Ofcom shows why public service providers must cease using 0845 telephone numbers, initially providing 0345 alternatives

Some interesting figures emerge from the Ofcom Communications Market Report 2011 - published on 4 August 2011. See Conclusion.

It is well known that, due to special regulations which apply only to it alone, BT is able to offer calls to 0845 numbers without charging a premium over the cost of an ordinary call. (BT does however charge a premium for 0845 calls made by those who subscribe to its "social tariff" - BT Basic.)

All call originating telephone companies have to pay on a revenue share of around 2p per minute to the call recipient on 0845 calls. Except when under the conditions which apply to BT, they may pass this on directly to the caller as a premium over the charge for a call to a geographic number. Most commonly they exclude these calls from discounted and call inclusive arrangements, thereby effectively applying a much greater premium. This is seen most clearly in the mobile market where intense competition causes the cost of calls to ordinary landline numbers to be kept very low. Calls to 0845 numbers from public payphones are charged at 30 times the rate of calls to ordinary numbers.

It is common to refer to BT Call Plans (which provide free calls to geographic and 0845 numbers) as if these applied to an overwhelming majority of callers, with the dismissive comment that "others may vary".

The figures shown below indicate the proportion of the population who are being dismissed in this way by public service providers.

I refer, in particular, to NHS Direct, HMRC and the various DWP agencies - all of whom primarily use 0845 numbers for enquiries.

Public service providers must consider the whole of the population they are serving, not some selective group, nor what may be (perhaps wrongly) thought to be a majority.

Those requiring "non-geographic" telephone numbers must move away from 0845 numbers and IMMEDIATELY OFFER THE 03 EQUIVALENT AS AN ALTERNATIVE.

Citizens who cannot afford a telephone, choose Virgin Media as their telephone provider, find a mobile phone best for their needs or subscribe to BT Basic, should not be required to suffer a premium charge for contacting public services providers.

The Cabinet Office sets the standard for all public services, through Guidance or Direction. I note that an e-petition to the Cabinet Office, on this very point, has just been started.

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I refer below to data from Section 5 - Telecoms and Networks of the Ofcom Communications Market Report 2011 - published on 4 August 2011.

Shares of non-business call origination

Calls from Landlines

The report notes on page 286 - "BT’s share of retail residential UK voice call volumes falls below 40%".

The most recent, and fully inclusive, figure (from Table 8 of the Telecommunications market data tables for the three months to March 2011) is 39.9%.

This means that significantly less than half of all residential landline calls are made under the specially regulated terms which apply only to BT.

Share of all Calls

By breaking down the respective totals for Business and Non-Business calls (see note) it may be seen that only 61.4% of non-business calls are made from landlines.

This shows a BT percentage of total call volumes at (39.9% x 61.4% =) 24.5%.

Less than a quarter of all non-business calls are made under the specially regulated terms which apply only to BT.

Household availability of landlines

Where important services are provided by telephone, one must have regard to those households which are unable to access these from a landline, and would therefore use a mobile or public payphone.

The Ofcom report publishes (on page 319) the proportions of households, categorised in various ways, which DO NOT have a landline telephone:

Total Population: 16%

Socio-economic groups DE: 27%

Households aged 16-24: 32%

Households aged 25-34: 23%

Over a quarter of households both of the socially disadvantaged, and of younger families, do not have a landline.

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Conclusion

BT may be the largest single provider of telephone call services, however its charges for calls to 084 numbers are wholly atypical due to unique regulation. Attempts to justify use of revenue sharing 084 numbers on the basis of BT charges are thereby fundamentally invalid.

The figures given above indicate the proportions of the population who are being subjected to improper premium charges when required to access pubic services through a 0845 number.

Where non-geographic numbers are required, 03 numbers offer the only equitable option - * Callers pay only the cost of a normal telephone call. * Providers meet the cost of their telephone operations, unsubsidised.

Migration to 03 numbers – initially parallel operation of the 0345 equivalent of every 0845 number, as an alternative – is not only vital, but conveniently and inexpensively achieved.

The Cabinet Office, which initially pressed for the introduction of 03 numbers, must sieze this issue as a way of demonstrating the government’s commitment to equity.