A Statement issued by the Director General of Telecommunications following a consultation on proposals to publish a National Telephone Numbering Plan.

Contents

Summary
Chapter 1 - Introduction
Chapter 2 - General comments
Chapter 3 - Specific comments on the National Telephone Numbering Plan

Annex A - Non-confidential respondents to the Consultation Document

Annex B - The National Telephone Numbering Plan, published by the Director General of Telecommunication on 9 July 2003

Annex C - General Condition 17 ("Allocation, Adoption and Use of Telephone Numbers"), contained in the Schedule to thdraft Electronic Communications (General Conditions) Regulations 2003, published by the DTI on 7 July 2003
Glossary

      Summary

S1. The document in Annex B to this Statement is the National Telephone Numbering Plan (‘the Plan’), published today to accompany the General Conditions of Entitlement, which are contained in the Schedule to the draft Electronic Communications (General Conditions) Regulations 2003 (the ‘Regulations’). The Plan is part of the new regulatory framework for Telephone Numbers following implementation of the new EU Directives S2. The version of the Plan in Annex B is the version which will apply if the Communications Bill does not receive Royal Assent by 25 July 2003 and the Regulations are made. The Plan sets out the numbers available for Allocation by the Director General of Telecommunications (the ‘Director’) as Telephone Numbers, together with such restrictions on the Adoption and other use of those numbers as the Director considers appropriate.

S3. This Statement follows on from the Consultation Document, ‘The National Telephone Numbering Plan’ of 19 March 2003 (www.oftel.gov.uk/publications/numbering/2003/ntnp0303.htm). To a great extent the Plan reproduces restrictions on numbering use already contained in the Numbering Conventions for the United Kingdom (Issue 6, 7 March 2003) and the Numbering Code for the United Kingdom (Issue 1, 30 November 2001).

S4. The key changes of note that result from the implementation of the new framework will be that-

• Those who Adopt or otherwise use any number listed in the Plan shall not do so other than in accordance with the applicable designation given for that number;

• There are three types of Telephone Number: (i) those regulated by Oftel; (ii) those not regulated by Oftel but which may be subject to future regulation; and (iii) those not regulated by Oftel and subject to an Exclusion Order by the Secretary of State for Trade and Industry (or exclusion in the Regulations);

• Many terms, for example ‘Geographic Number’ and ‘Mobile Number’, are now specifically defined in a discrete ‘Definitions and Interpretation’ section of the Plan; and

• Oftel has introduced rules on Telex Numbering.

  Chapter 1

Introduction

The National Telephone Numbering Plan

1.1 The document in Annex B to this Statement is the National Telephone Numbering Plan (‘the Plan’), published today to accompany the General Conditions of Entitlement, which are contained in the Schedule to the draft Electronic Communications (General Conditions) Regulations 2003 (the ‘Regulations’).

1.2 The Regulations were published by the DTI on 7 July 2003 (see http://www.communicationsbill.gov.uk/Interim_Implementation_revised.html). The Regulations will be made (and hence the General Conditions of Entitlement, and the Plan, will be given legal force) in the event that the Communications Bill does not receive Royal Assent by 25 July 2003 (see below).

1.3 The Director-General of Telecommunications (the ‘Director’) is today publishing the Plan and the publication date will be inserted in Part 1 of the Schedule to the said Regulations, where the definition of ‘National Telephone Numbering Plan’ appears. As this version of the Plan is the version that will apply if the Regulations are made, it refers to the Regulations rather than the Communications Act.

1.4 This Statement follows on from the Consultation Document, ‘The National Telephone Numbering Plan’ of 19 March 2003 (www.oftel.gov.uk/publications/numbering/2003/ntnp0303.htm) (the ‘Consultation Document’). A number of obligations in General Condition 17 ‘Allocation, Adoption and Use of Telephone Numbers’ (the ‘Condition’) (reproduced at Annex C of this Statement) refer to the Plan. The Plan sets out the numbers available for Allocation by the Director as Telephone Numbers (‘Telephone Number’ is defined in the Regulations). The Plan also sets out the restrictions on the Adoption (as defined in the Regulations) and other use of Telephone Numbers as the Director considers appropriate. To a great extent the Plan reproduces restrictions on numbering use already contained in the Numbering Conventions for the United Kingdom (Issue 6, 7 March 2003) (the ‘Numbering Conventions’) and the Numbering Code for the United Kingdom (Issue 1, 30 November 2001) (the ‘Numbering Code’). A number of definitions from the Plan are also incorporated in the Annex to the Condition (also at Annex C), which sets out certain Telephone Numbers the use of or, where specified, the Adoption of which is restricted through the Condition.

