such its primary duty is to protect the consumer from scams and rip-offs. Ofcom, I understand, is charged with ensuring and encouraging an open, competitive marketplace but it must also define the rules to ensure that companies do not mislead or take unfair advantage of the consumer.

The problem is that 084 and 087 numbers are wrong in fundamental concept and are unethical by design. The concept of all 084 and 087 numbers contravenes normal business practice, conventions, ethics and common sense. I say this because the wrong person pays for the 084 and 087 product -- they are rip-offs by design. They are designed to mislead the consumer who does not get what he pays for. The consumer is required to pay for the features and facilities from which another person or entity benefits. The consumer does not get what he pays for, someone else does.

Why do I say this? Because the point about 084 and 087 numbers is that they are non-geographical and they enable certain claimed functions and facilities which the "user" (i.e. the company using the number) may choose to use or select from a product choice such as :
call forwarding and diverting
network queueing
call menus of options for callers
call monitoring and statistics
prestige,status and kudos, national image
etc
The point is that these functions and facilities are primarily of benefit to the "user" and not the caller. Some may argue that the caller gets some benefit in terms of access to the "user" organisation and I can see there may be a small element of that but I see the overwhelming benefit accruing to the "user" in that he is managing the route of access into his organisation for his benefit. Therefore I say it is the "user" who should pay for these functions and facilities and not the caller. It is the "user" who is buying the service, choosing who his supplier will be, deciding whether or not he is satisfied with the service and deciding when to enter and terminate contracts for the supply of the 084/7 number -- and not the callers (consumers) who have no decision options or choice about who provides the number and its associated facilities.

I see three parties involved here -- the telephone service supplier who provides the 084/7 number and the network facilities, the "user" who is the customer of the telephone service supplier, and the consumer or member of the public who wishes to call the "user" company. So in normal business terms the User engages in a contract with the phone company for supply of a service to them, the phone company supplies the 084/7 number and associated service and the contract and payments are between them. This part of the business transaction is between the -phone company and the "user" company/organisation and is nothing to do with the consumer or caller.

So my contention is that the "user" company/organisation should pay for the service and the caller/consumer should pay for his call at his normal rate to his telephone service supplier, in other words at his geographic rate. This would mean that "revenue sharing" is banned. This would remove all the problems with 084/7 numbers which have frequently been described in Parliament as "rip-offs". It would remove the danger of all sorts of scams, primarily the practice of making callers wait in a supposed queue so that the "user" company can accumulate revenue from the calls. This is a major problem because the 084/7 system is designed to encourage companies to increase the delays for callers because they earn money from delays. This is contrary to all common sense and good ethical business practice and it should not be allowed. Ofcom have failed the general public and consumers over the years by allowing this scam to continue and increase and Ofcom should now put an end to it. I was told just a few days ago that one of our largest banks, part publicly owned and whose name begins with L, have a standard practice of making all callers wait for a minimum of 9 minutes just in order to ensure they earn a certain amaount of revenue. This is a disgrace, it is daylight robbery of their customers, it should be illegal and Ofom should stop it happening. Just one example of many thousands I am sure.

You may say that what I propose would make 084/7 numbers work in exactly the same way as 03 numbers -- and I would reply YES.

My comments on 0800, 07 and 09 numbers will appear in my next post.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by loddon on May 20^th, 2010 at 8:05am

To continue from my previous post on the question "what should be done about non-geographic numbers?"

Regarding 0800 numbers. My view is simple. 0800 is promoted as "freephone" so that the consumer/caller makes no payment and the entire cost of the call is accepted by the user company/organisation. There is a big problem however and that is that 0800 calls are not free on mobiles although some are free (a very small fraction) but most callers don't know which are the free ones and which ones (most of them) are very expensive. In fact 0800 calls are outside most (all?) inclusive packages and are charged at a high premium rate. This is very confusing and unfair to callers/consumers.

This must be sorted out by Ofcom. If 0800 means "free to caller" then that is what it should mean to all callers at all times regardless of which service network or device is used to make the call, whether landline, call box or mobile. Ofcom must make the rules about 0800 clear, consistent and simple.

I don't know much about 070 numbers or even why they exist at all. What is the reason for them? My impression is that they are very expensive to call and are easily confused with 07 mobile numbers. This confusion for the caller/consumer must be removed by Ofcom. The best way to do that I am not sure; perhaps by moving 070 numbers to a different and distinct range where they will be recognisable by callers/consumers for what they are and for their price range.

The 07 range I understand to be reserved for mobile phones. I think this is generally well understood and see no problem apart from the confusion caused by 070 numbers mentioned above.

I understand 09 numbers to be special premium rate numbers designed specifically for revenue earning purposes through the telephone system. While I don't really like the idea I suppose it is a legitimate business idea provided ther are suitable safeguards for the caller/consumer defined by Ofom and their co-regulator PPP. There are others on this Forum who know this subject much better than I and have often proposed rules and safeguards via this Forum and directly to Ofcom and PPP. These include a strict limit on queuing and waiting times, cost announcements before a call begins, pin numbers to protect the person who pays the phone bill from misuse by others, all of which I support. I will leave it for others to make more specific proposals.

In summary, I believe that Ofcom should use this Review to consider changing the non-geographic phone number structure to remove anomalies and confusion of the public and to remove or minimise the occurrence of scams and rip-offs throughout the industry :---

Make 084/7 numbers non-revenue sharing and chargeable only at normal geographic rates and to be included in packages
Make all 0800 numbers free to all callers at all times and from all services
Remove the confusion between 070 and 07 numbers
Strengthen the rules controlling 09 numbers.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on May 20^th, 2010 at 4:51pm

Loddon

Some brief points in response to your well-argued comments. Some of these extend my own comments.

Ofcom has to represent the interests of consumers of telephone services. Users of 084 numbers are part of that group. If they wish to be able to subsidise the costs they incur in providing additional facilities at the expense of callers then Ofcom has a duty to enable them to do so. With charities and public services, if the "consumer" does not pay, then it is the donor or taxpayer. In the private sector, a business has to cover its costs by income, so the "consumer" always ends up paying in one way or another. The issue of "who pays" for a benefit is ultimately a matter of shifting costs from one of these groups to another.
In principle we agree about 084/7. 0871/2/3 is already classified as PRS. I propose that 0845 and 0870 should be essentially treated in the same way as 03. 0844/3 is the snag; as I do not see it as being able to be treated as PRS, although I demand that it be designated in some way that makes it recognisable as essentially the same. In an ideal world 0844/3 and 0871/2/3 (and 070) would be moved to 09 to provide greater clarity, however I do not see that as achievable.
070 is the remnant of what may have seemed to be a good idea at the time - a "personal number" to contact someone wherever they may be. This never took off and has been horribly abused.
I believe that resolution of the 080 from mobiles issue will have to await the outcome of moves to transfer the additional cost of mobile calls to users of mobile phones. Whilst this premium remains in place I do not support the idea of those who are not prepared to pay it being prevented from offering free calls from landlines by using a 080 number. If the premium were set to remain then there would be an argument for opening a separate range for those who wish to offer "free from landline only" calls. The present scheme under which the mobile telcos waive their charges for 080 calls to registered "helplines" is a valuable exceptional arrangement, which should not be compromised.

Many thanks (and also to CJT-80) for airing your thoughts, It would be great to hear some other views.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by derrick on May 21^st, 2010 at 12:05pm

SilentCallsVictim wrote on May 20^th, 2010 at 4:51pm:

I believe that resolution of the 080 from mobiles issue will have to await the outcome of moves to transfer the additional cost of mobile calls to users of mobile phones. Whilst this premium remains in place I do not support the idea of those who are not prepared to pay it being prevented from offering free calls from landlines by using a 080 number. If the premium were set to remain then there would be an argument for opening a separate range for those who wish to offer "free from landline only" calls. The present scheme under which the mobile telcos waive their charges for 080 calls to registered "helplines" is a valuable exceptional arrangement, which should not be compromised.

This is an easy fix, include an 01/02 number for mobile callers alongside the 080 number, it will cost nothing as, (I assume), the 080 number works in the same way as 084/087 numbers, i.e. it is laid over an 01/02 number.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by Kiwi_g on May 21^st, 2010 at 2:44pm

Is it not now the time to campaign for “freephone” calls from all mobile numbers to be exactly that – FREE !! Something for "saynoto0870" to take up?

I’m involved with a business line and we have BT’s OneBill Plus. Calls to land lines are capped at 5p for one hour and calls to mobile numbers are capped at 20p for the same time. Therefore, the costs of taking a call from a mobile number should not be excessive. We also have a number of BT mobile phones. The service allows us to divert calls to any phone number. If the diversion is to another number in the group, there is no charge, either for the diversion or the call.

As an aside, calls to 0845 and 0870 numbers are still charged by the minute unlike private BT customers and the bill differentiates between "local" and "national" calls.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on May 21^st, 2010 at 3:55pm

derrick wrote on May 21^st, 2010 at 12:05pm:

This is a most useful idea for callers who have free or inclusive calls to 01/02/03 numbers. (03 may provide the necessary redirection more readily, in cases where the underlying number cannot simply be released for direct dialling.) It does not however provide "free" calls, as many mobile users pay for 01/02/03 calls.

I have long argued that it is for those who wish to be able to meet the cost of incoming calls from mobiles to pressure Ofcom to designate a number range that may be used for this purpose. I see no reason why Ofcom would fail to respond to such representations. I believe that campaigners need to establish that there are such consumers of telephone services whose interests are not being served by Ofcom. (I would be delighted to be proved wrong, but I suspect that there are not very many of them!)

it is intended that over a period of time mobile users will have to get used to meeting the costs associated with the service they are using (rather than having their costs subsidised by others). Once the current call charge premium has reduced significantly, it may become reasonable to expect all those who wish to offer "free to caller" numbers to pay for calls from mobiles also.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on May 21^st, 2010 at 4:16pm

Kiwi_g wrote on May 21^st, 2010 at 2:44pm:

I’m involved with a business line and we have BT’s OneBill Plus. Calls to land lines are capped at 5p for one hour and calls to mobile numbers are capped at 20p for the same time. Therefore, the costs of taking a call from a mobile number should not be excessive. ...

As an aside, calls to 0845 and 0870 numbers are still charged by the minute unlike private BT customers and the bill differentiates between "local" and "national" calls.

Thanks for reminding us that the world is different for business users - including the retention of distinct rates for local/national calls, which do apply on some tariffs, if not on yours. The BT "giveaway" to residential customers on 0845 and 0870 numbers, by making them inclusive, is also seen for the exceptional measure that it is. One could also point out that BT residential customers are being forced to pay for inclusive 0845 and 0870 calls, whether or not they want them. This means that all residential BT customers with inclusive packages are subsidising users of 0845 numbers.

If the cost of paying for mobile calls is four times that of landline calls, I cannot quite see where the suggestion that the difference is "not excessive" comes from. I respond to the point about campaigning for "free to caller" in my preceding contribution.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by derrick on May 22^nd, 2010 at 10:07am

SilentCallsVictim wrote on May 21^st, 2010 at 3:55pm:

derrick wrote on May 21^st, 2010 at 12:05pm:

The reason I never mentioned 03 numbers was because there is a cost associated with them for the recipient, hence why I used 01/02numbers as there is no cost for incoming calls, therefore the suggestion will work.

ALL phone customers pay for their calls, there are no free calls, you either pay by the minute or it is included in your monthly bill.

Also, 080 numbers are usually charged at a higher rate than 01/02/(03) numbers by mobile operators, so paying or not it will still be cheaper to supply an 01/02/03 number for the mobile user, and will also be cheaper for the recipient as they will not be paying a subsidy every time the the 080 number is used.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on May 22^nd, 2010 at 12:08pm

derrick wrote on May 22^nd, 2010 at 10:07am:

ALL phone customers pay for their calls, there are no free calls, you either pay by the minute or it is included in your monthly bill.

A fair point. This is indeed perhaps the difference for the recipient between having redirection facilities on a 03, rather than a 01/02 number. It is of course wrong to say that there is "no cost for incoming calls" on 01/02 numbers - it is part of the monthly charge (indeed that is one of the options for mobile providers as they lose the ability to collect this fee from callers).

