VON Europe Comments on ACMA’s Numbering Discussion Paper

Comments on ACMA’s Discussion Paper

“Geographic Numbering amendments”
May 2010, VON Europe

The Voice on the Net Coalition Europe (“VON”) welcomes the opportunity to comment on ACMA’s
Discussion Paper on “Geographic numbering amendments”(hereafter “the Paper”).
VON would like to congratulate ACMA on the very transparent manner in which it has been conducting
its numbering discussion over the past years.
VON’s disappointment in the suggestions put forward in this Discussion Paper is probably therefore
especially deep, as it had put high expectations into the outcome of this ongoing dialogue with
stakeholders. For if VON agrees that waiting and enforcing are not realistic or innovation-friendly
options, it fails to see how the suggestions put forward by ACMA constitute any real evolution.

Outbound services

1/ Do you have any comment on the proposed amendment (as provided at Appendix 1) to allow the allocation,
issue, use of geographic and LICS numbers to outbound only services?
2/ Are any other refinements necessary to allow the use of numbers by outbound only services?

The Numbering Plan currently precludes the use of geographic numbers and LICS numbers with
outbound only services, including VoIP out services, because the service definition if the Numbering Plan
provides for the use of these numbers only by services that are able to receive calls. Outbound only
services cannot receive calls.

The amendments proposed by the ACMA are focused on regularising one existing widespread business
model/practice, namely "VoIP Out".

In the section which addresses the effect of the proposed measures (page 9 of the Paper), ACMA states
that ‘no implications are anticipated’.

VON can only agree as, in fact, these proposals merely confirm the status-quo.

Whilst this allows for current practice to be regularized, it fails to meet the promise of “evolution” as the
path ACMA states it has chosen to follow. It is quite difficult to see how these amendments will
contribute to:

 promoting innovation and competition (since "VoIP Out" already exists); and

 meeting the existing demand for self-provision as well as for innovative applications and
services requiring geographic numbers.

Page 1 of 4
 VON Europe Comments on ACMA’s Numbering Discussion Paper

Moreover, ACMA’s proposal leaves in place the link of the right to use geographic numbers with the
ability to provide reliable location information to the IPND. This approach has negative implications for
innovation, given that many innovative utilisations of geographic numbers either do not require reliable
location information (e.g. because it concerns a secondary utilisation, as the ACMA itself recognises in
its footnote 16, or because it has altogether different features and utilisation), or do not technically
enable reliable location information.

VON therefore considers that the “evolve” mantra announced by ACMA has not translated itself in its
proposed amendments. ACMA quotes our previous response to its December 2008 Consultation (page 5
of the Paper) in which we stated “Instead of tinkering with its existing Numbering Plan, ACMA should
step back and consider reviewing more fundamentally its entire approach to numbering…”: this
recommendation is still true after reading the current proposals. VON urges ACMA to take a positive and
forward-looking step into 21st century numbering, by recognizing the outdated nature of traditional
technical limitations and geographic boundaries in numbering, and proposing amendments that
recognize this obsolescence.

Geographic numbering

3/ Do you have any comment on the proposed amendment (as provided at

Appendix 1) that will require CSPs to either meet existing numbering rules (which generally require fixed-line
services to have a number that corresponds with the physical location of the service) or to provide customers
with certain information regarding the implications of having a number for a service that does not correspond
with the physical location of the service?
4/ Are any other refinements necessary to better achieve the effect of providing this additional flexibility to CSPs?
5/ Are there any other effects or implications about which customers should be informed?
6/ Would a broader construction (see discussion on page Error! Bookmark not defined.) of the amendment be
better?

In its draft amendment, ACMA prefers the “evolve option” by making small amendments to the
Numbering Plan so that it evolves “to support greater flexibility, ensure consumers are adequately
informed about the implications of their choices and provide certainty for the industry”. The proposed
amendment of the Numbering Plan creates additional complexity and uncertainty for industry
players, which implies an additional barrier for the emerging of new innovative services.

VON believes that the first part of the proposal of requiring “CSP to meet existing numbering rules
requiring the physical location of the number” is outdated and should not be embedded in a text of Law.
Location information of geographic numbers is a legacy from the Plain Old Telephony Services, where
habits were not what they are today. In recent years, people have become more flexible, ready to move
and travel at any time.

In this context there is a clear demand from the market to use regular (i.e. geographical) numbering
resources without restrictions. Technically it is today already possible in the IP world, and will become a

Page 2 of 4
 VON Europe Comments on ACMA’s Numbering Discussion Paper

generality with the roll out of NGN networks. Important change in the general way of life and the
evolution of technology, have an impact on the features customers are demanding. Therefore VON
supports the second part of the proposal only (i.e. to provide customers with certain information
regarding the implications of having a number for a service that does not correspond with the physical
location of the service).

This being said, VON believes that rather than imposing a general obligation of requiring all CSPs “to
provide customers with certain information regarding the implications of having a number for a service
that does not correspond with the physical location of the service”, a further step should be taken and
remove the link between location information and geographic numbers whilst at the same time
enhancing the rate transparency for the calling party.

Such removal would allow the obligation of untimed local call to remain unaffected and based
exclusively on the structure of the number. It would have the effect of giving certainty of the price to be
paid by the calling party and thus remove the necessity of informing the customer about possible
implications of having a number that does not correspond to a physical location. The calling party, when
dialling a number, does not automatically know whether or not the called party is located in the local
area of the called number and could lead to higher fees than expected by the consumer. We strongly
believe that the calling party should have certainty of the rates when calling a number. Therefore the
principle of untimed local call obligation should remain unaffected, but be linked with the simple
structure of the numbers without referring anymore with the location information.

Moreover, the proposed wording may not lead to more flexibility for CSPs, rather to the contrary.
According to the amendment, CSPs will be required to provide information to customers in case the
geographic number does not correspond to the geographic location of the consumer. This means in
practice that, for each allocation of a number by a consumer, a CSP will need to collect the exact
location of the consumer and map it with the location information of the number (i.e. query in a
database). If the locations match, no information needs to be provided. If there is no match, the
consumer needs to be informed about certain restrictions.

Regarding the possible limitation of porting a number outside of the local area of the number, VON
definitely supports that ACMA encourages every CSP to support port in of numbers independently of the
physical location of the end user. If the geographic numbers is not anymore linked with a physical
location, such information will be unnecessary.

Therefore, VON strongly encourages ACMA to focus its attention on ensuring the fullest possible retail
price transparency and to remove the link between location information and geographic numbers.

We thank you in advance for taking consideration of these views. Feel free to contact Caroline De Cock,
Executive Director VON Europe, by phone (+ 32 (0)474 840515) or email (cdc@voneurope.eu) should
you need further information.

Page 3 of 4
 VON Europe Comments on ACMA’s Numbering Discussion Paper

*
* *
ABOUT the VON Coalition Europe
The Voice on the Net (VON) Coalition Europe was launched in December 2007 by seven leading Internet
communications and technology companies, on the cutting edge – iBasis, Google, Microsoft, Skype and Voxbone –
to create an authoritative voice for the Internet-enabled communications industry.
The VON Coalition Europe notably focuses on educating and informing policymakers in the European Union in
order to promote responsible government policies that enable innovation and the many benefits that Internet
voice innovations can deliver.

Page 4 of 4