Issued by the Director General of Telecommunications

30 November 2001

Contents

Summary

Chapter 1 Background

Chapter 2 Comments on the Introduction and on the General Conventions

Chapter 3 Comments on Conventions relating to the public switched network

Chapter 5 The Numbering Code

Annex A Non-confidential respondents to the February 2001 consultation document

Annex C The Numbering Code for the United Kingdom – Issue 1, 30 November 2001

Glossary

Summary

S.1 This statement sets out the changes that Oftel has made to the United Kingdom’s Numbering Conventions, the Third Issue of which is at Annex B.

S.2 The revised Numbering Conventions follow on from the consultation document, Revising the Numbering Conventions, issued by Oftel in February of this year.

S.3 The Numbering Conventions (‘the Conventions’) are a set of rules and principles that 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.

S.4 In addition, those codes and numbers which are outside the scope of the Numbering Arrangements Condition, and which should therefore not be dealt with in the Conventions, will now be covered by the new Numbering Code, which is at Annex C.

S.5 When compared with the second issue of the Conventions (April 1997), there are many changes, both major and minor. Main changes include:

• restructuring of the Conventions;

• creation of the Numbering Code;

• a new guiding principle in the Conventions – that Oftel will allocate numbers on a ‘first come first served’ basis;

• clarification that, firstly, only those operators who are running a system licensed under the Telecommunications Act 1984 are eligible for number allocations, but, secondly, this includes those running systems under a class licence, provided that such licences contain a ‘Numbering Arrangements Condition’;

• banning end user revenue share for 070 Personal Numbers;

• revision of the list of Conservation Issues coupled with the announcement that Oftel will, from six months after the publication of the new Conventions, allocate blocks of 1,000 numbers in more critical ‘Type A Conservation Areas’;

• formalisation of the practice that Oftel will not open new 100,000 ranges, whilst blocks are still free in already opened ranges within that code area; and

• revision of Status Indicators that appear on the SNS List.

Chapter 1

Background

1.1 This statement accompanies the publication, at Annex B, of the Third Issue of the Numbering Conventions for the United Kingdom (‘the Conventions’). Also attached, at Annex C, is the First Issue of the Numbering Code for the United Kingdom (‘the Code’), a code of practice for codes and numbers controlled by Oftel but which are outside of the scope of the Numbering Arrangements Condition and which should therefore not be dealt with in the Conventions.

1.2 This statement sets out comments made by respondents to the consultation document entitled Revising the National Numbering Conventions (February 2001), and the decisions that Oftel has made or its reasons for not adopting certain proposals. Minor changes to the text of the new Conventions, such as word order changes, that Oftel believes are of no policy significance are not covered by this statement. This statement follows the order of the new Conventions, unless otherwise stated.

1.3 In publishing the new Conventions, Oftel has additionally incorporated changes that result from the separate consultations initiated under the following statements:

• Access Codes: Options for the future, March 2001; and
• Restoring Trust in Personal Numbering, October 2001.

Future changes and publication

1.4 As stated in the February 2001 consultation document, Oftel intends, in future, to consult on any necessary amendments to the Conventions, when it consults on policy changes that would affect them (probably as an annex to the relevant policy consultation document). Changes will then periodically be incorporated into a new issue of the Conventions, without the need for a further consultation (this is what Oftel meant by the term ‘pre-agreed’, in relation to changes to the Conventions, used in paragraph 1.7 of the February 2001 consultation document). Such changes would take effect from the point when that new issue is published. Any new issue of the Conventions would be published and brought to the attention of all relevant parties in the usual way. The procedure for future changes to the Code is set out in paragraph 5.4 of this statement.

1.5 Future issues of the Conventions and the Code will be published on the Oftel website. It is not intended that future issues will be published in a paper format.

Replacement of ‘customer’ with ‘end user’

1.6 Oftel has decided that at various points in the new Conventions it is appropriate to replace references to ‘customer’ with the expression ‘end user’. This has been done to add clarity and, in some instances, to improve consistency.

Chapter 2

Comments on the introduction and on the General Conventions

The introduction

2.1 Oftel has decided to adopt this introductory text having considered (but rejected) the only substantive comment from an operator that Oftel should commit itself to act in accordance with Conventions. Naturally, Oftel will in all foreseeable circumstances act in this way. However, to commit Oftel to always act in accordance with the Conventions may fetter the Director General’s discretion in relation to his duties under Section 3 of the Telecommunications Act 1984.

2.2 One interesting by-product of this review has been a call from various sectors for clear consumer-orientated information about numbering. There was criticism that the Conventions themselves did not provide clear consumer information. This is not surprising as the Conventions are designed to be the rules or principles, under which Oftel manages and those to whom it allocates numbers use this resource; it is not intended in any sense to be a consumer guide. Accordingly, to further clarify the status of the Conventions, Oftel has added an extra sentence to paragraph 1:

2.3 However, Oftel has decided that having a clear and straightforward guide for consumers to numbering policy and practice would be useful and has therefore instigated a work package for 2001 to 2002 to produce such a guide.

Convention 1: rights, responsibilities and the review process

Oftel’s guiding principles

2.4 The following change to draft Convention 1.1 has been made at the suggestion of one operator. Oftel believes that this is a useful clarification and has incorporated it as follows (change underlined):

2.5 Respondents commented that draft Convention A10 need not be stated in such detail. Oftel agrees and believes that the principle contained in that draft Convention is already contained in Convention 1.1(c) (see also paragraph 3.50).

2.6 In addition, draft Convention 1.1 (f) has been amended in two respects. Firstly, at the suggestion of one respondent, it now reflects the fact that Oftel will take into account the need to anticipate innovative services as well as general growth when allocating, reserving or managing numbers from the Scheme. Secondly, in the light of the review of Conservation Areas that Oftel has undertaken, more detail of which is outlined below at paragraph 3.11 and onwards, and in Convention A.3, the term Watch Areas has been removed. Oftel keeps all geographic areas under review, or ‘watch’, through the annual audit, to check whether they should be subject to conservation measures. It is therefore misleading to refer to ‘Watch Areas’ as if they had a distinct status in conservation policy. Accordingly, the opening of 1.1(f) has been amended to read as follows:

Operators’ responsibilities

2.7 Oftel has decided that, as number portability is a licence requirement, there is no need for this to be restated in this part of the new Conventions. This does not, however, alter Oftel’s ability to seek information about portability arrangements from applicants for numbering capacity or as part of the Annual Numbering Audit.

