Contents

Summary

Chapter 1 Background

Chapter 2 Summary of responses to the proposals and the Director’s comments

Chapter 3 The Director’s conclusions and next steps

Glossary

Annex A List of respondents

Summary

S.1 Number portability enables subscribers to keep their telephone numbers when switching between suppliers of telecommunications services.

S.2 One of the difficulties faced by UK customers, when they are subject to a network closure, is that they risk losing their telephone numbers even if they have ported them to a new provider in advance of the closure. This arises because, under current porting arrangements, the donor network remains responsible for the onward routing of calls to the ported numbers.

S.3 Currently, the only way to avoid this loss of numbers is for another network to host the numbers of the failing network and carry out the necessary data build to allow them to function on its network. Currently there is no simple process for this and operators generally regard it as too costly and time consuming to arrange.

S.4 In the interests of consumers, the Director General of Telecommunications ("the Director") consulted on proposals to change the framework for number portability primarily to allow consumers to keep their numbers in the event of network closure. The Director set out two options but invited respondents to suggest others.

S.5 The first option was to make changes to the current system of onward routing to allow another network to take over the onward routing function of a failed network. This was viewed as a fairly short term solution.

S.6 For the longer term, the Director proposed that the UK move toward the creation of a central database of numbers. This follows the direction of the US and several European countries and avoids the problems associated with onward routing. It could also play a major part in enhancing the resilience of the UK telecommunications network in recovering from major disasters.

S.7 In this statement, the Director summarises and comments on the responses to his consultation of 14 June 02 and draws his conclusions on next steps.

S.8 With regard to the short term proposal, the responses from industry – whilst demonstrating some intention to recognise and rectify the problem – did not propose a solution acceptable to the Director. The Director therefore plans to engage directly with industry in more detailed discussions and publish the results of his endeavours, subject to satisfactory progress, by next spring.

S.9 Turning to the longer term proposals, the Director explained that Oftel would carry out a Regulatory Option Appraisal (ROA), including an analysis of the costs and benefits of introducing a centralised database, and therefore invited industry to submit cost information in their responses to the consultation. Insufficient information was provided by industry on which Oftel could draw any early policy conclusions. The Director will therefore seek to collate such material as he can in order to produce a ROA in accordance with the guidelines published on 28 June 02. When this is completed, the Director will publish his analysis and carry out a further public consultation. This phase is expected to take around six to nine months.

Chapter 1

Background

Introduction

1.1 Number portability is the name given to a facility that enables subscribers, who so request, to be able to keep their telephone number(s) on the public telephone network independently of the organisation providing service.

1.2 It is recognised by the European Union as a key facilitator of consumer choice and effective competition in a competitive communications environment; subscribers being reluctant to consider changing their provider if this means they have to change telephone number(s). As such, number portability has been a requirement in respect of fixed services under EU law since 2000 and will be extended to mobile services from July next year.

1.3 The UK recognised the benefits to competition of requiring number portability in the early 1990s. Under UK licences, fixed operators were required to port numbers, on a reciprocal basis, to another operator who requested it from 1997 and, on a similar basis, mobile operators were required to provide mobile portability from 1999.

Implemented solutions

1.4 The UK’s leading role in the introduction, by regulation, of number portability led it to consider, in 1994, the costs and benefits of implementing geographic number portability which factored in different methods of implementation. At this time, analysis showed that the net benefits, of what was described as a total Intelligent Network solution, were strongly negative. Today this approach would more commonly be referred to as all-call-query ("ACQ"). Call redirection options, which includes what we now call onward routing, and call re-routing options (which includes call dropback and query-on-release ("QoR") made a less significant difference to the overall outcome of the cost/benefit exercise.

1.5 The chosen method of implementation developed by industry through the Network Interoperability Consultative Committee ("NICC") was onward routing, with an enhancement to avoid inefficient routing for calls to ported geographic numbers originating in the recipient exchange.

1.6 In the case of the porting of non-geographic numbers, industry via the NICC, opted for a similar onward routing solution with a call trap option. The latter enabling an originating operator, at its discretion, to filter out a number which has been ported to itself. This reduces the degree of tromboning and, thereby, improves routing efficiency. Industry also identified ACQ as a future solution; migration to ACQ requiring the introduction of a centralised number administration.

