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Ofcom consultation: Simplifying Non-Geo Nos 2010 (Read 151,952 times)

SilentCallsVictim

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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #45 - Jan 26^th, 2011 at 11:27am

NGMsGhost wrote on Jan 26^th, 2011 at 11:04am:

Surely you at least must have done so SCV even though I must confess to only so far having read the bullet point summary of what is proposed.

I admit to having trawled through to see what is there. I find the essence of what is proposed to be essentially sensible, given the way in which Ofcom approaches these matters. There are however many important issues that should have been addressed and have not. In particular no serious thought has been given to important questions about how this may be implemented, whereas some implementation issues have been addressed in inappropriate detail.

I hope that this thread will enable many members to express their views on the key issues; e.g. the three call types, the future of 0870, the unbundled approach and the maximum retail price option. I see these and other issues as worthwhile topics for discussion.

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CJT-80

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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #46 - Feb 6^th, 2011 at 9:54pm

I have done my best to read some of the details, but at 482 pages long I am struggling to read all of it!

I also had a look at some of the "attachments" given with the main link, and they range from 30 pages onwards, hardly tea time reading.. Sad

From what I have read here are my observations:

Ofcom and the call providers still would expect US to know how much it is to call X number, unless a: it's a pre set charge across ALL networks and ALL telecoms types (Mobile/Landline/Call Box), or b: every call to a NON Geographic (01/02/03) number has a Pre Call Announcement (PCA).

From what I can also gather the PCA would STILL require US to establish part of the call cost invloved in making the call, unless the PCN was wordered as follows " You will be charged a maxium of X pence per minute in total for the call" - source here page 22 section 4.2.

On this basis I would suggest Ofcom and ALL call providers impliment 2 parts to this consultation:

A maxium ALL network/call provider charge (per minute) and a PCN detailing it as per my notes above.

I will post a seperate response as to why I recommend these.

Regards,

CJT-80

Any comments made are my own and are not those of SayNoTo0870.com

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SilentCallsVictim

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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #47 - Feb 7^th, 2011 at 1:32am

CJT-80 wrote on Feb 6^th, 2011 at 9:54pm:

I have done my best to read some of the details, but at 482 pages long I am struggling to read all of it!

It is indeed a nightmare. I am reluctant to try to be authoritative myself, as I have not read every line, but I will have a go at addressing the points made above.

The key element of the "unbundling" (or disaggregating) proposal is that the "Access Charge" levied by the caller's telco (known as the OCP) be advised and billed separately from the "Service Charge" levied by the "Service Provider" (SP) and their telco (TCP).

The idea is that the OCP has a fixed "Access Charge" for all NGCS calls which it advises to its subscribers. It may be that there are different access charges for various call plans, but the point is that they are fixed, regardless of the "Service Charge" that applies to a particular number range.

Ofcom proposes that advising the "Service Charge" is the responsibility of the Service Provider. There is already such a requirement for PRS numbers, however it is vague and is generally met by quoting BT rates. The idea is that this would be covered by a statement in the form
Quote:

This call/text will cost you X pence per minute plus your phone company charge.

As with the present system, specific Service Charge levels would be associated with blocks of numbers. There would have to be a central place where this information was recorded, so that telcos could bill correctly and for reference in cases where the SP was not able to provide the Service Charge information, e.g. if their number was quoted by someone else. This would be similar to the lengthy tables that presently clutter the BT price list (and others) - but there would be only one, giving the Service Charge applied to any particular number by every telco.

All that telco's price lists would have to show is the applicable "Access Charge", with the vital comment that a "Service Charge", selected by the SP, would be added.

I believe that the table of Service Charges would have to be published (probably by Ofcom) on the internet and available in hard copy also. Other ways of accessing this information could be considered. The point for me is that if a Service Provider is levying a "Service Charge" for a service, it is their primary responsibility to see that the price is advised to those who are to pay it.

