NGCS Commercial and Technical Working Group – 11th August 2011, 2.00pm Ofcom
Meeting notes & Actions
- Sean Hartley, BT Wholesale (Chair)
- Colin Rochester, BT Wholesale
- Laurent Pariat, C&W Worldwide
- Paul Reid, C&W Worldwide
- Paul Rothsbottom, C&W Worldwide
- Elizabeth Gannon, Ofcom
- Peter Farmer, Gamma
- Sandra Reid, Virgin Media
- Steve McGeary, Via-Vox
- Andy Martin, IV Response
- Don Wilson, Vodafone
- Tony Harrison, Vodafone
- Sarah Godfrey, 4D Interactive
- Grant Forsyth, Sky
- Mike Barford, The Number UK
- Simon Grossman, The Number UK
- Alistair Dixon, Colt
- Richard Anderson, Colt
- Kushal Sureen, Three (on the phone)
- Matthew Peake, Verizon (on the phone)
- Robin Vernon, O2 (on the phone)
- Andrew Wileman, Virgin Media (on the phone)
- Lesa Green, Kcom (on the phone)
Technical Working Group
Discussion of technical questions
Sean noted that the list of technical questions had been circulated at the end of the last commercial group meeting. He noted that Ofcom had prepared a slide on the questions. Elizabeth Gannon (Ofcom) introduced the slide and noted that its intention was to try and group the questions into topic areas and provide some high level principles for answering the questions, for example that existing commercial arrangements should stay in place unless there was a reason for change, and that the aim should always be for simplification where possible.
Colin Rochester (BT) noted that if Ofcom wanted to have an idea of the potential costs of changes to the existing system, the relevance of the listed questions should be considered. He noted that peripheral small issues that could over be overlooked often influenced the costs of billing systems development. He said that if too many assumptions were made about these issues, which later turned out to be incorrect when it came to implementing, then the assessment of costs would not be accurate.
Pete Farmer (Gamma) suggested that much of the additional costs were caused by out of date billing systems and he did not consider that Ofcoms assessment of costs should be affected by those systems.
Colin Rochester (BT) highlighted the first question and noted that the rules around rounding for example were important, because different rounding rules for access and service charges would increase the complexity of billing systems.
Mike Barford (118118) suggested it would be better if a smaller group could be formed to look at each of the issues highlighted in the list of questions and work out whether the questions were relevant. He noted there was a danger that each group member was going to come up with their own answer, but that nevertheless, it was important that Ofcom had full information in order to make its decision.
There was some discussion about the first two questions in the list, related to what would be presented on retail bills. Paul Reid (C&W) noted that they needed a clear indication of what has to be presented on bills and they could then cost the changes on that basis. Grant Forysth (Sky) noted that it was not just a question of feasibility, but also a weighing up of costs and benefits. Mani Manimohan (Ofcom) noted that ideally Ofcoms preference was for the AC and the SC to be presented separately, because as discussed in Ofcoms Consultation it was important that consumers could distinguish between those elements of the charge. However, Ofcom recognised that this requirement might lead to additional costs and therefore was open to exploring other options such as presenting aggregated access and service charges. Therefore a comparison of the two different options in terms of costs would be useful.
Alistair Dixon (Colt) noted that his preference was that the disaggregation of the charges should not be necessary for business customers. Colin Rochester (BT) noted that the answer to the first two questions was therefore that two different options should be considered, as well as an option that business calls did not have to disaggregate.
Alistair Dixon (Colt) noted that he had particular concerns about how number portability would work under any new system (questions 48-50 in the list (Draft C)). Sean Hartley noted this had been discussed at the last commercial group meeting and it had been agreed that as long as the SC was the same within the 10k number blocks (or 100k depending on how they were allocated by Ofcom) then no new issues with porting differentials should not arise as a result of the proposed changes to the NGCS. However, he conceded that the aim was not to build in existing problems into the new system, although it had been recognised that the wider issue of number portability was outside the scope of the current NGCS review.
