Comments on Draft ECC Recommendation 15(02): “Guidelines for Major Changes to National Numbering and Dialling Plans concerning E.164 Numbers”
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ETNO welcomes the opportunity to comment on the Draft ECC Recommendation 15(02) on “Guidelines for Major Changes to National Numbering and Dialling Plans concerning E.164 Numbers”.
Regarding the concluding Recommendations for NRAs, ETNO would like to commend the ECC for laying down these guiding principles which can serve in the event of structural or policy changes to a national numbering plan. It is important for the industry that these guidelines be kept in mind to avoid complexity and to minimise costs. Despite the fact that each national numbering system has its own history, it is ETNO’s experience that similar issues indeed arise across Member States and having common principles such as those provided in the proposed Recommendations can help and should be adhered to as much as possible.
It is ETNO’s opinion, however, that the proposed draft Recommendation should take more into consideration the impacts on operators and users of national numbering plans changes, in particular as regards geographic numbers. In general, to justify an evolution of a national numbering plan, a cost / benefits analysis should be performed in advance. In addition, a national numbering plan should evolve and not be completely disrupted.
Changing the numbering plan can also have a potential impact on the competition in the market and the existing ecosystem within the market. The numbering is not a standalone domain; it cannot be dissociated from the development and competition in the market. Sometimes numbering changes are introduced to facilitate competition and sometimes to follow a certain demand and evolution. However, if new options or changes in the numbering plan are introduced, this could change this market dynamics such as the merging of the geographic and mobile numbering plans. A correct assessment of the regulatory framework should be made and possibly some regulation should change or should be updated to take account of the impact of the changes in the numbering plan on the market conditions and to guarantee a level playing field and fair conditions for all players.
Another element to be evaluated when changing the numbering plan is the impact on other aspects not directly linked to numbering but linked to other legal obligations and concerns such as the CLI authenticity, the implementation of legal obligations such as localization, correct identification of customers and the routing of calls to emergency services. When changing the numbering plan, this impact should be taken into account and investigated.
This Draft Recommendation mentions two major changes which in ETNO’s opinion should be evaluated carefully before considering eventual future implementations: removing the requirements for geographic information, the fragmentation of the numbering plan and the creation of sufficient capacity for M2M services.
As regards the removal of geographic significance of numbers, in ETNO’s opinion the scarcity of numbers is not a reason, since there are already many country specific solutions to cope with scarcity. A specific need for nation-wide location portability for geographic numbers should be assessed in the market before considering it as a reason to justify location independent numbers evolution. In addition a step approach could be evaluated as regards the removal of geographic significance.
As regards creation of sufficient capacity for M2M services, it is worthwhile citing ECC Recommendation (11)03 on “Numbering and Addressing in Machine-To-Machine (M2M) Communications”, which:
2) that as a long term solution IPv6 addresses, or numbers/addresses other than E.164 numbers should preferably be used for M2M applications, and these numbering/addressing schemes or switching from E.164 numbering plan to a new plan should not prohibit market development or competition;”
In ETNO’s opinion, M2M services could take advantage from a dedicated range (with possibly longer numbers than the other normal ranges, and dedicated rules, taking into consideration that these numbers will not be dialed by people but only by devices), but this is a national matter. It should also be considered that generally it could be difficult to define M2M services as a complete separate category from traditional services. Indeed a clear definition of M2M would be needed beforehand.
In ETNO’s opinion, the need for geographic numbers will not disappear in the future since this need is very much related to information on the location of the called user, which is of great value for calling users. In addition, geographic numbers are still significant for fixed lines; for instance emergency calls from geographic numbers are still, in a number of countries, routed automatically to the appropriate regional PSAP. Moreover, ETNO does not think that the tariffs for mobile calls will become exactly the same as the geographic ones in the long run. Even when tariffs are the same for mobile and geographic calls, the «cheap» image of geographic calls will remain for consumers for a number of years. For these reasons, ETNO considers it very important to maintain both geographic and mobile numbers.
In general, evolutions regarding national geographic number policies and the removal of numbering ranges are one way moves which induce significant costs due to technical and business impacts. Decisions in these areas must be preceded by extensive consultations with all stakeholders, including operators and users representatives, and can only be part of long term numbering strategies. If changes are decided to be introduced, a clear (progressive) planning should be agreed many years in advance to optimize the migration and the investments associated with the change and taking into account the network evolution. Finally the technical impact on end users, residential and business, should be taken into account.
Future major changes regarding the national numbering plan should also take into account the current situation regarding the existing technologies that are in use. These kinds of changes are very costly and require a very careful design due to the impacts that may apply to both operators and subscribers. Moreover, changes like the removal or reduction of geographic requirements/significance of numbers are highly dependent of the used technology. As long as the TDM network with current configuration is in use, it is not feasible to proceed to these kinds of changes. In a future all-IP-network, moving towards that direction could be considered but also with a significant cost and effort both to network and IT (provisioning / billing) systems. Regarding numbering of M2M applications, in accordance with ECC Recommendation (11)03, in order for machines to communicate between them, it is more logical and more convenient not to use E.164 numbers, but different addressing/numbering schemes like IPv6 addresses.
Download the full Reflection Document here.