I am making progress, and it is worth explaining some of the misunderstandings. Having read the General Conditions more and discussed more with OFCOM I can see some sense in their replies and some misunderstanding on my part.
However, it seems a slight mess.
They seem to only want to regulate consumer charges for these 084, 087, 09 & 118 calls, but they have made definitions that implicitly regulate inter CP charges in a subtle way.
They define that the retail service charge must be the same for all retailers. This was my original assumption and the big issue being how we find what he service charge is.
However, reading more, they define "service charge" as what we pay to the ongoing carriers.
Now, these two definitions can only be both correct if the ongoing carriers charge us exactly the "service charge" defined for each range as set by the range holder.
In fact, neither carrier does that - they both pay BT the standard service charge for each range and hence charge us that plus a small amount to cover their costs. This means that the "service charge" as defined by OFCOM is not the same for all retailers.
It is a cack-handed way to impose rules on carriers charging carriers - by making two definitions that are only non contradictory if the CPs charge each other in a certain way.
Now, this puts the carriers we use on the spot - they will have to charge us the "standard" service charge for these numbers, but they then need to negotiate a discount on what they pay BT to make their own profit on such numbers. BT may not be keen on that, but I see no reason why that should not be the case.
The other odd thing is that I, as a consumer, assumed the service charge went to the end telco, or even the operator of the number, and the access charge is what paid to get the call there. This is not the case. The way OFCOM define it the access charge only pays the originating telco. The cost of getting the call on to the end terminating telco is all taken out of the service charge. So if you use a premium rate number to pay a charity at say "£1/call plus telco access charge", that is not £1 going to the charity even though you may be paying hugely over the top of a "normal" call for the access charge element on top.
What a mess. Waiting on latest OFCOM response.
Update: Why is the BT carrier price list not being updated? Well, from what I just heard today, BT are taking the sensible view of "why the hell should we be the ones to compile this list of charges" and arguing with OFCOM too. That is hearsay, but interesting and plausible.
Update: Getting resistance from carriers, and no reply from OFCOM - this needs sorting.
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The way that we see it working is even more complicated. We are a telco much like yourselves but we also have our own BT interconnects so we see what happens at the other end of the chain as well.
ReplyDeleteSo assume that we send the call via carrier A which then sends it through to BT who forward it on via a BT interconnect to carrier C.
Carrier A pays BT the service charge.
BT invoice carrier C for the transit charge to carry the call over their network.
Carrier A bills us for the service charge plus an access charge.
We bill the customer for the service charge and our access charge which is calculated to include the allowance for carrier A's access charge.
It is carrier A applying an access charge to another carrier which does not seem to meet the OFCOM regulation.
Indeed, it is the access charge to another carrier which does not fit OFCOM rules. They define access charge *only* as the final retail CP access charge. So we have an issue with carriers trying to charge us something other than the service charge... All fun.
DeleteBut the rules only apply to consumers don't they - as such you paying another carrier for a call is a B2B transaction so the rules don't apply and the carrier can charge what they like, just as you could if the end customer is a business...
DeleteYes and no - the rules define the service charge as being what I pay the next carrier, and then define that the service charge is a fixed charge regardless of retail CP, so those definitions make it a rule that the wholesale/next CP charge me as the final retail CP the defined service charge... The carriers we are talking to are a tad concerned about this!
DeleteBut at that point wouldn't you have to somehow tell the carrier if the end caller was a consumer (so the rules applied), or a business so they don't - I suppose could be done with e.g. a SIP header but still crazy...
DeleteAlex, absolutely - I don't make these crazy rules.
DeleteAnd worse! If my caller is retail they have to charge the SC. If my caller is business they could change me more than SC. If my caller is another CP and their caller is retail I have to charge my caller SC, and so I would expect to pay less than SC. I could have all three types of customer.
DeleteAre the intermediate carriers even bound by the Ofcom GCs given they're not serving any end users?
ReplyDeleteDoes A&A route calls to 084, 087, 09 and 118 numbers that use Service Charge price points SC081 to SC100?
ReplyDeleteSome, non premium, yes, not sure specifically of SC081 or SC100 though.
DeleteBoth the A&A price list and prefix list make no mention of any of the price points from SC080 to SC100.
DeleteThe additional twenty price points SC081 to SC100 came into effect on 1 July 2016, exactly a year after the introduction of unbundled call pricing for 084, 087, 09 and 118 numbers.
Although some of the price points apply only to 09 prefixes and/or 118 numbers, several are also used on various 084 and/or 087 prefixes.
AFAIK OFCOM never solved the issue of actually finding a definitive list or prices and codes. So what did they expect?
DeleteThe FCS-sponsored list at http://checkit.uboss.com/ appears to be an attempt to fix that issue.
DeleteAnd that is an official source?
DeleteI guess it's as official as anything else out there. It tallies with what BT lists.
DeleteThis blog details the additional price points added on 1 July 2016:
http://plumcom.blogspot.co.uk/2016/07/new-non-geographic-service-charges.html
Well quite - with an OFCOM rule to get it right, if they have an error and someone relies on them, and OFCOM fines someone for making a mistake, who pays the fine. This is why OFCOM need to make an OFFICIAL source for the data.
DeleteVirgin Media also appear to be unaware of the additional price points. Their detailed tariff list makes no mention of them.
DeleteNow that you are aware that twenty additional price points were added a year ago, on 1 July 2016, will you be updating the A&A price list to match?
ReplyDeleteNumerous number ranges have changed to one of the new price points since that time.
I'll get someone on to that - but AFAIk there is still no definitive reference one can rely on for this data.
Delete