A consultation document issued by the Director General of Telecommunications on proposals for the allocation of Access Codes for Directory Enquiry Services and neccasary changes to the Numbering Conventions

Contents

Summary

Chapter 1 Introduction

Chapter 2 Main issues

Chapter 3 Operator responses

Chapter 4 Oftel’s Proposals for Allocation of Codes for Directory Enquiry Services and necessary changes to the Numbering Conventions

Chapter 5 Consultation

Annex A Draft changes to the Numbering Convention

Glossary

Summary

S.1 Oftel issued a Statement on 19 September 2001 entitled Access codes for directory enquiry services. That Statement included proposals for the allocation of a new range of codes for directory enquiry (DQ) services, namely codes beginning with 118, and the withdrawal of the 192 (currently used for national DQ services). Oftel also plans to withdraw 153 (currently used for international DQ) and any other access codes (where used) for DQ services, at the same time as 192 (except for the 195 access code for blind and otherwise disabled consumers).

S.2 Oftel has formed an industry working group to progress the detailed implementation of the new arrangements for DQ services, and from this a sub-group was formed to consider the numbering issues surrounding the DQ implementation – the ‘DQ numbering sub-group’.

S.3 The DQ numbering sub-group has provided responses to requests for information from Oftel on the allocation procedure for the new DQ codes and surrounding issues.

S.4 Changes will be necessary to the Numbering Conventions to allow implementation of the allocation procedure for codes for DQ services.

S.5 This consultation document sets out the issues surrounding DQ code allocation, a summary of operator responses to the issues, and finally Oftel’s proposals, including necessary changes to the Numbering Conventions.

S.6 Oftel is seeking the views of stakeholders (ie the telecoms industry and consumers) on its proposal for allocation of DQ codes and necessary changes to the Numbering Conventions.

S.7 This consultation will last for 28 days. Following the end of the consultation period, and taking any representations made as a result of this consultation into account, Oftel expects to publish a new issue of the Numbering Conventions, to replace the issue published on 30 November 2001, which will incorporate the necessary changes.

Chapter 1

Introduction

1.1 As provided in the Third Issue of the Numbering Conventions (‘the Conventions’) – (November 2001), Oftel needs to ensure that numbers are allocated to operators on a fair and equitable basis; any arrangements for allocation should also support effective competition.

1.2 Oftel’s standard procedure is for numbers to be allocated on a first-come first-served basis. However, the opening up of a new number range calls for a modified approach, otherwise there may be a rush from the moment the numbers are designated for assignment, and it might be difficult to fairly determine the first applicant for any particular number.

1.3 As provided in the Conventions, Oftel also needs to ensure that numbering arrangements must be able to meet current requirements for numbers, and also to cope with anticipated growth and demand for numbering in the future.

1.4 In drafting the proposal for the number allocation procedure for DQ codes, Oftel has taken account of the views and ideas of the operators and service providers who have volunteered to be part of Oftel’s DQ numbering sub-group and who wish to provide DQ services. In doing this Oftel sought specific information from them as follows:

• how many codes they would need for their own organisation and for sub-allocation, how many codes sub-allocatees were likely to request from an eligible operator, and whether sequential codes were considered to be important;
• comments on the allocation procedure proposed by Oftel in Oftel’s September 2001 Statement –Access codes for directory enquiry services;
• details on which codes they considered to be ‘golden number’ codes, and which 118 codes could be problematic if they were allocated for new DQ services.

1.5 The Third Issue of the Numbering Conventions will require changes to ensure they comprise arrangements for codes for DQ services. The changes are discussed below, and the draft Numbering Conventions are shown in Annex A.

Chapter 2

Main Issues

2.1 Oftel considers that there are four main issues surrounding the allocation of DQ codes:

• Length of codes
• Eligibility to apply for codes
• Application and allocation procedures
• Number of codes per operator/ service provider.

Length of codes

2.2 The designated code range for the new DQ services is 118. Oftel needs to decide whether to allocate 5- or 6-digit 118 codes. If 5-digit DQ codes are issued ie 118XX this gives a pool of 100 codes compared to 1000 codes if 6-digit codes are issued ie 118XXX.

2.3 Oftel needs to consider whether shorter codes are more beneficial to the consumer ie fewer digits to dial and remember, and balance this with the fact that longer codes provide greater capacity to meet current and future demand as well as providing a greater choice of codes for operators.

