Comments
from:
Commentary
on "Number Allocation Service – A Business Model"
The following represents the view from Torch Telecom on the paper
produced for the last Rights of Use of Numbering.
1. Summary
Paragraph 1:
(i) Drafting error "to in ensure a system that is transparent…"
the "in" seems surplus to requirements.
(ii)It would be better to say "encompasses porting obligations"
rather than "openly supports porting".
Paragraph 2:
OK
Paragraph 3:
(i) PAP is not yet agreed and whilst there is no compulsion on operators
it is unlikely to be agreed.
Paragraph 4:
(i) Surely the model is "designed to maximise the utilisation
of numbering allocations" rather than to maximise the "number
of numbers in active use", which is surely a function of sales!
Paragraph 5:
Maybe the money should be paid to operators to recompense the costs
of implementing INA? In all events, surely the group making the
allocations should be constituted not to make a profit?
Paragraph 6:
OK
2.
Individual Number Charging
Paragraph 1
(i) Customers need to understand why operators are (likely to be)
passing on a charge of £5 and need to be convinced that this reflects
the true costs of the allocation. There must be economies of scale
– surely the allocation of a block of numbers will not be the
cost of one number multiplied by the size of the block?
a) Golden
numbers
Paragraph 1
(i) I am not sure that the premise is correct – why is 1234567
better than 9090000? Surely it depends on the person wanting the
number?
Paragraph 2
OK
Paragraph 3
(i) How will charities and small organisations get access to these
numbers, if they are to be sold for their true worth? The reality
is that they will be effectively precluded. If a statement like
this is to be included, there must be clear and absolute guidance
as to how it will be enforced!
I see no reason why the two sentences are linked together into one
paragraph.
Paragraph 4
(i)What is this referring to? Running cost of the auctions? Surely
it could be argued that if there was no charging for numbers (as
is the de facto position the industry is moving towards) then there
would be no need to support a body financially. A better use of
everyones money, I would think!
(ii) If the auction does "more than cover" the costs,
what happens to the left over money? The principles behind the organisation
running the scheme must surely be that it is non-profit making?
<
b) Select
Numbers
Paragraph 1
OK
Paragraph 2
Again, what happens to the money raised "over and above"
the costs of administration? This makes the charge look increasingly
like a tax!
c) Sequential
Numbers
This is a bad, or at the very least, misleading, name. This name
suggests that the digits contained are sequential. There needs to
be further thought given to the name – perhaps "non-select"
would be better.
Paragraph 1
(i) Which pile? Which 10K block? What does "number owner"
mean – surely the numbers belong to the nation?
Paragraph 2
(i) Surely the Oftel audit and obligations to return unused numbering
(as is the case already) would protect the scheme from abuse? Why
introduce more administration.
Paragraph 3
(i) Support this idea – surely the "over and above"
money raised from the Golden and Select numbers could cross subsidise
the Sequential numbers.
Paragraph 4
(i) This will be a nice surprise for all of our customers –
suddenly receiving a bill for something they previously got for
free.
5. Number
Allocation
Golden Numbers – surely the charge should be linked to the
RPI, otherwise it will loose value in real times.
Sequential Numbers – does this mean that operators will loose
control of their existing allocations?
7. Change
of ARO assigned to Number
Careful consideration needs to be given as to when ARO1
stops paying and ARO2 starts paying.
8. Reservation
Period
It would make sense that the reservation period should tie up with
that for PAP (if it comes through). I am unclear what benefit a
"random point" has to the process. How would people plan
effectively based on the loss of a number at a random point?
12. Parameters
of the System
(i) Presume that "days" means "working days".
(ii) Reservation period would be better as one calendar month.
(iii) The charges need to be presented to those that will ultimately
be paying them – the consumers – for approval. Given the
low margins associated with NTS, very few, if any, operators will
absorb these costs. Most will be passed straight on. The charges
would need to be significantly reduced before operators could consider
absorbing the cost.
(iv) The transfer fee would be on top of the inter-operator porting
charge. Again, there should be economies of scale associated with
this charge – the costs of porting a 100 number block are not
the 100 times the cost of a single port, for example!
Comments
from CWC on the Oftel Paper: Latest Business Model for Allocation
& Charging Structure with INA.
General
Comments
CWC believe that the benefits (both economic and through improved
consumer choice) of a any allocation and charging structure for
individual numbers should outweigh the costs and overheads of implementing
such a system. It is not clear that in all instances this is the
main priority, as potentially onerous mechanisms and complicated
legal positions are suggested. Our main concerns are summarised
in the three bullet points below, with further comments about specific
sections of your document following.
