ETNO Reflection Document on “Draft ECC Report 213: Impact of Number Portability between Fixed and Mobile Services”
The Association of European Telecommunications Network Operators (ETNO) welcomes the opportunity to comment on Draft ECC Report 213 “Impact of Number Portability between Fixed and Mobile Services”.
As a general remark, this Report seems to propose a revision of the European Regulatory Framework regarding Number Portability obligation, when that matter is not under the responsibility of ECC.
In fact the Universal Services Directive, in describing the implementation of the number portability provisions, clearly mentions that the number portability requirement “does not apply to the porting of numbers between networks providing services at a fixed location and mobile networks”.
In addition it is for ETNO premature to set milestones (for instance 2020) for “service portability”, when such a need is not predictable as emerging from the market and surely it cannot be considered a regulatory need for any concrete motivation.
 The European Telecommunications Network Operators' Association (ETNO) is representing 41 major companies, which provide electronic communications networks over fixed, mobile or personal communications systems in 35 countries. ETNO is Europe's leading trade association. More information about ETNO can be found at: www.etno.eu
Close vs open dialling plans
ETNO considers that some topics, such as closing of dialing plans, are not related with the issue considered by the draft Report. ETNO notes that the latter would cause high costs to the industry for those countries that are impacted. ETNO suggests that such scenarios be treated separately.
In fact, changes in dialling plans are very onerous for operators because of the impacts on network and IT platforms, and for the migration definition and synchronization among all operators, service providers, service centres. Apart from that, extensive communication to and education of the consumer is needed.
It has to be underlined that geographic numbering maintains its relevance for the market, also in VoIP/IP networks, and, in some cases, recognisable local geographic information in the number is required for commercial use and/or by local Administrations.
It is ETNO’s view, although there may be a case for adding some flexibility with regard to geographic mobility for geographic resources, the broad notion of geography still has some relevance. However, such nation-wide location portability could be seen as an option only where there is a clear benefit for the users. A balance has to be found in advance between an extension of location portability and the attachment of users with geographic significance of numbers, even in situations where tariffs are not based on distance. In any case, a thorough assessment of technical impacts and a cost/benefit analysis should be performed before considering further evolutions regarding location portability.
As an alternative, for nation-wide portability in some national numbering plans specific number ranges (non-geographical numbers with a geographical tariff structure) are reserved to facilitate nation-wide portability. E.g. in the Dutch numbering plan 085-numbers are reserved for this purpose.
ETNO notes that in all cases, compliance with the geographic nature of the E.164 country codes under which these resources are defined must be assured.
Fixed to/from mobile portability
ETNO considers that market needs for service number portability between fixed and mobile services and networks has not been assessed. ETNO does not see at this stage any current or future need for fixed-mobile service number portability. This is for ETNO a matter that regards gradual fixed and mobile market convergence with implications that go further than what the report suggests. Possible fixed-mobile convergence is a progressive concept that may in the future prevail for networks and services evolution, without any relevance for the maintaining of fixed or mobile numbers.
Today there is no barrier at all for customers to take a mobile number when selecting a mobile service, this is common practice and allows full development of mobile services. This clearly demonstrates there is no structural need or benefit for service portability.
ETNO appreciates the draft scenarios and list of impacts outlined in the report. These impacts for the various stakeholders seem even at this stage.
A more detailed and concrete cost/benefit assessment should be done by the ECC in consultation with all potentially impacted parties to assess the feasibility of such fixed-mobile number portability. In particular, a detailed assessment of the technical and operational impacts, together with a cost/benefit analysis, has to be performed before considering such a major change in the numbering plan structure. A prior market analysis is required as well to guarantee a level playing field for all operators.