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Access Codes: Options for the Future Layout image
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A consultative document issued by the Director General of Telecommunications

May 2000

Contents

Summary

Chapter 1 The Current Position

Chapter 2 Future Demand

Chapter 3 Addressing the Shortage of Type B codes

Chapter 4 Other Issues

Consultation

Annex A Allocated Type B Access Codes

Annex B Network Constraints on the Length of Access Codes

Annex C The European Perspective

Annex D Summary of Questions

Glossary


Summary

Access codes are short, generally memorable 3 or 4-digit numbers beginning with ‘1’ which allow customers to access a wide range of telephony services. Examples include 100 to contact the Assistance Operator and 1471 to find out the telephone number of the last person who called you. Most telephone companies use access codes.

Given that these numbers are only 3 or 4-digits long, they are in limited supply, and the availability of new access codes is already nearing exhaustion. The explosive growth of new telephony services in the UK market over the last few years has led to high levels of demand for access codes, and this looks likely to continue or even increase in the future. As a consequence, there is a need to increase the supply of access codes, and this document invites views on how this should be achieved.

Access codes are categorised by the type of service for which they are used. The type of codes in shortest supply and facing greatest demand are those commonly used to allow access to another network operator's services – known as ‘indirect access’ – such as 1640 to access First Telecom services. Codes which are used by a network operator either to provide customer services or for internal network operations are under less pressure. One example of this would be codes for access to voicemail.

Any changes in the use of numbers impacts on consumers as well as the telecoms industry: if familiar numbers are withdrawn or changed, this can be inconvenient for the consumer and impose costs on operators. Changes to policy on the allocation of codes could also have an impact on competition; for example, if new short codes are unavailable some companies may be forced to offer their services via longer access codes or freephone numbers, and might feel disadvantaged against competitors offering services using shorter codes.

Oftel commissioned a Cost Benefits Analysis (CBA) to help formulate public policy. The CBA considered a range of options to increase the supply of access codes, and concluded that the least cost method of increasing the supply of access codes would be to recover certain unused codes from operators over a reasonable period. It also proposed that future allocations should be made in 5-digit number form. Subject to the outcome of consultation, Oftel is minded broadly to endorse this approach.

Oftel is also seeking other views in relation to access codes in order to consider longer term policy for their use that will provide sufficient capacity to meet unforeseen demand together with securing an equitable basis for their allocation.

This document does not address the specific issue of the use of short access codes for the provision of Directory Information and Services. This matter will be addressed as part of a future consultative process.

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Chapter 1

The Current Position

Background

1.1 The current use of access codes dates back to when BT, as a monopoly, used such codes as a quick and convenient method to offer their customers access to a range of services (such as 100 for the Assistance Operator). Over the years BT increased its use of access codes, and additional numbers for further services were utilised (such as the codes 150 to 154 for customer services and fault reporting).

1.2 With the ending of the monopoly when Mercury – now called Cable & Wireless Communications (CWC) – was licensed to provide telecoms services, BT allocated Mercury codes such as 131 and 132. These were used to give BT customers access to the CWC network – known as ‘indirect access’. The practice of allocating codes for indirect access was extended following the ending of the duopoly in 1991, and has been continued by Oftel since taking over responsibility for the management of the Numbering Scheme from BT in 1994.

1.3 In its 1996 Consultative Document on the National Numbering Scheme, Numbering: Options for the Future 2, Oftel put forward proposals for the future of access codes. However, the subsequent Statement of January 1997 deferred a decision on a future policy pending the publication of the European Green Paper on a Numbering Policy for Telecommunications Services in Europe. The main effect of the Green Paper was to mandate the implementation of Carrier Pre-Selection (CPS) across Europe (see glossary). The Green Paper also placed an obligation on all European National Regulatory Authorities (Oftel in the UK) to allocate numbers in a competitively neutral way.

Types of access codes

1.4 There are currently three types of access code defined in the Numbering Conventions.

  • Type A – these are codes such as 100 (operator services) or 123 (speaking clock) used by callers to reach commonly used services, and may be used throughout the UK by all operators offering equivalent services. This means that Assistance Operator Services offered by any operator can be accessed by dialling 100. They are therefore ‘service orientated’, with the caller primarily calling a service. These codes are allocated by Oftel.
  • Type B – these are codes used by customers to have selected calls connected by a telephone company other than the one from whom they rent their telephone line (usually BT). This is known as indirect access in the UK. Typically callers use Type B codes to select indirect access service providers for long distance calls. Type B codes can also be used by service providers as a means of providing content services or other facilities. These codes are therefore ‘operator orientated’, with the caller primarily selecting a provider. These codes are allocated by Oftel.
  • Type C – these codes are used by operators as they wish, either to provide particular services exclusively to its directly connected customers or for internal network operations. The access code 150, which is used by BT for residential sales and billing enquiries, and Orange for customer services, falls into this category. These codes are therefore ‘service orientated’ for services provided by the serving operator. While Oftel has designated a range, it does not allocate Type C codes but, based on information supplied by operators, their use is recorded in the Scheme.