1.7 With regard to mobile networks, calls cannot be delivered to mobile subscribers simply by means of analysing the digits dialled because a mobile can be anywhere in the mobile network or even roaming on another network. To deliver a call a routing enquiry is made to a Home Location Register (HLR) to determine where the subscriber is located and to obtain a routing number. The solution for mobile number portability, known as the Signalling Relay Function (SRF), is that the donor network sends the routing enquiry signal addressed to a ported number to the appropriate recipient network for treatment. In this way the recipient network can provide the routing number to complete the call. Where a called party is roaming, the SRF will cause the call to be routed direct from the donor network to the roaming network and will not enter the recipient network which causes several problems. To overcome this, a Direct Routing Override Function (DROF) is defined which forces calls to ported numbers into the recipient network.

1.8 In principle, the implemented solution for mobile number portability, like those for fixed, can be described as onward routing. A call to a ported number is usually delivered by the originating network to the donor, who identifies the recipient and subsequently "onward routes" the call to the appropriate recipient network.

1.9 These technical and other principles necessary to support the provision of Portability between operators are set out in the Director General of Telecommunications’ ("the Director’s") Number Portability Functional Specification.

The June 2002 consultation

1.10 On the 14 June 2002, the Director consulted on proposals to change the framework for number portability. The Director’s prime objective was to propose changes to the current framework in order to ensure that, in the event of the failure of a telecoms operator, end users transferring or having already transferred to another operator can keep their original number. This objective took into consideration legal requirements, the effectiveness of, and consumer confidence in, number portability in the light of concerns arising from, in particular, the failure of Atlantic Telecom in November 2001. Affected end users, both Atlantic customers and customers of other service providers who had ported their telephone numbers from Atlantic, lost telephone service on their numbers. Even after these customers secured a replacement service, they were unable to retain their original numbers thus incurring such costs, at short notice, as are associated with a number change such as reprinting stationery and signage in the case of business customers.

1.11 In questioning whether onward routing should be developed or replaced, Oftel highlighted several other actual and potential problems with the currently implemented number portability solutions. In particular the efficacy of the solution looking forward, the lack of an effective block transfer process, the additional costs of conveyance, potential network congestion and the disincentives to set-up service establishment. Moreover Oftel opined that enhanced number portability technology could offer significant benefits to the overall resilience of the UK communications network.

1.12 Oftel set-out two broad options in its consultation. These were:

• to improve the onward routing system by ensuring that the donor network function is performed by another network provider when a network closes, and/or

• to adopt an alternative system, which would additionally remove the other identified difficulties of the implemented solutions and give greater network resilience overall.

1.13 A summary of the issues raised by the respondents and the Director’s comments are set out in chapter 2 and his conclusions are explained in chapter 3. A list of respondents can be found at annex A.

Chapter 2

Summary of responses to the proposals and the Director’s comments

Introduction

2.1 The Director received twenty one responses to his consultation on proposals to change the framework for number portability. A list of respondents can be found at Annex A.

2.2 7 responses were from parties who may be viewed as potential vendors. The Director is grateful to them for sharing their knowledge - particularly about central database solutions - and experience of delivering such projects in other countries. This helped the Director to more fully understand the issues and complexities involved. The Director notes that most of these responses did not opine on regulatory policies.

The justification for change

2.3 Consumers, consumer groups and the Scottish Executive all supported the contention that the failure of Atlantic Telecom clearly demonstrated an urgent need to change the framework for number portability.

2.4 In the main, fixed operator responses recognised the concerns of customers facing possible loss of service because their supplier ceases to trade and indicated some willingness to find short term solutions. However several companies felt that the circumstances surrounding the failure of Atlantic were unique and, whilst the prospect of telecoms operators going out of business may remain high, the probability of no buyer being found was viewed as remote.

2.5 In response to the actual or perceived weaknesses of the current arrangements set out in the Director’s consultation, in general, fixed operators rejected the idea that such issues had a material effect on their view that onward routing remains the most efficient solution for number portability at this time.

2.6 The Operators Group, OPF number portability sub-group and BT whilst not explicitly rejecting the Director’s view that enhanced porting technology might make a contribution to the resilience of the UK telecommunications network and its ability to recover from a major disaster (such as occurred in New York on 11 September 01), suggested that number routing rather than porting technologies enabled a rapid re-routing of traffic destined for numbers hosted on destroyed exchanges.

2.7 2 of the 3 responses from mobile operators considered economic efficiency to be the justification for change rather than the failure of telecoms operators.

