idb wrote on Jan 22^nd, 2009 at 2:19am:
Someone may like to take a copy and release serialised extracts (suitably redacted to avoid compromising a desire for anonymity).

Question 4: Do you agree that Ofcom should require OCPs to give greater prominence to the cost of calling 070 numbers in published price lists and promotional material?

We generally welcome Ofcom’s proposals to give greater prominence to the cost of calling 070 numbers. As a consumer focussed organisation, Virgin Media takes its consumer interest and information obligations very seriously. Given the level of scams that have hitherto prevailed in the personal numbering environment, Virgin Media believes that consumer protection should be at the forefront of Ofcom’s objectives in undertaking this review. As such, we consider that the requirement for OCPs to afford greater prominence to 070 call charge information should be a constituent part of a wider package that also includes additional obligations on PNS providers - for example the requirement to undertake due diligence as per Ofcom’s proposed ‘Option 4’ in the consultation document. We therefore support the proposed extension of GC14 to encompass personal numbering services, on the basis that it is applied in parallel to extended obligations on PNS providers to undertake due diligence etc in accordance with the PhonepayPlus Code of Practice.

Furthermore, in extending the scope of GC14 we encourage Ofcom to ensure that originating CPs’ responsibilities are both proportionate and absolutely clear. Absence of ambiguity and scope for interpretation should be a key tenet of the establishment of any tariff transparency obligations – and to this extent we believe that the provision of examples and specific guidance would be beneficial to all stakeholders. For example, the proposed amendments to Annex 2 to General Condition 14 includes, at paragraph 3.2, a requirement on OCPs to ‘give prominence’ to certain pieces of information. By the same token, paragraph 4.2 obliges OCPs to provide ‘a clear reference’ as to where on websites and published price lists certain information can be found and paragraph 4.3 requires OCPs to include a ‘prominent statement’ indicating whether or not prices for call packages include calls to personal numbers. While we absolutely endorse the philosophy that Ofcom is attempting to foster within this Condition, we do believe that the terminology used has the potential to be interpreted in a number of ways and exposes the Condition to subjectivity. We suggest, therefore, that Ofcom provides a clearer set of guidelines or examples against which OCPs can develop and assess their compliance with the regulatory requirements.

Question 2: Do you agree that the costs outweigh the benefits in relation to closing the 070 number range and migrating users to an alternative range?

Virgin Media generally agrees that the costs of closing the 070 number range and migrating users to an alternative range would outweigh any benefit achieved. As Ofcom has identified, the costs to end users, service providers and indeed originating CPs would be substantial – and we believe that this would be the case irrespective of whether a completely new range was utilised or if the services were subsumed within an existing alternative range. Further, we believe that such migration would generate significant operational disruption, as well as potentially introducing additional inconsistencies to Ofcom’s objectives for number range/service transparency.
While personal numbering services are, in respect of service classification, perhaps not a ‘perfect fit’ alongside mobile numbers within the 07 range, Virgin Media is of the view that they reside more appropriately within this range than in certain of the alternatives proposed by Ofcom. That they have existed as a sub-range of 07 for a number of years, together with the absence of any conclusive proof of consumer confusion between 070 and mobile numbers constitutes, we believe, a strong argument to maintain the existing numbering arrangement. On this basis, and taking into account the perceived disruption and costs that would result from migration, we believe that migrating personal numbering services to an alternative number range at this time would be both impracticable and disproportionate.

Irrespective of which range ultimately supports personal numbering services, we believe that usage and application of the services should be closely monitored, with a view to undertaking further reviews of the situation as appropriate in the future.

NGMsGhost wrote on Jan 22^nd, 2009 at 12:41am:


I was fully intending to respond, but I don't have as much spare time as I would like, and it basically slipped my mind.  If I'd know about it a little more in advance, I would probably have done so.  I did respond to the 116 and DH 0844 consultations, and I do to other non-telecoms consutations occasionally.  I did, hower, recognise it's relevance to members of this forum when I got the email from Flextel, and afer checking to see if it had already been mentioned, create this topic.
If you choose to stay up until 4am formulating your response, then it's not really my problem, although I do commend your dedication, and I do recognise the sterling work you do generally in relation to the cause.  Most of my contributions to this forum are of a more technical nature, or trying to find alternates for people: My strengths are not in the campaigning field, and writing detailed responses are not second nature to me.  I also don't wish to get into personal arguments, so let's leave it there, eh?

NGMsGhost wrote on Jan 22^nd, 2009 at 12:29am:


I started. After reading 2 or 3 I decided I'd prefer waterboarding at Guantanamo.

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Of course it was. I had no idea there were so few in opposition. Oh dear!

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I don't have anything to say!

idb wrote on Feb 5^th, 2009 at 3:44am:


Yup, it has gone!

So its official then.

Responding to any Ofcom consultation is only a way of putting one's criticism of Ofcom's proposals on the public record but Ofcom never ever takes any notice whatsoever of consultation responses and instead always ploughs on utterly regardless with its original proposals in the consultation.

It can of course however throw its own proposals in the dustbin or reverse them whenever it feels like it or it receives instructions from government ministers to do so.

Yet they still have the nerve to say in their Statement on 070 that:-

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I have never heard so much crap in my life.  They cant even effectively enforce GC14.2 with regards to ensuring OCPs make sure 08x prices are more prominent.

I cant take anymore of OfcoN.  They refuse to enforce their own regulations/conditions effectively.  They, most of the time, refuse to investigate/enforce any complaint ordinary consumers have.  However, when a "stakeholder" has a problem, they are all ears and investigate without hesitation.  They have a habit of doing u-turns on anything that might actually benefit ordinary consumers as soon as a "stakeholder" makes a complaint.

In my opinion, I have yet to see any evidence that OfcoN are "independent" regulators!