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Ofcom consultation: Simplifying Non-Geo Nos 2010 (Read 99,808 times)
SilentCallsVictim
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #60 - Feb 9th, 2011 at 6:23am
 
I will try to summarise certain questions, as I understand them, and respond.

This first posting addresses Call Originating Telephone Companies. The second addresses Service Providers and offers some personal views in conclusion.


Why does BT charge more for a Geographic Rate (01/02/03) call than a 0844 / 0871 call?


The current BT rates for calling all NGCS numbers (except for 0845, which is regulated slightly differently, so I will leave this out for now) are set at fixed levels by regulation. The level is equal to the "Service Charge" paid on to the other party, plus a modest allowance to cover some BT costs. This regulation applies only to BT landlines. Ofcom proposes to remove it.

BT offers calls to Geographic Rate numbers as inclusive in the Call Plan selected by the caller to cover the times when they use the telephone. Calls made outside these times attract what I refer to as "Penalty Rates". BT charges for line rental, call plans, the call set up fee and the rates for Geographic Rate calls are no longer regulated.

Whilst call plan charges have remained constant (and the primary plan rate will fall in April) the "penalty" charge for non-inclusive weekday daytime Geographic Rate calls has been increasing at around 30% per annum throughout the last few years. This overtook the charge for the most expensive 0844 calls in October 2010. It has now overtaken some 0871s. Evening rates for non-inclusive Geographic Rate calls are lower, whereas for NGCS (excluding 0845) they remain the same.


Do mobile companies charge line rental?


The fact that they do not is most clearly seen by the issuing of SIMs and numbers for free. The absence of a line rental charge explains the need to levy significant termination fees on incoming calls - all network revenue is derived from usage charges.

Monthly mobile fees may include payment for a handset; apart from this they cover bundled amounts of usage (calls, texts, data). Landlines now commonly have call plans, however these are in addition to a line rental charge. Landline call charges are generally lower than those for mobiles because a line rental charge is paid separately.

If anyone can show an example of what is clearly a line rental charge from a mobile provider, then I would be prepared to accept that there may be an exception and may even be forced to reconsider my understanding on this point.


Should telephone companies be prohibited from levying "Access Charges" on NGCS calls?


One option to achieve the fixed price approach and to address other points made would be to totally disallow "Access Charges". This would essentially put all Telcos into the same position that BT is in at present. This has not been considered previously, because it would not have been legal, however the new powers which Ofcom will be acquiring could perhaps allow it.

The status of call setup fees for non-inclusive calls may have to be considered very seriously in this context (as it would anyway).

Without any "Access Charge" many NGCS calls would be cheaper than non-inclusive Geographic Rate calls for all providers - not just BT, as at present. This would make for a completely absurd situation with PAYG and indeed in other cases where non-inclusive Geographic Rate calls were not seen as a rare exception.

If SayNoTo0870 has the objective of making it cheaper to call NGCS numbers, then that objective could be said to have been advanced if such a proposal were to be adopted. The site would perhaps have to re-focus its efforts to also provide NGCS alternatives to geographic numbers, for those who paid to call geographic numbers. Perhaps it would need to be re-branded as SayNoTo010203 and to campaign for non-inclusive geographic calls to be made cheaper.

If telcos were to remain profitable, then the removal of any revenue from calls to NGCS numbers would have to be covered by price increases elsewhere.


Should telephone companies be allowed to set their own prices?


The principle of a free market allows providers to charge whatever they wish for the services they choose to provide. One could say that there is a cost difference between placing a call from a mobile phone as against a landline to justify a difference in price. This does not however answer the point because there are call charge differences between different landline providers and between different mobile providers.

Ofcom has a statutory duty to encourage competition between providers in the market for communications services, in the interests of consumers. Ofcom would be in breach that duty if it were to allow, let alone require, price fixing.

There is much evidence to show that there is competition in the market for telephone services in general. There are cases where a lack of clarity impedes this at present, e.g. charges for calls to NGCS numbers. Ofcom does however have a good proposal on the table to address this. The NGCS "Access Charge" will be as visible as any other element of a telephone tariff; far more so than the rates for calling NGCS numbers at present.

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SilentCallsVictim
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #61 - Feb 9th, 2011 at 6:32am
 
I continue to summarise certain questions, as I understand them, and respond. The previous posting covered Call Originating Telephone Companies; here I address Service Providers and offer some personal views in conclusion.