Director’s comments

2.8 The Director made clear in his consultation that the present situation, whereby customers of a failing operator and customers of other operators who ported their numbers from the failing operator could lose their telephone numbers, is unacceptable. Moreover he explained why this position was consistent with his regulatory objectives regarding both competition and consumer protection.

2.9 Furthermore, the Director does not regard the failure of Atlantic as unique. Whilst the details of any company failure are specific to each case, there are common underlying themes which may recur.

2.10 The Director notes that, in the main, most industry respondents maintained that onward routing remains the most efficient solution for UK number portability at this time. He agrees with respondents that a significant factor in any decision to migrate to an alternative solution should be the conclusions of any evaluation of the relative costs and benefits. Indeed the Director intends to produce a Regulatory Option Appraisal ("ROA") in respect of longer term solutions.

2.11 However, whatever the most efficient solution may be, the solution itself must deliver users’ number portability rights. In the circumstances of a failed network there is a risk that the current arrangements may not allow the right to number portability to be maintained. It is for this reason that changes primarily need to be made.

Is this about number portability?

2.12 Several respondents commented that whilst customers may want to retain their numbers, most would view continuity of service or rapid restoration of service as more important. Some respondents argued that number portability did not apply where a customer needs to change companies because their current company is unable to serve them. Indeed one respondent pointed out that most of the changes and costs required to transfer customers of a failed operator to a new one and retain their number would arise even in the absence of number portability. In this sense this was about re-hosting customers not about number portability.

Director’s comments

2.13 In making such conclusions, respondents fail to de-couple number retention from service provision and to take due account of the fact that it is not only customers of the failed operator who will risk losing their numbers but also ported customers of other operators. The Director acknowledges concerns about loss of service and notes that this matter was subject to Government public consultation. However, regardless as to whether a solution can be found to continuity of service, the Director believes that this does not imply that the issues surrounding number portability cannot or should not be resolved.

2.14 An operator which ceases to run its network cannot perform the necessary onward routing solution currently deployed to support number portability - ie where a customer has switched to another operator and ported their number. It is self evident then that this flaw in onward routing raises consumer protection issues. Moreover it may potentially harm confidence in number portability and inter alia have damaging consequences for competition.

2.15 As noted in the consultation document, the current regulatory regime imposes obligations on the Director in relation to number portability. Furthermore, the new EU regulatory framework (due to come into force in July 03) also sets out obligations in relation to number portability. In particular, Article 30 of the Universal Service Directive (2002/22/EC) requires that the UK "...shall ensure that all subscribers of publicly available telephone services, including mobile services, who so request can retain their number(s) independently of the undertaking providing the service". It is proposed that this requirement will form part of the general conditions under the new regime, which were consulted on in May 02. The right to number portability exists regardless of the motivation behind a subscriber’s request for number portability.

2.16 In making his proposals, the Director considered that in broad terms the solutions lay in either making provision for the onward routing function to be transferable in certain circumstances or to adopt an alternative solution. The transfer of the onward routing function would seemingly imply re-hosting. Therefore re-hosting and the provision of number portability are clearly linked.

Short term versus longer term options

2.17 All 3 responses from mobile operators supported the longer term aim of a central database approach and rejected investing in enhancements to the current onward routing solution. 2 of the respondents were of the view that migration to a new framework should occur when it is justifiably the most cost effective solution for the UK and that Oftel should carry out a cost benefit analysis to determine this. Another respondent disagreed and maintained that a central database approach should be deployed now as the current arrangements both failed to protect consumers and positively hindered the development of innovative services. In this case, a cost benefit analysis was suggested as a means of determining which variation(s) of the longer term option (eg QoR, ACQ or hybrid) should be deployed.

2.18 Consumers generally regarded as crucial the speed of putting in place arrangements to enable customers to retain their numbers should their supplier fail. In this respect, whilst most recognised the potentially wider benefits of a central database approach as being the preferred option but some way off, enhancements to onward routing should be pursued concurrently in order to deploy effective contingency arrangements rapidly.

2.19 The fixed operators generally presented a more sceptical view of the central database approach, in several cases pre-determining the outcome of any ROA as failing to demonstrate that the benefits would outweigh the costs and therefore concluding that such an approach would be disproportionate. Some operators suggested that the emergence of new technologies might offer alternative technical solutions. Several respondents suggested that the Director was indirectly seeking to secure other numbering policy ambitions such as individual number allocation and sought further consultation on numbering aims. In general, fixed operators maintained that onward routing is and will remain for the foreseeable future, the most efficient and cost effective solution for number portability in the UK.