Eligibility to apply for codes

2.4 Oftel currently only allocates numbers to operators providing publicly available telecommunications services and running a telecommunication system under a licence granted under Section 7 of Telecommunications Act 1984, whether that is an individual or a class licence, containing a Numbering Arrangements Condition. Oftel may also consider allocating numbers or codes to Systemless Service Providers (SSPs) or others in demonstrably exceptional circumstances (eg. where the provider is in the process of setting up a system).

2.5 However, those who are not eligible to apply for an allocation of numbers may also wish to compete to provide DQ services. Numbering Convention 2.2 sets out that those not eligible to apply for numbers should seek a sub-allocation from an eligible operator.

Application and Allocation Procedures

2.6 As explained in paragraph 1.2, although as provided in the Conventions Oftel normally allocates numbers on a first come first served basis, in this particular case Oftel needs to consider an alternative method of initial allocation so that DQ codes are allocated on a fair and equitable basis. Any allocation method will also need to take account of the fact that some codes are considered more ‘valuable’ because of the way they look or sound – so-called ‘golden numbers’.

2.7 A suitable timetable will need to be drawn up to allow all potential applicants sufficient time to submit an application for the allocation procedure. The timetable should allow time for operators to receive orders from sub-allocatees.

2.8 The allocation procedure needs to be transparent to applicants to ensure that codes are allocated in a non-biased way.

Number of codes per Operator/Service Provider

2.9 Another consideration for Oftel is whether to restrict the number of codes allocated to any one operator and/or service provider.

2.10 If Oftel allocates DQ codes at 5-digit length and demand is for more than 100 codes, a maximum limit may need to be set on the number of codes that can be allocated per operator or service provider.

2.11 Oftel will need to consider whether any restriction in the number of codes may stifle competition. For example, if a service provider can only apply via an operator, and that operator has submitted an application for more than half the maximum number of codes allowed to provide its own DQ services, the service provider will not be able to apply for as many codes and will not be able to compete effectively.

2.12 However, if there is no restriction on the number of codes per applicant, operators may apply for many ‘golden number’ codes and stockpile them, thus preventing other operators from getting more desirable codes.

Chapter 3

Operator Responses

3.1 Operator responses to the specific requests for information as outlined in Chapter 1, are summarised below.

DQ Questionnaire Responses

3.2 19 out of the 22 respondents said they would apply directly to Oftel for 118XX(X) codes, and out of the number of codes required by the 19 direct applicants, 74 would be for their own use and 308 for sub-allocation.

3.3 Less than half of respondents believed the ability to obtain sequential codes to be an important feature of the allocation procedure.

Length of Codes

3.4 There were mixed responses over whether 5 or 6 digit codes were easier for consumers to remember.

3.5 Another suggestion was to allocate most of the 118 code range as 5 digits and keep the remainder of the range back for expansion to 6 digits, if required.

3.6 One respondent believed that demand could be met using 5 digit codes only, and thought it extremely unlikely that the indicated demand for DQ codes would materialise when the lottery day arrived. The respondent thought that the final decision on number length should be delayed until immediately before the lottery, and that applicants should provide 3 preferred choices of both 5 and 6 digit codes.

3.7 Another respondent believed that the figures for the number of codes required in response to the DQ questionnaire were likely to be exaggerated by 50%.

3.8 Several respondents believed that issuing 6 digit codes from the outset gives a level playing field for all operators wishing to provide DQ services, whenever they enter the market.

3.9 Some operators commented that 6 digit codes would provide a larger supply for future demand, and provide more choice of ‘golden numbers’.

‘Golden Numbers’ and Protection of Problematic Codes

3.10 There was general agreement that some DQ codes are more commercially advantageous – ‘golden numbers’ – and they should be allocated on a fair basis. However, there was no specific agreement on which codes are ‘golden numbers’. One operator believed that ‘golden numbers’ should be protected.

3.11 Operators agreed that certain codes should not be allocated because of potential consumer confusion eg. 118100, 118999, or where codes have historical significance eg 118192, 118153, etc.

3.12 One operator suggested that other codes should be protected because of potential mis-dialling eg. Reading code area 0118 3XX or 0118 9XX.

