VON Europe - Comments on ACMA’s Consultation on Allocation and Charging of Numbers

8/3/2019 VON Europe - Comments on ACMA’s Consultation on Allocation and Charging of Numbers

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VON Europe - Comments on ACMA’s Consultation on

allocation and charging of numbers

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Comments on ACMA’s Consultation on allocation and charging of

numbers

by VON Europe, May 2011

Preliminary remarks

The Voice on the Net Coalition Europe (‘VON’) welcomes the opportunity to comment on ACMA’s

Consultation on allocation and charging of numbers (hereafter “the Consultation”).

VON believes that a well-designed and forward looking numbering plan is feasible (numbers are

not intrinsically scarce; it is rather the way in which they are structured and managed that can

artificially cause this scarcity) and will bring consumer benefits and promote competition. We also

recognise that numbers have been, are and will remain a critical resource for communication

services and applications.

More details can be found in VON’s responses below.

Detailed remarks

Question 2: Is the current block allocation process encouraging allocation and efficient use, orshould it be changed? If so, how?

Question 3: Should the allocation of telephone numbers be used as a compliance and enforcement

tool?

VON believes that the Internet creates tremendous opportunities for new services and applications

and that a well-designed and progressive numbering plan will accommodate growing usage, bring

consumer benefits, and promote competition.

Greater competition in the telecoms sector, facilitated by a well-designed numbering system, is a key

policy goal of the Australian government and will be a key contributor to the wider government

efforts to promote the development of the Digital Economy in Australia and improve communication

services for people across Australia.

Therefore, VON considers that ACMA should take a forward-looking approach to make sure all users

have access to numbers of the national numbering plan without conditions or restrictions. VON





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believes that what should matter is how to ensure that user demand for numbers is met, and that

this could be achieved through a user-centric evolution in approach to numbers.

VON is convinced that a forward-looking approach to numbering is a must in light of changing

consumer demands and the inevitable switch to an all-IP world on both fixed and mobile Next

Generation Networks. In order to accommodate these shifts more flexibility will need to be

embedded into the allocation process, by adjusting the current institutional arrangements,

alleviating the usage conditions and making available numbering blocks in variable units. We believe

that such user-centric approaches to numbers would allay the assumption that numbers are a scarce

resource and free the ACMA to set allocation rules and charges for telephone numbers in future in a

manner which promotes end-user freedom, innovation and competition.

For historical reasons, the ACA (now ACMA) decided to outsource the allocation of certain numbers

(local rate, free phone and premium rate) to the non-profit organisation INMS. For other types of

numbers (mobile, IP enabled and geographic numbers) the allocation process is still administered by

the ACMA. A move to a “one stop shop” may simplify the current operational complexity in the

allocation of various numbering ranges.

VON believes that the allocation of numbers should not be used as regulatory enforcement tool. The

enforcement could significantly affect the end user’s usage and rights when numbers are being

withdrawn.

Question 6: Is there value in extending enhanced rights of use to end-users? If so, what would be

the implementation issues involved? What would the costs and benefits be of allocating individual

general purpose numbers (such as mobile and geographic numbers) directly to end-users?

Apart from the comments made above, the current Australian model for allocation of numbers to

CSPs through the ‘over the counter process’ is working well. In light of changing consumer demands

and the inevitable switch to an all-IP world on both fixed and mobile Next Generation Networks, a

more user centric approach to numbering is recommended. Some parallels can be drawn with the

allocation process for internet addresses where any end user can ask for an internet domain, as an

example of a more user centric approach.





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Question 9: Why is sub-allocation being used in preference to direct allocation or permanent

transfer?

Question 10: Are there any price or process barriers within the current allocation arrangements or

within the broader regulatory arrangements? What problems are they causing? How might they

best be addressed?

Question 13: Should the ANC be restructured to better reflect an efficient price for a public

resource? If so, what approaches should be considered?

The $100,000 Annual Numbering Charge (ANC) for a carriage service provider (CSP) identification

code in order to interconnect with another CSP creates a barrier-to-entry for smaller and innovative

CSPs, which pushes them towards the use of sub-allocation.

The high charge is a disincentive for smaller CSPs to enter the market and to directly interconnect

with other CSPs. As the ACMA rightfully pointed out, transit is not a feasible option for smaller CSPs

who are allocated geographic numbers as according to the Implementation Plan, the CSP

identification code used in conjunction with a geographic number must be allocated to the same CSP

to whom the number is allocated. This leaves smaller CSPs with the only option to obtain geographic

numbers as a sub-allocation from another (larger) CSP.

The sub-allocation of numbers has, however, some drawbacks. It creates complications for CSPs in

terms of managing rights of use such as number portability for these numbers. It also places the sub-

allocatee in a greater dependence towards the CSP that has complete power over the numbers and

the network. In case of problems (divergence of views on commercial conditions, compliance, or

financial problems of the CSP holding the numbers), the only solution the sub-allocatee has, is to

transfer the numbers to another CSP provided that both the transferring CSP and the receiving CSP

allows it and that they have a proper arrangement in place. Porting would need to involve the end

users – which is not the preferred solution for solving CSP-to-CSP issues. This shows that technical

obstacles and commercial barriers could be put in place by certain CSPs to slow down the uptake of

sub-allocation.

VON urges ACMA to ensure that the amount of the ANC will be adjusted in line with international

market practices.





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In addition, extra attention should be paid to the asymmetries in the market between the larger and

smaller CSPs. Safeguards should be put in place regarding both the charges levied and sub-allocation

practices in order to protect current players and future entrants.

Therefore VON encourages ACMA to find ways in which to allocate number blocks to smaller and

innovative CSPs lowering this barrier to entry with negative effects for competition.

***

We thank you in advance for taking consideration of these views. Feel free to contact Herman Rucic,

VON Europe, by phone (+32 (0)478 966701) or email ([email protected]) should you need

further information.

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About the VON Coalition Europe

The Voice on the Net (VON) Coalition Europe was launched in December 2007 by leading Internet

communications and technology companies, on the cutting edge to create an authoritative voice for the

Internet-enabled communications industry. Its current members are iBasis, Google, Microsoft, Skype, Viber and

Voxbone.

The VON Coalition Europe notably focuses on educating and informing policymakers in the European Union

and abroad in order to promote responsible government policies that enable innovation and the many benefits

that Internet voice innovations can deliver.

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VON Europe - Comments on ACMA’s Consultation on Allocation and Charging of Numbers