The charge for a redirection facility on 01/02 numbers may indeed be reflected in a monthly fee, rather than on a per-call basis. That is what I was referring to when I said "03 may provide the necessary redirection more readily". I was thinking of those cases where there is not a simple one-to-one relationship between a 0800 and an underlying number, i.e. "where the underlying number cannot simply be released for direct dialling". I am sorry if I did not make that clear.

When I said "It does not however provide 'free' calls, as many mobile users pay for 01/02/03 calls" I should have made it clear that by "free" I was referring to there being no marginal cost for the call. The marginal cost may indeed be less for 01/02/03 calls than 0800, but it is not necessarily nil.

I fully support efforts to get 080 users to offer suitable 01/02/03 alternatives for mobile callers, under the present regime. I suggest however that we should not let this modest advance, and our concern about terminology, cause us to lose sight of the interests of those who may wish for mobile users to call them (other than on a registered helpline) whilst incurring no marginal cost for the call. These are people who want to subsidise the caller's costs!

I am personally happy with this latter arrangement being described as "free to caller". I see this as a suitable abbreviation of "free of any marginal call cost to the caller". I do however acknowledge the repeated concerns of those who do not, but hope they recognise that the disagreement on this particular point is essentially a semantic debate on the validity of this particular interpretation.

I see severe dangers in a, fully worthy, campaign for the use of 01/02/03 alternatives becoming confused with a campaign for "freephone" calls from mobiles to be FREE. If we expect others to be clear in what they refer to as "free", we must surely do the same ourselves.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by sherbert on May 22^nd, 2010 at 2:06pm

SilentCallsVictim wrote on May 19^th, 2010 at 3:48pm:

It is perhaps disappointing that there has been no extensive discussion in this thread on what action Ofcom should now be taking.

The reason why, has been said many times over the last few weeks is because when ever anyone has anything to say, you always argue the opposite to anyone else's suggestions that they may put and not only that as mentioned before, you usually respond in such a patronising and belittling way, most members have given up contributing. As always you seem to think to treat this is as your own forum and unless anyone agrees with you, you are not happy.

So, I guess that is why I and most others do not add to the discussion in this thread on what action Ofcom should now be taking.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by loddon on May 22^nd, 2010 at 4:59pm

sherbert wrote on May 22^nd, 2010 at 2:06pm:

-----------------------------------------------------------------------------------------------------------------------------------------------------
Sherbert, it is a great pity that you don't feel like posting and particularly on this thread because this is a most important subject and it is probably a once in a decade or more opportunity for us to tell Ofcom what we think they should be doing about the whole numbering architecture and non-geographic services. 8-)

I appeal to you not to be put off by the postings of one individual. Where's the good old British fighting spirit? :) If you disagree then say so, this is an open public Forum and anyone can say whatever they like within the normal bounds of decency and civility. And I must say this Forum is usually a very civil place and people can have reasonable discussions and can reason in depth if they fell inclined.

As for SCV I don't think he is half as bad as you make out. He puts forward his views forcefully and appears to have certain deeply held principles, like the NHS being "free at the point of need", but I must say he has never attacked any poster at a personal level. I think he only attacks the argument or will question or try to correct alleged facts, but he doesn't get personal, as far as I have noticed. Yes, he may be difficult to argue against sometimes, and I have found him locquacious, long-winded, overly persistent and sometimes damned irritating occasionally (fair comment SCV? ;) :)) and at others quite difficult to spar with but I believe he is fair and will acknowledge valid points and arguments when he can. SCV is also an indefatigable campaigner and a great asset to our cause.

So can I urge you and others to please give your views on what Ofcom should be doing about non-geo numbers and services. I have set out my own view in earlier posts and would welcome support and comment from you or anyone else. My contention is that the concept of revenue sharing is conceptually wrong, unethical and a rip-off of all telephone callers. It should not be allowed except, perhaps, with the exception of 09 numbers where appropriate controls and rules are applied by Ofcom/PPP. I think all 084/7 numbers should be treated in exactly the same way as 03 numbers as that would eliminate most of the scams that the public are currently subject to.

So come on lads and lasses, as Mrs Merton would say, lets have a heated debate. :) ;D

~ Edited by Dave: Quote box finished off

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on May 22^nd, 2010 at 5:20pm

loddon wrote on May 22^nd, 2010 at 4:59pm:

... fair comment SCV?

I hope that I am no more and no less prone to error, arrogance, over-loquation and many other faults than any other contributor. I admit to being keen on raising the level of understanding and debate in this forum and to focus on effective campaigning activity, rather than expressing bland agreement with comments that demoan the awful state of the world. I hope that I earn the right to comment on other contributions by offering my own thoughts for examination and argument.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by sherbert on May 22^nd, 2010 at 8:35pm

loddon wrote on May 22^nd, 2010 at 4:59pm:

sherbert wrote on May 22^nd, 2010 at 2:06pm:

~ Edited by Dave: Quote box finished off

Thanks for your witty response lodden and I will put my views here, although I know 'His Holiness' will disagree with me as usual and will have to put up with his usual nonsensical and patronising reply.

I have said elsewhere in this forum that SCV's statement about 'the NHS being "free at the point of need"', is of course complete and utter nonsense. We all (or most of us) pay our contributions to the government to pay for the NHS. We also pay for prescriptions, dental care, phone calls to the doctor, car parking to visit a hospital for an appointment and at the end of our lives we have to sell our homes to pay for care before we go to the great unknown, just to name a few. Nothing in this life (and that includes the NHS) is free. If SCV thinks it is free, I wonder how he thinks it is funded?

As to the more relevent point about telephone calls, this is what I think should be happening.... With the exception of calls to 'chose a Dorothy' and programmes like that, competition games on the television, radio and the press, calls to technical help lines, and other such calls where it is obvious this is the only way the company is going to receive any revenue, (and to save any confusion they should all be 09 numbers) should all be included in the various calling plans that are about thus being charges the same rate as 01, 02 & 03 calls. After all BT and some others have now included 0870 & 0845 calls into their inclusive packages, so let us see the rest of the 08 numbers included.

This would make everything simple and everybody will then know exactly what the call charge is.

Calls to to technical help lines should either be answered or the engaged signal should cut in if the line is busy. It is completely unacceptable to be kept on hold listening to music, advertisements and announcements and having to pay ridiculous sums of money for the priviledge. I never know why people object to paying for technical help on the telephone, they would not expect someone to turn up at their house to fix something for free.

All freephone numbers such as 0800, 0808, 0500 etc.etc. should be 'free' on all mobiles as well as land lines.

So, there is my contribution to this debate and hope it will prove useful.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on May 22^nd, 2010 at 10:16pm

My beloved Sherbert

I am happy to confer my blessings on you and your posting.

Many thanks for expressing an honest opinion in a very straightforward manner.

I will continue the expected patronising response below - I will however be happy to remove it if you wish. Just PM me and I will delete both this and all the subsequent paragraphs.

The important bit of "free at the point of need" is the "at the point of need" bit. We pay for NHS services through taxation as we earn and spend, not when we fall ill. Those of us who are not exempt, through need or lack of supposed ability to pay, do pay charges on using some services, but these are paid to the NHS, not to the actual provider of the service. Where a charge for parking on NHS land is greater than a reasonable fee for public car parking in the area (not easily determined) then this may be considered as a charge for accessing NHS services and is improper. Any net income from car parking on NHS land should belong to the NHS, i.e. offset against funding given to the NHS body in question. There are also issues around the income from, and the prices charged in, retail concessions in hospitals and other NHS premises. The situation with revenue sharing telephone numbers is, I hope, absolutely clear.

By referring to end of life care, you tempt me to comment on the previous government's proposals for a National Care Service, as a sort of extension to the NHS. I saw this as a far greater threat to the principles of the NHS than the present and continuing efforts to inject consumerism. The NHS funding model is under quite enough challenge as it is, although it still largely survives (with modest breaches). To combine it with a service that could not be sustained on the same model from day one would be to risk fatally undermining its core values. I do not share the view that the state should provide us with a home, meet our daily care needs and also give us a stake in the property market.

I hope that you do not feel patronised if I point out that my outline proposal, published above, covers clear cost information for those calling to "chose a Dorothy" etc. whether or not they are calling from BT. I agree that those who use revenue sharing / premium rate numbers to simply obtain subsidy, rather than relying on them for income, should be treated differently. For this reason, I do not, on balance, approve of 0871/2/3 having been classified as PRS, under the present regulatory regime. I do not believe that 0844/3 should, or could, join them, however they must be classified in some way as being "like Premium Rate Services".

I do strongly disagree with your suggestion that the cost of inclusive packages should be forced up to include the cost of these calls, as happens with BT and 0845 at present. It happened with 0870 for a period of just over 6 months, before revenue sharing ceased.

I believe that the fact, and the general level, of revenue share involved in a call should be clear to the caller, whatever type of telephone service they have, so that those who benefit from revenue sharing can be clearly answerable to their callers. It is for those callers to make an informed determination about whether the level of surcharge is appropriate - I believe that the same applies to queuing. Whilst it may be fair for Phonepay Plus to take a view, and set rules, about acceptable practice for the top end of the PRS industry, I do not believe that Ofcom should be asked to determine what is acceptable and unacceptable as a service for which revenue sharing is appropriate. I believe that this has to be left in the hands of the properly informed caller.

As stated above, I also do not agree that users of 080 numbers should be prohibited from using these for calls that are only "free" from landlines under the present mobile charging regime. I see an opportunity to address this issue in the medium term, but would see an early attempt to enforce such a requirement as leading to a near total withdrawal of the 080 service.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by idb on May 23^rd, 2010 at 12:48am

Without going down the whole pointless philosophical "what is free" debate again, my recollection of UK cellular consumer plans is that Orange and One2One provided free calls to 0800 numbers, and Cellnet and Vodafone charged 0800 at the given rate for geographic calls, and were included in any such bundled allowance. Greed took over, and not only did the PCN providers drop the free 0800 calls, the other two decided to remove all 08 calls from bundled allowance. Somewhere, I have a 'spin' letter from a Vodafone airtime provider (probably Cellular Operations) informing me that to 'simplify' my tariff, and to make it 'better value for me', calls to 08X would be excluded from my allowance.

I would not necessarily advocate that 0800 calls should be charged at a zero rate from a cellular line, rather that they were treated, for billing purposes, in exactly the same way as geographic calls, that is the situation that generally prevailed before the greed took over.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by idb on May 23^rd, 2010 at 1:17am

sherbert wrote on May 22^nd, 2010 at 8:35pm:

I have said elsewhere in this forum that SCV's statement about 'the NHS being "free at the point of need"', is of course complete and utter nonsense. We all (or most of us) pay our contributions to the government to pay for the NHS. We also pay for prescriptions, dental care, phone calls to the doctor, car parking to visit a hospital for an appointment and at the end of our lives we have to sell our homes to pay for care before we go to the great unknown, just to name a few. Nothing in this life (and that includes the NHS) is free. If SCV thinks it is free, I wonder how he thinks it is funded?

I don't see why this should be such a contentious point. I am sure SCV is fully aware, perhaps more than most, of how the NHS is funded. To describe it as 'free at the point of use' seems to me to be a perfectly satisfactory and accurate description. Of course it has to be funded, but there again, so does the army, the police, the nuclear deterrent, and all other governent expenditure that does not result in billing for service rendered. Would I consider the army, the police and the nuclear deterrent free? Of course, as I would so consider with the National Health Service.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on May 23^rd, 2010 at 2:22am

In looking at the issue of 080 calls from mobiles, we are mixing up too separate issues.

The key issue is about whether the recipient should pay the full cost of the call so that it is truly "free to caller".

I take the fact that lots of companies have not apparently been breaking down Ofcom's doors asking to be allowed to pay to receive calls from mobiles, as an indication that there is a reluctance to meet the full cost of doing so, including the hated inflated "termination rate", which would presently apply. Ofcom has laid out a plan for gradually reducing this rate over the coming years. This will (I believe) inevitably lead to some adjustments in the way that mobile service is paid for, e.g. the introduction of a "line rental". Once the inflated termination rate is considerably reduced, it is likely that 080 users will be more ready to pick up the cost of calls from mobiles.

I suspect that if every 080 user were to be required to pay the high termination rate at present, as is commonly proposed, this would simply lead to many ceasing to use their 080 numbers. The growth in use of inclusive packages on landlines tends towards making them redundant anyway. I would not wish to see those with landlines, but without inclusive packages, lose this benefit.