Application Procedure

3.13 There was general support by operators for having a one week period when all applications for DQ codes should be submitted. Thereafter, applications should be dealt with on a first come first served basis.

3.14 A couple of respondents suggested that in order to guarantee that only genuine applicants apply, operators should submit a bond, refundable when the DQ service is delivered. Figures of £100k or £200k were suggested.

3.15 There was a suggestion that companies, other than those running a public telecommunication system under a licence granted under Section 7 of Telecommunications Act 1984, should be able to apply for DQ codes.

3.16 Some operators believed there should be a restriction on the numbers of codes allocated per operator to prevent stockpiling. Also, that operators should provide several choices per DQ code required, in case the first code choice they have selected is not available.

3.17 Operators suggested there should be protection against associated companies applying together to get a greater number and a wider selection of codes between them.

Allocation Procedure

3.18 Respondents generally favoured a lottery process for allocation.

3.19 Operators suggested that when allocating the DQ codes, companies should be selected at random and each given their first choice of code, then at random again for second code, etc. until all codes have been allocated. If the operator’s choices of codes have already been allocated to other operators, a choice should be offered from the remaining codes.

3.20 Other suggestions were to set aside ‘golden number’ codes and allocate them first, or to allocate every operator their first choice, and any clashes to be resolved by random selection.

3.21 Operators were not in favour of giving preference to operators to be allocated codes that duplicate codes those operators already use in other countries.

3.22 It was questioned whether there should be a distinction between codes used for National DQ services (which are generally cheaper) and International DQ services. However, there was a suggestion that this would not work as consumers would not know the principles being used, and in addition, not all companies would offer an International service and the responsibility of marketing access codes/services lies with the Operator/Service Provider. It has also been suggested that 118 access codes could be allocated in tariff bands eg. codes in the 1181XX range could be for those services costing 10p, codes in the 1182XX range for those costing 20p.

3.23 One respondent believed the consultation on allocation procedure for DQ codes to be both unnecessary and time-consuming as Oftel had already consulted on access codes for DQ services. Also, it believed that all those with a serious interest in applying for access code(s) were attending the DQ numbering sub-group and would therefore already have given their views on the allocation procedure. However, the same respondent had assumed that the consultation period would be for 3 months, instead of the proposed 28 days.

Withdrawal Procedure

3.24 There was general consensus that Oftel should consider withdrawing allocated codes not in use after a period of time eg six months. The codes should go back into the pool for re-allocation on the first-come first-served basis.

3.25 Operators queried how Oftel would decide whether a code was not ‘in use’. Suggestions for ‘in use’ were: data-built on all networks; billing and interconnect arrangements in place; and code actively marketed.

3.26 One operator suggested that low usage should result in withdrawal of the code by Oftel, but did not explain how this could be measured.

Chapter 4

Oftel’s Proposal for Allocation of Codes for Directory Enquiry Services, and Necessary Changes to the Numbering Conventions

Length of Codes

4.1 Codes allocated for directory enquiry services will be six digits in length ie 118XXX. Although Oftel’s Statement entitled Access codes for directory enquiry services (September 2001) stated that Oftel will allocate 5-digit numbers for DQ services, as a result of a general consultation with interested parties, and discussions with the DQ numbering sub group it has become clear that 6-digit codes are actually required in this particular case.

4.2 The main reasons for allocating 6-digit codes are set out below:

• it provides sufficient codes to meet current forecast demand, and allows enough codes for future use. Responses to the DQ Questionnaire indicated that a total of 382 codes are required for both operator’s own use and for sub-allocation. Oftel acknowledges that the DQ Questionnaire may have over-estimated demand, but Oftel also considers that it is equally possible that not all operators or service providers were able to respond to the questionnaire. Therefore, on balance, Oftel considers that the additional code capacity obtained by using six digit codes is likely to be necessary;
• Oftel believes that opting for 5-digits could lead to the need for some form of rationing process. It believes that the delay that would be caused by the need to design and consult on such a process could not be justified;
• there are more codes available with 6-digits so operators will have a wider choice. There will be more ‘golden numbers’ and more opportunity for sequential numbers to be allocated to the same operator or service provider;
• by only allocating 6-digit codes from the outset (rather than 5-digit codes initially and six digit codes subsequently if necessary), it provides a level playing field for companies offering DQ services, no matter at what time a company enters the market. There will also be less confusion for the consumer, as a DQ code will always be 6-digits long;
• Oftel has seen no objective evidence that 6-digit codes are less memorable for consumers than five digit codes;
• the cost to the caller of dialling an extra digit is insignificant. This was indicated in Figure 4.2 of the cost benefit analysis (CBA) carried out by Ovum on behalf of Oftel as part of the Consultation on access codes for directory enquiry services (November 2000).

