0871 - The baby and the bathwater?

Opinion piece from Kieron James, chairman, FCS Numbering Group

London, 09 July 2006 - Ofcom has asked the Premium Rate Regulator, ICSTIS to regulate 0871 calls from early 2008. The decision is based upon evidence that 0871 numbers are being targeted by a minority of rogue operators who are using the range for dialler scams and adult services. Ofcom has also commented that “customers do not like revenue sharing aspects of phone calls”. But despite the fact that the majority of Number Translation Services (NTS) operated on 0871 are entirely legitimate, the number range will be regulated by ICSTIS, with a fees levy on number providers.

Furthermore, Ofcom has already extended Premium Rate Services regulation to enable ICSTIS to take action against any rogue dialler, irrespective of the telephone number used or call charges and has proposed that all adult services will have to move to 09 before the end of the year, removing much of the rationale for further regulation.

A highly innovative telecoms sector has developed network level call management functionality, such as intelligent routing, time of day call plans, follow-me hunt groups, interactive voice response (IVR) facilities, voice and fax to email services based on NTS services.

Small businesses are able to use 08 numbers and these services improve call handling and response times for their customers without the need for expensive hardware PBX systems to route calls internally. More often than not, the small firm earns little or no call revenue share, but the additional pence per minute paid by the caller is used to fund services provided by their service providers.

But providers of such services now face a dilemma. Ofcom is setting about regulation to stop bad practice, but has not we feel considered the impact on the legitimate majority of numbering service providers – that is why we set up the FCS Numbering Group to provide a coherent voice for businesses in our sector and their customers and callers.

Within its package of measures Ofcom says that the geographic link will be restored for 0870 by early 2008. In practice this means Ofcom has removed the commercial model which underpins the call management services its predecessor was instrumental in developing. With no commercial justification for providing call routing services, small businesses such as painters, decorators and plumbers will be forced to move to 0871and fall under the ICSTIS regime as their providers withdraw services on 0870.

There are several outcomes, which do not appear to benefit the industry, small business or the citizen consumer:

• Businesses retain their 0870 numbers but pay for call management services which have been provided in good faith at no cost. Perhaps this seems reasonable but it presupposes that each 08 reseller has the necessary billing platform;
• Businesses find another way of providing services rather than through convenient micro-billing associated with 08 calls;
• Businesses migrate to 0871 and bear all the costs associated with publishing their new numbers;
• Callers lose out by paying around 2p per minute more to call a 0871 number than they would a 0870 number at current pricing.

There are several questions that the FCS Numbering Group needs answers to:

• Why is this really necessary when remedial measures are in place for diallers and adult services?
• How many 0871 suppliers will be affected?
• How many 0871 small business users will be affected? Does Ofcom or ICSTIS know?
• Will there be any negative implications for a decorator or an advice centre from being regulated by a telecoms organisation because he provides "premium rate services"?
• Does an advice centre have to send an invoice to every enquirer to cover the cost of the service if the cost cannot be recovered in the phone bill?
• How can ICSTIS apply its current mechanism of asking number suppliers to forecast their revenue from 0871 in order to pay ICSTIS for regulation in this low margin sector?

We welcome input from number operators and resellers - how will you respond to these changes?

Contact Kieron via numbering@fcs.org.uk