- CWC believes
that it would be most appropriate for NDAS to directly bill the
customer, this would facilitate easier (legal) understanding of
the customer’s rights and obligations wrt the number. Of
course if the ARO is to act as a billing agent on behalf of the
NDAS, this service must be paid for by the NDAS.
- The cost
of retrospectively applying charging to all customers with 08xx
numbers should be investigated in detail. The cost of auditing,
datafill the database, billing and other associated activities
is not trivial. As many numbers have been ported, this task is
even more complex.
- Offering
support for charitable causes could be difficult to implement.
Arbitrary decisions of the worthiness of individual organisations
or the relative merits of a proposal are likely to be impossible
to resolve satisfactorily and suggest an onerous administration
overhead. Where charitable customers require a ‘select number’
for marketing purposes, this is most likely to be backed with
a large advertising campaign. The campaign will probably be sponsored
by a commercial organisation, which would, most probably also
sponsor the cost of the number. Charitable organisations that
are not heavily advertising numbers would in most cases suffice
with a sequential number, where the cost is burdensome.
Section 1
CWC note that a monopoly database administrator/manager could result
in inefficiencies and duplications if this database did not carry
out all the functions required of it by AROs. Processes for the
request of developments, implementation and charging of such work
must be developed. This will enable ARO to use the database effectively
and will ensure there are no duplications (resulting in increased
costs and potential errors with duplicate databases), as they develop
their own systems to cover areas that the national database is not
doing or doing well.
Section 2
CWC have concerns with the proposal to levy a flat initial fee
with variable rental. We believe that a variable initial fee should
be levied. Otherwise it would be perfectly plausible for someone
to hoover up a large volume of golden numbers (at minimal initial
cost), then sell them all for a windfall gain, not being affected
by the high annual charge since they sell before it kicks in. There
is possibly a better economic case to charge a high initial rate
being the NPV of the future incremental economic value of the number
over a sequential one, then have uniform rental thereafter. The
number wouldn’t be squandered by being hoarded, as it would
have an economic value via secondary trading. On a practical level
variable rate annual charging could result in an infinite number
of price points being required in a billing system, resulting in
huge system developments.
We
would like to see further information on secondary trading system.
The
ARO should have rights not to contract with a customer in such cases
as bad debt/credit references etc. Standard commercial judgements
should apply.
Section 3
The benefits of non-operators acting as AROs is unclear to CWC,
as it seems to complicate matters without adding any material benefits.
Further explanation on the purpose and benefits of non-operators
AROs would be useful. Today VASPs reserve numbers with several Network
Operators (AROs). By becoming an ARO themselves they would either
reserve numbers from a range that has already been allocated to
a Network Operator or reserve pre-allocated numbers and then assign
to a Network Operator. There still requires a relationship between
VSAP and Network Operator.
Section 4
On a practical note we suggest that perhaps the codes for 'Available'
and 'Allocated' could be reversed so that 'Allocated' is A and Available
(or renamed 'Unassigned') is U?
We
believe that care should be taken over the introduction of the 'Reserved'
status. Reserved status could be a tool for hoarding if the reservation
period is too long, a minimum period is recommended. It is assumed
that golden numbers bought at auction could not be reserved, therefore
this status only applies to Sequential and Select Numbers. Sequential
numbers by their nature really do not require a long reservation
period and Select numbers, surely if requested and are available
require no longer that it takes for necessary contractual work to
be carried out between the ARO and the customer.
The
Reservation period for the number and the Provisioning period of
the customer's service are completely independent and as such start
of charging should not be linked.
Section 5
It is unclear to CWC how a non-operator ARO would be allocated
a sequential number, would it be from a random operator's range?
However in this case the non-operator ARO would immediately have
to get it built on a network, meaning all numbers provisioned via
them would likely be subject to PAP - inefficient. However, if the
entity was a VASP, they would get the number via an operator, meaning
the number would come from their pool.
Section 6
A state diagram would be useful addition to illustrate this
section.
While
there may be no direct connection between the NDAS and PAP, there
is a strong case for the NDAS to hold the network on which the number
is hosted, in order that operators could use the NDAS as a routing
database in the future if they so wish. This implies a linkage into
the PAP process such that when a number is changed to U (either
from R, A or T) a field is populated with the terminating network.
If the NDAS was used for routing, the action would then be A=don’t
route call, U=route call to operator in question, T=route to rangeholder.
The point is that the choice to take such action would be an operator
matter.