Freephone origination charge
Don Wilson (Vodafone) raised a query on questions 40-41 (in Draft C of the technical questions). He considered that these questions potentially overcomplicated this issue as they considered that the use of a mobile CLI would be sufficient to identify mobile calls. C&W agreed and noted that network CLIs were always passed between the operators. Colin Rochester suggested, however, that a CLI was not passed for all calls.
Colin also noted that a definition of what a mobile service was would be needed. Don Wilson agreed and said this was a separate policy question for Ofcom and was likely to overlap with work in Ofcoms MCT statement.
Publication of Service Charges (by the TCP)
Colin Rochester (BT) noted that it would be useful to have Ofcoms view on question 30 in particular, which related to what the obligations would be on TCPs for publishing SCs. Elizabeth Gannon (Ofcom) questioned whether this was an issue for Ofcom or for industry to agree amongst itself. Colin noted that in Ofcoms recent statement on fixed termination rates there was an obligation for those to be published.
It was agreed in the group that a single source of information on SCs would be more appropriate than each TCP holding that information. Grant Forsyth (Sky) noted that a particular party could be nominated to keep that information and that there needed to be a Carrier Price List type format, although it shouldnt be presumed that that would continue to be BT. Sky also noted that there would need to be an obligation on the TCP to keep informed whoever that single source was for any changes in SC prices.
Don Wilson (Vodafone) agreed that TCPs publishing SCs on their websites was not going to be helpful and instead TCPs should be responsible for notifying a central source in a consistent format. Colin Rochester (BT) queried whether the central source would be able to charge a fee for holding that information.
Pete Farmer (Gamma) suggested that the NTNP could hold that information and if the individual chargebands were set in the NTNP then it would act as the central point of information. Paul Rothsbottom (C&W) noted that would require TCPs to apply to Ofcom when they wanted to change a price, which did not seem an appropraite approach.
Colin Rochester (BT) asked Ofcom to provide a view on this question, as well as Q11 (relating to the maximum service charge price). Elizabeth Gannon (Ofcom) confirmed that she would take that away as an action point, although noted that there might not be a single answer to the question and instead the group might have to consider different options.
Colin Rochester (BT) noted that it would also be helpful to have Ofcoms view on Q28, which queried whether PCAs would be required. Elizabeth Gannon (Ofcom) noted that under Ofcoms current proposals PCAs would not be required, however, they were be considered as part of the issue around raising the higher rate PRS tariff. She said that this issue would not be part of the next consultation, however, and would therefore be considered separately as a stand-alone consultation. Therefore for the purposes of this work it could be assumed that PCAs were not required.
Technical questions next steps
It was noted that the list of questions could potentially evolve into a list of assumptions. Grant Forsyth (Sky) noted that just as useful as a list of questions could be a list of presumptions.
Colin Rochester (BT) noted that at this stage, the aim was to identify whether all of the questions highlighted were relevant and necessary.
It was agreed that Elizabeth Gannon (Ofcom) should circulate the list of questions in order to elicit specific comments from group members. Elizabeth confirmed that the next technical meeting would be on September 8th and she would request comments ahead of that. It was decided that the relevant technical questions would be agreed at that meeting.
Dates of next Technical WG meetings: 8 September 2.00pm, Ofcom 22 September 10am, Ofcom (TBC)
Commercial Working Group
Minutes of last meeting and action points
Sean highlighted the minutes of the last meeting, which were agreed. He also noted the issues register had been circulated and asked the group, and Ofcom, to submit any comments on that ahead of the next meeting.
AIT and Fraud
Sean noted this item had been included in the list of potential issues to discuss. He suggested that the general process could still operate in the same way under an unbundled approach, although there might be some elements of the SIA which would need amending (in particular Annex E).
Don Wilson (Vodafone) suggested that the issue of fraud might arise if TCPs/SPs were able to change SCs at short notice. He noted that a notice period would be needed for price changes.
Pete Farmer (Gamma) noted that under the existing regulations there was already a 56 day notice period to BT, and then 28 days notice to industry. He suggested that the biggest risk was around higher rate PRS, and also with 070/076. Elizabeth Gannon (Ofcom) confirmed that higher rate PRS and Ofcoms proposals around 070/076 were not going to be within the scope of the next consultation document but would be considered separately at a slightly later stage.