4.3 Oftel will change Numbering Convention A9.6, which currently states that ‘allocation of access codes will be on the basis of five-digit ‘1XXXX’ codes’, to allow for 6-digit codes to be allocated for DQ services. The draft Convention is set out in Annex A.

‘Golden Numbers’ and Protection of Problematic Codes

4.4 Oftel recognises that operators consider that some codes are more commercially advantageous than others. These are commonly referred to as ‘golden numbers’. However, such codes are not always easily identifiable because what may appear ‘golden’ to one operator may not be to another.

4.5 Oftel therefore will not try to identify or set aside ‘golden numbers’. The lottery process for allocation (as discussed below) will ensure that operators are given equal opportunity to be allocated codes they consider ‘golden’.

4.6 Oftel will protect a minimal number of DQ codes that it considers to be problematic ie codes that may be confusing to the consumer such as 118100, 118999, etc. and codes that have historic significance such as 118153, 118192, 118195, etc.

4.7 The full list of available codes for full national and international directory enquiry services (and those shown as protected) will be available on Oftel’s Numbering web site before the start of the application procedure.

Eligibility to Apply for Codes

4.8 As provided in the Conventions (Conventions 2.1 and 2.2) , Oftel will only allocate DQ codes to those operators providing publicly available telecommunications services and running a telecommunication system under a licence granted under Section 7 of Telecommunications Act 1984, whether that is an individual or a class licence, containing a Numbering Arrangements Condition, or it may consider allocating numbers to SSPs or others in demonstrably exceptional circumstances, such as where the provider is in the process of setting up a system.

4.9Those not eligible to apply for allocations, but who wish to compete to provide DQ services, should seek a sub-allocation(s) from an eligible operator.

4.10 In addition to the standard criteria above, Oftel will normally only allocate DQ codes to operators who have confirmed in their application that the codes applied for will be used to provide full national DQ service or an international DQ service (or both). Oftel will normally specify a condition on the allocation that the code(s) must be used for the service(s) and by the operator/service provider indicated in the application.

4.11 The definitions of DQ service, full national DQ service, international DQ service are shown in the Glossary.

4.12 Those companies not eligible should apply for a sub-allocation via an eligible operator of their choice.

Standard Procedures

4.13 Codes for directory enquiry services will be Type B Access Codes. The main reason for this is that Type B codes are the only Access Codes allocated by Oftel specifically for use by an operator or a sub-allocatee, and can be used for indirect services.

4.14 Oftel will change the definition of Type B access codes in Convention A9.4, and will add a further type of Type B access code in Convention A9.9. The Conventions will then allow for codes for DQ services to fall within the Type B category. The draft Conventions are set out in Annex A.

4.15 Operators should use the existing S10 Application Form to apply for DQ codes – modifications will be made to the Form in time for the application procedure.

4.16 Any codes allocated after the proposed DQ code allocation procedure will be on a first-come first-served basis.

Application Procedure

4.17 Oftel will announce the time period during which it should receive applications for DQ codes. The announcement will allow time for sub-allocatees to submit orders to operators.

4.18 As discussed above, there may be no restriction on the number of DQ codes operators can apply for. However, Oftel will normally request the following information to support an application for codes for DQ services:

• evidence of a firm order(s) from the sub-allocatee eg customer order, letter from account manager, etc. This will prevent a sub-allocatee from approaching several operators to get more than one code for the same directory enquiry service;
• alongside every code applied for, the operator should indicate the company offering the service and the nature of the service eg. Zebra Telecom plc – Full National Directory Enquiry Service in French. This information will be shown alongside the code on the allocation certificate to prevent misuse of the code or trading.

4.19 Currently, operators are asked to provide 3 choices for Type B Access Codes - this will be the same for DQ codes. Operators should avoid duplication of choices across the codes applied for.