Should businesses be allowed to charge for people calling them?


It is currently established that they can. The situation is however confused by the fact that BT alone is prohibited from adding its own charge (to the pence per minute rate) for such calls. Furthermore the breakdown between the "Service Charge" and what other telephone providers themselves charge (the "Access Charge") is not revealed.

This applies from the most expensive 09 number down to the humble 0845. Ofcom now proposes to essentially treat all such cases in the same way.

Ofcom proposes to put BT in the same position as other providers. The "unbundling" proposal forces the split nature of the charge into the open. I suspect that when (if) they are forced to show what is happening, some will cease use of "Business Rate" numbers. If they advertise a charge that people knowingly pay, then it is hard to say that such practice should not be tolerated.

There may be situations where a consumer has entered into a relationship with a provider and then finds that unacceptable charges are imposed as that relationship continues (e.g. premium rate charges for enquiries / complaints by telephone). This is obviously unfair practice, which could equally well apply to any other aspect of a continuing business relationship. There should be remedies for such situations, although these may only apply if the telephone is the only means of contact offered. It is hard to see how the potential for NGCS telephone numbers to be used in this way provides a sufficient reason to affect the way in which Ofcom uses its powers to regulate their use.


Should "Service charges" only be allowed above a certain level?


Some may argue that it is OK for a chat line or some other telephone based service to charge at a high rate (on a 09 number), but not for a call centre to obtain a relatively modest subsidy of its costs (using a 084 number).

Starting from where we are now, there is a clear difference between the two cases. The former is under an obligation to make some (if insufficient) call cost declaration, whereas the latter is not. The cost involved with the former is understood to be high, whereas with the latter it is muddled up with the cost of calls to Geographic Rate numbers - in the case of the biggest single provider and some others. This is unacceptable.

In making its proposals, Ofcom recognises a continuing demand for relatively modest subsidy from callers and does not propose to withdraw this option. It will be interesting to see if that demand is sustained when a requirement to declare the "Service Charge" is threatened or imposed. The level at which telephone companies set their "Access Charge" will also have a bearing. It could be that the modest benefit obtained from the lower levels of "Service Charge" will not be thought worthwhile when it has to be declared as a charge (possibly where any charge for calling would be seen as improper) and where callers may incur a significant supplementary "Access Charge".

I do not believe that Ofcom is going about this is in the best way, as it will not engage with the major users of 0845 numbers to find out what the position really is. With its squinting approach I cannot see how it could set a minimum level for the "Service Charge" so as to effectively rule out the price bands covered by the 084, or even 087, ranges.

As stated above, I do not rule out the possibility that use of the 084 range will die naturally if the "unbundled" proposal is adopted properly. 087 has already been sustained after being classified as PRS and therefore subject to (inadequate) price declaration. I think it likely that use of 087 will continue, even with a clearer price declaration requirement in place.

Those who wish to propose that "Service Charges" should be set at a minimum level of over 10p per minute (thereby ruling out "Business Rate") may have an argument to advance. The case for Ofcom withdrawing an option that is presently available and is widely used may however need to be put with some weight. Suggestions about what to do with the present 084 and 087 number ranges will also be required.


In conclusion


I am reluctant to take a strong moral stance on any of these points because I see business as essentially amoral. It is the matter of transparency that is most lacking. The problem is that the truth is not always simple in a sophisticated world.

A clear understanding is difficult, if not impossible, for the consumer, who may want to take the time to get to the bottom of why they have to pay certain prices for certain items. Opacity may suit the provider, however consumers may not thank them for making a situation complicated.

Unfortunately Ofcom thinks that all of this is far too complicated for anyone to understand, so it has no hesitation in presenting its proposals in a totally inaccessible form.

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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #62 - Feb 9th, 2011 at 11:53am
 
CJT-80 wrote on Feb 8th, 2011 at 8:51pm:
Dave wrote on Feb 8th, 2011 at 2:54pm:
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.


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.

Smiley

The mobile phone is the gas guzzler.

Consider another analogy: A can of fizzy drink can cost £1 in an airport or railway station, yet the exact same product costs a fraction in a supermarket. That is the way it is.