2.20 Those fixed operators who supported the joint response from the Operators Group, OPF number portability sub-group and BT (the majority) also rejected the short-term approach outlined by the Director, describing it as technically unachievable and commercially not viable. However these respondents recommended a possible alternative option which de-coupled the issue of deploying line plant to affected customers. Other operators also presented ideas focused on expediting the transfer of number blocks from the failed operator through to speeding up industry data build and reducing the particular problems faced in dealing with a company in administration.

Director’s comments

2.21 The Director wishes to clarify that any assessment of the longer term options would not solely be based on costs and benefits but would follow the ROA guidelines which he published in June 02. Oftel will carry out this exercise and share its analysis and findings with stakeholders. Several respondents claimed that the creation of a central database and the range of solutions that might function with it, would not produce sufficient benefits given the alleged high capital expenditure and would therefore be disproportionate. The Director considers that such strong positions may have been reached with little or no supporting evidence of either the high costs of implementing a central database solution or indeed any detailed economic assessment of costs and benefits.

2.22 As regards numbering policy ambitions, the Director wishes to make clear that any central database would initially be for the purpose of number portability. The Director does not currently have powers to allocate numbers individually to end users. The Communications Bill in its current form provides Ofcom with these powers. However, should Ofcom wish to consider a policy change in this respect, they would consult fully on any proposed changes to allocations.

2.23 The Director concurs with consumers that contingency arrangements need to be in place sooner rather than later. 

The short term solution: improvements to the onward routing system

2.24 Most fixed operators set out a range of commercial and technical hurdles to the transfer of number blocks from the failing operator to another, particularly (from a commercial perspective) where such a transfer is forced upon an operator(s) against their commercial judgement. The main technical problem, aside from interconnection issues, was the transfer of 10k geographic number blocks between networks with different network coverage areas. This issue, whilst not insurmountable technically speaking, would seemingly present problems where there was a requirement to provide service to customers whose geographic location did not match the geographical area of an operators network associated with a particular number.

2.25 Fixed operator respondents expressed no agreed position on how an operator or operators might best be chosen to take-on the failed operator’s blocks although most agreed that some form of distribution across relevant players would seem equitable.

2.26 However most fixed operators recommended a possible arrangement whereby the number blocks of a failed operator might be transferred, perhaps temporarily, to a new operator that might not supply physical lines connected to the numbers. Instead a range of network based services such as voicemail, call forwarding and change number announcements might be provided to those customers who wanted to ensure that callers to their old numbers could continue to contact them whilst providing sufficient time to manage a change to a new number.

2.27 Other proposals focused on the issues surrounding the transfer and re-hosting of blocks. Proposals included the separation of number ranges into smaller blocks for wider distribution amongst industry, the mandatory escrow of essential data – particularly customer records - to a neutral third party to facilitate rapid re-hosting of numbers, and due discrimination of BT data build in order to prioritise network changes surrounding re-hosting.

Director’s comments

2.28 The Director considers it relevant to note, in the context of the concerns expressed by certain fixed operators, the consideration given to issues surrounding continuity of service by the Department of Trade & Industry ("DTI") as part of its consultation on the matter. The Director observes that the DTI, having considered the responses to its consultation, has published its conclusion that there is not a strong enough case for changes to the current framework for continuity of service largely because of the cost to consumers of the options identified. 

2.29 The Director is not persuaded that issue of network topology creates any major obstacle to the transfer of blocks from the failed operator to another, where there is a disparity in geographic coverage areas, and where the new operator seeks or is required to provide service to the customer. Current portability techniques or Intelligent Network ("IN") solutions (whichever is most efficient in particular circumstances) could be deployed to re-direct calls between network nodes in order to deliver calls to numbers which are outside normal coverage areas. However, provision of service was not the subject of the Director’s consultation. His reason for proposing the re-hosting of number blocks was based on the principle of transferring the donor network function, recognising this to be critical to the solution of onward routing upon which the provision of portability is dependent. Such a transfer would support both continuity of service and number retention for ported subscribers albeit not necessarily without disruption. Moreover it would facilitate eventual number retention to customers of the failed operator whether they chose to take service direct from the operator(s) taking on the donor network function or from any other operator. The Director believes that the practical suggestions for expediting re-hosting made by some respondents warrant further consideration. For the avoidance of doubt, the Director wishes to re-emphasise that the Functional Specification requires a transfer process and notes that industry is currently reviewing this.

