Friday, 3 May 2013

OFCOM stitch up

OFCOM have advised us today, for the first time, that, since 1st April, we are running up a bill for some of the telephone number blocks we have in some 30 area codes.

This is a slight shock - whist I try and keep a rough eye on some of the consultations it seems a document published on 27th March states a pilot scheme starts 1st April, yet instead of contacted anyone affected in advance they have left it until a month after it started to mention it directly.

It may surprise people to know that telephone number blocks don't have a cost, or didn't until now. Only telcos can get them, and we have a block in all area codes (which is a lot). The blocks are at least 1,000 numbers and some are 10,000.

OFCOM have decided to charge 10p/year/number for some 30 area codes. If this was just for numbers in use for which we had paying customers it might be viable, but it is not. It is for the whole block, and we can't get under 1,000 in each area. The 30 areas are a pilot, and I cannot see anything to stop OFCOM charging for the whole country if they want to screw up small telcos.

As a small telco getting even the smallest block for each area to provide a national service, that is about 650 area codes each costing at least £100/yea, so a minimum of £65,000/year for the smallest of telcos offering geographic numbers if OFCOM did all area codes. In practice, for many areas, we have 10,000 number blocks. So this is scary if it grows.

It is a pilot now, but we have to tell OFCOM what we think. If we allow the pilot to work it will grow to more areas and screw up a lot more telcos.

But this is a fundamental change!

Why? Well, until now, a telco had no reason to hand a block back. Even a telco that was sold or went bust could sell its blocks and paying customers to another telco. A block had some value if only because it was already allocated and saved applying for it.

Once blocks have an ongoing cost then they are a liability. This means, for the first time, it is commercial viable to hand blocks back to OFCOM. This is new. This is serious.

The main reason it is serious is the way numbers work, and especially ported numbers. If you have number from a small telco, even if ported away, if that block is handed back your number stops working. Simple as that. It is a stupid system, but as long as numbers were never handed back it sort of works. OFCOM are making a system that will mean numbers are handed back.

We are looking in to what to do. We may be giving customers 30 days notice on some numbers, and porting away will not help them. Any of the few customers that have ported away will simply find they stop working and nothing they can do.

One option is to stop doing VoIP at all. I hope it does not come to that.

This is somehow in the interests of consumers, is it? OFCOM?

11 comments:

  1. They published a document 27th March for a significant change starting 1st April?

    "It was on display in the bottom of a locked filing cabinet stuck in a disused lavatory with a sign on the door saying 'Beware of the Leopard'."

    I'm surprised that kind of notice period is legal.

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  2. Hang on...

    Correct me if I'm wrong... but what they're saying is that they're going to charge operators for any number they've ever allocated and want to keep allocated, even if said number has long been ported out to another operator?

    Bonkers!

    P.S. what happens to ported-in numbers if the subscriber cancels without porting them out further? Do the operators they ported to them generally reallocate them, or are they somehow repatriated, or are they generally just left to rot?

    Because if the former is the case, surely a company dropping a block could knock out a subscriber who has never even heard of them?

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    1. My understanding is that if/when a block is returned to OFCOM, all numbers in that block will stop working even if ported out. Until now blocks would not be handed back as they had no cost. OFCOM are creating a potentially big problem here, from what I can see.

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  3. Imagine the complaints they will have to deal with if / when larger telcos hand back numbers or ranges.

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  4. > One option is to stop doing VoIP at all.

    Oh crap, please don't - the 2nd reason I'm a customer was the VoIP

    The first, of course, was that you guys know which end of the soldering iron is hot (speaking metaphorically).

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  5. Hmm.. you pay 10p per number, but get a discount of 18p per number for every number ported out.

    So.. port half your number range to someone else eg. gr0mtel (I see nothing in the document that says they pay anything) and claim a 100% discount.

    BT will of course do this immediately (the document excludes companies within the same group but there's nothing stopping them doing a deal with 'Totally not BT Really (UK) inc.').

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    1. I am glad I am not the only one that read it like that, it does seem rather odd.

      If it is indeed what it looks like, a discount of 18p per ported-out number, then I may "port" lots of the numbers to AQL, which currently "host" them for us. As you say, nothing seems to be paid for ported in numbers. If we did that OFCOM would pay us, and AQL would get numbers they can use which have no cost.

      I'll have to have a chat with someone.

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  6. They definitely need to fix the "hand back a block and your customers and even ex-customers get cut off, with no remedy" - and the 180% discount on out-ported numbers must be a mistake of some sort. Is there any indication why Ofcom - not normally the fastest-moving bureaucracy out there - seem to be rushing this through now? Are these 30 areas under particular pressure?

    The sad thing is, there is a genuine reason for doing *something* - just like IPv4, it's a finite address space, and handing out big blocks freely regardless of need has obvious consequences - but this clearly isn't the right something.

    Perhaps small operators could be better accommodated by Ofcom self-allocating a single block in each area, then porting individual numbers to operators as and when they are needed. That, or making much smaller allocations (again like IPv4 - except thanks to porting, there aren't the same prefix-length constraints): having, say, 10 numbers "in stock" in all 650 areas would be £650/yr, which should be much more palatable for most businesses.. I seem to recall something similar being done in the 0800/0808 range for similar reasons.

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  7. It shouldn't be a surprise, Ofcom ran a consultation on this a year ago: http://recombu.com/digital/news/10p-per-year-charge-to-stop-phone-numbers-running-out_M10154.html

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    1. Something did need to be done, but the solution Ofcom have come up with is not going to solve the real problem, which is that due to legacy equipment in many of the larger telcos, there is a minimum block size of 1000 or 10000 in many areas.

      To the larger telcos, 10p/number is a minimal amount, particularly as they are likely to be using more of the numbers, but the small providers who have to take the larger blocks (due to no fault of their own - if they could they'd go for smaller), end up faced with a bill which in relation to the size of the company is a much bigger deal.

      IMO what they should have done is put in place charging on those telcos who have equipment which can't cope with smaller block sizes in order to encourage them to upgrade, rather than penalise the smaller providers. It would also be fair I suppose to put a charge on anybody who gets a subsequent block in an area code without having mostly utilised the first one.

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    2. I guess that's why they ran a consultation. That's a good point I think, I'm not sure if it's too late to respond or lodge some kind of appeal.

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