Length of access codes

1.5 Access codes are used to provide customers with a quick, direct and easy way to reach various services and facilities, and have therefore been made as short as possible. However, shorter numbers mean fewer codes.

1.6 Access codes used by BT and CWC prior to 1994 were generally three digits long (such as 100 for Assistance Operator and 131 to access CWC). However, this was insufficient to accommodate the growth in telecommunications systems and services, and with the issue of the 1994 Numbering Conventions the number of digits in new allocations was increased to four (such as 1471 for Call Return and 1620 to access services provided by Energis). Currently, most Type A codes comprise three digits, most Type B codes comprise four digits (except those for BT and CWC which are still three digits), while Type C codes comprise between three and five digits, depending on the use by the operator. Oftel is of the opinion that the number length should be the shortest possible, consistent with providing sufficient capacity to meet anticipated future demand.

1.7 Telephone networks can only handle a finite, and defined, number of dialled digits, and this limits the maximum possible length of access codes. This affects Type B codes when used for ‘single-stage call set-up’, which is where the telephone number is treated as a single unit or ‘string’ by the telephone networks in setting up the call. This term is more fully described in Annex B.

1.8 With the exception of Type B codes used for single-stage call set-up, there are no restrictions in respect of the length of access codes. However, given that these codes are considered, by their very nature, as short numbers, it is unlikely that significant increases in the length of these codes would be acceptable. This would result in different and longer numbers being dialled, and would cause inconvenience to customers, particularly if there were changes to familiar numbers.

 

Access codes use and available numbering capacity

Type A access codes

1.9 There are eight 3-digit codes, one 4-digit code and three 5-digit codes currently in use as Type A codes.

  1. Assistance Operator
  1. Emergency Service

123 Speaking Clock

141 Suppress CLI

1471 CLI – Call Return

153 International Directory Enquiries

155 International Assistance Operator

180XX Voice Text Service for the Deaf

192 Directory Enquiries

195 Blind & Disabled Directory Enquiries

1.10 Oftel has designated 29 per cent of the 1XX space in the Numbering Scheme for Type A use, with current usage representing little less than 30 per cent of the total available Type A capacity.

1.11 Oftel has assigned the 11X range for possible future European harmonisation such as 118 which is being reserved for possible development of Directory Enquiry Services. In addition, Oftel currently reserves the 10X range and unused parts of the 19X range for possible future European harmonisation.

Type B access codes

1.12 Oftel has designated 42 per cent of the 1XX space in the Numbering Scheme for Type B use. As at May 2000 about 320 access codes had either been allocated or reserved, representing about 85 per cent of the total available Type B capacity. The majority of these have been allocated by Oftel over the last four years.

1.13 A further development is that Type B access codes have until recently only been allocated to, and used by, individually licensed operators. These are the ‘traditional’ telecommunications operators who own and operate networks. However, in order to conform to recent EU requirements, these codes may now be allocated to service providers, who do not necessarily own and operate networks, but who provide services over the public networks. This means that the demand for Type B codes is likely to increase in the future. This is discussed in greater detail in the CBA.

1.14 Operators having Type B access code allocations often need two codes – one for use as single-stage call set-up plus another for two-stage call set-up. This is explained in detail in Annex B. However, certain operators have more codes than this. There are two major factors that account for multiple allocations. First, some older telephone exchanges (now withdrawn) required additional numbers. Second, company mergers or acquisitions have resulted in the new organisations retaining all the codes previously allocated to the earlier separate companies.

 

Type C access codes

1.15 Oftel has designated 29 per cent of the 1XX capacity in the Numbering Scheme for Type C use. As already indicated, these are not allocated by Oftel, but are used by operators as they wish. Oftel has been notified that all 29 of the 3-digit codes designated as Type C codes are in use by at least one operator for some purpose. However, because different operators may use identical codes, there remains significant unused Type C capacity within those ranges.

1.16 A number of operators follow the ‘BT pattern’ for certain Type C access codes, particularly those in the 15X range (150, 151, 152, 154) which provide customer services, including sales, billing enquiries and faults. Other operators are more disparate in their use of Type C codes, including various network tests (primarily for use by the operator’s own staff rather than the public).

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Chapter 2

Future Demand

Type A access codes

2.1 The demand for Type A codes is unlikely to increase significantly in the future. Indeed, with the exception of 1471 (used for call return) and 180XX (used for Voice Text services for the deaf), the number of these codes has remained constant since 1994.

2.2 A central feature of the European Green Paper on a Numbering Policy for Telecommunications Services in Europe related to the harmonisation of access codes within Europe. However, other than 112 and 118, there is no evidence at the present time that further harmonisation of access codes is likely. This is discussed in detail in Annex C – The European Perspective.

Type B access codes

Carrier/operator selection

2.3 At present, only operators with significant market power (see glossary) are required to implement Type B codes on their network, with only BT and Kingston Communications currently subject to this requirement. However, this is due to change this year, with Vodafone and BT Cellnet being required to implement indirect access using Type B codes. The introduction for indirect access on mobile networks may further boost demand for B codes.