Differences between implementation via the Bill or Regulations

1.5 The Regulations are intended to be made to come into force on 25 July 2003 as part of an interim SI package to implement the four new EU Directives on electronic communications (should the Communications Bill not receive Royal Assent by that date).

1.6 For further information about the Communications Bill and the new Directives please see Chapter Two of the Consultation Document.

1.7 Should the Bill come into force in time to implement the Directives, the Director using powers under the new Communications Act will implement the general conditions of entitlement. In this case, the Bill version of the general conditions (as consulted on by Oftel) will be finalised and brought into effect instead of the version of the general conditions intended to be incorporated into the Regulations. The Director will then publish the Plan under powers in the new Communications Act (which will be contained in Section 53 if the clause numbers in the Bill are not further amended). Such publication will broadly follow the Plan at Annex B but will be amended so as to take into account the fact that there has been a Bill implementation rather than implementation through Regulations. In this event, the version of the Plan at Annex B of this Statement should be discarded.

1.8 Further information about the background to the general conditions, the new regulatory regime in general and the Plan can be found in the Consultation Document.

Chapter 2

General comments

2.1 The comments received in response to the Consultation Document dealt with points both general and specific. This chapter deals with some general comments received on the new numbering framework. The next Chapter goes through specific comments on the Plan.

Telephone Numbers outside of the Plan and the Annex to the Condition

2.2 There has been considerable concern within the industry about the issue of their use of Telephone Numbers. Telephone Number is defined widely in the Communications Bill and the Regulations but Oftel will only be responsible for such numbers as it regulates (ie, as set out in Plan and the Annex to the Condition). Other Telephone Numbers could come within Oftel’s remit in the future, subject only to an Exclusion Order that the DTI has consulted on with regards to Internet and Domain Name numbering (the draft Telephone Number Exclusion (Domain Names and Internet Addresses) Order 2003 (the ‘draft Exclusion Order’, available at www.communicationsbill.gov.uk/Orders_Regulations.html. It should be noted that if the Communications Bill does not receive Royal Assent by 25 July 2003, then exclusions from the definition of Telephone Number will be dealt with in the Regulations (and any amendment to those exclusions would of course need to be dealt with by an amendment to those Regulations).

2.3 In response to the DTI’s consultation on the draft Exclusion Order operators argued that the scope of the Order should be extended to exclude numbers allocated (a) by other regulatory bodies i.e. numbers allocated by overseas countries or the ITU. (b) undiallable intra-network routing codes within the BT network, and (c) private network numbers which are not part of the Oftel numbering plan. The operators were unclear as to the status of these categories of numbers that were neither included in the Plan, which Oftel has recently been consulting on, nor excluded by the draft Exclusion Order.

2.4 As stated above, Oftel currently regulates none of these categories of Telephone Numbers, as Oftel has not included any of them in the Plan or Annex to the Condition. Oftel has no current plans to regulate such categories of Telephone Numbers. If it was considered necessary to regulate such numbers at any point in the future, then the Director or, once they assume their duties, Ofcom would be bound to carry out a full public consultation on any extension of areas of regulation in numbering and any decision to extend into these areas would be subject to full rights of appeal.

2.5 Operators suggested that extending the draft Exclusion Order would bring more certainty, but that could undermine the Director’s or Ofcom’s ability to manage numbering effectively in the future. For example if the use of intra-network codes was in conflict with inter-network codes, then there might be a need to intervene and if intra-network codes were excluded from Oftel’s remit then Oftel would be unable to deal with any such problems without a new exclusion order being made (or an amendment to the Regulations, if the new Directives are implemented by statutory instruments). Whilst the definition of ‘Telephone Number’ in the Communications Bill and the Regulations is broad, only those Telephone Numbers within the Plan and Annex to the Condition are subject to Oftel regulation. All other Telephone Numbers (as defined in the Communications Bill/ the Regulations) may continue to be used by operators subject only to the possibility that the industry may request, or market forces may require, future regulatory intervention. Of course such intervention would then be subject to consultation, as set out above. Oftel would reiterate that the new regulatory framework is not intended to introduce new, more burdensome regulation, but to reflect current policy. Any changes to that policy would require full consultation.