4.20 Oftel will use all reasonable endeavours to make an allocation of DQ codes within a period of 28 calendar days, as specified in Convention 4.5.

4.21 If an operator fails to provide all the relevant information requested on the application form, including any information sought by Oftel during the 28-day period following receipt of the application, that operator will not be eligible to be entered into the initial allocation procedure and will have to re-apply at a later date.

4.22 Operators that have provided all the information requested in the application form (and any clarifications subsequently sought by Oftel during the 28-day period following receipt of the application) will be eligible for the allocation procedure.

Allocation Procedure – Directory Enquiry Code ‘Lottery’

4.23 Oftel will set a date for the DQ code lottery which will be approximately 1 week after the end of the 28 day application processing period.

4.24 Oftel will request all applicants to send one representative to the lottery.

4.25 Oftel will chair the lottery and it will be held at a venue designated by Oftel.

4.26 Any company that has chosen a code as a first choice that no other company has chosen as a first, second or third choice will be automatically allocated that code.

4.27 Oftel will enter the names of all remaining applicants into a ‘hat’ – including a separate entry for each sub-allocatee.

4.28 The first company drawn will be allocated one code from their choices, as shown on the application form. The next company drawn will be allocated one code, and so on until every company has been allocated one code.

4.29 A company that has requested more than one code will go back into the hat for the next round. The process will be repeated, and so on, until all codes have been allocated to all companies.

4.30 At any point in the lottery, where all the choices of a particular company have already been allocated to other companies, the representative of that company must select another code from those remaining before the lottery moves on to the next company. In this situation, the representative is responsible for selecting an alternative code on behalf of sub-allocatees as well as on behalf of his or her own company.

4.31 No preference will be given to companies seeking to be allocated codes that duplicate codes they use in other countries, and Oftel will not allocate sequential codes to companies (unless this happens through the lottery process).

4.32 Oftel will not seek bonds from operators as such a procedure is not covered by the Conventions, and so would not be enforceable.

4.33 Oftel will not set bands of codes based on tariff eg. 10p codes in 1181XX, 20p in 1182XX, etc. as this may prevent operators from changing the tariff for their DQ service unless they change the code, which would not be beneficial to consumers.

4.34 In the week following the lottery, Oftel will send out an Allocation Certificate to operators showing the code(s) allocated to that operator and its sub-allocatees. The name of the company providing the directory enquiry service, and the specific type of service will be shown alongside the code. Operators are advised to only set the code up for the company and the service shown. This should prevent misuse of the code and trading.

4.35 All allocated directory enquiry service codes will be listed on Oftel’s website. The name of the operator to whom the code has been allocated, together with the specific directory enquiry service, and the name of the sub-allocatee (where appropriate) will be shown against each code. Other codes, whether ‘Protected’ or ‘Free’ will also be shown on the website.

4.36 Only after the end of the final week of the whole procedure will Oftel process new or further applications for directory enquiry codes – on a first-come first-served basis.

Withdrawal Procedure

4.37 Oftel will consider withdrawing directory enquiry codes, in line with the Conventions, that are ‘not in use’ after 6 months from the date of allocation.

4.38 ‘Not in use’ is defined as:

• where the code(s) has not been data-built on all networks;
• where no billing and interconnect arrangements are in place;
• where the code(s) has not been actively marketed.

4.39 Operators must approach Oftel with a justification to change the service behind a directory enquiry code and/or where there is a requirement to change the operator/ service provider offering the DQ service.

4.40 Oftel will withdraw directory codes that it discovers are not being used for the service shown on the Allocation Certificate and/or codes that have been traded between companies (without previous agreement by Oftel).

4.41 Withdrawn directory enquiry codes will go back into the pool of available codes and will be allocated on a first-come first-served basis.

4.42 Operators should inform Oftel when a code(s) is not likely to brought into use or where it ceases to be in use, and relinquish it to Oftel so that it can be returned to the pool of available codes

Chapter 5

Consultation

5.1 The consultation will run for 28 working days until 28 January 2002. The 28-day period is appropriate as a draft version of the allocation procedure has already been presented to the DQ numbering sub-group – the main stakeholders. Also, Oftel considers that a longer consultation period would delay competition in the directory enquiry services market. Through this consultation, Oftel is seeking the views of all interested parties.