2.4 Until recently Type B codes have only been allocated to, and used by, individually licensed operators. However, as already indicated, a wider range of service providers are now entitled to access code allocations and, as a consequence, it may be that future demand for these codes is driven by content services and facilities as service providers seek to offer similar services to those of fixed and mobile network operators (including services such as two-stage call completion services, calling card service access and access to fault reporting and customer information services). This may well have a significant impact upon future demand for Type B codes.

2.5 Under current allocation rules, one company may obtain several licences such as for the provision of different types of service, for instance, and it would then be entitled to apply for access codes under each licence. In addition, when acquisitions or mergers between operators and/or service providers occur, the newly formed organisation retains all the access codes previously allocated to the constituent parts. There are no provisions within current allocation rules to prevent this occurring nor are there are any formal arrangements to limit the total number of allocated codes that a licensee may hold. A number of methods to control Type B allocation holdings are considered in Chapter 4.

2.6 Annex A illustrates how the total Type B allocations have increased over the period since 1994. This represents an average net monthly demand of between three and four codes. Using simple extrapolation, Annex A also illustrates, by means of a trend line, how this demand could rise over the next four years if the same demand profile and basis of allocation continues. In this event, the remaining Type B capacity could expire early next year.

Carrier pre-selection (CPS)

2.7 The European Green Paper on a Numbering Policy for Telecommunications Services in Europe mandated the implementation of CPS across Europe. However, although CPS would not itself require access codes in order to work, Type B codes would be the normal means of a caller overriding, on a call-by-call basis, a pre-selected carrier.

2.8 Operators and service providers already having Type B access codes for indirect access will use them for CPS override and therefore not need further codes. However, provision of additional capacity needs to be made for new CPS market entrants and for any service providers currently using other numbers, such as freephone, to access their services, and who wish to change and use the CPS method.

Type C access codes

2.9 As already indicated, Type C codes are used for a variety of purposes by the fixed and mobile network providers. Not all of these uses provide a direct service to the customer.

2.10 Because of the relatively free way in which operators have been permitted to employ this type of code a large number have been used by operators, and future demand would appear to be high, with sufficient supply being important in supporting service innovation. In particular, the use of access codes in the mobile market is likely to increase in the future, as mobile operators set up new services and facilities which are accessed by short codes.

Summary of future needs and demands

2.11 Because of the continuing demand for Type B codes and the limited remaining supply of new B codes, it is necessary to consider methods of providing additional Type B capacity. There appears to be no immediate requirement to increase Type A capacity, while future demand for Type C codes is likely to expand to take up whatever supply is made available.

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Chapter 3

Addressing the Shortage of Type B Codes

3.1 Oftel commissioned consultants to carry out a Cost Benefits Analysis (CBA) to evaluate a range of options for increasing the supply of access codes. A CBA is a useful tool to help assess the costs and benefits to all parties of a range of public policy options.

3.2 The CBA included three options for change. These were measured against an ‘ideal theoretical position’ where:

  • there was no constraint on the supply of Type A or B codes;
  • the supply of Type C codes remained constrained to the currently designated space within the 1XX range; and
  • existing access codes remained unchanged at their current length.

3.3 As this was an ‘ideal theoretical’ option, there were no benefits in respect of the options considered. The best option was the one with the lowest cost relative to the ideal baseline. A ‘do nothing’ option was not considered as a baseline.

3.4 The CBA analysed three ways of expanding the supply of access codes:

Option 1 – Redesignating code types

3.5 In this option, certain Type A and C codes would be redesignated as Type B codes. In particular:

  • 11 unused 3-digit Type A codes would be redesignated as B codes, namely codes 101 to 109 plus 180 and 199.
  • the 15 most lightly-used of the 3-digit Type C codes would be recovered, with the displaced services being moved to longer codes from other parts of the designated C code space.

3.6 These 26 3-digit codes would then be reissued as 5-digit B codes, thereby increasing the supply by 2,600 B codes. It was also proposed that 40 4-digit B codes from the existing supply be kept in reserve so as to preserve the option of lengthening B codes (option 2) in the long term.

Option 2 – Lengthening Type B codes

3.7 In this option, all Type B codes would be lengthened to five digits. In particular, all 3-and 4-digit Type B codes would become 5-digit codes using 40 unused 4-digit B codes from the existing range. These codes would be issued as 3,800 5-digit B codes. The overall effect of this option would be to increase supply from 384 3-and 4-digit B codes to 4,200 5-digit B codes.

Option 3 – Rationing the use of Type B codes

3.8 In this option, the use of Type B codes for existing and new indirect access service providers would be rationed. Each existing service provider would be limited to one 3- or 4-digit B code and one 5-digit B code, while each new service provider would be limited to two 5-digit B codes.

3.9 This option would have two main effects. First, it would release a substantial supply of 4-digit B codes currently used by existing service providers, which could be reissued as 5-digit codes, when required. Second, because existing service providers would not be getting further codes, and each new service provider would be restricted to two 5-digit codes, future demand would be reduced.

