Ofcom has, today, set out how telephone charges will be made clearer, as well as starting a consultation on the finer points.

This represents a major landmark in the campaign. The fairtelecoms news release is here (PDF).

The consultation is called Simplifying non-geographic numbers - Policy position on the introduction of the unbundled tariff and changes to 080 and 116 ranges and runs until 28^th May.

The consultation is titled Simplifying non-geographic numbers - Policy position on the introduction of the unbundled tariff and changes to 080 and 116 ranges  It  deals with the Ofcom proposals for all the non-geo number ranges --  03, 05, 070/076, 080, 0845, 0870, 0843/4, 0871/2/3, 09, 118 numbers and now the 116 numbers.

Ofcom have set a deadline of 28th May for responses to this final phase of their consultations and so we have a limited time to examine and discuss the Ofcom proposals as they have now refined them.

The proposals are quite significant in that the main idea is to introduce an Access charge and Service charge to be applied to some ranges of non-geo numbers.  This is important because this scheme will no doubt exist for many years whether it be good or bad.

A summary of the Ofcom proposals can be found here  ;---

http://stakeholders.ofcom.org.uk/consultations/simplifying-non-geo-no/summary

The whole consultation consists of several sections with advice on "How to Respond" and at least 8 supporting pdf documents and can be found here :---

http://stakeholders.ofcom.org.uk/consultations/simplifying-non-geo-no/.

It would be an onerous task to read the whole consultation, however, in my view a reading of the Summary and the pdf “Part B -- The Unbundled Tarriff” as a minimum would enable a reasonable understanding which would allow a reasoned response to be made.

I would urge readers of this Forum to look at this consultation and to post their comments on this thread with a view to formulating responses to the consultation.   I am considering and formulating my views and questions on the proposals and may post them on this thread soon.

loddon wrote on Apr 30^th, 2013 at 8:57am:

SilentCallsVictim wrote on Apr 29th, 2013 at 8:45am: loddon wrote on Apr 29th, 2013 at 6:38am: If "the fundamental problem" is the fact that the telephone bill can be used as a way of collecting money to be passed on to a third party (the person called), .... I agree that revenue sharing is a problem and should never have been allowed on 084 and 087 numbers however the fundamental problem is the premium that is charged to callers of these numbers as I have said repeatedly in postings here and responses to earlier Ofcom consultations.   The telecoms industry, and Ofcom, argue that 084/7 numbers offer all sorts of claimed facilities and benefits to the users of these numbers.   I say fine, then those users should be the ones to pay for them not the callers.   The premium is usually very much larger than the revenue share and is in my view the main problem. We seem to be straying very far off topic with this discussion so I suggest that we discontinue this line here and move over to the "Ofcom Consultation" thread.http://www.saynoto0870.com/cgi-bin/forum/YaBB.cgi?num=1366033132/2#2

Here we are.

We are therefore addressing a problem that is far less "fundamental" than that which I suggested. Loddon is suggesting that using the telephone bill as a way of collecting money to be passed on to a third party is unacceptable in certain circumstances. The principle which applies in the case of 084 / 087 numbers is exactly the same as in other cases, and at last Ofcom recognises this and will be treating all cases in the same way.

It is true that the limited level of the Service Charge on 084 / 087 numbers is almost always used to offset costs that would otherwise be incurred by users rather than to deliver revenue. Except in the case of 0845 numbers however, this generally extends well beyond that of the technical benefits derived from use of non-geographic numbers.

Many, notably BT, expected that Ofcom would be proceeding to prohibit revenue sharing on 0845 numbers, as it had on 0870, although more effectively. Ofcom has however acknowledged what it believes to be a demand to impose a Service Charge as low as 2p per minute, which does little more than offset the cost of the features of a non-geographic number. I believe that this demand will be seen to be considerably reduced when the imposition of this charge has to be declared.

The argument that the recovery of system costs (as in the case of 0844/3 numbers) and some call centre operational costs (as in the case of 0871/2/3 numbers) should be prohibited is not considered by Ofcom. Ofcom takes the view that Service Charges as low as 2p per minute should be allowed, so long as they are declared, and it takes little interest in how this benefit is applied - i.e. with reference to which particular costs it is used to offset.

From the perspective of the caller it matters little as to how the Service Charge is used. The person called is free to attempt to justify its imposition in whatever way they wish (within the bounds of honesty). I believe that this is where the argument has to rest, not with Ofcom attempting to determine what level of Service Charge may be appropriate in any particular case.

Likewise with the Access Charge. This is where the present "bundled" nature of the charging is most wickedly exploited. Simplicity and clarity must be applied to ensure that the present rip-offs are brought to an end. Furthermore, I do not believe that the same simplicity should be imposed on charges for calls to geographic numbers, where customers benefit from a more complex approach.

I fear that by addressing only certain ranges, we may be moving away from what is truly "fundamental". The distinction between cost offsetting and revenue is also hard to address when covering the whole extent of the ways in which 084 and 087 numbers are used. It would be very difficult to apply regulation in a way which respects this fundamental principle. This is especially difficult where the latter seems to be regarded as acceptable, but the former is not, as regulation would normally be applied the other way around. It would however be interesting to hear suggestions of how this could be achieved.

The main difficulty with the Ofcom proposals is the intention to maintain the premium charge for calling 084 and 087 numbers by calling it the “access charge” and to continue the scam of revenue sharing by calling it the “service charge”.

I have said many times before in postings on this Forum and in responses to earlier Ofcom consultations that it is fundamentally wrong to make callers pay for services and facilities provided to a third party, i.e. the users of these numbers.    The general public are very unhappy with these extra charges for 084/7 numbers as exemplified by comments made on newspaper and discussion sites such as this comment which appeared in the Mail On-line website ;---

"0845 and 0844 should be outlawed across every business. Why do you have to pay to ring your insurance company, your broadband/network provider, your electricity/gas/water provider when you are already paying for a service? ..... Its disgusting how we are treated by services we already pay for!
- whyohwhy, Horley, United Kingdom, 28/4/2013 13:20"
This is just an example because there are hundreds if not thousands of similar comments which clearly illustrate the public perception of these numbers.   They have also been referred to many times in Parliament as “rip-off” numbers by MPs and Ministers.
Ofcom has stated that it is expecting that their proposals will bring some “transparency” to these charges, will result in the public accepting them and getting to appreciate them and ultimately desiring to call these numbers as a preferred choice leading to increased use of these numbers and increased revenue for the telecoms industry.   Ofcom state in their consultation Summary :---
“1.23 The unbundled tariff will, we consider, provide significant benefits to consumers: clearer prices, better competition between phone companies and, perhaps, service providers, and reinvigorated consumer confidence in using these numbers.
1.24 As well as benefits for individual consumers, UK businesses stand to gain. Greater consumer confidence will in turn give UK businesses more confidence in using these services to be contacted by consumers and to provide new and innovative services to consumers. “

“Reinvigorated consumer confidence in using these numbers” says Ofcom which shows exactly what they are trying to achieve – public acceptance of paying higher costs to make phone calls.   Ofcom are not prepared to rule on this matter but are going to leave it to the public to complain, apply pressure, campaign and agitate to persuade phone companies and “service companies” like the DWP, Banks, Insurance companies and retailers to stop charging for calls which are often about poor service and mistakes made by the providers .   This is the most inefficient way of achieving regulation.   It will inevitably lead to enormous waste of time and effort to get rid of rip-off charges and excess costs.   The phone companies and “service companies” will no doubt expend a great deal of their resources and efforts to retain these charges by all sorts of clever schemes and marketing.   

Ofcom seem to be taking the attitude that they insist on “transparency” and then it is up to the consumers to fight to put things right.
 
I have nothing against transparency and indeed welcome it, but it is a poor substitute for proper regulation.   Having said all that and made clear that I am against the Ofcom proposals in principle I will say that I understand that Ofcom feel they cannot “regulate” to put this long-running rip-off right because it has been around for too long, it has grown up without apparent deliberate design or regulatory announcements and the phone industry now rely on it for a significant part of its revenue.   So from hereon I will confine my comments to matters of how the access and service charges are implemented and regulated.

loddon, I agree 100% with every word you say.   I don't care how transparently I am being "ripped off", the point is I object to being ripped off at all by organisations using these numbers or any number not included in my call plan. As for the idea that it pays for the telephone system, well, when I enter a shop or any other business premises to buy items or obtain a service, I don't expect to have to contribute towards their business rates or building maintenance costs!   Any customer contribution to those is, rightly, included in the costs of the items/direct services provided and this should be the case with phone contact.   The whole idea of having to pay more to call one sort of number than another is morally wrong, particularly as one often has no choice of an alternative.

One further point, much has been made of the Consumer Rights Directive but how will this impact upon public sector organisations and their outsource companies/contractors?   They are terrible abusers of NGNs yet do not "sell" goods etc as such and if they are not covered by this it will be useless as one cannot choose, for example, to use a neighbouring council which has a geo number if your local council has only NGNs. 

loddon wrote on Apr 30^th, 2013 at 12:42pm:

… from hereon I will confine my comments to matters of how the access and service charges are implemented and regulated.

If it is accepted that …


Quote:

the telephone bill can be used as a way of collecting money to be passed on to a third party (the person called)

then one needs to address the fundamentals in detailing when this should not be allowed.


I had understood that the point being made was about prohibiting the transfer of costs ("callers pay for services and facilities provided to a third party, i.e. the users of these numbers"), but as all retail prices reflect many costs, both direct and indirect, as well as a margin it is not easy to see how one may isolate specific direct costs in order to prohibit their consideration in the setting of a charge.


I am disappointed to hear that we will not be treated to an explanation of how this could work, although a position in favour of it has been reserved.


The present "rip-off" exists across the board because of the lack of transparency and the common misrepresentation. It exists in particular cases because Service Charges are imposed in situations where they are wholly improper.

I do not believe that it should fall to Ofcom to make a determination about the propriety of a charge made by a Service Provider, outside the market for communications services- which includes providers of designated "Premium Rate Services". The transparency offered by the unbundled tariff should however make this task easier for those who are responsible for regulating Service Providers.

Many rip-offs will be addressed by the provisions of the Consumer Rights Directive, some will be addressed by the appropriate regulators, others will need to be addressed by normal market mechanisms. We cannot expect Ofcom to be able to second guess what is proper, given that the practice of collecting money for third parties through the telephone bill is not to be prohibited.

Barbara wrote on Apr 30^th, 2013 at 2:29pm:

loddon, I agree 100% with every word you say.  The whole idea of having to pay more to call one sort of number than another is morally wrong, particularly as one often has no choice of an alternative.

The argument that no number should include a premium charge must be based on the principle that the telephone bill canNOT be used as a way of collecting money to be passed on to a third party (the person called). It is possible that the cost of all calls be increased to allow for the fact that some include an amount to be passed on (as BT does with its inclusive packages in respect of 0845 calls) - however I do not believe that this is what was being suggested.

I had understood that this was not the position being taken by Loddon, who had only opposed the inclusion of transferred costs on calls to 084 / 087 numbers. The suggestion of 100% agreement leaves one confused.

As for alternatives, I see very few cases where it is appropriate to offer a multi-tiered cost approach to telephone access. One would normally expect the same quality of access to be provided to all callers. Offering a premium option for improved access, in return for a Service Charge, is surely not something that should be welcomed by the majority. If a wholly different service is being offered, then we are talking about alternative services, rather than alternative numbers. I would be interested to hear an argument in favour of alternative numbers being offered.



Barbara wrote on Apr 30^th, 2013 at 2:29pm:

One further point, much has been made of the Consumer Rights Directive but how will this impact upon public sector organisations and their outsource companies/contractors?   They are terrible abusers of NGNs yet do not "sell" goods etc as such and if they are not covered by this it will be useless as one cannot choose, for example, to use a neighbouring council which has a geo number if your local council has only NGNs.

It is also recognised that if you have a complaint against one company you cannot direct it to another because the second does not impose a Service Charge on complaint calls! If the need to declare the Service Charge is not sufficient to demonstrate its impropriety in cases not covered by the provisions of the CRD, then the fact that businesses are prohibited from imposing a charge for customer telephone access to certain services may bear on public service providers who are not seen to require regulation by other public bodies.

One hopes that the underlying principle behind the CRD regulations will be recognised and mirrored both in practice and, where necessary, by parallel regulation to cover all cases where the principle may be seen to apply.

loddon wrote on Apr 30^th, 2013 at 12:42pm:

I have said many times before in postings on this Forum and in responses to earlier Ofcom consultations that it is fundamentally wrong to make callers pay for services and facilities provided to a third party, i.e. the users of these numbers.    The general public are very unhappy with these extra charges for 084/7 numbers as exemplified by comments made on newspaper and discussion sites such as this comment which appeared in the Mail On-line website ;---

In the past, the focus of discussions here, almost unequivocally, was to condemn the imposition of these fees and charges to simply call another party. The concept of being charged not only for the conveyance of a call, but to also provide some monetary compensation to the called party is utterly bizarre, and the public, through responses to consultation after consultation has made its views absolutely clear. There was little, if any, public response suggesting that the way forward was to separate out the charging mechanism into constituent parts - one revenue stream for the telco, and one for the recipient; rather the expression that the underlying issue of providing revenue to the recipient is fundamentally and ethically wrong. I continue to maintain that viewpoint. The focus on these forums is now to congratulate the dithering regulator in its proposal to increase transparency. The issue of transparency is irrelevant to me, as a foreign resident, as it's difficult to contact these wretched organizations in the first place. Irrespective of the foreign termination of calls issue, the whole premise that 'regular calls' should be subject to an additional payment to the recipient is simply unacceptable to me, and I suspect to many others. This whole mess has been created by the regulator and its predecessor, and despite repeated representations by the public, it has failed to act on our behalf, creating consultation fatigue and apathy.

The cost of a call should be exactly that - we should pay the telecommunication provider for the cost of conveying that call from one party to another. Whether that cost is one pence per minute or one pound per minute is largely irrelevant - we can make a valued judgement as to whether the cost is acceptable. We have the ridiculous situation whereby organizations from the largest multinational to the small 'mom and pop' business have non geographic numbers simply because everyone else is doing the same.

Will Ofcom's proposals help - perhaps, perhaps not, yet the underlying problem will still exist. As I have said many times, we never used to have to pay a 'service fee' to call our bank, our airline and our plumber so why should we now? Over here, a bastion of capitalism and corporate profits, it is simply inconceivable that any business would charge its customers to call, and commerce and industry seems to do quite well, thank you very much, in providing call centers and apportioning the costs into its general overheads for running a business.

It is encouraging that replies #4 and #7, if taken in isolation from other comments, represent a fairly clear position -


Quote:

The telephone bill SHOULD NOT be used as a way of collecting money to be passed on to a third party (the person called).

It may be that some would wish to permit the provision of Directory Enquiries services, and perhaps some others, under this otherwise prohibited arrangement. I fear that the possibility of contention would swiftly arise if one did not limit a list of exceptions to some very clearly defined types of service. Purists would allow no exceptions.

It must also be remembered that this principle, as stated, also covers premium text messages. Again it may be thought appropriate to allow an exception so as to permit this means of charitable giving.

There is no question that if the various measures being brought forward, and those additional measures which should flow from them, do not remove the "rip-offs" on 084 numbers in particular, then they, and we, should be seen to have failed. If a "robbery" can be seen to be carried out in the clear light of day, then something is very wrong with society.

Ofcom believes that Service Providers may be to justify the imposition of a Service Charge as low as less than 7p per minute, or as high as more than £1.50 per minute. If this happens, then it is for those who press the position quoted above to convince them and their willing customers that their right to conduct this transaction should be withdrawn.


I am inclined to disagree with Ofcom, as I believe that there will be seen to be very few who are able to justify use of 084 numbers (with a Service Charge of up to 7p per minute). I cannot however claim to have conducted exhaustive research into this point and look to "The Big Question" to help provide some answers.

The fair telecoms campaign finds it hard to argue that if someone wishes to impose a charge for a legitimate service, advises the charge fully and honestly and that someone is properly aware of the charge and happy to pay it, then this must be prohibited because previously the charge was not clear. We accept the principle that, in our present liberal society, the telephone bill may be used as a way of collecting money to be passed on to a third party (the person called). It is however good to engage in open discussion with those who disagree.

It may be helpful to understand that is perhaps because we do not oppose the imposition of a Service Charge in principle that we fight so passionately against cases where it is applied improperly.

SilentCallsVictim wrote on May 1^st, 2013 at 1:10am:

It may be that some would wish to permit the provision of Directory Enquiries services, and perhaps some others, under this otherwise prohibited arrangement. I fear that the possibility of contention would swiftly arise if one did not limit a list of exceptions to some very clearly defined types of service. Purists would allow no exceptions.

I do not have any particular issue with genuine premium services being offered in, and only in, the 09 premium range as long as one has to opt-in to remove a premium block. Such services are, I believe, relatively easy to define - where a clear product or need is being sold 'over the phone'. DQ, legal advice consultations, vehicle checks and of course dial-a-wnak services are valid examples where a fee is expected by the person making the call. Such services do not include access to public service providers and what we can reasonably define as regular calls that we used to make before the proliferation of these rip-off numbers.

The segregation of service and access charges makes not the slightest difference to me as I cannot call the numbers, at a reasonable cost, in the first place. This will also apply to those traveling and working overseas - a significant number of citizen-consumers or whatever the current warm and fuzzy term is.

If Ofcom had consumers' interests high on its priority list, it would prohibit all revenue sharing on any 08 number from say Jan 1, 2015. Service providers will then be forced to either accept no revenue and factor their telephone handling costs into their general overheads for air-con, heating, rent, lunchtime sandwiches and mail costs, or sell their wares through a highly-regulated PRS regime. This is similar to what, I suggest, the overwhelming number of telephone users would want to see happen. It will not, of course take place, as there are too many vested interests, and the regulator is a complete waste of inefficient space (compare the costs of Ofcom against the FCC).

084 and 087 have provided absolutely no benefit to the telephone end-user and they need to be put to rest. We didn't want them in the 1980s and we don't want them now, however their costs happen to be represented.

idb wrote on May 1^st, 2013 at 2:03am:

If Ofcom had consumers' interests high on its priority list, it would prohibit all revenue sharing on any 08 number from say Jan 1, 2015. Service providers will then be forced to either accept no revenue and factor their telephone handling costs into their general overheads for air-con, heating, rent, lunchtime sandwiches and mail costs, or sell their wares through a highly-regulated PRS regime. This is similar to what, I suggest, the overwhelming number of telephone users would want to see happen. It will not, of course take place, as there are too many vested interests, and the regulator is a complete waste of inefficient space (compare the costs of Ofcom against the FCC). 084 and 087 have provided absolutely no benefit to the telephone end-user and they need to be put to rest. We didn't want them in the 1980s and we don't want them now, however their costs happen to be represented.

Absolutlely agree with all of this with only one minor exception. In the 1980s and early 1990s an 0845 (was 0345 at the time) number was a benefit to customers since they would only pay for a local rate call to ring a company that might otherwise have to contacted using a national rate call at several times the cost. The predecessor to 0870 was 0990 which was rarely seen and offered no benefit to customers. Now that the usual marginal cost of a national call is zero all of this history is irrelevant.

Barbara wrote on Apr 30^th, 2013 at 2:29pm:

loddon, I agree 100% with every word you say.   I don't care how transparently I am being "ripped off", the point is I object to being ripped off at all by organisations using these numbers or any number not included in my call plan. One further point, much has been made of the Consumer Rights Directive but how will this impact upon public sector organisations and their outsource companies/contractors?   They are terrible abusers of NGNs yet do not "sell" goods etc as such and if they are not covered by this it will be useless as one cannot choose, for example, to use a neighbouring council which has a geo number if your local council has only NGNs.

Thank you Barbara for your encouragement, we are on the same wavelength as I suspect are many others who have not yet posted.

