12 November, 2012

ETNO Reflection Document on “Draft ECC Recommendation 12(04): Numbering for VoIP Services”

The Association of European Telecommunications Network Operators (ETNO)[1] would like to thank the CEPT/ECC (Electronic Communications Committee) for the opportunity to comment on Draft ECC Recommendation 12(04) “Numbering for VoIP Services”.


[1] The European Telecommunications Network Operators' Association (ETNO) is representing 38 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

Executive Summary

  • ETNO would like to thank the CEPT/ECC (Electronic Communications Committee) for the opportunity to comment on the Draft ECC Recommendation 12(04) “Numbering for VoIP Services”.
  • As a general remark, VoIP service providers that get numbers from the National Numbering Plans have to be duly authorized by the National Regulators and satisfy all the obligations related to the geographic number ranges from which they get numbers (such as Number Portability, Emergency Calls and Caller Location determination, Legal Intercept, link with used public network access, etc.), in exactly the same way as all the other service providers getting numbers from the same ranges. The allocation of mobile numbers will inevitably have an impact on the interface with the relevant authorities in charge of those aspects.
  • The proposed nomadicity definition is questionable, since it does not reflect the intrinsic characteristics and limitation of the nomadic service, as well as the essential respect for regulation regarding the identity of the national authorized telephone operator to whom the numbering is assigned.
  •  The evolution of the traditional voice networks towards VoIP should be taken into account when considering this Recommendation.
  • In addition, there will be fairness in the market place between all the service providers, because the same obligations will be applicable to the same number ranges.
  • Finally, a specific numbering space that is dedicated to the international or national nomadic services is, in principle, the most suitable choice for general end user protection (tariff transparency, etc.), as well as operator and voice calls traceability, legal interception. etc.
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