A consultation document issued by the Director General of Telecommunications

11 December 2001

Contents

Chapter one – Introduction

Chapter two – Consultation request

Chapter three – The numbering of CPS options within the CPS functional specification

Chapter four– Consultation questions

Chapter five– The consultation process

Annex A – Proposed modifications to the CPS functional Specification

Annex B – The current numbering formats for CPS call options

  Chapter one – Introduction

1.1 This is a consultation on two proposals to change the Carrier Pre-Selection (CPS) functional specification.

1.2 The CPS functional specification is a document referred to in the Telecommunications Act Licences of BT and Kingston Communications. It specifies technical and other principles to enable the efficient implementation and utilisation of CPS in the UK. It is published by Oftel from time to time after consultation with the Licensees and other interested parties.

1.3 The first proposal is to include calls to existing Directory Enquiry (DQ) access codes within the Carrier Pre-Selection ‘all calls’ option.

1.4 The second proposal is to change the numbering used for CPS options in the functional specification for the sake of clarity to match that found in other, industry-agreed CPS documentation such as the CPS process document.

1.5 Oftel is not consulting on changes to the functional specification for CPS using autodiallers (also known as the interim CPS functional specification). This is because interim CPS is expected to no longer be available by the time this consultation is completed. Interim CPS will be withdrawn when Phase 2 of permanent carrier pre-selection is launched (currently on schedule for December 2001). Oftel considers that a retrospective change to the functional specification for interim CPS after interim CPS has been withdrawn would be unreasonable and impractical.

Carrier Pre-Selection background

1.6 Customers on BT's network can, at present, use alternative carriers by dialling three- or four-digit access codes. These codes allow the calls to be routed to the carrier of their choice. This system is known as indirect access, and it requires customers always to dial the extra digits to use an alternative carrier. This process can be automated when a customer has special dialling equipment, called an autodialler.

1.7 CPS is a mechanism which allows users to select alternative operators in advance without dialling additional codes on the telephone. The customer subscribes to the services of one or more alternative operators and chooses the type of calls (eg all national calls) that will be routed through the alternative operators.

1.8 EC Directive 98/61/EC (the Amending Interconnection Directive) required CPS to be made available throughout the European Community from 1 January 2000. In the UK, the Director General of Telecommunications has determined that BT and Kingston Communications Ltd (KCL) have Significant Market Power (SMP) in fixed telephony. Thus they are required, under the Directive, to provide CPS.

1.9 CPS is being introduced in three distinct stages on the BT network. The first, 'Interim CPS' (ICPS) makes use of autodiallers and will cease in December 2001. Permanent CPS (PCPS) which does not use autodiallers, is itself being introduced in two phases. The first phase was launched in December 2000 and incorporated the national and international call options. The second phase is scheduled for December 2001 and will add the ‘all calls’ option in addition to national and international.

1.10 For further background information on CPS please see Oftel’s website at www.oftel.gov.uk/ind_info/network_inter/cps_icps.htm.

Call options

1.11 There are three types of call option under CPS, these are:

• national calls (this does not include local calls, international calls, calls to mobiles or calls to non-geographic numbers including the ‘national rate’ 0870 range);
• international calls (calls to the Republic of Ireland and overseas); and
• all calls (including international, national, local, mobile, non-geographic – eg freephone, local rate, national rate, premium rate, personal and paging).

1.12 A user can have both the national and international options at the same time, either from the same provider or from two different providers. The all calls option cannot be combined with any other option.

1.13 At present, CPS does not apply to calls using Type A short codes (eg 100, 999, 112, 192), Type C (operator specific) short codes or the 0844 04yyxxx and 0808 99yyxxx number ranges used for unmetered interconnect Internet access.

1.14 Oftel did not consider including 192 within the CPS call scheme at the outset, as the future of 192 was uncertain. Until Oftel had reached its final decision following its consultation on DQ access codes any moves to alter the status of existing access codes would have been premature and may have pre-empted full consideration of all the possible DQ options.

1.15 For further information on Type A and Type C short codes, please see Oftel’s document Access codes: options for the future use and proposals to revise access codes and short codes conventions at www.oftel.gov.uk../numbering/acco0301.htm.

