Communication from the Commission to the European Parliament and the Council regarding the consultation on the Green Paper on a Numbering Policy for Telecommunications Services in Europe
Date: 1997-05-21
Institutions: European Commission
Subjects: communications policy, new technology, research and development, telecommunications, telephone

COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels,  21.05.1997 
COM(97) 203  final 

Communication from the Commission 
to the European Parliament and the Council 
regarding the consultation on the Green Paper on 
a Numbering Policy for Telecommunications Services in Europe 

r4SL 

it. 

Communication from the Commission 
to the European Parliament and the Council 
regarding the consultation on the Green Paper on 
a Numbering Policy for Telecommunications Services in Europe 

Table of contents 

Summary 

I 

II 

Introduction 

Consultation process 

III 

Comments received on  main points of the green paper 

1. 
2. 
3. 
4. 
5. 
6. 
7. 
8. 
9. 

General remarks 
Carrier selection / carrier pre-selection 
Number portability 
Restructuring of national numbering plans 
European Telephony Numbering Space 
Administration of European numbering space 
Long-term European numbering plan 
Alphanumeric dialling 
Naming and addressing in the Internet 

IV 

Evaluation 

1. 
2. 

Issues of general consensus or major support 
Issues for further  discussion or study 

V 

Priorities for action 

1. 
2. 

Numbering and ensuring effective  competition 
Numbering and the internal market 

VI 

Timetable 

VII 

Conclusions 

Glossary 
List of written contributions 

2 

5 

6 

7 
7 
11 
14 
15 
16 
16 
17 
17 

19 
20 

22 
25 

28 

30 

33 

M 

SUMMARY 

Introduction 

In  November  1996  the  Commission  published  its  Green  Paper  on  a  Numbering 
Policy for  Telecommunications  Services in Europe1, presenting various options for  a 
common  approach 
towards  certain  numbering  issues  in  order  to  reach  the  agreed 
goals  of a competitive  and  liberalised  single telecommunications  market.  A broad 
public  consultation  on  these  options  was  intended  to  provide  the  input  for  a  more 
concrete  plan  of action,  closely  following  the  needs  and  demands  of  residential  and 
business customers  and  new entrants  in the telecommunications  market  while  taking 
account of any constraints within existing telecommunications structures. 

More than  100 participants attended a public hearing and around 80 written comments 
were  received  from  residential  and  business  users  associations,  telecommunications 
network  and  service  providers,  equipment  and  software  manufacturers  and  national 
regulatory authorities and from their respective associations. 

The  Green  paper  has  also  been  put  on  the  agenda  of  the  European  Parliament's 
Committee on Economic and Monetary Affairs,  the Economic and  Social  Committee 
and the Committee  of the Regions. Initial exchanges of view took place in these  fora 
but formal opinions have not been adopted yet. 

The  Joint  Committee  on  Telecommunications,  consisting  of  management  and  trade 
unions  of  telecommunications  network  and  service  providers  within  the  Union, 
issued an opinion  on 28 February. 

The outcome of the consultation 

flie  consultation  has  demonstrated  wide  support  for  the  Green  Paper  proposals  to 
introduce  call-by-call  carrier  selection,  carrier  pre-selection  and  operator  number 
portability  in order to enable the customer to benefit  from  a new competitive  market. 
The comments also provided a useful  basis to determine the most appropriate  service 
and  service  provider  coverage  for  the  mandatory  requirement  of  these  numbering 
features, as well as clear indications concerning the timetable for their introduction. 

Moreover, the outcome of the consultation showed a strong emphasis on the need  for 
national  numbering  plans  to  allow  equal  quantitative  and  qualitative  access  to 
numbering  resources  for  all  market  players.  This  was  generally  felt  to  be  a  key 
requirement  for  non-discriminatory  access  to  the  liberalised  telecommunication 
markets. 

COM(96)590 final, 20.11.1996 

There  was  broad  agreement  on  the  establishment  of  a  European  Telephony 
Numbering  Space  on the basis of the '388' country code as soon as feasible  after  the 
formal  designation  of  this  code  for  pan-European  services  by  the  International 
Telecommunications  Union  (ITU).  There  should  be  a  broad  coverage  of  various 
service types under this code, while ensuring  transparency for the user as to the  tariffs 
of the various  services. Suggestions  for  the management  of the European  Telephony 
Numbering  Space  pointed  in the  direction  of  a structure  within  CEPT  (Conférence 
Européenne  des  Postes  et  Telecommunications)  /  ECTRA  (European  Committee  of 
Telecommunications Regulatory  Affairs). 

There was support  for  medium term convergence of national numbering plans to the 
extent  that  this  would  not  require  major  additional  changes  in  numbering  plans. A 
common approach to alphanumeric  dialling on the basis of  ITU -T Recommendation 
I:. 161 , Option  A, on this  issue, was widely  welcomed.  It was generally  felt  that  the 
idea  of a  long  term  numbering  plan  for a  unified  European  Numbering  environment 
would  require  further  study  , especially  regarding  cost /  benefit  analysis, and  should 
be seen in a  10 to 20 years perspective. 