The Analysis Mason document appended to the consultation was looking at the mechanics of achieving the unbundled (or "disaggregated" as it calls it) approach. One of the options being considered was the possibility of advising Access and Service Charges by free PCA.

PCAs are very difficult in the context of an "unbundled approach" as there are two components to the call cost. The document discusses this at length. The possibility of different callers on the same network having different "Access Charges" in effect raises another potential problem.

I am personally opposed to the use of PCA's as a primary means of advising call cost. The decision to make a telephone call is made, with an awareness of the likely cost, before dialling the number. The only significant benefit to be derived from a PCA is a decision to abandon the call. Unless it has that effect then it is probably just a time-wasting annoyance. The only justification I see for PCA's is where the likely expected cost is much less than what will actually be charged. The emphasis should be (totally in my view) on proper cost awareness when taking out telephone service and when being invited to call particular numbers. The existence of PCA's can remove that responsibility altogether.

A worthwhile PCA must surely give the total cost basis for the call in cash terms. If it failed to do so, perhaps only covering one of the two elements of the cost of the call, many would see this as a waste of time. I think it highly unlikely that this could be achieved, not least because the necessary sophistication would make such a system very expensive - do not forget that costs always end up falling on the customer, unless Ofcom used taxpayers' money to pay for this. If the PCA idea were to be pursued, there would undoubtedly be a compromise, which would probably make the exercise pointless - Ofcom sees its role as being to deliver compromises.

(I continue with comments on the "Maximum price" option in the consultation, and conclude ...)

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SilentCallsVictim

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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #48 - Feb 7^th, 2011 at 1:34am

(... Further to my previous posting)

I also oppose financial intervention in the market to set a maximum price for NGCS calls. It is the alternative of the unbundled approach which provides the essential clarity that I see as being the proper solution.

The Service Charge would be fixed, within ranges applicable to each type of number, as at present (e.g. 084 up to 5p per minute, 087 up to 10p per minute). Telcos would have the freedom to set their Access Charge at whatever level they wish. If they decided to charge £1 per minute for all calls to NGCS numbers, then I see no reason why Ofcom should intervene to prevent this - given that it was properly declared on their price list. (Those who wish to see an end to use of NGCS numbers as a way of making money would probably celebrate such a move as it would kill the market!)

The major problem with the maximum total price approach is that it would have to consider the most expensive means of telephone service provision - currently payphones. The maximum set would therefore be totally meaningless in respect of normal charges for other types of provision.

(I have not read Ofcom's thoughts on the subject of maximum prices - I fear that this will get into levels of economics which are well beyond me. Maximum prices are seen as one option available to regulators to deal with "market failure", which is repeatedly referred to. The point is that there is no "market failure"; it will only be when prices are unbundled that markets will exist: for Telcos with their "Access Charges" and for SPs with their "Service Charges". The present mess enables each to assign responsibility to the other. I believe that, if there were transparency, then the "market" would work.)

I hope this is helpful.

CJT-80 wrote on Feb 6^th, 2011 at 9:54pm:

... I would suggest Ofcom and ALL call providers impliment 2 parts to this consultation:

A maxium ALL network/call provider charge (per minute) and a PCN detailing it as per my notes above.

I will post a seperate response as to why I recommend these.

I look forward to reading the arguments in favour of PCAs and maximum prices.

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CJT-80

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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #49 - Feb 7^th, 2011 at 1:03pm

Hello again, I have read through your response at great length, and hopefully I can now give a better answer.

Maxium Call Costs

For this I will give 2 examples which I have read today, one for 0844 and one for 0871. They are 2 companies who were both featured in a National Paper today,

Company 1 provides holidays and has an 0844 number to contact them, Company 2 provides plants mail order and uses an 0871 number to contact them. For reference Company 1 will be called HC and 2 will be called PC.

