| The National Telephone Numbering Plan - 22 July 2002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||
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A Statement issued by the Director General of Telecommunications following a consultation on proposals to publish a National Telephone Numbering Plan. Chapter 3 - Specific comments on the National Telephone Numbering Plan Annex A - Non-confidential respondents to the Consultation Document
S2. The version of the Plan in Annex C replaces the version of the Plan previously published in Oftel’s Statement of 9 July 2003 ‘The National Telephone Numbering Plan’ (the ’9 July Statement’). The version contained in the 9 July Statement would have applied had it been necessary to make interim Statutory Instruments to implement the new EU Directives. As the Act has now received Royal Assent, that will not now be necessary and the version of the Plan in the 9 July Statement should now be discarded. The Plan sets out the numbers available for Allocation by 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-
Chapter 1IntroductionThe National Telephone Numbering Plan 1.1 The document in Annex C to this Statement is the National Telephone Numbering Plan (‘the Plan’), published today by the Director-General of Telecommunications (the ‘Director’) pursuant to section 56 of the Communications Act 2003 (the ‘Act’). The Plan is part of the new regulatory framework for Telephone Numbers following implementation of the new EU Directives by the Act, which received Royal Assent on 18 July. Relevant provisions of the Act, including section 56, will come into force on 25 July 2003, pursuant to the [Communications Act 2003 (Commencement No.1) Order 2003 (the ‘Commencement Order’) 1.2 The Director is able to publish the Plan today in view of section 13 of the Interpretation Act 1978, which allows for the anticipatory exercise of powers under an Act after its passing but prior to its entry into force as may be necessary or expedient for the purpose of giving full effect to the Act or any provision of the Act at or after the time when it comes into force. In addition, the Director is able to exercise powers under the Act pursuant to section 408 of the Act and Article 3(1) of the Commencement Order, until Ofcom assumes those powers at a later date. Stakeholders should note in particular that the version of the Plan contained in Oftel’s Statement ‘The National Telephone Numbering Plan’ of 11 July 2003, which was published in case the Act did not receive Royal Assent by 25 July 2003 and it was necessary to make interim statutory instruments to implement the new EU Directives, should now be discarded. 1.3 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’ of the General Conditions of Entitlement (the ‘Condition’) (reproduced at Annex B of this Statement) refer to the Plan. The General Conditions of Entitlement (referred to as such in this document) were set by the Director today by way of publication of a Notification pursuant to section 48(1) of the Act and are contained in the Schedule to that Notification. The Plan sets out the numbers available for Allocation by the Director as Telephone Numbers (‘Telephone Number’ is defined in section 56(5) of the Act). The Plan also sets out the restrictions on the Adoption 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 B), which sets out certain Telephone Numbers the use of or, where specified, the Adoption of which is restricted through the Condition. Justification for the Plan 1.4 In publishing the Plan, the Director is satisfied that it meets the tests in section 60(2) of the Act. 1.5 The Plan is objectively justifiable, in that the Director is required, by section 56(1) of the Act to publish such a document setting out the numbers that he has determined to be available for Allocation by him as Telephone Numbers and such restrictions as he considers appropriate on the Adoption and other use of such numbers. It is not unduly discriminatory, in that it applies to all communications providers subject to the Condition. It is proportionate because it ensures that the requirements of the Plan are only likely to affect those providers who are subject to the Condition, and contains restrictions on the Adoption or other use of Telephone Numbers which are no more restrictive than is necessary to ensure best and most appropriate use is made of those Telephone Numbers. It is transparent in that the Plan has been consulted on, and the reasons for making it were set out in the Consultation Document and in this Statement. 1.6 In publishing the Plan the Director has considered his duties as set out in section 4 of the Act, in particular the fifth Community requirement to encourage the provision of network access and service interoperability, and the sixth Community requirement to encourage such compliance with the relevant international standards as is necessary for (a) facilitating service interoperability, and (b) securing freedom of choice for the customers of communications providers. Chapter 2General comments2.1 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 Act, [Telephone Number is defined in Section 56(5) as "any number that is used (whether or not in connection with telephony) for any one or more of the following purposes— (a) identifying the destination for, or recipient of, an electronic communication; (b) identifying the origin, or sender, of an electronic communication; (c) identifying the route for an electronic communication; (d) identifying the source from which an electronic communication or electronic communications service may be obtained or accessed; (e) selecting the service that is to be obtained or accessed, or required elements or characteristics of that service; or (f) identifying the communications provider by means of whose network r service an electronic communication is to be transmitted, or treated as transmitted] 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. Stakeholders should note that, until the draft Exclusion Order is made, Schedule 1 of the Commencement Order provides that sections 56 – 63 of the Act are commenced except in respect of internet domain names, internet addresses or addresses or identifiers incorporating either of an internet domain name or an internet address, including an e-mail address. 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. Whilst the definition of ‘Telephone Number’ in the Act 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 Act) 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 will be excluded from the definition of ‘Telephone Number’ by the draft Exclusion Order (see www.communicationsbill.gov.uk/pdf/draft_numbering_consultation.pdf). 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). 2.11 However, 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. 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’. All modifications to the Plan must be made in accordance with section 60 of the Act; i.e. must be objectively justifiable, not unduly discriminatory, proportionate and transparent. 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 3Specific comments on the National Telephone Numbering PlanDefinitions 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 Act or the General Conditions of Entitlement, 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 this definition comes from the General Conditions of Entitlement. 