The secondary issue is about what the mobile company charges the caller in the absence of any such arrangement.

The mobile companies waive any charge on calls to registered helplines on 080 numbers. A cynic (like me) would say that they have to make this up somewhere else.

As imposing any charge for what is described as a "freephone" number is somewhat odd, it is difficult to address the issue of what it should be. On reflection, I can see no justification for charging any more than the cost of normal geographic call and will apply such a provision to my proposal, summarised above. This places 080 in the same class as 0870 and the (future) 0845.

The issue of what is included in packages is a separate point, as this affects the price of the package - the more calls that may be made under the terms of the package, the more expensive the package must be. I see this as an issue between each telco and its customers. Just because BT customers are apparently happy to pay more for packages because 0845 and 0870 calls are included (currently including a revenue share in the former case), I would not wish to have the same additional cost imposed on all package users by regulation.

This has already been done with 03, perhaps for somewhat political reasons. 03 could be considered to be a special case, as it is primarily (although not exclusively) intended for use by public and third sector bodies. These bodies need to be able to assure callers that the cost of a call to their 03 number cannot be any greater than that of a 01/02 call under any circumstances.

(Perhaps I should admit my own political motive. I do not wish to present a proposal that would provide a justification for the price of inclusive packages to be increased.)

On the issue of "free at the point of use", we may do well not to get into discussing whether someone involved in police action, in receipt of an illegal invasion or deterred from attempting to acquire nuclear weapons by the fact that the UK has done so, should be required to pay for the service. Although Ofcom is calling for input on a wide range of topics, I think that these would fall outside the scope of the consultation.

I hope I have addressed the point of contention by highlighting the "at the point of need" bit.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by sherbert on May 23^rd, 2010 at 11:15am

So there you have it loddon, unless you completly agree with SCV's thoughts and ideas, you get the, as you so aptly put it, usual long winded reply arguing against yours and anybody's else's ideas.

From his latest ramblings you can see why out of a membership of 18,000 plus on this forum, so few bother to respond.

However I do appreciate the blessings 'His Holiness' has conferred on me ;)

I still think that all calls that not included in the various calling plans should be 09 numbers then everyone will know exactly what are premium rate numbers. At the moment there is huge confusion with the various 08 numbers. I will continue to campaign for that.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on May 23^rd, 2010 at 1:33pm

sherbert wrote on May 23^rd, 2010 at 11:15am:

... arguing ...

As I understand it, this is the purpose of a discussion forum.

sherbert wrote on May 23^rd, 2010 at 11:15am:

I still think that all calls that not included in the various calling plans should be 09 numbers then everyone will know exactly what are premium rate numbers. At the moment there is huge confusion with the various 08 numbers. I will continue to campaign for that.

Well said; a clear and coherent position.

I believe that the vital issue is for callers to know what are premium rate numbers, and to be aware of both the cost of calling and the amount of premium from which the recipient benefits. I will continue to campaign for that.

I hope that this is also a clear and coherent position. I am sorry if my attempts to explain my reasons for adopting it and my proposals for how it could be brought about are difficult to follow. I cannot apologise for the fact that some contributors to the forum disagree with me.

I suspect we agree that the present mess is highly undesirable. I do not however propose that Ofcom should compel the cost and confusion of a massive series of number changes (e.g. 0844/3 to 09, 0845 to 03). I do however propose many being shifted off 0845, probably onto 0844/3, as revenue sharing is removed.

Where there is no longer any justification for a premium (i.e. on 0870, and in future on 0845), I propose that the new powers available to Ofcom be used to prohibit the imposition of a premium on chargeable calls.

I understand that many would disagree with my proposal that Ofcom should not compel telephone service consumers to pay for all non-premium numbers being included in all packages. I believe that the terms and content of packages (properly defined and described) should be left to the market. If, for example, Talk Talk wishes to offer only local calls as inclusive at all times for all of its customers, then it should be free to do so. Likewise, any telco should be free to allow inclusive calls only within its own network on some packages.

My most radical disagreement with many forum members is my failure to propose that Ofcom should withdraw the ability of telephone consumers (other than PRS providers) to obtain subsidy for the costs of their telephone service from callers. I only propose that this must be transparent, and that this transparency must be sufficient to compel those unable to justify the practice to cease it. Ofcom's duty is to promote the (I would add proper and valid) interests of telephone consumers. This applies to both those who make and receive calls, however I do not believe that this should extend to readily enabling them to perpetrate scams, as is the case at present.

I hope that this summary of points on which we perhaps agree and disagree is helpful in explaining my position. Perhaps we can now return to discussing the issues themselves, rather than the matter of who holds particular ideas and how they express them.

When comments are made about my own contributions, I hope I am right to feel that I am being invited to respond. I have taken the points made, and now try to avoid launching into vigorous debate with every forum contributor.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by Dave on May 23^rd, 2010 at 7:41pm

loddon wrote on May 20^th, 2010 at 7:06am:

… It is the "user" who is buying the service, choosing who his supplier will be, deciding whether or not he is satisfied with the service and deciding when to enter and terminate contracts for the supply of the 084/7 number -- and not the callers (consumers) who have no decision options or choice about who provides the number and its associated facilities.

The "user" is also a consumer; that is a "consumer" of telecommunications services.

loddon wrote on May 20^th, 2010 at 7:06am:

I see three parties involved here -- the telephone service supplier who provides the 084/7 number and the network facilities, the "user" who is the customer of the telephone service supplier, and the consumer or member of the public who wishes to call the "user" company. …

There are in fact four parties. They are the recipient ("user"), the recipient's telephone provider, the caller and the caller's telephone provider.

I haven't decided where I stand on call charges for freephone numbers from mobile phones. I would like to learn more about what could be implemented and what isn't feasable. I wonder whether making freephone numbers free to call from mobiles is perhaps, in practice, not as simple as we would like it.

It's important to appreciate that charges to make freephone numbers free from mobiles is likely to be quite a bit more than those for landlines. The suggestion above that charges for mobiles "should not be excessive" is based on the retail call prices from one provider. The cost of mobile calls has been pushed down to attract custom.

To help with understanding, here is a brief explanation of what happens when a call is made. It is important to appreciate that in today's multi-operator telecommunications market, the entire connection or 'line' from the caller to the receiver is not necessarily under the control of the same telephone provider. The parties and how they relate are as follows:

[Caller]--------------------[+]--------------------[Receiver]
Line provided by Line provided by
Caller's telco Receiver's telco

The [+] in the middle represents the connection between the two providers, for which one pays the other.

A caller's telco pays about 4.7 pence per minute during the daytime to connect calls to a mobile network (the receiver's telco), whereas geographic and 03 calls cost them 0.5 pence per minute. That's over nine times!

With freephone numbers, the money flows in the opposite direction; the receiver's telco pays that of the caller. When someone calls from a BT line to another operator's 0800 number (e.g. to one provided by Virgin Media), it charges around 0.6 pence per minute. These figures come from the BT Wholesale Carrier Price List which shows the inter-operator costs.

If these proportions are anything to go by, then the mobile companies are likely to demand at least 6 pence per minute!

I would be interested to know industry insider's opinion on this and the other points made on this thread.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on May 23^rd, 2010 at 9:28pm

Dave wrote on May 23^rd, 2010 at 7:41pm:

To help with understanding, here is a brief explanation of what happens when a call is made ...

Thanks Dave, this is helpful.

For further clarification, my comments about the potential for the situation with 080 to change when the premium on mobile calls is reduced is with reference to the Ofcom announcement published at - http://www.ofcom.org.uk/media/news/2010/04/nr_20100401a.

I know that this is of no immediate comfort and there is no indication about the stage in the process of premium reduction at which 080 users will be expected to be happy to start picking up the tab for calls from mobiles. I will however urge Ofcom to start addressing the point now.

Dave is also right to remind us that users of 08 numbers are consumers of telephone services, whose interests Ofcom exists to further.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by NGMsGhost on May 25^th, 2010 at 9:24pm

sherbert wrote on May 22^nd, 2010 at 2:06pm:

Hear, hear sherbert. I think that is precisely how many other forum members feel.

Plus additionally I responded to 10 or so other Ofcom 084/7 or NTS numbering related consultations and one by PhonePayPlus and all of my views were completely and utterly ignored by Ofcom (I am sure their complacent civil servants never even read what I said other than perhaps in the consultation where they redacted large chunks of my comments) in favour of sticking to their own previously agreed secret agenda with the telcos that NTS numbers are a great money making wheeze and that the more of them they can have and the more deviously they can hide their charges then the better than they and their former and very likely future employers at the telcos like it. >:(

I personally now rarely visit or post in this forum since many of the other original contributors now also rarely participate knowing that almost every other post will be from SilentCallsVictim and that he will usually object to any of their views as being too simplistic and beyond what we believes we have a right to expect from the overpaid civil servants running OfCON

Title: Re: Ofcom consultation - Review of non-geo calls
Post by idb on May 25^th, 2010 at 11:27pm

NGMsGhost wrote on May 25^th, 2010 at 9:24pm:

Plus additionally I responded to 10 or so other Ofcom 084/7 or NTS numbering related consultations and one by PhonePayPlus and all of my views were completely and utterly ignored by Ofcom (I am sure their complacent civil servants never even read what I said other than perhaps in the consultation where they redacted large chunks of my comments) in favour of sticking to their own previously agreed secret agenda with the telcos that NTS numbers are a great money making wheeze and that the more of them they can have and the more deviously they can hide their charges then the better than they and their former and very likely future employers at the telcos like it. >:(

This is, more or less, how I feel on this matter, having determined, through previous consultations, that engagement with Ofcom is utterly pointless. There are so many scams, inconsistencies and inequalities with the Ofcom-administered numbering plan that short of a wholesale change to the plan to embrace fairness and consumer protection, little, if anything is likely to be achieved by general user participation in Ofcom's whitewashes. At the height of interest in this matter, an Ofcom consultation yielded some one thousand public responses - unprecedented for a telecommunication consultation. Dithering, delay and inaction followed, as will happen again.

Let me take one simple example. We have a commercial group, NEG, misrepresenting call costs in its marketing to NHS institutions. Not just once, but continually. This organization lies. On the reasonable assumption that Ofcom is familiar with such misrepresentation being perpetrated by this odious body, just what is Ofcom doing? Precisely nothing. It would be reasonable to further assume that if Ofcom had any modicum of consumer interest, one of its senior staff would pick up the phone and speak to a relevant individual within the NHS and explain just what is going on wrt NEG and Surgery Line and the deceit therein. Some may argue that this is not in Ofcom's explicit remit, however we all know the principal duty of Ofcom and it is about time that it acted upon that duty.

Anothe simple example. Reverse-billed, or mobile-terminated, SMS scams could be eliminated for many victims if an opt-in system was mandated. Why doesn't it take action? Because it is in the interest of the PRS industry not to have such mechanisms in place.

Ofcom,or at least this incarnation of Ofcom, is a pointless quango. Perhaps the blues and yellows will do something about it, but until they do, scams, rip-offs and expensive phone calls are here to stay.

The sad aspect of the 08 NGN nonsense is that there are some innovative and potentially useful services that operate within revenue-sharing numbering. Unfortunately, these are lumped in with calling one's bank or doctor. A ridiculous situation, and one wholly of Ofcom's making.

Ofcom has ignored previous user submissions to its various NGN consultations, and I suspect the resoponse rate to this consultation will be minimal.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by idb on May 26^th, 2010 at 2:14am

Title: Re: Ofcom consultation - Review of non-geo calls
Post by idb on May 26^th, 2010 at 2:15am

Title: Re: Ofcom consultation - Review of non-geo calls
Post by loddon on May 26^th, 2010 at 6:49am

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

. There are so many scams, inconsistencies and inequalities with the Ofcom-administered numbering plan that short of a wholesale change to the plan to embrace fairness and consumer protection, little, if anything is likely to be achieved by general user participation in Ofcom's whitewashes. At the height of interest in this matter, an Ofcom consultation yielded some one thousand public responses - unprecedented for a telecommunication consultation. Dithering, delay and inaction followed, as will happen again.