Oftel’s Directory Enquiries decision

1.16 At present, consumers are only able to use the DQ service provided by their network operator. This is typically done through the 192 code (for national DQ) or 153 (for international DQ). Independent DQ service providers would like to offer their services in competition with the existing network operators. However, there are not enough short codes to go around all interested parties. Therefore independent DQ service providers have had to use longer numbers.

1.17 In November 2000, Oftel consulted on possible changes to the access codes used for DQ services. The consultation document Access codes for directory enquiry services: Consultation document issued by the Director General of Telecommunications is available online at www.oftel.gov.uk../numbering/dqs1100.htm.

1.18 In September 2001 Oftel published its statement on the outcome of that consultation. Access codes for directory enquiry services: A statement issued by the Director General of Telecommunications is also available online at www.oftel.gov.uk../numbering/denq0901.htm.

1.19 The statement set out Oftel’s proposals for the future of Directory Enquiry services. Oftel concluded that a model of service-based competition, with all operators and service providers on an equal footing will provide the best deal for the consumer in terms of price, quality and choice of service. To implement this, Oftel will introduce a new range of 'type B' access codes, 118XX(X), for access to DQ services. Access codes in the new range will be allocated to individual DQ service providers (including network operators and independent service providers). Twelve months following the introduction of the new range, the old DQ access codes (such as 192, 153 and 142) will be withdrawn.

Chapter two – Consultation request

2.1 A number of CPS operators (CPSOs) have requested that Oftel include 192 within the CPS ‘all calls’ option for the interim period between the introduction of the new 118XX(X) codes and the withdrawal of 192.

2.2 The proposed modification would remove certain Type A short codes (192 and 153, ie those used on the BT network) from the excluded list within the CPS functional specification and place them within the ‘all calls’ option (see proposed modified functional specification at Annex A).

2.3 The key arguments advanced in favour of the inclusion of 192 with CPS ‘all calls’ as a transitionary arrangment are:

• those consumers who do not switch to 118XX(X) straight away and who do not use an Indirect Access code in front of eg 192 will benefit from the service offered by their CPSO as opposed to BT’s service;

• by moving DQ traffic away from BT to alternative providers it will act as an additional boost to competition in both the provision of ‘all calls’ CPS (by making it more attractive to consumers and providers) and in the provision of DQ services (by providing additional competition to BT's service); and

• if significant numbers of consumers do not switch to the new 118XX(X) codes immediately, it will provide certain DQ service providers (specifically the DQ service providers chosen by the CPSO) with an increased market during the early phase of 118XX(X) . In doing so, it is argued, it would improve business cases for long-term entry into the 118XX(X) market and thus would encourage development of a competitive 118XX(X) marketplace.

2.4 The key arguments against the inclusion of 192 with CPS ‘all calls’ are:

• all DQ service providers, including CPSOs, will be able to offer their services over 118XX(X) codes and therefore CPSOs will be able to reach those consumers on the BT network regardless of changes to the CPS functional specification;

• because the proposals are for a limited time only, any costs (to BT, CPSOs or consumers) might not be justified as any benefits (to consumers and CPSOs) would be for that limited time;

• as consumers will be in the process of being educated about the new 118XX(X) arrangements, moves to include 192 within CPS might cause some confusion due to the mixed messages;

• moves to include 192 within CPS might also cause confusion within the industry and result in less resources being put forward to ensure the move towards 118XX(X) is successful, since CPSOs will already have the opportunity to benefit from potentially significant DQ revenue streams without having to implement the new 118XX(X) arrangements;

• consumers are more likely (in comparison with conventional number changes) to start migrating to the new access codes prior to the old code withdrawal due to the large volumes of advertising expected. Therefore there would be less benefit than might at first appear to be the case to CPSOs in including 192 within all calls CPS; and

• it may create confusion as 118XX(X) will not be included within CPS so consumers might see calls to different DQ service providers (or indeed the same DQ service provider) billed by different phone companies (if they use both 192 and 118XX(X) access codes). When 192 is withdrawn any CPS customers who had not migrated to the 118XX(X) service until the last moment would find that their DQ calls were now back to being billed by BT.

2.5 Oftel’s initial view is that any benefits that consumers might expect to receive from the inclusion, temporarily, of 192 within the CPS all calls option, could just as easily occur through consumer use of the new 118XX(X) access codes. Furthermore, Oftel is concerned that the temporary inclusion of 192 within all calls might dilute the consumer awareness-raising that will be needed when switching over to 118XX(X) and hence delay the potentially substantial consumer benefits identified in Oftel's September statement.