Regarding your question about the Consumer rights directive (CRD) I have discovered that Ofcom refer to this in their Part B Annexes A19 para 116 :---
"With respect to the impact of the Consumer Rights Directive, we note this is not directly relevant to our assessment under this criterion given that its requirements will be implemented in the UK regardless of whether or not we implement the unbundled tariff. Nevertheless, we acknowledge that there may be a particular impact on SPs as a result of the requirements in the Directive, with some SPs potentially needing to migrate, or use alternative number ranges for particular aspects of their service. In particular this Directive contains a requirement that where a customer telephone helpline is offered to deal with contracts that have been concluded (with some exceptions for specific services) the call must be charged at no more than a basic rate.86 The Department for Business, Innovation and Skills (‘BIS’) issued a consultation on the implementation of this Directive in the UK in August this year.87 Its position in that consultation was that the definition of ‘basic rate’ would exclude any revenue sharing arrangements, even on the lower rated ranges where that revenue sharing was used to cover costs rather than passed through directly to the SP. The Directive is required to be transposed into UK law by 13 December 2013 and it will apply to all contracts concluded after June 2014.88 However, as indicated, this requirement only applies to communication after contracts have been concluded. Therefore this may not necessarily mean that SPs which have numbers that do not meet the ‘basic rate’ requirement have to migrate away from that number range, but instead they will need to ensure that they have at least one number range which meets that requirement for after-sales queries."

So Ofcom seem to be saying that the DWP, for example, will not necessarily have to migrate away from 0845 but they will have to ensure that they have at least one number that meets the CRD legislation.   Does that mean it must be a geographic or 03 number?   I'm not sure.

idb wrote on May 1^st, 2013 at 2:03am:

If Ofcom had consumers' interests high on its priority list, it would prohibit all revenue sharing on any 08 number ........ 084 and 087 have provided absolutely no benefit to the telephone end-user and they need to be put to rest. We didn't want them in the 1980s and we don't want them now, however their costs happen to be represented.

Agreed, that is precisely my view and of course it is the view of all the users of this site which is set up to provide ways of avoiding 08 numbers, but it does not seek to avoid 09 or 118 numbers.

Unfortunately, Ofcom are swimming in their own little pond of murky water with the phone companies.   In its current consultation which seems to contain over a million pages (I have been trying to read some of it) it goes on and on and on and on about consumer demand for 084 and 087 numbers.  It doesn't seem to realise, or perhaps admit, that there is no consumer demand for 084/7.   Consumers only call 084/7 numbers at all because there is no visible alternative.   They do not want to call such numbers.   The demand only comes from the phone companies themselves and the rip-off merchants who want to exploit the citizen-consumer;  Ofcom. the epitome of self-delusion.

Over the years of my campaigning on this matter I have never once come across a single person who said or wrote "I wish my doctor would get an 0844 number" or "I wish more government departments would follow the lead of the DVLA when they used 0870 numbers."   I have seen plenty of people complaining about 084/7 numbers and seeking to avoid them by using this site, and even Which? and others publishing advice on how to avoid such numbers.   Ofcom just don't get it !!! :( :o >:(

loddon wrote on May 1^st, 2013 at 4:21pm:

So Ofcom seem to be saying that the DWP, for example, will not necessarily have to migrate away from 0845 but they will have to ensure that they have at least one number that meets the CRD legislation.   Does that mean it must be a geographic or 03 number?   I'm not sure.

No ! You have missed the point of a very wordy paragraph. The DWP is totally outside the scope of the CRD provisions.

The government will be prohibiting businesses from charging customers for "after sales" enquiries, whilst - if the DWP policy remains unchanged - itself levying a charge on enquiries from pensioners, the disabled and jobseekers.

As I said previously, it would be a very sick society that tolerated such behaviour.

Isn't the DWP levying a charge now with its use of 0845 numbers?

loddon wrote on May 1^st, 2013 at 4:48pm:

… there is no consumer demand for 084/7 …

I am inclined to largely agree with this statement, although I believe that it has to be tested so that those who claim that there is such demand can be put in their place.

---

I am concerned about the case of a (hypothetical, for now) organisation which would rather that all interactions with consumers took place on-line, rather than through a much more costly telephone call centre. It could feel that a modest charge for telephone calls would help offset its costs and provide a sufficient incentive for on-line contact. To avoid having to deal with the CRD provisions, let us say that these are one-off transactions. At present "Premium Rate Services" are defined by the level of the "Service Charge", so if this organisation wanted to charge only 5p per minute it would not be classified as offering a "Premium Rate Service".

If this were the only basis on which the organisation was prepared to offer telephone access, are we content that it should be prohibited from doing so? Many organisations already do not offer telephone access.


I will offer one other (again hypothetical) example which concerns me.

A charitable enterprise offers a helpline service whereby calls are automatically switched around using a fairly costly bit of technology. A shortage of outside funding causes it to use a 0845 number so that the line and the switching technology is paid for by callers at the cost of 2p per minute. It declares this charge and advises that callers will also incur an Access Charge from their telephone company.

Should it be stopped, or forced to charge more than 13p per minute?


Because my energies are focussed on improper use of Service Charges, I have not undertaken the research necessary to identify specific cases, however I do not believe that the ideas are wholly fanciful. One could mention other potential (and perhaps many actual) cases where a low Service Charge is not obviously improper - The Land Registry is one actual case.

I do not invite specific answers to these questions, but urge those who make sweeping statements to ensure that they have considered the whole of the issue that they are addressing, not just the obvious and frequently discussed cases, even though they are the most important. I would also urge a stricter distinction between one's personal situation and experience (no matter how relevant and valid) and the considerations that have to be made by those who set public policy.

---

It is very easy to highlight cases of inappropriate application of Service Charges and there is no disagreement in this forum about the fact that they should be eliminated. We can argue about whether transparency will be sufficient and whether campaigning groups are strong enough in mobilising consumer power to ensure that it does its job.

We face the argument that there are cases where a Service Charge of less than 13p per minute can be justified. We can easily show that there are many present cases where the Service Charge cannot be justified, but that does not fully address the issue. Ofcom has determined that this issue must be resolved in the real world.


Smart readers of the Ofcom consultation document should be aware that it (like most "consultation" documents at the firm proposal stage) is drafted primarily as a defence against legal challenge of the action proposed. One needs to read very deeply between the lines if hoping to determine the motivation behind the actual proposals, as against the way in which it has been deemed necessary to present them.

loddon wrote on May 1^st, 2013 at 6:30pm:

Isn't the DWP levying a charge now with its use of 0845 numbers?

Yes, and it intends to continue doing so. See this news release.

SilentCallsVictim wrote on May 1^st, 2013 at 7:38pm:

loddon wrote on May 1st, 2013 at 6:30pm: Isn't the DWP levying a charge now with its use of 0845 numbers? Yes, and it intends to continue doing so. See this news release.

As noted above, does this mean Fair Telecoms and it's supporters will now be focussing on DWP to convince them to switch to 01/02/03 numbers instead of "ripping off" their callers with the continue use of 0845 numbers?

I for one at this present time, have had to call DWP on a few occasions from home, and am VERY glad that at this present time I get inclusive calls to 0845 numbers.

SilentCallsVictim wrote on May 1^st, 2013 at 7:35pm:

loddon wrote on May 1st, 2013 at 4:48pm: … there is no consumer demand for 084/7 … I am inclined to largely agree with this statement, although I believe that it has to be tested so that those who claim that there is such demand can be put in their place.

How would you propose to test it?   Or is that the purpose of the two hypothetical cases you posed?   

It would be interesting to see Ofcom or anyone present evidence of consumer demand for 084/7 numbers.   As I said, I have never seen any though I constantly see masses of evidence that consumers don't want 084/7 numbers; the existence of this site is just one example.

The Ofcom consultations on this subject, which commenced in 2010, have not even mentioned this issue never mind actually considered or discussed it as far as I can determine because these documents are so vast and inpenetrable.   It is staggering the way they go on about consumer demand for 084/7 numbers without once pausing to consider the real evidence and what consumers really want.   The fact is the only demand comes from the phone companies and the businesses and organisations who are their customers.   Ofcom claims to have carried out consumer research and they draw conclusions that consumers don't use 084/7 numbers as much as the industry wants them to (currently estimated to be 22 billion minutes per year) because the calls and pricing are confusing.   Certainly that is true but they seem to completely miss the main reason which is that they cost more and there is no justification for charging consumers more.

CJT-80 wrote on May 1^st, 2013 at 10:02pm:

… does this mean Fair Telecoms and it's supporters will now be focussing on DWP to convince them to switch to 01/02/03 numbers instead of "ripping off" their callers with the continue use of 0845 numbers?

Very much so, although not exclusively. Apart from supporting, and using information obtained by, John Healey MP, including this item on Money Box (see the link above), we see the DWP as being a major target in our "Big Question" campaign. Further activities are planned; support and suggestions are welcome from fellow campaigners.

SilentCallsVictim wrote on May 1^st, 2013 at 7:35pm:

loddon wrote on May 1st, 2013 at 4:48pm: … there is no consumer demand for 084/7 … I am concerned about the case of a (hypothetical, for now) organisation which would rather that all interactions with consumers took place on-line, rather than through a much more costly telephone call centre.

The honest stance for such an organisation would be to declare their policy on this matter openly and plainly to their potential customers or clients.   If they have a logical and fair rationale it would probably gain them, for example, competitive edge to declare that they will only communicate with customers on-line and not by phone because it reduces their costs and therefore they can offer more competitive prices.   Potential customers or clients could then decide if they wish to interact with this organisation or not.   

Of course if the organisation is in a monopolistic position, such as the DWP, then moral, social and ethical issues must be considered before designing and declaring that stance.

SilentCallsVictim wrote on May 1^st, 2013 at 7:35pm:

I will offer one other (again hypothetical) example which concerns me. A charitable enterprise offers a helpline service whereby calls are automatically switched around using a fairly costly bit of technology. A shortage of outside funding causes it to use a 0845 number so that the line and the switching technology is paid for by callers at the cost of 2p per minute. It declares this charge and advises that callers will also incur an Access Charge from their telephone company. Should it be stopped, or forced to charge more than 13p per minute?

As a hypothetical exercise this might have been helpful if Ofcom had posed it within one of their consultations.   We are in danger of trying to design the whole solution as a free service for Ofcom, however, my inclination would be to say that if Ofcom would decide that the Access charge could be no more than the price of a normal geographic call within that callers tariff and must be included within the tariff  package (something which I suggested previously as a possible solution) then this could be a justifiable case.

loddon wrote on May 1^st, 2013 at 10:10pm:

How would you propose to test it?

Initially, I believe that Ofcom should have considered the issue more closely, in the context of transparent Service Charges, before determining that use of the 0845 and 0844 ranges would be likely to continue largely unchanged once this option was in place. I do however accept that clear evidence would not have been easy to obtain.

It will be tested firstly when we see the reaction of users to the knowledge that the Service Charge has to be declared. I believe that many will be unable to justify the declared imposition of the Service Charge and will migrate to geographic rate numbers. For those who retain 084 numbers, we and they will gain a clearer impression of the consumer demand for clearly chargeable services by the reaction. In some cases this may have to be shown by active protest.


Let us please not get dragged too deep into the question of "consumer demand for 084/7 numbers", as clearly any consumer wants to pay the least they can to access any service. The issue is inexorably linked with demand for the services provided and the numbers offered to give access to those services. This is why I raised the point about services that may not be available if the provider was unable to levy a modest Service Charge.

loddon wrote on May 1^st, 2013 at 10:38pm:

We are in danger of trying to design the whole solution as a free service for Ofcom

It is true that some are proposing radical alternatives to what Ofcom has already done, for the purposes of discussion. I have only raised a case which I believe is fully covered by the Ofcom approach, as it leaves the legitimacy of the Service Charge to be determined in each particular case.

I do not see the level of the Access Charges, the rates for calling geographic numbers or any connection between them as being of any relevance to the legitimacy of a Service Charge. The whole point of the unbundled tariff is that it separates the caller's two relationships, with the Service Provider and with their own telephone company.


, however, my inclination would be to say that if Ofcom would decide that the Access charge could be no more than the price of a normal geographic call within that callers tariff and must be included within the tariff  package (something which I suggested previously as a possible solution) then this could be a justifiable case. [/quote]

loddon wrote on May 1^st, 2013 at 10:24pm:

… Of course if the organisation is in a monopolistic position, such as the DWP, then moral, social and ethical issues must be considered before designing and declaring that stance.

You were right to detect that, although my example was hypothetical, the DWP was one of those in my mind, because it has a policy of "digital by default" which aims to minimise the amount of telephone contact.

This may explain why it refuses to take any step that could be seen to make telephone contact more attractive. The present situation is however disgracefully unacceptable, and made to appear more so by the fact that HMRC has finally succumbed to campaigning pressure.

Thinking back to my reply to the earlier question about focussed campaigning, the phrase "Telephone Tax" as a way of describing the DWP Service Charge has just come to mind. The "Telephone Tax" forces pensioners, jobseekers and claimants to go out and buy computers. You read it here first!

idb wrote on May 5^th, 2013 at 11:55pm:

http://www.surgeryline.com/surgery-line/faqs/

This piece from the Surgery Line site states :---

"Frequently Asked Questions

Why would a practice change to 03 or even a local intelligent number?

The only way that a busy practice will EVER eliminate the engaged tone is to use an intelligent 03 or intelligent geographic number ..........."


So now we have it, at last, from the arch-villains who have made all sorts of untrue claims in the past about geo versus non-geo numbers.   They have finally admitted and confirmed what we have said for many years -- that everything that is claimed as capability on non-geographic numbers is equally available with geographic numbers -- except revenue sharing or micro-payments as Ofcom like to call them.  This proves that there is absolutely no need for non-geographic numbers at all and as we have said they have always been a RIP-OFF. We campaigners are quite happy to make an exception, however, for 03 numbers which must be charged at the same rate as geographic numbers.

One strange statement by Surgery Line "intelligent 03 number"; what do they mean by this?   When is an 03 not intelligent?  (Rhetorical of course.)   ;) :)

This plainly shows that this consultation and all the consultations from 2010 onwards have been a vast waste of time and money.  Ofcom didn't need to force us to go through all this pain and expenditure because we know that we never needed 084/7 numbers anyway and we don't want them now.

loddon wrote on May 6^th, 2013 at 8:16am:

This plainly shows that this consultation and all the consultations from 2010 onwards have been a vast waste of time and money.  Ofcom didn't need to force us to go through all this pain and expenditure because we know that we never needed 084/7 numbers anyway and we don't want them now.

This comment is based on the assumption that "intelligent geographic" (and 03) numbers have always been available and that the only acceptable purpose of 084/7 numbers is to provide geographic anonymity and intelligent routing.

I have not been able to quickly find a summary of the history of intelligent geographic numbers and the extent to which they have been and are offered by telephone service providers. The way they are marketed suggests that they are far from being a universally available service. It would be good to know more, but there is no question that they must be seen, alongside 03, as a ready issue to raise with those who claim that intelligent routing DEMANDS use of 084/7 numbers.

The ability to levy a Service Charge of less than 13p per minute has been proposed by Ofcom as being a valid, required facility that should be retained. This proposal, like all others, has been open to consultation. This Service Charge may be used, in part, to offset the cost of the intelligent routing facilities, however that is not its sole purpose. It seems that the cost of these facilities is generally valued at around 2p per call minute which leaves plenty of scope for the balance of the charge to be used for other purposes.

The focus of the Ofcom proposals, in this area, has been on the transparency of the charging. In particular, users of 084/7 numbers will have to declare and justify the imposition of the Service Charge, regardless of the purpose for which it is used. A user is free to explain that it is used (perhaps in part) to offset the cost of the intelligent routing, as part of the justification. Any claim that imposition of a Service Charge is technically essential would be untrue. If it were to be claimed that the Service Charge was economically essential for the service to be provided, then that would be a different matter!

Obviously no consumer wants to pay any particular charge, that goes without saying. It is also true that very many uses of 084/087 numbers exist where the Service Charge cannot be justified. It is these which obviously receive the most attention. Ofcom believes that users should have the opportunity to attempt to justify Service Charge on 084/7 numbers and that a significant number will succeed. I personally have my doubts about whether the number that will continue using them will show Ofcom to have been correct. I cannot however offer sufficient proof to warrant the suggestion that all use of 084/7 numbers - defined as having a Service Charge of less that 13p (currently 10p including VAT at 17.5%) per minute - should simply have been prohibited without discussion.

Ofcom is required by law to "consult" on any significant changes. Comments submitted to the Mail Online are, happily, not the sole, or even primary, proper source of evidence used in the formation of public policy. It falls to those who believe that Service Charges of less than 13p per minute should not be allowed, to make and present a case to Ofcom to this effect. I do not hold that view, but I am always open to persuasion by clearly presented argument.

Further to my earlier post in this thread which quotes Surgery Line as stating ;---

"The only way that a busy practice will EVER eliminate the engaged tone is to use an intelligent 03 or intelligent geographic number ....."

We should realise that Surgery Line have not entirely reformed their tendency to mislead, be economical with the truth and over-exaggerate things till they become untrue.   As ever they say that "The only way that a busy practice will EVER ...."  which is obviously untrue because there are other ways to achieve that objective.   They hint at the option to increase the number of lines, or the practice could make use of ISDN lines.   The cost/benefit analysis of alternative approaches would need to be evaluated of course.    A practice can also change its policies to avoid peak call times by NOT refusing to allow patients to book appointments more than a day ahead thereby causing a mad panic, and peak calls, first thing in the morning; and there could be other policy moves and actions which could be taken.

Let us hope that Surgery Line will in time become more honest and truthful.

SilentCallsVictim wrote on May 6^th, 2013 at 11:19am:

The focus of the Ofcom proposals, in this area, has been on the transparency of the charging.

This focus on "transparency" is something I have criticised previously and said whilst "I am all in favour of transparency, it is a poor substitute for proper regulation".   This is something which Magrathea Telecom alluded to in its response to the second Ofcom consultation issued April 2012 when it stated " We believe that Ofcom has tended to emphasise the level of consumers’ awareness of price, whilst not focussing enough on the harm caused by the actual level of retail prices particularly those levied by mobile OCPs."
http://stakeholders.ofcom.org.uk/binaries/consultations/simplifying-non-geographic-no/responses/Magrathea.pdf

Ofcom have dismissed or underplayed the importance of this observation from a significant player in the Telecom services industry it seems because that does not support the Ofcom determination to deal with the difficulties of 084/7 by avoiding real effective regulation.    Magrathea go on to say "We still believe that the best way to protect consumers from the harm of excessive retail charging is to impose maximum retail pricing. Whilst we accept that this amounts to fairly intrusive regulation, we believe that the particular structure of NGC services does not lend itself to effective competitive pressures."   

In other words Magrathea believe that competitive pressure will not be enough to rectify the real problem with 084/7 numbers (i.e. the real excessive cost) so the problem will persist, and I say we campaigners will need to continue working hard, after these Ofcom proposals for access and service charges are introduced, in order concentrate the inevitable public dissatisfaction with the new scheme.   I do not support the Magrathea suggestion of maximum pricing because I want the surcharges to be eliminated altogether but I do believe that Magrathea are not very far away from my general line of analysis and thinking.

Interestingly, Magrathea also make some very interesting comments about Access Charges (AC) which are not a million miles away from my own views :---   
"Regarding inclusion of the AC in inclusive call packages, we believe that this should be a requirement rather than an option. As stated in our answer to question 9.1 above, we do not believe that consumers will select a fixed or mobile telephone service based on the cost of calling non-geographic numbers if there are more significant factors to consider. In relation to mobile packages in particular, it tends to be the headline inclusive minutes packages that are the main focus of consumers’ attention. So unless the AC is included in those call packages, there is still potential for consumer harm caused by insufficient competitive pressure. (Ofcom acknowledges this point in paragraph 10.163.) We believe that there should be a link between the call bundles and the ancillary calling services."