Let me take one simple example. We have a commercial group, NEG, misrepresenting call costs in its marketing to NHS institutions. Not just once, but continually. This organization lies. On the reasonable assumption that Ofcom is familiar with such misrepresentation being perpetrated by this odious body, just what is Ofcom doing? Precisely nothing. It would be reasonable to further assume that if Ofcom had any modicum of consumer interest, one of its senior staff would pick up the phone and speak to a relevant individual within the NHS and explain just what is going on wrt NEG and Surgery Line and the deceit therein. Some may argue that this is not in Ofcom's explicit remit, however we all know the principal duty of Ofcom and it is about time that it acted upon that duty.

Anothe simple example. Reverse-billed, or mobile-terminated, SMS scams could be eliminated for many victims if an opt-in system was mandated. Why doesn't it take action? Because it is in the interest of the PRS industry not to have such mechanisms in place.

Ofcom,or at least this incarnation of Ofcom, is a pointless quango. Perhaps the blues and yellows will do something about it, but until they do, scams, rip-offs and expensive phone calls are here to stay.

The sad aspect of the 08 NGN nonsense is that there are some innovative and potentially useful services that operate within revenue-sharing numbering. Unfortunately, these are lumped in with calling one's bank or doctor. A ridiculous situation, and one wholly of Ofcom's making.

Ofcom has ignored previous user submissions to its various NGN consultations, and I suspect the resoponse rate to this consultation will be minimal.

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

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

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

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

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

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

~ Edited by Dave: Quote box completed

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on May 26^th, 2010 at 9:59am

The recent string of comments reflect a quite proper frustration that all which is sought has not been achieved, due to an imperfect process. The very concept of "regulation" implies little more than attempting to diminish the ill effects of a free market.

If we seek change within the existing process, we can only contribute to it. I am surprised that long-standing campaigners deny having had any influence in the removal of revenue sharing from 0870, the introduction of the 03 range, further steps that are likely to be announced in the Autumn and the very fact that Ofcom invites input to a long-running programme of change that is still continuing. The latter offers political cover, in that the absence of comment on any particular issue may be taken to imply public contentment.

Those wishing to present well-formed proposals in response to the consultation are limited by time, because Ofcom intends to present its proposals as early as this coming September, and the lack of published evidence about the true state of the market. I will be offering outline proposals with an offer to participate further by refining and perhaps adjusting them when provided with further information and time. Others may wish to do the same. I have received no assurance that such offers would be accepted, although I have been promised that they will be considered seriously.

I suggest that those wishing to achieve change either contribute to the current consultation or offer their serious suggestions for how Ofcom should be reformed or replaced, by legislation. It is possible that the Communications Act 2003 could find a place in the Great Repeal Bill. Proposals for Ofcom's replacement could be a topic worthy of discussion in this forum.

The Conservative Party election manifesto suggested that Ofcom's functions in regulating the telecoms market would be transferred to DBIS, as it joined other quangos in facing near or total abolition. The coalition government document however makes no specific reference to any such proposal. The appointed Secretary of State for Business is not known for wishing to increase the scope of his Department, indeed he is known to have favoured its abolition. Current policy would prohibit the appointment of additional civil servants to undertake this work; one assumes that this would extend to those dismissed by Ofcom. Ministerial responsibility for all of Ofcom's functions has been given to a junior Minister in DCMS, where the emphasis would be on the broadcasting side, although there is "dotted line" reporting relationship to DBIS. This change to the previous structure of ministerial duties appears to remove direct responsibility for telecoms from the Consumer Affairs Minister in DBIS. All in all, this does not strike me as indicating any intention of making the significant change to Ofcom which many are demanding.

Those unwilling to simply sit back,waiting perhaps five years in the hope that the government which emerges from the next parliament will put all to rights, may wish to discuss their proposals for change as well as expressing their frustration.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by idb on Jun 2^nd, 2010 at 12:51am

SilentCallsVictim wrote on May 26^th, 2010 at 9:59am:

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

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

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

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

Title: Re: Ofcom consultation - Review of non-geo calls
Post by idb on Jun 2^nd, 2010 at 1:14am

The response from IPV6 has a few discussion points:

http://www.ofcom.org.uk/consult/condocs/ngnservices/responses/IPV6.pdf

Quote:

For many years, the NTS industry (specifically the 084 and 087 Calling Party Pays (CPP) number ranges) gave both the private and public sector access to badly needed income through the legitimate and proven processes commonly referred to as micro-payments. promote a wholly competitive market for the development and promotion of services. We outline our reasons below:

NTS ranges were envisaged to provide permanency (a permanent number in case a business or individual moved location), continuity (a number which would be unaffected by future geographic number range changes and amendments), provisioning for immediate changes in cases such as disaster recovery (ability to move an NTS number at will in case of sudden business or individual relocation, something not as easily obtained using a conventional PSTN line and geographic number) and a source of income within the 084 and 087 CPP ranges via micro-payments.

Quote:

Public Sector With the exception of life-critical (eg surgeries, out of hours patient lines) or social-crucial (eg housing benefit helplines, immigration language helplines, jobcentres) services and/or departments, HM Government should be free to utilize CPP NTS in the 055, 084 and 087 ranges as an additional method of raising valuable income and revenue – especially in the current economic climate.

Quote:

In closing, we are aware that there is a small (but vocal) minority of persons and ‘consumer groups’ who continue to lobby for price reductions in both call-costs and rental-costs, without due regard for the telecommunications industry and the staff that work within. Those persons should be mindful that the telecommunications industry has to be allowed to make a legitimate and healthy profit if is to be able to employ people, compete, expand and continue investing in ‘the network’ and new technologies both at home and overseas.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on Jun 2^nd, 2010 at 2:19am

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

The response from IPV6 has a few discussion points:

Quote:

... the telecommunications industry has to be allowed to make a legitimate and healthy profit if is to be able to employ people, compete, expand and continue investing in ‘the network’ and new technologies both at home and overseas.

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

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

A good discussion point indeed.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on Jun 2^nd, 2010 at 6:13am

idb wrote on Jun 2^nd, 2010 at 12:51am:

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

I am not sure of how the analogy with the "brick wall" fits with the fact that positive change has been won through repeated effort. A "brick wall" is very different from a "steep mountain", up which one makes slow and difficult progress, "conquering" it in stages.

I am not sure if the analogy of the Berlin Wall implies that we are stuck in a totalitarian state, seeking to escape from nationalised industries and excessive regulations so as to enjoy the relative freedoms of capitalism and plural democracy, or that we are working from the other side trying to bring those freedoms to others. I struggle to see how our objectives can be likened to that of the re-unification of Germany.

My contribution to the consultation is now published here. There is a page of "Highlights", which I commend to forum guests and members. This is an extract of some strong and quotable elements, supported by links so that they may be seen in proper context. It is intended to provide ready access to the meatier elements of what I am saying in a lengthy structured document.

If anyone wishes to enter into lengthy detailed dialogue, I will be happy to do so by email, possibly concluding with whatever may be thought to be of general interest from the exchanges being published in the forum.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by idb on Jun 2^nd, 2010 at 10:36am

SilentCallsVictim wrote on Jun 2^nd, 2010 at 6:13am:

idb wrote on Jun 2^nd, 2010 at 12:51am:

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

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

Title: Re: Ofcom consultation - Review of non-geo calls
Post by Dave on Jun 2^nd, 2010 at 12:45pm

idb wrote on Jun 2^nd, 2010 at 12:51am:

… The typical consumer is not the slightest bit interested in TCPs, OCPs, conveyance, transit and any other jargon that is trotted out as a convenient excuse. Years ago, a consumer could make a telephone call with reasonable certainty of understanding the cost of such a call. Charge bands L, a and b were simple to understand, and low cost B1 and B2 (?) bands further reduced the cost of long-distance calling on popular routes. Deregulation and increased competition followed - all well and good, leading to inclusive plans, unmetered calls and low-cost international calling. …

But it is the deregulation and competition that is why we have OCPs, TCPs and transit operators in this country. The principal of switching to a consumer driven telecommunications market with competing providers is not straightforward because their are consumers at each end of the chain (with respect to making calls), unlike supplier services. The same is true of postal services.

idb wrote on Jun 2^nd, 2010 at 12:51am:

…Unfortunately, the Ofcom NTS framework has resulted in the reduction of the benefits to the consumer of such advantages derived through competition, with the exclusion of many, perhaps most, numbers from a typical consumer calling plan. Any given business, agency, government department appears to now have a telephone number that is disadvantageous in terms of cost to the consumer. There is little point in having an inclusive plan where most of the numbers that a typical consumer would call are excluded from such plan. To determine the cost, inclusiveness (if any) and discount (if any) from, say a BT line, one has to wade through a multi-page pdf file or similar, and that is for just one carrier that tends to publish its tariffs in an easy to use format. This is simply too much aggravation for most people, in my opinion, and the lack of clarity is quite staggering.

As I pointed out previously, in this thread, both callers and receivers are consumers of telecommunications services. The former group (the callers) have benefitted from competition in geographic (normal) calls with inclusive call plans, whereas the latter group (the receiver's of calls) have been benefitted by competition due to the receipt of revenue payments and other services.

The problem is that the receivers have benefitted at the expense of callers. The providers of these premium numbers now wish to hold on to the additional charges they receive from callers whilst still having them portrayed as normal rate numbers. With respect to "Calling Party Pays", the calling party should pay either:
1. only the cost to a conventional landline such as is the case with 03. Any additional charges for features such as NTS should be met by the recipient.
2. in addition to the cost of a conventional landline; in which case the extra cost is a premium or subsidy to the recipient.

I therefore do not call for the abolition of premium numbers, but rather I abhore the fact that consumers are unaware of those premiums. The fact that BT's retail call charges are abnormally low due to regulation placed on it when most calls were made from its lines is the reason for this.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on Jun 2^nd, 2010 at 7:08pm

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

... the fundamental consumer objection - calling plans exclude numbers that a customer wants to call. This is very simple.

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

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

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

I believe that it is fundamentally wrong for Ofcom to define what calls may be included in packages, without a sound reason. Such a reason exists with 03 ...

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

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

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

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

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

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

Title: Re: Ofcom consultation - Review of non-geo calls
Post by idb on Jun 2^nd, 2010 at 10:09pm

SilentCallsVictim wrote on Jun 2^nd, 2010 at 7:08pm:

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

... the fundamental consumer objection - calling plans exclude numbers that a customer wants to call. This is very simple.

Why do we need to have this subsidy? Why did this subsidy gradually increase from zero to virtually every commercial and public sector body? Who decided that this subsidy was necessary? I cannot support any calling party pays model unless there is a value-added service on offer over and above everyday general purpose calls. I am not against revenue sharing per se; there are legitimate and useful services that can be funded through the micro-payment mechanism collected through the billing process. Calling a commercial or public sector body on the CPP model, often for the purposes of rectifying a problem not instigated bu the customer is, I'm afraid, not one that I can entertain. We have the ludicrous example (from the number request forum) of a credit card company using a PRS 09 number for customer service. Simply staggering.

I live in a country that has one of the most liberated telecommunication systems around. The 'food chain' of operators and conveyance of calls is similar to that prevailing in the UK yet we have no need for this subsidy. It would not be tolerated.

I have no particular wish that customers should not pay their fair share of call costs. I am happy with my plan which provides free local calls (or for those that do not like the term free, unlimited bundled calls) to any number within my calling area, be it federal, state, local government, residential or business/commercial land line, cable line, cellphone or free number. This is easy for a typical customer to understand, and works well.

If a UK customer pays GBP 20, 30, 40 per month, then one would expect that the vast majority of everyday calls not to be excluded from such a plan.

