Opinion of the Economic and Social Committee on the 'Communication from the Commission regarding the consultation on the Green Paper on a Numbering Policy for Telecommunication Services in Europe` (98/C 19/08)

On 26 May 1997 the European Commission decided to consult the Economic and Social Committee, under Article 198 of the Treaty on the above-mentioned communication.

The Section for Transport and Communications, which was responsible for preparing the Committee's work on the subject, adopted its opinion on 15 October 1997. The rapporteur was Mr Mobbs.

At its 349th plenary session (meeting of 29 October 1997), the Economic and Social Committee adopted the following opinion by 108 votes for, one vote against and two abstentions.

1. Introduction

1.1. The Commission issued a Green Paper on a Numbering Policy for Telecommunication Services in Europe (COM(96) 590 final) on 20 November 1996. This resulted in a period of wide ranging consultation with all interested parties within the EU on a variety of options for a common approach towards certain numbering issues in order to reach the agreed goals of a competitive and liberalized telecommunications market.

1.2. In addition, the Commission organised a public hearing in February 1997, attended by over 100 participants. Over 80 written submissions were received by the closing date of 21 February 1997.

1.3. The Economic and Social Committee issued its opinion on 28 May 1997 ().

1.4. The Committee welcomed the Commission's initiative and recognized it as playing an important part of the process towards full liberalisation since the Green Paper on Telecommunications () was issued in 1987.

1.5. However the Committee had some reservations, in particular:

- There may be alternative solutions offering better 'value for money` (for both consumers and operators).

- The results of certain ongoing studies proposed by the Commission were not complete.

- More information was needed on many of the technical issues raised and these may well need additional studies.

- Some of the timetables proposed were unacceptable (from too early to too late).

- A number of the proposed actions would, perhaps, be best carried out by existing international organizations.

- Strategic matters, like a European Numbering plan, needed a lot more information as it was difficult to see obvious immediate benefits especially when these impact on the rest of the world.

1.6. It is interesting to note that the Committees' views (adopted after the Commission consultation period was closed) are not materially different from those received earlier by the Commission.

1.7. The Commission communication on the consultation is indicative of a thorough analysis of comments made by all interested parties and is a thorough appraisal of the Commissions original objectives and all views received.

2. The Commission communication

2.1. The Commission considers that there was wide support for many aspects of the green paper proposals.

2.2. There is a general view that for all numbering changes and number mechanisms, the needs of the user should be the main focus. Changes to numbering plans always impose a considerable burden on both businesses and residential users and should therefore only be envisaged when the benefits clearly outweigh the cost. Some consider that the green paper gave too optimistic a view of the benefits while underestimating the costs.

2.3. There is considerable divergence of views on how and when the key number mechanisms should be introduced. These vary from early harmonization and synchronization throughout the EU to avoid competitive distortions, through views that this would introduce undesirable delays in countries that were prepared to move faster, to introduction according to the development situation in individual Member State's own networks.

2.4. As a result of the consultation process, the Commission considers the following (main) objectives appropriate, expressed on a proposed target date basis.

2.4.1. 1 January 1998

Call-by-call carrier selection by all fixed local access providers with significant market power (not defined in the Commission communication) where full liberalization is required. Later introduction allowed for those Member States to whom derogations are granted.

2.4.2. 1 January 1999

Establishment of a European Telephone Numbering Space on the basis of country code '388`. The ITU is expected to authorize its use in the course of Summer 1997.

2.4.3. 1 January 2000

Carrier pre-selection for the user to be offered by all fixed local access providers with significant market power in all Member States.

Operator number portability to be offered by all fixed local access providers.

Number portability to be offered by all operators for non geographic special service numbers (freephone, shared costs, premium service rates).

2.5. Action plan

In order to reach the above target dates, the Commission proposes a timetable for action. This spells out in detail those who are involved and the actions which they have to take.

3. General comments

3.1. The Committee is pleased to have the opportunity to comment upon the Commission communication, especially since the subject raised by the Commission covers one of the last remaining major areas for action in the telecommunication liberalization process. It also covers matters which, whilst of particular interest to operators, service providers and manufacturers, concern more directly end users and consumers than do many of the Commission previous initiatives.

3.2. The Commission communication covers the views of those involved in the consultation process. As these views are well set out in its communication, the Committee opinion will concentrate mainly on specific actions relating to the Commissions' targets proposed in Chapter V entitled 'Priorities for action`.

3.3. The Committee welcomes the proposed priorities for action which are needed in order to foster the liberalization process. The objectives of the proposed actions are realistic and essential if there is to be genuine competition, innovation and customer choice for users, which best suits them in terms of quality, service and cost. The availability of adequate numbers and appropriate numbering mechanisms allocated and designed on a fair, transparent and non-discriminatory basis will contribute to the development of the single market in telecommunication services. Adequate numbering plans and procedures are required by the 'Full Competition Directive` () and the 'Interconnection Directive` ().