The  analysis  of  issues  regarding  naming  and  addressing  within  the  Internet  was 
confirmed,  but  most  respondents  felt  that  any  problems  could  be  solved  through 
further  self regulation rather than by regulatory  intervention. Nevertheless, it was  felt 
that representation of European interests required improvement. 

Proposed targets 

On  the  basis  of  the  consultation  the  Commission  considers  as  appropriate  the 
following  targets  for  the  introduction  of  carrier  selection,  carrier  pre-selection  and 
number  portability  and  for  the establishment  of the  European  Telephony  Numbering 
Space : 

by  1  January  1998: 
•  call-by-call  carrier  selection  to be offered  by all fixed local  access providers  with 
significant  market power in all Member  States where full  liberalisation  is required 
by that date  and  in  Member  States where  additional  transition  periods  have been 
agreed, by the end of that period. 

by 1 January 1999 : 
•  establishment  of a European Telephony Numbering  Space on the basis of country 

code '388' 

by 1 January 2000: 
•  carrier  pre-selection  for  the user to  be  offered  by  all  fixed  local  access  providers 

with significant market po'wer in all Member States 

c 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 rate services) 

4 

Action plan 
As  a  follow-up  to  the  consultation  and  in  order  to  reach  the  above  targets, 
Commission proposes the following  timetable for action : 

the 

by mid  1997  Adoption  of  resolutions  by  Council  and  the  European  Parliament 
confirming  the  priorities  and  timetable  for  action  which  have 
emerged from the consultation 

Commission  review  of  national  numbering  plans  in  view  of 
requirements of the full competition Directive 

by end  1997 

Proposal  for  appropriate  legislative  measures 
availability  of  facilities  for 
portability throughout the internal market by 1  January 2000. 

carrier  pre-selection 

to  ensure  the 
and  number 

ETO report with detailed description of national numbering plans 

Adoption of ETSI standard concerning alphanumerical key pads 

Launch studies on  1 ) possible minimum criteria and  standardisation 
requirements in view of a long term number portability solution and 
2)  alternative,  on-screen/on-line  means  for  tariff 
information  for 
the user 

by end  1998 

Examine  possible 
portability requirements to mobile operators. 

extension  of  carrier  selection  and  number 

by early 1999  Appropriate  legislative  measures  to  be  adopted  to  ensure  the 
and  number 

availability  of  facilities  for 
portability throughout the internal market by  1  January 2000 

carrier  pre-selection 

Member  States  to  implement  '388'  for  the  European  Telephony 
Numbering Space 

Commission 
competitive arrangements for sharing costs of number portability 

issue  common  guidelines  on  fair  and  pro-

to 

Commission  recommendations  on  further  restructuring  of  national 
numbering  plans  in  view  of  competition  requirements  and  gradual 
convergence between national numbering schemes 

by end  1999 

Examine  desirability  of  extension  of  carrier  selection  requirements 
tofixed local access providers without significant  market power. 

early 2000 

Further  study,  in  the  light  of  experience  with  a  liberalised  single 
market  in telecommunications  and with the ETNS, of need  for  and 
costs / benefits of unified European numbering environment. 

I. 

INTRODUCTION 

With the emergence of a liberalised  telecommunications  market  within the  European 
Union, the availability  of adequate numbers and appropriate  numbering  mechanisms, 
transparent  and  non-discriminatory  basis,  is  an 
allocated  and  designed  on  a  fair, 
essential condition for effective  competition, innovation and consumer choice. 

Moreover, the outline of the European  numbering environment,  at present  composed 
of national  numbering plans  and  additional  global  numbering resources, is likely  to 
have a significant  impact on the  opportunities  for  the development  of  pan-European 
services within a single market. 

Numbering  policies  determining  or  affecting  the  European  numbering  environment 
are currently  developed  at the national, the Community, the wider  European  and  the 
global  levels  and  in  several  different  organisational  frameworks.  This  practice  is 
consistent  with the principle  of subsidiarity  which requires measures to be taken at 
the most appropriate level. 

At the level of the European  Union,  existing and future  numbering structures must be 
assessed  against  the  objectives  of  the  completion  of  a  liberalised  and  competitive 
market  in telecommunications  services throughout  the Union  and  the creation  of  an 
effective  single market. 

of  a  liberalised, 

Against this background  the Commission  published  its Green  Paper on a Numbering 
Policy  for Telecommunications Services  in  Europe  , presenting  various options  for a 
towards  certain  numbering  issues  in  order  to  reach  the  agreed 
common  approach 
goals 
single  telecommunications  market.  A  broad  public 
consultation  on these options  was intended  to provide the input  for  a more  concrete 
plan  of  action,  closely  following  the needs  and  demands  of residential  and  business 
users and new entrants in the telecommunications market while taking account of any 
constraints within existing telecommunications structures. 