HC has an advert asking callers to dial an 0844 number, at NO point during the advert (in print) does it advise ANY cost of calling this number. How am I to know how much it would cost to call that number? Dial my network (BT for landine/O2 for mobile), go on the internet, ask someone? What if I didn't have the internet? What if I was not sure who to call? These are ALL questions Ofcom and companies need to think about, they may only make a SMALL profit, but someone somewhere still makes money out of my call.

PC has an advert asking callers to dial an 0871 number and advises "calls cost a maximum of 10p per minute from a BT landline, mobile networks vary", which is a way is good advice, or is it?

What if I am not with BT, what if I am dialing from a mobile, how much will it cost? Also it's MORE then 10p per minute with the VAT increase, and NO mention was made of the "connection" charge BT makes (currently 11.5p).

So whilst HC made NO mention of the call cost, PC did no better as it provided very basic info.

Why should anyone set the call costs?

Simply because I should NOT be penalised for calling a number from any provider I choose, just because they are allowed to charge more! If Ofcom set the rate which included the set up fee for malking the call, and which everyone had to charge (landline/mobile/payphone) then not only would the company you were calling be able to correctly advise the charge but you would know how much it would cost to ring that number, and you would be confident in it's cost!

This should apply to ALL 08 (including 0845/0870) numbers excluding FOC (0500/0800/0808) calls - which is a seperate subject all together!

I want to know how much it WILL cost me in total before I call that number, and it's unfair that one provider can charge 11p per minute, whilst another charges 35p per minute!

What effect would this have on the cost of the calls overall?

In honestly I don't know, but there is NO suggestion that the network would charge the FULL rate for the call, they are at liberty to charge less, all that has to be advised is "calls will cost a MAXIUM of X pence per minute inc network charges, regardless of your call provider" - It's that simple! (not being rude there)

PCA's

If the above system was inplimented, then PCA's would not be required, and would save all the companies in question money overall!

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

If anyone needs more info or clarification on what I have said, please let me know.

Regards,

CJT-80

Any comments made are my own and are not those of SayNoTo0870.com

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SilentCallsVictim

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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #50 - Feb 7^th, 2011 at 2:53pm

CJT-80 wrote on Feb 7^th, 2011 at 1:03pm:

Hello again, I have read through your response at great length, and hopefully I can now give a better answer.

Under the Ofcom proposals each telephone provider would have to set an "Access Charge" for calls to all NGCS numbers from 0845 to 09.

Ofcom proposes a single pence per minute rate that applies to all such calls. That would be as much part of what you know about your telephone tariff as any other feature, e.g. the daytime rate for calling geographic numbers.

The two newspaper adverts would both have to say:

"Calls cost x per minute plus your telephone company's access charge."

That is an improvement in both cases. The access charge would almost certainly be greater if you were calling from a PAYG mobile than from a landline.

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bbb_uk

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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #51 - Feb 7^th, 2011 at 8:01pm

SilentCallsVictim wrote on Feb 7^th, 2011 at 2:53pm:

The two newspaper adverts would both have to say:

"Calls cost x per minute plus your telephone company's access charge."

That is an improvement in both cases. The access charge would almost certainly be greater if you were calling from a PAYG mobile than from a landline.

Forgive as I have only very quickly scanned the consultation but where would OCP mention this 'access charge' and would it differ depending on type of call - ie 0845 access charge is different than 0871?

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CJT-80

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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #52 - Feb 7^th, 2011 at 9:18pm

SCV,

my issue with that method is the fact it's 2 charges! Yes it's broken down, but the call cost would still differ if: the access charge was different per telco or number, or if the X pence per minute charge was different per telco or number.

My idea was simple, ONE set charge per minute based on Access and Service charges. At the end of the day the end user is most likely wanting to know exacly how much it WILL cost them from their call provider before they make the call, and with as little complication as possible.

One set fee per minute / number (inc ALL charges) reglardless if what network the call is made from, is by far the fairest method of charging.