2.8 Several operators criticised draft Convention 1.2(c), which stated that "Operators shall not brand numbers, nor associate a number range with a given operator". This criticism was based on a misunderstanding that Oftel is happy to clarify. The branding referred to here is not end user branding but, as stated, operator branding. There are no objections in principle to end users having, for instance, easily memorable numbers, or numbers which alphanumerically spell out their company name. The concern, in this instance, is that operators may brand ranges as their own which could prevent or deter number portability, thereby distorting competition. Accordingly, Oftel has retained Convention 1.2(c).

Reviews of the Scheme

2.9 Most operators questioned the explicit inclusion of the Telecommunications Numbering and Addressing Body (‘TNAB’) in draft Convention 1.4 as a relevant body. Various operators commented that this body does not exist. Oftel recognises that no such body has been approved by the Director. However, it is a requirement of the Numbering Arrangements Condition that the Director must consult with members of the TNAB in publishing the Conventions. Therefore references to the TNAB must remain in the Conventions.

2.10 Draft Convention 1.5 required that the normal consultation period be three months but that in exceptional circumstances a shorter consultation period may be appropriate. There were concerns expressed that Oftel may be arbitrary in its decisions on what amounts to exceptional circumstances. Oftel recognises that it is difficult to state in advance what will amount to an ‘exceptional circumstance’. However, it is necessary for Oftel to retain its discretion in this regard, but it will of course give detailed reasons for shortening any consultation period.

2.11 In addition, one operator commented that in certain circumstances a consultation period might need to be longer than three months. Oftel accepts that this is consistent with the Statement Oftel’s use of public consultation, of August 2001.

2.12 One operator suggested that there should be six months’ grace between plans to change the Conventions being announced and that change being enforceable against operators. This was on the basis that draft Convention 1.6 stated that "Licensed operators will not be required to comply with any such amendment or withdrawal, unless they have been given a reasonable period of notice, such notice not being less than three months". This suggestion cannot be accepted as the Conventions are, in this area, simply repeating the requirements set out in the Numbering Arrangements Condition of the Telecommunications Act Licence and, therefore, any discretion that the Director has under that Condition cannot be fettered.

2.13 A question was raised as to what the appeals mechanism for changes to the Conventions would be. In most instances, Oftel will use the procedures set out in the Telecommunications Act 1984 to enforce the Numbering Arrangements Condition so any appeals would be brought under Section 46B of the Telecommunications Act 1984.

Convention 2: applying for numbers

Criteria for the eligibility

2.14 Various operators queried the opening up of eligibility to those who operate systems under a class licence. This change is necessary to meet the objectivity requirements of the EU Licensing Directive. However, Oftel recognises that there may be some confusion as operators running non-public telecommunications systems under the Self-Provision Class Licence (SPL) may feel they are eligible to receive numbers or codes.

2.15 Accordingly, Oftel has amended Convention 2.1 to read:

2.16 Further, it was brought to Oftel’s attention that this could exclude relevant offshore administrations, such as the Isle of Man and the Channel Islands, which rely on the United Kingdom for their number allocations. Section 108 of the Telecommunications Act 1984 has not been extended to cover those administrations in this context. However, Oftel recognises that this raises issues that are not straightforward and will need to be considered further.

Information to be supplied

2.17 Many respondents were concerned that draft Convention 2.3 did not reflect the changes that had been proposed as amendments to Application Forms. Oftel accepts this and has now revised this Convention to accurately reflect the questions currently being asked. The draft text is being replaced by the following (with the amendments shown as marked-up deleting and/or additional wording):

a) "Name and contact details of the applicant.

b) Where a person submits an application form on behalf of the applicant, a signed and dated letter of authorisation shall accompany it from that applicant.

c) Details of the Telecommunications Act licence under which the applicant intends to operate the numbering capacity sought and of the system being operated.

d) The purpose for which the numbering allocation is required. Details of any existing ranges held that are relevant to that application.

e) A preferred numbering code and/or block and, where appropriate, second and third preferences should be indicated. Details of the operator’s interconnection and number portability arrangements.

f) Details of the geographic scope of the service. A preferred numbering code and/or block and, where appropriate, second and third preferences should be indicated.

g) Details of the proposed tariff rate of the service (where applicable). Where relevant, details of the type of telecommunications service intended on the range and the proposed tariff rate of the service.

h) The date by which the allocation is required.

i) The relationship with existing reservations or allocations

h) Details of the applicant’s utilisation of existing number allocations. For example:

• Percentage of numbers allocated to end users in service; Numbers in service allocated to end users;
• Reserved capacity against firm orders Capacity not in use but contracted for (geographic numbering only); and
• Numbers set aside for geographic growth or customer orders and Free capacity; and
• A forecast of expected utilisation over a specified period.

i) Any other information that the applicant considers necessary or appropriate to justify the application."

2.18 Oftel has decided that information pertaining to number portability is necessary for current administrative purposes and so has been retained, albeit in a modified format, in e) above. This helps Oftel’s Numbering Unit decide whether an applicant is eligible for an allocation (ie whether they are providing publicly available telecommunications services and running a telecommunications system).

2.19 Some operators expressed concern that the draft Convention 2.4 allowed Oftel an unnecessary degree of discretion. Oftel’s view is that, when taken in conjunction with the provision not to place an undue burden on applicants, this is justifiable. Oftel will also ensure that such information is sought as quickly as possible so as not to unduly delay the making of an allocation. Oftel does not intend thereby to make unnecessary difficulties. It is simply intended to ensure that Oftel has all relevant information before it when making allocations.

Timing of applications

2.20 Several operators expressed some concern at Oftel’s proposal in draft Convention 2.5 to reduce the maximum time, between an application being made and a range coming into service, from six months to three months for geographic areas. In response to that stated concern, Oftel’s view is that it must ensure that this timing requirement does not discriminate against services that may require a new range and/or some wider consultation before allocation. One operator suggested that this time period could be extended to nine months in non-geographic areas, but Oftel believes this would be disproportionate and could lead to the hoarding of numbers by operators.