2.30 The Director notes the proposal to provide affected customers with temporary network based services to ease migration to a new number. This, at least, demonstrates that industry recognises that some form of initiative is necessary. However, such a proposal clearly falls short of enabling subscribers to keep their numbers independently of the company providing service and is therefore unacceptable.

The long term solution: a central database

2.31 As mentioned earlier, all 3 mobile operator respondents supported moving to a direct routing solution. Of these 1 respondent expressed an opinion that a database of ported mobile numbers could be set up first to enable any UK mobile originated call to be routed directly to the recipient operator and subsequently extended out to fixed operators. 1 mobile operator felt that if, in future, a centralised database and IN solution were to be deployed then it would move to an ACQ solution believing that QoR would fail to realise sufficient benefits to warrant adoption.

2.32 Unlike the mobile operators, all fixed operators set out their opposition to the creation of a central database and direct routing of calls to ported numbers whether triggered by way of ACQ or QoR. Objections were many and varied but at the heart of most responses was the capital expenditure - suggested by some respondents as being at least £10s of millions and possibly in excess of £100 million - associated with such solutions particularly given the current difficult trade conditions in the telecommunications market and general scarcity of cash. Indeed some respondents suggested that direct routing solutions were unlikely to be based on IN using Public Switched Telephone Network ("PSTN") legacy networks. Rather where the deployment of voice services was to be based on Internet Protocol ("IP") there was more likelihood of significantly lower (perhaps by a factor of 10) cost implementation of a centralised database solution.

2.33 Other respondents expressed concern about the distortion such a solution might have on the wholesale market. A "build or buy" approach, particularly with regard to an ACQ approach, was likely to result in only a few networks providing portability capability to which traffic would be transited.

2.34 Other issues included concerns about the effect of such a solution on call quality particularly the likelihood of increased post dial delay, network security, impacts on the provision of emergency and directory enquiry services.

Director’s comments

2.35 The Director acknowledges the concern of operators about the cost of implementing a central database solution. A central issue for the ROA would be the trade-off between these costs to industry, and the benefits to consumers from a more reliable approach to number portability.

2.36 The Director is aware from experience in other countries that the implementation of the central database itself will only represent one element of the total cost. Work may also be required on operators’ switches, signalling links, and Operational Support Systems ("OSS"). Oftel cannot, however, estimate the actual cost of such upgrades without detailed input from operators, and it has not yet received such input. This will be an essential contribution to the ROA.

2.37 The Director is aware of industry interest in voice over IP. However he notes that he has yet to see any serious deployment to replace the PSTN. Whilst the Director did not specify that any solution had to be IN based he is very reluctant to delay the development of policy until voice over IP becomes ubiquitous.

2.38 The Director notes those comments expressed by respondents regarding an outcome where only a few networks provide a portability capability. He does not consider this to be necessarily negative but evidence that investment in a central database solution may be minimised by commercial decision making (build or buy).

2.39 Several of the other concerns expressed by operators are a function of the detailed system solution chosen. For example, network security can be maintained by appropriate design of the central database and associated links, costs can be minimised by not immediately moving to an ACQ solution, and post-dial delay can be minimised by ensuring that operators are not required to submit real-time queries to the central database. The Director, whilst acknowledging that such issues need to be taken into consideration, is not persuaded that the use of IN causes significant deterioration in quality of service. Indeed he notes IN platforms are widely used today for the provision of, for example, freephone products without significant problems.

2.40 The Director made clear in his consultation document that he was keen to work with industry to develop a potential solution that would minimise costs to industry, whilst also addressing the various performance issues. Whilst he acknowledges some of the concerns raised by industry, he also believes that appropriate solutions may exist. Further analysis is required (a formal technical feasibility study) before the Director can reach any definitive conclusions.

Other comments

2.41 Some respondents also supplied responses on more detailed questions, set out in the annexes to the June 02 consultation, regarding technical specifications and cost allocation principles.

2.42 The Director notes these responses but does not consider it helpful to set out these issues in this statement given its focus on broader policy issues. However, the Director will take these responses into account when it is appropriate to do so.