Same charge for BT/TalkTalk/Virgin - and O2/Orange/T-Mobile/Voda/3 - Contract OR PAYG!

In the market of choice, I should NOT be penalised for calling a NGN from a mobile.

Regards,

CJT-80

Any comments made are my own and are not those of SayNoTo0870.com

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SilentCallsVictim

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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #53 - Feb 7^th, 2011 at 9:46pm

bbb_uk wrote on Feb 7^th, 2011 at 8:01pm:

The "Access Charge" for NGCS would be declared in the same way that other key features of the tariff have to be declared, i.e. on price lists and in marketing material.

The Ofcom idea, for the moment, is that there would only be ONE NGCS "Access Charge" per tariff and that it would only be levied as a pence per minute rate, i.e. no setup fee.

At least one further consultation will take place later before any specific proposal is implemented - there are other options covered by the Consultation, although clearly this is what Ofcom prefers. Ofcom does distinguish between "Business Rate" (084 / 087) and "Premium Rate" (09) numbers. I could see the possibility of different access charges at this level, but not any lower (i.e. all 084 and 087 would only have one access charge per tariff). There is no specific Ofcom proposal to prohibit use of setup fees, so it may well be that the Access Charge could be a fixed fee, a rate per minute, or both.

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SilentCallsVictim

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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #54 - Feb 7^th, 2011 at 11:00pm

CJT-80 wrote on Feb 7^th, 2011 at 9:18pm:

my issue with that method is the fact it's 2 charges!

It is two charges because two different parties earn income from NGCS calls, remember that this includes all of the Premium Rate ranges as well.

The call recipient earns the same amount regardless of how or where the call is originated. Many people think it right that this amount should be clearly declared, so that callers know what they are earning. They chose the precise amount they will receive by selecting a particular type of number - apart from 0845, each range is broken into many sub-ranges.

CJT-80 wrote on Feb 7^th, 2011 at 9:18pm:

My idea was simple, ONE set charge per minute based on Access and Service charges. At the end of the day the end user is most likely wanting to know exacly how much it WILL cost them from their call provider before they make the call, and with as little complication as possible.

To achieve this degree of simplicity someone would have to decide how much every telco may charge for connecting a call to a NGCS number. At present they are free to offer different types of service; i.e. landlines and mobiles, with different deals; e.g. credit contract / PAYG, bundled / pay per call. There are multiple competing providers in each market so prices are supposedly kept low by competition. Public payphones introduce a further complication, because the economics there are different.

Ofcom could determine what is an economic cost for provision of the service - it has to do so for BT at present - this produces rates for the most expensive 0844 and some 0871 numbers that are less than the penalty rates for non-inclusive geographic calls. It could however add on a modest margin to these landline BT cost rates to give a figure. Should this be the fixed price?

If it were, then mobile providers would probably cease to allow calls to NGCS numbers. Under the present arrangements mobile providers do not charge line rental, unlike landline providers, so they recover the costs of maintaining the network through call charges which are higher than those charged for calls from landlines. Without a contractual commitment, rates for PAYG calls are naturally higher still, so it is even more likely that PAYG callers would be stopped from calling NGCS numbers if a fixed rate based on the cost of originating calls from landlines were applied.

Perhaps Ofcom should do the job the other way around then, starting with the PAYG providers, perhaps the least efficient and therefore most expensive. Should this be the fixed price? - The implications for BT's profitability are clear to see. NGCS users would be in total revolt at this forced over-pricing of the cost of calling them.

Despite acquiring new powers of price regulation from May this year, Ofcom would probably end up in court, being accused of misusing them, however it set the prices.

If the economic cost of a call from a public payphone were used to set the price for all calls then the system would collapse totally. If a fair price for landline calls were applied to public payphone calls then every public payphone would be removed because it was not economic.