2.6 The following diagram is intended to be of assistance:

2.7 Any Telephone Numbers that are in the white box on the left are subject to Oftel control through the Plan or Condition. All other Telephone Numbers i.e. those falling within the large grey area may be Adopted or otherwise used by Communications Providers without restriction by Oftel. Examples of such Telephone Numbers outside of Oftel’s control are Short Codes and inter- and intra-network numbers not beginning with ‘0’ or ‘1’. However, such Telephone Numbers may be subject to regulation in the future, subject to consultation.

2.8 Those numbers in the smaller white box on the right of the diagram are numbers that are excluded from the definition of ‘Telephone Number’ by the draft Exclusion Order/the Regulations. Such numbers cannot be taken under Oftel’s control, and may be used without restriction by Communications Providers

Short Codes

2.9 A comment was made that Short Codes should be brought within the Plan so as to place on record their status as self-regulated. This indicates a misunderstanding of the Plan: Telephone Numbers cannot be within the Plan and at the same time self-regulated - if they were in the Plan they would be under Oftel’s control.

Responsibility for numbering rules

2.10 There were responses to the Consultation Document that suggested Oftel should change its policy on responsibility for rule keeping, and be prepared to directly tackle End-Users or intermediaries who use numbers in ways other than as directed in the Plan. Oftel would emphasise that the Condition applies only to Communications Providers (and cannot be extended to cover End-Users). Paragraph 17.8 of the Condition imposes an obligation on Communications Providers to take all reasonably practicable steps to secure that its Customers, in using Telephone Numbers, comply with the Condition and, where applicable, the Plan. In addition, the Condition imposes restrictions on Communications Providers more widely, not just Providers who have been Allocated Telephone Numbers by the Director.

2.11 However, some misuse by non-providers could fall within the persistent misuse rules as set out in Oftel’s Statement of policy on the persistent misuse of an electronic communications network or electronic communications service, 26 June 2003. As such Oftel would have means, other than the Numbering Condition or Plan, for tackling such difficulties.

NTS Regime & PRS redesignation

2.12 There were comments on the Consultation Document to the effect that the references to Local or National Rate for 084/ 087 in the Plan were imprecise as the actual rates charged by Communications Providers varies and often bares little relation to the actual cost of geographic calls. Oftel has sympathy with this view but this is something it is proposing to raise in a wider consultation on the NTS framework and therefore cannot be addressed in this Statement.

2.13 Another comment was made that the final sentence of Premium Rate Services (‘PRS’) definition should be deleted as trials of Higher Rate Premium Rate services are likely to increase the pence per minute and call price cap beyond those stated. Oftel agrees with this view, but could only amend the definition following a consultation, which is intended to be carried out in due course

Numbers within the Plan definitions

2.14 One respondent to the Consultation Document questioned the use of numbers in the Plan definitions (eg, as in the phrase "0845 Local Rate numbers"). Oftel believes that it is appropriate to put numbers into definitions where it is necessary to tie these together and provide greater clarity than would be the case were numbers not present.

Directory Enquiry legacy issues

2.15 Comments were received in response to the Consultation Document on the issue of Directory Enquiry legacy codes. Numbering policy about the future use of those codes has been subject to a separate consultation exercise and final policy laid out in ‘The Future Use of Legacy Directory Enquiry Numbers: a Statement’ of 3 June 2003 (www.oftel.gov.uk/publications/consumer/2003/dq0603.htm). The conclusions set out in that statement are reflected in the final version of the Annex to the General Condition. In response to a comment made in the consultation on the draft Exclusion Order in relation to this issue, which stated that it was unclear whether ‘192’ and ‘153’ would continue to be regulated once they have been deleted from the Annex to the Condition, Oftel would now clarify that once 192 and 153 have been deleted from the Annex, they will fall within Numbers beginning with ‘1’ which have been designated ‘Access to a number unobtainable tone or equivalent message’.

Third Party Pay for Product & Higher Rate PRS ranges

2.16 One respondent commented that the Plan should take into account the imminent launch of Third Party Pay for Product & Higher Rate PRS ranges. However, these services, which concern PRS that would be more expensive or less obviously controlled than those which operate at present, were outside of the scope of the Consultation Document. Indeed, there is far too much uncertainty about the policy aspects of these services, including, importantly, consumer protection, for Oftel to make numbering available at this stage. Any changes necessary to the Plan in relation to these issues could therefore only be made following a specific consultation.