Making such a statement is not an expression of one's own opinion, but an explanation of the way it works (principles at work).
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #63 - Feb 12th, 2011 at 12:59am
 
The question of what will happen with the levels of "Access Charge" has been raised in a number of places.

The present situation, where T-Mobile imposes an Access Charge of 39p per minute on calls to 0845 numbers, whereas BT has an Access Charge of -2p per minute, in both cases for callers on an inclusive call plan, is highlighted in this Daily Mail article - £3.70 to phone NHS Direct but free number for patients is axed. (The "free number" is a simplified reference to the fact that with call plans and packages in place, most contract customers would not pay a call charge to call 0345 4647.)

The equivalent "Access Charges" for a 0871 (type g7) number are: 30p per minute from T-Mobile and a setup fee of 11.5p from BT. "A complete mess".

I quote comments posted in another thread:

loddon wrote on Feb 10th, 2011 at 6:59pm:
... The main problem is that Tfl, for example, cause their mobile callers (which group I have already said are probably the majority) to pay between 20 and 40 million pounds extra for every 1.5 million pounds in revenue which they collect from using the 0843 number. ...

SilentCallsVictim wrote on Feb 10th, 2011 at 8:02pm:
... another important point, which has not been discussed at any length - the level of the "Access Charge". This same point applies equally to 084, 087 and 09 call charges.

Because of the present bundled situation, along with special conditions relating to BT, we currently have a complete mess. The status quo is indefensible. Ofcom admits this, although rather than beating itself up with guilt over its responsibility for it, Ofcom tries to move on by proposing radical measures.

We may get some idea about how telcos will deal with the "Access Charge" issue in their responses to the consultation. I am reluctant to guess, however there is an interesting possibility, which is linked in with another situation that will be changing over the coming years.

It is not impossible that telcos will be taking all of their income through packages covering calls to geographic rate numbers, mobile numbers and the access charge element of calls to Business and Premium Rate numbers. This will leave the only call charges on the telephone bill as the Service Charges associated with calls to Business and Premium Rate numbers.

There is a strong preference for packages, as many telcos have indicated that mobile call inclusive packages will be offered when the excess termination rates disappear. I am not an expert on PAYG deals, however top-up packages and bundles, rather than simply a cash credit against fixed charges, seem to be increasing as a feature in this market.

The situation has to change; TfL has taken a bad decision given the current realities. ...

loddon wrote on Feb 11th, 2011 at 11:06pm:
... I am not convinced that Ofcom is "proposing (sufficiently) radical measures" to clear up the mess and gain popular support.  

I don't think the Ofcom proposals will address the two main problems of excessive cost to callers and cynical exploitation by "owners" of 08 numbers.   ... BmiBaby, in similar action to their industry competitors, insist on using a rip-off 0844 number while offering toll-free and benign normal numbers to their customers in other countries.  

Their representative has had the audacity to start a thread on this site and yet will not respond to reasonable questions nor explain or attempt to justify BmiBaby's rationale in insisting on using 08 numbers.   Do BmiBaby have no confidence at all in their position such that they are not prepared to explain and justify their position?  This intransigence by Companies only fuels the public perception that they are only interested in ripping-off the British public, while they would never dare in other countries.  This is an issue which Ofcom should address.

The other big issue which I have aluded to is the ludicrous and exploitative design of the system which forces callers to pay excessive call costs while the companies are claiming to be making fair charges for services but in fact are receiving a mere 10% or less of the charges.  This charging structure will be no different under the proposed regime.


Under the "unbundled" proposal the structure would be different, because "Access Charges" will be at fixed levels for each caller, rather than varied across the various "Service Charge" levels. This is not true of the proposed "maximum price" option.

Whatever the injustice, I am not sure how far it falls within Ofcom's remit to regulate the way in which airlines participate in discussion forums or even in the types of telephone number which they select for particular purposes. Ofcom certainly has a duty to ensure clarity and transparency in relation to charges for telephone calls. It has been failing badly, but has now proposed improvements.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #64 - Feb 12th, 2011 at 10:20am
 
Quote:
Whatever the injustice, I am not sure how far it falls within Ofcom's remit to regulate the way in which airlines participate in discussion forums or even in the types of telephone number which they select for particular purposes. Ofcom certainly has a duty to ensure clarity and transparency in relation to charges for telephone calls. It has been failing badly, but has now proposed improvements.