CWC
believe that the ARO should not bill the customer for their numbers.
Any charges for numbers should be directly billed to the consumer
by the NDAS for a number of reasons:
- the rights
of stewardship of a number must be linked to its owner. If an
ARO decides to absorb costs (and through market forces all network
operators would do similar), dispute situations could be messy.
The network operator terminates the customers services (as a final
action) if there is outstanding debt, to try to recover his and
the NDAS's monies, however the customer's rights over the number
are in effect in suspense.
- Absorption
of number fees by ARO/network operators results in a tax on network
operators for offering services in this market. This is a barrier
to market entry and not reaching its intended purpose of reducing
number hoarding etc and it is back to the present situation.
- To ensure
the customer knows his rights of stewardship etc if an operator
ARO opted to pass the charge on, they would have to ensure that
the number is a separately billed "National Number Database
Administrations Charge", "Number Tax" or something
similar.
- AROs will
have to carry out IT developments to support billing on behalf
of a third party. If the ARO is doing third party billing, the
third party must cover these costs. On a practical level co-ordinating
the same capability (for no material gain) in the billing systems
of several AROs could be difficult and could limit future developments
in number administration where not all AROs can implement billing
system changes in a proposed manner or timeframe.
Charges
for numbers are completely separate from the charges for service
and therefore should be billed and contracted for separately. In
this way the consumer can maintain his rights of stewardship his
numbers if he maintains payments.
Section
7
The customer always attracts the charge for the number, however
we assume you refer here to the new ARO carrying out the billing
for this transferred number, we refer you to our previous comments
on the appropriate billing method.
Section
8
The reservation period should be carefully defined to guard
against number hoarding but allow enough time for necessary contractual
work between the ARO and customer to take place.
Section
9
CWC note the spirit of the limit in reservation quantities,
and although it pains us to highlight it, allowing only a limited
number of reserved numbers could be a barrier to market entry. A
sensible number needs to be agreed, with perhaps a sliding window
being used, similar to the one employed by RIPE to limit the number
of IP adddresses assigned to a customer by a local registry without
reference to RIPE - the window increases as RIPE gains confidence
in the local registry's ability.
Section
10
Please see our earlier comments on charging structure in section
2, Billing to the nearest hour for annual charges seems incredibly
detailed and perhaps requires capacity and capability which outweighs
its value.
Section
12
CWC do not see any purpose for a transfer fee paid by the consumer.
This is a minor barrier to changing to AROs, opposes the spirit
of number portability.
BT’s
Comments on Oftel’s Number Allocations Service Business Model
1 Introduction
BT welcomes the opportunity to comment on Oftel’s proposals
for a Number Allocation Service Business Model. The comments in
this document represent BT’s response to the proposed model,
and include a number of general points, followed by some more detailed
comments relating to specific points in Oftel’s document.
2 General
Comments
The model is vague as to the number ranges to be covered.
BT believes that if these arrangements are to be introduced they
should, initially at least, apply only to established Freephone
(080x), Local rate (0845) and National Rate (0870) numbers, as it
is still not clear how the remainder of the 08 and 09 ranges will
evolve. A clear statement to this effect should appear at the start
of the paper.
Whilst
BT does not disagree with the concept that customers' rights of
number use should be protected through commercial contracts, we
would point out that such contracts cannot in any way constrain
customers' rights as enshrined in UK and EU legislation. In particular,
contracts cannot place any restriction on their portability rights.
BT
notes Oftel’s intention to seek primary legislation enabling
charges, which would exceed those based on cost-recovery principles,
to be levied for certain classes of numbers.
BT
believes that charging for numbers will have little or no impact
in promoting more efficienct use, or better husbandry, of numbers.
However, it is likely to increase users' costs: not only will they
have to pay for a resource that was notionally free to them previously,
but the Numbering Administrator will also incur the costs of setting
up and running a billing system, including audit trails, bad debt
recovery processes, etc. These costs will be relected in the charges
for numbers, which will flow through to customers. Additionally,
operators will incur extra costs in administering the charging system:
these costs will inevitably be borne ultimately by customers.
BT
does not believe that it is necessary to quote figures in the model,
especially as they are not used to further the model or the arguments.
Experience shows that the figures will get used more and more as
examples and end up becoming ‘received wisdom’ and thus
reality. We would also observe that any cost-based figures ultimately
derived should take into account the costs of setting up, as well
as running, the centralised database.
