VON EU - Comments on BEREC's Questionnaire on Cross border Accessibility of Phone Numbers

8/3/2019 VON EU - Comments on BEREC's Questionnaire on Cross border Accessibility of Phone Numbers

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BEREC Framework Implementation Expert Working Group

Call for contributions to the questionnaire on Cross border

Accessibility of Phone numbers

Questions

Within this questionnaire the term cross-border communication means a call from anynetwork in the EU Member State A to a number range according to the numberingplan of Member State B. This questionnaire refers to inaccessibility in cross-bordercommunication if a number in Member State B cannot be reached from MemberState A, where A and B are initially random Member States.

A. Which number range(s) are inaccessible in cross-border

communication?

1. In the national numbering plans of the EU Member States various types ofnumbers, allocated in different number ranges, typically exist. Please indicate

in the table below whether a number range raises an accessibility issue during

cross-border communication:

Type of number range called AccessibilityIssue

Remarks

Geographic number Note 1Mobile number

Personal number

Nomadic or VoIP number Note 2Premium Rate Service (PRS)number

Free-phone numberDirectory enquiry service numberShared cost number

Internet dialling

Public utilities numberEmergency services numberSMS PRS number

Other special tariff number1

ETNS

UIFN

Table 1 Accessibility in cross-border communication

Note 1 Although geographical numbering ranges are generally the numberranges which are most accessible from other member states, VON would like

1For instance, national phone numbers for business and undertakings (the calling end subscriber pays the call

but there is no payment for the called party).


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Questionnaire on Cross border Accessibility of Phone numbers

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to draw BERECs attention to issues with in-country accessibility of numberingranges. Many time consuming and highly expensive constraints with regard toin-country accessibility of numbering blocks (including geographicalnumbering blocks) result in new entrants being prevented to enter the market.

In many member states there is no mandatory obligation or code of conductfor a time frame within which networks should adjust routing tables and ensurethat new numbering blocks from other service providers are being madeaccessible and reachable for the calling party. In some other countries, theconcept of hosting of numbering blocks (in combination with wholesaletransit) is not accepted by the industry, which leaves the owner of thenumbering block with no other means than to enter into individualinterconnection arrangements with each individual access network. Such timeconsuming and highly expensive constraints with regard to in-countryaccessibility of numbering blocks (including geographical numbering blocks)result in new entrants being prevented to enter the market. In addition, many

numbering plans link the usage of geographical numbers to a fixed location, orrequire an operator to comply with certain conditions or usage restrictions(such as terminating of the call within the geographical zone, requiring theuser to provide a fixed address etc). These conditions may be inherent to thePOTS but do no longer make sense in an all-IP world.

Note 2

Whilst it can not be denied that a number of accessibility issues exist withregard to VoIP/nomadic numbers, VON urgently requests BEREC not to focuson cross border accessibility of VoIP or nomadic numbers. Any attempts fromregulators to introduce specific ranges for nomadic use, albeit all goodintentions, failed and will continue to fail. Rather, a much more forward-lookingapproach would be for BEREC to focus its attention on lifting all barriers forthe use of geographical numbering ranges, ensuring transparent retail prices(the user should be able to access any geographical number for the cost of alocal call), while decoupling geographic numbers from their locationinformation.

According to Ofcoms latest research2, geographic numbering is still highlyvalued by consumers and businesses: In contrast, maintaining the geographic

significance of an area code was considered important by some businessesand residential consumers for a mixture of emotional and practical reasons.

2. Could you identify any differences in cross-border accessibility of numberranges based on the type of access network (network in Member State A:fixed, mobile, VoIP, etc.)?

VON members experience both cross-border and in-country accessibilityissues particularly with mobile networks. For example, in Germany, some (ifnot all) mobile network operators continuously attempt to block or degrade

2 Ofcom, Summpary report of findings June 2011, prepared by Futuresight for Ofcom,http://stakeholders.ofcom.org.uk/binaries/consultations/safeguarding-geographic-numbers/annexes/Geographic_Numbering_Future.pdf, page 6.
http://stakeholders.ofcom.org.uk/binaries/consultations/safeguarding-geographic-numbers/annexes/Geographic_Numbering_Future.pdfhttp://stakeholders.ofcom.org.uk/binaries/consultations/safeguarding-geographic-numbers/annexes/Geographic_Numbering_Future.pdfhttp://stakeholders.ofcom.org.uk/binaries/consultations/safeguarding-geographic-numbers/annexes/Geographic_Numbering_Future.pdfhttp://stakeholders.ofcom.org.uk/binaries/consultations/safeguarding-geographic-numbers/annexes/Geographic_Numbering_Future.pdfhttp://stakeholders.ofcom.org.uk/binaries/consultations/safeguarding-geographic-numbers/annexes/Geographic_Numbering_Future.pdf


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access (for their own customers) to regular local or national numbers allocatedto other carriers without any due justification3.