You have highlighted a presentation error on my part which I must now correct.   The sentence "This is an issue which Ofcom should address" was misplaced.  Embarrassed

Of course, I do not think that Ofcom should regulate discussion forums.  What I was clumsily trying to say was that Ofcom should address the issue I had mentioned earlier in that post and also in the Tfl thread.   Namely that Ofcom should address the issue of excessive cost to callers, particularly callers with packages.  (Bear in mind that the industry is trying to push all customers into packaged products and it is probable that currently the majority of callers do have a package).   I am referring to the fact that companies using 08 numbers are depriving callers of the opportunity to make use of pre-paid minutes and therefore the true extra cost of calling an 08 number is the total cost of the 08 number and not just the "service charge" levied by the company.  The suggestion by Ofcom that a statement such as "This call will cost you X pence per minute plus your phone company’s access charge" will not tell a caller with a package the real extra cost.

The example which had come up was that of Tfl where it was revealed by a FoI request that Tfl receive 1.5 pence per minute from their 08 numbers.   It is suggested that this results in an additional cost to callers of 5ppm whereas the real cost to callers , considering the inability to use their pre-paid minutes, is from 5ppm up to 41ppm (though some sources say that some telcos charge up to £1.50pm and even £2.50pm).   This is the issue which I would like to see Ofcom address.   I had suggested a more satisfactory solution in another post  where I said " ... if a system could be found which would allow Tfl to apply their charge of 1.5 ppm on top of the callers "normal" call cost then we may have a more acceptable solution  ...".   This is what I would like Ofcom to address.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #65 - Feb 12th, 2011 at 11:44am
 
loddon wrote on Feb 12th, 2011 at 10:20am:
The example which had come up was that of Tfl where it was revealed by a FoI request that Tfl receive 1.5 pence per minute from their 08 numbers.   It is suggested that this results in an additional cost to callers of 5ppm whereas the real cost to callers , considering the inability to use their pre-paid minutes, is from 5ppm up to 41ppm (though some sources say that some telcos charge up to £1.50pm and even £2.50pm).   This is the issue which I would like to see Ofcom address.   I had suggested a more satisfactory solution in another post  where I said " ... if a system could be found which would allow Tfl to apply their charge of 1.5 ppm on top of the callers "normal" call cost then we may have a more acceptable solution  ...".   This is what I would like Ofcom to address.

In the case in question TfL has selected a number which imposes a Service Charge of 5p per minute on callers. If its arrangements include 3.5p per minute being retained by TfL's telco, in lieu of charges that would otherwise be met by TfL, that point of detail is of no consequence to callers.

Under the "unbundled" proposal, how the NGCS "Access Charge" relates to what could be considered as the caller's "normal" cost is a matter to be determined between callers and their respective telephone companies. The existence of inclusive packages and penalty charges for calling outside the terms of the package makes it impossible to make any general determination of what is a "normal" call cost.

This is not a simple issue, as I will try to explain with two examples. If providers were to be required to cover the "Access Charge" element of NGCS calls along with 01/02/03 calls in inclusive "unlimited" packages, then the price for such packages would "undergo upward pressure" (possibly increase) as more calls would qualify. If, alternatively, providers were to be required (or expected) to set the level of the Access Charge at the same level as the penalty charge for making otherwise inclusive calls, then it would probably be higher than it would be otherwise, disadvantaging both callers and users of NGCS numbers.

The important feature of the "Access Charge", as proposed, is that this is a single figure which applies to all NGCS calls. Unlike the present situation, where it is variable and undeclared, this figure would be as visible as any other feature of a tariff. This means that it would be as likely to be known as any other fact about the caller's costs in using the telephone and therefore subject to the effects of competition.

I comment further on this, quoting myself in reply #63.

There are many issues regarding the way in which the unbundled proposal will or could be implemented, however the concept addresses the issues.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #66 - Feb 13th, 2011 at 12:28am
 
To keep "on topic", I respond here to relevant comments exchanged in another thread.

idb wrote on Feb 12th, 2011 at 2:46am:
For [a] UK-based airline to use telephone numbers that have variable international acceptance is, in my view, simply unacceptable. ... I have little interest in how the cost of a NTS call is described if I cannot connect to it in the first place.  Ofcom should be doing all within its remit to prevent such abuse of telephone numbering yet it is entirely passive. It is aware of the problems. It is aware of the solutions yet it exhibits such pathetic behavior.