Results

3.10 The CBA concluded that Option 1, which involves redesignating unused 3-digit Type A codes and lightly-used Type C codes as B codes, would offer the least cost method of increasing the supply of access codes. Option 2 generated significant extra costs, including costs associated with changes being made to customer premises equipment such as autodiallers and switchboards, publicity change costs, the costs of reduced competition and the user costs of dialling additional digits. Option 3, which was the least preferable option, suffered primarily from the cost of reduced innovation caused by the rationing of Type B codes.

3.11 However, the CBA proposed that, rather than implementing Option 1 in one go, a phased approach should be adopted, with initially only unused A codes being converted to 5-digit B codes, and the supply of C codes remaining unchanged. This proposal would create an additional supply of 1,100 new 5-digit B codes. The table below, taken from the CBA Report, presents the results on the three options in detail.

Results of the CBA

Component of the NPC

Composite NPC (£m) under

Option 1

Option 2

Option 3

Cost of CPE changes for SPs

-

28

11

Migration costs for ANOs and SPs

3

4

4

Publicity costs for ANOs and SPs

5

35

35

User learning costs

5

8

8

User costs of dialling extra digits

5

36

0

Long term costs of exhaustion

40

28

51

Costs of reduced competition

-

22

-

Costs of reduced innovation

-

100

Total NPC

59

161

209

CPE (Customer Premises Equipment)
ANO (Access Network Operator)
SP (Service Providers)
NPC (Net Present Cost)

3.12 The CBA included several assumptions given the difficulty of forecasting certain factors, such as future market demand, with any degree of certainty. Nevertheless, the robustness of the results was tested against reasonable variations, with the analysis being tested against different levels of demand to evaluate the effects of using different values on the outcome.

3.13 The results of this sensitivity testing confirms that the conclusion of the CBA is robust, with Option 1 remaining the lowest cost option for all cases considered within the sensitivity analysis.

3.14 The full CBA is accessible through the Numbering Information pages of Oftel’s website.

Analysis and Preliminary Conclusions

3.15 Having considered the range of options identified in the CBA, Oftel concurs that Option 1, from the CBA, would appear to offer the least cost option for increasing the supply of access codes in the short term. This option has the advantage of minimising disruption to the industry and consumers, while not reducing competition and innovation.

3.16 Oftel proposes only converting unused Type A codes initially, with 101 and 109 being converted to 5-digit B codes, leaving the supply of C codes unchanged. As a consequence of no existing codes being changed, there would be no significant impact on consumers or industry. These codes are currently reserved for European harmonisation following an ECTRA recommendation in late 1998. However, as already indicated, there is no evidence that further European harmonisation is likely, and many member states already use these codes for national purposes. Also, the whole of the 11X range would continue to be reserved for European harmonisation.

3.17 While the CBA proposed that the 199 and 180 codes should also be redesignated as 5-digit B codes, on balance, Oftel has not been persuaded to redesignate these codes. Oftel has reservations about utilising 199 given its similarity to 999 and the risks of misdials with emergency services. Oftel has also decided that 180 should remain a Type A code, and has designated 180XX for Voice Text services for the deaf.

3.18 This initial step would create an additional supply of 900 new 5-digit B codes and, given the uncertainty over future demand for these codes, could potentially be sufficient on its own. On the basis of current allocations, access code capacity should endure approximately ten years. However, in the event that this new designation of new 5-digit B codes proves insufficient, Oftel would consider whether to implement the remainder of Option 1 (redesignation of certain Type C codes) or in the light of future developments, whether another option would provide a better solution.

3.19 These preliminary conclusions do not, however, represent Oftel policy. Views are sought from customers, users, network operators, trade bodies and other interested bodies on the three options detailed in this chapter, or alternative options which are considered to provide a better solution.

Question1: Do you agree with Oftel’s view that Option 1 from the CBA, as detailed in this chapter, should be implemented? If so, do you consider that Option 1 should be implemented all in one go, or do you agree that there merit in using a phased approach, as outlined above?

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Chapter 4

Other Issues

4.1 In addition to increasing the supply of available of Type B codes, Oftel is seeking views in relation to broader policy issues about access codes, with the objective of further developing its long-term strategy. In this section, a number of issues are raised, and views in relation to these are sought by way of questions.

4.2 Oftel is not seeking views relating to the specific issue of the use of short access codes for the provision of Directory Information and Services. This matter will be addressed as part of a future consultation document.

Entitlement to allocation and maximum permissible holdings

4.3 The CBA considered the rationing of the use of B codes in Option 3. It concluded that this would be the least preferable option, from an economic perspective, given the cost of reduced innovation caused by the rationing of Type B codes. However, Oftel has a statutory obligation to ensure that the Numbering Scheme is organised and managed in a way that allows for the good husbandry of the supply of numbers and provides reasonable capacity to be kept as a reserve for new services and future expansion of the Scheme.