COM(96)590 final, 20.11.1996 

II. 

CONSULTATION PROCESS 

The Green paper on numbering  invited comments and views of all  interested  parties 
regarding  the  outline  and  features  of a numbering  environment  which  can  facilitate 
real  competition  in  a  liberalised  telecommunications  market  and  contribute  to  the 
development of a single market to the benefit of the users. 

The  Green  paper  was published  in November  1996 and  a public  hearing,  with  more 
then one hundred participants,  took place on 5 February  1997. 

Around  80  written  comments  were 
associations,  telecommunications 
software manufacturers  and national regulatory authorities and their associations. 

received  from  residential  and  business  users 
service  and  network  providers,  equipment  and 

The  Green  paper  has  also  been  put  on  the  agenda  of  the  European  Parliament's 
Committee on Economic and Monetary Affairs,  the Economic and Social  Committee 
and the Committee  of the Regions. Initial exchanges of views took place in these  fora 
but formal opinions have not been adopted yet. 

The  Joint  Committee  on  Telecommunications,  consisting  of  management  and  trade 
unions  of  telecommunications  network  and  service  providers  within  the  Union, 
issued an opinion  on 28 February. 

A list of written comments received by the Commission is set out in the Annex. 

IN.  COMMENTS  RECEIVED ON MAIN POINTS OF THE GREEN 

PAPER 

111.1  General Remarks 

The  Green  Paper  on  numbering  was  broadly  welcomed  and  the  issues  it  addressed 
were  recognised  as  crucial  for  the  development  of  effective  competition  in  a  single 
European telecommunications  market.  The Green paper was applauded  for  its  effort 
to revitalise the discussion  on numbering at the European level and for  its attempt to 
sketch a coherent view on numbering issues accompanied by  concrete  proposals  for 
action. 

for  all  numbering  changes  and  number 
At  the  same  time  it  was  pointed  out  that 
mechanisms  the needs of  the  user should  be the main  focus.  Changes  to  numbering 
plans always impose a considerable burden on both business and residential  users  and 
should therefore only be envisaged if the benefits clearly outweigh the costs. 

A consumer  association  and  various  service providers  stressed  the  importance  of an 
objective  information  campaign  to  inform  the  users  in  due  time  of 
the  new 
possibilities  which  would  be  available  ,  in  particular  number  portability,  carrier 
selection and Europe wide service numbers. The user should obtain clear guidance on 
how to benefit  from any of these new options. 

Incumbent  operators  insisted  that  the  introduction  of  key  numbering  mechanisms 
should be  harmonised  and synchronised  throughout  the European Union  in order to 
avoid  competitive  distortions.  Other  operators  feared  that  such  an  approach  would 
lead  to  undesirable  delays  in  countries  that  were  prepared  to  move  faster.  National 
regulators  felt  that  there  should  be  different  implementation  dates  for  different 
Member States  in accordance  with  the development  of their  network  and  in  line with 
transition  periods  that  were  granted  for  the  liberalisation  of  telecommunications 
services. 

Numerous  commentators  raised  the  question  of  whether  the  green  paper  gave  a  too 
optimistic picture  of the benefits  of numbering  changes and new mechanisms  while 
underestimating the costs involved. 

III.2  Carrier selection / Carrier pre-selection 

- Green paper proposal  -

Introduction of carrier selection in two steps, namely call-by-call carrier selection 
to be introduced by 1.1.1998 and carrier pre-selection by 1.1.2000. 

Comments  -

Key issues 

Obligation to be imposed only on fixed or also on mobile access providers ? 
Obligation to be imposed  only on operators with significant  market power or also 
on  new entrants ? 
Easy access or equal access ? 

Other  issues 

Cost mechanism 
Billing arrangements 
Technical  feasibility 
Allocation of prefixes 
Method for assigning the default carrier 
Timing 

The  potential  effects  of  carrier  selection  to  increase  competition  were  widely 
recognised  , both  by  those  who  therefore  advocate  a rapid  and  general  introduction 
and  by  those  who  for  the  same  reasons  insist  that  a  more  cautious  and  limited 
approach should be chosen. Comments focused on types of services (fixed, mobile) to 
be covered, categories of operators ( operators with significant  market power only or 
all)  to  be  obliged  to  offer  carrier  selection  and  on  the  merits  of  different  carrier 
selection mechanisms. 

Mobile versus fixed 
Mobile operators typically argued that no form of carrier selection should be imposed 
to  the  mobile  sector  since  sufficient  competition  already  exists.  Some  also  invoked 
technical complications  for implementation of carrier selection  in mobile networks for 
which  standardised  solutions  need  to  be  developed  first.  Long  distance  service 
providers  on  the  contrary  insisted  that  all  local  loop  access  providers,  wired  and 
mobile,  should be obliged to offer  carrier selection. 

