On behalf of its members the FCS has urged Ofcom specifically not to change the current 0870 charging regime (to national rates) as the consequential loss in revenue will cause some UK businesses to fail. Furthermore the FCS maintains that the Ofcom research prompting the proposed changes to NTS and premium-rate calls is incomplete, and should be revisited once a broader Numbering Review (along the lines of the recently completed Telecoms Strategic Review) is over.
Jacqui Brookes CEO of the FCS said, "In considering the findings of Ofcom's research, we do not believe that such consumer harm which would justify the proposed end to revenue sharing for 0870 has been fully demonstrated. Neither do we feel that proper account has been taken of the benefits associated with intelligent numbers and how these would be funded if revenue sharing is removed."
Codes of Practice
The FCS also maintains that further codes of practice, which are proposed to improve customer information on premium rate and number translation services, will be a duplication for many of the smaller service providers and resellers concerned.
In its responses the FCS suggests that relatively minor changes to existing Ofcom guidelines, for the provision of customer codes of practice for handling complaints and resolving disputes, will fully meet Ofcom's objectives and serve the public better.
Jacqui Brookes continued, "No one disputes that improving the information available and value to users of these services is important but most OCPs (Originating Communications Providers) are not big telecommunications operations but small innovative businesses providing useful telecoms services. We recommend that the most efficient solution for providers and their customers is not to set up a new code of practice regime but to adapt existing codes to cater for information provision on premium rate and number translation services."
On behalf of its member groups ACSP (Association of Communication Services Providers) and FSPA (Fixed Service Providers Association), The FCS has offered to meet Ofcom to explain how Communications' Providers existing code of practice for consumer and complaints could be modified to meet Ofcom's stated objectives.