30 October, 2012
ETNO Reflection Document: ECC WG NaN Green Paper - Long Term Evolution in Numbering, Naming and Addressing 2012-2022
The Association of European Telecommunications Network Operators (ETNO) would like to thank the CEPT/ECC (Electronic Communications Committee) WG NaN (Working Group Numbering and Networks) for the opportunity to comment on the Draft Final of Green Paper on “Long Term Evolution in Numbering, Naming and Addressing: 2012 – 2022”.
ETNO appreciates the difficulty of the task undertaken by the WG NaN to outline potential evolutions of a complex and multi-dimensional area ten years ahead in an environment as diverse as the 48 CEPT countries. In response, this paper merely intends to provide comments on the Green Paper for further discussions and related workshops; it does not have the ambition of setting out ETNO’s perspective on that same evolution.
On a general note, ETNO also observes that the introduction of the paper emphasises a potential trend for E.164 numbers to be used chiefly as ‘names’ within ten years. Whilst ETNO understands (and endorses) the growing importance of IP-based technologies (and addresses) and social media addressing schemes, we would note that as far as numbering plan evolutions are concerned, most current evolutions under study on national or international numbering plans for the next five years are related to the use of phone numbers as “addresses”, which may be seen as being in contradiction with this long term vision.
That vision seems also to argue for a gradual disappearance of “service numbers” like short numbers. This is not consistent with the current approach of harmonisation.
 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
- ETNO would like to thank the CEPT/ECC (Electronic Communications Committee) WG NaN (Working Group Numbering and Networks) for the opportunity to comment on the Draft Final of Green Paper on “Long Term Evolution in Numbering, Naming and Addressing: 2012 – 2022”.
- ETNO appreciates the statement that “efficient and effective regulations in the area of numbering, naming and addressing are only possible after a detailed and well informed dialogue with the entire involved stakeholder”. In this respect ETNO would like to be kept informed of possible future steps.
- ETNO recommend keeping stability in the numbering plans. Any unnecessary change should be avoided as it would have a significant impact on end-users’ behaviour, end-user equipment and operator networks. Any change in the numbering plan should therefore be based on a stable long term vision.
- ETNO would like to mention that the CEPT Green Paper clearly states that “as a consequence of all these developments it will become impossible to impose broader regulations, e.g. on customer protection linked to numbering ranges”. Taking into account Europe’s Digital Agenda, ETNO considers that the CEPT Green Paper should not disregard the continuous efforts for enhanced consumer protection in the electronic communications market.