Future changes and general guidance

2.17 As was the case with the Numbering Conventions, changes to the Plan will continue to be necessary over time – the Plan is therefore a ‘living document’ (although, if the version of the Plan at Annex B comes into force, ie, if the new EU Directives are implemented through the Regulations and other statutory instruments, then changes to the Plan could only be made alongside an amendment to the Regulations which would refer to a new published version of the Plan). In relation to the guidance on Numbering Policy referred to in the Consultation Document, Oftel agrees with respondents that it would have been helpful if that guidance had been made available at the same time as the draft Plan but this was unfortunately not possible, and it is intended that the guidance will be published later this year. However, with the exception of 3-week allocation timetable many of the broad rules remain unchanged from the old regime so applicants can refer back to see their basic obligations and what can be expected from Oftel. The Consultation Document stressed that this was a case of continuity rather than change and it appropriate to re-stress this here. There will of course be an opportunity to comment on the draft guidance once it is produced.

Chapter 3

Specific comments on the National Telephone Numbering Plan

Definitions and Interpretation removed from/not included in the Plan

Caller

3.1 In response to the Consultation Document a comment was received to the effect that the definition for ‘Caller’ should refer to the cost to ‘subscribers’ rather than ‘callers’, as it is the subscriber who pays the bill. Oftel has considered this point and has concluded that ’Caller’ is a redundant term that can be replaced, as appropriate, by either ‘End-User’ or ‘Customer’ depending on whether it relates to the person making the call or the person paying the bill.

Networks and Service

3.2 One stakeholder commented that references to ‘Telecommunications Network’ or ‘Telecommunications Service’ should be replaced with, where appropriate the terms ‘Communications Network’ and ‘Communications Service’. Oftel would agree with this but could find no such mis-references. . However, in some cases references to ‘Telephone Network’ or ‘Telephone Service’, do appear, which were also cited as incorrect by the respondent. Oftel can confirm that it has checked all of these and, where they remain, they are appropriate and have therefore been retained.

Telephone Number

3.3 One respondent asked why there was no definition of ‘Telephone Number’ in the Plan. This is simply because this, along with other definitions such as ‘Adoption’, is defined elsewhere, ie, in the Regulations or what will be the new Communications Act, and such definitions have been incorporated into the Plan (see paragraph 2 of the Definitions and Interpretation section of the Plan).

Definitions and Interpretation in the Plan

Access Codes

3.4 A comment was made in response to the Consultation Document that the definition of Access Codes which states that such codes ‘usually start with 1’ is inaccurate. Oftel disagrees with this view and therefore the definition has been retained. It should be noted that, other than the 999 Emergency Services number, Short Codes beginning with digits other than ‘1’ are not regulated by Oftel.

Approved Apparatus

3.5 One respondent commented that it is wrong to suggest that apparatus that meets defined standards is ‘approved’. He suggested that it would be more appropriate to define such as apparatus as ‘Compliant Apparatus’ since compliance, rather than Approval, is required in the Radio Equipment and Telecommunications Terminal Equipment Regulations 2000. For reasons of consistency, however, Oftel has retained this definition unchanged in the Plan, as the definition comes from Part 1 of the Schedule to Regulations.

Broadband Services

3.6 A point was made that there is a question mark over the definition of ‘Broadband Services’. Oftel agrees that it may be an obsolete term, but maintains that it is right to keep it for now – is being covered in a forthcoming consultation on a variety of PRS issues.

Calling-Line Identification

3.7 One respondent questioned why the term ‘Calling-Line Identification’ was not defined in the Plan. Oftel notes that this term appears in Part B of the Plan and was omitted in error. Oftel has therefore has added a definition into the Plan, consistent with that which appears in the Annex to the Condition.

Carrier Pre-Selection Code

3.8 There was a comment that Carrier Pre-Selection (‘CPS’) codes should only be Adopted by the parties to whom they have been allocated. This is true, as paragraph 17.1 of the Condition now makes clear. However, Oftel considers that that has no impact on the definition as drafted, which remains unchanged.