2.21 Having considered all these arguments Oftel has decided to return to a six-month period for all ranges.

Convention 3: reserving numbers or codes

Reservations and limitations

2.22 Draft Convention 3.1(d) stated that reservations are appropriate where a route for migrating numbers from another block or code needs to be identified. One operator said that this is irrelevant. On review, Oftel has concluded that in this instance ‘Reservation’ is not the correct term. Such circumstances are best covered by the use of a ‘Protected’ marker (see Convention 8.5). Accordingly, this draft Convention has been withdrawn.

2.23 It was further proposed that draft Convention 3.3 be amended to explicitly state that reservations will be treated in confidence, unless the applicant requests otherwise. Oftel accepts this and has revised this Convention:

2.24 Various respondents were concerned by the suggestion that reservations might not normally become allocations that appeared to be implicit in the draft Convention 3.4. Oftel cannot go as far as to state that a reservation will result in an allocation as that would fetter the Director General’s discretion, but it has redrafted Convention 3.4 to give a greater level of assurance and clarity to this process:

Competing requests

2.25 There was some confusion among respondents about what Oftel is trying to achieve with draft Convention 3.6.

2.26 Oftel believes that in most circumstances the ‘first come first served’ rule will be sufficient – this is particularly true where applications are received via e-mails that have clear submission times on them.

2.27 However, circumstances will arise from time to time, where a significant customer order is key to the requirement for a block. In such circumstances, two or more operators may be in competition for that customer, and may have both reserved the range concerned, with allocation conditional on securing the customer. In such circumstances, Oftel will allocate to the operator who can provide Oftel with firm evidence of the customer order. Oftel hopes that this is now clear and has slightly amended the wording to clarify this intent:

Convention 4: considering applications

Number portability

2.28 Despite concerns expressed, Oftel has retained draft Convention 4.4 in a modified form. As stated above, in paragraph 2.18, Oftel believes that knowledge of an operator’s number portability helps Oftel to decide whether an applicant is eligible for an allocation (ie whether they are providing publicly available telecommunications services and running a telecommunications system). As stated in the February 2001 Consultation Document, it will be the Number Portability licence condition and the Functional Specification that set out the requirements for porting numbers, and not the Conventions.

Consultation on applications

2.29 In contrast, having considered the objections received, Oftel has decided to delete draft Conventions 4.5 to 4.8. These dealt with consultations on applications, but in great detail with circumstances that, bearing in mind commercial confidentiality or sensitivity, were very unlikely to transpire.

Timescale for handling applications

2.30 Various respondents commented that the time it takes between an application being submitted and the requisite numbers or codes being allocated could be significantly reduced. In the draft Convention 4.9, now Convention 4.5, Oftel has retained the standard period for allocations at 28 days. This is because, at present, Oftel is unable to shorten this timescale or offer a fast track for straightforward applications.

2.31 However, Oftel is committed both to reducing the time needed to process applications and to making the process more transparent. Oftel is pursuing this through a project to set up an online transaction process coupled with a degree of automation for allocations. Oftel hopes to be able to shorten the standard allocation time by introducing an online applications procedure that will include a fast-track procedure for standard repeat applications.

Draft Conventions 5 and 6

2.32 These draft Conventions collectively dealt with the following: general conditions, changes to allocations, the audit process, the annual numbering report, notifying others, code re-allocation and the withdrawal of numbering allocations.

2.33 Oftel has decided that it would make more sense to rearrange these to into three Conventions: The first dealing with conditions on allocation; the second with withdrawal and reallocation; and the third with requirements relating to notifying others.

Convention 5: conditions placed on allocations

Conditional allocations – codes

2.34 Draft Convention 5.10, dealing with the re-allocation of codes, caused some respondents to be confused. This would appear to be because of the use of the word "ported". Oftel has therefore changed this work to "transferred" and believes that Convention 5.2 is now clear as it provides that:

Audit

2.35 Oftel had intended the proposed changes set out in draft Convention 5.3 to be a liberalisation measure. However, many operators responded by saying that they did not like the uncertainty of what was proposed. In particular, it was noted that many operators wished to know what information would be required each year.

2.36 Oftel wishes to make it clear that it finds it undesirable to collect excessive amounts of unnecessary information. However, in order to give a higher degree of certainty to operators, Oftel has returned to the text used in the 1997 issue of the Conventions, so Convention 5.4 now reads:

2.37 Oftel has revised the wording of Conventions 5.5(b) to (d), inclusive, to bring them into line with questions on application forms (see Convention 2.3). The following revisions have therefore been made:

2. "(b) the percentage of numbers that have been in service allocated to end users;
3. details of numbers that are unavailable for further allocation and the reasons why they cannot be allocated set aside for planned growth, customer orders or other usage, with explanations;
4. the allocation of blocks of numbers allocated to any person for purposes other than end use…"

Convention 6: reallocating and withdrawing allocations

Reallocations

2.37 Oftel wishes to make it clear that it will reallocate number blocks or codes when it has received the written consent of both the existing allocatee and the intended allocatee. Oftel has therefore added a further sentence to draft Convention 6.4 (now Convention 6.1) to read:

Withdrawals

2.38 Some operators commented that there was a need to manage the impact of withdrawals, but almost invariably numbers or codes are withdrawn because they are not being used. In such instances, there will be no impact to manage. However, Oftel recognises that from time to time withdrawals will take place in circumstances where the numbers in question are in service. Naturally, such withdrawals will need to be managed and will be in accordance with a plan that would be agreed with the relevant parties at the time such changes were planned. Oftel believes that Convention 6.3, as drafted, covers such eventualities but Oftel wishes to make it clear that in circumstances where there are numbers in service on a range of numbers to be withdrawn, a longer period of notice or transition may be agreed upon.

Convention 7: requirement to notify others

2.39 The paragraphs referring to a requirement to notify others when number ranges are brought into service, including references to the list kept by Oftel of contacts (previously known as the ‘A6.2 List’), have been formed into a new Convention 7. In the future it may be convenient to refer to the list that Oftel will maintain as the ‘Convention 7 List’.

Convention 8: Specified Numbering Scheme records

Publication of changes

2.40 In the light of uncertainty over the precise nature of future technology and the requirements of operators, Oftel has decided to drop the use of ‘documents’ from draft Convention 7.5, and to simply state that it will publish confirmations and what these will include. It (now Convention 8.3) has therefore been amended to read:

Status indicators

2.41 Oftel has concluded that indications of designation within the Scheme do not need to be status indicators themselves. Draft Convention 7.3 (now Convention 8.4) and onward has therefore been redrafted:

2.42 Respondents to the consultation suggested two further status indicators. First, it was suggested that there be a new indicator to be called ‘Allocated for Temporary Use Only [with date]’. Secondly, it was suggested that the term ‘Free’ should be replaced with ‘Unallocated’.