SilentCallsVictim wrote on Feb 12th, 2011 at 5:55am:
... Ofcom sees a justifiable benefit in use of telephone numbers that generate subsidy or income for the person called. It concludes ... that the problem is with the visibility of the charges. If one could argue that there is no way that this problem could ever be satisfactorily overcome, then one could oppose its proposal that use of NGCS may continue.

There is no question that the present situation is utterly unacceptable.

idb wrote on Feb 12th, 2011 at 2:07pm:
The correct role for the regulator is to act upon previous representations to its numerous prior consultation exercises and realize that, for most engaged with this issue, the matter of whether a call is described as costing 45p per minute or (15+30)p per minute or 15p+30p per minute or indeed any other 'transparency issue' is secondary to the existence of these numbers in the first place. My understanding of previous consultation responses is that there is a overwhelming preference from the 'end user (ie caller)' for the 08 numbering regime to be simply abolished. This is the position that I would maintain. I accept that some will take an alternative position. ...

It is the regulator's responsibility to create a numbering framework that is fit for purpose. ...

For the sake of disclosure, if a business wishes to obtain a payment stream through the telephone system, then it must use premium rate numbering. There must be adequate redress and opt-out facilities, and there must be certain exclusions and constraints on some classes of premium users. For everyday calls, it is unacceptable, to me,  to have a fee collected through the telephone system.

I do not believe that there is any dispute about the present numbering structure, and the way it is able to be used, as being unsatisfactory, nor that Ofcom carries the blame.


Ofcom undoubtedly considered the interests of all those who use 084, 087 and 090 numbers and the views expressed by respondents to consultations, notably the "call for input", when deciding that all of these ranges should continue to deliver income or subsidy to users.

As suggested, Ofcom proposes that all be formally classified as providers of "Premium Rate Services", although with the manner of charging being changed: to unbundle the Service Charge - to the benefit of the Service Provider, from the "Access Charge" - to the benefit of the originating telco.

We already see the extent of the regulation applied being proportionate to the level of Service Charge. This would surely continue as further lower rate (084) ranges are added.


If by "everyday calls" one means those with a Service Charge of up to 5p per minute (084) or 10p per minute  (087), then one is effectively calling for a minimum level to be set for the Service Charge.
How else can Ofcom make any such distinction?


Ofcom cannot itself regulate which types of number are used by particular persons for particular purposes. That is the responsibility of those who regulate or set standards for specific industries or markets. PhonePay Plus does this for the "phone-paid services" industry. This industry does not include those who use NGCS simply to obtain subsidy towards the cost of providing services that are mainly funded in other ways.

(This distinction may be of little concern to callers, but is highly significant in terms of the role of a regulator.)

Apart from many statutory and voluntary industry regulators, there is also a role in this for the Cabinet Office in respect of all public bodies, for the Trading Standards Institute to cover all business and for the Committee on Advertising Practice, which sets the rules enforced by the ASA. In my view, Ofcom should be closely engaged with all of these bodies to ensure that its proposals provide them with a suitable basis for the imposition of proper regulation to cover use of numbers and declaration of Service Charges by NGCS users. Ofcom's narrow approach, focussed only on its own powers, is improper.

It is ultimately for consumers of the services of users of NGCS numbers to make a decision about a Service Charge. Access Charges are set by the telephone service providers, therefore a feature of the consumer's relationship with them. It is for Ofcom to ensure that all is in place for this to work; only some of that falls within its powers to impose and enforce regulations.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #67 - Feb 14th, 2011 at 10:14pm
 
SilentCallsVictim wrote on Feb 12th, 2011 at 12:59am:
Under the "unbundled" proposal the structure would be different, because "Access Charges" will be at fixed levels for each caller, rather than varied across the various "Service Charge" levels. This is not true of the proposed "maximum price" option.
.