2.6 To justify changing the functional specification, Oftel would need to see evidence as to the benefits consumers would gain from the inclusion of 192 within ‘all calls’ for a limited period that they would not also receive from use of the 118XX(X) number range.

2.7 It has been argued that consumers might not migrate to the new access codes until the last possible moment. In this case, consumers would not benefit from the competition brought about as a result of the new access codes. Therefore, it is argued, allowing 192 to be included within ‘all calls’ will mean that consumers are provided with some of the benefits of competition in the interim period before 192 is withdrawn.

2.8 Oftel would expect to see evidence demonstrating why the provision of a DQ service by a CPSO brings greater benefits to consumers than provision by the incumbent operator. Oftel’s understanding is that there is little, in general, to differentiate between the respective offerings currently and consumers are already able to use an indirect access over-ride code to access a CPSO’s DQ service if they wish to.

2.9 If it is argued that consumers migrate to new access codes at the last possible moment, Oftel would also expect to see evidence from similar situations abroad justifying this as Oftel is not convinced that the experience of normal number changes is a particularly useful guide.

2.10 Under a normal number change (for example the change to 020 codes for London), there is no clear incentive for network operators to get consumers to switch immediately and therefore many consumers are not persuaded to switch until the last possible moment.

2.11 However, with an access code change such as that for DQ access codes, the new providers have a clear benefit in getting consumers to switch to their services as soon as possible (as consumers cannot access their particular services in any other way). Furthermore, existing service providers (network operators) are likely to want to position their own 118XX(X) number in the market place at the earliest possible opportunity, to avoid losing market share to the new entrants.

Work required

2.12 Oftel understands that any move to include calls to DQ within the CPS functional specification would require some technical work by the industry, in particular by BT. Oftel’s understanding is that this work would not be particularly complex or costly if DQ were a compulsory part of the ‘all calls’ option.

2.13 However, were the ‘all calls’ option to be offered in two variants in the functional specification in future, one with DQ calls and one without DQ calls, Oftel’s understanding is that the level of technical work required might be far more significant. Given the limited life-span of the proposed modification, Oftel is only considering the obligatory inclusion of DQ within ‘all calls’.

2.14 Oftel welcomes comments on this understanding and position, not least its potentially adverse impact upon consumer choice.

118XX(X) and CPS

2.15 Oftel has taken the view that it is not appropriate to include the 118XX(X) codes within the ‘all calls’ option for CPS. This is a logical consequence of the decision in the September statement to opt for services based competition on the basis of complete dialling parity.

2.16 Oftel believes that when consumers dial one of the new 118XX(X) codes, they will be actively selecting their choice of DQ service provider at that point and will not be concerned about who carries the call (this is in contrast to the old 192-based service, which is more generally seen as an extension of the network operator’s own telecoms service.). The new DQ arrangements have been developed to promote competition in the service layer, whereas CPS has been developed to promote competition in call conveyance. Therefore Oftel does not consider it desirable that 118XX(X) codes should be subject to CPS.

2.17 It has been argued that making 118XX(X) codes subject to CPS would promote a single relationship between the CPS operator and the consumer. However, Oftel would point out that under the CPS ‘all calls’ option, the consumer will continue to get a bill from the access operator (eg BT) for the line rental and for any facilities used anyway. Oftel does not therefore consider that there are likely to be significant benefits to consumers from the inclusion of 118XX(X) codes within CPS.

2.18 Oftel is also concerned about several other possible disbenefits arising from the inclusion of 118XX(X) codes within CPS:

• it could place an additional burden on DQ service providers to negotiate billing agreements with CPS operators. It could also increase DQ service providers costs for receiving calls, since they would have to pay both a call origination charge and a call transit charge and hence mute price competition at the retail level and potentially restrict the range of services available; and

• it could place a burden on CPS operators that do not want to offer DQ services to either negotiate billing agreements with DQ service providers or to make their product offerings less competitive by not carrying these calls;

2.19 In its November 2000 consultation, Oftel put forward the position that including 118XX(X) DQ calls within CPS in the event that the 192 code was withdrawn (ie Option 3 – the option eventually selected), would not lead to any increase in competition and / or benefits to consumers. There was no disagreement with this specific position (a number of respondents did argue in favour of including DQ within CPS, however this was not on the basis of Option 3 being chosen).