Magrathea also say :---
"Where the AC is not included in the call bundle, it should be capped to the level of the cost-based mobile termination rate plus a reasonable uplift for customer acquisition, retention and service costs."    This is not what I advocate but I much prefer it to what is proposed.

loddon wrote on May 6^th, 2013 at 2:18pm:

… we campaigners will need to continue working hard, after these Ofcom proposals for access and service charges are introduced, in order concentrate the inevitable public dissatisfaction with the new scheme.

This is where I find myself in fundamental disagreement with Loddon (and perhaps others).

There may be the possibility of Ofcom tweaking the situation, for example by intervening to address excessive Access Charges that may be imposed. The likelihood of it removing the scheme after it has been introduced, due to public dissatisfaction, will surely be seen as very small. If I genuinely believed that the scheme would inevitably be found to be unsatisfactory, I would be opposing it now with all possible vigour, whilst there was some prospect of doing good, rather than waiting to "concentrate dissatisfaction" to little purpose. Is this the difference between campaigning and moaning?

I see my campaigning role as being to continue to press dissatisfaction with the imposition of Service Charges (and the consequent incurring of Access Charges) in all cases where it cannot be justified. I believe that this has been effective and is likely to be so in many more cases.That is NOW and it is helped by the fact that the "unbundled tariff" represents exposure of what is happening at present.

The fair telecoms campaign seeks to do this through "The Big Question", on which more will follow very shortly.

---

Ofcom acknowledges the Magrathea proposal regarding mandatory inclusion of Access Charges (at 9.42) and concludes its remarks on this point (at the foot of 9.43) by stating


Quote:

we may reconsider this position and revisit whether a requirement to include the AC within bundles is justified

see http://stakeholders.ofcom.org.uk/binaries/consultations/simplifying-non-geo-no/summary/Part_B.pdf#page=33.

Discussion of the related issue of a cap on the Access Charge follows, beginning at 9.47. Again Ofcom remains open to the possible need for intervention, based on what develops.


Given the amount of attention which Ofcom shows in responding to an extensive, contradictory and sometimes bizarre series of proposals from Magrathea in section B and the annexes to Section B, I cannot agree that its approach may be fairly characterised as dismissive.


The suggestion that Ofcom is actually determined to avoid "real effective regulation" implies that we are indeed wasting our time by discussing these matters. This may have been hyperbole, however there may be some confusion about the powers and duties held by the body, as against how it chooses to use them. For example, Ofcom cannot direct the DWP not to impose a Service Charge on callers.

It could perhaps aim to achieve this effect by, as proposed, imposing a minimum Service Charge of greater than 10p per minute. As the regulator of a market, rather than the director of a state controlled sector, Ofcom has a duty to allow "market mechanisms" to function unless it can clearly demonstrate failure.

It is perhaps not strictly true to describe public demand for claimants to be relieved of the need to pay a charge when enquiring about their benefits, being set against pressures to minimise DWP spending, as a "market mechanism". Ofcom must however leave this to be decided by resolution of these competing positions. Until one points out that the genuinely disabled, genuine job-seekers, those in need of Child Support and all pensioners fall within the affected group, the balance of public demand could be open to question!

SilentCallsVictim wrote on May 6^th, 2013 at 6:08pm:

loddon wrote on May 6th, 2013 at 2:18pm: … we campaigners will need to continue working hard, after these Ofcom proposals for access and service charges are introduced, in order concentrate the inevitable public dissatisfaction with the new scheme. This is where I find myself in fundamental disagreement with Loddon (and perhaps others). There may be the possibility of Ofcom tweaking the situation, for example by intervening to address excessive Access Charges that may be imposed. The likelihood of it removing the scheme after it has been introduced, due to public dissatisfaction, will surely be seen as very small. If I genuinely believed that the scheme would inevitably be found to be unsatisfactory, I would be opposing it now with all possible vigour, whilst there was some prospect of doing good, rather than waiting to "concentrate dissatisfaction" to little purpose. Is this the difference between campaigning and moaning?

This is where I find myself in disagreement with SCV.   I have been away for the last week and so have not been able to respond to post #29 until today.  The suggestions of “waiting” and “moaning” are utterly unfair and constitute gross misrepresentation.   I was campaigning long before SCV joined this Forum and have written to Ofcom, Ministers and Authorities and engaged the press over many years so these scurrilous allegations are totally rejected. 
   
I ask, who is going to be the judge of whether the Ofcom scheme will be satisfactory or not?    I venture to suggest it should be the citizen consumers rather than any “campaigner” or special interest group.  You seem to give unqualified backing to these Ofcom proposals whilst I want proper regulation now because I foresee them failing to resolve the problems because, as Magrathea pointed out Ofcom have not analysed the problems correctly .   I wish that my expectations for widespread dissatisfaction are wrong but we will see after the introduction whether these Ofcom proposals are effective or not.    I don't want to see the need for endless campaigning in the future, I would prefer regulation now.

I have already said that this Ofcom scheme is wrong, even unethical, in concept and is likely to be a failure and I have explained exactly why.   I  have asked Ofcom to think again but it appears that Ofcom is determined to provide legitimacy for the telephone service industry to scam the public with “micro-payments” whilst they are making and paying for their “regular” phone calls.   I have seen others on this Forum give support to my position on this but have seen no-one give any support, let alone full or enthusiastic backing, to the Fair Telecoms unqualified support for Ofcom's proposals on this Forum or in any public discussion site such as newspapers readers comments. 

I say the introduction of  access and service charges, while providing some “transparency”, is a poor substitute for proper regulation.   It is akin to “hiding in plain sight” a phrase which seems to have  been gaining currency in various contexts recently.   I am not decrying your campaigning efforts in general SCV but I do feel that your backing for Ofcom in these proposals is unfortunate because the ultimate goal of elimination of “Service Charges (and the consequent incurring of Access Charges) in all cases where it cannot be justified” will depend on consumer pressure and campaigners efforts rather than regulation and will never be achieved, but might or might not be reduced.   This is a grossly inefficient way to stop rip-offs and scams.   Magrathea Telecom pointed out that there will be insufficient competitive pressure to effectively protect consumers from harm and I feel you are mistaken in dismissing the Magrathea response as “contradictory and bizarre”.    Magrathea pointed out quite correctly that charges for 084 and 087 calls are a subsidiary matter for consumers if they are considered at all when a phone package is being chosen.   Many consumers are often subject to all sorts of sales pressure and sleight of hand when they are looking to buy a package.

You SCV suggest that Ofcom are limited in the scope of their powers when designing and introducing schemes and so are unable to take more substantial action on these matters, but I would remind you that Ofcom prohibited revenue sharing on 0870 numbers recently and I see no reason why they could not continue along this path and take similar action with all 084 and 087 numbers.  Unfortunately they have decided, and are determined not to be persuaded otherwise, while you misguidedly support and endorse Ofcom in failing to deal with the real problems by proper regulation.

Like loddon, I am unhappy with OFCOM's proposals, I do not see "transparency" as any real benefit to the consumer, I think it is very unlikely to have the desired effect of "shaming" users of NGNs into using ordinary numbers (the facts have never worked as a disincentive to scamming so why should transparency?)   For me, being charged anything above the rate for a geo number (in my case, nothing because of my package) is a scam and a rip off, particularly when, in the large majority of cases one has no choice about calling a particular organisation.   It is the fact that I am being scammed/ripped off which is the issue, knowing by how much benefits me not at all!

This is by no means a criticism of the efforts of others, I just feel it is too small a step and not even in the right direction.   If OFCOM wanted, it could be asking, even demanding, stronger powers from Ministers, it would certainly get public support for this.

Thread #28 focuses on the true issue - transparency being a poor substitute for proper regulation. The public has, over many years and through many consultation responses, made its views perfectly clear - it does not want to see the imposition of additional fees or charges while making a call to a regular, normal organization or individual. There has not, as far as I am aware, been any public crusade to split the cost of a telephone call into separate elements - in simple terms, a fee for the telephone company and one for the recipient. The concept is utterly bizarre. The regulator created this monster and it is unwilling to remove it as there are too many vested interests. The public viewpoint is well understood by the regulator. It chooses to ignore this opinion and impose a solution that protects the prevailing situation where the telephone user will still be subjected to scams and rip-offs, and those of us who live overseas will still have difficulty and expense in maintaining telephone relationships with UK organizations. UK residents do not want transparency in charges, they just want the charges eliminated as such fees are unjust. The regulator knows this and fails to act, instead preferring to use some complex conjuring trick to express one rip-off in the form of another one.

I agree with idb.

Ofcom knows exactly how the general public feel about this.

It is going to cause general confusion by allowing Sky (example only) of stating that calls to their 0844 number cost 2ppm plus network operators charge.

As Loddon has mentioned many consumers are dazzled by sales tactics focusing on the positive and ignoring/hiding the negatives like adverts that state "broadband/tv, etc from £21 per month" only to find (either hidden or in smaller print) that you have to take that companys line rental (no choice) and this will cost around £15 extra per month so without realising it at first that the so-called great deal turns out to be around £36 per month and not the £21 advertised in big print.

The OCPs charge may have to be transparent but that doesn't mean it will and also how big/small text size will they make it?

Also, when an OCP advertises their "great!" value packages will they make the OCP charge for calling 08x/09x the same very clear and same size text that they use for advertising, for example, the monthly cost, or will they purposely make the text a lot smaller and therefore hard to see?

The general argument against allowing a third party to collect money through our telephone bills is well made. If this is an argument about prohibiting the practice, thereby causing the withdrawal of directory enquiry, dial-up internet and other premium rate services, then that is fair enough.

If however it is focussed only on those cases where the public feels that a Service Charge is not justified, then surely it is for the public, not Ofcom, to decide which those are.


Some suggest that Ofcom should prohibit imposition of a Service Charge of 13p per minute or less, i.e. for those services which are accessed through 084 / 087 numbers. This is suggested as being what the public has clearly stated. I am inclined to believe that every consumer simply objects to paying more than they can argue that they should for everything. That is fine, however I do not think it fair to attempt to draw so refined a conclusion about the terms of a regulatory measure from such expressions of opinion.

Ofcom believes that there is a demand for such services to remain. I argue that in a new situation, where public confusion about call charges can no longer be exploited, it would be minimal, although I cannot produce the extensive evidence necessary to show that my rough judgement is sound. We cannot be certain of how many 084/087 users will be taken out by the provisions of the Consumer Rights Bill, as announced in the Queens's Speech, will do so under pressure, as HMRC has done, or will simply be unwilling to declare a Service Charge when confronted with this as a serious prospect.


The other great uncertainty, which will have a significant effect on the general position, is over how BT will react to removal of the NTS condition. This will provide it with the opportunity to rebalance its charges, correcting the appalling distortion to public perceptions which its present situation creates. There are however reasons why BT would not seize this opportunity in the way that we might expect, so it is very difficult to be sure that all of the confusion will be removed.

Although BT is no longer as big a player as many believe - that is why the regulation must be removed - it and its tariffs still have a disproportionate effect on public perception, for probably false reasons. This is exploited by those who sell business telephone services, and thereby by their customers.


The opportunity for anyone who holds the necessary evidence of lack of demand to present it, and engage in the necessary battles, has been around since the first Ofcom consultation on this subject. Such a submission would have to address the three possible consequences of the suggested prohibition of Service Charges of less than 13p per minute: 1) withdrawal of the telephone service, 2) continuation with a higher Service Charge, 3) continuation without a Service Charge. One could not assume (without evidence) that the latter consequence was the only possibility. Had Ofcom made such a proposal, it would have had to address the potential impact of all three and the likelihood of each.

Ofcom's actions are open to challenge in law. Had such a proposal been carried forward, any 084 / 087 user who wished to contest Ofcom's determination that consumers should be denied the opportunity to pay a Service Charge of 13p per minute or less to access its services by telephone would be able to have their day in court. One would expect that their arguments would be focussed on the first two of the consequences given above!

Ofcom's approach is always to be well protected (I believe, often over-protected) against the possibility of such actions. Losses undermine enormous amounts of work, as well as damaging the credibility of all its efforts. Some may believe that Ofcom would be bound to win any such case, however it is has passed this particular argument to be conducted in the court of public opinion.


I commonly find myself arguing against the consumerist approach, as it is too often extended to areas where it has no place, because clear values may be applied arbitrarily. In this situation, I find myself on the other side of the argument, competing with those who believe that Ofcom should be able to make a judgement, on behalf of the people, about which applications of a Service Charge are justifiable and which are not.

Unless all cases are unjustified, I cannot see any clear objective and defensible basis for a demarcation line. People know what they find unacceptable and they can make their arguments about each particular case, or class of cases.


I do not believe that all cases of 13p per minute or less are inevitably unjustified, nor do I believe that Ofcom is the right body to make any more refined determination, or to sit in judgement on the balance of public opinion in any particular case. I do not believe that Ofcom has the powers or resources to engage in such matters, and if it did, I am damned sure that I would disagree with many of its determinations!

Can anybody see a realistic prospect of DCMS giving Ofcom (a barely accountable QUANGO) the power to tell HMRC, an agency of the Treasury, or the DWP (Departments of State) what to do? There is to be no new Communication Bill to even begin its process in the current session, so we are probably looking to the next parliament to change Ofcom's powers.

Talk Talk have today published their Annual Report :---

http://www.talktalkgroup.com/~/media/Files/T/TalkTalk/pdfs/reports/2012/talktalk-ar12-web-ready-v2.pdf

This was mentioned on BBC's Breakfast TV and the Talk Talk Chief Exec Dido Harding was interviewed for all of a gruelling er ... (1min 30secs?).    The interviewer managed to bring in the £750m fine imposed on Talk Talk for silent calls and various other transgressions and unethical practices during the last year, which Dido dismissed as slight "problems" but said they were learning and improving all the time ..... of course.   :-/ ::)

This must have caused some sort of curiosity in my subconscious because I later found myself looking at the Talk Talk website and using it to seek out the sort of phone package that might interest me.   I currently have an all day anytime package, or whatever they call it, from VM and wondered how Talk Talk's offering would compare.   In particular I wanted to find out how they presented information about 084 and 087 numbers and the cost of these numbers.   This is what I found :---
“*Unlimited anytime calls to UK landlines
Applies to calls to UK numbers. Max 60mins/call then charged at standard rate. Applies to UK numbers starting 01/02/03/0845/0870 only (excludes calls to Channel Island, dial-up internet, indirect access & all other numbers).”
084 and 087 are merely “other numbers” according to Talk Talk and nowhere on their site can I find such numbers are ever explicitly mentioned.   When I clicked on “Talk UK Anytime Rates” this is part of what I saw :---
TALK TALK
“Rates to UK Landlines
Daytime       Evening        Weekend
01/02/03 & 0845 / 0870*       Inclusive
Jersey & Guernsey  2.76p    1.84p       1.38p
0800 / 0808 / 0500 numbers
Free          Free         Free
*Maximum inclusive call time 60 mins per call (redial to avoid 8.41p per min rate).
0845/0870 numbers are inclusive when line rental is taken with TalkTalk.
All rates in pence per minute.

Other call types. (click here for number list)

Call Connection Charge  Per Minute Charge  Chargeband
(at all times)
Directory Enquiries DQ1 13.87p   28.08p    28.08p 28.08p
Directory Enquiries DQ2  13.87p  39.32p  39.32p  39.32p
Directory Enquiries DQ3 .......... "

The DQ numbers run up to DQ143.

“Premium Rate 0  13.87p  168.51p  168.51p  168.51p
Premium Rate 1   13.87p   55.05p    43.81p   43.81p
Premium Rate 2 ..........................."

Premium Rate numbers run up to P44.   The above tables have not reproduced very well but they give an idea of the layout.

There are various other types such as Internet Services, Services C Rate tec, Services Fixed Fee, Services FW01, Fw02 up to FW 12, G1Rate, G2 Rate up to G28Rate and more.    No mention of 084, 087 or 07 or 09 numbers. 
I can find no explanation of what all these codes mean or what numbers they might relate to.    How on earth do Talk Talk expect any customer to understand all this?   :( :'(   I am not picking out TT especially but this seems to me to be typical of this industry and illustrates to scale of the problem which Ofcom need to understand and deal with.


We know that Ofcom are addressing this problem at present via their current consultation on Non Geo numbers which started in 2010 and might result in some new regulations coming into operation in 2015.   Meanwhile consumers are supposed to grapple with all this!   :o


At the same time Ofcom after years of cogitation and then consultation waffle on with their deeply academic analysis of the consumers view of 084 and 087 numbers with stuff like this :---


“4.42 Consumers’ general awareness of the price of calls to 084 and 087 numbers is poor. Only a small minority are confident that they know the price of fixed and mobile calls to these numbers (see Tables 4.1 and 4.2 above).146 Furthermore, consumers overestimate the price of these calls with both mean and median expected prices exceeding actual prices by a significant margin (see Table 4.3 above).
4.43 This lack of consumer price awareness contributes to the vertical externality on the 084/087 number ranges by creating an incentive for OCPs to set retail prices above the level that many SPs would like. In contrast to 080, we are not aware of any attempts by SPs on the 084/087 number ranges to negotiate a particular retail price with OCPs. Nevertheless, evidence from the 2011 SP survey suggests that the vertical externality is still a material concern on these number ranges. For instance, we noted that of the two options for intervention that we asked about, 52% of 0845 SPs preferred all callers paying the same as for calls to a “normal landline” even though this option also involved a 1.5ppm increase in the cost of operating the number for the SP.147 This suggests that a significant number of 0845 SPs would like to contract with OCPs to set a different price for their services but, due to the difficulties in reaching such agreements, they are unable to do so.”

This sort of thing goes on for pages and pages in the current consultation document.   What sort of cloud cuckoo land are Ofcom living in?    :o

Continued in next post as character limit reached.

Ofcom seem throughout their document to be rather surprised that consumers are not well aware of call costs to 084/7 and make no mention at all as far as I can see of the way call costs are displayed by Talk Talk and others, which are just as complex and obscure but very different.    One strongly suspects that the small minority who told Ofcom they are confident that they know the cost of calls to 084/7 are actually seriously deluded schizophrenics who have no idea what they are talking about.    Of course Ofcom base their analysis and understanding of consumers and the market on this sort of information.

I am afraid that this does not encourage me to be optimistic about the outcome of the current consultation and the way in which the phone services industry will implement a new regime and interpret the new regulations whatever they are.

Since posting I have just noticed the "click here" for other call types, my lack of perspicacity  :-[,  OR an illustration of how phone companies make it difficult for consumers to find out about these pesky 084, 087 numbers.  ::)   However when clicking this is what the consumer is confronted with, dozens of pages (correction 183 pages, eek  :o):---

PREFIX CHARGEBAND
0300 Services G21 Rate
0302 Services G21 Rate
0303 Services G21 Rate
0306 Services G21 Rate
0330 Services G21 Rate
0331 Services G21 Rate
0332 Services G21 Rate
0333 Services G21 Rate
0343 Services G21 Rate
0344 Services G21 Rate
0345 Services G21 Rate
0370 Services G21 Rate
0371 Services G21 Rate
0372 Services G21 Rate
0500 Free
05516 Services G21 Rate
055114 Services G21 Rate
055551 Services G21 Rate
055553 Services G21 Rate
055554 Services G21 Rate
055555 Services G21 Rate
055883 Services G6 Rate
055888 Services G21 Rate
0551100 Services G6 Rate
0551107 Services G21 Rate
0555500 Services G21 Rate
0555508 Services G6 Rate
0558866 Services G21 Rate
056 Services G21 Rate
0560 Services G21 Rate
07000 Services D Rate
07001 Services D Rate
07002 Services PN22 Rate
07004 Services PN22 Rate
07007 Services K Rate
07008 Services PN2 Rate
07009 Services D Rate
07010 Services PN2 Rate
07017 Services PN2 Rate
07020 Services D Rate
07050 Services K Rate
07051 Services J Rate
07056 Services PN2 Rate
07057 Services PN2 Rate

Somewhere in these 183 pages the 084 and 087 numbers are buried.
Is all this quite clear now?? :)

loddon wrote on May 16^th, 2013 at 5:45pm:

This was mentioned on BBC's Breakfast TV and the Talk Talk Chief Exec Dido Harding was interviewed for all of a gruelling er ... (1min 30secs?).    The interviewer managed to bring in the £750m fine imposed on Talk Talk for silent calls and various other transgressions and unethical practices during the last year, which Dido dismissed as slight "problems" but said they were learning and improving all the time ..... of course.   :-/ ::)

The fine was for exceeding the allowance of silent calls permitted by Ofcom. It was for a breach that occurred two years ago. TalkTalk need only 'learn' to make no more calls than are allowed in order to avoid a fine. It does not have to make no silent calls.