4.4 As already indicated, there are no provisions within current allocation rules to limit the total number of allocated codes that a licensee may hold. In addition to increasing the pressure on the access codes resource, the lack of formal arrangements in this area is not consistent with fostering effective competition. It may be that, following an acquisition or merger, access codes over and above a defined maximum entitlement should be returned (withdrawn) within a defined period. This period would need to be carefully defined in order that the company has an opportunity to effect and publicise the changes, while callers have sufficient time to adjust to new dialling arrangements.

4.5 There are essentially two elements relating to allocation rules that need to be taken into account, namely entitlement to allocation and maximum holdings. However, these options are not exhaustive, and respondents are welcome to suggest further arrangements.

(a) Entitlement to allocation

4.6 There are three methods by which this could be achieved, namely allocations based on a company group, allocations based on licences and unrestricted allocations.

  • Basing allocation entitlement on a company group would have the effect of moderating demand for Type B codes. It would also provide a method for reclaiming any codes that are held over a defined maximum. The main effect, however, would be that companies within a group would be unable to increase their holdings of Type B codes simply by forming new subsidiaries, or applying for further licences. In addition, in the event of mergers or acquisitions occurring, holdings of the new group which are over a defined maximum would be withdrawn and made available to other applicants in due course.
  • Basing allocation entitlement on licences would moderate demand to an extent, although companies would still be able to increase their holdings of B codes by obtaining allocations for each of the licences under which they operate. All new subsidiaries formed to provide specific services and having their own licence(s) would be entitled to their own allocations.
  • Adopting a policy of unrestricted allocations means that there would be no restriction on the number of access codes that a company could hold, with the only control being the length of the number(s) allocated, and the justification supplied to Oftel by the applicant or holder for having additional, or retaining existing, allocations. However, because it would be very difficult to have explicit rules relating to maximum holdings and/or the nature of use, the management of the resource would be very difficult and decisions could be open to challenge. This option would also inevitably result in the early exhaustion of the remaining available resource; or require longer codes in order to increase the available resource. Moreover, it would be necessary to determine what action is required once the remaining stock expires.

Question 2: Should future Type B access code allocations be made on the basis of either company group or licence?

Question 3: In the light of Oftel’s statutory responsibility to ensure numbering capacity, what should be done to prevent the exhaustion of Type B codes in the event of Type B code allocations being made on an unrestricted basis?

(b) Maximum holdings

4.7 If allocations are made on the basis of either a company group or licence it will be necessary to identify the maximum holdings of Type B allocations.

4.8 As detailed in Annex B, Type B access codes may be used for either single-stage call set-up and two-stage call set-up. Because of the different purposes for which these are used, Oftel considers that, at the minimum, those entitled to allocations should be permitted to hold one single-stage call set-up code plus one two-stage call set-up code which, in accordance with Option 1 of the CBA, should be made in 5-digit form. This may well be a useful starting point in considering the establishment of a possible limit for Type B allocations. It may be argued that operators require a greater number than this in order to facilitate service providers offering a variety of services using different codes. However, increasing the permitted holding above the minimum of one code of each sort would result in the remaining available capacity being more quickly used up. Moreover, it would also be necessary to define the criteria for any additional permissible holdings to avoid ambiguity or other confusion in the future.

4.9 The extent to which these rules should be applied to existing Type B allocations needs consideration and, in particular, whether holdings over any specified amount should be withdrawn. The arguments are finely balanced. On the one hand, the withdrawal of codes over any specified amount will be inconvenient for the consumer and impose costs on the operator, whereas on the other hand, the existence of companies with a larger pool of access codes than others may be contrary to ensuring competitive neutrality. It may be that rather than withdrawing any codes already allocated to existing operators, those operators should be limited to their current allocation. They would therefore need to carefully manage their own supply of access codes and, should further codes be required, would need to reissue their existing 4-digit codes as new 5-digit codes.

Question 4: If Type B access code allocations were made on a company group or licence basis, should the maximum holding be limited to one single-stage call set-up plus one two-stage call set-up code per applicant?

Question 5: If yes, should these rules be applied to existing Type B allocations, and should holdings over any specified amount be withdrawn? or should operators be restricted to their current allocation?

Question 6: If not, what should be the maximum permitted holding of each sort and what should be the criteria for allocation?

Use of Type A codes

4.10 The CBA concluded that, based on current perceptions of Type A codes, demand for Type A codes was unlikely to increase significantly in the future. Oftel concurs that the prospects for further A codes would appear to be limited, and while the C codes covering the 15X range (widely-used for customer service) and 198 (used by BT and some other operators for disabled access to the 100 Assistance Operator) are obvious candidate for redefinition as A codes, there are relatively few other candidates.

4.11 Oftel would welcome views on whether respondents agree with this assessment, or whether it is anticipated that future developments within the market may increase demand for Type A codes. Views are also sought in relation to the current classification of Type A codes.

Question 7: Is the current classification of Type A codes satisfactory?

Question 8: Do you agree that demand for Type A codes is unlikely to increase significantly in the future? If not, what other codes should we consider making Type A?

