Latest OfCom proposals - and THA's response

We can now announce Ofcom's longer-term proposals for UK telephone numbering are as follows:

a) 01 and 02 remain as prefixes for geographic numbers

b) 080- stays as freephone

c) Other 08- ranges are for chargeable and revenue-share(but not premium) services,segmented into charge-linked prefixes which increase up the range (e.g. 084- for up to 5p per minute, 087- for up to 10p per minute).Please note that this is the long-term view.In the interim,until proposal d) comes along, 0870 will lose revenue-share capacity from 2008 and will be charged at an equivalent rate to geographic numbers unless the operator puts a free-to-caller pre-announcement saying otherwise.

d) A new 03- range will be introduced for agencies wanting non-geographic numbers and a national presence but wanting customers to pay geographic rates and with no revenue share.

e) 09- will be reserved for premium rate numbers, including a suggestion of an 092 range for charity fund-raising.

THA has responded to very specific areas in the 65-point consultation. These are:

Question 8. Do you agree with Ofcom’s proposal to open a new ‘03’ number range for non-geographic, non-revenue sharing services?

THA supports the introduction of a new 03- range where revenue share is not permitted and call costs are linked to that of the geographic 01- and 02- numbers. However, confusion may arise during any transition period between one system and another, so it may be useful to consider systems that minimise disruption, such as in Option 3a (e.g. converting existing 0845 numbers to 0345 numbers for services that wish to migrate).

Question 9. How should the ‘03’ range be structured, in terms of tariffs and services?

Much of the current confusion about 084- and 087- numbers arises because the local and national cost distinctions do not apply to mobile networks and have almost disappeared for the majority of landline users whilst the associated terminology carried on in relation to non-geographic numbers.

In the longer term, it would seem sensible to abolish any distinctions between 'local' and 'national' call rates and to encourage providers to set their own standard rate for all numbers in the 01, 02 and 03 ranges. Whilst the 03 range may accommodate both 034- and 037-services migrated from their existing 084- or 087- numbers (Option 3a), these need not be charged differently (Option 3b).

We think it is important that linking 03- numbers to geographic rates must also apply to calls from mobiles and payphones. If there is no difference between calling an 020 and an 03- number from a fixed line network, there should also be no difference when calling from a mobile or payphone network, further avoiding any confusion.

We think it is also important to preserve the availability of call traffic statistics on 03- numbers to organisations that receive calls on these numbers, even if the organisation is not being charged to receive the call (as they currently are with 0800 or 0845 calls). Our members tell us that this data is crucial for monitoring and developing their services.

Question 10. How should the ‘08’ range be structured, in terms of tariffs and services?

THA agrees that the place of the 080- range in the numbering scheme should be retained. We feel that the public description 'freephone' is misleading as, unlike in most other EU states, most UK mobile networks charge standard rates for calling most 'freephone' numbers. Through partnership work, THA has been able to ensure that these charges to some freephone helpline numbers are waived by some mobile networks - this not only increases accessibility but also adds confidentiality as the calls are not itemised on paper bills. However,THA recognises that these services are a very small proportion of 0800/0808 numbers. In a context where an increasing proportion of calls are made from mobiles, we question the longer-term use of the description 'freephone' as long as the mobile networks charge users for calling any of these services.

We think the proposal to have increased prices as you move higher up the 08- number range is sensible. We suggest that this gradation should also be reflected in payphone pricing structures. Many helplines operate services on 0845 numbers that may be called from payphones by users in vulnerable situations, but at present there is no distinction in charges between calling an 0845 and an 0870 number from a BT payphone, with a 10-minute call costing £1.20. Current payphone interiors do not display charges for 0845 calls, nor are these identified in a pre-announcement. THA recognises the additional cost of maintaining the payphone network but feels the current charges are excessive.

Question 11. Which broad approach should Ofcom take to structuring the ‘09’ range, and if a re-structured ‘09’ range is preferred how would you arrange the different types of ‘09’ services (e.g., according to price per minute, price per call, inclusion of adult content)?

THA would like to respond only to a specific proposal made by Ofcom for a fundraising range such as 092. This is similar to a suggestion we made for the NTS consultation. We proposed a 'give-as-you-talk' number range that is specific for charities as this would allow some organisations to provide services that would otherwise be beyond their means, as long as a free-to-caller pre-announcement would indicate the costs and explain that these costs were contributing to the good cause concerned. We therefore welcome Ofcom's proposal.

We have had feedback from our members, however, that to use the a sub-range within 09 to do this may lead charities to be perceived as falling into the same category as 'premium' or 'adult' services, which may give rise to public distrust.

We think it would be more appropriate to open up a new sub-range within 08-, such as 081-. THA would be well-placed to have an involvement with Ofcom in co-ordinating such a sub-range in the same way as we have done with the 0808 80- range.

We also think it may be worth exploring differential number ranges for SMS shortcodes that link back to the voice service number ranges. For example, if 092 were used for charity voice services, then a number range 92xxx could be used for charity SMS services

If you have any questions about Ofcom's proposals and/or THA's response, contact Mark McLean, Senior Consultant, at mark.mclean@helplines.org.uk

Updated January 2007 by Marc Gillespie