Where does it say this in the Ofcom proposals?   And does it make clear that the current  situation where numerous rates can be applied by each Telco, will be prevented and that only one "access charge" rate will apply to an 08 or 09 number?   I raised this question in Post #14 on this thread with --- "Could someone explain how the Ofcom proposals will simplify the current pricing complexity of non-geographic calls, because I cannot see in the Ofcom consultation document.   For example, if you want to find out the charge rate for any non-geo number from Virgin Media, you need to consult their pricing tables to be precise, here :---  http://allyours.virginmedia.com/pdf/uk_non-geographical_calls_a.pdf  

This document is 24 pages long and contains lists of non-geo numbers with the "chargeband" alongside.   You then need to look up the chargeband somewhere to find out the cost.   As you can see there are thousands of numbers and hundreds of chargebands ..."


The following posts did not clarify to me that the nonsense where Virgin Media currently charge hundreds of different rates for calls to 0843 numbers will be prohibited.   For example their charge for calling an 0843001xxx number is on the "PG24" scale whereas a call to an 0843002xxx number is on the "FF29" scale.   Can you assure me that under the proposed scheme VM and all the others will only be allowed to charge a single access charge rate to all 0843 numbers?
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #68 - Feb 15th, 2011 at 3:30am
 
loddon wrote on Feb 14th, 2011 at 10:14pm:
Where does it say this in the Ofcom proposals?   And does it make clear that the current  situation where numerous rates can be applied by each Telco, will be prevented and that only one "access charge" rate will apply to an 08 or 09 number?

The Ofcom consultation document makes the Virgin Media price list (and the equivalents from all other providers) appear to be the essence of simplicity and brevity!

A simple summary of the unbundled option is given starting at section 1.30 (pdf page 11).

I recommend section 6.74 (pdf page 86), which addresses the specific point raised, by explaining the difference between the Access Charge and the current situation with OCP price lists. Surrounding sections outline the various regulatory options being considered for the unbundled approach in more detail.

For the detailed arguments one should review the sections for the specific ranges as follows:
  • starting at A7.198 (pdf page 384) for 0845
  • starting at A7.315 (pdf page 407) for 0844
  • starting at A7.349 (pdf page 414) for 0871
  • starting at A7.392 (pdf page 422) for 09

The consultation is on strategic options at this stage. Further consultations will have to occur when specific regulatory proposals are advanced.

Ofcom is however very clear about what it is looking for from the Access Charge, which it refers to in the singular:

Quote:
Provided the Access Charge is structured simply, it potentially provides a price that consumers can readily take into account when selecting which OCP to subscribe to and which callers can easily remember.


The Service Charge

Ofcom proposes that the "Service Provider" should carry the responsibility for declaring its Service Charge whenever its number is advised - in the same way as currently applies to providers of PRS. It proposes a much clearer message that refers to the telco-specific Access Charge but explicitly states the Service Charge, which will apply regardless of how the number is called.

Although the structure of the table of Service Charges, related to number ranges, would remain essentially the same as at present, this provision means that callers would not normally need to access it.

There would only be one such table, but the complexity referred to would remain if one needed to discover, or verify, the level of "Service Charge" associated with calling a particular number. This could apply if querying the Service Charge raised on a bill, if doubting the information given by a Service Provider or if made aware of a NGCS number to call by a third party (perhaps a friend), who could not be made subject to a regulatory requirement to include the price declaration statement.


I suggest that Ofcom would have to accept the responsibility for maintaining and publishing this table for the benefit of consumers - it would have to do so for OCPs anyway, so as to ensure that they could bill accurately and answer customer enquiries. As well as hard copy versions that could be distributed by all OCPs on request and an on-line "full print" version, I would suggest that an on-line lookup facility be provided.

If, as has been suggested, 084 numbers are added to the definition of PRS, then some of this work could be sub-contracted to PhonePay Plus.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #69 - Feb 15th, 2011 at 1:31pm
 
SilentCallsVictim wrote on Feb 15th, 2011 at 3:30am:
I suggest that Ofcom would have to accept the responsibility for maintaining and publishing this table for the benefit of consumers - it would have to do so for OCPs anyway, so as to ensure that they could bill accurately and answer customer enquiries. As well as hard copy versions that could be distributed by all OCPs on request and an on-line "full print" version, I would suggest that an on-line lookup facility be provided.
Some OCP's now only publish their prices for NGN's in hard-to-find areas which is going against GC14.2.  It took Ofcom two tries and getting OCP's to comply with GC14.2 and BT doesn't do it now.