Incumbents versus new entrants 
Alternative fixed local loop access providers felt that the debate on carrier selection is 
based  on  the  (false)  presumption  that  the  local  loop  is  a  utility  rather  than  a 
to  be  a  useful  temporary 
competitive  product.  They  considered  carrier  selection 
instrument  to force  down  tariffs  for  international  and long distance calls as charged 
by operators with significant  market power. However, any across the board  obligation 
for  local  access  providers  to  offer  carrier  selection  would  act  as  a  disincentive  to 

invest  in local  infrastructure.  These arguments were countered  by others, in particular 
the  regulatory 
long  distance  and  international  service  providers,  who  believe  that 
framework  should  not  favour  one  particular  structural  outcome  of  the  competitive 
process (infrastructure  or service based competition). Moreover they added that carrier 
selection  will 
also  provide  an  incentive  to  invest  in  the  local  loop  given  the 
importance of  customer ownership. 

"Easy access"3 versus "equal access" 
As  to  the  mechanism  of  carrier  selection,  a  small  minority  held  the  view  that  easy 
access  is  a  sufficient  instrument  to  facilitate  competition  in  order  to  lower  long 
distance  and  international  tariffs.  Moreover,  they 
insisted  that  where  easy  access 
already exists, the costs of a mandatory migration to equal access  would not outweigh 
the benefits. 

Nevertheless, a majority  of the comments , not only those of new entrants in the long 
distance  and  international  services  market  and  of  business  and  residential  users 
associations, but also the majority  of incumbents and national  regulators supported  the 
eventual  need  for  full  equal  access. Various international  service providers  expressed 
strong  misgivings  concerning  the  risk  that  easy  access  is  wholly  inadequate  in 
bringing  about  effective  competition given its strong bias in favour  of the incumbent 
operator. They said that experience shows that customers find it difficult  to make the 
additional  dialling  effort  required  for  selecting  a  different  carrier  than  the  one 
determined by default by the local access provider. The latter will in most cases be the 
incumbent  even in a fully  liberalised market. 

In  the  same  context  incumbent  operators  stressed  the  need  for  harmonised  and 
synchronised  introduction  of pro-competitive  numbering  mechanisms  throughout  the 
EU in order to avoid competitive distortions (see below under 'timing'). 

Cost calculation 
Many  respondents  underlined  the  need  for  a  fair  and  transparent  calculation  of  the 
interconnection costs which the local access providers may charge the selected carrier, 
as  these  will  have  a  significant  impact  on  the  profit  margin  of  the  selected  carrier. 
Sufficient  unbundling  of  the  local  loop  is  a  crucial  requirement  to  ensure  that  the 
selected  carrier and  his customer  only pay  for  the part of the local access providers' 
network which is used for  setting up the call.  A significant  detail will be whether the 
local access provider will also charge for unsuccessful  calls (busy line, no reply). 

Billing arrangements 
Related to the calculation of costs is the issue of billing arrangements. No clear trend 
emerged  from  the  comments  apart  from  the  fact  that  billing  arrangements  are 
considered  to be important.  Various commentators  felt  that  being able to send  bills 
directly  to  customers  is  important  for  service  providers  in  view  of  branding  and 

3 Easy access , in relation to carrier selection, refers to the situation where the default  long distance 
carrier is determined by the local access operator with the possibility of override through dialling of a 
(short) code by the user on a call-by-call basis. 
4 In relation to carrier selection  , equal access refers to the situation where the long-distance carrier is 
pre-selected by the customer with the possibility of override through dialling on a call-by-call basis.. 

10 

building  a  customer  relation.  This  however  requires  that  the  local  access  network  is 
able to transfer  Calling  Line  Identification  to the  long distance carrier.  Others  said  that 
the  selected  carrier  should  have  a  choice  between  direct  billing  or  sub-contracting  , 
subject  to  commercial  negotiations  with  the  local  access  provider.  A  consumer 
association  pointed  out  that  it  would  be  in  the  interest  of  users  for  billing  to  be 
transferred  to  a  third  party  so  that  the  exercise  of  choice  through  frequent  switching 
between  carriers  would  not  lead  to 
just  as  many  bills  as  there  were  operators 
involved. 

Technical  feasibility 
The  technical  feasibility  of  introducing  carrier  selection  and  carrier  pre-selection 
within  the  proposed  time  frame  was  hardly  questioned,  except  for  subscriber  lines 
linked  to  analogue  exchanges.  Especially  the  absence  of  Calling  Line  Identification 
(CLI) capability  in such  lines  is  seen  as a problem  since  CLI  would  be necessary  for 
the  selected  carrier  to  identify  his  customer.  It  was  felt  that  it  would  not  be 
appropriate,  solely  for the  purpose  of ensuring  carrier  pre-selection,  to  insist  on  costly 
upgrades  of  such  analogue  exchanges  where  their  replacement  by  digital  exchanges 
was already  foreseen  in  investment  plans. 