---

loddon wrote on May 16^th, 2013 at 5:59pm:

Since posting I have just noticed the "click here" for other call types, my lack of perspicacity  :-[.   However when clicking this is what the consumer is confronted with, dozens of pages (correction 183 pages, eek  :o):--- PREFIX CHARGEBAND […]

The Unbundled Tariff will mean that the different rates are quoted by the Service Providers. Each call provider will have one Access Charge which will be far simpler to convey and understand.

Of course each sub-prefix may have a different Service Charge associated with it, but this will be common to all originating providers.

loddon wrote on May 16^th, 2013 at 5:45pm:

What sort of cloud cuckoo land are Ofcom living in?

It may be helpful to understand the purpose of the current consultation by reading the consultation questions at stakeholders.ofcom.org.uk/binaries/consultations/simplifying-non-geo-no/annexes/Part_A_1_7.pdf#page=7.

Ofcom's role as a regulator applies to providers of communications services, where it is required to foster effective competition, which (it is believed by those who established Ofcom) will serve the interests of consumers. Whatever the truth, and whatever its officers may believe, Ofcom has to be seen to be operating within those limits.

On Silent Calls, Ofcom has the situation totally wrong, because the persistent misuse powers have nothing whatsoever to do with its powers as a regulator. Persistent Misuse has to be eradicated, not regulated, and in the interests of "citizens" (not "consumers"), as victims are not necessarily suffering at the hands of those who provide them with communications services.

Has anyone else noticed that Ofcom have estimated the Access Charge to be 16ppm??? :o

It is referred to by the THA (Telephone Helplines Association) where Ofcom quote the THA who were in turn quoting Ofcom's previous consultation in para A19.58 :---

"A19.58 THA also said it was not convinced that the unbundled tariff would necessarily lead to improved transparency for callers, because not all callers would be aware of their AC at the point of call. In particular it argued that if the AC was not lower than Ofcom’s estimate of 16ppm, the advertising requirements on the SC could be misleading, as they would detract from the real cost of the call."

This implies that a typical call to a 0845 number will be 26ppm plus the call set-up fee.    I say this because Ofcom were on BBC Breakfast TV this morning and Markham Sivak of Ofcom gave an example where he said in future under Ofcom's proposed regime a caller would see that a call to a 0845 number would be, say, 10ppm plus your network charge.  I guess he meant "access charge plus set-up fee" when he used the new term "Network Charge".

It doesn't seem that Ofcom expect the new regime to result in an improvement in call costs for consumers as a result of all this consultation.   :-? ::) :(

http://www.bbc.co.uk/news/business-22540999

Thanks sherbert for providing this link.   

There is one glaring mistake in the BBC report :---

"Under Ofcom's proposals, the charges will be split into two sections so consumers know what they are paying and where the money is going.

Callers will be told: "This call will cost x pence per minute, plus your standard access charge."

The access charge is a fixed fee that will go to the telephone company. The service charge, quoted in pence per minute, goes to the company being called."

Ofcom have made it clear that the access charge will ONLY be  a ppm charge and NOT a fixed fee., as the BBC have wrongly reported.

This is another example of Ofcom's erroneous (rip-off) thinking because there is no justification for the AC being ppm.   The service being provided by the originating phone company (OCP) is to put the call through; once that is done there is nothing more for the OCP to do so why should they continue to rake in a charge on every minute of the call??   This is what most people will call a RIP-OFF !!   Just one aspect of how Ofcom are proposing the system to work.   Unfortunately this exposes yet again that Ofcom are not trying to regulate the market they are blatantly assisting the phone service industry in continuing their RIP-OFFs.   

Again we have to conclude that Ofcom is either incompetent or deliberately malicious in failing to protect the public, consumers, from harm.   This whole review and consultation process can be seen to be yet another scam perpetrated by the regulator.   This is not a partial or biased view because if you look at the comments on this BBC report you see they are coming in thick and fast and almost every one is deeply critical of Ofcom and its proposals, for example ;---

" 133.itsdavehere
26 Minutes ago
Ofcom should be looking companies that have these automated queues/options menus etc... as these are a real money spinner for the phone companies and the companies that use them.
They are open to abuse as an easy way to rip off the consumer.

The law should be changed stating that, if a company uses these automated services, then the call MUST be free! Why should I have to pay to wait in a queue?

132.spam spam spam spam
27 Minutes ago
Some people are "put off" making important calls because of confusion over the amount they will be charged,

CORRECTION - Some people are "put off" making important calls because they know so many "customer service lines" are blatant extortionate rip offs, designed to maximise profit & even if you were the 1st to phone 1st thing in morning "sorry we are experiencing high call volumes",

131 16.rememberdurruti
4 Hours ago
"The service charge, quoted in pence per minute, goes to the company that you are calling"

Make this illegal, pass a law and fine companies that charge you. Why should you have to pay these companies when you ring them to complain about their lousy service."

When I started writing this post there were 127 comments and it has now grown to 157 and they are all deeply critical and unhappy with Ofcom.   I have only found one comment that is slightly in favour.   So if Ofcom does not think again and change these proposals radically it looks like the disaster I fear and have predicted is likely to happen. :( >:(

162.voice of reason
42 Minutes ago
You have reached the Government Destiny Helpline.

To abandon the current Government press 1
To reduce the involvement of politics in every detail of your life press 2
To introduce online instant referenda on critical issues press 3
To introduce lie detection in politics press 4
To divide the country into more self governing territories press 5
To prosecute corporate/banking criminals press 6

85.RDG
3 Hours ago
Ofcom should have addressed this issue several years ago, but it chose to ignore it.
Why do we have to put up with Government Regulators that are not fit for purpose?

84.cathinscotland
3 Hours ago
I recently got stung by an 0844 number and sworn never to call another one! Making it simpler will help business and the rest of us. Doing a voice over that tells us, what the cost will be in we continue the call is a great idea. I for one, will hang up, at the point!

83.Colin2108
3 Hours ago
Ofcom, like all regulators, is a smokescreen shielding the companies. It does not protect or serve the customers. It should be illegal for any call recipient to make money just for receiving the call. That is simple but it will not happen, Ofcom and the government will see to that. But worst of all are doctors' surgeries using 0844 numbers to take money from ill patients.

82.Michael Lloyd
4 Hours ago
Why on earth should any calls (inside a gien country) cost any more than any others, dependent upon number? Why can we not have a simple, straightforward cost per second for the use of line and equipment? Similarly, why can we not have a simple cost per mile for train fares? And a cost per unit for gas/electricity? All these "tariffs" exist to screw us, as ever. I'm sure "simplification" will, too

113.WatchdogSucks
3 Hours ago
For the consumer there is zero advantage in these '08' numbers. Many people today only have a mobile number and as such have to pay way above the odds to make a call which more often than not is actually a helpline anyway. For Ofcom to sit by and have silently condoned this situation to prosper is a scandal itself. Minor lip-service from them now does nothing to redress their inaction.

loddon wrote on May 18^th, 2013 at 11:29am:

Has anyone else noticed that Ofcom have estimated the Access Charge to be 16ppm??? :o It is referred to by the THA (Telephone Helplines Association) where Ofcom quote the THA who were in turn quoting Ofcom's previous consultation in para A19.58

Anyone who is genuinely interested to understand the point being made by THA needs to follow the references given in the documents as follows (I include links for anyone who does wish to follow the track):

para A19.58 of the (Annex to) Section B of the current Ofcom consultation has a footnote (⁵⁰) which refers to:

THA, April 2012 consultation response, pp.5 - 6, which (at the bottom of page 6) refers to:

estimates provided by Ofcom in Part B - Table 10.2, which shows the figure of 16.1 ppm as the estimated current revenue retention level value for mobile OCPs on calls to 084/087/09/118 numbers, using data from the 2010 Flow of Funds study.


If anybody would like to argue that this represents a current Ofcom projection for what any particular (or averaged) Access Charge will be in 2015, then I would be interested in giving serious attention to the point being made.



loddon wrote on May 18^th, 2013 at 11:29am:

It doesn't seem that Ofcom expect the new regime to result in an improvement in call costs for consumers as a result of all this consultation.   :-? ::) :(

The problem with the size of these consultation documents is that it is very easy to dip in and pull out some figure to use for any purpose that one wishes.

---

loddon wrote on May 18^th, 2013 at 11:29am:

… I guess he meant "access charge plus set-up fee" when he used the new term "Network Charge".

Because Ofcom has determined that …

Quote:

the AC can be charged at a ppm rate only

(Bullet #3, section 5.3 of Part A)

… there will be no "set-up fee" on calls to Unbundled Tariff numbers.

I suspect that the term "Network Charge" was intended as a synonym for "Access Charge" (the formal term) which could be more readily understood by viewers of "Your Money". With text messages it is common to use the term "network rate" to refer to the equivalent of the Access Charge. It may be that "Network Charge" will appear more commonly in normal usage than "Access Charge". Alternatively we may be making too much of this. "Access Charge" is the formal term; "Your Money" is notable for its informality.

loddon wrote on May 18^th, 2013 at 1:51pm:

Quote: … The access charge is a fixed fee that will go to the telephone company. The service charge, quoted in pence per minute, goes to the company being called."

The point that should have been made is that the rate of Access Charge is fixed for each caller, whereas the Service Charge will vary according to the company being called. This got mixed up by implying that the Access Charge was a fixed fee, rather than a fixed rate.

The number of errors in the on-line article and the filmed package is about normal for this type of item in any news medium.

---

There are many good points being made by contributors to the online discussion. Opponents of our membership of the EU will be disappointed to see extensive support for the provisions of the EU Consumer Rights Directive.

---

Perhaps the topic of the legitimacy of telephone call charges being linked to the duration of the call requires a thread of its own. This is an interesting topic, which demands proper consideration.

loddon wrote on May 18^th, 2013 at 1:51pm:

...This is another example of Ofcom's erroneous (rip-off) thinking because there is no justification for the AC being ppm.   The service being provided by the originating phone company (OCP) is to put the call through; once that is done there is nothing more for the OCP to do so why should they continue to rake in a charge on every minute of the call??...

The SP would still charge the OCP a ppm for the length of the call and so this is why OCP charge a ppm rather than a one-off charge.

---

SilentCallsVictim wrote on May 18^th, 2013 at 3:23pm:

… there will be no "set-up fee" on calls to Unbundled Tariff numbers.

Both "set-up fees" and "minimum call charge" accomplish the same thing in my eyes.  They allow the OCP extra revenue for the connection of the call regardless of length.

---

If Ofcom have said there will be no "set-up fees" does this include "minimum call charge" as well?

---

Has Ofcom proposed a maximum "access charge" but are hoping that OCPs compete with each other and so undercut each other?

bbb_uk wrote on May 18^th, 2013 at 5:31pm:

The SP would still charge the OCP a ppm for the length of the call and so this is why OCP charge a ppm rather than a one-off charge.

Surely this is more related to the fact that (apart from "unlimited" packages and certain special call types) OCPs invariably charge according to the duration of the call, e.g. for non-inclusive calls to geographic numbers from landlines, and to both mobiles and landlines from mobiles. The suggestion that OCPs should ONLY charge a call set-up fee is an exciting and radical idea that warrants serious discussion. This is also an argument for fixed fee Service Charges.

There is also a strong argument for this from those who believe that they should not be paying for being connected whilst they are waiting to speak with someone or navigating a menu system.

My belief is that because we are very much moving to the situation where we pay a flat fee for all our calls (either through unlimited packages or packages that more than cover our needs) has already dented the idea of the ticking meter being a feature of telephone conversations.

---

bbb_uk wrote on May 18^th, 2013 at 5:31pm:

SilentCallsVictim wrote on May 18th, 2013 at 3:23pm: … there will be no "set-up fee" on calls to Unbundled Tariff numbers. Both "set-up fees" and "minimum call charge" accomplish the same thing in my eyes.  They allow the OCP extra revenue for the connection of the call regardless of length.

I cannot see how a minimum duration (for charging purposes) affects the revenue from a call of greater than the minimum duration.

---

bbb_uk wrote on May 18^th, 2013 at 5:31pm:

If Ofcom have said there will be no "set-up fees" does this include "minimum call charge" as well? Has Ofcom proposed a maximum "access charge" but are hoping that OCPs compete with each other and so undercut each other?

The following slightly larger extract from my comment includes a link to the relevant section of the summary of the Ofcom plan. This includes answers to the further questions.


SilentCallsVictim wrote on May 18^th, 2013 at 3:23pm:

Quote: the AC can be charged at a ppm rate only (Bullet #3, section 5.3 of Part A) … there will be no "set-up fee" on calls to Unbundled Tariff numbers.

Perhaps it is worth repeating some general points made earlier.

The Ofcom plan is based on the assumption that if Service Providers have to declare Service Charges and OCPs declare Access Charges, then only those which can be justified for callers will remain, and this will be at a level that is (in some general sense) acceptable.

I fully recognise the argument that consumer power cannot be guaranteed to work, but I do not accept that it is so weak that Ofcom has to make decisions about what is acceptable on behalf of consumers. As I have said previously, I would not trust Ofcom to get the decisions right anyway! (I suspect that Ofcom shares my view.) I am not warmed by the idea of Citizens Advice Bureaux perhaps being able to say that their Service Charge (be it on 0844 or 0944 numbers) was approved by Ofcom. I would rather engage in argument over this with them, believing that it was none of Ofcom's business to decide such matters. (Citizens Advice is strongly opposed to the "unbundled tariff".)

The Ofcom plan covers all cases where Service Charges are imposed, including Premium Rate Services and Directory Enquiry services. Most comments are focussed only on those cases where a Service Charge is obviously unacceptable or will be prohibited by the provisions of the Consumer Rights Directive. Strongly expressed feelings of this sort are actually supportive of the Ofcom approach, because they indicate that unwarranted Service Charges will not be accepted.

By treating 084 numbers in exactly the same way as the PRS ranges, the unbundled tariff finally (and belatedly) exposes them for what they are, thereby clearing placing the responsibility for that element of the call cost on the Service Provider. It also brings far greater clarity to the commonly misleading call cost information required with PRS, thereby leaving them (notably the improper use of 087x numbers) more open to direct challenge.

SilentCallsVictim wrote on May 18^th, 2013 at 7:23pm:

bbb_uk wrote on May 18th, 2013 at 5:31pm: SilentCallsVictim wrote on May 18th, 2013 at 3:23pm: … there will be no "set-up fee" on calls to Unbundled Tariff numbers. Both "set-up fees" and "minimum call charge" accomplish the same thing in my eyes.  They allow the OCP extra revenue for the connection of the call regardless of length. I cannot see how a minimum duration (for charging purposes) affects the revenue from a call of greater than the minimum duration.

I didn't realise Ofcom had stated that a maximum of 1 minute minimum call charge would apply.  I thought that OCP's would try and use expensive minimum call charge to get around the no 'set-up fee'.  So an accidental call lasting a second or two will only cost same as 1 minute whereas without the maximum limit of 1 min, there would have been nothing stopping OCPs from stating a minimum call charge of 20p even though ppm may be 10ppm.

---

My main concern is that companies may get away with saying that "calls cost 2ppm plus network extras" when under current system it states calls cost 5ppm from BT landline, other networks may charge more"

I agree that under current system calls can vary for every sub-division of 084 which can cause even more confusion so under the new system so long as AC is same for every 084 which it is then that would improve clarity.

But all this still is based on consumers being aware of the AC in the beginning which is assuming OCPs use same AC regardless of tariff (which they don't have to) and they are as open with the AC charge as they are their geographical call costs.  The latter, I suspect (going by previous history) we may find that OCPs try to hide as much as possible their AC charge.

bbb_uk wrote on May 18^th, 2013 at 9:04pm:

My main concern is that companies may get away with saying that "calls cost 2ppm plus network extras" when under current system it states calls cost 5ppm from BT landline, other networks may charge more" … and they [OCPs] are as open with the AC charge as they are their geographical call costs.  The latter, I suspect (going by previous history) we may find that OCPs try to hide as much as possible their AC charge.

Regardless of the extent of the work done by Ofcom and the enforcement agencies (e.g. ASA, OFT, Trading Standards), there will continue to be a role for consumer pressure groups and campaigners to ensure that any improprieties are recognised and understood.

The clarity provided by the unbundled tariff will make this much easier than it is under the present regime, because the respective responsibilities for the components of the charge will be identified beyond dispute.


bbb_uk wrote on May 18^th, 2013 at 9:04pm:

I agree that under current system calls can vary for every sub-division of 084 which can cause even more confusion so under the new system so long as AC is same for every 084 which it is then that would improve clarity. But all this still is based on consumers being aware of the AC in the beginning which is assuming OCPs use same AC regardless of tariff (which they don't have to)

There may be some confusion about the term "tariff".

There will be only one Access Charge for each consumer tariff, covering calls to all 084, 087, 09 and 118 numbers, even though each sub range will have a different level of Service Charge.

Each OCP will be able to offer different Access Charges for its different packages. Based on the way in which call charges are currently set, it is not unreasonable to expect that the only difference will be in respect of inclusion (free of charge) rather than the actual rate charged.

---

We have no clear idea about how OCPs will set a single level of Access Charge to replace the present system, whereby they vary enormously, and BT is prohibited from applying an Access Charge. We do however know that Service Charge levels will remain essentially as they are at present (notwithstanding some tweaking).

The fair telecoms campaign is seeking to focus attention on those who levy a Service Charge inappropriately, using the clarity now offered by Ofcom, rather than criticising Ofcom for failing to perhaps attempt to distinguish between proper and improper cases. That is not say that we agree with everything Ofcom has done, but we see the improper imposition of Service Charges as being the main issue of popular concern.

SilentCallsVictim wrote on May 19^th, 2013 at 7:37am:

Regardless of the extent of the work done by Ofcom and the enforcement agencies (e.g. ASA, OFT, Trading Standards), there will continue to be a role for consumer pressure groups and campaigners to ensure that any improprieties are recognised and understood.

All that is needed is that Ofcom actually actively enforce what they say instead of basically letting them get away with it.

There is a requirement even now (GC 14.2) that is meant to give similar prominence to 08x/087x as there is geographical and this GC has been in operation since August 2006.  For ages after I kept letting Ofcom know but only once did Ofcom raise an "own-initiative".  In the end I stopped bothering letting Ofcom know because it was clear that Ofcom is more on the side of teleco's than consumers due to their lack of bothering to do anything.

To this date, I wonder how many OCPs actually fully comply with this GC?

---

Essentially, all I see happening is price of NTS calls increasing once BT introduce their AC and all other OCPs will basically just copy like they do now.

I still anticipate that for many consumers they will not be aware of how much a call actually costs ppm because companies will be able to display lower SC ppm rather than an overall guide and I believe OCPs will go out of their way to avoid the AC being easily found/known.