3. Please point out if an inaccessibility issue of the number range stems from an

accessibility issue within a Member State (a national call).

VON refers to note 1 under question 1 above.

Moreover, assignments at national level in themselves are mainly an issuebecause they entail 27 different procedures, but the main impediments lie inthe different obligations, restrictions and burdens attached to numbers by the27 different national regulators and/or policy-makers.

The EU regulatory framework for electronic communications (Directive2002/21/EC, as amended), requires numbers to be made available for all

public electronic communication services4 and that the EuropeanCommissions Information and Consultation Document of 14 June 2004 on thetreatment of Voice over Internet Protocol (VoIP) under the EU RegulatoryFramework5, Section 7.1, stated explicitly that:

Any undertaking providing or using electronic communication networksor services has the right to use numbers. ()

4. Are you aware of any significant differences in the treatment of cross-border

calls depending on the MS where the calling/called parties are located (that is,MS A and MS B)? In which MS and number ranges can you identify such

differences?

No info available

B. Due to which reasons are these numbers inaccessible?

A quick scan of possible reason for cross-border inaccessibility of number ranges hasresulted in the following list of reasons:

3 For illustration purposes, in August 2011 Eplus unilaterally decided to block the access to certain geographicalnumbers of other carriers for the reason that the numbers would be used for (virtual) calling card purposes.Although the regulation does not prohibit to use geographical numbers for such type of services, it is unlikely thatthe NRA disposes of the proper legal basis to act against such practices.4 Directive 2002/21/EC (as amended), Article 10 Numbering, naming and addressing:1. Member States shall ensure that national regulatory authorities control the granting of rights of use of allnational numbering resources and the management of the national numbering plans. Member States shall ensurethat adequate numbers and numbering ranges are provided for all publicly available electronic communicationsservices. National regulatory authorities shall establish objective, transparent and non-discriminatory proceduresfor granting rights of use for national numbering resources.5 European Commission. (2004). Commission Staff Working Document on the Treatment of Voice over InternetProtocol (VoIP) under the EU Regulatory Framework. An Information and Consultation Document. Retrieved at,http://ec.europa.eu/information_society/policy/ecomm/doc/library/working_docs/406_14_voip_consult_paper_v2_1.pdf.
http://ec.europa.eu/information_society/policy/ecomm/doc/library/working_docs/406_14_voip_consult_paper_v2_1.pdfhttp://ec.europa.eu/information_society/policy/ecomm/doc/library/working_docs/406_14_voip_consult_paper_v2_1.pdfhttp://ec.europa.eu/information_society/policy/ecomm/doc/library/working_docs/406_14_voip_consult_paper_v2_1.pdfhttp://ec.europa.eu/information_society/policy/ecomm/doc/library/working_docs/406_14_voip_consult_paper_v2_1.pdfhttp://ec.europa.eu/information_society/policy/ecomm/doc/library/working_docs/406_14_voip_consult_paper_v2_1.pdf


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- Technical and operational limitations, (for example signalling andonline/prepaid charging)

- Pricing and billing issues (offline charging)- Numbering plan aspects

-Aspects linked to access and transit wholesale interconnection services

- Legal issues linked to the definition of services, (for example VAT, age foradult entertainment)

- End user protection from fraud and misuse of numbering- Called subscriber has chosen not to be accessible from another Member

State- Differences in language- No market demand- Other

5. Which additional reasons for cross-border inaccessibility of number rangescan you distinguish? Please add them to the list providing a short explanation

for each one.

The reasons listed above are the most common ones. As far as in-countryinaccessibility of numbers is concerned, one could add the requirement ofaccess operators to enter into specific individual interconnection arrangementswith each access network (Bulgaria, Romania6) or the lack of any hard codedrules about time delay within which routing table should be updated andnumbering ranges should be made accessible for calling parties, or, in thecase there would be industry standards available, the lack of penalty for adelayed implementation (most EU member states)..

