ICSTIS higher tariffs

BT Response dated 11 September 2003,  to the ICSTIS Consultation 'THE POSSIBLE INTRODUCTION OF PREMIUM RATE HIGHER TARIFFS OF £2.50 AND £5.00 PER MINUTE', June 2003

Download full response in PDF format.

Summary

• BT welcomes the opportunity to comment on ICSTIS’ proposals for the introduction of new higher premium rate services.

• BT believes that providers of electronic communication networks have a role to play in supporting regulatory bodies in the regulation of PRS.

• Consumer protection has to be central to the integrity of the service.

• BT does not oppose the two price levels proposed.

• It is crucial that HRPRS numbers must be easily identified, both during a trial, and afterwards, should the service proceed. This supports consumer protection measures and also aids the monitoring of debt issues during the trial. To this end BT recommends a dedicated number range and proposes the range ‘09X’, where ‘X’ equals ‘2’ to ‘8’. Oftel may wish to consider how this may impact on the National Telephone Numbering Plan, however BT does not think such a solution need hold up a trial unduly.

• BT believes that it would be appropriate for ICSTIS to consider the need for clear and accurate pricing across all networks, particularly in the mobile market to support consumer validation and clarification.

• BT believes that our response is consistent with our previous discussions with the industry and our response to their Statement of Requirements. However, there are still a number of points of detail regarding technical and process matters that must be finalised before BT is in a position to offer service. In particular, BT would urge ICSTIS to ensure that a robust process is agreed with the industry on such matters as the recording of consent and scripting for the free to caller message.

• It should be remembered that once BT opens up these services they will become accessible through our interconnect arrangements. ICSTIS should consider initiating an information programme to bring this to the attention of all network operators.

• This proposal offers BT a number of commercial opportunities and we recognise that the premium rate market has the potential for new, innovative services that can benefit consumers. However, we acknowledge that many of these services will be new to consumers and, as they cost considerably more than current premium rate tariffs, could lead to unexpectedly high bills. Therefore, BT believes that introduction of these tariffs should only take place in a way that provides our customers appropriate and proportionate protection.

• To that end BT does not oppose the limitations of the trial as proposed but has detailed several issues relating to these limitations.

• Furthermore, it is BT’s intention to reintroduce the ‘free to caller’ facility on our network for these services upon their maximum call charge being reached. This would be in addition to the requirement for Service Providers to implement such a facility and in no way replaces their obligation.

• This proposal is unlikely to be the end of the matter since the industry are likely to propose services with even higher rates once the new higher premium rate tariffs are opened up. This will bring even more serious consumer debt and detriment issues as well as more lucrative fraud opportunities

 BT would welcome further discussion on the contents of this paper with interested parties. In the first instance comments, questions, requests for further details or points of clarification should be emailed to:

Anthony Foster
anthony.2.foster@bt.com