The
use of Pre-Allocation Portability (PAP) as a basis for this model
is, at this stage, unwise as Oftel is currently unable to mandate
its use. The principles and detail which underpin this concept are
still being discussed at the Non Geographic Number Portability Commercial
forum, and have not yet been agreed in totality. Furthermore, this
concept does not have the support of all Operators and Service Providers
who currently offer Number Translation Services.
3 Specific
Points of Detail
3.1 Individual
Number Charging
BT believes that a customer will either want a specific number or
will accept the next sequential number. There is no obvious reason
to differentiate between ‘Golden’ and ‘Select’
numbers, as any number from these ‘categories’ will be
of value to some customers. Any attempts to ‘guess’ the
value a customer would attribute to a specific number is misguided.
Furthermore, it would not be a fair and equitable arrangement for
all customers.
BT
believes that there should be one ‘category’ of ‘Vanity’
numbers which encompasses both the ‘Golden’ and ‘Select’
numbers referred into in the model. It must also include Alpha-Numeric,
or Alphabetic numbers, e.g. FLOWERS, and take into consideration
the practice of over-dialling which currently prevails in some instances.
BT’s definition of over-dialling is the practice of adding
additional digits at the end of a number to turn it into a word
e.g. BLOSSOMS (an 8-digit number).
BT
is also concerned at the potential for ‘speculators’ to
obtain ‘Golden’ or ‘Select’ numbers which have
not been identified by Oftel and/or the Administrator, that could
be worth a fortune. The current internet model has allowed the hoarding
of internet URL's which has enabled allowed certain bodies to hold
the businesses to ransom. The proposed model greatly underestimates
the value of numbers to some people.
BT
remains concerned that charities and smaller companies will be disdvantaged
by the auction process. Auctions expressly favour those with deep
pockets and it is difficult to foresee how these organisations will
be able to obtain golden numbers "for specific projects for
an acceptable fee". This model does not improve the chances
of charities having access to attractive numbers: if it is felt
that this is a worthwhile objective, the model should specifically
address this issue.
Operators
have contractual and billing relationships with their customers:
if a customer refuses to pay the Oftel charge whose responsibility
would it be to pursue its collection?
BT
notes that in their December 22nd 1999 statement on Freephone
Numbers, Oftel are considering proposals to associate a higher fee
with 6-digit ‘0800’ numbers to provide an incentive to
return numbers which hold no more value to the user than a 10 digit
number. Surely Oftel should be applying the same set of criteria
to existing allocated numbers as they would for those which will
be allocated in the new regime, should the proposals outlined in
their model be implemented.
BT
is concerned that treating all existing numbers to be ‘sequential’
is a charter for speculators to prosper. Although this is not necessarily
a problem in itself, it creates so many exceptions to the principle,
that the principle will be undermined.
3.2
Definitions
BT would like to seek clarification of the definition for the
Number Data Administration System (NDAS) as this suggests that the
Administration Manager will manage the database on behalf of Oftel
rather than on behalf of the Industry. Industry discussions regarding
a Pre-Allocation Portability WEB Server database could potentially
result in the database being managed on behalf of the Industry which
is at odds with the definition in Oftel’s proposed business
model.
The
definitions and roles of the Accredited Reservation Organisation
(ARO), Valued Added Service Provider (VASP), Full Rights User (FRU)
and Restricted Rights User (RRU) ignore the complication of end
user allocation and also those issues brought about by number portability.
These definitions need to be re-written to take into account these
issues.
3.3
Number Status
The model overlooks the need to tackle numbers which have been
returned to the Numbering Administrator by customers when they are
no longer needed. The model needs to be modified to included a period
of sterilisation or quarantine, during which numbers cannot be allocated
to new customers.
The
definitions and number status need to be amended to reflect who
owns responsibility for deciding which numbers are ‘Withheld’
and ‘Restricted’ for various reasons. Similarly, it needs
to define who will decide which numbers are held back for auction,
and when they will be sold.
Although
the model refers to a status of ‘Structure Restricted’
it is not clear how this will be enforced. It could be interpreted
that this status effectively rules out the practice of over-dialling,
particularly in the case of 6-digit numbers which don’t, and
won’t, have a 7-digit equivalent. If BT’s interpretation
of this status is correct, Oftel will need to develop rules for
‘policing’, which meet this criteria.
BT
is concerned that the model appears to overlook the need for numbers
to be kept free of reservations in order to accommodate products
such as DDI and other products which require blocks of numbers.
This would not really fit into the category of Regulatory restricted
as these numbers do need to be allocated, but in a more restricted
and managed.
