Following our updated Porting Policy this week, we’ve had a number of ‘what if’ type scenarios posed that we wanted to give some clarity on. The wording on the policy is clear, but we’ll cover here how we’d interpret it in a number of scenarios for the avoidance of doubt or ambiguity.
So exports are now essentially free?
We charge for exports, but any charges we levy will be automatically offset against any imports you do. So, yes, if you’re like the majority of customers who do more ports in than out, you could consider them free.
Will you block a wholesale Return to Range-holder or Subsequent port?
Generally no. When a number leaves us but we’re not the Range Holder, technically it is much simpler as we’re not in the call path any more. The administrative overhead is still significant so we will still charge but typically, certain nameless operators will take back “their” number anyway, then try and clean up 6 months later when 999 records turn out to be wrong and the end-user is affected.
So the wholesale porting prohibition is on Simwood range-holder numbers only?
That is correct. We fully respect any end-user rights under GC18 and have been very vocal in enforcing these where others seek to deny them, but we’re under no obligation to allow wholesale customers to move numbers for their own benefit. When this happens, we remain the range holder and despite the revenue disappearing, the infrastructure cost in terms of our Regulated Interconnect to BT and other networks doubles. For every call in we use both a channel in, and a channel out over our SS7 circuits. Furthermore, every time those numbers are ported in future, we incur administrative costs. That is a cost of doing business where the end user wishes to port, but we cannot sustain it for wholesale customers seeking to misuse the porting process. There are other fair options described below.
Aren’t you profiteering from me losing a customer?
Sadly the porting process is very broken, open to abuse and costs money. We estimate an export to cost us £150 per attempt. We have elected to pass on £20 of that, with a cap where there are many numbers. So we’re passing on some of the cost, broadly 13% of it in fact. Further, where the port is for an engaged customer doing porting business in the other direction, we’ll absorb 100% of the cost because we give that £20 as a credit against the next port-in on the account. We can assure you there is no profit in porting and in fact our porting charges, plus the revenue we make for number rental, amount to less than the overhead of running a busy porting desk. This updated policy will not shift that balance materially.
Does the ‘per number per attempt’ mean I’m going to get charged for every third party mistake or slamming attempt?
In short, no. “Attempt” is open to interpretation but really relates to when we send you an export notification. The reality is that certain CPs fire out export orders that can take several attempts to even be coherent. We reject those through our own validation with no charge or notification to you, until they eventually get it right. That final scenario is a chargeable attempt to you but the many attempts beforehand all go into our costs that we cite.
With regards to slamming, again a number may fail our internal validation because it isn’t in service despite being on your account, and you wouldn’t be charged in that situation. If, however, there was a valid looking port that we pass to you for validation, then you would be charged. You can assist us in not needing to refer any further attempts to you by giving us the relevant information. In practice, we see very little of this for it to be a concern and our attempt here is to minimise abuse, not punish our own customers for being victims of it! In the exceptionally rare case of persistent slamming we are of course not going to charge our customer for every attempt, but work with you and competent authorities to deal with the problem.
Why should I pay?
There are certain costs to operating in a regulated space. 999 is one example where you need to give it for free to your customers, but we incur call costs which we pass on to you. Porting is another one where you should not be expecting to pass our costs on to your end user. It is a cost of doing business rather like a flower shop having to buy water but being unable to charge for it.
There is a bigger conversation around where margin sits nowadays. Ofcom have, in our view, dramatically shifted margin from wholesale to retail in recent years and we blogged about this some years ago. Your costs on calls have plummeted much faster than retail prices, ergo, margin has shifted to you from us. We try to price competitively and fairly across all services but we also have to be fair to all customers and avoid cross-subsidies. In our view, this updated policy appropriately reflects that and reduces the extent to which good engaged customers subsidise others.
You host my numbers so do I get charged for exports too?
It depends on the nature of your agreement. If you have asked us to manage porting for you we will. If you are paying for number hosting through Virtual or Managed Interconnect, then we would not normally charge you for exports of your own numbers. If you are one of a handful of customers who were offered long-term ‘free’ hosting of numbers many years ago, then you will be charged – we need to charge for something sometime! There are very occasional exceptions to this such as customers spinning up new companies and seeking to port their own numbers to themselves, which we would charge for. In any event, any charge is credited against future imports so the option remains for this to be cost neutral.
