By: Roger Darlington
How should telecoms consumers be empowered?
It is now several weeks since Ofcom published its “Final statements on the Strategic Review of Telecommunications, and undertakings in lieu of a reference under the Enterprise Act 2002″. Welcome though the settlement between BT and Ofcom clearly is, the regulator has so far spent much more time and resource on the supply-side of the equation (how to increase choice for the consumer by improving the terms of competition) than it has on the demand-side of the equation (how to ensure that consumers are empowered to exercise such choice in a meaningful manner).
This requires reducing the search and switching costs involved when a consumer wishes to explore the options for changing telecoms supplier. Crucially it also involves providing the consumer with accurate and accessible information that enables an easy and fair comparison to be made between the many options on offer. These needs exist now. If � as one hopes � the agreement on equality of access bears fruit, there will be more consumer choice and more rapid change in the marketplace and therefore consumers will have these needs to an even greater extent. Ultimately competition cannot deliver for the consumer without both effective choice of supply and the information and confidence to choose between these suppliers.
Now it is often the case with Ofcom�s reviews that the review leads to other reviews. In the case of the Strategic Review of Telecommunications (SRT) where we have just had a third document, we are told: �This final statement marks the completion of Ofcom�s Strategic Review of Telecommunications� (para. 2.1). But, in fact, there are no fewer than four further reviews emanating from the SRT:
- A review of consumer policy
- A review of next generation access
- A full cost-benefit analysis of the provision of the USO
- A major audit of the nations and the regions
The review of consumer policy will be of particular interest to those of us on the Consumer Panel and a consultative paper is due to be published by the end of 2005.
The final statement itself is a disappointment in terms of what it has to say on consumer information. It has some helpful comments:
�Though competition may be a means to delivering the kinds of outcomes that consumers want, it cannot be effective unless customers are able to make well-informed choices, and to switch easily between suppliers. Our research showed that some groups of consumers had various difficulties in making these choices. Although the same could be said of most markets, there may be features of some telecoms markets that exacerbate these problems. Though we do not consider it appropriate to leave this problem entirely to the market, it is important that we target any activity to the particular groups of consumers who are having problems. We are making changes in a number of areas and will be looking at this issue further in the wider review of consumer policy that we are now undertaking.� (para 1.4)
and
�Nevertheless, it is important to note that this kind of competition is only a means to delivering the kinds of outcomes that consumers and businesses require. We also considered the need to balance �supply side� intervention with an effective �demand side�. Creating greater scope for competition amongst suppliers would be of little benefit if consumers, through lack of
information or inability to switch suppliers, were unable or unwilling to take advantage of such competition.� (para. 3.16)
However, in a substantive sense, STR3 takes us no further forward than STR2. It simply closes down a number of the options in STR2 in relation to the reduction of search and switching costs, leaving just three possible areas of intervention:
�In relation to the provision of information, Ofcom will pursue an approach that builds on the consumer information principles set out in the Phase 2 consultation. Where there is evidence of an information problem for consumers, we will consider intervening in one of three ways:
�working with service providers to improve or increase the information they publish themselves;
� encouraging the role of independent information intermediaries who can help guide consumers� decisions; and
� publishing information ourselves where there is a benefit to consumers that can only be achieved by Ofcom undertaking publication.� (para. 3.30)
However, the Commission for Communications Regulation in Ireland has a separate, user-friendly web site called Ask ComReg which is dedicated to the provision of consumer information. Is it too much to ask that Ofcom could do something similar?
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