Issued 15 November 2011
Ofcom’s September 2011 statement and further consultation about geographic numbers confirms that it will:-
Closing local dialling
Ofcom plans to establish an industry forum to oversee the implementation of the closure of local dialling in the relevant areas. If past experience is anything to go by, the funding of any industry-wide campaign is bound to be contentious. In order to promote constructive discussion, Ofcom should look again at the merits of a small percentage of the revenue raised through the number charging pilot, should it go ahead, being used to fund it.
100-number block allocations
For a modest cost, BT’s networks and platforms could handle up to 10,000 numbers in blocks of 100 in the eleven five digit code areas, if implemented in the manner proposed by Ofcom. As 100-number blocks cannot be supported economically on all of our switches, any extension would have to be considered individually and consulted upon. In addition, we ask Ofcom to consider whether area codes with extended linked numbering schemes (ELNS) (these are areas which share the same dialling code but are discrete charge group areas differentiated by the first digit of the local number) might be starting to experience number shortages, and, if so, whether 100-number block allocation might play a helpful role in conserving number blocks.
Number charging pilot
We are still not convinced that Ofcom’s number charging proposals would materially affect CPs’ behaviour for the reasons we set out in our previous response. It is still not too late for Ofcom to press the pause button. Nonetheless, we make constructive suggestions in answer to Ofcom’s questions which if adopted would make the framework as efficient and equitable as possible. If number charging is to go ahead, we agree that it should be in the form of a pilot with very clear success criteria. We think that these criteria need to be developed with industry as soon as possible and the conclusions should then be set out in Ofcom’s statement.
We believe that the areas that Ofcom proposes to include in the pilot stretch the definition of scarcity, the concept that underpins Ofcom’s rationale for charging. The predicted exhaustion dates are well over ten years away in many areas, and that is before Ofcom introduces administrative measures aimed at reducing pressure on number blocks. We suggest how to tighten the definition of scarcity (in answer to question 6). We also ask whether some of the areas where number blocks are more plentiful should be replaced in the pilot by ELNS areas in which number block supply appears to us to be more at risk.
Our answers to Ofcom’s questions also set out how we think the pilot could be introduced with least impact overall and in particular how costs of WLR and exported numbers could be most efficiently recovered. As such, we support the discussion of Ofcom’s new Option 5 which removes the need for CPs to bill each other for exported and WLR numbers, Ofcom instead applying a discount on the number charging invoice at source to account for the use by third parties of a CP’s allocation. However, this Option gives rise to a further problem, as those CPs gaining numbers in other CPs’ ranges would not pay for them. We offer up alternative ways in which this problem could be eliminated or reduced to make Option 5 more equitable.
If these measures are adopted, we believe it would reduce implementation costs to the lower end of the estimate we gave in the confidential version of our last response or below it.
We would welcome any comments on the contents of this document. Comments should be addressed to Howard Erdunast, BT Group Regulatory Affairs Department, pp C7J, BT Centre, 81 Newgate Street, London EC1A 7AJ, or by e-mail to email@example.com.