2.43 Oftel has considered the first suggestion, but it can see little merit in advertising the fact that an allocation is for a temporary period only. Such information is already held on Oftel’s system and would be set out at the time of allocation to the operator concerned. More importantly, it is difficult to understand what use such information would be to competing operators and, indeed, it might prove to be commercially sensitive in certain circumstances. Taking all these factors into consideration Oftel believes that the cons outweigh the pros, so Oftel has decided not to adopt this suggestion.

2.44 Whilst Oftel can see some merit in using the term ‘Unallocated’ rather than ‘Free’, it is concerned that this change would require a considerable amount of reprogramming and database query alterations. The term ‘Free’ has been in use for many years and is widely understood. Whilst there was concern that those browsing the Scheme might be confused by this status, Oftel believes that simply defining the term in the new Conventions is sufficient to address that problem.

2.45 Finally, Oftel has decided to simplify the Conventions in relation to parts of the Scheme that are ‘Free’ but only for particular purposes, eg, ‘Free for National Dialling Only’ and ‘Free for New 100,000 Block Only’.

2.46 One respondent suggested that the words ‘to the local number’ be added to the definition of the ‘Free for National Dialling Only’. Oftel considered this and decided that whilst it would add precision, such a level of precision is unnecessary and would be burdensome to those entering data. Oftel then considered this issue further and concluded that it is perfectly clear to simply have ‘Free for X’ (where ‘X’ is a purpose that will, in all instances, be specified) in the Conventions. This would include the above options, but it has the extra benefit of allowing for other purposes, such as any future allocation of Access Codes for full national or international directory enquiry purposes, to be dealt with within the Scheme, without the necessity of making further changes to the Conventions.

Chapter 3

Comments on Conventions relating to the public switched network

Convention A1: structure of the scheme

Standard number of digits

3.1 Convention A1.1 has been extended to state, specifically, that whilst the NSN will usually be ten digits long, there are non-standard number range lengths:

3.2 It should also be noted that Oftel has decided to amend all references to annotation by alphabetical sequence from ‘SABCDEXXX’ to ‘SABCDEFGHI’. This helps make sense of common references to the ‘F-digit’ in relation to allocation at F-digit level, ie in blocks of 1,000 numbers.

3.3 Contrary to representations made, Oftel has retained references to 03 being for future geographic numbering and 05 being for Corporate Numbering. In addition, Oftel has removed draft Conventions relating to the undesignated 04 and 06 parts of the Scheme.

Convention A2: standards and standard presentation

3.4 The title of this Convention has been amended to reflect that it does not merely deal with presentational questions, but includes references to other regulatory factors.

Country code

3.5 Convention A2.3 has been amended to remove the phrase ‘for use on the PSTN’ from the section on the UK’s country code as this is unnecessary as this section deals only with the telephony network.

Consistency of format

3.6 Oftel has redrafted this section to emphasise that the question of format is one of encouraging use of best practice. Therefore, Convention A2.9 has been redrafted as follows:

Convention A3: geographic number ranges

3.7 At this time, Oftel has flagged the 03 range for future geographic use and it is therefore appropriate for this to be stated in the Conventions. However, any further detail will be subject to future consultation. Accordingly, in the face of certain objections, Oftel has decided to retain Convention A3.1.

3.8 There was an objection to the phrase "Oftel will endeavour…" in Convention A3.2 – one major operator requested that this be changed to "Oftel will…" but suggested it would normally be possible to make changes within two years (with less than a full year being necessary for, amongst other things, parallel running). Oftel has therefore decided to adopt the use of "will" but change the period to two years, ie Convention A3.2 reads:

"Oftel will give at least two years’ notice of any code change."

3.9 There was a misunderstanding over the meaning of draft Convention A3.3. This specifically refers to decisions on new codes and not just to migrating codes. One respondent suggested levels of details concerning timescales for parallel running and number announcements. However, Oftel has decided that such matters are best decided on a case-by-case basis, and they should not be fixed by the Conventions.

3.10 At the suggestion of one operator, the order of draft Conventions A3.6 and A3.7 has been reversed.

Conservation measures

3.11 There was considerable concern expressed about Oftel’s plan to allocate blocks of numbers in conservation areas in units of 1,000 numbers. Oftel has consequently reviewed its proposal and, in discussion with operators, has now decided to review its conservation policy.

3.12 Conservation measures will not only enable Oftel to delay implementing code changes, but may remove the need for some code changes altogether. However Oftel has been happy to work with operators to ensure that these measures only bite where absolutely necessary. This review has led to the discontinuation of Watch Area for the reason stated in paragraph 2.6 above, and a clarification of Conservation Area policy. Conservation Areas will now be split into two types: Type A Conservation Areas, where numbers will henceforth be allocated in units of 1,000; and Type B Conservation areas, where blocks will be allocated in units of 10,000, but on the understanding that numbers will be used only in units of 1,000 at a time. Should an area move from being a Type B to being a Type A Conservation Area, Oftel may withdraw 10,000 number blocks and reissue numbers in 1,000 number blocks. This is set out in Conventions A3.9 to A3.12:

a) Conservation Areas where numbers will be allocated in units of 1,000 (‘Type A Conservation areas’); and

b) Conservation Areas where numbers will be allocated in units of 10,000 (‘Type B Conservation Areas’).

3.13 At the time of publication, there are nine Type A Conservation Areas:

Aberdeen (01224)
Bournemouth (01202)
Bradford (01274)
Brighton (01273)
Guildford (01483)
Iver (01753)
Middlesborough (01642)
Stoke-on-Trent (01782)
Wolverhampton (01902)

3.14 From six months after the publication of the new Conventions, allocations in the above areas will be in blocks of 1,000 numbers and the other conservation measures, as set out above, will apply.