 

Use of Type B codes

4.12 As already indicated, future demand for Type B codes is highly uncertain. Historically, Type B codes have grown as a result of indirect access operators allowing customers to make cheaper calls (national and international), and this looks likely to continue. However, because these codes may now be used additionally by service providers, future demand for these codes may also be driven by content services and facilities (such as voicemail) as a means of allowing service providers to provide similar services to those of network operators using Type C codes. Oftel would welcome views about future likely demand for Type B codes.

4.13 Oftel would also welcome views in relation to short 3-digit access codes for competitive services (such as 144, 131, 132, 133). These codes are only used by BT and CWC whereas other operators have 4-digit codes, and it could therefore be argued that these are inconsistent with supporting effective competition and competitive neutrality, and should be withdrawn. The CBA considered the possibility of withdrawing all 3-digit Type B codes to become 5-digit codes in Option 2. However, it concluded that this proposal had a number of significant drawbacks from an economic perspective, not least that the withdrawal of familiar numbers would be inconvenient for the consumer, while imposing costs on operators offering a substantially greater number of applications behind access codes than other operators. Oftel recognises that the arguments are finely balanced, and would welcome the views from interested parties on this matter.

Question 9: What are your views in relation to future demand for Type B codes? Do you agree with Oftel’s assessment that future demand for these codes may be driven by content services and facilities?

Question 10: Do you think that BT and CWC should continue to hold 3-digit codes (like 144 and 131)? If not, should some or all of them be withdrawn and what should be the criteria for withdrawal?

Question 11: If you do consider that allocation of Type B access codes should be on the basis of company size, level of services or other similar parameter, how could this be managed?

 

Use of Type C codes

4.14 Oftel recognises that future demand for Type C codes is likely to be high, with fixed network and mobile operators continuing to use these codes as a means of introducing new services and facilities. In particular, the developing mobile market is likely to increasingly make use of Type C codes in the future, as mobile operators introduce new services and facilities which may be accessed by short codes. This demand scenario was highlighted in the CBA, which stated that, in the absence of regulation, future demand for Type C codes was likely to expand to take up whatever is made available, and that the provision of a plentiful supply of C codes was important in supporting service innovation.

4.15 However, while all 29 of the 3-digit codes designated as Type C codes are in use by at least one operator for some purpose, given that different operators may use identical codes, there remains significant unused capacity within these ranges. Moreover, the majority of Type C codes comprise either three or four digits, and it therefore remains open to operators to move to longer digit codes (such as 5-digit codes) as a means of increasing Type C capacity. Also, there is no local dialling for mobile phones and, as a consequence, mobile operators can, and do, use short codes (ie the 2XX to 9XX dialling space). This represents a significant level of available supply for C code use for mobile operators, and Oftel may wish to consider authorising the use of short (not access) codes for mobile operators (not currently prohibited).

4.16 Accordingly, there would appear to be no requirement at this stage to consider methods to increase the current supply of Type C codes. Indeed, given that these codes can only be used by fixed and mobile network operators, it could be argued that this is not an appropriate use of a scarce resource, and that there is a strong case for redesignating certain Type C codes as B codes (as outlined in Option 1 of the CBA). This would enable service providers to compete on a more equitable basis with mobile and fixed network operators. Any redesignation of Type C codes, as discussed in the CBA, would only have a minor effect on the ability of network operators to offer innovative services given the significant available Type C capacity at present (see paragraph 4.15).

Question 12: What are your views in relation to future demand for Type C codes?

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Consultation details

Oftel is seeking comments on its proposals for changes to the allocation of access codes. The initial consultation period will run until 11 August 2000. There will then be a further period to 1 September 2000 during which comments are invited on any submissions made to Oftel during the initial period.

Written comments should be submitted to:

Josephine Ibegbuna
Oftel
50 Ludgate Hill
London EC4M 7JJ

Tel: (020) 7634 8981, Fax: (020) 7634 8784

Alternatively, please e-mail

Written comments will be made publicly available in Oftel’s Research & Intelligence Unit unless confidential. Respondents are therefore asked to separate out any confidential material into a clearly marked annex, which is clearly marked as such. In the interests of transparency, respondents are asked to avoid confidentiality markings wherever possible. All written submissions may be viewed on request at Oftel’s Research & Intelligence Unit, and can be arranged by calling (020) 7634 8761.

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Annex A

Allocated trye B Access Codes

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Annex B

Network Constraints on the Length of Access Codes

1     Telephone networks can only handle a finite, and defined, number of digits. In the event that too many digits are dialled, the additional digits will be lost.

2     For international calls networks must be able to handle a maximum of 15 digits for the international number plus any digits necessary for international access – in the UK these are ‘00’ for normal international calls and ‘000’ for international ISDN calls. This gives a total maximum of 18 digits to be dialled for international calls from the UK.

3     The current maximum number of dialled digits that all UK networks can handle is 22 and, taking account of the 18 digit maximum number for international calls, this is sufficient for dialling international calls not using indirect access. For calls made using indirect access, however, additional digits need to be dialled – those of the relevant Type B access code. In certain circumstances the 22-digit limitation of UK networks can be critical for this type of call.