195 for blind or otherwise disabled consumers

2.20 All public telecoms operators are required to provide a directory service, free at the point of use, to those customers who are unable to make use of a conventional paper directory. This service is commonly provided via the 195 access code. Because 195 is a replacement for a paper directory it is not a subject of this consultation.

Chapter three – The numbering of CPS options within the functional specification

3.1 Oftel has been asked for the sake of clarity to renumber the call options within the CPS functional specification to match that in other CPS industry documentation. Oftel believes this is purely an administrative matter; however, Oftel is obliged to consult on possible changes to the CPS functional specification, hence the inclusion within this consultation.

3.2 Examples of the current numbering formats for CPS call options are detailed in Annex B.

3.3 Oftel proposes to update the CPS functional specification as follows:

Customers opting to use CPS may select from the following options:

Option 1: International Calls
Option 2: National Calls
Option 3: All Calls (to include international, national, local, mobile, specially tariffed (eg freephone, local rate, national rate), premium rate, personal and paging)

If a customer selects Options 1 and 2 they can either have calls from both options carried by the same CPSO or by different CPSOs. In all other cases there is only one CPSO involved.

3.4 Stakeholders are invited to comment on this proposal (see question three in the next chapter).

Chapter four – Consultation questions

DQ access codes within the CPS ‘all calls’ option:

Q1. Do you think the DQ access codes 192 and 153 should be included within the CPS ‘all calls’ option for an interim period until their withdrawal? If you have a view what are your reasons?

Q2. Do you think there would be any benefits to consumers if the existing DQ access codes were included within the CPS ‘all calls’ option for an interim period that would not be delivered through use of the new 118XX(X) codes? If so what are they?

Renumbering of CPS call options within the functional specification:

Q3. Do you think it would be appropriate to renumber the CPS call options within the CPS functional specification to match that used in other industry documentation? If not, why not?

Chapter five – The consultation process

5.1 Comments are invited by 15 March 2002.

Enquiries

5.2 Telephone and e-mail enquiries concerning this consultation document should be directed to:

Alex Campbell
Oftel
50 Ludgate Hill
London
EC4M 7JJ

tel: 020 7634 8970
fax: 020 7634 8893
e-mail: alex.campbell@oftel.gov.uk

Responses

5.3 Written responses should be sent to:

David Parsons
Oftel
50 Ludgate Hill
London
EC4M 7JJ

fax: 020 7634 8746
e-mail: david.parsons@oftel.gov.uk

5.4 Written comments will be publicly available from Oftel's Research and Information Unit and on Oftel’s website, except where confidential. Respondents are therefore asked to separate out any confidential material in a clearly marked annex.

5.5 In the interests of transparency, respondents are requested to avoid confidentiality markings wherever possible. Appointments to view written comments in Oftel's Research and Information Unit must be made in advance (tel: 020 7634 8761, fax: 020 7634 8946).

Alternative formats

5.6 A large print version of the summary section of this consultation is available. Copies of this consultation are available on disk and braille and tape formats of the summary can be provided on request.

5.7 Please contact the Oftel Research and Information Unit on 020 7634 8761, or email infocent@oftel.gov.uk, or call textphone 020 7634 8769 for more information.

Annex A – Proposed modifications to the CPS functional specification

A.1 If Oftel, following this consultation, were to conclude that it would be appropriate to include 192 and 153 within the CPS 'all calls' option, the CPS functional specification would need to be modified.

A.2 The proposed new functional specification (in the event of 192 and 153 being included within CPS 'all calls') is listed below. All the text remains as per the current version (2) with the exception of the text in italics (which is new) and the text with a strikethrough (which will be replaced by the new text).

FUNCTIONAL SPECIFICATION FOR CARRIER PRE-SELECTION (V3)

Definition

Carrier Pre-Selection (CPS) is the facility offered to customers which allows them to opt for certain defined classes of call to be carried by an operator selected in advance (and having a contract with the customer), without having to dial a routing prefix or follow any other different procedure to invoke such routing. CPS can be overridden by dialling an indirect access code of another operator (again where there is a contract between the customer and the operator).

Scope

Carrier Pre-Selection will be provided by the following originating operators:

• BT; and
• Kingston Communications,

on, or as soon as practicable after, 1 January 2000 (subject to any deferment agreed to by the Commission in the light of the timescales needed to introduce the facility, technically and geographically).

