Number portability

Review of General Condition 18 - Number Portability

Issue January 26, 2007

Executive summary

As industry and BT in particular start to roll out advanced next generation networks (NGNs), Ofcom is taking the opportunity to review whether the onward routing (OR) implementation of Number Portability (NP) should be replaced by a common database (CDB) solution, for mobile NP (MNP) by September 2009 and for fixed NP by December 2012.

BT agrees with Ofcom that a CDB solution would be technically superior to OR, and is desirable in principle but that it comes at a cost.  Separately, since the administration by the larger mobile network operators (MNOs) of the existing MNP solution is proving problematic, with new entrants effectively being blocked from using the system, Ofcom's consultation is extremely timely. 

In terms of the timescales of moving to a CDB solution, BT's initial view is that a September 2009 date for MNP is likely to be achievable and, given the cost benefit analysis (CBA) that has been carried out on behalf of Ofcom, justifiable.  However, if Ofcom mandates such a move, it is important that at the same time it ensures that this requirement and its implementation are not successfully used as an excuse by any industry players to continue to deny customers their rights to port their mobile numbers to and from new entrants under the current arrangements. 

Given the priority of addressing the problems with the existing MNP solution, and assuming a rapid move towards full implementation of a CDB solution by September 2009 (or as determined following this consultation), BT would question whether the introduction of an interim direct routing solution based on NICC Service Description 8 is realistic.  For example, the need for agreed standards by mid 2007 seems particularly optimistic.

The commercial case presented by the CBA for moving to a CDB solution for fixed NP is far less clear.  It is heavily dependent on certain key assumptions.  BT is not even certain that the CBA justifies a transition to a CDB solution at all, let alone by the prescribed date.  Whilst BT supports a CDB solution for fixed NP in principle, setting a date for full implementation six years out appears to be premature.  BT would prefer to see Ofcom agree with industry rather more realistic shorter term and intermediate commercial and technical milestones, linked to NGN roll out, standards development, agreement of CDB governance arrangements, etc rather than today setting December 2012 as the date for full implementation of a CDB solution for fixed NP (even if this ends up being “the right answer”).  BT would like to see Ofcom setting a date for a further review, following which it may be appropriate to amend the General Condition setting a date for full implementation.

Whilst BT believes that the case for a CDB solution for MNP is far clearer than for fixed NP, and that it is likely to be achievable sooner, it is important that a coherent approach be adopted for fixed and mobile NP, given the wide recognition of fixed/mobile convergence.  This principle is important, and can be applied sensibly without implementation dates being set simultaneously for fixed and mobile NP.

Regarding the proposed shortening of the MNP lead time, in BT's view, the MNP lead time could be fairly readily reduced to two working days but a further reduction may only be practicable once a CDB solution was in place.  Whilst BT believes intuitively that the shorter the lead time the better, so long as there are sufficient safeguards against slamming and other practices that run counter to customers' interests, the evidence presented by Ofcom does not show the five day lead time to be a significant disincentive to porting for customers and therefore seems to BT an issue of lesser significance.

BT agrees with Ofcom that possible changes to fixed NP processes and lead times are best dealt with in its forthcoming consultation on inter-working and transfers between all fixed, transferable products.

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BT would welcome any comments on the contents of this document. Comments should be addressed to Howard Erdunast by e-mail to howard.erdunast@bt.com.