4     Type B access codes are used in two distinct modes: single-stage call set-up; and two-stage call set-up. This is illustrated in Figure1.

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  5     In single-stage call set-up all the dialled digits of the access codes and the following number are treated as a single unit, or ‘string’, by the telephone networks in setting up the call. Accordingly, the number of digits in the access code plus the number of digits in the following dialled number must not exceed the maximum number of digits that networks can handle. As already indicated, an international ISDN call from the UK uses the initial digits ‘000’ which are followed by up to 15 further digits of the international number – 18 in total. This means that, with the current maximum of 22 digits that can be handled by UK networks, the number of digits in access codes used in this way must not exceed four. However, from the latter part of this year, with the withdrawal of ‘000’ for international ISDN access, this could be increased to five digits.

6     In two-stage call set-up the dialled digits are treated as two distinct strings by the networks: those in the access code as one string and those in the ensuing dialled destination number as another. The originating network makes a call to the network identified by the access code on the basis of the digits in the access code and passes any further digits to that network as part of that call. The second network may then use the subsequent dialled digits to verify the caller’s identity and set up the call to the required destination. This means that the originating network only has to deal with the digits in the access code rather than all the digits dialled. Accordingly, the number of digits in access codes used in this mode could therefore be greater than the 4-digit limitation of those used for single-stage call set-up.

7     In practical terms, the limit on the total number of digits which can be dialled does not apply to Types A and C access codes as the useful code length for these is far shorter than the network capability.

8     To increase the number of digits that telephone networks can handle would be costly and time consuming, not only for the operators, but also for customers, as some types of customers’ equipment have limitations in respect of the maximum number of dialled digits. The costs of any change are therefore likely to be much greater than just those relating to operators.

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Annex C

The European Perspective

1     The 1997 European Green Paper on a Numbering Policy for Telecommunications Services in Europe identified several areas which are relevant to access codes. These relate mainly to the implementation of Carrier Pre-Selection and Carrier Selection across Europe and the need for all European National Regulatory Authorities (Oftel in the UK) to discharge their responsibilities of number allocation in a competitively neutral way.

2     Since a CEPT (the European Conference of Posts and Telecommunications) agreement in 1976 the UK has earmarked all access codes beginning with ‘11’ for European harmonisation, and this range has therefore not been allocated for UK-only purposes. The ‘11’ range would naturally be a Type A code in that it has a common meaning and use. To date, ‘112’ has been allocated in Europe for Emergency Service and 118 for Directory Enquiries. A further code (115) has been reserved in Europe for International Assistance Operator.

3     The Emergency Service code ‘112’ was activated in the UK at PhONEday (16th April 1995) and now runs in parallel with the traditional ‘999’.

4     Although ‘118’ was allocated for provision of competitive Directory Enquiries in Europe, it was left to individual countries to decide how many digits should follow the ‘118’ to provide competing services. The Republic of Ireland, for instance, has decided to adopt a fairly open sub-structure using a 5-digit code, 118XX, with the XX being allocated, on application, to DQ Service Providers who meet the requisite conditions. However, the Irish Republic is not making available the ranges 1180X, 1181X or 1189X on the grounds that it considers that these are the most likely ranges for any future European harmonisation. It considers that the available capacity – some 70 codes using two digits (XX) minus the 1180X, 1181X and 1189X ranges – is sufficient for any Service Provider needs for the provision of competitive national and international DQ services.

5     A recent ETO (European Telecommunications Office) Report, Final Report on Harmonisation of Short Codes in Europe, was agreed by ECTRA (European Committee for Telecommunications Regulatory Affairs) at its plenary meeting in December 1998. This recommends that a separate range from 10..., 19..., or 99... (these last are not UK access codes) may be required for Harmonised European Short Codes (HESC).

6     However, as already indicated Oftel proposes addressing the shortfall in Type B access codes by redesignating codes 101 to 109 as Type B codes. While these codes are currently reserved for European harmonisation following the ECTRA recommendation, there is no evidence at the present time that further harmonisation of access codes is likely in the future.

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Annex D

Summary of Questions

Question1:     Do you agree with Oftel’s view that Option 1 from the CBA, as detailed in this chapter, should be implemented? If so, do you consider that Option 1 should be implemented all in one go, or is there merit in using a phased approach, as outlined above?

Question 2:     Should future Type B access code allocations be made on the basis of either company group or licence?

Question 3:     In the light of Oftel’s statutory responsibility to ensure numbering capacity, what should be done to prevent the exhaustion of Type B codes in the event of Type B code allocations being made on an unrestricted basis?

Question 4:     If Type B access code allocations were made on a company group or licence basis, should the maximum holding be limited to one single-stage call set-up plus one two-stage call set-up code per applicant?

Question 5:     If yes, should these rules be applied to existing Type B allocations, and should holdings over any specified amount be withdrawn, or should operators be restricted to their current allocation?

