By Simon Woodhead
I’ve made no secret that I find origin surcharging a disgusting hijack of good intent. It is an embarrassing spectacle of economic Darwinism and tone-deafness that highlights big-business’ darkest underbelly. That starts with Vodafone and BT, something I hope consumers remember. It is also an embarrassing spectacle of regulatory incompetence and refusal to listen. All this being played out on a global stage at a time when Britain is redefining its place in the world.
Let’s be clear what happened here: Ofcom suggested opening a door, the world and his dog told them it was a bad idea, except Vodafone, Three and BT who supported it, they opened the door anyway, Vodafone, Three and BT walked through it. They’ve been followed quickly of course by EE (owned by BT) and latterly Gamma. Telefonica/O2 are a notable absence, perhaps better explained by inertia than morals, but time will tell.
Maybe that door will get closed, but it won’t be overnight now. It certainly needs boundaries setting, as what was intended to prevent UK operators being unfairly treated in bilateral interconnects with overseas operators, and ultimately UK consumers overpaying, is being used to gouge money from huge swathes of the world with seemingly no discrimination by overseas network.
Before that happens, other networks are going to join the party. It gives me a moral dilemma but when Vodafone are choosing to charge their origin surcharges on calls across their network to Simwood numbers, the damage is arguably already done and we may have no choice.
Add into this mix our third world porting regime, for which most people would point at Ofcom, but Ofcom would likely point at Vodafone and BT (see Competition Appeal Tribunal judgment), and doubly ironically the third world is being punished here. Take Burundi as an example. The average wage there is £16 per month. NDAs prohibit us from being specific but let’s just say that whoever is carrying the calls into the UK will be paying broadly 1.8% of that per minute before markup from local operators. Now maybe there are no Burundaise people with mobile phones and relatives in the UK, but if there are and their local telco and any transit operator are entirely benevolent, they can talk to their relatives here for broadly an hour a month before exhausting their entire income. And, adding to that the choice of operator in the UK doesn’t make a blind bit of difference here if numbers were originally allocated to one of the surcharging trio because calls always go to the original range-holder first and their rates apply. Shameful. Absolutely shameful.
But, I don’t want to be negative here and I’ve already given my somewhat depressing outlook of what could happen. There’s lots to celebrate here and some amusing snippets.
In what is apparently now 25 years, Simwood has never once bought an industry award. We tried to sponsor one once but even that was a seedy depressing experience. We have our own of course, the SimCon Awards, which you cannot buy – there are no dinner packages or advertising offers and they’re often a surprise. We aim to recognise those in the industry and community doing good but who are so busy doing so they wouldn’t or couldn’t entertain filling in an application form about how good the wholesale platform they don’t have is, or how ‘best’ the IP network they resell from someone else is. They’re 100% douche-bag free. So, as our own website isn’t adorned with logos we bought, and we can’t award ourselves the only award you can’t nominate yourself for (the SimCon Awards), we could be perpetually unsung. But that’s ok, we’re not in this for the glory.
We’re confident and straight talking, and some have said ‘irreverent’. Hell, someone even called me irascible once. Once I’d looked it up in a dictionary I was quite cross! However, what can easily go overlooked is that we’re good at what we do. I don’t say so often, especially internally, but days like today I’m really proud of Simwood and everyone in her because we think differently.
We made a policy decision early on that we didn’t want the filth of origin charging to impact our customers – realistically how could many implement it? We’ll stick to that as long as we can BTW. Yet, whilst the rest of the industry ran around like headless chickens (or dead chickens in some cases), and people’s supply chains were exposed by who’s text they copied and how late in the day they did it, we were quietly working away.
Our focus was on risk not revenue, as it always is. It doesn’t matter how big and clever your bucket is or how much water you can extort into the top if it has a hole in it. We prefer to have no hole and can therefore be a little more discerning about who or what goes in. Much of it had been in place over a decade, our loss protection for example which protects us from customer arbitrage, and (had we passed surcharges on) the ability for our customers to dynamically control what calls we allow to protect themselves. However, implemented properly, origin charging is massive because it multiplies up the computation required to route a call 3-5X. That’ll only get worse too. We want to know exactly what each call is going to cost and continue to route differently based on numerous factors.
That process was frustrated by the apparent frenzy of those imposing these surcharges. Their rate sheets, to put it politely, have very evidently neither come from a billing system nor will be going anywhere near one. We’re talking control characters, typos, hidden columns, numerous different rates for the same thing, missing codes compared to other rate sheets, additional codes compared to other rate sheets and on and on. Seriously, if you’d hired an intern and given them a task to make a new rate-sheet, you’d be questioning the merit of ever hiring interns! All that suggests to me that this is a revenue-only exercise across the industry and that there’ll be many more spreadsheets and a fair bit of ‘mediation’ before bills go out at the end of the month. ‘Don’t worry about competence boys, just grab the money’ is screaming out as a value there!
Then there’s those who have done nothing. Now admittedly, many who we thought had done nothing have rushed an email out in the last 24 hours – the same text working its way down their value chain – and they’ve even managed to put a HTML table of surcharges in there in some cases! Even the Excel Paperclip was facepalming I’m sure. Amusingly, I was also sent this late last week. Multi-billion pound operator’s identity hidden for obvious reasons.
International surcharging from 1st July 2021
As you are probably aware, several Terminating CPs have introduced A-Number surcharging, whereby calls originating from certain countries will incur additional charges.
I’m writing to inform you that any surcharges applied to any traffic XXXX transits on behalf of Simwood will be passed through and will appear on a later billing cycle.
Please let me know if you have any questions.”
I kid you not!
And then there’s those who had no choice but to implement something sell-side because they wanted to grab the money, have no idea of the cost or risk but work on a prepaid basis so can’t wing it until the end of the month. In one case they managed to produce a CSV file, (but possibly only because they don’t think HTML will catch on) until yesterday when I think they decided to half-copy our cost capping feature from 10 years ago. It wasn’t dynamic and doubtless was hard coded. They deployed this to their live environment mid-morning today and, you guessed it, it went wrong. As far as we’re aware the new feature still isn’t working, but basic service was restored after 20 minutes or so!
Contrast this with Simwood. We began filtering out invalid caller-id over a year ago and our customers (mostly) embraced it. We also know exactly what every call is going to cost, now including origin routing. We know how much complexity that adds and have worked to manage it. Rather than grabbing the money, we’re trying not to have to grab the money and relying on the protections we put in place for customers to work with us. My team have worked tirelessly to consume garbage rate sheets, those sheets changing repeatedly, and in one case to make one up as even the operator who expects to charge us in retrospect doesn’t know what it will be yet. All staff were trained on the background for this lunacy, what we were doing about it, and how to support customers through it earlier this week. Finally, we were up until 3am this morning ensuring that the changes deployed previously and seamlessly through our CICD procedures, combined with the commercial rate changes, worked faultlessly. Oh, and to double check that our expectations of load-increase were realistic and be sure auto-scaling would appropriately deal with hot spots. Of course, that all went well.
I don’t say this to gloat, not at all, but in an industry that seems to get sleazier by the day and has demonstrated apparent money-grabbing incompetence, I feel the need to say to consumers: “some of us care about you, and we know what we’re doing!”. Moreover, I’m proud of the amazing team making up Simwood and privileged to lead it. That’s my award.