Carrier  prefixes 
Concerning  the  carrier  prefixes,  most  respondents 
insisted  that  it  was  too  late  to 
harmonise  codes  at  a  European  level  since  various  Member  States  have  already 
dedicated  different  ranges  of  prefixes  for  carrier  selection.  Harmonisation  of  these 
ranges  only  just  after  they  have  been  introduced  would  be  costly,  disruptive  and 
confusing. 

Other  comments  on  prefixes  stressed  the  importance  of  dialling  parity  with  the 
incumbent  operator  and  the  need  to  have  short  prefixes 
,  which  can  be  easily 
memorised  and  which  do  not  deter  the  caller  from  using  them  because  of their  length 
in  cases  where  they  cannot  be  pre-programmed  in  terminal  equipment.  On  the  other 
hand,  one-digit  prefixes  were  considered  to  be  inappropriate  because  they  will  only 
offer  room  for  6 or  7 alternative  carriers. 

Various  regulators  pointed  out  that  the assignment  of a carrier  prefix  would  depend  on 
the  ability  of  a  certain  carrier  to  cover  (most  of)  the  national  territory.  Others 
remarked  that  by  foreseeing  carrier  prefixes  of varying  length  it would  be possible  to 
stimulate  investment  in  infrastructure  by  allocating  short  prefixes  to  infrastructure 
based  carriers  and  longer prefixes  to service based  carriers. 

Moving to equal  access 
Among  those who  were  in favour  of  carrier pre-selection,  there  was  wide  support  for 
leaving the initiative to change the default  long distance  carrier to the customer  and  to 
use  marketing  campaigns  as  an  instrument  to 
influence  the  customer's  choice.  The 
method  where  all  subscribers  are  requested  through  a  ballot,  organised  by  the 

5 a first  level of harmonisation would be to have one structure of prefixes throughout Europe (e.g. 
lOxy) but leaving the allocation of the xy part  at the national  level; a seond level would be to allocate 
the xy part at the European  level so that an operator could be selected  by the same code throughout 
Europe. 

11 

regulator, to indicate their preferred  long distance default  carrier, was widely  rejected 
by  the  market  players.  Nevertheless,  a  consumer  association  felt  that  the  regulator 
should  play  a strong role  in raising  the awareness  of the consumer  and  in  providing 
complete and unbiased information  about the various options. 

Timing 
Strong  views  were  expressed  by  national  regulators  and  incumbent  operators  about 
the need to harmonise and synchronise the introduction of, inter alia, carrier selection 
and pre-selection throughout the EU. Given the important competitive implications of 
especially  carrier selection  and pre-selection,  it was felt  by a majority  that a situation 
were different  mechanisms  were used in different  Member States  at  different  times 
would  lead  to  unacceptable  competitive  distortions.  A  small  minority  held  the 
opposite  view,  arguing  that  the  selection  mechanism  should  depend  on  the  state  of 
competition  in  a  given  national  market  and  on  the  technical  development  of  the 
network. 

to  be  general  acceptance  for  carrier  selection  and  pre 
Nevertheless,  there  seems 
selection  to be  synchronised  with  the  liberalisation  of voice  telephony  which  means 
that for  Member  States  with agreed additional transition periods, the introduction  of 
carrier selection and pre-selection should take effect  at these later dates as well.  Some 
operators pointed out that in these cases the intermediate step of easy access should be 
skipped  in order to have equal  access established  throughout the European  Union  at 
the same time. 

Several  alternative  service  providers  consider  a  two-step  approach  unnecessary  and 
undesirable.  They  argue  that  there  are  no  valid  reasons 
to  postpone  carrier  pre 
selection except the wish to protect existing market shares.  A majority  however  is in 
agreement  with  the  mandatory  introduction  of  some  form  of  carrier  selection  by 
I.1.199X  followed  by carrier  pre-selection  by  1.1.2000. liven  for those operators and 
user  associations  who  consider  that  the  time  frame  could  be  more  ambitious  ,  this 
appears to be an acceptable proposition. 

IH.3  Number portability 

- Green paper proposal-

Implementation of number portability for  the  (fixed) local loop as from  1.1.1998 

and by 1.1.2000 at the latest in all major centres of population and from  1.1.2000 

for  mobile networks and for  special services. 

- Comments 

Key issues 

•  coverage  (types of services) 

12 

• 

cost sharing mechanism 
technical solutions 
timing 

The  importance  of  number  portability  as  one  of  the  elements  to  achieve  real 
competition between  local access providers  is generally  accepted. The main point of 
debate  are the technical  feasibility,  the costs of implementation  and the  mechanism 
for sharing these costs between the operators involved. 

Coverage 
As for carrier selection, there is opposition  from  mobile operators who say that given 
the  level  of  competition  in  mobile  markets  number  portability  is  not  needed  and  its 
implementation  costs would outweigh the benefits. 

