Please complete this form in full and return to 080review@ofcom.org.uk.
| Consultation title | Free-to-Caller Wholesale Regulation Review |
| Full name | Stefanie Norman |
| Contact phone number | 07917 020368 |
| Representing (delete as appropriate) | Organisation |
| Organisation name | Federation of Communication Services |
| Email address | snorman@fcs.org.uk |
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 name / Organisation name / Whole response / Part of the response (you will need to indicate which question re sponses are confidential) |
| 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 4.1: Do you agree with our provisional assessment of the results of imposing the access conditions? Please set out your reasons and sup porting evidence for your response. |
Confidential? – N Yes, in part. There is though one area where Ofcom’s as sertions might be flawed. Ofcom states that the lack of disputes indicate that the access conditions have achieved their aim and that pricing levels are therefore “fair and reasonable”. A lack of formal disputes does not in itself indicate this. Ofcom rightly recognises potential power imbalances within the market, and it is difficult for smaller providers to challenge the prevailing prices/conditions, so they are unlikely to initiate a dispute. The FCS believes that there should be a review of the pricing to meet Ofcom’s objective of ensuring that origination payments are fair and reasonable across the market. The current pricing levels were set and defined at a time when there was a different landscape, and some FCS members believe that there is no longer justification for such a large differential between fixed and mobile origination payments. Ofcom states that they do not believe it is proportionate to review costs. The FCS disagrees with this position and believes that Ofcom should require Mobile Network Operators to confirm the cost of mobile origination for these calls. Ofcom states that, when taking into account inflation, prices have reduced across the period. However, it is also clear that the number of calls from mobile numbers, which have higher originating charges, has increased dramatically and this needs to be factored into the calcu lation. |
| Question 4.2: Do you agree with our provisional conclusion that it would be necessary to maintain the access con ditions to avoid the potential conse quences of market failures set out in Section 4? Please set out your reasons and supporting evidence for your response. |
Confidential? – N Yes. The FCS supports Ofcom’s position. It is important that customers have trust in numbers, and we agree that 080/116 calls should be free to both consumer and business customers. We agree that access conditions are the right way to regulate the wholesale element and were pleased to see that Ofcom acknowledged the potential power imbalance in the market that could cause issues for the complex supply chain. The number of operators subject to the access condi |
| Question 5.1: Do you agree with our proposed amendments to the access conditions in Section 5? Please provide reasons for your response and supporting evidence. |
Confidential? – N Yes, though please see our response to question 4.1 where we urge Ofcom to review costs of call origination. |
| Question A4.1: Do you agree with our assessment of the likely impact of our proposals? Please set out your reasons and supporting evidence for your response. |
Confidential? – N Yes, though please see our response to question 4.1 where we urge Ofcom to review costs of call origination. |
| Question A4.2: Do you agree with our assessment of the potential impacts on specific groups of persons? Please set out your reasons and supporting evidence for your response. |
Confidential? – N No comment |
| Question A4.3: Do you agree with our assessment of the potential impacts on the Welsh language? Please set out your reasons and supporting evidence for your response. |
Confidential? – N No comment |