I guess we must differ on the acceptability of revenue-sharing calls for a particular service.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by loddon on Jun 2^nd, 2010 at 10:43pm

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

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

Title: Re: Ofcom consultation - Review of non-geo calls
Post by idb on Jun 2^nd, 2010 at 11:00pm

Dave wrote on Jun 2^nd, 2010 at 12:45pm:

This I fully accept, however the situation here is not drastically dissimilar. We have an arrangement known as intercarrier compensation, a highly regulated (federal and state) mechanism whereby a payment is made by one carrier to another carrier to originate, relay and terminate a given call (the 'food chain'). This compensation comprises two elements - access charges and reciprocal compensation. The main difference between the US and the UK, as far as I can see from my limited understanding of intercarrier compensation is that it is not skewed against the consumer. The UK system is broken and needs fixing. I come back to my earlier assertion that a typical end-user is not the slightest bit interested in the conveyance mechanisms for a call originating in London and terminating in Glasgow, or from a call originating in Miami and terminating in Seattle.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by idb on Jun 2^nd, 2010 at 11:23pm

loddon wrote on Jun 2^nd, 2010 at 10:43pm:

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

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

Title: Re: Ofcom consultation - Review of non-geo calls
Post by Dave on Jun 3^rd, 2010 at 12:10am

SilentCallsVictim wrote on Jun 2^nd, 2010 at 7:08pm:

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

... the fundamental consumer objection - calling plans exclude numbers that a customer wants to call. This is very simple.

Clearly, numbers carrying a premium (i.e. those referred to as being "revenue sharing") cannot be mandated as inclusive package elements where geographic/03 numbers are inclusive. If that were to be the case, then there would be a surge in organisations and individuals getting premium numbers as they can be paid revenue share and callers won't pay any more.

There would also be people getting these numbers and calling themselves to generate revenue from a zero-fee call. This is known as "Artificial Inflation of Traffic" or AIT.

SilentCallsVictim wrote on Jun 2^nd, 2010 at 7:08pm:

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

I believe that it is fundamentally wrong for Ofcom to define what calls may be included in packages, without a sound reason. Such a reason exists with 03 ...

I respect your point, although I'm not sure where I stand. The following points are worth considering:

The 0870 range now doesn't carry a premium or subsidy to number users, but it's not included in packages. This means that the charge to recipients (users) is the same as with 03 numbers. Thus, there is no reason why any right-thinking organisation would want an 0870 number when 03 numbers are on offer.
Certain number ranges tend to be populated largely by businesses and other organisations (i.e. non-residential numbers). Where a non-premium non-geographic range isn't part of an inclusive package, the annoyance and frustration of business calls costing more will continue and hence the need for subscribers to look-up alternative numbers in our database.

The suggestion that the cost of an inclusive package will have to increase is a valid one, but how is this a reason not to include calls? The calls will be made regardless and consumers will continue to be aggrieved at having to pay extra to phone their bank or insurance company.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by Dave on Jun 3^rd, 2010 at 12:20am

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

Why do we need to have this subsidy? Why did this subsidy gradually increase from zero to virtually every commercial and public sector body? Who decided that this subsidy was necessary? …

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

It was Oftel that decided this subsidy should be available.

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

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

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

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

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

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

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

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

Title: Re: Ofcom consultation - Review of non-geo calls
Post by Dave on Jun 3^rd, 2010 at 12:34am

idb wrote on Jun 2^nd, 2010 at 11:23pm:

I will pose a question or two to those who support the continuance of CPP model. …

As I say, the amount that the calling party pays for premium/NTS (that is, the amount the caller's telco hands over to the receiver's telco) is by and large related to BT's retail call prices as opposed to the amount it costs the telco operating the receiver's number. I understand that the latter method is how the 0.5 pence per minute for landline calls is arrived at.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on Jun 3^rd, 2010 at 3:27am

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

I guess we must differ on the acceptability of revenue-sharing calls for a particular service.

Not necessarily.

We differ insofar as I do not believe that it is the responsibility of Ofcom itself to make a determination about what are the circumstances in which a caller can be invited to consider whether or not to make a particular call. The crucial issue is that where a premium charge is involved, the caller is made aware of the existence, and guided as to the amount, of the premium. That is Ofcom's responsibility. In my response to the consultation, I both lay out this principle and propose a regulatory mechanism that could be used to implement it in the market that currently exists.

The present regulatory structure is many years behind the times, in that it is based on the assumption that BT is the only provider of telephone services and that all of its charges are regulated. In that context neither 0845 nor 0870 were CPP services. The former provided both a discount to callers and a subsidy to users. This is of course now so far from the truth that it does indeed appear to be ridiculous. 0870 has been addressed, with failings that must be corrected, 0845 (in its present form) must now be ended also. Ofcom has been disgracefully tardy in getting to grips with this issue, however I believe it is now set to act.

I write at length about 0844/3, making the point that consumers who "require" the benefits which this facility offers, in general, have to make a case for its continuation as a feature of the National Numbering Plan. History suggests that a case has been accepted in the past, however I believe that it has to be argued strongly against the valid objections which exist and are themselves argued strongly. These objections are over and above the vital issue of cost transparency, which must be addressed anyway. (I urge those who press these objections to do so on the assumption that a fair degree of transparency has been achieved, so it cannot be said that this alone will remove their concerns.)

Moving further up the call cost scale, determination about the validity of a CPP service should rest with Phonepay Plus, which has the responsibility of
being the self-regulator of those who derive a living from CPP services. Maintaining the integrity of the industry represented by its membership, it has a proper right to exclude those who it believes are not truly offering a valuable service. Its capacity to perform this role has been undermined by adding in users of 0871/2/3 numbers to this membership. In general these are not organisations in the same market as any true PPP member, they are simply gaining a little subsidy from callers towards the costs of running their call centre operations. The self-regulatory model does not work for these cases, however no other is presently available under the terms of the Communications Act 2003.

0871/2/3 is now already in the PRS scheme, I have no alternative regulatory model to propose. I would be delighted to hear of other suggestions and how these could be put into effect. For the time being, I propose that the clearest possible means of advising potential callers of the cost of a call, in an open market for telephone services, be compelled by regulation, so that the issue can be addressed properly - between the seller and the buyer.

Ofcom's duty to consumers is not to run the market, by setting fair prices or determining what may be sold, but simply to ensure that it functions. We may not be happy with this role and wish to propose amendments to the Communications Act, however that is not something that Ofcom can do and so such discussion may be better kept separate from a thread focussed on an Ofcom consultation. I personally find myself kept very busy in trying to get Ofcom to comply with the provisions that already exist in the Act. Seeking to amend the largest item of legislation every passed by the UK parliament, and perhaps some of the competition legislation both local to the UK and derived from EU Directives may be a worthy aim, but it is a sizeable challenge.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on Jun 3^rd, 2010 at 3:48am

The preceding remarks were prepared before I lost internet access for a period, several replies back. Apologies if they are rendered irrelevant by subsequently posted contributions that address the same points in a different way.

Dave wrote on Jun 3^rd, 2010 at 12:10am:

A totally fair point. This is however a matter that could be fully addressed by the market. I see no reason for Ofcom to intervene, as this will always have the potential for creating all manner of unintended and undesirable consequences.

Arguments about what telcos might or should do to meet the needs of customers in a competitive market is very different from what Ofcom should compel by regulation. By suggesting that Ofcom should not intervene to force a particular effect, I am not arguing that the effect should not happen naturally. Where consumers have a choice of provider, perhaps it is a good thing that some offer widely inclusive packages, whereas others are more limited. The vital need is to remove the distorting NTS condition from BT and ensure that the greatest possible transparency in pricing is achieved.

A disappointing footnote for those who responded to the consultation hoping for Ofcom to introduce new regulations in the Autumn is found in an announcement from the Department for Business.

Quote:

Business Secretary Vince Cable said:

“The deluge of new regulations has been choking off enterprise for too long. We must move away from the view that the only way to solve problems is to regulate. ..."

I will continue to argue that the regulatory changes which I propose are supportive of enterprise, essential in the interests of a properly competitive market and simply a suitable and long-overdue replacement for legacy regulations that have been harming both business and the proper interests of consumers.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by idb on Jun 3^rd, 2010 at 1:16pm

Dave wrote on Jun 3^rd, 2010 at 12:20am:

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

Why do we need to have this subsidy? Why did this subsidy gradually increase from zero to virtually every commercial and public sector body? Who decided that this subsidy was necessary? …

Poor choice of words on my part. What I meant was the use of this subsidy gradually increased from zero to a point where subsidy numbering is virtually an automatic choice. Thanks for the clear explanation of the current situation. I am trying to find out the equivalent payments for the system in place here.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on Jun 3^rd, 2010 at 2:06pm

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

The response from IPV6 has a few discussion points

When responding to the limited quoted extracts from this contribution to the consultation, I may have been unfair to IPV6 Ltd, as reading the full consultation response does (sort of) answer my question.

Quote:

National Price Plan
We believe it is in the general interest of all parties and consumers if Ofcom were to consult on the forming of a National Price Plan, (drawing from the pricelists which are commonly known as ‘costs from a BT landline’) and introduce legislation which would prohibit any originating network or point from charging more than the National Price Plan for any call.

This is a familiar argument from those who benefit from the use of revenue sharing numbers. They argue that the cost should be carried by the originating telephone companies, rather than callers. There are indeed many who would support this view, arguing that telephone companies have lots of money and so they can be expected to readily drop some of their prices, without there being any adverse impact elsewhere.

Those who have progressed from a kindergarten understanding of business and economics will see the weakness in this basic argument and reject it. Those more advanced may attempt to resurrect it by arguing about the effect of competition. I would argue that whilst there may be such an effect, it does not guarantee that an enforced reduction of income in one area will not be made up in another.

There is certainly nothing that Ofcom can do to ensure that this does not happen. The regulated "costs from a BT landline" are set on the basis that BT does not make a proper margin on these calls. (Incidentally, this kills the economist's other argument about lower prices leading to higher volumes and potentially greater net income - because there is no net income at the prices referred to.) As BT continues to make an acceptable level of profit on its turnover, one must assume that this is being disproportionately obtained from its margins on other activities.

(As it has been determined that BT no longer holds SMP, Ofcom loses its capacity to look inside its books so as to be able to try and fix things in this way. It is highly unlikely that Ofcom would get away with reversing this determination and doing the same with all other providers. Oddly, Ofcom is trying to do the same with the mobile telcos in relation to the MTR, but I have my doubts about whether it will succeed as it intends; it may have to achieve the reductions by a slightly different route.)

Returning to IVP6. It is somewhat odd to see an argument for swinging price control preceding an impassioned claim that "the telecommunications industry has to be allowed to make a legitimate and healthy profit".

I am not sure if the author is characterising themselves as being amongst the "small (but vocal) minority" alleged to be failing to show "due regard for the telecommunications industry and the staff that work within". I suspect that, like many respondents, they are just a bit confused by these complex issues. It could be unfair to suggest that they are presenting themselves as representing "the telecommunications industry", despite the fact that they are attacking the interests of the originating providers, whom most of us would see as being part of that same industry. On the other hand, this could be exactly what they are doing.)

In effect, those who benefit from revenue sharing calls and argue for retail price controls are suggesting that their financial benefit be derived from telephone users in general, rather than those who call them. This to me is an outright admission that they cannot justify the benefit that they are receiving, and wish to see the cost diluted and thereby hidden. In the interests of transparency, as well as for the sake of the telecommunications industry being "able to employ people, compete, expand and continue investing in ‘the network’", this suggestion should be rejected.

I strongly beleieve that if receipients are to benefit from a subsidy then this must be openly reflected in the price that their callers pay. I see no justifiable basis for Ofcom compelling this to be funded in some other way.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by NGMsGhost on Jun 3^rd, 2010 at 2:39pm

I see that even on a sunny summer day that SCV does not seem to have more productive things to do with his time than enter in to his usual long and impenetrable discourses on this website. :P

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on Jun 3^rd, 2010 at 3:14pm

I see that even on a sunny summer day that NGMsG does not seem to have more productive things to do with his time than offer helpful and profound responses to long and impenetrable discourses on this website. :P

Title: Re: Ofcom consultation - Review of non-geo calls
Post by sherbert on Jun 3^rd, 2010 at 3:20pm

NGMsGhost wrote on Jun 3^rd, 2010 at 2:39pm:

I see that even on a sunny summer day that SCV does not seem to have more productive things to do with his time than enter in to his usual long and impenetrable discourses on this website. :P

Down in my neck of the woods, the NHS have found a very good way to save a huge amount of money. When you have an operation in our local hospitals they have now done away with the need of having an an anaesthetist. Before having an operation, they give you SCV's posts to read and they will always send you to sleep! ;D

Title: Re: Ofcom consultation - Review of non-geo calls
Post by loddon on Jun 16^th, 2010 at 10:26am

Quote from SilentCallsVictim on Jun 13th, 2010, 3:41pm:

Quote:

I would not go so far as to say that the provisions it has put in place on pricing for calls to 0870 numbers amount to "encouragement of", "participation in" and "supervision of" a scam. I understand that no complaints about breaches of the relevant regulations have been received. I imagine that any member who had identified such a case would have drawn our attention to it in this forum.

