Wednesday, September 29, 2010

The ACCAN "super complaint"

The weekly ACCAN newsletter drew my attention to this article in the SMH about the ACCAN "super complaint" on the cost of 13/1300 and 1800 calls from mobile phones.

As I said about this in my first comment on it, it is a little distressing that this issue has taken consumers so long to come to grips with. It is particularly distressing to see the naivety of various help-lines as demonstrated in the SMH story.

They are the customers of the providers of the 1800 and 13/1300 service providers. They pay those service providers a per minute charge to reflect the fact these are "B party charging" numbers. If they wanted calls from mobiles included they needed to ask their service providers to do that for them. The cost would have been higher, especially back in the earlier days of mobile services. As I noted there was an "originating service" declaration that was designed for the voice providers to get the mobile services included in the free/local rate arrangements.

It is probably not too late for these organisations to "provider shop" and see if anyone will come to the market with a 1800 13/1300 offering that incorporates the cost of the calls from mobiles. This issue there would be what is the access price for the undeclared originating access that the mobile operators could provide? Is it something like the current retail price of those calls now, or is it more like the price of the (declared) mobile terminating access? (An economic argument would tell you the latter).

What has made the issue particularly prevalent now is the growth of the so-called "capped" plans. This has highlighted the issue in two ways. The first is that these calls can fall outside the cap (to many customers' surprise) and hence result in unexpected charges including the category of "unexpectedly high" charges. The second reason is related to this but is more pernicious. The marketing of caps is typically conducted as "X dollars worth for only Y". The X dollars worth is based on the call rate used to calculate prices charged once the "cap" is exceeded. As an incentive for over purchasing the cap, and to increase the supposed "value", the call charges outside the cap have been increasing. The consequence is that the 13/1300 and 1800 call charges have been increasing despite supposedly declining prices over-all.

Ultimately consumer groups need to be complaining more about the whole structure of capped plans, the anti-competitive affect of differential on-net and off-net pricing, and the misleading and deceptive conduct at the core of the claimed value.

I am no lawyer, but I think that ACCAN rather than seeking a new "super complaint" power could more productively initiate its own proceedings - either to injunct the telcos from engaging in that marketing behaviour or to seek damages for the affected consumers.

1 comment:

ian said...

I tried to raise this issue a few times in the past, including at a CTN conference 2 years ago, and with an ACMA director.

No one seemed interested.

I am sure David knows the reason for the bizarre interconnect pricing structure for these calls.

My recommended solution is to lobby the organisations which use Local Rate and Freephone numbers to provide a geographic number, in addition to, or in lieu of these numbers.

This would be cheaper for many fixed phone users, and included in call caps for mobile users.