3.15 Additionally there at the time of publication there are 11 Type B Conservation Areas:

Ascot (01344)
Cambridge (01223)
Derby (01332)
Markyate (01582)
Northampton (01604)
Oxford (01865)
Preston (01772)
Swindon (01793)
Wakefield (01924)
Warrington (01925)
Wigan (01942)

3.16 Oftel will publish and keep updated the list of Conservation Areas, which will be available on the Oftel website.

3.17 There was concern among respondents to the February 2001 consultation document that Oftel had not considered the costs of moving allocations down to 1,000s (or to the ‘F’ digit, as this is termed). On the contrary, Oftel undertook a consultation on this issue in 1997 with the Numbering Advisory Group (NAG). Oftel wishes to make it clear that it will not trigger number changes where there is no demonstrable need.

3.18 As part of the 1997 consultation, the costs of changing numbers were established. To summarise, the case for deferring a further change is obvious. The cost to consumers of a premature (or unnecessary) code change greatly exceeds operators’ costs in introducing 1,000 block routing and analysis. In fact, it was estimated that the cost to consumers of a change is possibly a hundred times that of the cost to operators of delaying the change. Specifically, a broad-brush analysis in 1997 confirmed that the cost to individuals and companies of varying sizes in six UK cities (assuming a population of 1.5 million in each) would be in excess of £150 million. That is, the cost to consumers of advertising number/code changes is possibly a hundred times that of the cost incurred by operators each year that a change is delayed.

3.19 Oftel’s policy decision in 1998, which was presented to NAG at that time, also took account of the Trade and Industry Select Committee’s earlier insistence that Oftel take less account of operators’ technical inconvenience.

National dialling only

3.20 A new sub-heading has been created to emphasise this section. Draft Convention A3.11 has been amended to include reference to the new status indicator ‘Free for National Dialling Only’ (see paragraph 2.46 above) which covers numbers that cannot be used for locally diallable Subscriber Numbers, as they start with 0 or 1 and would therefore hence clash with the national prefix or access codes. A further sentence has been added to the end of Convention A3.16:

3.21 Also, the second part of draft Convention A3.11, now Convention A3.17, has been clarified by the insertion of the words "in circumstances":

A4: corporate numbering

3.22 There was widespread criticism of Oftel’s move to signal the use of the 05 range for corporate numbering. Whilst there will be a full consultation in the near future on the detail of corporate numbering, the decision that there is a demand has already been taken. Ranges within 05 have been designated for corporate numbering, and it is therefore appropriate to reflect that in the new issue of the Conventions.

3.23 Oftel believes that there is an important principle here. In the interests of commercial sensitivity Oftel must be able to begin using new parts of the spectrum for services that do not fit into the existing Scheme. It is simply not practical for Oftel to delay the introduction of new services simply because they do not fit into existing designated ranges. Whilst matters of detail or practice will be subject to consultation, some matters of principle that are closely tied to technological or commercial confidentiality cannot be subject to consultation.

3.24 One change to this draft Convention is the designation, ‘Freephone 0500 Migration’. Following previous statements that this is not, in fact, a migration issue, that reference has been dropped. The new Conventions state, simply, ‘Freephone 0500’.

Convention A5: ‘find-me-anywhere’ services

Personal Numbering

3.25 Comments relating to Personal Numbering are dealt with in detail in the Statement Restoring Trust in Personal Numbering, of October 2001. However, for information, the only substantive change to draft Convention A7 (now Convention A5) is the addition of a ban on end user revenue share set out in Convention 5.5:

3.26 In the interests of clarity Oftel has also decided to adopt the text in this Convention that ensures that the 070 range shall not be used for services that fall within the definition of Premium Rate Services (Convention A5.4). In addition, Oftel has made it clear in Convention A5.3 that the only services that will be allowed to use the 070 range shall be Personal Numbering Services, and has defined what shall constitute those services.

3.27 One further, minor change to this Convention, not covered by the October 2001 statement, is the removal of draft Convention A7.3 (the sentence "Find me anywhere numbers must be placed in the appropriate range"). That convention is unnecessary as it has already been stated, in other words, in the last line of Convention A5.1.

Paging and mobile services

3.28 Oftel has decided to add a short Convention A5.6 stating that it allocates numbers in the 076, 077, 078 and 079 ranges in blocks of 100,000.

Convention A6: special services

Allocation at 1k level

3.29 Following extensive further discussions with the industry, the proposal to move to allocation in the 084 and 087 ranges in blocks of 1,000 numbers has proved unnecessary. Instead, allocations will continue to be made in blocks of 10,000 numbers.

Misleading indicators

3.30 One respondent observed that the comment that 080 calls were free of charge, except on some mobile networks, where a notification was always given, was inaccurate. Oftel has investigated and it would appear that its assertion is accurate. Oftel would be happy to investigate specific allegations that this is not happening and work with mobile operators to rectify any lapses.

3.31 As a result of other observations, Oftel is clarifying the meaning of price points in the 08 range. In the new Conventions, it is clearly set out both what the price points are and which relate to terminating or originating operators. Convention A6.4 now states:

3.32 End users should refer to the information provided by their suppliers to determine the exact price they will be charged for a call. The terms, ‘Local Rate’ and ‘National Rate’ have been defined in the glossary of the Conventions as being an indication that the price for the call is equivalent to the rate for that type of geographic call as set by the relevant originating operator, where this exists.

Other issues

3.33 One operator said that, although it was not opposed to the 084/087 price caps in principle, these needed to be supportable within the new NTS scheme. This question will be addressed as part of the Oftel review of retail prices for NTS that is currently ongoing.

3.34 Finally, it was observed that there should be a specific reference to 0800 six-digit numbers. In fact, this is already the case in Convention A6.3:

3.35 When referring to 0800 nine-digit numbers, Oftel means six digits plus the (0)800 prefix.

Convention A7: Premium Rate Services

Premium Rate Services

3.36 Several issues arose here about lack of clarity about what constitutes a Premium Rate Service (PRS), what distinguishes it from a Special Service, and what the price points relate to.

3.37 Firstly, it is to be noted that with the exception of the 0907 (‘pay for product’) and the 0909 (sexual entertainment services) ranges, 09 numbers relate to definable price points. However, end users should refer to the information provided by their suppliers for the actual price charged for the call. Any failure to publish such information should be reported to Oftel.

3.38 Secondly, it has proved difficult to develop a definition for PRS. Oftel has studied the comments it received to this consultation and has looked carefully at the definitions of PRS that have appeared in previous publications and which ICSTIS has developed.