---

The simple answer to this is make 0844/0871 classed as a PRS and subject to full PRS regulations as essentially these calls are used to gain money from the call for the company called in someway or another.

Most companies wont use 09x range due to the fact that callers know they are premium rate so instead use stealth premium rate 0844/0871 numbers instead.

bbb_uk wrote on May 19^th, 2013 at 8:44am:

All that is needed is that Ofcom actually actively enforce what they say instead of basically letting them get away with it. … To this date, I wonder how many OCPs actually fully comply with this GC?

The current failure to enforce the various relevant GC's is wholly unacceptable. By taking radical and substantial action, Ofcom is drawing much more attention to its future enforcement activity and it must not be permitted to get away with further weakness in this respect. That is critical to its success with a brave project that puts its reputation on the line.

Enforcement of the requirements newly imposed on those who will continue to use 084 / 087 numbers, was not seen to be realistic under the self-regulatory regime which applies to PRS (i.e. PhonePay Plus). There is a strong argument for reversing the mistake of adding the 087 range, but this would be seen as sending an unsuitable message.

It is perfectly correct to apply the same cost declaration requirements to 084 / 087 / 09 and 118 numbers, however the strongly seen difference in usage demands that suitably refined and distinct further regulatory measures be applied. I believe that such measures are rightly beyond the scope of Ofcom's responsibilities, including those devolved to Phonepay Plus.

SilentCallsVictim wrote on May 19^th, 2013 at 10:04am:

The current failure to enforce the various relevant GC's is wholly unacceptable. By taking radical and substantial action, Ofcom is drawing much more attention to its future enforcement activity and it must not be permitted to get away with further weakness in this respect...

Wish I could believe that Ofcom wont continue to be weak, but going by past history, I can't help but think this whole re-organisation is going to cause more confusion due to lack of action by Ofcom to enforce its own GC, etc.

IMHO, Ofcom seem to side moreso with the industry than general consumers.

bbb_uk wrote on May 19^th, 2013 at 6:33pm:

IMHO, Ofcom seem to side moreso with the industry than general consumers.

The nature of Ofcom's role is to regulate the behaviour of providers in a supposedly competitive market by measures that are reasonable in the eyes of the law. It can only deliver benefits to consumers in that market through the way in which those providers behave. It is thereby inevitable that it will appear to be far more concerned about the industry than consumers, because that is where its attention has to be focussed.

IMHO, Ofcom is too concerned about the risk of being found to be unreasonable in its actions and is therefore far too weak in its enforcement activity. It also has a policy of only taking action in big headline-grabbing cases which means that it will not commit resources to relatively minor, but nonetheless significant, cases. It claims that lesser matters are dealt with by private informal action, which it cannot detail, because this has to remain confidential.

For the record, I can state that I am deeply unhappy with this approach, however I cannot see any prospect of it changing significantly whilst Ofcom's role as a regulator remains as it is. Ofcom's use of the persistent misuse powers (in relation to Nuisance Calls) has nothing to do with its role as regulator, although Ofcom behaves as though it does. That is why I am seen to be strongly opposed to Ofcom on a fundamental point of principle in that respect.


The present level of public confusion is enormous and is not helped by the BBC reporting on measures being taken, and then concluding that this will do nothing to help. Hear the comment at the end of the error-filled piece in the middle of this programme. (If anyone knows how to set start points for BBC embedded player items, then please advise by PM).

SilentCallsVictim wrote on May 20^th, 2013 at 8:12am:

The nature of Ofcom's role is to regulate the behaviour of providers in a supposedly competitive market by measures that are reasonable in the eyes of the law... [quote]...Ofcom is too concerned about the risk of being found to be unreasonable in its actions and is therefore far too weak in its enforcement activity...

Couldn't agree anymore.

SilentCallsVictim wrote on May 20^th, 2013 at 8:12am:

The nature of Ofcom's role is to regulate the behaviour of providers in a supposedly competitive market by measures that are reasonable in the eyes of the law...

Quote:

...Ofcom is too concerned about the risk of being found to be unreasonable in its actions and is therefore far too weak in its enforcement activity...

Couldn't agree anymore.

SilentCallsVictim wrote on May 20^th, 2013 at 8:12am:

It is thereby inevitable that it will appear to be far more concerned about the industry than consumers, because that is where its attention has to be focussed.

It doesn't just appear to be more concerned about the industry than consumers; surely any objective assessment would conclude that it has failed to safeguard the interests of consumers over many years and has stood by and allowed consumers to be exploited and in some cases seriously harmed (in a financial sense).   Is that not contrary to the Ofcom purpose and reason for its existence?   Should it not be doing more for consumers and be seen to be doing it?   Is there not some mechanism to watch over Ofcom and evaluate its effectiveness compared to its charter?   I suppose the Parliamentary Select Committee is supposed to do that job, but it seems hopelessly incapable judging by past performances, spending little more than an hour once per year weakly and timidly questioning Ofcom officers.

Comments on the recent BBC story included several with very specific criticism of Ofcom :---

"207.  tellitasitis
18th May 2013 - 16:21
Hang on, lets not expect OFCOM to actually do something meaningful. We must remember that the one thing OFCOM does not want to do, is adversely affect the scandalous profits of the telecommunication industry. This may result in the telecommunication industry not supporting OFCOM and that they would actually have to look after the consumer and deliver something in the consumers interest."

"216.  adam
18th May 2013 - 17:16
OFCOM always do too little too late.The numbers and charges fiasco should have been implemented at least ten years ago"

"236.  cyclotrimethylenetrinitramine
18th May 2013 - 18:46
OfCom? Should that not read OfCon?
IMHO, a complete waste of the tax-payers money - a bit like the FSA and many other 'supervising'/'standards' agencies set up to provide high-earning opportunities for the incompetent and/or pocket-lining pals of Government."

"255.  John Campbell
18th May 2013 - 20:39
Ofcom have got this wrong.
There is no public confusion
The public know when they are being ripped off.
Bit late for them to realise that.
An OfGov with sharp teeth and claws would be good!
(thanks wonkypops)"

Some are suggesting that another body should have oversight of Ofcom's performance and have the teeth to hold Ofcom to account, because this is not currently seen to be happening, and Ofcom has shown itself to be incapable.

loddon wrote on May 20^th, 2013 at 11:59pm:

SilentCallsVictim wrote on May 20th, 2013 at 8:12am: It is thereby inevitable that it will appear to be far more concerned about the industry than consumers, because that is where its attention has to be focussed. It doesn't just appear to be more concerned about the industry than consumers; surely any objective assessment would conclude that it has failed to safeguard the interests of consumers over many years and has stood by and allowed consumers to be exploited and in some cases seriously harmed (in a financial sense).   Is that not contrary to the Ofcom purpose and reason for its existence?   Should it not be doing more for consumers and be seen to be doing it?   Is there not some mechanism to watch over Ofcom and evaluate its effectiveness compared to its charter?   I suppose the Parliamentary Select Committee is supposed to do that job, but it seems hopelessly incapable judging by past performances, spending little more than an hour once per year weakly and timidly questioning Ofcom officers.

I think most of us agree that the measures being brought forward now are long overdue.

I am personally furious that the Select Committees have not been stronger in holding Ofcom to account.

We will see whether DCMS proposes any significant changes when the Communications White Paper is published, but the Bill will not be following in this session. There will therefore be plenty of opportunity for those who advocate a re-structuring of Ofcom to present their proposals.

Perhaps we need another thread to discuss these issues.

I also sense a call for the re-nationalisation of the industry, so that the state may be fully accountable for its effects on consumers. Privatisation with "Of"s has not been seen to be a glittering success in general, and the oft-suggested "OfOf" solution, with the inevitable "OfOfOf" to follow etc. is surely not the answer. "Quis custodiet ipsos custodes?" (the motto of the former OfcomWatch blog) would be an excellent title for another thread.


As stated above, I am unhappy at Ofcom's timidity in enforcing compliance and question the extent to which the market is competitive. These realities limit what may be achieved, along with many others, but I do not accept that they make the cause hopeless. I disagree with the quoted suggestion that consumers are not confused, however I believe that the BBC is being unhelpful in simply reporting and sustaining that confusion, rather than attempting to diminish it a little.

I can understand the position of those who have given up on Ofcom and wish to dismiss its measures because they come from Ofcom, or who believe that it has improper motives. I do not however share that view, and if I did, I would not waste my valuable time and energy by engaging in this discussion.

SilentCallsVictim wrote on May 21^st, 2013 at 1:04am:

I am personally furious that the Select Committees have not been stronger in holding Ofcom to account.

I think we are of like mind, SCV.    Perhaps this might be a good objective for the Fair Telecoms Campaign to consider --- to bring this issue specifically to the attention of the Select Committee, now, as that would give them time to think deeply about the problems and to prepare for their next annual meeting with Ofcom which I think is in September?   I am now thinking about writing to my MP on this specific topic asking him to raise the issue with the Chairman of the Committee, and maybe others should consider doing the same?

By the way, I suspect that several readers may be wondering what is the DCMS, should we enlighten them?

SilentCallsVictim wrote on May 21^st, 2013 at 1:04am:

I also sense a call for the re-nationalisation of the industry, so that the state may be fully accountable for its effects on consumers. Privatisation with "Of"s has not been seen to be a glittering success in general, and the oft-suggested "OfOf" solution, with the inevitable "OfOfOf" to follow etc. is surely not the answer. "Quis custodiet ipsos custodes?" (the motto of the former OfcomWatch blog) would be an excellent title for another thread.

Are you suggesting that I am calling for renationalisation, or do you see this in some of the responses to the BBC article?   I think setting up an "OfOf" would be easier and less costly than renationalisation of whole industries.
Perhaps you would be a good candidate for your suggestion of an answer to "who guards the guards?"



SilentCallsVictim wrote on May 21^st, 2013 at 1:04am:

As stated above, I am unhappy at Ofcom's timidity in enforcing compliance and question the extent to which the market is competitive. These realities limit what may be achieved, along with many others, but I do not accept that they make the cause hopeless. I disagree with the quoted suggestion that consumers are not confused, however I believe that the BBC is being unhelpful in simply reporting and sustaining that confusion, rather than attempting to diminish it a little.

Agreed, there is a severe lack of competitiveness in the 084/087 market and I have been saying why for a long time.   I don't see such limitations as you seem to and would hold out hope for someone in Ofcom to really start thinking deeply and making decisions.

I believe that the response containing reference to confusion was in the context of "The public know when they are being ripped off."   Therefore   "There is no public confusion" about that.


SilentCallsVictim wrote on May 21^st, 2013 at 1:04am:

I can understand the position of those who have given up on Ofcom and wish to dismiss its measures because they come from Ofcom, or who believe that it has improper motives. I do not however share that view, and if I did, I would not waste my valuable time and energy by engaging in this discussion.

I don't know if you are suggesting I have given up on Ofcom, but I would say not quite.   This little last minute marketing exercise by Ofcom may indicate that there may be a slim chance that they will redeem themselves.   Certainly this has been a salutary exercise for Ofcom to see the virulent and aggressive responses to the proposals from the public.   It all endorses what I have been saying, that these proposals are ill-founded having no ethical basis, responding to a mistaken analysis of the problem and trying to conjure up a fictitious demand which does not exist.   All the demand for 084 and 087 numbers comes from the organisations who benefit and NOT from the public .   The public, the consumers, want genuine simplicity, not faux, and to see real competition.   I and others have previously suggested how this may be achieved.

I attended my local Neighbourhood Action Group (NAG) last night and the Chairman asked me to give an update on the telephone numbers scene.   I took the opportunity to refer to the recent BBC report on the Ofcom proposals, which some said they had seen   The BBC headline states "Phone cost confusion putting off callers, Ofcom says" which I think fairly Summarises the Ofcom conclusion that confusion is putting off callers from dialling 084 and 087 numbers.   I offered my opinion that Ofcom had mistakenly analysed the problem and that the real problem was the cost of calling these numbers being imposed on callers whereas the cost should be for the organisations who want them and benefit from them.  Confusion and lack of transparency added to the problem but are not the root cause.   There is no demand for these numbers from the public and many would be happy to see them disappear.  There was unanimous agreement for that view.

Referring to readers comments on the BBC report we see:---

"225.  Brian McNaughton
18th May 2013 - 17:58
About time. All these technical advances seem to involve a degree of ripping off the public. Amazing that ofcom did not spot this at the begining or are they a branch of the organisations being called?"

"224.  revolutionnow999
18th May 2013 - 17:53
Phone companies, energy companies and banks. They are private organisations who confuse their customers about their charges, so they can get more money out of them. It is the accepted practice for their salesmen. And it is not surprising that private companies push at the boundaries of legality to make more profit when regulators have a proven tracker record of being powerless."

"213.  David Holder
18th May 2013 - 16:37
My phone package includes calls of up to 1 hour to 01, 02 & 03 Numbers. If you want to get rid of anything then get rid of 0845 which so many businesses use and customers then have to pay extra to call."

"209.   mog499
18th May 2013 - 16:24
I recently looked up a number on the internet for a company. when I dialled the number it was a mega premium rate it took all the credit from my phone. It warned me I was being charged a high rate but emptied my phone before I cut off the call. Rip off Britain they are all at it."

"196.  Andy
18th May 2013 - 15:32
I have had a gripe with Silverstone Circuit who use a 0844 number. After numerous unanswered calls listening to a prerecorded message for over a total of 2 hours I found I'd been charged nearly £8 for not getting through.
I have been compensated but these prerecords should tell the caller that they are being charged while waiting"

"193.  Ian
18th May 2013 - 15:14
No one should have to pay to speak to a business particularly one that they are having problems with. I strongly object to paying credit card companies if I have a problem. 0844 and 0871 numbers should be banned they are used just to make more money out of their customers. I don't place orders with companies the only use 0844 and 0871 numbers, they don't get my business."

"181.  widgeon
18th May 2013 - 14:50
I have never understood why a company would use a non-geographic number unless they have something to hide. I used to work for a charity that ran loads of 0870 numbers. When I questioned it the managers over-ruled me. They were trying to give the impression that "helplines" were call centres when in fact they were staff by one person"

These comments reflect a general dissatisfaction that will not be satisfied by greater transparency alone.   The fundamental problem is that people recognise they are being charged unfairly, the organisations they are calling should pay for the facilities and benefits attributed to these numbers.

Readers will notice that one person who commented liberally on the other comments on the BBC report called himself FoneDave, and I suspect that many might think that FoneDave spends quite a lot of his time not far away from this Forum.   I would say, what a good job was done and how well and calmly he answered and explained many of the questions and misconceptions raised within the other comments.   Well done FoneDave. :)

It leads one to wonder whether Ofcom bothered to read the comments and on seeing so many misunderstandings on display why Ofcom did not take the trouble to provide some answers and explain in simple terms what they are proposing and the implications and results that they are expecting.   Instead they seemed to just leave it to an unpaid person of goodwill to do their job for them instead of taking advantage of a golden opportunity.   It make s one think Ofcom doesn't really want to support and explain/clarify their own proposals.

An example of one of FoneDave's responses :---
"249.  FoneDave
18th May 2013 - 19:48
Re: 99 "All companies using 08*** numbers should have to provide an alternative 01/02/03 number as these are included in call bundles from both landline and mobile." -- Even better, most companies are going to be FORCED to move from 084 and 087 numbers to 01, 02 and 03 numbers by the Bill on Consumer Rights. This EU directive has to be passed into UK law by the end of 2013."

It is indeed fortuitous that the Consumer Rights Directive is arriving at this time and I welcome the CRD and believe that it will help quite a lot with the problems on 084 and 087 numbers, and will of course prevent some organisations from considering a move to 09 numbers.    However, I think CRD will only be a partial solution to the problem.   It would be even better if Ofcom would design a full solution.

loddon wrote on May 21^st, 2013 at 8:26am:

SilentCallsVictim wrote on May 21st, 2013 at 1:04am: …

As stated above, I believe that much of what we are addressing is beyond the proper scope of this thread. Some points could be worthy of discussion in their own right, in particular the reconfiguration of Ofcom and its powers, which some believe would be required for these measures to be turned into something effective.

I will address points of direct relevance.

In the absence of clarity offered by the "unbundled" tariff, I do not believe that the public in general know when they are being ripped off - and in particular, by whom. The true significance of the content and balance of comments posted to the web in response to a news article may be readily exaggerated. This is a common failing by the media itself, although one that campaigners are ready to exploit.

As stated previously, I believe that the genuine demand to be able to apply Service Charges of less than 13p per minute is very much less than Ofcom is assuming. At this stage however, I cannot offer the evidence necessary to show that a greater minimum Service Charge level must be set. ALL improper imposition of Service Charges has to be an issue between those who impose them and those they serve.

I do not believe that the question of whether a Service Charge is used to offset the costs of network facilities, locally deployed systems or the staff attending calls, to provide other financial benefits to the Service Provider or simply to make money is a fundamental issue. It makes no difference to the caller, although such points can be used in an attempt to justify a Service Charge. I can see no point whatsoever in focussing only on the first of these.

Markham Sivak's brief appearance on "Your Money" was not a "last minute marketing exercise"; in that sense it was preliminary. I understand that the major Ofcom marketing exercise will begin once the statutory hurdle of the consultation has been passed, so that what are currently technically only "proposals" can truly be presented as fact.

It is accepted in the Ofcom consultations that there is little, if any, direct competition over Service Charges of less than 13p per minute and that the level of Access Charge will not be a major factor in selecting a call service provider. Providers in competitive markets can however be sensitive to all manner of relatively insignificant issues that may affect public perception of them and their products and services. That same sensitivity also exists when there is no competition at all. It is for consumer groups and campaigners to exploit that sensitivity - may I offer the recent announcement by Daisy Group as a case in point. In terms of competition, I cannot see what could be clearer than the parties levying charges each being compelled to declare it (rather than two separate charges being bundled together). In this respect, I do not understand what is the "real competition" that "the public - consumers" want.

I know that many people get hung up on the issue of "choice". I cannot however see the merit of those who provide access on an expensive number with a Service Charge also providing access on a number without a Service Charge. Obviously the former would have to offer some priority, or a higher quality of service once connected. If there is a demand, presumably from the wealthy, to have better access than others, then a Service Charge could be used for this purpose. I cannot however think of many cases where this would be appropriate, indeed it will be prohibited in cases subject to the provisions of the CRD. (If "FoneDave" is a member of this forum, perhaps he would like to respond to this criticism of his proposal.)

In one of his responses to the BBC report FoneDave said :---

"200.  FoneDave  18th May 2013 - 15:46
"0844 and 0871 numbers should be banned." -- Rather than ban these numbers outright (and thereby close down legitimate users such as dial-in conferencing systems, dial-up internet and pre-recorded information lines) Ofcom will require users to declare the Service Charge. In 2014, the Bill on Consumer Rights will force customer services, etc, off 084/087 numbers and over to 01, 02 and 03 numbers"

Such services would not necessarily close down because 03talk.com have offered services on 03 numbers for years and seem to be thriving.
http://www.03talk.com/

loddon wrote on May 22^nd, 2013 at 9:01am:

Such services would not necessarily close down because 03talk.com have offered such services on 03 numbers for years and seem to be thriving. http://www.03talk.com/

03talk proudly claims that its service is unique, but fails to explain how it can be provided without any visible means of income. If something looks too good to be true, perhaps one should question how this may be, before suggesting that something identified as being unique offers a model that could readily be followed by others.

(In this case, the truth actually lies in a rather quirky feature of the way in which the fractional elements of termination charges are paid and the readiness of some businesses to operate on tiny margins with low overheads in the hope of capturing a sufficient share of the market for the business to be sustainable.)


I do not hold with idea that some Service Charges are "legitimate" and all others are not, although introduction of the provisions of the Consumer Rights Directive will render some illegitimate. I argue that every Service Charge has to be justified to those who may pay it, in terms of its very existence and the level at which it is imposed.