Communications Provider Identification Code

3.9 One respondent commented that a Communications Provider Identification Code should continue to be an administrative code and not a Telephone Number. Oftel notes that administrative codes are Telephone Numbers. The definition of Telephone number is, as stated above, very broad, and ‘Communications Provider Identification Codes’ are in Part A.4 of the Plan (‘Administrative Codes’).

Conservation Areas

3.10 One respondent commented that it seemed surprising that the Plan made little reference to Conservation Areas, for example, the criteria that need to be fulfilled for an area to be listed as one, and which areas have been so designated.

3.11 Oftel agrees with that view, and a definition for ‘Conservation Area’ which reflects that which is currently contained in the Numbering Conventions, ie, in accordance with existing policy, has been added to the Plan, as follows-

3.12 Additionally, a further paragraph setting out a restriction on the Adoption or use of Geographic Numbers in Conservation Areas has been added to Part B of the Plan:

3.13 Finally, in the table of all Geographic Area Codes (Appendix B to the Plan), a column has been added which states, where applicable, that a code area is either a Type A or a Type B Conservation Area.

Content Service

3.14 One respondent stated that the definition of ‘Content Service’ in the Plan differs from that in the general conditions. To clarify this matter Oftel has removed the term ‘Content Service’ from the Plan and replaced it with ‘Premium Rate Content Service’. However, the definition of Premium Rate Content Service is the same as the former definition of Content Service, as follows-

3.15 Similarly, Oftel has removed the term ‘Non-Content Service’ from the Plan and included a new term ‘Premium Rate Non-Content Service’. However, again, the definition remains the same as the former definition of Non-Content Service.

Corporate Numbering

3.16 Various respondents to the Consultation Document were not in favour of including a definition of ‘Corporate Number’ in the Plan. This was because the issue of corporate numbering is subject to consultation (see the ‘Corporate Numbering: a new option for businesses’ consultation document of 28 March 2003. However, the definition in Plan was deliberately constructed in as neutral a way as possible. Additionally, there is a need for a definition as Telephone Numbers have already been Allocated in this range. Having said that this definition will, in all likelihood, be replaced once new rules on Corporate Numbering are introduced.

Directory

3.17 Respondents to the Consultation Document made the point that the definition of ‘Directory’ was being artificially limited to a printed document. This is nothing new; it has always been so limited. Additionally, the definition reflects the definition of ‘Directory’ in Part 1 of the Schedule to the Regulations, and has therefore been retained for reasons of consistency and slightly amended to ensure that consistency.

Freephone Number

3.18 This definition has been amended, following comments, to reflect that the call is free to the Customer, except where a charge is notified at the start of the call.

Geographic Area Code

3.19 It was pointed out that the terms Area Code and National Destination Code in the draft Plan amounted to the same thing. These have therefore both been replaced by the term ‘‘Geographic Area Code’, which is now defined as meaning "a Telephone Number identifying a particular geographic area".

Geographic Number

3.20 It was put to Oftel by a number of respondents that the draft definition of Geographic Number in the draft Plan would rule out a number of existing businesses that use Geographic Numbers for ‘virtual office’ services. These allow, for example, an electrician to publish a London number but with routing features provided by their Communications Provider who might not be their fixed line supplier. Equally, there is some demand from overseas companies who wish to operate a presence in the United Kingdom but with call centres overseas, where it is important to give the image of a London (or other location) office. The draft definition would have meant that all such services were disallowed. Not wishing to restrict reasonable out of area service provision, Oftel has therefore revised the definition as follows:

3.21 However, this definition alone would leave Geographic Numbers open to systematic abuse for services that would be better placed in Personal Numbering ranges. Accordingly, Oftel has placed a restriction in Part B of the Plan stating that:

Mobile, Radiopaging & Personal Numbers

3.22 A comment was made in response to the Consultation Document that Mobile, Radiopaging & Personal Numbers were not defined in the Plan. Oftel notes that such definitions were included, but the redundant term, ‘Find me anywhere’, which added nothing specific to the above three service types, has not been included in the Plan.

Mobile Network Code

3.23 One respondent believed that the mobile market had changed such that fixed networks may also need MNCs, to deliver innovative services, and as such, the word "mobile" should be removed before the word "network" at the end of this definition. Oftel’s response is that this in itself may be going too far, as the fixed networks that may, in future, become eligible for MNCs will have taken on some characteristics of mobile networks (specifically, for example, having a home location register (‘HLR’). Oftel has therefore amended the definition so that it is possible for not necessarily full mobile network providers to be eligible for MNCs. The following uses wording lifted direct from ITU-T standardisation recommendation E.212:

Network Termination and Testing Apparatus

3.24 One respondent commented that the definition in the Plan differed slightly from that in the general conditions. This definition has been checked by Oftel to ensure that it is consistent with the definition in Part 1 of the Schedule to the Regulations.