6. For each of the non-accessible number ranges as indicated in response to

question 1 above, could you describe and explain to the maximum extent

possible, the concrete reason(s) (from those of the former list) for cross-border

inaccessibility? Please indicate which are the most important ones from your

point of view.

For retail price charge model, the following models can be distinguished:

-Calling party charged numbers (no value added service): typicallygeographical numbers, mobile numbers, personal numbers, nomadic orVoIP numbers.

- Free of charge for the caller: typically emergency services, publicutilities numbers, free phone call numbers and harmonized numbers forharmonized services (116).

- Shared cost numbers- Premium rate service numbers

6 Please note that in Romania and Bulgaria, there is no practice of transit through the incumbent (at least noincumbent service plan for transit from and to other carriers), so individual interconnection agreements arerequired.


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7. For which number ranges an inaccessibility issue could be related to the retail

priced charge model (e.g., due to limitations asked by the user of free phone

or shared cost numbers or for premium rate service and the related difficulty in

complying with the regulation of the Member States).

8. Which are in your opinion the most important issues regarding national

regulations that prevent or hinder a fully cross-border accessibility of number

ranges?

For inter-operator price charging two models can be distinguished:

- termination model (originating operator fixes the retail price and paysthe termination rate to the terminating operator)

-origination model (terminating operator fixes the retail price and paysthe originating rate to the originating operator)

The most important issue preventing cross-border accessibility of premium

rate services is linked to the complexity to cope with the complete lack of

harmonization as to the applicable conditions in each country with regard to

pricing, consumer protection, and the billing complexity resulting from such

variable conditions. In order to avoid the risk for abusive or fraudulent traffic,

most access operators throughout the EU determine to block access to this

type of numbers from abroad.

9. For which number ranges the inaccessibility could be related to the inter-

operator price charging model?

All numbers other than fixed geographical numbers and mobile numbers.

10. BEREC is interested in best practices of cross-border special tariff services.

Please provide examples of cross-border special tariff services that you might

beaware of, which are working currently on the basis of cooperation among

operators (e.g. certain services functioning among two neighbouring countries,such as directory inquiry). Please elaborate on the agreements, technical

solutions adopted, conditions applied to the calling subscriber and any other

subject considered relevant.

C. To what extent is inaccessibility perceived as a problem?

11. Does your organization receive complaints from stakeholders (like individual

users, groups or organizations) that some number ranges are not cross-border


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accessible? If yes, please describe the complaints and from whom they are

coming.

Yes VON members are receiving complaints mainly from business customers

for whom accessibility from all networks (fixed and mobile, national and

international) is crucial for their business. Whilst some customers have

difficulties to understand that the lack of or delayed accessibility is due to the

access networks, the perception is thereby created that the service provider is

not a reliable partner.

12. From your point of view, which are the most important barriers and problems

derived from cross-border inaccessibility?

The following examples of stakeholders that have an interest in cross-bordercommunication are:

- Consumers (in home country or abroad like travellers)- Companies (customer service departments, helpdesks, sales, business

travellers, expats etc.),- Network Services providers (access, transit and terminating, inbound

services),- Content service providers,- Public bodies and governmental organizations

13. Please describe which stakeholders in your opinion are most affected by the

cross-border inaccessibility of number ranges. How are these stakeholders

impacted by the inaccessibility? Do these stakeholders have any influence on

the accessibility of the number?

14. What new opportunities, products, services and business activities in your

opinion could be developed in an open-access framework for special tariff

numbers? (e.g. new platforms and contents, new access network provider

wholesale services, etc.)

VON believes that the Internet creates tremendous opportunities for newservices and applications and that a well-designed and progressive numberingplan will accommodate growing usage, bring consumer benefits, and promotecompetition.

In this context, assignments at national level in themselves are mainly anissue because they entail 27 different procedures, but the main impedimentslie in the different obligations, restrictions and burdens attached to numbers bythe 27 different national regulators and/or policy-makers.


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16. Regarding to which specific number ranges would you advise to the European

Commission and/or BEREC to take the required actions to improve the cross-

border accessibility? Please give an explanation of these actions.

Documents

VON EU - Comments on BEREC's Questionnaire on Cross border Accessibility of Phone Numbers