This can only be done if it is seen in isolation from the consequential, but highly variable, Access Charge. The level of Access Charge in turn must also be justified by those who impose it, and the inevitability of the Access Charge is a further consideration that must be covered in the justification of the Service Charge.

Most of the particular cases that generate public concern are clearly unjustified and unjustifiable. The sooner that attention can be drawn to them (in the light of the forthcoming requirement for the Service Charge to be declared), the sooner the issues can be resolved.

SilentCallsVictim wrote on May 22^nd, 2013 at 9:59am:

Most of the particular cases that generate public concern are clearly unjustified and unjustifiable. The sooner that attention can be drawn to them (in the light of the forthcoming requirement for the Service Charge to be declared), the sooner the issues can be resolved.

I agree, most are unjustifiable and most generate public concern, there is plenty of evidence of that.  You seem to be supporting my argument in post #30 where I said :---

  "I am not decrying your campaigning efforts in general SCV but I do feel that your backing for Ofcom in these proposals is unfortunate because the ultimate goal of elimination of “Service Charges (and the consequent incurring of Access Charges) in all cases where it cannot be justified” will depend on consumer pressure and campaigners efforts rather than regulation ...."

Even the phone industry understands that it is really perpetrating a scam.   For example Windsor Telecom say :---

"033 Phone Numbers from Windsor Telecom
We like to think of 0330 numbers and 0333 numbers as being 'fair for all', meeting the ever-growing public demand for a recognisable phone number range which is cheap to call from a both a landline and mobile. Calls to both 0330 numbers and 0333 numbers cost the same as a normal landline number (even from a mobile), or are completely free if the caller has free minutes. This is why a lot of savvy businesses are turning to 03 numbers and you might have even noticed some of the companies that use 03 numbers: BBC, EBay, Lloyds TSB, Transport for London and countless SME's.
Published on 11 Oct 2012 "  http://www.youtube.com/watch?v=vwcgMRCxGBo

Windsor Telecom market and sell all ranges of numbers including 01/02, 03, 080, 8845 and 0844 but Windsor see 03 as "fair for all" strongly implying that 084/5 are unfair.   There are small chinks of light through the wall of obfuscation put up by the phone services industry which let us know that the industry really does know that 084/7 numbers are rip-offs whereas 03 numbers are "fair for all".   

My point is that Ofcom are not prepared to regulate but are depending on the CRD and campaigners like us to battle to achieve some sort of fairness.   This is a cop out by Ofcom, although I accept that Ofcom are going to eventually, after another year and a half, provide a slightly more level playing field.   This is not playing fair by the consumers, it is relying on consumers complaining and campaigners battling.   As I said "This is a grossly inefficient way to stop rip-offs and scams.   Magrathea Telecom pointed out that there will be insufficient competitive pressure to effectively protect consumers from harm ....."   The efficient way to do it is by proper regulation.

Did anyone see the BBC TV ONE Show yesterday in which a reporter roamed the streets asking people what would be their idea of HELL?   One lady said without hesitation  "08 numbers!!!"  :) :-*

08 numbers are HELL.   The public speak the truth. :)

loddon wrote on May 22^nd, 2013 at 11:32am:

Quote: … the ultimate goal of elimination of Service Charges (and the consequent incurring of Access Charges) in all cases where it cannot be justified will depend on consumer pressure and campaigners efforts rather than regulation … The efficient way to do it is by proper regulation.

We have had some very interesting political ideas presented in this discussion. We now read the classic defence of fascism, as an alternative to the largely liberal (and thereby inefficient) society that we currently enjoy.


loddon wrote on May 22^nd, 2013 at 11:38am:

… 08 numbers are HELL.   The public speak the truth.

We have also been entertained by some classically silly ways of offering an argument in support of a particular point. (I fear that the final quoted sentence was intended to be taken seriously, but would be delighted to be corrected.)

One is tempted to get drawn into discussing “Room 101” and “1984” in general, but enough has probably been said.

These distractions are most unfortunate, because there is a very important issue, and shared objective, at the heart of this discussion - as stated in the first quotation above. I do not believe that our campaigning efforts have failed as dramatically as has been suggested, nor that they need to be undermined by applying so much attention to this alleged failure.

SilentCallsVictim wrote on May 22^nd, 2013 at 1:04pm:

We now read the classic defence of fascism, as an alternative to the largely liberal (and thereby inefficient) society that we currently enjoy.

Oh dear, when a debater resorts to desperation the argument is thereby conceded.   Even in a largely liberal society, and I wouldn't want any less, there is a need for some rules by which the game must be played in the interests of all, otherwise things can get distorted and even dangerous.  The natural forces of the market usually do their job well enough but sometimes it goes all wrong, just to mention some recent examples,

Libor Rate setting     http://en.wikipedia.org/wiki/Libor_scandal

Oil Price Rigging   http://www.dailymail.co.uk/news/article-2325217/Oil-price-fixers-face-prison-says-Cameron-Rigging-cost-household-2-000.html?ito=feeds-newsxml

PPI Mis-selling   http://www.guardian.co.uk/money/2013/mar/04/ppi-facts-figures-biggest-mis-selling-scandal

08 numbers HELL  http://www.thisismoney.co.uk/money/bills/article-2162169/Rip-phone-scam-big-companies-charging-customers-calls.html#comments

I could go on quoting for pages.   Therefore we must strive towards a balance between liberal markets for business and sensible rules and regulation, and I think many people, a vast majority, think that Ofcom has been negligent, incapable and wholly ineffective in regulating this market.   While the current Ofcom proposals are a small step in the right direction most people say they are still inadequate.   I find I have support from other members of this Forum as well as being able to point to Windsor Telecom, Antelope Consulting, Agrathea Telecom, The Federation of Small Business in arguing for better regulation.

loddon wrote on May 22^nd, 2013 at 2:48pm:

… most people say they are still inadequate …

Maybe the time for such an assessment is after they have been introduced.

I am not sure who is resorting to desperation or what specific point of argument is thought to perhaps have been conceded. I fully accept the common public perception that "08 numbers are hell" and believe that this can be focussed into effective pressure to achieve our common goal.

We have yet to see if the extent of the measures which Ofcom is taking will survive potential legal challenge. For this reason, the question of whether it could have gone further by, as proposed, imposing a minimum Service Charge of more than 13p per minute (or compelling mass number changes to keep things as they are, as has also been suggested) is open to some doubt. I hope we already understand that responsibility for regulating with regard to the purpose for which a Service Charge is applied generally falls outside Ofcom's remit, i.e. with BIS in the case of the CRD provisions, with the Cabinet Office or individual departments and bodies (e.g. NHS England) in the case of the public sector, with the industry self-regulator PhonePay Plus in the case of PRS and with others. Ofcom could set conditions regarding the imposition of Service Charges by those providers in the communications sector for which it has direct regulatory responsibility.

I have suggested that those who wish to discuss possible further extensions to Ofcom's powers at this time may wish to do so in another thread. We must however be concious that parliament will not be given the opportunity to debate possible legislation until the 2014/5 session. This assumes that the White Paper does emerge fairly soon and at least touches on the possibility of increased regulation (a principle that has been contrary to government policy for many years). The powers which have enabled it to be as radical as in the current measures only arrived in 2010, by virtue of a EU Directive.

I am ready to debate history, but I am far more concerned with how we move forward, using what I see as a significant positive development to our advantage. Clearly some believe that I am wrong, as I believe that Ofcom was wrong in its assessment of the true demand to use numbers that impose a Service Charge of less than 13p per minute. I am keen to persuade those who read this forum that I am right, because I am keen to engage their support for our continuing efforts, however I am not "desperate".

I want us to make a success of "The Big Question", because I believe that this will do more to advance the cause of "fair telecoms" than chewing over Ofcom's past and continuing failures. (This is distinct from my position on the issue of "Nuisance Calls", where I continue to believe that Ofcom is fundamentally wrong in its approach, which could and should be changed.) I will however be ready to concede a small measure of defeat if, as suggested, "The Big Question" attracts little or no public interest when it is launched shortly.

SilentCallsVictim wrote on May 22^nd, 2013 at 4:49pm:

I fully accept the common public perception that "08 numbers are hell" and believe that this can be focussed into effective pressure to achieve our common goal.

This seems to entirely agree with my argument; that Ofcom are not trying to deal with the problems of 084/7 numbers by proper regulation but Ofcom is intending to offer consumers a little more information about the cost of such calls and then leave it to campaigners to battle and consumers to complain in order to apply pressure over future years; because I suspect it will take years to get any significant change from the industry.   As I said before, transparency is welcome but it is a poor substitute for proper regulation.

loddon wrote on May 30^th, 2013 at 5:42pm:

… proper regulation …

I know that I am exaggerating when I comment that:

one man's ‘proper regulation’ is another's ‘fascist state’

If we want to discuss the nature and extent of Ofcom's role and powers in detail, then we should start another thread.

It is a matter of coincidence that an example of an alternative approach to regulation has today been brought to my attention. Some may see other nations as being more inclined towards "proper regulation" than the British.

See http://www.bundesnetzagentur.de/cln_1932/SharedDocs/Pressemitteilungen/EN/2013/130528SpecialServiceNumberCallQueues.html?nn=404530.

As I understand it, our telephone network cannot apply different rates for distinct portions of the duration of the call. Some may be excited about the idea of a state regulator getting involved in deciding when "a caller's business is being attended to". I make many calls where the person who answers is not in any way competent in dealing with my business, however I would not fancy having to argue my case for a refund of the call cost with a regulator.

Given that the Consumer Rights Directive will prohibit use of numbers including a Service Charge for customer contact an equivalent provision in the UK would only cover calls with a declared Service Charge, but not covered by the CRD. One suspects that another EU member was already addressing the queuing issue separately and has decided to press on, despite being required to also apply the more comprehensive regulations by the middle of 2014.

It may also be noted that the fair telecoms campaign has called for other sectoral regulators to get directly involved in placing specific regulations covering telephone usage on those whom they regulate. If there were a single state regulator covering telecoms, power utilities and public transport, then obviously this would be more easily achieved.

SilentCallsVictim wrote on May 31^st, 2013 at 7:56pm:

Some may see other nations as being more inclined towards "proper regulation" than the British. See http://www.bundesnetzagentur.de/cln_1932/SharedDocs/Pressemitteilungen/EN/2013/130528SpecialServiceNumberCallQueues.html?nn=404530. As I understand it, our telephone network cannot apply different rates for distinct portions of the duration of the call. Some may be excited about the idea of a state regulator getting involved in deciding when "a caller's business is being attended to". I make many calls where the person who answers is not in any way competent in dealing with my business, however I would not fancy having to argue my case for a refund of the call cost with a regulator.

I don't think anyone could accuse the current German government of Nazism so their attempts at "proper regulation" are worthy of consideration.    I feel their, the Bundesnetzagentur, proposals are impressive and I wonder why Ofcom have not taken a leaf out of their book. :-/

I also wonder why the Fair telecoms campaign make no mention of this issue (queuing) and is not pressing Ofcom to take "proper" action?  :-/

In my response to the Ofcom consultation in 2010 I said :---
"Inefficiency
Another aspect of this concept and design is that the longer a call takes the more revenue the called Organisation receives. Therefore the Organisation has no incentive to keep calls as short and efficient as possible. Indeed the incentive is directly opposite and there must be some temptation to cause calls to last longer and so to increase the revenue. Long winded recorded messages, extensive menus, long call queues all have this effect without costing the Organisation anything as they are zero cost once set up. Queues can be unlimited in length. The phone service companies also do not mind longer calls at premium rates because this provides additional revenues. There are many examples in the public domain of people complaining of long queues while calling 084 numbers. This used to be a problem with 0870 but is curtailed somewhat with 0871/2/3 by regulation although the regulation could be more strict and more rigorously enforced. The idea of “light touch” regulation in this regard is totally unacceptable from a callers point of view.
The deliberate or incidental extension of call lengths leads to considerable waste of time by callers which when multiplied by the millions of calls to 084 and 087 numbers every day must add up to a massive cost to the national economy. ..... 

Revenue share
I am generally against this in concept, but if it were to be retained then it should not necessarily be related to the length of the call which could still tempt call lengthening for revenue earning purposes. It may be better to make this a fixed price per call, to be set by the Organisation. This would provide true transparency and enable callers to make clear decisions prior to committing to a call because they would know in advance their access charge (or its basis) and they would know how much they are paying for the service and that the whole cost is going to the Organisation called. The Organisation would be in a position to influence the cost of use of the 084 number and realistically to negotiate. This would address the question of overall efficiency because the Organisations would have an incentive to keep their service calls efficient."

The Bundesnetzagentur states :---
"The final regulations on free call queues take effect on 1 June. As from this date, call queues for special service numbers (eg 0180 and 0900 numbers) can only be used if a fixed price applies to the call or the call queue is free of charge for the caller. "

Yes, the Bundz allows "fixed price calls" which is what I said in 2010 to Ofcom; I said I am against premium charges on 084/7 numbers in principle but if Ofcom insist in allowing the industry to carry on ripping-off consumers at least they ought to make the calls fixed price which would remove the incentive for companies to cause, create or allow queues and delays!   8-)

Please take this as a recommendation to Fair Telecoms to call for an end to queuing and manufactured delays on 084/7 numbers and to campaign for fixed price calls instead of per minute access and service charges which allow the scamming to continue.

loddon wrote on Jun 5^th, 2013 at 9:16am:

Please take this as a recommendation to Fair Telecoms to call for an end to queuing and manufactured delays on 084/7 numbers and to campaign for fixed price calls instead of per minute access and service charges which allow the scamming to continue.

The fair telecoms campaign opposes the imposition of unjustified Service Charges.

Most of the cases one has in mind should not be on 084/7 numbers anyway. I feel that it could be dangerous to dilute this message by perhaps implying that it is call queueing, which is often an essential element of the service, that should be removed, rather than the Service Charge.

The tricky cases are those where a Service Charge may represent a justifiable way of charging for a service currently offer on a 084/7 number. For example, there are technical advice services supplementary to dealing with issues related to the product or service provided, such as an ISP offering assistance with use of computer applications. I cannot see a general case for arguing that one of the following must apply:

• The Service Charge must be greater than 13p per minute, so as to fall within the scope of the Phonepay Plus regulations.

• Callers must receive the engaged tone if they cannot be immediately connected to an agent competent to deal with their business.

• Those with business that can be resolved simply and quickly must pay the same as those who have many different questions or a complex issue, and therefore keep an agent necessarily engaged for a long time.

There are other ways of charging for such services, however I cannot say that these would inevitably be fairer.


I believe that our campaigning focus must be on removing all unjustifiable cases of imposition of the Service Charge from the 084/7 ranges. This will include a significant proportion of those cases where callers express concern about the cost incurred as a result of the duration of the call.

Even if we are successful, this will leave many other issues remaining. These will include the duration of calls where a Service Charge is accepted and the cost incurred by those who pay for calls to geographic rate numbers. There is also the general issue of the inconvenience suffered by those who endure long waits to be connected to a call centre, in response to which we urge consideration of "virtual queueing" call-back facilities, although we must take care not to be seen to be promoting particular products.

These, along with many other matters, all need attention. The unjustified imposition of Service Charges must however be a priority and efforts on this issue must not be diluted.

SilentCallsVictim wrote on Jun 5^th, 2013 at 12:44pm:

The fair telecoms campaign opposes the imposition of unjustified Service Charges. I feel that it could be dangerous to dilute this message by perhaps implying that it is call queueing, which is often an essential element of the service, that should be removed, rather than the Service Charge. The unjustified imposition of Service Charges must however be a priority and efforts on this issue must not be diluted.

I would think almost everyone on this Forum opposes unjustified Service Charges (SC).

I would say that I am even more against Access Charges (AC) which are currently much larger than the SC, up to about 20 times larger.   

These two evils, AC and SC, are further compounded by the third evil – queueing.  I am equally against queueing as it compounds the problem.   Consumers have been complaining about it for years and are still complaining as we saw in the comments on the recent report by the BBC :---
http://www.bbc.co.uk/news/business-22540999

Just two of the comments on the BBC website:---
"133.itsdavehere
26 Minutes ago
Ofcom should be looking (at) companies that have these automated queues/options menus etc... as these are a real money spinner for the phone companies and the companies that use them.
They are open to abuse as an easy way to rip off the consumer.
The law should be changed stating that, if a company uses these automated services, then the call MUST be free! Why should I have to pay to wait in a queue?

132.spam spam spam spam
27 Minutes ago
Some people are "put off" making important calls because of confusion over the amount they will be charged,
CORRECTION - Some people are "put off" making important calls because they know so many "customer service lines" are blatant extortionate rip offs, designed to maximise profit & even if you were the 1st to phone 1st thing in morning "sorry we are experiencing high call volumes",

Why should I have to pay to wait in a queue says “itsdavehere”.   A good question.   The Bundz has stipulated that phone companies cannot charge people while queueing and queue time must be free or the call must be fixed price.   If Germany can do it why can't Ofcom?
I described to Ofcom in 2010 exactly the problem of combining call queueing with premium rate numbers and how that combination incentivises phone companies and organisations to cause inefficiency because the longer the queue and the more callers time is wasted the more they earn.    This is totally wrong in concept and in design.   This must cost the country massively in total wasted time, and I regard Ofcom as responsible.    The Bundz have recognised this problem and have done something about it.   I suggested in 2010 fixed price calls could be a solution for 084/7 calls and I have seen nothing in Ofcom's consultations stating they have considered this or explained why they have rejected the idea.

I don't see why Fair Telecoms could not take up this issue of the evil of combined premium rate numbers with the menace of queueing and give it equal priority.   Surely this isn't too complicated for Ofcom to understand?

Of course the real problem is that Ofcoms proposals are deeply flawed because they are now introducing AC and SC but they are not addressing the fundamental problems and are doing nothing about queueing.   The idea that this is simplification is laughable because most consumers will see this as a complication.   The forthcoming CRD (Consumer Rights) legislation may provoke some improvements but that has not been an Ofcom initiative.

SilentCallsVictim wrote on May 31^st, 2013 at 7:56pm:

Some may see other nations as being more inclined towards "proper regulation" than the British.

For the avoidance of doubt, my reference to the widely understood national ‘inclinations’ of a particular EU partner was general and timeless, not on account of a specific period in its history.



loddon wrote on Jun 5^th, 2013 at 6:38pm:

I would say that I am even more against Access Charges (AC) which are currently much larger than the SC, up to about 20 times larger.

As the "Access Charge" is defined as being the amount retained by the call originating telephone company when a Service Charge is imposed, removing the Service Charge from a particular call also removes the Access Charge.

Unlike the Service Charge, the nature of the Access Charge will be changed significantly from what it is at present. As it will be recognised as being to simply cover the cost of originating and placing a call, it will be hard to justify it being any different from the cost of a geographic call. The question of what calls are covered by a package subscription is however separate, as providers will be free to keep package subscription costs down by only covering calls to actual geographic rate numbers, if they so wish.



loddon wrote on Jun 5^th, 2013 at 6:38pm:

The Bundz has stipulated that phone companies cannot charge people while queueing and queue time must be free or the call must be fixed price.

That is not true. The regulations referred to do not apply to calls to geographic or mobile numbers. One assumes that phone companies charge for these calls, as freephone numbers are also mentioned.

A special range of numbers has been allocated for the purpose of "free queuing", which presumably terminate on special equipment with the capability to suspend and apply the charging process at particular points during a call. It is not made clear whether it is the caller who makes the determination that they have been connected to someone capable of dealing with their business, or if charging is commenced at the instigation of the party called.

I am not aware of there being sufficient demand for this facility to warrant the UK networks investing in this technology, assuming that there are no fundamental technical issues to preclude its use. Decisions about where and how to deploy it would then have to be made by users, possibly compelled by regulation.