As to the wishes of consumers in this  matter, various mobile operators claim that  for 
mobile  users  changing  number  is not  a  significant  deterrent.  However,  one  mobile 
operator  , arguing  in  favour  of  mobile  number  portability,  quotes  a market  research 
result  which  suggests  that  40%  of  mobile  users  ,  especially  users  in  the  business 
segment,  see  changing  numbers  as  a  significant  barrier  for  changing  to  another 
network  provider.  A  major  consumer  association  also  pleads  in  favour  of  having 
number portability in the mobile sector as well. 

There  is  general  agreement  about the need to have  reciprocity  in number  portability 
meaning that both incumbents and new entrants  should offer  it to their customers. 

In contrast  to the Green  Paper suggestion  (and the provisions of the  Interconnection 
Directive)  many  respondents  advocate  general  territorial  coverage  ,  rather  than  a 
phased-in  approach  requiring  at  an  initial  stage  only  coverage  of  major  centres  of 
population, since the latter option could be a disincentive to invest in infrastructure  in 
less populated areas. 

Various  international  operators and some regulators stress that portability of numbers 
for  special  services  (freephone,  premium  rate  and  shared  costs)  is  an  urgent 
requirement 
to  change 
since  holders  of  such  numbers  are  even  more  reluctant 
operator if this implies changing their number too. 

Geographic portability (keeping the number while changing location) is not seen as an 
important  option  for  the  general  public but  it was recognised  as most desirable  for 
corporate and other business users. Their needs  could however be accommodated by 
non-geographic numbers . 

Consumer  associations  and  operators  stressed  that  the  present  numbers  contain  an 
important  element  of  tariff  information  which  should  be  preserved  (i.e.  identifying 

6 Non-geographic numbers are (national) number ranges that are not identified  with one specific 
geographic region, city area or local community. They are used for  instance for freephone,  shared cost 
and premium  rate services. 

13 

whether a call  is a long distance or premium rate call) . Number portability  should not 
lead to less transparency  in the expected price of a call. 

Technical solutions 
There  is consensus that any switch based  implementation of number portability, such 
as remote call forwarding  or drop-back,  is unsatisfactory  in the long run because it is 
inefficient  and  may  impair  the  quality  of  the  network  services.  Moreover, 
the 
operator  who receives the number will  remain dependent  on the operator who  looses 
the  number  for  termination  of calls,  and  the conveyance  costs  for  rerouting  of  calls 
will be high, with no particular incentive to bring them down. 

There is consensus that the technically and economically  superior solution for number 
portability  is that  of  a parallel  data  base  with  equal  access  for  all  operators  and  no 
interdependence. However, various respondents maintain that the costs of a data base 
solution  are  underestimated.  An  international  operator  on  the  contrary,  felt  that  the 
implementation  of an intelligent network solution should be a formal  requirement  for 
which a time frame should be imposed. 

Another  respondent  suggested  that  ,  following  the  example  of  the  FCC,  minimum 
criteria  should  be determined  for  a  long  term  portability  solution,  taking  account  of 
characteristics and dissimilarities  of existing national  numbering plans so that  switch 
manufacturers  could work towards a single standard. 

Some regulators insisted  that methods  of implementing number portability  should be 
left  to them and similarly  incumbent operators maintained  that the technical  solutions 
should be their domain,  provided that interoperability  would be assured on the basis 
of ETSI standards. 

Costs and cost sharing 
Little  evidence  of  projected  costs  was  provided.  The  total  costs  of  the  various 
solutions  and  the  way  in  which  they  should  be  shared  by  the  operators  concerned 
were the subject  of  many  comments and  divergent  opinions, though  not  necessarily 
very  developed.  All  agreed  however,  on the  great  importance  of  a  fair  cost  sharing 
mechanism for a successful  implementation of number portability. 

On  the  basis  of  specific  experience  regarding  this  issue, one  regulator  suggested  a 
cost allocation scheme in which the administrative and per-line set-up costs should be 
borne  by the  'recipient'  operator,  each  operator  should  bear  his own  system  set-up 
costs  and  any  additional  conveyance  costs  should,  in  principle,  be  borne  by  the 
'donor'  operator  to  be  recovered  through  general  network  charges.  This  would 
encourage  most  efficient  routing  methods.  There  should  then,  however,  be  a 

7 Number portability solution where recognition of a ported number can only be achieved at the 
original terminating local exchange. 

14 

possibility  to have some temporary additional conveyance charges  for the  'recipient' 
to allow the implementation of efficient  routing. 

In the case of an  intelligent  network  solution, an international  operator  proposed  that 
a charge be imposed  on all  service providers based  on their service revenues to cover 
the common costs of the creation and management of the  necessary data base. 

It was also suggested  that the Commission  should provide detailed  guidance  on cost 
issues. 

