Introduction

The Federation of Communication Services represents companies which provide professional communications solutions to (primarily) business users.  Our members deliver telecommunications services via mobile and fixed line telephony networks, broadband, satellite, wi-fi and business radio.

Our members’ customers range from SMEs, home-workers and micro-businesses up to the very largest national and international private enterprises and public-sector users.  FCS is the largest trade organisation in the professional communications arena in the UK, representing the interests of around 300 businesses who supply B2B services nationwide

FCS Response

We welcome the opportunity to respond to Ofcom’s latest consultation on implementing the new European Electronic Communications Code – and specifically the proposed changes to the General Conditions, the Metering and Billing Direction and the Numbering Plan. Broadly, we support all the proposed changes. 

However, we have taken this opportunity to reiterate a concern regarding the use and definition of the term VoiP Outbound Call Service (and its consequent impact on the scope of applicability of General Condition A3.3) which we first raised in our response to the December 2019 consultation. As currently defined this definition specifically excludes VoiP services which can receive calls. This will have the effect of removing services which allow the customer to make and receive calls from the scope of this requirement which seems illogical and potentially harmful to end users.

Consultation Questions

Question 1: Do you agree with our proposed amendments to terminology/definitions in the GCs set out in paragraphs 15.7-15.45 above? 

We broadly agree with the proposed amendments. We are pleased that Ofcom is effectively replacing the term “Small Business Customer” across all General Conditions and related documents which, in our view ,will make the GCs easier for CPs to interpret and use.

As noted above, we do have a concern about the use of the term VoIP Outbound Call Service in General Condition A.3.3. As currently defined this definition specifically excludes VoiP services which receive calls. This will have the effect of removing services which allow the customer to make and receive calls from the scope of this requirement – which seems both illogical and potentially harmful to end users, who may be unaware of the consequences of losses of power or broadband connectivity as a result

Question 2: Do you agree with the consequential changes we are proposing to make to the Metering and Billing Direction?  

We agree. The proposed changes will make no effective change to the applicability of the regulation.

Question 3: Do you agree with the consequential changes we are proposing to make  to the National Telephone Numbering Plan? 

We agree. The proposed changes will make no change to the applicability of the regulation.

Question 4: Do you have any comments on our proposed timing for implementing these changes? 

The proposed timing of implementation seems logical.

Question 5: Do you agree with the modifications we are proposing to make to General Conditions A1 (general network access and interconnection obligations) and B4 (access to numbers or services) in light of the end of the transition period? 

We agree. The proposed changes are necessary to ensure that the regulation continues to apply in the UK

Question 6: Do you agree with the modification we are proposing to make to the Numbering Plan in light of the end of the transition period? 

We agree. The proposed changes are necessary to ensure that the regulation continues to apply in the UK

FCS hopes that this brief response is helpful to Ofcom in its considerations and we would be happy to discuss further.