I thought they had requested responses to a consultation. That they have not received specific complaints does not mean that there is no problem. Surely it is their job as regulator to monitor what is going on. If they took any notice at all of petitions on the Prime Minister's website, articles and comments in the press and media, comments in Parliament about 08 numbers being a "rip-off", the very existence of this website as well as much of the discussion in this Forum they would realise that there is a big problem with 08 Rip-off numbers and action needs to be taken.

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Because the present situation makes use of a 0870 number pointless (with both users and callers paying more), one must assume that over time they will disappear. Announcing that they will be changed to be the same as 03 would give them a new lease of life, including through the period before such a revised regulation came into effect.

I agree that 0870 numbers are now pointless except for those phone companies that choose to profiteer shamelessly while they still exist -- so Ofcom should do something about a scam on the public.

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I take serious issue with those (notably idb) who suggest that it should be for Ofcom or Phonepay Plus to determine what type of call may be subject to a relatively modest surcharge to the benefit of the recipient. Expecting Ofcom to assess every case to see if there is an "added value element" and if the charge incurred by callers is proportionate and proper, might be easy for NHS providers (for whom no charge can be proper) and a few other cases, but would be a nightmare in many others. I do not believe that Ofcom would be able to reject all such applications, as some may suggest it would. I am not even sure where it could find the statutory basis for the exercise of any such regulation.

I think that idb may be referring to dial-up internet access as possibly a valid "added value service" and I accept that maybe some provision should be made for such, but I don't pretend to know what. Some sort of pre-call price announcement could be one of the measures required. Surely Ofcom would not have to "assess every case"? Instead it could just define those added value services which are justified and rule out all others. My point is that most of these numbers are used in a way which does not add value for the caller. All the benefit accrues to the user company and therefore it is they who should pay for it as they do with 03 numbers.

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Ofcom has a duty to all consumers of telephone service, and that includes users of 084/087 numbers. If they can make a case for continuation of this benefit, then I cannot see how Ofcom can deny it, unless it can be shown to be "unfair" in terms that would survive legal challenge. The fundamental issue at present is the lack of transparency of the surcharge incurred by callers. If Ofcom were able to address that, as I propose that it could, then the situation should be able to right itself.

Provision of transparency would not resolve the fundamental issues with these rip-off numbers, the opportunity for scams, the incentivisation towards inefficiency and the fact that the callers are being forced to pay for a service which they are not receiving. The whole concept is fundamentally flawed and deceitful. Most ordinary people don't know why these numbers are so expensive, do not know that they are paying money over to the receiving company and are given no choice in the matter. Why do you think this website is so popular?

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I do not believe that 0871/2/3 should have been classed as PRS under the present regulatory regime. After all the work that was done to achieve this, however, I cannot see how Ofcom could be expected to change its mind, reverse the situation and take a step in a different direction. I regret the fact that some would therefore see whatever measures it does take as being insignificant in the context of what will be determined to be a "COMPLETE FAILURE".

Ofcom will be a "COMPLETE FAILURE" if it fails to take action to prevent the phone service industry from continuing to rip-off the public. They are having a review so now is their opportunity to put right a long standing wrong and a continuing scam of the British public.

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In the present political climate, we can have little hope for additional sweeping regulatory burdens being imposed on any industry. I believe that we should focus on openness and transparency, as I see this as an achievable objective that would resolve many of our concerns. In particular, I believe that it would nail the issue of NHS providers (GPs, Hospitals ) using revenue sharing 084 numbers, without having to draw Ofcom into a position of partiality between one group of telephone service users and another.

I am all for openness and transparency and I am not suggesting increased regulatory burdens. I just want Ofcom to put right a serious wrong.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by loddon on Jun 16^th, 2010 at 10:34am

This post and the previous one are copied from another thread where some of us veered slightly off topic so I have copied my points over here to where they belong. I expect that the debate about Ofcom's Consultation will continue for some time! :)

Quote from Dave on Jun 13th, 2010, 4:33pm:

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Quote from idb on Jun 12th, 2010, 3:16am: [quote]..... my own position is that, generally, the cost of handling everyday general-purpose telephone calls (banks, transportation, utilities etc) should fall on the recipient and not on the originator unless there is some significant added-value element.

Quote from loddon on Jun 13th, 2010, 8:23am:

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Hear Hear idb. This is absolutely my position and what I submitted to Ofcom for their recent consultation "Review of Non-Geographic Calls Services". See my posting #5 here http://www.saynoto0870.com/cgi-bin/forum/YaBB.cgi?num=1272746772/0
I totally agree with this quote and the quote within it.

The fact that the likes of Virgin Mobile has increased the cost of calling 0870 numbers when last August it could have reduced them without loosing out seems to me to be a symptom of the market in that there is no natural competitive forces to achieve this. Likewise, most of the fixed line providers that chose not to pass on savings to callers.

As I said previously, there are consumers at both ends of the chain (i.e. callers and receivers are both consumers) and the regulator must act in the interests of both.

On the basis of where we are now, I cannot see how the regulator can be deemed a "complete failure" if it doesn't rule that 0843/4/5 and 0871/2/3 numbers be charged inline with 03 numbers. It must consider the interests of the consumers of those telephone numbers (banks, insurance companies etc) who will loose subsidy of their services or face the cost of migrating to other numbers.

What's more, these numbers have been in existance for over 10 years now and were born by Ofcom's predecessor, Oftel.

The current regulation is known as the NTS Condition and I explained how this came about earlier this month, although I didn't mention it by name. Basically, the said regulation was introduced in 2003 as BT had been found to be a dominent originating provider.

Essentially, it gave the advantage to receiving telcos (and their customers) at the expense of callers (those not with BT). Perhaps the regulator at the time had no other option but to do this. However, I say that it was then (or prior to it) that it started to go wrong and why we are where we are.[/quote]
Thanks Dave for your explanations and your support, at least in part, of my position that it is the receivers of the benefits of NTS Services who should pay for them and not the callers.

Your point about Virgin Mobile supports my case for the need for Ofcom action. I am a customer of Virgin Mobile and I would not know about this price increase if it were not for the good people of this website bringing it to our attention. Virgin haven't notified me! Clearly there is a lack of competition to hold down prices so Ofcom need to take action.

I agree that the regulator must act in the interests of both callers and receivers. I feel that under the present regime callers are not being protected from scams.

"Banks, insurance companies etc" are part of the problem and are being allowed to rip-off callers by taking money from them for which there is no legitimate basis as far as I can see. Where in any phone service contracts does it say that a caller must pay part of the cost of a call over to the call receiver? What choice does the caller have to avoid such a charge or to negotiate the cost in order to get a better service for himself? 08 numbers are a rip-off in concept and should be brought into the same charging mechanism and rules as 03 numbers.

Having been in existence for 10 years a rectification of the current scandal is long overdue. The length of time over which a rip-off has been allowed and encouraged is no justification for allowing it to continue.

Your links to the regulations are interesting but I find it difficult to understand what is written. However, I found no reference to revenue sharing and how it is regulated. It is not the job of ordinary phone service users such as me to read and understand all the regs and machinations of the internal workings of the industry. That is why we have Ofcom who are supposed to be acting to protect us!!

Title: Re: Ofcom consultation - Review of non-geo calls
Post by loddon on Jun 16^th, 2010 at 1:07pm

All the responses to the Ofcom Consultation on non-geographic calls services have now been published on the Ofcom Consultations website here :---

http://www.ofcom.org.uk/consult/condocs/ngnservices/responses/

Surprisingly there are only 42 responses in total. The major phone services suppliers such as BT, Cable & Wireless, BSkyB, O2, Orange, T-Mobile, Talk-Talk and Vodaphone have responded. Disappointingly, it appears only two of the regular contributors to this Forum have responded, particularly as the BT Response mentions the "high profile saynoto0870 campaign" as being influential.

I recommend that members read as many of these responses as they can and comment and draw attention to important points by posting in this Forum where we may debate them with a view to submitting our views to Ofcom on some future date. We have a significant influence on the non-geographic industry, as the industry and Ofcom itself admit, so let us try and use our influence on this and the following reviews now that we have a unique opportunity.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on Jun 16^th, 2010 at 6:57pm

This article is on a particular issue covered elsewhere in the forum: Ofcom sides with mobile operators on 0845 - The Register 14 June 2010

Some of the observations and many published comments (not mentioning any names ;)) pick up on the points that are highly relevant to this thread.

One comment aims to draw the two issues together. (OK, some of us do work under many names, including in places where a particular alias may sometimes appear unusual and therefore have to be temporarily set aside.)

For those tempted to review one of the larger consultation responses, I repeat my tips and recommend use of the link offered in the posting quoted below. (The document is easier to jump through and read with an index in the margin. This technical feature was lost on re-publication.)

SilentCallsVictim wrote on Jun 2^nd, 2010 at 6:13am:

Title: Re: Ofcom consultation - Review of non-geo calls
Post by loddon on Jun 17^th, 2010 at 2:43pm

One of the submissions to Ofcom is by Powwownow, a Conference Call Service provider.
http://www.ofcom.org.uk/consult/condocs/ngnservices/responses/via-vox-powwownow.pdf

They appear to offer a genuine added-value service making use of 0844 numbers and it seems to me that if ever there is a sensible and legitimate use for 0844 and it's charging mechanisms then this is it. Whilst I am resolutely opposed to the exploitative use of 0844 and other 084/7 numbers by Banks, Insurance, Retail etc companies and Government Departments I can see the benefits of the type of service provided by Powwownow.

My conclusion from this is that Ofcom need to work out some way of allowing legitimate added-value services such as this to continue to operate and for other valid services to be innovated and added whilst at the same time prohibiting the disgraceful exploitation of the 0844 range by the vast majority of the companies and organisations that are ripping us off.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by loddon on Jun 17^th, 2010 at 2:53pm

Following on from my previous post it is interesting to see what Powwownow have to say about the way the industry is confusing and mistreating the consumer:

http://www.ofcom.org.uk/consult/condocs/ngnservices/responses/via-vox-powwownow.pdf

I have selected just a few of Powwownow's comments which illustrate just what a mess this industry is in and substantiate our long held feelings that the industry is malevolent, greedy, profiteering and deceitful and is desperately in need of proper regulation.

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Extracts from Powwownow submission to Ofcom
Powwownow is a conference calling brand running a large conference call service in the UK.

The market is damaged by the freedom for originating networks to set their own price for a call to special services numbers. The range of these prices is so great that consumers are uncertain how much a call to a special services number will cost.

Special services numbers are infrequently called (compared with normal Landline and Mobile numbers); therefore do not make up the buying decision for telephone packages. As they are not part of the buying decision market forces are not driving prices down – indeed network operators are using the uncertainly of the pricing to create excessive charging plans for their customers.

As the market is not working Ofcom should extend the scope of the regulation framework for these numbers to set a retail price.

"How much do 0843/4 calls cost? Calls are typically charged between 1p and 12p per minute for landline customers. Calls from mobile phones are typically charged between 20p and £1.50 per minute, depending on the provider and the number called"...Ofcom.

There is a lack of certainty over the cost of a call. With a percentage difference between providers of nearly 2,000%, consumers are confused.

The disincentives are related to deliberate confusion from mobile network providers in communicating the cost of the service.

For 0844 numbers we believe that the retail price of the call is very difficult to determine for a consumer.

While it is the case that these numbers are more expensive to provide that standard landline calls (as there is an outpayment to make) there is no justification for the mark-up that is being made over the cost of a standard outbound call.
If BT can make an acceptable return on 0844 calls other operators should be able to offer the same service on the same terms.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by Dave on Jun 17^th, 2010 at 5:09pm

Powwownow is essentially calling for the regulations that apply to BT to be extended to all other originating communication providers for their "special" numbers. What it wants is for the retention by OCPs on these calls to be kept to a bare minimum to pay for the service.

