EDM 2035 (Premium Rate Telephone Nunbers)

I quote below the text of a message sent to:

•    Proposers and Signatories of EDM 2035 (Premium Rate Telephone Nunbers)

•    Members of the Public Administration, Health, Treasury and Work & Pensions Committees

I offer members a briefing on the relevant issues and express my concerns about the way in which the EDM is presented.

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Many of you will be aware of my campaigning efforts on this issue. I am focussed primarily on the NHS, however the other issues raised in EDM 2035 are well within the scope of my campaigning efforts. I have been deeply engaged with HMRC and done a lot of work with the DWP agencies.

I offer a further briefing and comment on the EDM.

Summary

It is most unfortunate that EDM 2035 fails to mention 03 numbers. These not only have a proper place in the considerations, but provide the basis for the most effective resolution of this matter (see My Proposal below).

There is no reference to other "Business Rate" numbers i.e. 0844/3, 0871-3. These are also (improperly) used in the delivery of public services.

I have published a large amount of relevant material which provides further briefing.

The following items may be of particular interest, as they contain specific information that may be used in support of the EDM:

♦	... public service providers must cease using 0845 telephone numbers .... This offers a statistical basis to support the arguments and objectives declared in the EDM.
♦	Ofcom's proposed call cost advice. This shows the effect of proposed new call charge declaration regulations.
♦	My table of typical call costs. This shows the scope and the extent of additional charges incurred when calling 084 numbers.

Non-geographic telephone numbers

There are many advantages to use of non-geographic telephone numbers. They all provide an absence of association with a particular locality as well as technical benefits that are not so readily available with geographic numbers.

The point at issue here is the cost of calling, where they fall into five groups:

♦	080 - the recipient pays towards the caller's costs, at a level sufficient to make calls free for callers from landlines and payphones. Under present regulation, mobile companies can and generally do raise charges for 080 calls as their costs are not met by the recipient. There are some specific cases where exemption from call charges is granted, by arrangement.
♦	0870 - no longer subject to revenue sharing, but still commonly charged at a premium. This range is currently in a complete mess, it is however now only rarely used.
♦	084 (0843, 0844, 0845) - the caller generally subsidises the recipient's costs. This is rarely extended to a cashback arrangement with the recipient's telephone service provider however the subsidy is always present. Certain perversities with BT, as a result of legacy regulation that will shortly be withdrawn, can cause the effect on the caller to be concealed.
♦	0871-3 / 070 / 09 - classified as for use for "Premium Rate Services". The recipient draws income, as well as subsidy at the expense of the caller. Regulation by PhonePay Plus demands some (inadequate) declaration of call cost.
♦	03 - cost neutral. Calls to all 03 numbers are (by regulation, and as seen in practice) charged on the same basis as calls to geographic numbers. The recipient receives no subsidy towards the cost of the features deployed. The 030 block of numbers is reserved for use by public bodies and charities; the 034 and 037 blocks are reserved for migration from the equivalent 084 and 087 numbers.

IT IS PERFECTLY ACCEPTABLE TO USE 03 NUMBERS -
where there is some clear benefit to using a non-geographic number.

Following an earlier wide-ranging consultation, Ofcom will shortly be presenting firm proposals to address many aspects of the use of non-geographic numbers.

Application of a premium charge

Presenting the issue of additional cost as though it only relates to those with certain types of telephone service contracts totally misses the point. It is inevitable that where the telephone company originating the call incurs the extra cost of revenue sharing, this cost will be passed on to the caller. The present perversity with BT should not be allowed to distort the general point, especially as this will shortly come to an end.

I personally have no issue with a private business raising charges on customers, so long as this is done openly and honestly. The Ofcom proposals will address the fact that the level of the "Service Charge" is presently totally concealed with 084 numbers and inadequately presented with PRS numbers.

I believe that this forthcoming requirement for proper declaration of a charge will address the impropriety of the recipient levying a supplementary charge for sales and customer service calls, on top of the call cost imposed by the caller's provider to its own benefit. If the charge is declared, consumers and relevant regulators will be able to determine whether or not it is appropriate in a particular context.

The Land Registry is a self-funded public body which meets some of its costs through premium charges levied on users of some of its services provided by telephone. I can see no argument for it to be prohibited from raising charges for use of its telephone services whilst that use is taking place, given that the charge is properly declared. The proposed Ofcom regime would provide a ready opportunity for this to be done with full propriety.

Apart from this, and perhaps some other cases of self-funded public bodies, there can be no justification for taxation-funded public bodies using 084 or Premium Rate Service numbers. The imposition of a "Service Charge" on the service user (as it will shortly be known) cannot be sustained. The level of subsidy obtained is but a tiny fraction of the cost of handling telephone enquiries, whereas the cost to the caller is both improper and often significant.

The EDM

The failure of the EDM to make reference to 03 numbers seriously undermines its value. This enables (non-financial) arguments in favour of use of non-geographic numbers to be set against it. If, as is suggested, the only issue is about the cost of calling, there is no need to invite discussion about the (undoubted) merits of non-geographic numbers as against geographic numbers.

There are many issues raised by the idea of offering geographic numbers as alternatives. These would commonly not provide the same service, unless significant additional costs were to be incurred. The present complexity of telephone tariffs would make it extremely difficult to advise callers which number to choose (many would be unaware of which was best). The cost of updating publications and then carrying two telephone numbers, not to mention the resulting confusion, provides a strong argument for not following this approach.

The geographic vs. non-geographic argument is pointless and draws in wholly irrelevant considerations.

(The first amendment fails to note the very special arrangement made by DWP to fund calls to its 0800 numbers from mobiles. Some other 080 numbers used by public bodies are exempted from charge by the mobile companies.)

My proposal

I HAVE LONG BEEN PROPOSING THAT THE EQUIVALENT 034 NUMBERS BE IMMEDIATELY OFFERED AS ALTERNATIVES BY ALL PUBLIC BODIES USING 084.

I see this as a practical, low-cost interim solution, as part of a general move to 03 numbers. The advantage of the "equivalence" approach is that it need only be declared as a general rule - existing references to 084 numbers can remain for the time being.

Once swapping the second digit "8" for a "3" were to become generally recognised as a proper principle, those who failed to follow it would immediately come under direct and simple pressure to fall in line.

(If a body does not need a non-geographic number - it must simply be abandoned immediately!)

This proposal is specifically relevant to NHS Direct, where the cost and confusion of a complete number change would not be appropriate, given that 0845 4647 may have less than 2 years of operations remaining. As 0345 4647 has already been configured and stands ready for use (currently in test mode), there is no reason why it cannot be switched on immediately. It is a disgrace that the NHS Direct NHS Trust was granted total exemption from Directions which apply to other NHS bodies, as this “approved” example of use of a 0845 number makes compliance very difficult to achieve.

Conclusion

I much urge your support for my proposal. There is no good reason why the Cabinet Office could not be persuaded to adopt it as recommended or mandated policy very swiftly. I was able to make some progress in instigating publication of a Clarification Statement in 2009, however this work was never carried through.

If the government is seen to be dragging its feet when the Ofcom proposals are published later this year it will be highly embarrassing for the government. Furthermore, I am concerned that this threat of embarrassment may be used to put pressure on Ofcom to hold back from much needed action that will affect other sectors and issues.

Do please contact me for further information and briefing on this matter.