• Agenda
• Note of meeting

AGENDA

1. Matters Arising from the last meeting

• Comments on the Note of the last meeting

2. Introduction and Context

• New attendee, Paul Brisby, One2One
• Summary of working group progress (Mark Whitbread, Oftel)

3. Ongoing Review of Numbering Conventions (Sandy Grom, Oftel)

4. Number Porting and Rules of Use

• Paper explaining Pre-Allocation Portability and how it might affect rules governing number use (Lesley Bulman, ntl)
• Paper on the issues to be addressed where number stewardship is disputed over ported numbers (Bill Crane, BT)

5. First draft of a new Number Trading model (Alan Pridmore, Oftel)

6. First draft of a list of items to go into a Rules of Use mini-manual (Mark Whitbread, Oftel)

7. AOB

8 Next Steps and Future Meetings

• Action Points for next meeting.
• Dates

 (Please assume the meeting will last about three hours)

MEETING NOTE

Rules Governing Number Use Working Group

11 November 1999

Time & Place: 2:00 pm at Oftel

Meeting called by: Oftel

Meeting chaired by: Claire Milne (Independent telecoms consultant)

Oftel representatives:
Alan Pridmore
Mark Whitbread
Sandy Grom

Attendees:
Lesley Bulman (ntl)
Michael Dixon (TMA)
Isobel Brown (FUG)
Richard Cox (Mandarin)
Roger Gilbert (DMA)
Steve Smith (DMA)
Peter Hamilton (BT)
Paul Rosbotham (CWC)
Noel Scanlon (ADTS Ltd)
Owen Watson (Torch)
Liz Wainman (CA)
Paul Brisby (One2One)
Alan Price (Dial It)

Apologies:
Andrea Dworak (Energis)
Rob Borthwick (Vodafone)

1. Matters Arising from the last meeting

None at the meeting. Members were invited to suggest any amendments to the notes of the previous meeting in writing within the next few days.

2. Introduction and Context

New attendee, Paul Brisby of One2One, was introduced to the group.

Oftel summarised the papers which had been prepared for this meeting and that since the last meeting of this group there had been two meetings of the Allocation Structure Consumer Workshop (WG3). Those meetings were to better assess users’ desires with respect to the allocation of 08 and 090 numbers. The Charging for Numbers working group (WG2) has met once, in September. At that meeting the discussion about charging was hampered by the uncertainty about allocation structure. The second meeting, which will now take place on 24 November, was postponed to make way for WG3.

3. Ongoing Review of Numbering Conventions (Sandy Grom, Oftel)

S Grom explained that his review of the present, April 1997, version of the Conventions was triggered by the need to update several relatively minor parts that had become out-of-date with time.

He estimates that a draft of the new Numbering Conventions will be available before Christmas. This will be sent to the group. The group asked Oftel to consider any comments the group offered before the new version was finalised.

4. Number Porting and Rules of Use

L Bulman explained the main elements of Pre-Allocation Portability (PAP), the process by which operators will make available to other operators unused numbers within allocated blocks and allocate them as a precursor to formal network connection. Through PAP, the intention is to more completely utilise number blocks that are already allocated by removing the need to bring a number into service with the block-holder before being able to port. The first phase of PAP (PAP1) begins on 10 January 2000 and will require fax enquiries to the block-holder operator about the availability of numbers from potential recipient operators before numbers can be ported.

The working group had concerns about the transparency of PAP1 and suggested it would be simple for operators to withhold available golden numbers from PAP. The group also queried whether it will provide proper quarantining of re-used numbers.

Operators are co-operating on the development of the second phase (PAP2), which will include a read-only Internet database of available numbers to bring greater transparency. They are considering including a ‘last used’ date on the PAP2 web-site to give information about the likely sterilisation of the number.

The group suggested a need for the database to carry a date on which reservations lapse so that all PAP participants have an equal chance to jump in and reserve those numbers when reservation periods lapse.

Oftel reported that the WG3 user workshops, which representatives from two operators had also attended, had given the operators a clearer picture of what users would like PAP2 and future, enhanced PAP systems to offer. This included either quarantining or full information about previous use of available numbers.

It was suggested PAP gave a golden opportunity for some standardisation of number layout. The operator representatives noted this.

With respect to number trading with PAP, the group saw the potential PAP, and PAP2 especially, gave to companies to pursue attractive numbers for trading by searching the database. It was proposed that the database could include contact information for the present user on those users who want enquiries about selling their number. The operators pointed out that the PAP database was intended for porting and was not a directory.

The group revisited the problem of what to do if operators fail financially. It was agreed that PAP should be structured to make it easy for another operator to adopt such numbers.