This principle is fundamentally flawed as OCPs will simply pass back to their customers (callers) the charges they incur in connecting calls by increasing line rental charges and the cost of other types of call etc. Such a move would also make "special" service numbers more attractive as they will then be cheaper to call from non-BT OCPs.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on Jun 17^th, 2010 at 5:58pm

loddon wrote on Jun 17^th, 2010 at 2:43pm:

... My conclusion from this is that Ofcom need to work out some way of allowing legitimate added-value services such as this to continue to operate and for other valid services to be innovated and added whilst at the same time prohibiting the disgraceful exploitation of the 0844 range by the vast majority of the companies and organisations that are ripping us off.

I am pleased to read this open-minded conclusion and a well made point.

Powwownow are perhaps amongst only a small minority of 0844/3 users who are content to declare the (relatively modest) amount that they earn from calls to subsidise the cost of an appreciated and properly charged-for service. I believe that all the call providers should be made subject to suitable and equal regulation in respect of surcharge limits, so that Powwownow and other service providers could offer their services more reasonably. If this was associated with a proper basis for transparency of call charges (i.e. declaration of the surcharge limits that were in place) then the rip-offs would be exposed and thereby more readily dealt with.

There will always be deliberate cheats and bare-faced liars. Proper knowledge of the existence of the premium would however deal with public bodies and major enterprises. They would either have to justify the surcharge or cease benefiting from it.

I propose that after a big transparency shake-up (including removal of revenue sharing from 0845, and the option for the consequent migration of some to 0844/3 with an honest declaration of benefit and cost to caller) Ofcom should review the situation that remains. We can all speculate as to what that may be; I would wish to reserve judgement.

Dave is right to point out that when Powwownow moves on to its own suggestion of a solution, it makes a false supposition -
"If BT can make an acceptable return on 0844 calls". BT is currently explicitly prohibited from doing so; it is currently forced to cross-subsidise the costs of originating 0844 calls.

In a competitive market, cross-subsidy will always exist. There may be situations where Ofcom has to intervene to prevent or compel it. These interventions however must be rare, properly applied without ill effects that are greater than than the wrong being addressed, and always clearly justified. Powwownow attempts to make a case for enforced cross subsidy of NGCS whilst attacking the cross-subsidy that is working on the opposite direction on mobiles. I believe that innovation in NGCS has received quite sufficient encouragement through the regulation of BT charges and NGCS must now openly pay their way. The mobile providers must be compelled to recognise their duty to the NGCS Service Providers who bring them business and the overall need to provide pricing transparency.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by loddon on Jun 17^th, 2010 at 7:05pm

Quote from SCV

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There will always be deliberate cheats and bare-faced liars. Proper knowledge of the existence of the premium would however deal with public bodies and major enterprises. They would either have to justify the surcharge or cease benefiting from it.

The problem is how long would it take for the unjustified surcharges to be exposed and then dealt with. Given our previous and recent experience it would take from many years to forever. We need the new NTS regime to be right from the beginning.

My thinking on a possible solution is slightly different and is guided by the principle that "he who benefits must pay the premium".

So in the case of a valid value-added service such as a conference call, for example, I am content to see the callers pay, but in all the other cases then the "user" must pay the premium while the caller should only pay at his normal geographic rate.

This suggests to me that perhaps there should be two types of low-premium (not 09) NGN numbers. Type A will be where the "user" pays the premium and Type B where the "caller" pays the premium. If these Types are accompanied by the transparency which you advocate then we could see a properly regulated solution which will allow the NTS industry to earn a legitimate crust while callers, consumers, the public are protected from rip-offs. Ofcom will of course have to define the rules which determine which service types are allowed to use which "Type" of NTS classified number.

This would eliminate the "deliberate cheats and bare-faced liars" and lesser evil doers at an earlier stage and prevent years of unnecessary ripping-off before an overcharging "user" is dealt with.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by Dave on Jun 17^th, 2010 at 10:06pm

loddon wrote on Jun 17^th, 2010 at 7:05pm:

This suggests to me that perhaps there should be two types of low-premium (not 09) NGN numbers. Type A will be where the "user" pays the premium and Type B where the "caller" pays the premium. If these Types are accompanied by the transparency which you advocate then we could see a properly regulated solution which will allow the NTS industry to earn a legitimate crust while callers, consumers, the public are protected from rip-offs. Ofcom will of course have to define the rules which determine which service types are allowed to use which "Type" of NTS classified number.

Your "Type A" already exists in the form of 03 numbers. I don't see why you infer that they are premium numbers though.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on Jun 17^th, 2010 at 11:06pm

loddon wrote on Jun 17^th, 2010 at 7:05pm:

This suggests to me that perhaps there should be two types of low-premium (not 09) NGN numbers.

I believe that what is proposed is actually met by 03 and (originally) 084/087 numbers. With the former the recipient pays the full cost of the NG services, with the latter the caller pays and perhaps a little bonus as well. 0870 (fully) and 0845 should come out; 0871/2/3 have already been classified in essentially the same was as 09, albeit with slightly different regulatory requirements. This leaves 03/0845/0870 as Type A, with 0844/3 as Type B. Do we then extend to B₁, B₂, B₃ etc. with more refined determinations.

My difficulty is with the suggestion that a single body should sit in judgement on what is good value for money as a "Service Type", and therefore an acceptable use for 0844/3, or for that matter the different grades of PRS. I believe that the caller should be made clearly aware of the status and cost and therefore able to make their own decision. How would one feel if Ofcom judged a particular case to be acceptable, thereby enabling the user to declare it as being "approved", when one did not agree?

Furthermore, as I would understand it, Ofcom could only be expected to be able to rule in relation to the facilities provided, not to the propriety of a charge in the broader commercial context, including the way that a NG call service it was described in promotional material.

The classic example is the basic fault reporting service from a provider of computer equipment - we would not expect to pay a premium to call this number (Type A). Additional technical assistance, which provided advice on the configuration and use of third party accessories and software, would perhaps be thought reasonable to be a chargeable service (Type B). That is the easy bit. I do not agree that any useful purpose would be served in having Service Providers potentially getting into long legal arguments with Ofcom over the grey area that may exist between these two. The simple cases should be obvious, I see the more complex cases as being as being best resolved between the Service Providers and their customers.

As for timing, how long would it take for the definitions of the various "Service Types" to be agreed? How long thereafter for existing users of these numbers to have to apply for and be granted approval to continue using their numbers? How long then for the appeals against Ofcom's refusal to be heard by the relevant tribunals?

Ofcom could announce in September a proposal for 0844/3 to be re-classified on the National Numbering Scheme as "Premium Rate (lower) - up to 5p per minute above standard tariff rate", or something similar. That would give us 6 months in which to use this announcement to ensure that NHS GPs gave them up.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by loddon on Jun 19^th, 2010 at 4:42am

Dave wrote on Jun 17^th, 2010 at 10:06pm:

Your "Type A" already exists in the form of 03 numbers. I don't see why you infer that they are premium numbers though.

Agreed, 03 numbers are of Type A. There may need to be other ranges allocated to Type A in order to provide enough numbers to meet the needs of the market.

The distinction is that the "premium" is paid by the "user" (Bank, Insurance company, Government Department) instead of the caller. The caller pays his normal geographic rate. The "user" is paying for the benefit of the NTS service which the user is receiving.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by loddon on Jun 19^th, 2010 at 5:09am

SilentCallsVictim wrote on Jun 17^th, 2010 at 11:06pm:

Do we then extend to B₁, B₂, B₃ etc. with more refined determinations.

I don't think so; that would be too complicated.

SilentCallsVictim wrote on Jun 17^th, 2010 at 11:06pm:

My difficulty is with the suggestion that a single body should sit in judgement on what is good value for money as a "Service Type", and therefore an acceptable use for 0844/3, or for that matter the different grades of PRS. I believe that the caller should be made clearly aware of the status and cost and therefore able to make their own decision. How would one feel if Ofcom judged a particular case to be acceptable, thereby enabling the user to declare it as being "approved", when one did not agree?

I envisage that Ofcom will have to set clear defining rules as they have already done for certain services which are compelled to use the 09 range.

SilentCallsVictim wrote on Jun 17^th, 2010 at 11:06pm:

Furthermore, as I would understand it, Ofcom could only be expected to be able to rule in relation to the facilities provided, not to the propriety of a charge in the broader commercial context, including the way that a NG call service it was described in promotional material.

Ofcom would make the rules which would determine whether a "user" could charge callers for the call or not.

SilentCallsVictim wrote on Jun 17^th, 2010 at 11:06pm:

The classic example is the basic fault reporting service from a provider of computer equipment - we would not expect to pay a premium to call this number (Type A). Additional technical assistance, which provided advice on the configuration and use of third party accessories and software, would perhaps be thought reasonable to be a chargeable service (Type B). That is the easy bit. I do not agree that any useful purpose would be served in having Service Providers potentially getting into long legal arguments with Ofcom over the grey area that may exist between these two. The simple cases should be obvious, I see the more complex cases as being as being best resolved between the Service Providers and their customers.

Agreed.

SilentCallsVictim wrote on Jun 17^th, 2010 at 11:06pm:

As for timing, how long would it take for the definitions of the various "Service Types" to be agreed? How long thereafter for existing users of these numbers to have to apply for and be granted approval to continue using their numbers? How long then for the appeals against Ofcom's refusal to be heard by the relevant tribunals?

I would like to see Ofcom set the rules and for all 08 premium charges to be paid by the "users" now in order to stop the current rip-offs. Users would have to appeal if they wanted to.

SilentCallsVictim wrote on Jun 17^th, 2010 at 11:06pm:

Ofcom could announce in September a proposal for 0844/3 to be re-classified on the National Numbering Scheme as "Premium Rate (lower) - up to 5p per minute above standard tariff rate", or something similar. That would give us 6 months in which to use this announcement to ensure that NHS GPs gave them up.

GPs should be giving up their use of 084 numbers now under their amended contract with the NHS. Nothing further needs to change before GPs take the necessary action.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on Jun 20^th, 2010 at 6:38am

Rather than extending a private exchange, I will attempt to move the discussion on.

Many consultation respondents propose that call charge price limits be set for all providers in respect of all revenue sharing numbers (including PRS, 118 etc.). It would be interesting to know what views members have.

It is well argued that some type of limit is essential in the interests of service providers (users of revenue sharing numbers), their telcos and callers. Originating telcos argue that they must have the freedom to set their tariff rates as best suits the needs of their customers.

I suggest a number of considerations:

Should the limits be the same as those currently imposed only on BT?
Should a pence per minute limit be irrespective of call setup fees, package fees etc. or if not, how should these enter into the equation?
Should the limit be expressed as an absolute value, or as a surcharge over the cost of a geographic call, or some other base point?
Should there be different limits for landlines and mobiles to reflect the different ways in which these are paid for?
How should any limit reflect the amount which the originating telco pays on to the terminating telco?

My own proposals are published in my consultation response. Perhaps the most radical element of my proposal is that there should be a declared "standard call rate", as the basis for a limited surcharge. This avoids the undesirable effect of Ofcom actually setting retail prices.

I propose that the "standard rate" need not be the same as the cost of a 01/02/03 call. I see this as essential in order to allow discounting of some or all 01/02/03 calls in general or at particular times, and the option to offer them in limited bundles or unlimited packages. I see no good reason why each provider should not be free to set its "standard call rate" (including a call setup fee if it wishes), as well as its line rental fee, at whatever level it chooses. I see the essential issue as being that the (maximum) level of the surcharge for each type of "premium rate" call is common and transparent.

My other, related, possibly radical proposal is that calls subject to a maximum surcharge of zero (0845, 0870 and 080) should not have to be offered on exactly the same terms as 01/02/03 calls. This is so as to allow greater potential for discounting, bundling and packaging of some or all 01/02/03 calls.

Please understand that I do not necessarily oppose that which I would not wish to see compelled.

BT customers already pay more for their packages because many more calls (all 0845 and 0870 calls) may be made under their terms; I have no desire to see other operators compelled to follow the same course, however if they do so in response to demand from their customers or market pressure I cannot object.

If a mobile operator wishes to increase its rates for calls to geographic numbers and reduce those for 084/087 calls so as to remove the cross-subsidy currently being provided then it should be free to do so; alternatively it could set its "standard rate" well above that applied to geographic calls, so as to maintain the status quo. I do not believe that it is for Ofcom to specify which course should be followed, Ofcom should simply ensure that the "standard rate" is declared as an essential item of pricing transparency.