Question 6:     If not, what should be the maximum permitted holding of each sort and what should be the criteria for allocation?

Question 7:     Is the current classification of Type A codes satisfactory?

Question 8:     Do you agree that demand for Type A codes is unlikely to increase significantly in the future? If not, what other social codes should we consider making Type A?

Question 9:     What are your views in relation to future demand for Type B codes. Do you agree with Oftel’s assessment that future demand for these codes may be driven by content services and facilities?

Question 10:     Do you think that BT and CWC should continue to hold 3-digit codes (like 144 and 131)? If not, should some or all of them be withdrawn and what should be the criteria for withdrawal?

Question 11:     If you do consider that allocation of Type B access codes should be on the basis of company size, level of services or other similar parameter, how could this be managed?

Question 12:     What are your views in relation to future demand for Type C codes?

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Glossary

Access Codes – Short dialled numbers beginning with the dialled digit ‘1’.

CEPT – Conférence Européenne des Postes et des Télécommunications (the European Conference of Posts and Telecommunications). The original body concerned with pan-European topics for Posts and Telecommunication services.

Calling Line Identity (CLI) – a facility that enables identification of the number from which a call is being made.

Carrier Pre-Selection (CPS) – the facility offered to customers which allows them to opt for certain defined classes of call to be carried by an operator selected in advance (and having a contract with the customer), without having to dial a routing prefix or follow any other different procedure to invoke such routing.

Class Licence – a licence granted by the Secretary of State to a class of people which permits any within the relevant class to provide specified services without the need for an individual licence or, in certain circumstances, the need to register the system or provide the service.

Cost Benefit (Analysis) – the analysis and comparative assessment of the relative costs and benefits of a particular course of action.

Easy Access – a facility allowing a BT customer to select an alternative operator using a short access code, usually 3 or 4 digits in length. Outgoing calls use BT's lines and network to the first point of interconnection and are then switched to the chosen operator.

ECTRA – European Committee for Telecommunications Regulatory Affairs. ECTRA is the major European forum for the discussion of regulatory issues, set up within the framework of the European Conference of Posts and Telecommunications (CEPT).

ECTRA-PTN the ECTRA Project Team on Numbering. A team, set up by ECTRA, to take forward European matters relating to Numbering. It reports to the main ECTRA meetings. ECTRA has a number of such Project Teams covering different aspects of telecommunications.

Equal Access -the ability of a customer connected to one operator to choose to have their long-distance and international calls carried by that operator or by another operator, with no extra processes or procedures required if they choose that other operator rather than the operator to whom they are connected (often known as Carrier Pre-Selection).

ETO – the European Telecommunications Office. A staffed office, located in Copenhagen, funded by ECTRA. It carries out and co-ordinates studies into European telecommunications matters on behalf of the EC and others and works in conjunction with ECTRA and its Project Teams.

Group (Company) – A parent undertaking and its subsidiary undertakings as defined in Section 262(1) of the Companies Act 1985.

Harmonised European Short Codes (HESC) – These are short numbers intended to have a common significance in all European countries. Examples are ‘00’ for international access, ‘112’ for emergency services, ‘118’ for access to competitive Directory Enquiry services.

Indirect Access – where a customer’s call is routed and billed through operator A’s network even though the call originated from the network of operator B. It is the generic term for both easy access and equal access.

National Regulatory Authority (NRA) – the body or bodies, legally distinct and functionally independent of the telecommunications organisations, charged by a Member State with the elaboration of, and supervision of compliance with, telecoms authorisations.

Numbering Conventions – A set of rules and principles relating to the use and management of numbers from the National Numbering Scheme. The Numbering Conventions are published on Oftel’s Internet pages.

Numbering Scheme (also termed The UK Numbering Scheme, Specified Numbering Scheme and The National Numbering Scheme) – A scheme for the allocation and re-allocation of numbers which is specified by the Director General and described in a list made available by him for public inspection. The list is published monthly on Oftel’s Internet pages – http://www.oftel.gov.uk

Operator/ Network Operator – An organisation, generally with its own network, entitled to obtain allocation of numbering capacity from Oftel. The relevant criteria are identified in the Numbering Conventions.

PhONEday – 16th April 1995. The date on which all geographic codes were changed by the insertion of a ‘1’ following the initial dialled ‘0’ (ie they became ‘01......’).

Service Provider – provider of telecommunication services, or services with a telecommunication service component, to third parties whether over its own network or otherwise.

Significant Market Power – The Significant Market Power test is set out in various European Directives, including the Interconnection Directive, the Amending Leased Lines Directive and the Revised Voice Telephony Directive. It is used by the National Regulatory Authorities (NRA) such as Oftel to identify those operators who must meet additional obligations under the relevant directive. It is not an economic test, rather it requires a consideration of the factors set out in the test within a specified market.

Sterilisation (period) – The period of time, following withdrawal, during which a number is not allocated or used for another purpose in order to minimise the potential for mis-dialling and mis-routing of calls.

Switchless Resellers – Service Providers who do not have their own network.

 


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