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

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

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

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

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


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

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

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

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

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


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

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

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

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

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

I suggest a number of considerations:

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

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

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

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


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

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

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

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

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

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

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

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

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

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

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

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

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

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

Continued in next post.

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

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

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

and ConferenceGenie  http://www.conferencenow.co.uk/?utm_source=adwords&utm_medium=cpc&utm_term=%7Bke...

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

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

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

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


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

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

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

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