Submission: Proposed variation to Numbering Plan – charges for calls to free-phone and local rate numbers

Consumer Action believes the Australian Communications and Media Authority’s proposal of amending the numbering plan to make 1800 numbers free of charge and 13 and 1300 numbers (hereafter ‘13 numbers‘) a fixed local call cost should be implemented to ensure consumer awareness and price transparency. The experience of our organisation leads us to believe that this is the best method to ensure that the greatest number of people have access to the essential services offered by 13 and 1800 numbers.

Our clients are predominantly low income and amongst the most disadvantaged and vulnerable consumers in Victoria. For the purposes of this consultation, it is important to note that this disadvantage is two pronged.

Firstly, low income means that our clients have difficulty affording the cost of calls on mobiles to 1300 and 1800 numbers.  Pre-paid phone plans tend to have the highest rates for calls to 1800 and 1300 numbers, yet in the experience of our financial counsellors these plans tend to be most often used by low income earners because they allow easier budgeting on a low income.

Secondly, low income and disadvantaged individuals are in many ways the group with the greatest need for access to the services often provided by organisations with 1300 and 1800 numbers. Government departments, Centrelink, Community legal centres, medical and drug and alcohol services, and the Office of Public Housing all provide 13 numbers for clients, presumably to ensure that those on low incomes can access these vital services

ACMA has proposed that the number plan should be varied so that the cost of calls from mobile (and fixed) services to freephone services – that is, 1800 and 18 numbers – would be free.  This proposal is replicated by industry in its own proposal.

ACMA has also proposed that the number plan should be varied so that the cost of calls from mobile and fixed services to local rate numbers – that is 13 numbers –  would be explicitly limited to being no more than ‘the low charge amount’. The practical effect of this would be that the cost of calls to local rate numbers would be limited to 22 cents. The low charge amount can be changed at the discretion of the Minister, but the important part is that ACMA’s proposal will limit all mobile calls to 13 numbers to a single, fixed, low rate.

In our view, ACMA’s proposal is the surest way to provide clarity and certainty for consumers. By regulating to provide that 1800 numbers are free from mobile phones, and fixing the cost of a call to a 13 number at a low rate, consumers will have price transparency. They will be able to use this knowledge in deciding whether to access the services often provided through 1800 and 13 numbers through calling on their mobile telephones, which include Centrelink and Lifeline, as well as many other government and community services.  In our view, implementing this proposal would provide immense benefit to the whole community.

Industry also proposes to make 1800/18 numbers free of charge. However, they propose that rather than fixing 13 numbers at the ‘low charge amount’, these calls can be included in ‘mobile phone plan packages’ – which they state some of which are already in place. In our view, this option provides far less certainty and clarity for consumers. We outline our concerns below about price transparency, and the availability of these kinds of plans for low income earners.

To read our submission in its entirety, click here: Proposed variation to Numbering Plan – charges for calls to free-phone and local rate numbers.

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