 Chapter 3

The Director’s conclusions and next steps

General

3.1 The Director reaffirms that subscribers’ rights to be able to keep their numbers, irrespective of who their supplier is, are paramount. The flaw in current onward routing arrangements, as set out in both the June 02 consultation and again in this statement, must be rectified or else an alternative solution found and implemented. Moreover the Director concurs with those respondents, particularly consumers, who consider that a solution must be found which can be implemented sooner rather than later.

3.2 The Director, having considered the responses to his consultation, concludes that the immediate priority is to work with industry to find and implement proportionate enhancements to the current onward routing arrangements that meet his stated objectives. This approach, coincidental to industry’s own review of the block transfer process, is more likely to deliver the required outcomes in a proportionate and certainly, timely, way. Subject to satisfactory progress being made with industry, the Director intends to produce a further statement on the short term arrangements in the spring.

3.3 The Director indicated in his consultation document that the block transfer process was part of the original functional specification for portability and was encompassed by the original cost benefit analysis. The Director commented that it could therefore be argued that further analysis is not required. The Director maintains this view at this time.

3.4 Concurrently, Oftel will develop a ROA on the longer term options and draw policy conclusions following further consultation during 2003. The Director wishes to emphasise the importance of operators providing quantitative input into the ROA.

Glossary

Block transfer: The facility to transfer a number block from one operator to another.

Central database: A database managed by a neutral third party and containing details of all ported numbers. Operators download information from this database in order to route calls to the appropriate destination.

DTI: Department of Trade and Industry.

Donor operator: An operator whose customer number(s) are in the process of being, or have been passed or ported to a recipient operator.

End user: A person using or requesting publicly available telecommunications services.

Functional specification: A document published from time to time by the Director General, following consultation with all Licensees, which specifies technical and other principles which are intended to enable the efficient implementation and utilisation of portability.

Geographic numbers: Ordinary telephone numbers of subscribers at a fixed geographic location eg those beginning with 01 or 02.

NICC: Network Interoperability Consultative Committee.

Non geographic numbers: Numbers that do not refer to a fixed geographic location eg freephone numbers (080), premium rate numbers (090).

Number block: A number range, normally of 10,000 numbers. It is used for allocating numbers to network operators who then allocate individual numbers to customers. The sizes of blocks for the different parts of the National Numbering Scheme are currently identified in the Numbering Conventions.

Number portability: A facility that enables subscribers, who so request, to keep their number independent of the organization providing service.

Ofcom: Office of Communications.

Oftel: Office of Telecommunications.

Onward routing: The system adopted for portability for geographic, non-geographic and mobile numbers, whereby calls to ported numbers continue indefinitely to be routed via the switches of the donor operator.

Operator: Any person authorised to provide telecommunications services not being prohibited from receiving any financial benefit from such provision of such services.

OSS: Operations Support Systems – the IT systems required to support the operation of a telecommunications network (customer service, network management, billing etc).

Portability: Any facility provided by Licensees or service providers which enables a Subscriber who requests Number Portability to continue to be provided with service on the same number regardless of who provides that service.

Recipient operator: An operator to whom customer number (s) are in the process of being, or have been passed or ported from a donor operator.

Service provider: Any person who is the business of providing telecommunications services of any description.

Subscriber: Any natural or legal person who or which is party to a contract with a provider of publicly available telecommunication services for the supply of those services.

Tromboning: A loop in call routing through a Transit or Range Holder network, occupying an ingress and egress circuit for the duration of the call.

 Annex A

List of respondents

A.1 The consultation document on proposals to change the framework for number portability was published on 14 June 2002 and responses requested by 13 September 2002. Responses were received from:

1. Advisory Committee on Telecommunications, Chairmen’s Group;
2. BP International Ltd;
3. British Telecommunications plc;
4. Cable & Wireless;
5. Cartesian Limited;
6. Core Telecommunications;
7. Energis;
8. Hutchison3G;
9. NeuStar;
10. Nortel Networks UK Limited;
11. Northern Ireland Advisory Committee for Telecommunications;
12. Operator Group, Operator Policy Forum for number portability and BT;
13. Orange;
14. Porting XS;
15. Scottish Advisory Committee on Telecommunications;
16. Scottish Executive;
17. Siemens Business Services Limited;
18. Telcordia Technologies, Inc;
19. Telspec Europe Limited;
20. Transaction Network Services (UK) Limited; and
21. Vodafone.

A.2 In this statement references to responses from consumers or consumer groups refers to respondents at 1, 2, 11, 15 and 16. Likewise potential vendors refers to those listed at 5, 9, 14, 17, 18, 19 and 20.