3.4. The responsibility for achievement of these objectives belongs to the National Regulatory Authorities (NRAs). The Committee points to the responsibility of the Member States to have the required independent NRAs in place and fully operational on time. Without the NRAs and common rules applicable in the EU, the prospects for the intended uniform numbering plan actions will be materially reduced.

4. Specific comments

4.1. Carrier Selection

4.1.1. The Commission proposes that this be the subject of a two-stage approach: call-by-call selection (easy access) by 1. 1. 1998 and carrier pre-selection (equal access) by 1. 1. 2000 for all fixed local access providers with significant market power (which is not defined in the Commission Communication). Some Member States already operate a system whereby user's choice is offered by the 'easy access` method. To date no Member State operates the 'equal access` method.

4.1.2. The Commission proposes (as it did in its Green Paper) that Member States should operate the 'equal access` form of carrier selection. Whilst the Committee generally was supportive of this approach in its previous Opinion () (point 4.1.1.4) it felt consideration of selection and pre-selection 'must include comprehensive cost-benefit analysis`. Since the Commission has proposed a two stage approach 'easy access` in 1998 and 'equal access` in 2000, there appears to be time for the Committee's suggestion to be considered.

4.1.3. Since there are so many differing views on the need for extension to local access providers and mobile operators, it makes sense for this to be re-evaluated/examined in 1998/1999 reviews.

4.2. Number portability

4.2.1. The inability for a user to keep his number when changing service provider is seen as an important deterrent (in its previous opinion, the Committee referred to polls indicating that some 80 to 90 percent of business customers would not consider changing if they could not retain their numbers). The need for all local fixed access providers and all operators who issue non-geographic special service numbers to be required to offer number portability does not seem to be disputed. However, divergent views exist regarding the coverage and the timing.

4.2.2. The best method for achieving this is considered by the Commission to be by amendment to the Interconnection Directive (). This is to be done by 1. 1. 2000. Before then, it will be necessary to develop guidelines on fair and pro-competitive arrangements for sharing costs between the operators involved.

4.2.3. Studies are being undertaken by ETSI () for completion by the end of 1998 on the desirability and possibility of requiring mobile operators to offer number portability. This is to be re-evaluated in the 1999 review. Specific attention should be paid in this context to the new industry agreements on the mobile UMTS network, development of which is of vital importance for the competitive position of the European Industry.

4.2.4. Attention will also have to be given to the development of a system whereby on-line per call tariff information can be advised when numbers are no longer a reliable indication of the cost of a call. This is a problem that has to be solved before full implementation of number portability.

4.3. European Telephone Numbering Space (ETNS)

4.3.1. The consultation produced the classic 'chicken and egg` situation. Since there is currently no ETNS using a suggested '388` number, it is not possible to tell if a demand exists. On the other hand, there seems sufficient support for supply to precede demand. The Committee agrees with the Commission that this latter route must be followed. This must be managed within the existing CEPT/ECTRA organizations.

4.4. National Numbering Plans

4.4.1. The Committee is pleased to see recognition of the fact that there is widespread concern at any further changes to national numbering plans in the short to medium term, especially where changes have recently been made. A period of stability is needed and nothing more should be proposed before early 2000.

4.4.2. Harmonization in itself is not seen as sufficient grounds for changing national numbering plans. However since in the long term there may be merit in a gradual natural convergence, the Commission believes that future changes in (national) numbering plans should be based on common guidelines. In particular, a number of Member States are allocating specific number groups to specific categories of user without any coordination (for example, 05 is available for private business networks in the United Kingdom).

4.5. Long-term European numbering plan

4.5.1. The consultation indicated considerable uncertainty about the costs and benefits of a unified European numbering environment and that further study is therefore required.

4.6. Alphanumeric dialling ()

4.6.1. The Committee notes the general interest in the adoption of a common standard for alphanumeric dialling.

4.7. Internet

4.7.1. The Committee agrees with the Commission that the situation should be kept under active review.

Brussels, 29 October 1997.

The President of the Economic and Social Committee

Tom JENKINS

() OJ C 287, 22. 9. 1997, p. 15.

() Towards a dynamic European Economy - Green Paper on the development of the common market for telecommunications services and equipment (COM(87) 290 final) - ESC Opinion: OJ C 356, 31. 12. 1987, p. 46.

() Commission Directive 96/19/EC of 13 March 1996 amending Directive 90/388/EEC with regard to the implementation of full competition in telecommunications markets (OJ L 74, 22. 3. 1996, p. 13), ESC Opinion: OJ C 39, 12. 2. 1996, p. 52.

() Directive 97/33/EC of the European Parliament and of the Council of 30 June 1997 on interconnection in Telecommunications with regard to ensuring universal service and interoperability through application of the principles of Open Network Provision (ONP) (OJ L 199, 26. 7. 1997, p. 32), ESC Opinion: OJ C 153, 28. 5. 1996, p. 21.

() European Telecommunications Standards Institute (ETSI).

() Dialling a telephone number by using the corresponding letters on the telephone's keypad that correspond to the name of the service or the called party e.g. '0-800-FLOWERS`.