So with this in mind, what would Ofcom do to ensure that OCP's provide a look-up table of somekind when Ofcom has trouble getting OCP's to comply with a GC?  Wink
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #70 - Feb 15th, 2011 at 2:49pm
 
bbb_uk wrote on Feb 15th, 2011 at 1:31pm:
... what would Ofcom do to ensure that OCP's provide a look-up table of somekind when Ofcom has trouble getting OCP's to comply with a GC?

The whole point of the "unbundled" approach is that it avoids this problem.

OCPs would only be responsible for advising their Access Charge. Advising the Service Charge would primarily be the responsibility of the Service Provider.

In the section from which my quote was taken, I was referring only to the need for a fall back to cover situations where the information provided by the Service Provider was being verified or was unavailable, e.g. when querying a billed charge or dealing with a number provided by a third party.

In the present situation, even when an OCP provides the information in the clearest possible form, the structure is so complex that it is effectively inaccessible anyway (this point is well made above).

Given that the opportunity to impose Service Charges is to remain largely as it is, I strongly believe that the "unbundled" approach represents the best way forward. There are however many points of detail about the manner of the implementation to address.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #71 - Feb 18th, 2011 at 6:02am
 
A number of members have commented on the difficulty of reading the Ofcom document.

It is too big to read start to finish and there is no usable index that provides any guide to the content of sections. I have made appropriate representations to the Ofcom "consultation champion".

For my own purposes, I have prepared an "indexed" version, using a standard feature available when creating a pdf document from MS-Word. As the published versions of all Ofcom consultation documents are prepared in this way, I can see no good reason why this feature is not used generally.

My version, which stops at the end of the material subject to consultation, has been subjected to manual editing so there may be errors, the pagination is different and some graphics have not survived the out and in conversion process. I cannot therefore formally publish this as an "alternative" version. I do however keep a copy on the internet for easy reference. Members may be interested to know that it can be accessed via this short url - http://tinyurl.com/dhtiny/ofcon.
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #72 - Feb 19th, 2011 at 9:49pm
 
SilentCallsVictim wrote on Feb 18th, 2011 at 6:02am:
For my own purposes, I have prepared an "indexed" version, using a standard feature available when creating a pdf document from MS-Word.....Members may be interested to know that it can be accessed via this short url - http://tinyurl.com/dhtiny/ofcon.
Thanks for this.
If Ofcon insists on it's preferred way then I would prefer a name like 'Lower Premium Rate Service (LPRS) instead of the use of Business Rate.  That way, the description alone informs us consumers that it is a premium rate number albeit a lower charged one than the normal PRS 09x numbers.

Ofcon would also have to do more to ensure that consumers were informed of the 'Access' charge.  Landline OCP's change their prices that often now that a table of Access charges held by Ofcon would most likely be out of date within a short period.

OCPs should be made to ensure Access charges are in a easy to read format on the same page where it mentions geographical call costs.  As I mentioned in an earlier post, GC14.2, was meant to ensure just this but Ofcon, as per usual, doesn't actively enforce it and actually fine OCPs for not complying instead of a constant 'light-touch regulation' hence why it took 2 tries to enforce the new GC14.2 on price transparency and to date BT at least doesn't actively comply.


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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #73 - Feb 20th, 2011 at 5:23pm
 
bbb_uk wrote on Feb 19th, 2011 at 9:49pm:
Thanks for this.

If Ofcon insists on it's preferred way then I would prefer a name like 'Lower Premium Rate Service (LPRS) instead of the use of Business Rate.

Thanks for the positive input to the discussion.

I can see two points of merit in use of the term "Business Rate", given that there is any validity in making some distinction from "Premium Rate". It is important to remember that for the caller, there is no fundamental difference; the "Access Charge" and the need for price declaration are identical.

The way I see the difference is that "Business Rate" (084 and 087) numbers are used by businesses, other than those who are providers of telephone services, to obtain subsidy towards the cost of their business operations in whatever field they occupy. I doubt that anyone would set up a 087 number, where they did not otherwise receive telephone calls, simply as a means of generating fresh revenue. There simply would not be enough money in it, given that the calls were actually going to be handled in some way (scams are different).