My analysis may be a little over-simplistic and the dangers could be exaggerated. (I have not addressed the possibility of cross-subsidy, which nobody ever admits to because it is too complicated to consider. BT at present is not permitted to make a margin on NGCS calls, it is only permitted to recover its costs. Given that BT does produce a return for its shareholders, it may be argued that some other charges, somewhere, must be too high.)

Whilst Ofcom's economists may relish the task of setting prices, price fixing is foreign to Ofcom's proud role as a light-touch regulator of a competitive market. I cannot, offhand, think of any occasion when any one of the "Of-" regulators has set a fixed retail price.

More complex arguments are needed to set against the Ofcom proposal for maximum pricing, which it offers as an alternative to the unbundled approach.

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Dave

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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #55 - Feb 8^th, 2011 at 2:54pm

CJT-80 wrote on Feb 7^th, 2011 at 9:18pm:

my issue with that method is the fact it's 2 charges! Yes it's broken down, but the call cost would still differ if: the access charge was different per telco or number, or if the X pence per minute charge was different per telco or number.

My idea was simple, ONE set charge per minute based on Access and Service charges. At the end of the day the end user is most likely wanting to know exacly how much it WILL cost them from their call provider before they make the call, and with as little complication as possible.

One set fee per minute / number (inc ALL charges) reglardless if what network the call is made from, is by far the fairest method of charging.

Same charge for BT/TalkTalk/Virgin - and O2/Orange/T-Mobile/Voda/3 - Contract OR PAYG!

In the market of choice, I should NOT be penalised for calling a NGN from a mobile.

In a free market, it is to be expected that providers offer different (and the same) services for different prices. That is what we have now.

This appears to be an argument in favour of full price regulation; or perhaps nationalisation.

Having landline and mobile networks charging the same would be like offering fuel to those with gas guzzlers at a lower (pence per litre) rate than those with vehicles that use less fuel. This would then even out the "pence per mile" that everyone paid.

The Access Charge would vary between tariff, just as call charges vary between tariffs now and a Service Charge will be fixed for a particular 08/09 number.

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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #56 - Feb 8^th, 2011 at 8:45pm

SilentCallsVictim wrote on Feb 7^th, 2011 at 11:00pm:

Ok, so how does anyone justify the difference between the cost of a call from a Landline and the cost of the call from a Mobile?

Lets take Virgin Media a call to an 0844 800 number is PG6 which is rated @ 10.41p per minute plus a 12.24p connection/network fee.
O2 Paymonthly is 20.4p per minute with no connection/network fee.

a 5 minute call to this Number on Virgin costs - £5.34 (rounded up) and on O2 costs £10.50 that's almost twice the cost!

Can you justify that? I am sorry I cannot.

What if they only telephone option someone had was a mobile, do you feel it's "fair" to charge them more?

SilentCallsVictim wrote on Feb 7^th, 2011 at 11:00pm:

Ofcom could determine what is an economic cost for provision of the service - it has to do so for BT at present - this produces rates for the most expensive 0844 and some 0871 numbers that are less than the penalty rates for non-inclusive geographic calls. It could however add on a modest margin to these landline BT cost rates to give a figure. Should this be the fixed price?

If it were, then mobile providers would probably cease to allow calls to NGCS numbers. Under the present arrangements mobile providers do not charge line rental, unlike landline providers, so they recover the costs of maintaining the network through call charges which are higher than those charged for calls from landlines. Without a contractual commitment, rates for PAYG calls are naturally higher still, so it is even more likely that PAYG callers would be stopped from calling NGCS numbers if a fixed rate based on the cost of originating calls from landlines were applied.

Perhaps you would kindly indicate where BT charge lower for an 0844/0871 call then to a Geographic non inclusive call? Have I not already pointed out it was a the difference of aound 1p per minute?

I hardly think that's a fair or justified comparison personally.

Which mobile provider does not charge line rental, and to whom? I have a pay monthy account where I pay a montly rental charge, for which I get a set number of X network and Landline minutes, and "unlimited" texts and on network minutes. I would gladly pay a "add on" charge to include or greatly reduce the cost of calling 08 numbers!

