50 Ludgate Hill
Consultation on the Revised Standard for Telecommunications Metering and
Billing Systems (OTR 003:2001)
Thank you for the opportunity to respond to the above consultation.
The timetable put forward by Oftel would require Vodafone to convert our existing
systems for metering and billing by the end of 2003. Our existing systems exclude
end-to-end billing and pre-pay which are in the proposed new standard. Operators
seeking compliance with the new standard for the first time have until June 2002 to
do so. Is Oftel is expecting us to comply with some elements of the new standard by
June 2002 and the rest by the end of 2003?
Annex A. The Standard.
Our comments are as follows:
Section 1.4 concerns charging for content and goods. Telecommunications
companies cannot be held responsible for the accuracy of the charges for goods or
non-telecommunication services, only for accurately transmitting the charges
provided by the merchant. The term "charging" therefore needs clarification.
Sec 3. We welcome the use of percentages for measuring accuracy and reliability,
which will make it easier to generate and understand the necessary figures.
Sec 5.1.4. This refers to the establishment of a bill delivery schedule. I understand
that it was agreed by Oftel that this was unnecessary. Can this requirement
therefore be removed as agreed?
Sec 7.2/7.3. These sections refer to the accuracy of signals or data received from
another operator. The sections appear to contradict one another. We believe that
the wording of 7.3 needs to be revisited to make it consistent with 7.2.
Sec 9.1. Materiality.
Defining 5% "of turnover with the customers targeted" is a huge extension to the old
scheme and will cause practical measurement difficulties. It to seems be an
especially excessive requirement where, for example a product or service is aimed at
a small section of a company’s total customer base, as sales may amount to a
miniscule proportion of total turnover.
Sec 10.1. Conformity Measurement.
This allows individual operators and approvals bodies to agree on the means for
demonstrating conformity with the standard. It seems inevitable that different
procedures will be used and that this will make the results incomparable. Oftel would
therefore be unable to publish any comparable information on the accuracy of bills
under this kind of regime as it would be misleading for consumers. Further achieving
conformity with the standard would then have far less meaning, undermine the
purpose of the standard and be of little use to customers.
Annex B: Approval Scheme Guide
4.1.3. Use of Unaccredited Approval Bodies.
Unaccredited approval bodies should not be permitted. This would threaten the
credibility of the Scheme and risk public embarrassment for Oftel and the industry.
We are perplexed by this section. We are sure that Oftel agreed after the last
consultation that it was not reasonable for every company in a chain of service
provision to be responsible for ensuring end-to-end billing accuracy but this is what
the section appears to be suggesting.
Each company can only ensure accuracy for that part of the billing process it has
control over. Any requirement requiring end-to-end accuracy of a billing chain
involving several companies would mean asking each company to try and ensure
things beyond its control. It would impose a heavy cost burden on all involved to
handle the inevitable inter-company disputes about fault with little prospect of
agreement being reached, as well as the cost of mundane day-to-day inter-company
checks. Vital business relations will be damaged as a result. Service level
agreements will not prevent this.
Further, the introduction of these cost burdens will discourage operators from striking
up partnerships with third party service providers and the requirement would
therefore appear to be in breach of Oftel’s overriding interest in competition.
Again we ask that this requirement should be removed as agreed.
5.4. TMBS owned by more than one operator.
We are unclear what section means. We do not believe that both approval bodies
should visit both receiving and sending operators. Can Oftel please clarify its intent.
12.4.2/12.4.3. Chargeable Events.
These two sections appear to be contradictory. 12.4.2 implies that only rental/service
provision and also calls should be classed as chargeable events. By omission, it
precludes accuracy of bills for non-telecommunications items. 12.4.3 then expands
this to include accuracy of bills for non-telecommunications items.
12.4.7. "Non-call" billing events.
Should this read "non-voice"?
We believe that this is too prescriptive. This clause amounts to a significant change
over the previous draft. Technical limitations and the capital cost of making such
changes should be considered first. We reserve the right to round in the fashion we
deem fit as long as we make our rules clear to our customers.
12.6.3. Correcting CDRs before they are priced.
This is not possible for Pre-Pay. In respect of Post-Pay there is no time to correct the
CDRs. CDRs have entered billing by the time it is detected that logging/metering
equipment is over- metering. We would not halt billing in order to correct in real time
as the cost and potential to introduce greater problems represent too great a risk.
Correction via interception after pricing has occurred has been successful thus far.
We can see only disadvantages in terms of cost and the risk of greater inaccuracies
if we were to attempt to change the system.
We would appreciate a meeting with you to discuss our comments as soon as
Regulatory Affairs Manager