Reasons to change telephone numbers

(a)   A shortage of numbers within existing codes is one, but far from the only, reason for the changes proposed by Oftel to telephone numbers (paragraph 19).


(b)  The inefficient allocation of numbers is an underlying cause of the dispute concerning changes to freephone numbers. We are concerned that Oftel has not pursued improvements by operators of the efficiency with which they allocate telephone numbers to end users as vigorously as they have inconvenient and costly changes to customers' numbers. Oftel must not be unduly swayed from putting customers' interests first by operators' claims that improving the efficiency of number use poses them with significant technological problems. We welcome the Director General's announcement that he will sit down with the operators to consider FUG's solution to the freephone numbering issue and recommend that he also discuss with them technical solutions to wasteful number use throughout the whole numbering scheme. If numbers were properly recognised as a scarce, national resource — and they should be — the telephone operators would be on a charge of grossly negligent husbandry (paragraphs 22 and 24).


(c)  We are concerned that, at a time when Oftel aim "to ensure...that numbers of different types give a broad indication of service/price wherever possible", the link between local dialling and local tariffing is being weakened, especially because we are unconvinced that the full implications of this innovation have been explained to, and accepted by, the businesses and consumers most affected. While we acknowledge that the national numbering scheme can give consumers information about the cost of their calls we recommend that Oftel do more, working with the telecommunications industry, to ensure that pricing information reaches consumers by other means (paragraphs 26 and 28).


(d)  Oftel has cited a number of consumer "needs" as reason to alter the National Numbering Scheme, which, in the case of the "need" for codes to provide pricing information and for standardised number lengths, are, at best, unproven by detailed research or consultation. We are disappointed that number changes are being proposed, and implemented, on the basis of unsubstantiated claims by Oftel, apparently backed by the statutory consumer organisation, of what customers want from telephone numbering. In the case of freephone numbers, unless research suggests that the costs to consumers of coping simultaneously with nine- and ten-digit numbers outweigh the costs invoved with changing those numbers, we recommend that efforts to standardise 0800 number lengths are ended (paragraph 29).


(e)  Although the numbering system did, previously, discriminate against operators other than BT wishing to offer freephone numbers to new customers, it does not appear to do so now. It appears to us, however, that one of the most significant barriers to competition in the numbering scheme is the control by BT of thousands of unused nine-digit freephone numbers (paragraphs 32 and 35).


(f)  Although we support efforts by Oftel to remove barriers to competition in the National Numbering Scheme, no compelling case for all 0500 numbers to be migrated into the 0800 range has yet been made. We question why, if both 0500 and 0808 codes do not provide a fully satisfactory basis for fair competition, 0500 numbers are being merged with the 0800 range but 0808 codes are to be retained and further 080X freephone codes are to be introduced in future. This situation is particularly puzzling given the number of unused 0800 freephone numbers retained by BT, to which we have already drawn attention (paragraphs 35 and 36).


(g)  We would strongly deprecate any attempt by Oftel to raise revenue at the expense of existing freephone customers, who would bear significant costs as a result of being forced to alter their freephone numbers (paragraph 38).


(h)  The National Numbering Scheme is an administrative arrangement, whose first aim should always be the protection of consumers' interests in respect of telephone numbering. Number changes should not be proposed purely for the sake of keeping the Scheme neat and tidy (paragraph 39).


(i)  We do not believe that Oftel has stated clearly the reasons for many of the number changes it has proposed; nor backed up many of its assertions about what customers want and need from the telephone numbering system; nor adequately considered alternatives to change. In particular:

• the shortage of numbers identified behind certain geographic codes, and behind the 0800 code, could be alleviated by the more efficient use of number blocks by operators. This option should have been explored exhaustively, and the results widely disseminated, before it was proposed that consumers would be required to change their telephone numbers to deal with this problem
• Oftel should not justify number changes by reference to customer needs, unless those needs have been comprehensively surveyed and the results subjected to public scrutiny
• we are totally unconvinced by Oftel's arguments for changing freephone numbers and have been left with the impression that its proposals are, in fact, a smokescreen for an attempt to create new golden numbers which Oftel can auction to firms
• we are concerned that some numbers are being changed in order to suit arbitrary administrative arrangements rather than because consumers are expected to benefit from the change (paragraph 40).

Cost-benefit analysis

(j)  We find it inexcusable that a cost-benefit analysis was not used by Oftel to assess the impact of its current proposals for changing telephone numbers. We recommend that, before Oftel implement any changes to freephone numbers, a full cost-benefit analysis of the changes is prepared and published (paragraphs 41 and 42).

Consultation

(k)  We note the claim of the Director General that Oftel has a good record of consultation, but we believe, in this instance, that Oftel has failed to consult adequately (paragraph 43).


(l)  We believe that Oftel's freephone numbering consultation exercise was badly flawed. The importance of freephone numbers to many firms and organisations, particularly as key elements of their marketing strategies, was not adequately recognised by Oftel. The consultation document, and subsequent comments on the freephone issue, suggested that Oftel was not interested in the views of respondents but, instead, wished for its own prefered option for change to be rubber-stamped. When FUG and the DMA first questioned the proposals for change, Oftel should have responded more quickly, including by meeting with them and discussing in detail their concerns and their alternative suggestions. We recommend that, with the help of the operators and relevant business groups, Oftel consult individually with freephone customers in order to develop a numbering policy satisfactory to all (paragraph 45).


(m)  We recommend that, when Oftel next proposes changes to geographic codes, residential and business consumers in each of the areas affected are directly consulted, including by means of telephone canvassing and focus groups (paragraph 46).

Publicising changes to mobile telephone numbers

(n)  We recommend that, as a matter of priority, Oftel work with telephone operators to improve consumers' knowledge of the impending changes to many mobile telephone numbers; and that consumers intending to buy analogue mobile telephones which do not accept ten-digit numbers are informed of this at the point of sale (paragraph 48).

Number Administration

(o)  We believe that telephone numbers are a national resource; income derived from them should be returned to the public purse. We recommend that Oftel, working with Ministers, bring forward legislative proposals to clarify the ownership of telephone numbers and to permit number charging and individual number allocations, once the costs and benefits of these proposals, and the objections raised to them, have been carefully assessed (paragraphs 49 and 52).

Overall conclusions

(p)  We expect Oftel to consider the conclusions we draw from this inquiry, as well as the responses it has received to its freephone consultation exercise, before proceeding further (paragraph 13).


(q)  We are satisfied with neither the content of the National Numbering Scheme, nor the process by which it was derived, nor the way in which customers have been consulted about its implementation. We recommend that, in the light of the conclusions and recommendations of this Committee, Oftel undertake a thorough and far-reaching review of the National Numbering Scheme and the way in which it is administered, so that, in future, the Scheme puts customers' interests first (paragraph 53).