3.39 Oftel has considered moving to adopt substantively the ICSTIS definition of PRS, as it has with sexual entertainment services. However, the issues involved are not straightforward, and Oftel has concluded that further consideration in this area is warranted. In particular, the following market development factors require further discussion and understanding:

a) the distinction between content and non-content;

b) the (non-financial) distinctions between ‘Special Services’ and PRS; and

c) the degree to which consumers derive significant meaning from the current sub-structures.

3.40 Oftel has therefore decided that it is best to substantially adopt the text that was consulted on in February 2001, with some rewording, but intends to review further, with stakeholders, a wide range of issues concerning the regulation of PRS and Special Services in the near future. The effect of this is to produce the following Conventions setting out the characteristics of PRS:

3.41 In addition, draft Convention A9.4 has been removed because requiring all services caught by the new Controlled Premium Rate Services Licence Condition to be behind 090 was not Oftel’s intention, but would be the effect if this convention had been retained.

Sexual services

3.42 In draft Convention A9.5, Oftel stated that 0909 was to be used for ‘Services of a sexual nature’, which were defined as:

3.43 Respondents suggested that we follow the ICSTIS definition. ICSTIS has concurred with this view and Oftel has therefore replaced the above with the term ‘Sexual Entertainment Services’, as follows:

3.44 This definition is referred to in Convention A7.8. Oftel believes that this is a helpful alignment of definitions.

Allocation at 1k level

3.45 Following extensive further discussions with the industry, the proposal to move to allocation in the 090 range in blocks of 1,000 numbers has proved not to be necessary. Instead allocations will be made in blocks of 10,000 numbers with tariff distinctions at the 100,000 level. This leaves Oftel with a potential shortage of numbers at novel or popular price points and Oftel will discuss further with the industry how this can be addressed.

Convention A8: broadband services

3.46 This turned out to be rather a contentious point. One respondent suggested that ‘broadband’ is technology-specific, whereas ‘multimedia’ is technology neutral. Oftel disagrees. It believes that ‘broadband’ covers a specific type of services that could not use number ranges from elsewhere in the Scheme, whereas ‘Multimedia’ is so ambiguous a term as to be meaningless. This Convention therefore remains as drafted. However, Oftel notes that there has been little use made of this number range and, subject to utilisation in the future, may review this part of the scheme.

Convention A9: access codes and short codes

3.47 With two exceptions the text annexed to the Statement Access codes: options for the future, issued by Oftel in March 2001, which was itself subject to a period of consultation, has been incorporated into the new Conventions.

3.48 The first change is with regards to the ‘allocation’ of Type A access codes. Type A access codes are used to reach commonly used services, or, as this has been more recently redefined, are to be used for particular services where there is a social imperative, sometimes backed up by regulatory force. It is inaccurate to say that Oftel allocates these codes, in fact these codes are set aside, or designated, for a particular service, possibly with reference to a service provider or network provider. Accordingly, what is now Convention A9.3 has been revised as follows:

3.49 The second change has been made because there was some textual ambiguity as to the uses of Type B access codes. This was set out in Access Codes: options for the Future as draft Conventions A11.6 to A11.8. Oftel has decided that this could be phrased more succinctly, and has therefore done so, as follows:

"A9.9 The two types of Type B access code are:

a) Access codes used for the purpose of a direct call set-up, where the dialled digits of the access code and the following number are treated as a single unit, or ‘string’, by the telephone networks in setting up the call; and

b) Access codes used as a prefix, where the second stage relies on the conveyance of a Personal Identification Number (‘PIN’)."

Draft Convention A10: tariff significance

3.50 On consideration of various comments made, this Convention has been deleted. However, its essence, ie that wherever practical, the Scheme will be planned to provide the greatest possible tariff transparency, is now covered in Convention 1.1(c), one of Oftel’s ‘Guiding Principles’.

Chapter 4

Comments on Conventions relating to other codes and numbers, and on the glossary

Conventions for other codes and numbers

4.1 There were no comments of substance on what are now Conventions B1, B2 and B3. Oftel has made no changes, to these Conventions since the February 2001 consultation document. However, they have been renumbered as a result of restructuring.

4.2 The only comments received related to draft Conventions that are now in the Numbering Code and are covered in Chapter 5 of this Statement.

The glossary

Terms revised

4.3 The text in the definition of ‘Country Code’ has been extended, with the addition of a last line:

4.4 At the suggestion of an operator the word ‘public’ has been added to the first line of the definition for ‘Number Portability’:

4.5 The last sentence of the draft definition for the Numbering Arrangements Condition has been deleted on the grounds that detail of the enforcement mechanism is not relevant to the definition of that condition.

4.6 The first sentence of the definition for ‘prefix’ has been amended to clarify its meaning:

New terms

4.7 Finally, certain new definitions have been created at the direct suggestion of respondents, or as a result of changes made to the Conventions that have led to new definitions being necessary. The terms now being additionally defined are:

Access Codes
Calling line identification (CLI)
Company Group(s)
Conservation Area
Local Rate
Mobile Service
National Rate
Number Block
Number Range
Operator
Premium Rate Service (PRS)

Chapter 5

The Numbering Code

5.1 One respondent to the February 2001 consultation document objected to the inclusion of Conventions relating to other codes and numbers on the grounds that they do not form part of the Specified Numbering Scheme within the parameters of ITU-T recommendations.

5.2 Oftel has removed the appropriate previous draft Conventions, ie those relating to codes and numbers which are outside the scope of the Numbering Arrangements Condition, and which should therefore not be dealt with in the Conventions. The principles for allocation of such codes and numbers by Oftel are now contained in the Numbering Code, at Annex C to this Statement.

5.3 Oftel wishes to make clear that the Code is only intended to be a set of principles by which Oftel allocates the codes and numbers to which it applies. It does not and cannot place any obligations on allocatees to, eg, have a numbering plan which accords with the Code. To impose such obligations would require modifications to the licence. However, Oftel will keep the position under review and, if necessary, will consider proposing modifications to the licence to impose appropriate obligations on allocatees.

Future changes

5.4 As set out in the introduction to the Code, Oftel will consult on any necessary amendments to it at the same time that it consults on linked policy changes. As with the Conventions, such changes would probably be annexed to the relevant policy consultation document. Such consultations would follow standard procedures as published in the August 2001 statement, Oftel’s use of public consultation. Changes to the Code that have been thus publicised and consulted on will then periodically be incorporated into a new issue of the Code, without the need for a further consultation. Such changes would take effect from the point when that new issue is published. Any new issue of the Code will be published on the Oftel website and brought to the attention of all relevant parties in the usual way.