Portability and Portability Transit Codes

3.25 The point was made in response to the Consultation Document that the definitions for ‘Non-Geographic Number Portability Code’ and ‘Non-Geographic Number Portability Transit Code’ are identical and that this could not be correct. For the purposes of the Plan the definitions are almost identical and such differentiation as exists takes places within the Functional Specification for Number Portability. However, so as to clarify the matter, the word "transit" has been inserted into the definitions for ‘Non-Geographic Number Portability Transit Code’ and ‘Personal Number Portability Transit Code’ as follows-

and

Numbering Condition

3.26 One respondent stated that the definition for ‘Numbering Condition’ was unnecessary, as it is not referred to anywhere else in the Plan. Oftel notes that it is referred to in the Access Code definition.

Personal Numbering Service

3.27 A respondent stated that the definition for Personal Numbering Service (‘PNS’) did not permit e-mail, voicemail or fax services to operate as extras to, or instead of, voice. Oftel considers that that is an incorrect reading of the definition. The definition was not intended to exclude these means of delivery so long as they are in the context of the core PNS service. However, for reasons of clarity and certainty, the definition has been amended as follows-

3.28 Consequential changes have also been made to the definition of ‘Personal Number’ in the Plan. Additionally, it was noted that the ban on End-User revenue sharing was not covered in the definition. This is so, but the ban remains, because it is contained as a specific restriction in Part B of the Plan.

Public Telephone Network Numbers

3.29 There was a comment that in the definition of ‘Public Telephone Network Numbers’ there was a need to specifically state that these included Mobile, Paging and Personal numbers. Oftel notes that this is not the case as the definition of ‘Public Telephone Network Number’ refers to Non-Geographic Numbers, and the definition of ‘Non-Geographic Number’ covers Mobile, Paging and Personal Numbers i.e. it covers all Telephone Numbers which are not Geographic Numbers.

Paging/ Radiopaging

3.30 It was pointed out that the Paging definition was not consistent with the fact that the service is in fact Radiopaging. This has been corrected and a definition consistent with that used in the Regulations has replaced that in the draft Plan. This is not a change of policy, merely a timely clarification of long-standing policy. The definition now reads:

Served Premises

3.31 One respondent pointed out that the definition for ‘Served Premises’ in the Plan differs slightly from that in the general conditions. This definition has been checked by Oftel to ensure that it is consistent with the definition in Part 1 of the Schedule to the Regulations.

Subscriber

3.32 It was pointed out that the definition in the Plan differs from that in the general conditions in that the latter does not mention the United Kingdom. This definition has been checked by Oftel to ensure that it is consistent with the definition in Part 1 of the Schedule to the Regulations.

Voiceband

3.33 There was a request that the terms ‘Voiceband’ be defined. Oftel agrees that this would be useful and has therefore inserted the following definition into the Plan:

3.34 Oftel noted that some terms used in the Definitions and Interpretation of the Plan did not have a definition – namely Emergency Organisations, Public Pay Telephones and Wireless Telegraphy. A definition for these has therefore now been included in the Plan – the definitions are consistent with those in the Schedule to the Regulations. Additionally, some definitions, eg, that of Corporate Number have been updated to fit the definitions of ‘Allocation’ and ‘Adoption’ given in the Regulations.

Introduction

3.35 There are no changes to this part of the Plan.

Part A: Telephone Numbers Available for Allocation

3.36 Several respondents raised the issue of how the 03, 04 and 06 ranges were to be treated, along with 01 and 02 numbers that were not stated geographic code areas or, for example, 083 or 085. As the Plan is a positive document it cannot include Telephone Numbers which are not available for Allocation by the Director. However, the Annex to the Condition can deal with Telephone Numbers that can be used without Allocation within certain parameters. Oftel has therefore resolved this issue by setting out in the Annex that Public Telephone Network Numbers starting ‘0’ or ‘1’ are available for use without Allocation, but only for ‘Access to number unobtainable tone or equivalent message’ (unless specified elsewhere in the Annex or in Part A of the Plan).