Sean noted that the issue for discussion here was purely whether there were any issues around the structure of the AC (e.g. ppm, ppc, inclusion of set-up fees etc), rather than the level it should be set at.
Andy Martin (IV Response) noted that the more variants in the structure of the charge, the less transparency to consumers.Elizabeth Gannon (Ofcom) noted that Ofcoms preference in the December Consultation was that the AC should be a ppm charge only, for that reason.
Paul Reid (C&W) noted that the principle of simplicity could still be applied if there was a potential to have a pence per call charge at the same rate as the ppm charge. He suggested this could be charged on the same basis as the SC, i.e. if the SC was ppc then the AC could be also.
Sean noted that the spreadsheet of chargebands that had been circulated was a proposal put together by Andy Martin (IV Response) on the potential number of SC chargebands under an unbundled approach (40). Andy noted that when the options for ppm, ppc and ppm plus ppc variants were included the number of chargebands could be up to 120, although potentially those three variants would not be required under all chargebands.
Elizabeth Gannon (Ofcom) introduced her slides which summarised the data on the most commonly used chargebands. She noted that within the 0844/0871, G6 and G7 were by far the most common price point. Around 97% of traffic was within ten chargebands. For PRS, the P0, P7 and P10 chargebands were most common, with around 95% of traffic within twenty chargebands.
Don Wilson (Vodafone) noted that the request for additional chargebands could be influenced by any additional transparency requirements in the new regime, i.e. if SPs had to publish their SCs, they were less likely to want to change that in future (because it would involve changing all their advertising materials).
Andy Martin (IV Response) noted that SPs might be merging towards the higher price points because under the current regime they were not able to control the retail price to consumers and therefore considered they might as well pick the highest point. He noted that if SPs were able to exercise more control over the retail price then they might choose a different price point.
Paul Reid (C&W) noted if the unbundled approach was implemented, there would need to be some kind of mapping exercise which linked the existing chargebands with the new SC price points. He noted that it would be easier to communicate with SPs on the price changes if they could point to a mapping exercise by Ofcom and a default SC that they would be moved to (and if the SP did not want that price point they would have to move to a different number range). He noted that if individual TCPs decided where the G6 chargeband (for example) sat within the new price points then that would lead to a world of bespoke service charges.
Sean Hartley (BT) questioned whether that was a feasible approach contractually. Several group members suggested that any statement by Ofcom should supercede any contractual requirements.
Pete Farmer (Gamma) noted that there was still a question of how the changes would be communicated to smaller TCPs and SPs.
Andy Martin (IV Response) noted that the number range certificates either included the chargebands or the charge for the number and therefore there would need to be consultations by Ofcom on changing those as well.
Agenda for next Commercial working group
It was noted that the issue of changes to Service Charges had not yet been covered in the group discussion and should be part of the next Commercial Working group. Pete Farmer (Gamma) noted that it would be useful to have some form of guidelines as to how often DQ providers in particular would be able to change their SCs.
Sean Hartley noted that the intention was to go through the issues register which had been circulated and confirm whether the description of the issues appropriately represented the discussions that had been had.
Pete Farmer (Gamma) asked whether Ofcom would be able to bring a representative from its investigations team that was dealing with the 08x CAT judgment to the next NGCS Focus Group (on 1 September) to talk about the outcome. Elizabeth Gannon (Ofcom) said she would take that away as an action point.
Dates of next Commercial WG meetings: 1 September, 2.00pm, Ofcom 15 September, 2.00pm, Ofcom
28 September, 2.00pm, Ofcom
- Elizabeth Gannon (Ofcom) to circulate technical questions again and specifically ask for comments from group members on whether all questions were relevant to an assessment of costs of changing billing systems to support Ofcoms proposals in the Consultation.
- Elizabeth Gannon (Ofcom) to confirm Ofcoms view on Q11 and Q30 at next technical meeting.
- Elizabeth Gannon (Ofcom) to confirm whether a representative of Ofcoms team dealing with the outcome of the 08x judgment would be able to attend the NGCS Focus Group on 1 September.