Proposals to change the framework for number portability

BT comments on Oftel's consultation on proposals to change the framework for number portability - July 2002

Download full response in PDF format.

Download Annex A response in PDF format.

Download Annex B response in PDF format.

Executive summary

1. BT understands the imperative to consider changes to number portability that could benefit consumers following the failure of telecommunications operators (e.g. Atlantic and previously Ionica).  In a broader context, BT has worked hard with other operators, regulators and customers to smooth the impacts of previous operator failures and to try to ensure that consumers continued to have ready access to telecommunications services.

2. While the importance of minimising disruption to customers of the failed operator is not in dispute, addressing this importance should not be at the expense of efficiency overall, or additional disruption, which could disadvantage the customers of other operators.

3. BT believes that the Consultation would have benefited from a Cost Benefit Analysis.  In the absence of such, BT believes that proper evaluation of the case is inhibited and the specific proposals for dramatic change have not been substantiated.

4. The short-term proposal put forward by Oftel does not appear to BT to be technically achievable, let alone commercially viable.  The long-term proposal appears to be a disproportionate response to addressing the problems created by an operator failing - the subject of this Consultation.  The case for a need for a central number portability database in the UK has not been made.

5. BT does not believe that a central database should currently be explored, as the costs of such a solution would be high, and the benefits limited and that therefore it would not be a proportionate approach to the specific issue in hand.  In addition, with IP solutions imminent, investment in the Oftel proposal would be stranded once the functionality can be achieved more efficiently with new technology.

6. In this response, BT proposes an alternative outline solution for improvements to the Numbering regime that would potentially deliver consumer benefits when companies with number allocations fail.  The development of this approach could lead to companies accepting number blocks in an equitable way from failing companies.  Customers with numbers on these blocks would then be able to opt for various services which would let them be reached, e.g. by being able to record a message, or by arranging for calls to be forwarded to a new number.  In BT's view, there is not a case for funding by industry and it may well be that some form of support from Government or some central agency is more suitable.

7. BT considers that this option should be fully costed, explored and, if feasible, tested out in a real situation before time and money is expended in considering and developing changes to the existing number portability framework which generally works efficiently and economically.  BT would welcome further discussion with industry and Oftel on how to move this issue forward given the key consumer concerns.

BT welcomes comments on this submission which should be addressed to:

Howard Erdunast
BT Wholesale Regulatory Affairs
4th floor Dowgate Hill House
Dowgate Hill
London
EC4R 2SU
Tel:  020 7728 4190
Fax: 028 9049 6096
Email: howard.erdunast@bt.com