3.37 There was a suggestion from some respondents that greater detail, for example on price points was needed in the Plan. Oftel has concluded that this is not the case, as the Plan should always be read alongside the National Numbering Scheme (‘the Scheme’), which will contain more detail. The Scheme amounts to a record of all numbers Allocated, available for Allocation or protected. It includes all those numbers currently in the United Kingdom’s Specified Numbering Scheme (‘the SNS’) with the addition of certain network and administrative codes that Oftel has been responsible for allocating for some time but which were outside the SNS.

3.38 Similarly, it was commented that full standardisation of tables used in the Plan was desirable. Oftel agrees in principle but has found that attempting this in fact makes them less intelligible and has therefore standardised only where it really adds to overall clarity.

3.39 There was a comment made that 0800+6 digit numbers should be identified in the same way as 0500 (ie, as Public Telephone Network Numbers not available for Allocation but which can be Adopted where already Allocated’). Oftel agrees with that view and has therefore put 0800+ 6-digit numbers into the Annex to the Condition. That reflects the policy outcome of previous reviews of Freephone Numbers.

Part B: Restrictions for Adoption of Telephone Numbers

3.40 Paragraph B2.1 shows the notation of the National Significant Number. One respondent suggested the use of "J" rather than the letter "I", which may be confused with the digit "1". Oftel has previously referred to ‘I’ as ‘1’ and believes that this is acceptable standard notation and not in the least ambiguous or confusing.

3.41 One respondent suggested that using the word ‘company’ in what is now paragraph 3.1.4 would be more appropriate than ‘person’. Oftel has not accepted this suggestion, as ‘person’ includes a corporate body but not vice versa and hence the breadth of the provision would be lost.

3.42 Finally, amendments have been made to part B3.1.6 and B3.1.2 of the Plan as set out above in paragraphs 3.12 and 3.21, above.

Appendix A: Geographic Area Codes

3.43 When preparing the draft Plan for consultation, Oftel recognised that the naming of Geographic Areas is not an exact science. Oftel attempted in the draft Plan to capture areas within one name or, where that was clearly not possible, within a minimal set of names. Following the responses to the Consultation Document, Oftel has made some amendments to the names, believing that it has now been possible to ensure that the names set out in Appendix A of the Plan represent a consensus on the largest centres of population within the area concerned. However, the essential point is to give every numerical code a name so that Oftel can ensure that inappropriate number Adoption can be dealt with.

3.44 One respondent argued that each area should have only one single name. Oftel agrees that this is a desirable concept, but simply not practicable in large rural areas where no one conurbation dominates.

3.45 As referred to above, following responses to the Consultation Document Oftel has, where these seem logical, consistent and necessary, made changes to the some Geographic Area Code names. Those that amount to more than a spelling correction are listed below:

3.46 Finally, there was a suggestion that the use of a name plus a suffix, to avoid confusion, such as ‘Scotland’ or ‘Wales’, in insufficient and should be supplemented by a 4-digit National Grid Reference for a typical point in each area. This is not practical, as Geographic Area Codes are often large and imprecise. However, to assist with clarification, in cases of local name duplication, Oftel has dropped the potentially ambiguous use of regional tags and is instead using county tags (eg, Alford (Lincs) instead of Alford (England)).

Appendix B: Telex Area Codes

3.47 As a result of one response the designation for Telex Area Code 621 has been amended from ‘Manx Telecom’ to ‘Isle of Man’.

Other Issues

Cross-network use of Internal codes

3.48 It is open to Communications Providers to agree to use "internal" codes/ numbers across networks by mutual agreement but it is Oftel’s view that this requires no change to any definitions. Indeed, unless these codes begin with a ‘0’ or ‘1’ or are specified in the Plan or elsewhere in the Annex to the Condition, they fall outside the area of Telephone Numbers regulated by Oftel (see diagram at paragraph 2.6).

The Annex to the Condition

3.49 Comments on the Annex to the Condition (at Annex C of this Statement) have been addressed in the Oftel Statement on the general conditions of entitlement.

Annex A

Non-confidential respondents to the Consultation Document

Jeremy Beard
BT
Cable and Wireless
Communications Commission, Isle of Man
Easynet
Magrathea Telecommunications Ltd
NIACT
NTL
Orange plc
Thus plc
Vodafone

Annex B and C are available in pdf format only. Please click here.