As an alternative to using a "Geographic Rate" (01/02/03) number for the same operation, the cash or discount benefit is seen by some as worthwhile, even when offset against a directly corresponding cost to callers. That is a business decision to be made, and a much clearer decision in a more transparent environment. I hope that when faced with this clearer decision, businesses will think carefully about whether they wish to openly impose charges on callers. Some will decide that they do not, others will be required to present clear justifications without being able to blame telephone companies.

The term "Business Rate" suggests a valid connection with "Business Class", as used by airlines and hotels. It is not the top of the scale, but it is conveys some sense of unnecessarily extravagant expenditure to many people. It also reflects the fact that there is some commercial motive behind its use.


The concept of a "Lower" "Premium Rate" has been understood for some time, as it provides the only justification for the use of the awful term "Lo-call". The "Lo" simply means lower than other premium rates. The phonetic connection with "local" is a most transparent deceit.

I fear the suggestion that LPRS calls were cheaper than Premium Rate calls being used to imply they may not always be more expensive than Geographic calls. "How much lower?" is the obvious question, to which answers will be expected to be predictable. Campaigners will be expected to say "not much", users will be expected to say "lots". Longstanding confusion will continue.

There is the even greater danger that, as is common, terms get shortened in regular use, missing out a vital element. "Lower Rate" would be a most convenient shorter version for the term "Lower Premium Rate Services"! As with "lo call" the implication would be that the rate is low with reference to rates in general, rather than just to some very high rates.


With my focus on the public services, I feel that the term "Business Rate" would be more uncomfortable than "Lower Premium Rate" for service providers to use. A primary purpose of these proposals must be to get those who should not be using 084 numbers away from them and onto 01/02/03. If, as Ofcom believes, there are a large number of people who would be happy to justify their use of 084 numbers, they need to be set the fairest possible test.

bbb_uk wrote on Feb 19th, 2011 at 9:49pm:
Ofcon would also have to do more to ensure that consumers were informed of the 'Access' charge.  Landline OCP's change their prices that often now that a table of Access charges held by Ofcon would most likely be out of date within a short period.

When I have referred to a table held by Ofcom, I was speaking about the large and complex table of "Service Charges". The "Access Charge" is part of the normal commercial relationship between a telephone service provider and their customer. Ofcom has no need to be involved in keeping records of what these are.

Ofcom is adamant that "Access Charges" must be very simple - one rate per customer / contract is suggested. OCP price lists would no longer have to include the complex tables of rates for UK NTS calls, which are commonly larger than the sections covering the rest of the world - in time rats for calls to UK mobiles will become simpler too.

I cannot think why the Access Charge for Business / Premium Rate calls would ever be presented anywhere other than on the first page of calling rates, as one of the first half dozen figures quoted in a call charges price list. It is perhaps too early to judge whether this charge will be something that OCPs would wish to hide, or whether they would want to be quick to show that when one is paying £1.50 a minute to call a premium rate number, only a few pence of this is going to them.

It is also important to remember that under the unbundled proposal, every advert for a Premium Rate Service or announcement of a Business Rate number will contain a reference to "your telephone company's access charge". Every viewer of some of the most popular television shows will see this on the screen and hear it announced, even if they have no thought of calling themselves. Customers will want to know what this is. Those who have paid their provider for all of their calls will understand that they have to p
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Re: Ofcom consultation: Simplifying Non-Geographic
Reply #74 - Feb 20th, 2011 at 8:36pm
 
SilentCallsVictim wrote on Feb 20th, 2011 at 5:23pm:
I cannot think why the Access Charge for Business / Premium Rate calls would ever be presented anywhere other than on the first page of calling rates, as one of the first half dozen figures quoted in a call charges price list. It is perhaps too early to judge whether this charge will be something that OCPs would wish to hide, or whether they would want to be quick to show that when one is paying £1.50 a minute to call a premium rate number, only a few pence of this is going to them.
In my experience, OCP's go out of their way to hide the cost to of NTS numbers - even the most common 0845/0870.  That's why Ofcon finally decided to enforce it via a GC although it took them several tries.

Can someone remind me if BT's prices on 084/087 (except 0845/0870) are still regulated?  If so, will the regulation be dropped with Ofcon's new proposals because if so then I can see price rise after price rise because all that happens now is that when one OCP increases prices the others just basically follow (although some may not increase to exactly the same as their competitors - just drop slightly short like a penny).
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