5.2 Where possible, comments should be made in writing and sent by e-mail to jonathan.dawson@oftel.gov.uk. However, copies may also be posted or faxed to the address below. If any interested parties are unable to respond in one of these ways, they should discuss alternatives with the Oftel manager named below:

Jonathan Dawson
DQ Code Allocation Consultation
Numbering Unit
Oftel
50 Ludgate Hill
London EC4M 7JJ

Fax: + 44 (0)20 7634 8784
E-mail: jonathan.dawson@oftel.gov.uk

Further copies of this document

5.3 This document can be viewed in the Publications section of Oftel’s website (www.oftel.gov.uk), under classification Responses to Oftel consultations. Paper copies and more accessible formats such as large print, Braille, disc and audio cassette can be made available on request. Please contact Oftel’s Research and Information Unit by phoning 020 7634 8761 or by sending an e-mail to infocent@oftel.gov.uk.

Publication of comments made by stakeholders

5.4 On this occasion, Oftel is not programming a formal period during which interested parties may comment on the responses made by others. Nevertheless, in the interests of transparency, comments will be published, except where respondents indicate that a response, or part of it, is confidential. Respondents are therefore asked to separate out any confidential material into a confidential annex which is clearly identified as containing confidential material. Oftel will take steps to protect the confidentiality of all such material from the moment that it is received at Oftel’s offices. However, in the interests of transparency, respondents should avoid applying confidential markings wherever possible.

5.5 Non confidential responses can be viewed on Oftel’s website in the Publications section under Responses to Oftel consultations. Comments can also be viewed at Oftel’s Research and Information Unit. Appointments must be made in advance by phoning 020 7634 8761 or sending an e-mail to infocent@oftel.gov.uk.

e-mail notifications

5.6 Oftel has a free e-mail based mailing list to help people stay informed about the work that Oftel is doing. Each time an Oftel document is published and placed on Oftel’s website at www.oftel.gov.uk, subscribers to the list receive an e-mail alert. To register, please go to the What’s New section of the website and access the electronic form.

Next Steps

5.7 Following the completion of the consultation exercise Oftel will publish a statement setting out its conclusions.

Annex A

Draft Changes to the Numbering Conventions

A9.4 Type B access codes have network-wide significance as they are used by the end users of one public telecommunications operator to have selected calls connected by an operator other than the one from whom they rent their telephone line (known as ‘Indirect Access’). For example, callers might use Type B codes to select Indirect Access providers for long distance and/or international calls. Type B codes can also be used by callers to access services available from their own operator’s system or another public operator’s system. These codes are allocated by Oftel.

A9.6 Given the need to ensure reasonable numbering capacity, allocation of access codes will generally be on the basis of five-digit ‘1XXXX’ codes. While three- and four-digit codes will no longer be issued, three- and four-digit codes already in use will remain in use. Access codes may, however, be withdrawn in accordance with Convention 6.

A9.9 There are generally three types of Type B Access Code:

Glossary

Allocation Certificate

A certificate issued by Oftel to operators showing the number range(s) allocated to them and signed by an Oftel employee who is authorised to do so the Director General of Telecommunications.

Directory Enquiry Service

A service which provides information on telephone numbers of subscribers who have not withheld their consent to being included in such a service, and is otherwise in conformance with Data Protection requirements.

International Directory Enquiry Service

A Directory Enquiry Service which provides information to UK subscribers on allocations of numbers from the numbering scheme(s) of at least one, probably several major non-UK countries.

National Directory Enquiry Service

A Directory Enquiry Service which provides information on allocations of numbers to subscribers from the United Kingdom numbering scheme to callers located in the United Kingdom. A National Directory Enquiry Service shall be considered a "full" National Directory Enquiry Service for the time being if it provides information on the geographic numbers (starting with the digits 01 or 02) of all business and residential listings and on other numbers used for comparable purposes to geographical numbers (e.g. 08 numbers used for main switchboards etc), where the subject of the listing has not withheld their permission for its inclusion.

Numbering Conventions

The Numbering Conventions are a set of rules and principles that govern the use, management and allocation of numbers from the United Kingdom’s Specifed Numbering Scheme.

S10 Application Form

A form on which eligible operators may apply for Type B Access Codes – available to eligible operators via Oftel’s web site.