Content of the Code

5.5 The Code includes the following sections that previously appeared as conventions:

a) draft Convention C1, National and International Signalling Point Codes, now Code 1;

b) draft Convention C2, Number Portability Prefix Codes, now Code 2;

c) draft Convention C3, Targeted Transit Codes, now Code 3;

d) draft Convention C5, Mobile Network Codes, now Code 4;

e) draft Convention C6, Carrier Pre-Selection Codes, now Code 5;

f) draft Convention C7, Licensed Operator Identification Codes, now Code 6; and

g) draft Convention C8, Reseller Identification Codes, now Code 7.

5.6 Of those codes the following have been substantially amended and need to be highlighted:

Code 1: national and international Signalling Point Codes

5.7 Oftel has revised the description of the three ranges set out in Code 1.6 (draft Convention C1.7) to make them more straightforward and compatible with the three types of signalling point code set out in Code 1.1:

5.8 A misleading reference to the Scheme (contained in draft Convention C1.4) has been removed. In addition, Code 1.7, previously draft Convention C1.5, has been amended, to correct two inaccuracies, as follows:

Code 2: number portability prefix codes

5.9 Following the suggestion of various operators Code 2.2 has been clarified by the addition of an extra sentence:

"The recipient operator will assign the prefixes to the switch or smaller unit."

Code 4: mobile network codes

5.10 At the suggestion of various operators, the relevant international standards are now referred to in Code 4.1 as follows:

Code 7: reseller identification codes

5.11 In the light of forthcoming moves to revise the procedure, eg, possibly discontinuing use of customer reply slips, Oftel has removed the draft Convention C8.2. This reference to the procedure is covered by the phrase "administrative purposes" in Code 7.1.

Annex A

Non-confidential respondents to the February 2001 consultation document

British Telecommunications
Cable & Wireless
Centrica
Consumer Communications for England
Childline
Operators’ Group, on behalf of:

Atlantic Telecom	COLT
Cable & Wireless	Dolphin
Easynet	Energis
GTS	Global Crossing
Global One	Hutchinson 3G
Kingston Group	Level 3
Worldcom	Norweb Telecom
NTL	On Cue
One2One	Orange
Redstone	Thus
Telinco	Telstra
Viatel	Vodafone
World online

Flextel
ICSTIS
Intelligent Network Management Services
Isle of Man Communications Commission
National Consumer Council
NIACT
NTL
Redstone
SACOT
Telewest
Vodafone
World Online

Annex B

NUMBERING CONVENTIONS FOR THE UNITED KINGDOM

Issued by the Director General of Telecommunications

Issue 3, 30 November 2001

Contents

Introduction

General Conventions

1: Rights, responsibilities and the review procedure

2: Applying for numbers or codes

3: Reserving numbers or codes

4: Considering applications

5: Conditions placed on allocations

6: Re-allocating and withdrawing numbers or codes

7: Requirement to notify others

8: Specified Numbering Scheme records

Conventions for numbers and codes for the public switched telephony network

A1: Structure of the Scheme

A2: Standards and standard presentation

A3: Geographic numbering ranges (01,02 & 03)

A4: Corporate numbering (05)

A5: ‘Find-me-anywhere’ services (07)

A6: Special services (08)

A7: Premium Rate Services (090/ 091)

A8: Broadband services (092+)

A9: Access Codes and Short Codes

Conventions for other codes and numbers

B1: Inbound and Internal Routing Codes

B2: Data Network Numbers and Codes

B3: Telex numbering

Introduction

1 The Numbering Conventions for the United Kingdom (the ‘Conventions’) are a set of principles and rules relating to the use and management of numbers from the Specified Numbering Scheme (the ‘Scheme’). The Conventions are not intended to be used as a guide for consumers to any aspect of numbering policy or management.

2 The Conventions also govern the specification and application of the Scheme and licensees’ Numbering Plans. It is a breach of the Numbering Arrangements Condition, contained in a licence granted to an operator under Section 7 of the Telecommunications Act 1984, for an operator to not have a Numbering Plan, or to have a Numbering Plan that does not accord with these Conventions. Oftel uses the procedures set out in the Telecommunications Act 1984 to enforce any breach of a licence condition.

3 The Conventions are revised from time to time by the Director General of Telecommunications (the ‘Director’) after consultation with relevant licensees and interested parties. The first and second issues of the Conventions were published in June 1994 and April 1997, respectively. This third issue takes into account:

• The provisions of the Numbering Arrangements Condition.

• Representations received by the Office of Telecommunications (‘Oftel) on the draft revised Conventions published in the Oftel consultation documents ‘Revising the Numbering Conventions’, of February 2001, ‘Access Codes: options for the future’, of March 2001, and ‘Restoring Trust in Personal Numbering’, of May 2001.

• Oftel’s experience of managing the Scheme since 1994, including recent developments affecting numbering issues.

4 Comments or queries regarding the Conventions should be directed to:

The Numbering Unit
Oftel
50 Ludgate Hill
London
EC4M 7JJ

E-mail: numbers@oftel.gov.uk

5 Numbering information appears on Oftel’s website: www.oftel.gov.uk/ind_info/index.htm.

General Conventions

1: Rights, responsibilities and the review procedure

Oftel’s guiding principles

1.1 The Office of Telecommunications (Oftel) is responsible for managing the Scheme and issuing the Conventions. In addition, Oftel is responsible for developing numbering strategy in the national interest and developing the Scheme. Numbers and codes are a national resource and the following guiding principles will be taken into account by Oftel when allocating, reserving or managing numbers:

a) Oftel will manage the Scheme to ensure that there are sufficient numbers available to meet all reasonable demands that end users, operators and service providers might have.

b) The Scheme will, where applicable, be compatible with relevant European and international agreements, standards and recommendations.

c) The Scheme will, wherever possible, seek to ensure that numbers of different types give a broad indication of service and/or tariff.

d) Oftel will ensure that costs or inconvenience to consumers, operators and service providers are objectively justified, and kept to the minimum consistent with meeting demands for numbers and sound management of the Scheme.

e) Oftel will allocate or reserve numbers in a fair and equitable manner, normally to the first operator that requests the block or code (ie on a ‘first come first served’ basis). Oftel will only allocate or reserve numbering capacity to operators who meet the eligibility criteria set out in Convention 2.

f) Oftel will take into account the need to anticipate growth and innovative services in demand for telecommunications services and, when allocating numbers, the need to conserve numbering capacity in ranges identified as having a number shortage (eg, Conservation Areas, a list of which is placed on the Oftel website). In particular, the utilisation of previous numbering allocations, including any numbers made available for porting, will be taken into account when considering new requests for number allocations.