Telcos should be answerable to their customers first, the market second and Ofcom only if both fail, or if the market needs tweaking. At this stage a longstanding powerful market intervention has long been obsolete and is increasingly damaging and needs to be renewed.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by loddon on Jun 22^nd, 2010 at 8:47am

SilentCallsVictim wrote on Jun 20^th, 2010 at 6:38am:

I think this is a good idea and that the "standard call rate" should be the supplier's normal geographic rate including the geo rate for calls included in their packages, i.e. zero.

SilentCallsVictim wrote on Jun 20^th, 2010 at 6:38am:

I propose that the "standard rate" need not be the same as the cost of a 01/02/03 call. I see this as essential in order to allow discounting of some or all 01/02/03 calls in general or at particular times, and the option to offer them in limited bundles or unlimited packages. I see no good reason why each provider should not be free to set its "standard call rate" (including a call setup fee if it wishes), as well as its line rental fee, at whatever level it chooses. I see the essential issue as being that the (maximum) level of the surcharge for each type of "premium rate" call is common and transparent.

Yes the "premium rate" must be declared.

SilentCallsVictim wrote on Jun 20^th, 2010 at 6:38am:

My other, related, possibly radical proposal is that calls subject to a maximum surcharge of zero (0845, 0870 and 080) should not have to be offered on exactly the same terms as 01/02/03 calls. This is so as to allow greater potential for discounting, bundling and packaging of some or all 01/02/03 calls.

If revenue sharing is disallowed on 0845 and 0870 what is the point of them? To my mind it is essential that they cannot charge callers more than the geo rate for these numbers and they must be included in packages.

SilentCallsVictim wrote on Jun 20^th, 2010 at 6:38am:

BT customers already pay more for their packages because many more calls (all 0845 and 0870 calls) may be made under their terms; I have no desire to see other operators compelled to follow the same course, however if they do so in response to demand from their customers or market pressure I cannot object.

0870 numbers are rapidly disappearing and I expect the same for 0845 if revenue sharing is stopped. So they must be regulated in the same way as 03 numbers to stop the current stupidity where Virgin Media charge 10ppm and Virgin mobile charge 40ppm to call these numbers. There is no justification for such rip-offs and I think Ofcom is there to stop rip-offs which constitute "harm to callers".

SilentCallsVictim wrote on Jun 20^th, 2010 at 6:38am:

If a mobile operator wishes to increase its rates for calls to geographic numbers and reduce those for 084/087 calls so as to remove the cross-subsidy currently being provided then it should be free to do so

Surely this would increase the cross-subsidy?

SilentCallsVictim wrote on Jun 20^th, 2010 at 6:38am:

...alternatively it could set its "standard rate" well above that applied to geographic calls, so as to maintain the status quo.

I don't understand this.

SilentCallsVictim wrote on Jun 20^th, 2010 at 6:38am:

I do not believe that it is for Ofcom to specify which course should be followed, Ofcom should simply ensure that the "standard rate" is declared as an essential item of pricing transparency.

Surely the standard rate is their geo rate?

SilentCallsVictim wrote on Jun 20^th, 2010 at 6:38am:

Telcos should be answerable to their customers first, the market second and Ofcom only if both fail, or if the market needs tweaking. At this stage a longstanding powerful market intervention has long been obsolete and is increasingly damaging and needs to be renewed.

No, Ofcom must ensure that harm to customers/callers/civilians is prevented so they must set the rules first within which the phone companies must operate and compete. There will be plenty of opportunity for them to compete in their pricing of the premiums they charge to their 08 customers (companies and organisations) who should be paying the premiums because they are the ones who want the NTS facilities and should be paying for them.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by loddon on Jul 1^st, 2010 at 10:33am

I have sent this letter today to all available MEPs in South Central England James Elles, Sharon Bowles, Nigel Farage, Catherine Bearder, PeterSkinner and Marta Andreasen.

"EU limits Mobile Phone Roaming Charges. 1st July 2010

I see the EU has today introduced limits on phone tariffs for calls while abroad within the EU. As the EU is concerned about excessive phone charges I raise another case of excessive call charges which affects us in the UK apparently more than other countries but is a growing problem all over Europe.

I ask you if the EU should look at placing limits on the use of so called “revenue sharing” numbers also known as NTS (Number Translation Services) and “non-geographic calls services”. Ofcom, the UK regulator, held a public consultation “Review of non-geographic calls services” :--

http://www.ofcom.org.uk/consult/condocs/ngnservices/

for one month only in May 2010, and received a mere 42 responses most of these being from companies in the telephone services industry and very few from citizens/consumers. In my response I raised the fundamental issue that “revenue sharing” is a flawed concept and is unfair even harmful to consumers. It means that phone service providers take money from callers, almost always without their knowledge or agreement, and make payments to the user companies/organisations called. For these payments the phone companies provide services to the user companies/organisations such as number translation (to geographic numbers), statistics, routing, forwarding and location anonymity. Many Government Departments, Agencies, public Authorities, Banks, insurance companies and retailers routinely use these phone numbers for customers to call for normal everyday access, even making callers use these numbers to make complaints or to seek rectification of the companies' mistakes.

All these services are for the benefit of the user companies/organisations, so this means that callers are paying for services from which someone else, usually a company/organisation, benefits. To add insult to injury callers also must pay a premium to call these numbers, part of which pays the “revenue share” and part pays extra to the phone companies. In effect this is a massive scam upon the citizens/consumers. This scam, frequently referred to in Parliament as a “rip-off”, is perpetrated by the phone service industry, taken advantage of by many user companies/organisations and is entirely presided over and encouraged by Ofcom. It is particularly inappropriate that public bodies make use of such numbers. It should be stopped.

I must say that there are a small number of “added value” services which I would see as legitimate users of “revenue sharing”, sometimes referred to within the phone industry as “micro-payments” services. These would include dial through internet access and conference call services. I want to see Ofcom make rules and regulations, perhaps including a special range of numbers, for such legitimate services whilst making all the other non-geographic numbers conform to the same regulations as currently apply to the 03 range of services.

The number ranges which should be brought into line with 03 are 0842/3/4/5 and 0870/1/2/3. This would result in the charges for the NTS services being paid for by the user companies/organisations which benefit, while callers pay for their calls at their phone service providers normal geographic rates. I see 09 “premium rate” services as a different matter.

I know that this will be a very big issue for phone service companies and that their industry are likely to strongly resist any attempt by Ofcom to impose the sort of regulations which I advocate and that is why I am asking if the EU may have a role here in ensuring that “consumer harm” is minimised. Many have no doubt that this whole rip-off scam is a massive harm to citizens/consumers. The difficulty is that this is often seen as a small issue for the individual citizen/consumer as it seems initially to be a matter of only a few pence on the cost of a call, but it can sometimes amount to a very large “bill shock” when a long call involving waiting or use of a mobile phone or call box is involved. This results in lack of concerted or large scale protest by the public so the problem is played down by the phone service industry and Ofcom although there is a good deal of evidence that the public is very unhappy with these “rip-off” numbers. For example, the enormous publicity given to the minority of GPs who have started using 084 numbers, the well supported petitions against use of these numbers on the Prime Minister's website, Early Day Motions signed by over 120 MPs, the enormous number of questions raised by MPs in Parliament, and the very existence and growth of the “SayNoTo0870.com” website. Many citizens/consumers generously contribute time and research to this website as well as using it to avoid the excessive costs of calling 084/7 numbers."

Continued in next post.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by loddon on Jul 1^st, 2010 at 10:35am

Contunued from previous post.

"Ofcom have recognised to some extent that there is a problem with this type of number and the cost/charging concept because Ofcom recently banned “revenue sharing” from 0870 numbers. Unfortunately Ofcom did not regulate the charging for calls to 0870 numbers so the distasteful situation now exists where many phone companies charge an excessive premium to call 0870 for which there is no revenue share to provide justification. It is however noticeable that use of 0870 numbers by user companies/organisations is disappearing rapidly. The Ofcom position is therefore inconsistent at present where Ofcom has banned “revenue sharing” on 0870, is considering banning it on 0845 but is allowing it on 0842/3/4 and 0871/2/3. Ofcom is apparently in the process of shifting the “consumer harm” from one range of numbers to a new range.

Is this a problem the EU should be concerned about and be considering action?"

If any other members of this Forum wish to take this matter to their MEPs, or MPs, you are most welcome to make use of all or any part of this letter if you think it is helpful.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by loddon on Jul 19^th, 2010 at 6:33pm

A conference call service 03Talk which uses only 03 numbers and does not make any additional charge for its basic service is offered here :--- http://www.03talk.com/

This was brought to our notice and discussed on this thread :---
http://www.saynoto0870.com/cgi-bin/forum/YaBB.cgi?num=1279482155/4#4

It is interesting that 03Talk are able to provide such a service and earn their revenue, and profit presumably, from the 03 termination fees alone. Compare this to Powownow :---
http://www.powwownow.co.uk/Enhanced-Access/?gclid=CLbewtGH-KICFQT92AodB133lA

and ConferenceGenie http://www.conferencenow.co.uk/?utm_source=adwords&utm_medium=cpc&utm_term=%7Bkeyword%7D&utm_campaign=Conference%2BCall&gclid=CIz03sSI-KICFQGZ2AodLHe5kg

and many others which all claim to offer a "free" conference call service :) and then they say you only have to pay for your telephone calls and these are invariably using an 0844 number! :-? ::) >:( :'(

So they are not "free" at all !! Its just that some are perhaps more "free" than others and the one that seems to be most "free" of those found is 03Talk which only uses 03 numbers. :)

This all goes to show that if Ofcom were to rule that charging to callers for 084/7 numbers were to be regulated under the same rules as 03 numbers then conference calling in this way would not disappear and goes further to support my contention that all 084/7 numbers should be regulated exactly as 03 without exceptions. :)

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on Sep 13^th, 2010 at 2:32pm

Those with an eye for detail may wish to have a look at section 166 (on adobe reader page 44) of this document.

It is the full text of the BIS Consultation - Implementing the revised EU Electronic Communications Framework – Overall approach and consultation on specific issues.

If I read correctly, this is about providing confirmation of Ofcom's power to regulate charges for calls to non-geographic number levied by all providers, rather than just those from BT as is the case at present. Ofcom's authority to impose such regulation was confirmed when the EU Directive came into force late last year, so Ofcom may propose to apply such regulation when it launches it own consultation on this topic next month.

The BIS consultation is not on whether Ofcom should be granted this power.

Title: Re: Ofcom consultation - Review of non-geo calls
Post by Trenod on Sep 13^th, 2010 at 6:38pm

ng
SilentCallsVictim wrote on Sep 13^th, 2010 at 2:32pm:

If I read correctly, this is about providing confirmation of Ofcom's power to regulate charges for calls to non-geographic number levied by all providers, rather than just those from BT as is the case at present. Ofcom's authority to impose such regulation was confirmed when the EU Directive came into force late last year, so Ofcom may propose to apply such regulation when it launches it own consultation on this topic next month.

I find Ofcom's hypocrisy astonishing and quite sickening. They regulate BT's NGN charges, but insist that they are powerless to stop BT's disgusting practice of making a profit on non-direct debit payments and paper billing! (It does NOT cost as much as £1.50 to process a cheque, and certainly not for a cash transaction or one-off bank transfer. And no WAY does printing and sending out two sheets of A4 paper come to as much as £1.25!!!)

And when BT controversially moved its off-peak call time period back an hour in June (apparently to bring it into line with mobile phone operators... yeah, RIGHT! If that's the case, where on earth have they been for the last 10-15 years?!), I didn't hear Ofcom saying ANYTHING about how that move would penalise people who work Monday to Friday, nine to five (the standard working day), who obviously have no NEED for an 'Anytime' calling plan bolt-on (which was BT's smug suggestion to people who need to use the phone between 6 and 7pm).

Ofcom is nothing but a lapdog for BT - an OLD dog with no teeth! They have no real interest in protecting the consumer.

Sorry for the shouting, but both BT and Ofcom make me sick! >:(

Title: Re: Ofcom consultation - Review of non-geo calls
Post by SilentCallsVictim on Dec 16^th, 2010 at 10:21am

Quick update - the consultation on the stragic proposals is being launched TODAY - press briefing currently in progress - watch / listen to / read the media