CPS facilities will be provided to any operator (referred to as the CPS Operator) which qualifies under Schedule 2 of the Interconnect Regulations and has established Points of Interconnection with the originating operator and been allocated a CPS prefix code and/or a Type B single stage indirect access code by Oftel.

Originating Operators will provide CPS facilities to all customers, on request of CPS operator, on direct exchange lines, including ISDN and Centrex lines (1). CPS will not be provided on public or managed payphone lines or lines on Low User Schemes.

Originating Operators shall support up to 100 CPS Operators on any switch. Where demand appears likely to exceed this limit, steps will be taken to develop further capacity.

Customer Options (2)

6. Customers opting to use CPS may take up both or either of the following options:
(a) International calls
(b) National calls
or they may make a single pre-selection for the following
(c) all calls, to include international, national, local, mobile, specially tariffed (eg freephone, local rate, national rate), premium rate, personal and paging

Customers opting to use CPS may select from the following options:

Option 1: International Calls
Option 2 : National Calls
Option 3 : All Calls (to include international, national, local, mobile, specially tariffed (eg freephone, local rate, national rate), premium rate, personal and paging)

If a customer selects Options 1 and 2 they can either have calls from both options carried by the same CPSO or by different CPSOs. In all other cases there is only one CPSO involved.

CPS will not apply to calls using Type A short codes (eg 100, 999, 112, 192), Type C (operator specific) short codes or the 0844 04yyxxx and 0808 99yyxxx number ranges used for unmetered interconnect Internet access.

CPS will not apply to calls using Type A short codes (eg 100, 999, 112) except those 3-digit codes used for directory enquiries services (192 and 153) for such time as these codes continue to be in use. CPS will also not apply to Type C (operator specific) short codes, five- or six-digit directory enquiries services (118XX(X) ) or the 0844 04yyxxx and 0808 99yyxxx number ranges used for unmetered interconnect Internet access.

Where no option is made, relevant calls will be routed according to the decision of the originating operator.

Local calls shall be interpreted as calls to those geographic destinations which are charged at local call rate by the originating operator.

Routing

Where a customer has elected to have calls routed by CPS, the following will apply:

1. calls to ranges subject to CPS (see paragraph six) will be routed according to the customer’s selected CPS Operator to an agreed Point of Interconnection; and

2. calls to ranges excluded from paragraph six will not be affected

Where a call is routed by CPS, the originating operator will prefix the customer’s dialled digits with the ‘CPS access code’ before passing the call across the Point of Interconnection. The CPS access code ensures routing through the originating operator’s network to the Point of Interconnection.

Where a pre-selected call is dialled using the local dialling format, the originating operator will insert the leading zero and area code between the CPS access code and the dialled number.

CPS facilities shall not apply to operator controlled calls, including transfer charge calls. Operator and other special services of CPS Operators will be accessed using the appropriate indirect access code.

A CPS access code will be a four digit non-diallable prefix (3).

Override

Calls made to Type B Indirect Access Codes will override CPS options and route to the operator identified by that code, without alteration to the digit string dialled by the customer

Billing

Responsibility for billing the calling customer on CPS and Indirect Access calls rests with the CPS Operator. Where no pre-selection or other form of selection has been made by the calling customer, the originating operator will bill for those calls.

CPS services

CPS calls will be provided as a standard interconnect service to qualifying CPS Operators.

Annex B – The current numbering formats for CPS call options

Current issue of CPS Functional Specification (Issue 2)

B.1 Customers opting to use CPS may take up both or either of the following options:

(a) International calls
(b) National calls

or they may make a single pre-selection for the following

(c) all calls, to include international, national, local, mobile, specially tariffed (eg freephone, local rate, national rate), premium rate, personal and paging.

Version 7 of CPS process document

B.2 Option 1 is International Calls.

B.3 Option 2 is National Calls.

B. 4 Option 3 is All Calls.

B.5 A customer can select Option 1 or Option 2, or Options 1 and 2, or Option 3 (no other combinations are possible).

B.6 If a customer selects Options 1 and 2 they can either have calls from both options carried by the same CPSO or by different CPSOs. In all other cases there is only one CPSO involved.

Version 5 of CPS IT Automation document (v5)

B.7 Refers to Option 1, Option 2, Option 1 and 2 and Option 3 in the ‘Data record’ table in section 7.1.3 (ie consistent with CPS Process document).