Operators’ responsibilities

1.2 Operators who have received allocations of numbers or codes shall act in accordance with the following principles:

a) Operators shall adopt a Numbering Plan, for such numbers or codes as are allocated to it, in accordance with the Conventions

b) Operators shall be efficient in their use of numbers

c) Operators shall not brand numbers, nor associate a number range with a given operator.

Reviews of the Conventions and the Scheme

1.3 Oftel may from time to time review the Conventions and/or the Scheme upon its own initiative, or upon a request in writing by any operator, service provider, user or other interested party.

1.4 The Director may from time to time amend or withdraw in full or in part the Scheme and/or a Convention already published, or publish additional Conventions. This would take place only after consulting with relevant licensees, interested parties who are members of the Telecommunications Numbering and Addressing Body (TNAB) and, if the Director considers it appropriate, end users.

1.5 The normal consultation period will be three months. However, in exceptional circumstances, a shorter consultation period of not less than 28 calendar days may be appropriate.

1.6 Licensed operators will not be required to comply with any such amendment or withdrawal, unless they have been given a reasonable period of notice, such notice not being less than three months.

Structure of the Conventions

1.7 These Conventions are structured in two parts. The first part (Conventions 1 to 8) sets out the general rules or principles concerning the procedures for applications, reservations, withdrawals and other operations of the Scheme from both Oftel and recipients’ points of view. The second part (Conventions A1 to A9 and Conventions B1 to B10) sets out specific rules relating to numbers or codes within the public switched network or other parts of the Scheme.

1.8 This structure is for presentational purposes only and shall not affect the status of any of the individual Conventions, whether they are placed in the first or second part of these Conventions.

2: Applying for numbers or codes

Criteria for the eligibility of applicants for number allocations and reservations

2.1 All operators providing publicly available telecommunications services and running a telecommunication system under a licence granted under Section 7 of the Telecommunications Act 1984, whether that is an individual or a class licence, containing Numbering Arrangements Condition, are eligible to apply for allocations and reservations of numbering capacity.

2.2 Other persons who may require an allocation of numbering capacity, but who are not eligible under Convention 2.1 above, should seek a sub-allocation from an eligible operator (as defined in Convention 2.1 above). Sub-allocations should be fairly and reasonably available from such operators. However, Oftel is prepared, at its discretion, to consider reserving or allocating numbers or codes to systemless service providers in demonstrably exceptional circumstances (eg, where a systemless service provider is in the process of setting up a system).

Information to be supplied by an applicant for a numbering allocation and/ or reservation

2.3 When applying for an allocation or reservation of numbering capacity, the applicant shall provide the following information to Oftel’s Numbering Unit on an appropriate application form (available from Oftel’s Numbering Unit):

a) Name and contact details of the applicant.

b) Where a person submits an application form on behalf of the applicant, a signed and dated letter of authorisation shall accompany it from that applicant.

c) Details of the Telecommunications Act licence under which the applicant intends to operate the numbering capacity sought and of the system being operated.

d) Details of any existing ranges held that are relevant to that application.

e) Details of the operator’s interconnection and number portability arrangements.

f) A preferred numbering code and/or block and, where appropriate, second and third preferences should be indicated.

g) Where relevant, details of the type of telecommunications service intended on the range and the proposed tariff rate of the service.

h) Details of the applicant’s utilisation of existing number allocations. For example:

• Numbers in service allocated to end users;
• Capacity not in use but contracted for (geographic numbering only);
• Numbers set aside for geographic growth or customer orders; and
• A forecast of expected utilisation over a specified period.

i) Any other information that the applicant considers necessary or appropriate to justify the application.

2.4 In addition, applicants shall provide to Oftel any other information, judged by Oftel to be relevant to the application, and the supply of which does not place an undue burden on the applicant. This may include a brief description of the applicant’s technical and operational system configuration.

Timing of applications

2.5 Applications for numbering allocations should not, in general, be made more than six months prior to the planned in-service date.

3: Reserving numbers or codes

Making reservations

3.1 In addition to allocating numbering capacity, Oftel may, at its discretion, agree to reserve it. Reservations are appropriate where:

a) an applicant does not want to be identified;

b) the reason for the application should not be divulged prior to an application for the allocation; or

c) a customer order has not been finalised.

3.2 A reservation may be made:

a) in anticipation of an application being made for numbering capacity in accordance with a three year rolling forecast provided by licensees entitled to apply for an allocation; or

b) against a specific request submitted by any person eligible to receive allocations (for example, for the expansion or growth of existing services or for the introduction of new services).

3.3 An application for a reservation shall be made to Oftel’s Numbering Unit in accordance with Convention 2. Applications for reservations will be treated in confidence, unless the applicant requests otherwise.

Limitations

3.4 Wherever possible, Oftel will endeavour to convert a reservation into an allocation upon request. However, it should be noted that a reservation does not automatically entitle an applicant to activate the capacity. Nor, where numbering capacity is reserved, is there any guarantee that a corresponding allocation will subsequently be made. Reservations will be time-limited and the limit for reservations will normally be three months. Reservations may be renewable on request to Oftel.

Cancellation

3.5 Once a reservation has been made, that numbering capacity will be unavailable for allocation, except for the purpose and to the organisation for which the reservation was made. However, a reservation will automatically be cancelled if:

a) the time limit has expired;

b) the applicant withdraws the reservation; or

c) Oftel and the applicant agree a substitute reservation or allocation.

Competing requests

3.6 Where available number ranges are limited, and several operators have requested the same number block, Oftel may reserve the block for more than one operator, but will allocate it to the first operator who provides Oftel with firm evidence of a customer order.

4: Considering applications

4.1 When making number allocations or reservations within the Scheme, Oftel will take into account:

a) the