I would be happy to be briefed on the realities of this proposal by anyone who wished to advance it seriously, rather than simply chat about it in a discussion forum.



loddon wrote on Jun 5^th, 2013 at 6:38pm:

Quote: The law should be changed stating that, if a company uses these automated services, then the call MUST be free! Why should I have to pay to wait in a queue?

It is interesting to read this proposal being introduced to the discussion, as it is not confined to the issue of non-geographic numbers and Service Charges. Although thereby outside the scope of this thread, it would be interesting to read of how such a proposal could be fair.



loddon wrote on Jun 5^th, 2013 at 6:38pm:

I don't see why Fair Telecoms could not take up this issue of the evil of combined premium rate numbers with the menace of queueing and give it equal priority.   Surely this isn't too complicated for Ofcom to understand?

There is no question that imposition of an unjustified Service Charge is compounded when call queuing is involved and one can see that we do not miss this point when it is relevant.

We do not however wish to be seen to be opposed to a fair way of handling situations where there are more callers than there are agents available. We believe that call queuing is a perfectly legitimate approach, and do not wish to offer any comfort or support to those who falsely claim that it is only possible when a Service Charge is imposed.

Whilst Ofcom has clearly not been misled, we believe that many people fail to appreciate that the features available with non-geographic (and enhanced 01/02) numbers are not restricted to those ranges on which a Service Charge is applied.


As for Ofcom, its relevant resources will be committed to the implementation of the unbundled tariff and making freephone free for two years and beyond. I see no prospect of it taking a significant turn or adding a load of additional provisions. This could change, if legal action by those who stand to lose as a result of the transparency being introduced forces it to abandon its present plans and return to the drawing board.

If all goes to plan, the whole position will have to be reassessed in something over two years time, when we will know for certain about the demand for the 084/087 ranges.



loddon wrote on Jun 5^th, 2013 at 6:38pm:

I suggested in 2010 fixed price calls could be a solution for 084/7 calls and I have seen nothing in Ofcom's consultations stating they have considered this or explained why they have rejected the idea.

As I understand it, Ofcom has not rejected the fixed price option for 084/7 calls. As we devote our energies to campaigning for Service Charges to be removed, there is no reason why others may not campaign for users to switch to fixed price (per call) Service Charges.

SilentCallsVictim wrote on Jun 6^th, 2013 at 1:23am:

..... removing the Service Charge from a particular call also removes the Access Charge.

Well, my view is that the AC is still a major concern because for some strange reason financial services, healthcare and social services are excluded from the the requirements of the CRD.   Financial Services covers banks   :o and insurers  :o  which are among the largest and very worst organisations that have been exploiting NGNs to rip-off consumers and we now know that they will not be compelled to change by the CRD.  :o



SilentCallsVictim wrote on Jun 6^th, 2013 at 1:23am:

loddon wrote on Jun 5th, 2013 at 6:38pm: The Bundz has stipulated that phone companies cannot charge people while queueing and queue time must be free or the call must be fixed price. That is not true. The regulations referred to do not apply to calls to geographic or mobile numbers.

Of course, I don't think anyone would deduce that the Bundz included geographic or mobile calls in their regulations.   This thread has NGNs in its title and I have made it clear all along that my concern is with the evil of combining queue charging with premium rate numbers and that is why I criticise Ofcom because they seem to be oblivious to the problem.  The Bundz however do see it as a major problem and clearly decided some time ago, probably in 2010 when I was pressing the issue with Ofcom, to introduce legislation to ban charging of consumers while they are in a queue on a premium rate number.   They have allowed the the Deutche phone service industry two ways to  comply --- use fixed price calls OR if they want to charge per minute then queue time is free!!!   

The Bundz have gone through their preliminaries, written the regulations, held a 9 month trial and have now fully implemented the regulations, meanwhile Ofcom have done nothing but prove their incapability and incompetence. ..  And interestingly if a caller sits in a NGN queue in Germany to be answered and then is moved by an agent to wait in another queue midway through the call the second queue time must also be free !!!   :) ;D


[quote author=SilentCallsVictim link=1366033132/78#78 date=1370478203]quote author=loddon link=1366033132/77#77 date=1370453893]
Quote:

The law should be changed stating that, if a company uses these automated services, then the call MUST be free! Why should I have to pay to wait in a queue?

[/quote]
This was not something I originated and you are quoting a BBC reader's comment out of context.  I referred to it as an example of the many adverse comments about Ofcom's proposals that illustrate the strength of concern that people have which Ofcom seem to be ignoring.    This reader would probably be much happier living in Deutchland because the Bundz has listened to his complaints and stipulated that he should not have to pay while waiting in a premium rate NGN queue.  :)

loddon wrote on Jun 7^th, 2013 at 9:16am:

SilentCallsVictim wrote on Jun 6th, 2013 at 1:23am: ..... removing the Service Charge from a particular call also removes the Access Charge. Well my view is that the AC is still a major concern because for some strange reason financial services, healthcare and social services are excluded from the the requirements of the CRD.   Financial Services covers banks   :o and insurers  :o  which are among the largest and very worst organisations that have been exploiting NGNs to rip-off consumers and we now know that they will not be compelled to change by the CRD.  :o

The EU-imposed regulatory structure for financial services, and also transport is separate to that for other businesses. All of the provisions of the CRD therefore do not apply, including areas where stricter regulations for financial services are already in force. It also does not cover services provided by the state, e.g. those of the Department for Work and Pensions.

I understand that BIS has secured the support of the Department for Transport to extend the provisions to its sector. The possibility of extending the provision covering telephone numbers to Financial Services would have to be addressed as a separate issue by the Treasury.

The campaign to remove unjustified Service Charges, where not made invalid by the CRD, will be greatly helped by the tone set by the CRD provisions. The Treasury and the DWP will have to argue, respectively, that something which is prohibited for other businesses is acceptable for the financial services sector and for itself. Similarly every individual financial services company will have to advance the same argument in attempting to justify its Service Charge to its customers.


The level of the Access Charge could indeed remain as being a concern in cases where the Service Charge is retained. The degree of actual concern will not be known until we see how telcos choose to set this. Ofcom is waiting to see if intervention will be necessary. The present variable and undeclared levels of Access Charge do however provide a very strong additional reason for the immediate abandonment of unjustifiable Service Charges.

loddon wrote on Jun 7^th, 2013 at 9:16am:

Well, my view is that the AC is still a major concern …

Service Providers with 084/087 numbers will, no doubt, agree with you here.

After all, they frequently quote the bundled rate from a call provider whose Access Charge is nothing and claim that those that do impose an Access Charge vary.

Dave wrote on Jun 7^th, 2013 at 11:36am:

loddon wrote on Jun 7th, 2013 at 9:16am: Well, my view is that the AC is still a major concern … Service Providers with 084/087 numbers will, no doubt, agree with you here. After all, they frequently quote the bundled rate from a call provider whose Access Charge is nothing and claim that those that do impose an Access Charge vary.

There is an excellent example of this from a recent news item.


Quote:

We have to remember that the problem is not so much the system practices use but the system providers. These days people have mobile phones and phone contracts which charge more for certain numbers. The system as a whole needs to change. It’s those providers that are ripping people off, not practices.

This argument is put forward to confuse the issue and I do not wish to be seen to be supporting it. The Service Charge is not truly a secondary issue, but the basis to which the Access Charge may be added.

loddon wrote on Jun 7^th, 2013 at 9:16am:

..... and insurers  :o  which are among the largest and very worst organisations that have been exploiting NGNs to rip-off consumers and we now know that they will not be compelled to change by the CRD.  :o

Nita wrote on Jun 7^th, 2013 at 6:21pm:

I have just been looking at moneysupermarket.com to renew my car Insurance. All the companies quoted give 0844 numbers. I think they should be added to your "Hall of Shame"

I am inclined to agree with Nita.   Thanks Nita for confirming my earlier assertion.  :)

Ofcom has now published some responses to its consultation here :---
http://stakeholders.ofcom.org.uk/consultations/simplifying-non-geo-no/?showResponses=true&pageNum=1#responses

There appear to be less than 30 responses of which most are from corporations within the industry and a mere 8 are from individuals.

Some of the corporate responses  provide an insight into the way these companies think and also reveal interesting information about the industry.   For example EE says this on page 5 of its response :---

"It is beyond argument that the non-geographic calls market, including the market for 08x calls, is a naturally dwindling one. Service Providers (“SPs”) of all descriptions including banks, utilities and government departments are increasingly utilising more cost effective but equally, if not more, customer friendly service models such as online ordering and service provision and real time web chat / VoIP services, as well as mobile alternatives like SMS, premium SMS and mobile voice short codes."

So this major company has declared that 084/7 market is dwindling.  :)     Our joy at this good news must be tempered by the Ofcom objective which is to "reinvigorate" the market by implementing its proposals.

EE also says this :---
" ...... Ofcom‟s confirmation that it will not require ... for the 084/087 ... ranges that the Access Charge (“AC”) is separately split out on customer bills from the Service Charge (“SC”), which EE welcomes."

So EE doesn't want to show the Access charge separately on its customer bills!   I wonder why not?   Could it be that if the Access charge is printed separately on bills its customers would get to understand what it is and how much is being charged by EE?   

If it is combined with the Service charge then customers will be that much lacking in knowledge of the charges being made.    And Ofcom appear to be backing this attitude --- how does that square with the Ofcom promise of greater transparency, being clear to consumers about charges and eliminating opportunities to mislead consumers and to reduce customer harm?   :(

The Federation of Communication Services which is the UK trade association for the communication services sector with over 350 members and associates is very sceptical about the likely efficacy of the Ofcom proposals, where it states :---.

"In its response to Ofcom’s April 2012 consultation, FCS expressed the view that, without a
cap on access charges, the measures proposed to increase transparency and trust in the
non geographic ranges were unlikely to be effective. While we recognise some of the
additional protections required by Ofcom relating to the access charge (one access charge
per tariff package), we continue to believe that lack of certainty of the total cost to the
customer remains the single biggest barrier to achieving genuine transparency for
consumers. It seems clear that customers will continue to be confused and resistant to
calling numbers where they will incur a further unknown access charge in addition to the
stated service charge."

The FCS seems to agree with my earlier assertion that these proposals will be seen as further complication rather than simplification.  :(   Will Ofcom recognise this and change the proposals accordingly?   :-/

Magrathea Telecom still broadly agree with my views on the Ofcom proposals.   They say :---

"Magrathea remains opposed to the introduction of the unbundled tariff regime as we do not believe
it is the right way to solve the problems associated with non-geographic call services.

0844
We do not believe that Ofcom has demonstrated that the benefits to consumers (callers) of
unbundling 0844 tariffs will outweigh the costs, in financial terms. It is true that callers, both fixed
and mobile, already pay more than the 5ppm designated in the Numbering Plan. This is because the
lack of regulation at the retail price level has enabled OCPs to introduce call set-up charges that,
when added to the pence per minute rate, have the effect of increasing the per-minute cost of a call.
It is therefore no surprise that this “tariff creep” has led consumers to be confused about what they
are actually paying."

It is interesting that a major company within the telecoms services industry highlights the menace of "tariff creep" and draws attention to "call set-up charges".


They also say :---
"Ofcom notes that it would like to maintain pricing flexibility for OCPs, but
we do not believe that this degree of flexibility is necessary, since consumers are unlikely to make
buying decisions on the basis of the cost of calling numbers which they rarely call. Mobile
consumers tend to focus on the overall bundle of calls, texts and data and the handset on offer.
Fixed line customers may also be considering broadband and/or pay TV services. Non-geographic
numbers would come a long way down the list of decision factors."

Exactly.   This confirms what I say about the fact that there is and will be in the proposed regime no real competitive pressure which would help control prices.

This posting has appeared on the Which? website conversation concerning GPs and rip-off phone numbers :---

"Author: Valerie Zebedee
Comment:
I phoned my G.P. surgery in Calne, Wilts. at 8.30 am today to make an appointment for my little granddaughter and despite being first in the queue it still took ten minutes on the 0844 number for an answer. So this cost me 50p plus the Sky charge, and I was advised four times to ring 999 for an emergency and four times to try at a less busy time!"

A typical example of the rip-off combination of a premium number combined with queuing that is not tolerated in Germany but is continuing to disgrace the phone services industry in UK due to the negligence of our regulator Ofcom.   The German regulator Bundesnetzagentur has banned precisely this type of rip-off and ruled that if a caller is held in a queue that time cannot be charged for, queuing time must be free.

This is one of the main reasons callers complain 084 and 087 numbers and repeatedly call for them to be banned.   The Bundesnetz' has demonstrated that it is perfectly feasible to disallow charging for queue time but Ofcom have failed even to recognise the problem in their analysis through all their consultations from 2010 up to the recent may 2013 consultation.   :-[ :( >:(   This embarrassing failure by Ofcom must now be rectified !!!

Out of interest the GP practices in the Calne area using 0844 include :---

Dr E Goedbloed
voice(0844) 412 0023
32 New Road, SN15 2JB

Lodge Surgery
(0844) 477 0919
Lodge Road, SN15 3SY

The Southbroom Surgery
(0844) 477 8657
15 Estcourt Street,
SN10 1LQ

These GPs should be embarrassed and ashamed of their behaviour, unworthy of the medical profession.   They have no excuse, they should be changing to 03 numbers immediately.   >:(   They have had three years to do it, now is the time.

loddon wrote on Jul 5^th, 2013 at 10:14pm:

Out of interest the GP practices in the Calne area using 0844 include :--- Dr E Goedbloed voice(0844) 412 0023 32 New Road, SN15 2JB Lodge Surgery (0844) 477 0919 Lodge Road, SN15 3SY The Southbroom Surgery (0844) 477 8657 15 Estcourt Street, SN10 1LQ

I'm not sure where you sourced this list from, but the parentheses around the 0844 prefix indicates that it can be omitted for callers dialling from a phone line with the same code. Not since 1995 has this applied to 0844, when those within the Thame STD area could get through without it.

Dave wrote on Jul 6^th, 2013 at 3:54pm:

I'm not sure where you sourced this list from, but the parentheses around the 0844 prefix indicates that it can be omitted for callers dialling from a phone line with the same code.

I hadn't noticed the parentheses Dave, so I have checked the source.   It is Yahoo Local

http://uk.local.yahoo.com/Calne/SN11/Wiltshire/Doctors/uk100006006-s-26788490.html

On that site all area codes are set in parentheses including the non-geo ones.   Are you sayng they are wrong to do so?

loddon wrote on Jul 6^th, 2013 at 8:45pm:

Dave wrote on Jul 6th, 2013 at 3:54pm: I'm not sure where you sourced this list from, but the parentheses around the 0844 prefix indicates that it can be omitted for callers dialling from a phone line with the same code. I hadn't noticed the parentheses Dave, so I have checked the source.   It is Yahoo Local http://uk.local.yahoo.com/Calne/SN11/Wiltshire/Doctors/uk100006006-s-26788490.html On that site all area codes are set in parentheses including the non-geo ones.   Are you sayng they are wrong to do so?

This is obviously off-topic, *ahem*.  :-[ :-[ :-[

The purpose of the brackets is to indicate that the bit inside is optional for those calling from a phone line with the same code. Thus it is correct for geographic area codes, with a few exceptions due to local dialling having been closed, but it has never been available to 0844 non-geographic numbers, just as it has never been available with mobile numbers, for example.

Coming back to the approach taken by Germany: is it in addition to the unbundled tariff approach?

Does it mean that companies will have to pay for the call during periods where the call is in a queue or on hold? If so this will reduce the benefit of or otherwise make it not worth the company's while to use a Special Service number.

There is, as pointed out in reply #75, the question of whether the receiving party is the one which determines when the call is being "handled" and when it is waiting to be handled or on hold. If so then it makes me wonder whether some might not signal to the network accordingly in order to avoid incoming call charges for the periods when the caller isn't paying (assuming that such charges will be made).

Dave wrote on Jul 6^th, 2013 at 10:11pm:

…Does it mean that companies will have to pay for the call during periods where the call is in a queue or on hold? If so this will reduce the benefit of or otherwise make it not worth the company's while to use a Special Service number.…

Although Father Christmas, as we know him, probably originated in Germany, he is unlikely to serve the telecoms market, so someone will have to be paying for the use of the line during the period when the caller is on hold - and someone will be paying for the technology and administrative cost of splitting the charge for the call.

Given that the use of a Special Service number is justified, this additional cost would have to be taken into account in choosing the charge band applicable to the number. A justified Service Charge meets the costs incurred in providing the service.

Sorry if it's already been covered, but do any of the well-informed persons who post here know what level of "access" and "service" charges we are in practice likely to see?
I would guess that BT etc will continue with their policy of pushing everyone to monthly "all the calls you can eat" tariffs. Does this mean that they will increase their monthly charge, but include the "access" element of calls to 08* ? For calls outside the monthly "bundle", will the access charge be the standard (deliberately punitive?) 15p "connection" plus 7p (or whatever) per minute?
Will there be tables showing "service" charges for 08***** "ranges" ? Or will we have to rely on all "service" users advertising their individual "service" charge?
So a call to 0844 from a BT landline may increase from the present (anomalous, and BT would claim subsidised?) 15p plus 5p a  minute, to 15p + 7p a minute "access" plus, for example, 5p a minute "service" ?
And do I understand correctly that the "service" charge will have to be shown separately on itemised bills?

There's a long process to go through to re-organise and consolidate similar Service Charges, but the levels are likely to be a penny or two above and then rounded up from the present BT retail price.

e.g. call currently advertised by BT as 5.1p/min plus 15p connection fee (with no profit made by BT due to the "NTS Condition"), might become 7p/min Service Charge on the new system.

Don't forget that the Service Charge hasn't changed in all the time these numbers have been in use, and that they first came into service in 2000. There's several other possibilities for the levels that are set, as there are many issues to resolve.

I am sure the Service Charge list will be published somewhere so that people can look these up when they need to do so.

The Access Charge will be interesting. Providers will obviously compete in some way as it will be much easier to compare them. I would hope for around 0p to 5p/min from landlines and 0p to 10p/min from mobiles. I suspect mobiles will be substantially higher than that, but I doubt that Ofcom will tolerate the current 30p/min and above levels that are currently charged by some networks... especially as the levels currently embedded within the call price charged by Tesco Mobile for 0844 numbers are around the ~3p/min mark - less than the equivalent charged by Virgin Media on calls made from landlines.

Connection fees on calls (to 084, 087 and 09 numbers) made from landlines are to be scrapped, replaced by a per-minute rate Access Charge.

On a call that costs 5p/min plus 15p connection fee on BT, Virgin Media currently charges 12p/min plus 16p connection fee. The Service Charge is ~7p/min on both calls.

Virgin may decide to set a ~5p/min Access Charge. I suspect BT will be less, and as you say, they may choose to make the Access Charge "inclusive" in call plans. For those callers without an inclusive call plan, it's anyone's guess what the level of Access Charge will be.

Most people should be on inclusive call plans. That will become ever more obvious as the use of 03 numbers continues to rise. It doesn't take many minutes of 01/02/03 calls per week at 9p/min plus 15p connection to justify swapping to an inclusive callplan for well under a tenner per month.

In the same way that BT used to have two versions of Anytime, one with cheap calls to mobiles and one without, I suspect there will be one version with the Access Charge inclusive for 084, 087 and 09 numbers and one where the Access Charge is a small pence-per-minute rate within each call.

Disclaimer: All of the above is speculation.

Ian G wrote on Sep 12^th, 2013 at 5:49pm:

… Connection fees on calls made from landlines are to be scrapped, replaced by a per-minute rate Access Charge. …

Whilst being less ready to speculate on the levels of Access Charge that are likely, I can endorse all of the comments made in this posting.