Timing 
Several  of  the  incumbent  operators 
stressed  the  importance  of  a  synchronised 
introduction  of  number  portability  whereas  others  felt  that  a  gradual  introduction 
would be more appropriate in order to allow operators to integrate the introduction of 
number portability capacity in their regular network update programme. 

As to the date for  implementation,  number portability  has already  been  introduced  in 
several Member States  and  will be introduced in other Member States  by next year. 
These  Member  States  and the operators  based there felt  that the proposed  timetable 
was not ambitious enough. Users' associations,  manufacturers  and alternative  access 
providers also proposed earlier dates 
However, a minority of regulators and incumbent operators insisted that  the proposed 
date of  1.1.2000 was too early and that the existing deadline of 2003 foreseen  by the 
Interconnection Directive should be maintained . 

f 11.4  Restructuring of national numbering plans 

- Green paper proposal -

Review  of  national  numbering schemes  towards further  integration of  national 
numbering plans,  adaptation  of  national  numbering schemes  according  to  the 
agreed  common guidelines,  to  be  completed by  the year  2000. No  allocation of 
numbers beyond the length of 13 digits (not including carrier selection prefixes or 
international prefixes). 

- Comments -

There was widespread concern over the cost and impact for users of further changes of 
national  numbering  plans  in the  short  to medium  term.  Major  overhauls  of  various 
national numbering plans had recently been completed and a period of stability would 
be welcomed by all. 

15 

At the same time, there  was support for gradual convergence in the  long term on the 
basis of common guidelines but the time  frame  should  stretch well beyond the 2000 
date proposed in the Green Paper. 

Moreover,  most  respondents  stressed  the  significance  of  open,  non-discriminatory 
and transparent national numbering plans  managed by independent authorities  for the 
success  of  a  competitive  market.  One  regulator  suggested  that  national  numbering 
plans  should  be  examined  systematically,  with 
technical  assistance  of 
CEPT/ECTRA,  to  verify  whether  the  competitive  requirements  were  met.  I'or  any 
necessary  further changes reasonable implementation  periods should be allowed. 

the 

II 1.5  European Telephony  Numbering Space 

- Green Paper Proposal -

Implementation of European Telephony Numbering Space by I  January  1998 at 

-1 "omments -

Pan-European  carriers  and  other  operators  with  a  pan-European  strategic  vision, 
expressed strong support  for  the development  of an  European  Telephony  Numbering 
Space and  felt  that it would create opportunities for the development of pan-European 
services. Many  others , although not against the idea, questioned  the current demand 
for Europe wide numbers for special services.  It was however admitted by some that 
supply might have to precede demand in this case. 

There was broad support for  implementation  of  an European Telephony Numbering 
Space on the basis of the  '388' country code. However, given the fact  that  clearance 
for the use of this code by the International Telecommunications Union is expected in 
May  1997, the proposed  implementation date of 1.1.1998 was seen as unrealistic, and 
should be replaced by a target of late 1998/ early 1999. 

Many  comments  insisted  that  any  development  of  Europe  wide  services  should  not 
interfere  with  the  development  of  global  services  and  that  duplication  should  be 
avoided.  Some  felt  that  for  this  reason  '388'  should  in  any  case  not  be  used  for 
freephone  services  since  these  could  already  be  accommodated  by  the  Universal 
International  Freephone  Service  number  '800'.  They  argued  that  use  of  global 
numbers could  be confined  to  European countries  if the service  provider  wished  to 
do this. 

In contrast, others urged to maintain a wide spectrum of special European services to 
be covered by the European Telephony Numbering Space. Several commentators  saw 
an  interest  in  accommodating  the  numbering  needs  of  multinational  corporate  users 
within the European Telephony Numbering Space. 

16 

Consumer  associations  underlined  that  there  should  be  a  clear  distinction  between 
numbers  for  freephone  and  premium  rate  services  in  order  not  to  confuse  the  users 
about  (he  costs  of  their  calls.  Moreover,  it  would  be  necessary  to  introduce 
possibilities  for selective call barring , simultaneously  with the introduction of Europe 
wide premium rate numbers. 

Various  comments  suggested  that  '388'  would  prove  a  useful  testing  ground  for 
demand of pan-European services and for the value-added of numbering management 
at a European  level. Further development could be decided depending on the success 
of this initial code. 