Disputed Number Stewardship

P Hamilton summarised his colleague’s paper as beginning but not resolving the debate about grey areas over who has "rights" over a number. With the now complex sets of relationships between operators, service providers, resellers and other telecommunications companies in the supply chain, ports can be equally complex.

It was agreed that, whenever a "customer" was referred to in the porting context, it was often unclear which customer was in question. It was proposed that a definition of "customer" was required.

It was also agreed that there was no single solution to all portability problems. Many would have to be dealt with on a case-by-case basis.

Non-operators within the working group could not understand why the Internet domain name principles could not be adopted for telephone numbers. The operators reported that the problems arise because of the complex supply chain for certain types of telecoms services. In many cases, a number is assigned by an operator to a service provider, which is then used within the provision of a service to end customers - in some cases there may be multiple service providers in the supply chain, adding varying degrees of value at each stage. In these circumstances, it is unclear who has the rights of use of the number, i.e. is it the user or the customer. The analogy with the internet is not exact; the similar situation has not been fully resolved in that, for example, in many cases the name of the service provider is part of the internet address (e.g. noname@hello.freeserve.co.uk) so that customers could not expect to port this name to another provider.

6. New Number Trading model

A Pridmore explained Oftel’s latest ideas about how number trading might work when charging is introduced.

The group commented on these aspects:

• It should not be left to the seller to tell the buyer to send the "certificate" away to be authorised;
• if a number is moved, there should preferable be safeguards against paying for non-existent numbers, although Caveat emptor must suffice;
• the process was likened to car number plates in that the plates do not exist on their own without a car (or service in the case of a number) re: contractual changes
• must legislate for possible trading abuse, e.g. fraudulently sell numbers of which they do not have stewardship;
• standard contract/certificate;
• operators felt neither they nor service providers should be expected to act as charge collectors on behalf of Oftel;
• the group felt that, while some out-of-service time might be inevitable, no out-of-contract time could be permitted for a traded number. While harsh on the purchaser, this was a necessary anti-hoarding safeguard.

A suggestion to restrict number trading to specialist number traders was generally thought unworkable and unfair. It would seem to be forcing people to use a middleman even for simple one-number transfer deals.

The group saw problems with having a set of other organisations that could receive allocations.

Users felt strongly that market forces should be left to control the system. As soon as the free market was in any way interfered with, it was thought likely to unbalance the system and, although some trade might be officially restricted or forbidden, it was more likely to become illicit.

The users also feared unreasonable hoarding might result if annual rental charges were too low. They estimated very roughly that an annual rental of more than £100 would be needed to discourage hoarding. They therefore supported strongly Oftel’s plans to extract the value of numbers through charging. The DMA have taken this one step further and propose categories of golden (auctioned), select (above cost) and sequential (admin charge only) numbers with some special rates for charity numbers. They also support the right to keep numbers out-of-service if proper payment is made.

Others queried the policing mechanism; it was suggested that the market would regulate itself more effectively than by regulatory imposition.

At the group’s request, Oftel confirmed that it expected trading to involve numbers in ranges other than 08 and 090 in time but this depended largely on the demand for them. Geographic numbers in conservation areas seemed good candidates.

6. Items for a Rules of Use mini-manual

- Next draft including suitable obligations to come at next meeting.

- Meaning of "customer" needs to be defined.

- "infrequently" will be a source of contention given recent, arguably frequent changes

- unclear who delivers the rights

- operators / traders share some obligations

- Business / domestic split not clear

- Check with TPS requirements re: refusal of DM calls;

- Mini-manual could be seen as a Numbering Highway Code, incl. Everything we’ve come up with so far.

- Operators were disinclined to grant as many rights to companies as to individual number users but it was pointed out that the distinction was inexact because many sole proprietors trade under Ltd company names.

- Rules of use manual should apply to all number ranges.

7. AOB

- The group were invited to raise any use issues surrounding ranges other than 08/090.

Main Points

PAP1 and PAP2

How do we guard against operators holding onto golden numbers, because trust may not work.

Number Trading

How do we prevent unreasonable stockpiling? Users propose charging: auctions for golden numbers; the market sets the economic charge. Sequential numbers get admin charge; select numbers are above cost.

General view: 08 and 09 trading model should, in principle, be used as the basis for trading in other ranges (01/02/07) in time.

Rules of Use

No clear agreement where rights in numbers reside – in particular the rights to port and trade. This is seen to depend heavily on the definition of "customer".

Do rights persist only after secondary allocation or they passed all the way down the supply/ trading chain?

There is a need for clarity.

Action Points

*This depends on the timing of the issue of the draft coinciding with the availability of the group’s members. But it should be possible at the group’s January meeting.

Still to come from 2^nd Meeting of the Group:

Future meeting dates

2:00 pm 9 December 1999

A meeting will be held in January 2000.

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