With reference to the specific quoted comment, I must point out that this applies only to calls covered by the unbundled tariff. Ofcom is keen for connection charges to be replaced by minimum charges / durations, as it will demand for calls covered by the unbundled tariff. It is however having enough trouble with getting this through to make it worthwhile to consider further regulation covering other type of calls for the time being.

Non-inclusive calls to geographic rate and mobile numbers etc. will continue to be subject to call setup fees / connection charges.

OFCOM have at last published their long awaited Press Release incorporating a STATEMENT on NON-GEOGRAPHIC NUMBERS following the three consultations which began in 2010 !!!


Telephone call charges to be made simpler
December 12, 2013

http://media.ofcom.org.uk/2013/12/12/telephone-call-charges/

The Statement starts with the following introduction :---
"
● Clearer pricing for all numbers starting 08, 09 and 118

● 080 to be free from mobiles as well as landlines

The cost of calling businesses and services will become clearer for consumers under major changes to telephone charging, Ofcom announced today.

"The measures are designed to tackle consumer confusion1 about how much it costs to call companies, public bodies and other organisations on numbers starting 08, 09 and 118. These ‘non-geographic’ service numbers have a range of uses, from finding out information to banking, directory enquiry and entertainment services."

We ask if OFCOM are aware of what is going on in the industry they are supposed to be regulating.  ::)  The statement today seems woefully out of touch with what is actually going on at present.  :-/

For example Ofcom state "Benefits to consumers

Ofcom (want to) .....  restore consumer confidence in non-geographic service numbers and increase their usage ...."

We must ask if OFCOM have noticed that the largest Government organisations have moved, or have declared they will move, away from non-geographic numbers, such as HMRC, DWP, NHS.   And the largest of the Banks have moved or have declared their policy to move away from non-geo numbers such as NatWest (moved to 03 number last month), RBS, Barclays, HSBC.   Transport for London have dropped their 0843 and moved to 03 !!!

Industry and public services are moving away from non-geo numbers and the general public is delighted this is happening --- so what planet are OFCOM living on ??? :o

Ofcom demonstrate their weakness and incoherence by lamely stating later in the statement---

"Ofcom is actively encouraging public and not-for-profit bodies to use 03 numbers."

What evidence do Ofcom offer to support this statement   ???

The lack of rational thought and analysis and the poor but predicted outcome from all the consultations is revealed by this quiet and insipid release.

The press release which I referred to in posting #96   above contains an OFCOM error.   The link in that release goes to a consultation document on the future of 0500 numbers  NOT to the Statement which is actually here:-


http://www.ofcom.org.uk/static/consultations/non-geo-statement-final.pdf

loddon wrote on Dec 12^th, 2013 at 8:20am:

For example Ofcom state "Benefits to consumers Ofcom (want to) .....  restore consumer confidence in non-geographic service numbers and increase their usage ...." We must ask if OFCOM have noticed that the largest Government organisations have moved, or have declared they will move, away from non-geographic numbers, such as HMRC, DWP, NHS.   And the largest of the Banks have moved or have declared their policy to move away from non-geo numbers such as NatWest (moved to 03 number last month), RBS, Barclays, HSBC.   Transport for London have dropped their 0843 and moved to 03 !!!

03 numbers are non-geographic numbers and are certainly included in my definition of them. They just happen to be charged the same way as geographic numbers.

kasg wrote on Dec 12^th, 2013 at 1:41pm:

loddon wrote on Dec 12th, 2013 at 8:20am: For example Ofcom state "Benefits to consumers Ofcom (want to) .....  restore consumer confidence in non-geographic service numbers and increase their usage ...." We must ask if OFCOM have noticed that the largest Government organisations have moved, or have declared they will move, away from non-geographic numbers, such as HMRC, DWP, NHS.   And the largest of the Banks have moved or have declared their policy to move away from non-geo numbers such as NatWest (moved to 03 number last month), RBS, Barclays, HSBC.   Transport for London have dropped their 0843 and moved to 03 !!! 03 numbers are non-geographic numbers and are certainly included in my definition of them. They just happen to be charged the same way as geographic numbers.

Indeed.. and I doubt the consumers have "no faith" in using them.. they just seriously disliked being bled dry by having to call them!

Coming back to the NGN Consultation.. this bit interests me...

"1.23 In order to ensure these different charges are made transparent to consumers, we are setting rules about the structure of the access and service charges so that consumers can more readily understand and, where appropriate, remember them. These include:
one access charge per tariff package, for calls to all unbundled non-geographic number ranges, though the access charge may be included in a bundle of inclusive minutes for some or all non-geographic numbers;
the access charge to be set as a simple 'pence per minute' rate;

each individual 084, 087, 09 or 118 number to have a single service charge that applies to calls to that number from all fixed and mobile phones;

with the exception of 118, there will be caps on the maximum rate of the service charge, according to the unbundled non-geographic number range.

For example, the cap on the rate of the service charge for numbers in the 084 ranges will be 7p (inc. VAT) and the cap for numbers in the 087 range will be 13p (inc. VAT);"

The part highlighted in bold... does this mean:

I ring an 084 number and the maximum per minute rate for it will be 7p inc VAT.. or

I ring an 084 number and the maximum "call connection" fee will be 7p inc VAT?

You can I hope appreciate MY confusion...

:-?

The maximum Service Charge will be 7p/min for 084 numbers and 13p/min for 087 numbers. This is to the benefit of the called party. This will be either a per-minute or a per-call rate.

Each phone company will set a single Access Charge per tariff that covers all 084, 087 and 09 numbers. This will be a per-minute rate. The Access Charge is allowed to be 0p/min (i.e. "inclusive").

The call price is the sum of the Access Charge and the Service Charge.

Call connection fees will be scrapped on 084, 087 and 09 numbers.

Calls may be subject to a minimum charge, perhaps equivalent to a one minute call. The precise details are down to each network to decide.

It may be informative to look at a real example.

When you call a number beginning 0844 477 your phone company pays 7p/min to the phone company of who you are calling. Other 084 numbers have an amount that varies from 2p/min to 7p/min depending on the first six digits of the telephone number called. There is nowhere you can easily find that information.

The "NTS Condition" means BT are not allowed to make profit on call origination.

BT currently charges 5.1p/min plus a 15p connection fee for that call, and, on aggregate, retains none of it.

Virgin Media landlines charge the same call at 12.4p/min plus a 16p connection fee.

Tesco Mobile charge the same call at 8p/min.

Orange mobiles charge the same call at 35p/min.

Vodafone mobiles charge the same call at 36p/min.

Virgin Mobile charge the same call at 41p/min.

None of these call prices give any indication of the 7p/min that they pass on, nor of how much they retain.

Consumers, especially those using mobile phones, are further misled because users of these numbers merely quote "calls cost 5p/min from BT, other providers may vary".

The "unbundled tariff" exposes where the money goes, and how much it is.

In future, the number user will declare the 7p/min Service Charge and note that the caller's phone network will add their Access Charge.

If total call prices remain much the same as now, then each of the above networks will declare the following Access Charges:

BT landlines: 0p/min.

Virgin Media landlines: ~8p/min.

Tesco Mobile: 1p/min.

Orange mobiles: 28p/min.

Vodafone mobiles: 29p/min.

Virgin Mobile: 34p/min.

The above figures now make it very easy to compare providers.

With the Access Charge exposed, those with excessive levels are also blatantly obvious. There are two important things to bear in mind.

Firstly, Ofcom are unlikely to tolerate Access Charges over, perhaps, 10p/min from landlines and 25p/min from mobiles. In general, call prices from mobiles are set to fall. Ofcom will be able to intervene where call prices are excessive and it will be much clearer to see when that is the case.

Secondly, phone networks must set a single Access Charge per tariff covering all 084, 087 and 09 numbers. This will naturally reign in the extremes of pricing.

I have to be honest I am now EVEN more confused!

:o

There's a retail and leisure park in an adjacent town. It has a supermarket, DIY store, furniture store, cinema, restaurant and bowling alley.

A local taxi firm charges £7.50 each way (total £15) if you go there to shop, and for this example this price is not dependent on night or day.

The taxi firm also sells a combined ticket for travel and entertainment. This ticket is £40 and is pre-paid for the journey and for viewing one film or eating one meal or taking part in one bowling session.

Having paid £40 for the ticket and knowing the travel costs £15, you might have a reasonable expectation that each of the entertainment options costs £25.

However, if you visit the park using some other form of transport, you'll find that the cinema is £10, the meal is £20 and the bowling is £15.

You have now discovered the taxi firm is effectively charging you £30 for the journey if you go to the cinema, £20 for the journey if you go for a meal and £25 for the journey if you go bowling.

This is similar to the situation you might find with mobile call pricing for 0844 numbers where a mobile network charges, for example, 40p/min for all 0844 calls irrespective of whether the underlying Service Charge is 2p/min or 7p/min. The other parallel would be if that same mobile network charged, say, only 20p/min for calls to 01, 02 and 03 numbers.

The "unbundled tariff" as applied to the "night out" deal would require the taxi firm to charge you the same £15 for every journey irrespective of which part of the venue you are visiting (the Access Charge) and the correct £10 for the cinema, £20 for the meal and £15 for the bowling (the Service Charge) and each party clearly states their part of the charge.

Is that any more clear?

CJT-80 wrote on Dec 12^th, 2013 at 1:49pm:

For example, the cap on the rate of the service charge for numbers in the 084 ranges will be 7p (inc. VAT) and the cap for numbers in the 087 range will be 13p (inc. VAT);" The part highlighted in bold... does this mean: I ring an 084 number and the maximum per minute rate for it will be 7p inc VAT.. or I ring an 084 number and the maximum "call connection" fee will be 7p inc VAT? You can I hope appreciate MY confusion... :-?

Neither.

The statement relates to Service Charge, as I've highlighted.

The total cost of calling any 084, 087, 09 or 118 number will be the Service Charge (to the benefit of the user) plus the Access Charge (imposed by the caller's phone company).

The Service Charge is the same for all callers, irrespective of the phone company used. The Access Charge will likely vary between phone call companies.

An explanation of the Unbundled Tariff is available from the fair telecoms campaign.

The BBC are running with it and offer an explanation of what it means.

http://www.bbc.co.uk/news/business-25345157

Shame we have to wait another 17 months for it to be implemented.

When it says callers may also be told by a recorded message is this up to the provider of the ngn ?

Right well yes that is clearer now..

I just wondered which bit of the "charged" is supposed to be capped.....

The Service Charge is capped. Up to 7p/min on 084 numbers. Up to 13p/min on 087 numbers.

The Service Charge depends on the first six digits of the phone number called.

The Access Charge is open to competition between call providers to keep it low.

See also: http://tinyurl.com/SN1384676248c34

Ian G wrote on Dec 12^th, 2013 at 6:30pm:

The Service Charge is capped. Up to 7p/min on 084 numbers. Up to 13p/min on 087 numbers. The Service Charge depends on the first six digits of the phone number. The Access Charge is open to competition between call providers to keep it low.

Service charge goes to the provider of the 08 number?

Will all 084 and 087 numbers have the same service charge? or will it just be as confusing as it is now....

bigjohn wrote on Dec 12^th, 2013 at 5:37pm:

The BBC are running with it and offer an explanation of what it means. http://www.bbc.co.uk/news/business-25345157

Surely this part of the BBC report is wrong:


Quote:

Ofcom also said that it would also simplify tariffs for calls to 03 numbers, which must now be included in the inclusive minutes or other promotional offers a phone user might have.

This suggests some change in the way 03 numbers are treated, and I can't see that in the Ofcom report.

The Access Charge is retained by the caller's telephone company.

The Service Charge is paid onwards to the telephone company of who you are calling. They use that money to pay for the call-queueing and other non-geographic features and for routing the call onwards to the business you are actually calling. If there is any money left over, that's then paid out to the called business under a revenue share arrangement.

Yes, the Service Charge will vary according to the first six digits of the phone number called, as already happens now. However, the number user will have to show that Service Charge next to wherever their number is advertised. There will rarely be a need for callers to have to look this figure up.

What callers will need to do is remember just how much the Access Charge is for calls made on their landline and on their mobile.


I don't know why the BBC have used the wording they have in explaining the call price for 03 numbers. They will continue using the same system as is already in place. The call price is either the same as calling an 01 or 02 number or the call counts towards the inclusive allowance.


Back to an earlier comment. There is no requirement for an announcement at the start of the call. I think someone misread the briefing from Ofcom. Of course, there is nothing to stop a service provider adding just such an announcement if they want to.

I know with Mobile networks or at least my mobile network (O2) that they advise in a pre call announcement when you try and call an 0800 number that they charge for it..

I would therefore assume it's possible to set up a similar announcement for ALL providers, both landline and mobile when calling a "non inclusive" call... to advise of the charge..

The Consumers Rights Directive reaches the statute books today. Transport appears to be included. Normal geographical numbers to be used apparently. Effective from June 2014.

"If something goes wrong with a cooker, or commuters want a refund on their season ticket, they will now pay the same to phone a helpline as they do to call friends or family”
Jo Swinson Consumer Minister."

http://www.bbc.co.uk/news/business-25355758

bigjohn wrote on Dec 13^th, 2013 at 3:18am:

The Consumers Rights Directive reaches the statute books today. Transport appears to be included. Normal geographical numbers to be used apparently. Effective from June 2014. "If something goes wrong with a cooker, or commuters want a refund on their season ticket, they will now pay the same to phone a helpline as they do to call friends or family” Jo Swinson Consumer Minister." http://www.bbc.co.uk/news/business-25355758

Oh excellent news.... including Transport.. so that's National Rail Enquiries having to change, either they will finally amend their 0845 number to 0345 or use an 020 number.  Plus all the Rail Operators (TOC's) will have to change theirs... I wonder if Traveline will have to amend their's... as that is technically transport related and is a huge rip off...

We shall see what progress is made...  :)

Apologies for joining this recent discussion a little late. Perhaps I can offer a wider context to the announcements of yesterday and today PLUS an announcement from the Cabinet Office covering government and the public sector which is promised "shortly". (My understanding is that "shortly" can be interpreted as meaning "within a few working days".)

The tone is clearly set that use of 084 / 087 numbers is only appropriate in situations where the person called has a valid justification for imposing a charge on the caller. It is also established that this cannot be justified for handling customer enquiries and complaints.

There will always be cases where laws are broken and regulations breached - the world of telecoms is little different to any other. Equally there will be a tendency for standards and principles that are established to guide decisions made by businesses. Ultimately it is not laws, regulations and formal guidance statements that matter for their own sake, it is the effect that they and other factors have on the behaviour of those making decisions.

It is my view that there are relatively few situations where a Service Charge of less than 13p (or 7p) per minute would be validly imposed for a telephone call. If campaigners, citizens and consumers keep up the pressure, it is my belief that when the "unbundled tariff" comes into effect in June 2015 there will be very few remaining users of 084 and 087 numbers.

It is important to understand that the "unbundled tariff" also provides much needed clarity in respect of genuine Premium Rate Services, including Directory Enquiry services. It is wrong to think that its only purpose is to drive away invalid use of 084/087 numbers (as this could have been achieved by other means).

I wonder if telecoms companies will be allowed to exclude any 0800 numbers from the tariff free calls from mobiles rule, e.g. call through numbers from indirect phone call providers. It could be interesting for PAYG mobile customers being able to bypass the high call charges - a single top-up could last for many years with just an occasional chargeable call to keep the SIM account active.

More likely they will simply block access to those numbers. Only BT and KC have a Universal Service Obligation.

This contribution, which originally stated …

Quote:

Apologies for not understanding what may be an important point.

has now been amended in the light of a later contribution.

---

Graham wrote on Dec 15^th, 2013 at 1:26pm:

I wonder if telecoms companies will be allowed to exclude any 0800 numbers from the tariff free calls from mobiles rule, e.g. call through numbers from indirect phone call providers. It could be interesting for PAYG mobile customers being able to bypass the high call charges - a single top-up could last for many years with just an occasional chargeable call to keep the SIM account active.

Indirect access 080 numbers would be unlikely to be of benefit to mobile users at present. The first point is addressing a modest extension to the "call through" market that already exists on other types of number, access to which may be blocked by some providers.

This point does however draw attention to a wider issue, as covered by the second point. The use of free SIMs is coming under attack from a quite different direction. At present, the absence of any "line rental" charge on mobiles is covered by high termination rates on incoming calls. These are in the course of being reduced - a vital factor in relation to making calls to 080 numbers free to caller, but without placing excessive costs on those using 080 numbers.


Notwithstanding the possibility of calling only 080 numbers, there are many free SIM PAYG users who survive on the basis of getting people to call them. When the mobile providers lose the significant income from these calls, through the high termination rates, the question of people who currently get "something for nothing" may have to be addressed.

This is a tricky issue. The present arrangement is essentially unfair, but it does enable many kids and those who are financially pressured to have access to the telephone network. It would be hard to argue against a reasonable monthly charge for maintaining a network connection, but this would be seen as most unwelcome, especially given the nature of those who would be most affected.

Although the reduction in the termination charges is already happening, through a phased arrangement, we have yet to see any significant effects (apart from its contribution to enabling prohibition of charges for calls to 080 numbers). In time, we will expect to see landline providers treating calls to landlines and mobiles in the same way. Whilst mobile operators appear to have absorbed their loss of income through the initial phases of the rate reductions, one has to expect that they will react once it essentially dries up altogether.

(Perhaps any further discussion of this issue belongs in a new thread.)

Ian G wrote on Dec 12^th, 2013 at 6:58pm:

Back to an earlier comment. There is no requirement for an announcement at the start of the call. I think someone misread the briefing from Ofcom. Of course, there is nothing to stop a service provider adding just such an announcement if they want to.

Another article claiming  you will hear a recorded announcement. :o

"Ofcom say that now you’ll hear a message along the lines of: ‘Calls will cost XX pence per minute, plus your phone company’s access charge.’ That way if your provider piles on massive access charges, then you can find out and you have more CONSUMER CHOICE. Which is what we like."

http://www.bitterwallet.com/free-to-call-you-and-me-even-from-a-mobile/70563

Graham wrote on Dec 15^th, 2013 at 1:26pm:

I wonder if telecoms companies will be allowed to exclude any 0800 numbers from the tariff free calls from mobiles rule, e.g. call through numbers from indirect phone call providers. It could be interesting for PAYG mobile customers being able to bypass the high call charges - a single top-up could last for many years with just an occasional chargeable call to keep the SIM account active.

This is an interesting point.

You're talking about freephone 080x dial-through numbers where the user signs up to a service and pays for it directly. These allow calls to UK geographic and mobile numbers, as well as good rates to overseas destinations.

The providers of these services may respond by blocking access from mobile phones via their 080x number. This is because it will cost them more to receive calls from mobiles than from landlines. Or, as Ian G says, the mobile operators might respond by blocking those 080x numbers.


But, will these services be popular enough that they could cause mobile operators to react? There are mobile services that have low pay as you go rates to international destinations, as well as to UK numbers.

Consumers who use dial-through services are generally those who are more savvy and so are more likely to know about mobile services with low pay as you go rates.  :-/

Dave wrote on Dec 15^th, 2013 at 11:19pm:

Graham wrote on Dec 15th, 2013 at 1:26pm: I wonder if telecoms companies will be allowed to exclude any 0800 numbers from the tariff free calls from mobiles rule, e.g. call through numbers from indirect phone call providers. It could be interesting for PAYG mobile customers being able to bypass the high call charges - a single top-up could last for many years with just an occasional chargeable call to keep the SIM account active. The providers of these services may respond by blocking access from mobile phones via their 080x number. This is because it will cost them more to receive calls from mobiles than from landlines.

They could also  impose a higher connection charge  to recover extra costs  if you use the 080 access number as opposed to the geographical one. Or have different rates as this supplier does http://www.savacalldirect.com/countrydetail.aspx?country_id=216