IP: calling party pays wireless

[Dave Farber <farber () cis upenn edu>]

> Date: Tue, 7 Mar 2000 08:29 PST
> From: lauren () vortex com (Lauren Weinstein)
> To: bkennard () fcc gov
> Subject: calling party pays wireless
> Cc: DFARBER () fcc gov, lauren () vortex com, neumann () pfir org
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> Mr. Kennard,
>
> Greetings.  I recently read your response to John Stahl (in TELECOM
> digest) regarding the calling party pays cellular/wireless proceedings.
>
> I must admit that I too have serious concerns about the shape
> of the service as it seems to be emerging.
>
> I'm assuming that CPP cellular would remain an *optional* service
> that would not result in artifical pressures on cellular services
> to migrate users from conventional plans to CPP.  If such pressures
> occurred we'd have yet another set of problems.
>
> I am most concerned at this point about the charge notification regime.
> I do understand (as per your note to Stahl) that you are considering
> the requirement for a recorded message notifying the caller that
> they are about to incur extra charges (presumably with a grace
> period to hang up and avoid the charges).  However, this is
> really insufficient protection:
>
>   --- Would such recordings explain in detail what the charges
>       would be for that particular call?  This could be
>       complex in the case of roaming, and would be important so
>       that potentially large charges would be fully understood
>       by the caller.  A simple, "you are calling a wireless customer
>       and will incur additional charges if you stay on the line"
>       would not be adequate.
>
>   --- As you know, cellular numbers are generally not discernable to be
>       "special" numbers to callers based on their NPA-prefix designations.
>       They look like ordinary landline numbers.  Competitive concerns and
>       subscribers' desire not to necessarily reveal when they are providing
>       a cellular number have created this environment.  This is in stark
>       contrast to many other parts of the world, where cellular numbers
>       typically are in separate prefixes that are easily recognized.  The
>       lack of any number segregation for CPP subscribers in the U.S. means
>       that it would be very difficult for telephone customers to themselves
>       block access to CPP numbers.  Some customers with suitable equipment
>       might be able to block access to all numbers in cellular prefixes, but
>       that would of course prevent access to non-CPP numbers as well, and
>       would still be hard for customers to manage in the rapidly changing
>       cellular prefix environment.  CPP number segregation doesn't seem
>       viable either, since we can assume cellular customers would desire the
>       flexibility of dropping CPP (or moving to it) without changing their
>       cellular number.
>
>       Unless some mechanism exists for ordinary residential and business
>       customers to specify that they do not wish to incur CPP charges (much
>       as they can do now for NPA 900 numbers, for example) it is likely that
>       the complaints will be rolling in.  Blocking is available for 900 --
>       and there are announcements on those numbers of charges also.
>       LXC-based blocking needs to be available for CPP also.  This suggests
>       the need for a database of every current CPP number that can be
>       referenced by the appropriate LXC during call setup.  Would this
>       expensive undertaking end up being underwritten by all cellular
>       subscribers, even those totally uninterested in CPP?  This would seem
>       unfair.
>
>   --- Finally, I am somewhat skeptical of the economic viability of CPP in
>       the U.S. market.  Given the falling costs of airtime and bulk minute
>       packages, the need for such a service would appear to be very niche
>       oriented.  The experience of many countries outside the U.S. where the
>       introduction of CPP resulted in significant increases in cellular
>       usage (particularly of inbound calls) does not necessarily translate
>       to the U.S. situation.  The big difference is that in most of the world
>       callers are used to paying per minute for every call--the concept of
>       flat rate local calling areas simply doesn't exist.  For them, the CPP
>       charges are typically not significantly outside the range of what
>       they'd expect to be paying anyway.  But in the U.S., where people (at
>       least for residential subscribers) are used to local calls being
>       untimed, (and even for business customers, costing just pennies a
>       minute in the local calling area) CPP would represent a significant
>       difference in charges.
>
>       My gut feeling is that the hangup rate on the CPP charge announcements
>       would be very high here in the U.S.
>
> I'm sure you're already familiar with these issues, but I did want
> to take this opportunity to note them.
>
> Thanks very much.
>
> --Lauren--
> Lauren Weinstein
> lauren () pfir org or lauren () vortex com
> Co-Founder, PFIR: People for Internet Responsibility - http://www.pfir.org
> Moderator, PRIVACY Forum - http://www.vortex.com
> Member, ACM Committee on Computers and Public Policy