3.4
Number Allocation
BT agrees that there needs to be different methods of allocation
for Sequential and ‘Vanity’ Numbers. However, it does
not believe that Oftel should differentiate between ‘Golden’
and ‘Select’ Numbers. Customers will attribute their own
value to numbers regardless of whether they are ‘Golden’
or ‘Select’.
3.5
Number Access and Status Change Rights
No Comment
3.6
Change of ARO Assigned to Number
BT is concerned that AROs could change the status of numbers
to Allocated as a means of ‘Holding’ Numbers that are
not in service. This practice must not be allowed as it potentially
enables unscrupulous AROs to hoard numbers. This ‘anomaly’
also highlights the need for an absolutely clear definition of ‘in
service’.
3.7
Reservation Period
BT notes that the industry has already discussed this issue
at great length and concluded that one month at a time for a maximum
of three months was best suited to customer requirements. The practice
of random availability, in respect of time, at the end of reservation
introduces uncertainty which is not helpful to the industry or its
customers. Numbers should become available immediately after the
end of a reservation period. Similar to ‘in service’ there
needs to be an absolutely clear definition of ‘reserved’.
A method of overcoming Number Hoarding may be to introduce a refundable
charge, which is returned upon bringing a number into service, for
reserving numbers.
When a number is being recycled, can it be reserved so that a person
has first call on it when it re-emerges? Can a person ask that the
recycling period be reduced on the understanding that they pay for
incorrect calls to the previous owner?
3.8
Reservation Quantities
These reservation quantities do not reflect the time taken between
provisional orders and bringing new numbers into services. Furthermore,
it does not consider the impact of large DDI orders which are quite
common. BT believes this figure needs to be significantly higher,
although it accepts that Oftel needs to approach this issue cautiously
because of the potential for number hoarding.
3.9
Charge Structure
See earlier comments regarding BT’s views on ‘Select’
and ‘Golden’ Numbers.
3.10
Database Record Structure (Operational Requirements)
BT believes that certain pieces of information need to be removed
as they reveal commercial information about the customer. For example;
- Date/Time
of last change of status
- Most recent
date when status was U or ‘never'
3.11
Parameters of the System
BT
is concerned about the concept of ‘Transfer Fees’ and
would like clarification as to whether these apply as well as, or
instead of, the existing portability payments, which are supported
by a Mergers and Monoplies Commission judgement. The model should
deal with a mechanism to allow number trading, including an arbitration
process to resolve disputes.
To register
any comments about the issues covered by this Working Group please
e-mail Alan Pridmore.
TERMS OF REFERENCE
Working Group Objective
To advise Oftel on charging and related policy in respect of individual
number allocation.
Background
In the consultative document Developing Number Administration published
in July 1998, Oftel made proposals for the introduction of individual
number allocation and the charging for allocations to bring more
efficiency to numbering administration. In February 1999, the Trade
and Industry Select Committee in its inquiry into telephone numbering
stated: "We think it vital that the efficiency with which
the nation’s resource of telephone numbers is used is increased
and believe that economic incentives are more likely to achieve
this than regulatory diktat."
In the Statement
Developing Numbering Administration and Freephone Numbers published
on 13 May 1999, Oftel concluded that:
- individual
number allocation should be introduced, to be carried out by a
Number Allocation Organisation paid for by annual rental and allocation
charges;
- charges for
allocations of individual numbers, amongst others, should be introduced;
and
- a period
of informal consultation would take place including a Working
Group set up to consider how best to set up the system of charging
for individual number allocations.
The informal
consultation will lead to a more formal consultation/ progress
report early in the year 2000. In setting up the Groups, Oftel’s
aims are:
- to provide
greater transparency of policy making;
- to obtain
the views of users, service providers and equipment suppliers;
and
- to enable
a consensus on issues to develop between the major interest
groups where practical.
Means of Operation
Oftel working papers on the development of policy on charging
for individual number allocation will be posted on Oftel’s
web- page. Comments on these papers are invited either in discussions
at the Working Group or, for those not attending, in writing to
Oftel.
Members of
the Group will be expected to participate actively in its work
and should be prepared to provide papers and other information
to assist meetings.
Oftel will
present key issues arising out of the working papers and responses
to the Group for discussion. The Group may decide to ask members
to produce papers or provide information for future discussion/comment.
Outputs from the Group will normally be posted on Oftel’s
web- page.
Oftel expects
that the Group will meet up to five times between September 1999
and February 2000.
Chairman and
Secretary
The chairman will be appointed by Oftel. Oftel will provide the
Secretariat functions.
[Return
to 'Numbering Working Group 2' page]
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