One of the reasons we encourage customers to get their own numbers and host them with us is the fact that they can all be moved to another network should we part company, without resorting to abusing the porting process. This remains the case and we’ll work with any Virtual Interconnect or Managed Interconnect customer to get their own number ranges with numerous other benefits from doing so.
Will this policy apply in the USA?
We’re a CLEC in the USA and building our status and capability over there very rapidly. This policy relates to UK porting only which is uniquely broken. In the USA there is a central database in which numbers are simply ‘re-pointed’ when they port. This removes the technical dependence on the losing network, and consequently the cost. Similarly, there is no former monopoly seeking (in our opinion) to re-monopolise in an unregulated way. Thus, much of the overhead and shenanigans are removed.
So if I have wholesale Simwood numbers I’m a customer forever in respect of those numbers?
In the current porting regime, possibly. Indeed we still spend thousands each month on numbers from other wholesale operators that precede us getting our own last decade. Abusing the porting process to avoid those charges or shift the overhead to them would be unfair and indeed anti-competitive. Other wholesale operators are the same. Until we have a new porting regime more like the USA, it is however necessary that we maintain accounts we wouldn’t choose to.
That said, there are alternatives. We will always process on-net ports so if you would like an introduction to one of our other customers with a view to porting to their account, we’re happy to oblige. This would be an internal port with much lower admin and none of the technical issues. We do not charge an export fee to another customer, i.e. on-net.
Similarly, if your reason for migration is because your end user needs some kick-ass service, talk to us. We can probably work with the vendor for accreditation, or indeed you can map your numbers to their SIP end-point without any need to port anything anywhere. In the worst case scenario, where service is only available from X and X is a reseller of another operator, X or their operator are welcome to a Simwood account and the numbers can be moved there as an internal port.
Finally, if any of our porting partners wish to modify our porting agreement such that we mutually permit two-way wholesale ports over a lower cost interconnect (i.e. without BT involved) we’re game. We’re always willing to entertain that and would in fact prefer a world where numbers can move anywhere with no cost implications for the losing operator. We cannot however, be the party that subsidises or operates a one-sided policy. We’ve launched the Open Porting Initiative to this end, and strongly encourage you to make your wholesale operator aware of it.
Our focus is on fairness and service for the end user, and whilst we might want to absorb the overheads of the rest of the industry we wouldn’t be around long! We’re always happy to work with others to take the cost out and improve the fairness.
We don’t like saying no, we don’t like staff being the punch-bag for a broken process – we see and feel it whereas others outsource it to India – and to be perfectly honest there are a handful customers we’d happily terminate contracts with on various grounds, were it not for the wholesale porting angle. We welcome anything that changes that but cannot create it alone. In the mean-time this is the best we can come up with.
X says it doesn’t work like this?
Sadly, in the UK some have a tendency to lie and the system enables them to. A reseller of a reseller that pretends to be the carrier, is going to know little about the business of the carrier 3 steps above them. They may resell a number of resellers of resellers and see commonalities but unless they’re the carrier, they do not know. When they talk about porting, perhaps ask them who they have porting agreements with, if anyone. Perhaps look at their network map (does it say ‘coming soon’ whilst their website is on AWS?). We’ve commented on these fluffers before. When they say ‘give us a call’, do they even have a phone number published or do they hide behind email? Anyone can make stuff up about what they don’t understand and lie about their authority to do so – we know lots of people with brains, but we won’t profess to be experts on neurology.
Whilst we seem unique in having a transparent policy on this, we know most of our contemporaries do not allow wholesale ports so having established them as a credible source (perhaps people we have porting agreements with for one) why not ask them how it works? They know what they’re talking about and face the same pressures we do. We welcome free consultancy if they come up with a viable solution that is better than our Open Porting Initiative.
X charges less than you.
See above to establish whether X is simply passing on charges from the party they’re reselling, and someone above is actually absorbing the overhead. Our cost is £150 but we pass on £20. However, where they may be passing on an charge, we pass on a conditional charge – the actual charge is £0 for a customer who does an import. With X, they’ll charge both ways and you won’t know what it is until they decide who they’re reselling today.
So imports are going to be one-charge?
We’re trying! It isn’t an overnight thing but we want to get to a stage where you give us a port, and it happens, with much less exposure to the games that go on behind the scenes. This would be much easier to do if you were reselling our service rather than us offering a wholesale service (see the talk of margin shift above) but with technology, efficiency and know-how we think we can make it work. Expect a steady improvement over coming months!
I have another question?
Ask us! You know we’re approachable so please pick up the phone!