What figure per minute do you feel is "fair" to call an NGN?

Regards,

CJT-80

Any comments made are my own and are not those of SayNoTo0870.com

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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #57 - Feb 8^th, 2011 at 8:51pm

Dave wrote on Feb 8^th, 2011 at 2:54pm:

Dave I am at a loss as to how we managed to compare Fuel usage to Sevice charges and NGN's.

What service exactly are you comparing? Is the Gas guzzler a Moblile or Landline, is it PAYG or Contact for the mobile?

If I go out and buy a 2 litre Merc I expect to pay the same per litre of fuel, but I won't expect to get the same MPG as apposed to a Fiat 500 Twin Air. I'd also be expecting to pay higher Road Fund Licence as I "polute" more, sadly I cannot compare this to making a call to a NGN.

Am I correct that the aim on SNT0870 is to avoid calling NGN's and finding ways to avoid this?

If I am correct may I ask WHY we are avoiding calling them? I would assume it's down to the cost compared to Geographic calls?

I look forward to your reply.

Regards,

CJT-80

Any comments made are my own and are not those of SayNoTo0870.com

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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #58 - Feb 8^th, 2011 at 11:51pm

None of this complicated discussion about complex NGNs would be necessary if the principle that the beneficiary of a service should pay for that service applied. The correct regime for 08 numbers should be that callers should pay the "access charge" and the business "owner" of the 08 number should pay the "service charge". Simple.

Competition would exist between callers' Telcos and competition would also exist between receivers' Telcos. The receivers Telcos would be competing on the basis of their charges to the "owners" of the 08 numbers and those "owners" would be in a position to negotiate with those Telcos over Terms, charges and services (something which callers are unable to do and therefore should not be forced to pay those extra charges).

If there is to be a charge for HAVING a 08 non-geographical number it should be borne by the recipient not the caller.

« Last Edit: Feb 9^th, 2011 at 8:33am by loddon »

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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #59 - Feb 9^th, 2011 at 1:27am

loddon wrote on Feb 8^th, 2011 at 11:51pm:

If there is to be a charge for HAVING a 08 non-geographical number it should be borne by the recipient not the caller.

This points to the absolute essence of the argument, and I would completely agree with this statement. This Ofcom consultation is, sadly, yet another pointless exercise designed as a smokescreen to simply re brand certain numbers as the warm and fluffy term 'business rate'. When did the need to have a 'business rate' number actually arise? There never used to be any discrimination, from the perspective of a caller, between the telephone line/number at the NatWest at 123 High Street, Anytown and the one at Mr Jones' apartment above at 123A High Street, so why is there a need now? There isn't. Never has been. Unless and until Ofcom addresses the fundamental concept relating to this absurdity of the UK numbering plan, then the consumer will always end up being shafted.

If a given business wants a fancy schmancy telephone system, then it should fund it. It would be preposterous for me to pay an additional call charge to contact, say, Bank Of America, simply in order to fund its telecom operation. It should not cost any more for me to call FPL in Miami than it does to call a residential consumer in the same street block. It doesn't. Ofcom will not address the main issue, and that is why the UK has such a convoluted and inappropriate telephone numbering system.

I was in the UK only last week, and was shocked to see the extent of NGN use. I had to call my airline due to a flight change. The absurdity of the UK system meant that it was (far) cheaper for me to call its call center in the US as opposed to the UK provided number. I know about this, but only because I have an active interest in telecomms. I suggest that a significant proportion of the UK public would be oblivious to such a nonsensical charging scheme.

No one over on this side of the ocean would assume that it would be more financially beneficial to call British Airways in the United Kingdom than use its American call center. Sadly the same does not apply for the opposite scenario.

As from November 21, 2013, I no longer participate in the forum and am unable to receive private messages.

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