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FCS Response on Revenue Sharing

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Please complete this form in full and return to 080review@ofcom.org.uk.

Consultation title Future of telephone numbers:
Further consultation on revenue sharing, including proposed modifications to the National Telephone Numbering Plan
Full name
Contact phone number
Representing (delete as appropriate) Organisation
Organisation name Federation of Communication Services
Email address

Confidentiality

We ask for your contact details along with your response so that we can engage with you on this
consultation. For further information about how Ofcom handles your personal information and your
corresponding rights, see Ofcom’s General Privacy Statement.

Your details: We will keep your contact number and email address confidential. Is there anything else you want to keep confidential? Delete as appropriate. Nothing
Your response: Please indicate how much of your response you want to keep confidential. Delete as appropriate. None
For confidential responses, can Ofcom publish a reference to the contents of your response? Yes

Your response

Question 3.1

Do you agree with our proposals to prohibit direct and indirect revenue sharing with called parties (end-users) on the category 1 number ranges, including UK geographic numbers? 

Confidential? – N

Yes. The FCS welcomes clarity in this area and supports Ofcom’s aim of removing potential abuse of revenue sharing which in turn could undermine inclusive bundles.  

Question 3.2 

Do you agree with our proposals to prohibit direct and indirect revenue sharing with only calling parties on the category 2 number ranges, namely 084 and 087 numbers. Please provide reasons for your view and any relevant evidence.

Confidential? –N

Yes. The FCS welcomes clarity in this area and supports Ofcom’s aim of removing potential abuse of revenue sharing which in turn could undermine inclusive bundles.  

The FCS also believes that Ofcom should take the opportunity to review the fees on 084 087 and 09 ranges.  There are many examples of extreme bill shock when numbers are accidentally called and this can undermine confidence in the industry.

Question 3.3

  1. Do you consider that there is a need to introduce revenue sharing rules for UK 07 mobile phone calls?
  2. Do you have any view on the appropriateness or benefits of applying such rules also to UK 07 SMS/MMS text and media messages, including to remove a possible incentive for misuse or artificial generation of text message traffic? 
  3. Do you have any views on the impact of such a measure on legitimate SMS/MMS-based services?
  4. Do you have any views on whether there would be an increased risk of revenue sharing on the 07 range in light of the other proposals set out in this consultation?

Confidential? –N 

The FCS believes that further work is needed to understand the impact if changes are made in the 07 ranges.  There may be unintended consequences and the FCS supports further review in this area.

Question 3.4 

Do you agree with our proposed approach to implementation in giving six months after the publication of our final decision before our new rules come into force?

Confidential? – N

The FCS agrees that six months seems a reasonable timescale to implement the changes proposed.

Question 4.1 

Confidential? – N
Do you agree with our proposal to amend the Numbering Plan to remove the 082 number range?

Yes

 

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