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 Code3.9 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- "‘Conservation Area’ means a geographic area that has a realistic expectation of number exhaustion within the foreseeable future. Type A Conservation Areas are those which Oftel believes are within two years of having less than ten spare 10,000 number blocks available. Type B Conservation Areas are those which Oftel believes are likely to become Type A Conservation Areas within ten years. Conservation Area status, where applicable, is indicated in Appendix B of this Document." 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: "B3.1.6 Telephone Numbers in geographic areas where a Conservation Area status is indicated shall only be Adopted or otherwise used in units of 1000 numbers at a time." 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- "‘Premium Rate Content Service’ – means a Premium Rate Service which carries a charge for the content of the call or other product or non-communication service delivered in the course of, or as a direct consequence of, the call. Such charges are in addition to, or form part of, the total charge for accessing the Electronic Communications Service which delivers the content, product or non-communication service;" 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: www.oftel.gov.uk/publications/numbering/2003/05nums0303.htmweblink). 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 General Conditions of Entitlement, 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: "‘Geographic Number’ means a Telephone Number, from a range of numbers in Part A of this document, where part of its digit structure contains a Geographic Area Code, consistent with Appendix A of this document, that is Adopted or otherwise used for routing calls to the physical location of the Network Termination Point of the Subscriber to whom the Telephone Number has been assigned, or where the Network Termination Point does not relate to the Geographic Area Code but where the tariffing remains consistent with it;" 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: "B3.1.2 Geographic Numbers shall not be Adopted or otherwise used for a Customer outside of the relevant geographic area except where the Customer has specified that they require a Telephone Number with the relevant Geographic Area Code." 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: "‘Mobile
Network Code’ means a Telephone Number that is part of the International
Mobile Station Identity that is Adopted or otherwise used to identify
the home 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 General Conditions of Entitlement. 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- "‘Non-Geographic Number Portability Transit Code’ means a Telephone Number that is Adopted or otherwise used for transit routing of non-geographic ported calls in accordance with the Functional Specification;" and "‘Personal Number Portability Transit Code’ means a Telephone Number that is Adopted or otherwise used for transit routing of Personal Number ported calls in accordance with the Functional Specification;"
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- "‘Personal Numbering Service’ means a service based on number translation that enables End-Users to be called or otherwise contacted, using a single Personal Telephone Number, and to receive those calls or other communications at almost any Telephone Number, including Mobile Numbers;" 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 General Conditions of Entitlement 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: "‘Radiopaging Service’ means Electronic Communications Services consisting in the conveyance of Signals by means of Wireless Telegraphy where every Signal, apart from simple acknowledgement, is ultimately transmitted from a station for Wireless Telegraphy comprised in the Communications Provider’s Electronic Communications Network to a station for Wireless Telegraphy or Wireless Telegraphy Apparatus that is not comprised in that Network;" 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 General Conditions of Entitlement. 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 General Conditions of Entitlement. 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: "‘Voiceband’ means a communication of signals in the frequency band from 300Hz to 4kHz;" 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 General Conditions of Entitlement. Additionally, some definitions, eg, that of Corporate Number have been updated to fit the definitions of ‘Allocation’ and ‘Adoption’ given in the General Conditions of Entitlement. 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 IssuesCross-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 B of this Statement) have been addressed in the Oftel Statement ‘The General Conditions of Entitlement, Final statement issued by the Director General of Telecommunications’, 9 July 2003
Glossary(Terms used in this Consultation Document not covered in the Definitions and Interpretation section of the National Telephone Numbering Plan) The Access Directive Directive 2002/19/EC on access to, and interconnection of, electronic communications networks and associated facilities. The Authorisation Directive Directive 2002/20/EC on the authorisation of electronic communications networks and services. The Framework Directive Directive 2002/21/EC on a common regulatory framework for electronic communications networks and services. General Conditions of Entitlement Conditions, including one that specifically covers the Allocation, Adoption and Use of Telephone Numbers, to which Communications Providers may be subject and set by the Director by way of publication of a Notification pursuant to section 48(1) the Communications Act 2003. The National Numbering Scheme The National Numbering Scheme (the Scheme) will be the list of all telephone numbers that are allocated, free, protected, reserved or not designated. It will remain as the contemporaneous detail of the framework set out in the Plan. The Scheme 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 while but which were outside the SNS. Numbering Code A code of practice for codes and numbers controlled by Oftel but which are outside of the scope of the Numbering Arrangements Condition, contained in a licence granted to an operator under Section 7 of the Telecommunications Act 1984, and which therefore cannot be included in the Numbering Conventions for the United Kingdom. Numbering Conventions A set of rules and principles that currently govern the use and management of numbers and codes from the United Kingdom’s Specified Numbering Scheme. Oftel allocates, reserves, and withdraws numbers in accordance with the Conventions. Those to whom numbers and codes have been allocated are obliged to have Numbering Plans that accord with the Conventions under the so-called ‘Numbering Arrangements Condition’ contained in certain licences granted under Section 7 of the Telecommunications Act 1984. The Privacy Directive Directive 2002/58/EC concerning the processing of personal data and the protection of privacy in the electronic communications sector. The Universal Service Directive Directive 2002/22/EC on universal service and users' rights relating to electronic communications networks and services.
Annex ANon-confidential respondents to the Consultation DocumentJeremy Beard
Annex B and C are available to download as pdf documents, please click here
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