1II.6  Administration of European numbering space 

~~~] 

- ( ireen paper proposal -

EU, in conjunction  with ECTRA ,  to propose  a  new structure for  regulation and 
administration of numbers in Europe by 1 January 1998 at the latest. 

- Comments -

Most comments on this topic were received from  regulators and incumbent operators. 
There  were  few  remarks  from  other network  and  service  providers.  It was  generally 
accepted  that  the  creation  of  an  European  Telephony  Numbering  Space  , even  on  a 
limited  scale,  would  require  the  administration  at  a  European  level  of  number 
allocation.  However,  in line with the modest ambitions which were expressed  for the 
the  management  tasks 
European  Telephony  Numbering  Space  in  an  initial  phase, 
would,  in  the  view  of  most  respondents,  not  require  a  new  structure  at  this  stage. 
Various  respondents  suggested  that  ETC) should  administer  the  European  Telephony 
Numbering Space. 

A consumer  association  pointed  out  that  any  newly  created  administrative  structure 
should also incorporate consumer interests. 

III.7  Long-term European numbering plan 

- Green paper proposal -

Development of a long-term strategic plan for  numbering in  Europe by 1.1.1998. 
This should include the creation of a European country code  (3xy) with transfer of 

17 

responsibility of administration  and management of the last two  digits to Europe 
and a unified numbering environment by the year 2000. 

- C 'ommenls -

A  majority  of  commentators  felt  that  the  advantages  of  and  demand  for  a  unified 
European  numbering  environment  were  insufficiently  demonstrated.  It  was  widely 
believed  that the costs would outweigh  the benefits  and that  in any case the proposed 
time scale of  1.1.2000 was not realistic.  There was general consensus that  the costs 
and benefits  as well as  the technicalities of any such evolution  should be examined 
thoroughly before any decision could be taken. The experience of the development of 
the  '388'  code  and  of the  European  Telephony  Numbering  Space  would  play  a key 
role.  If  the  outcome  of  further  studies  would  be  positive  ,  harmonised  European 
numbering should in any case be projected over a 10-20 years period. 

III.8  Alpha-numeric dialling 

I 

- ( ircen paper proposal  -

Adoption of a common standard for  keypads supporting alpha-numeric dialling. 

- Comments -

There was strong  support  for  a common approach  to alpha-numeric  dialling  on the 
basis of  International Telecommunications Union  recommendation E.161, Option A 
providing  a  format  for  the  association  of  alphabetic  characters  to  numbers.  A 
consumer association pointed out that it would be very useful  for users  if the '*'  and 
'# '  function  codes would be standardised as well. 

One respondent  warned  that  it  was  important  not  to create  the  impression  that  users 
could  actually  own  certain  numbers.  Even  if numbers  were  to be widely  associated 
with  letters  this  should  not  lead  to  trade  mark  claims  by  business  users  on  certain 
numbers. 

III.9  Naming and addressing in the Internet 

- Green paper proposal 

18 

Fair and  non-discriminatory allocation of internet names and addresses should be 
safeguarded. Situation in the Member States to be reviewed in order to assess the 
need for  concrete measures. 

- Comments -

Internet naming and addressing issues attracted  less attention  than other issues raised 
in  the  Green  Paper.  Nevertheless,  there  was  agreement  on  the  analysis  regarding 
naming  and  addressing  and  it  was  felt  that  the  problems  identified  should  be 
addressed. 

Some felt that global harmonisation  and restructuring of use and allocation of internet 
names and  addresses  was needed. Another  comment  insisted  that  the  use of  national 
top level domain names should be encouraged to ensure that  allocation practices were 
in  line  with  national  trade  mark  law.  With  global  top  level  domain  names  the 
protection of trade marks was much more  difficult. 

In general the comments said that  the best way to solve  any problems  was through 
continued  self-regulation  and  not  by  regulatory  intervention.  However,  there  were 
various  calls  for  European  non-regulatory  initiatives  in  order  to  improve  the 
representation of European interests in the global discussions. 

19 

IV  EVALUATION 

I V.l 

Issues of consensus or major support 

On the basis of the comments received at the hearing and in writing,  the Commission 
concludes that  the consultation has demonstrated that : 

• 

• 

the  crucial  role  of  numbering  in  ensuring  effective  competition  is  generally 
acknowledged ; 

the  introduction  of  carrier  selection  within  fixed  networks  for  operators  with 
significant  market  power,  at  the  same  time  as  markets  are  opened  to  full 
competition, is widely supported ; 

•  only  carrier  pre-selection  will  give  users the  full  benefits  of  competition  in  long 
distance and international  calls , and it can and should be introduced  by  1.1.2000 
at the latest for fixed local access providers with significant  market power; 

the  introduction  of  operator  number  portability  on  a  reciprocal  basis  (both  for 
incumbents  and  new  entrants)  in  the  fixed  networks  is  considered  to  be  an 
important requirement ; 

territorial  phasing-in  of  number  portability,  starting  in  the  major  centres  of 
is  not  considered  to  be  necessary  or  desirable  ;  general  territorial 
population, 
coverage  was favoured  instead; 

the portability  of non-geographic numbers (freephone,  premium rate, shared  costs) 
is generally regarded as a feature to be introduced  urgently ; 

the  implementation  of  a European  Telephony  Numbering  Space  initially  on  the 
basis  of  the  '388'  country  code  , to  be  used  as  a  testing  ground  for  any  further 
development,  is widely seen as the best approach ; 

a common approach  to alphanumeric  numbering based on European Union  wide 
International  Telecommunications  Union  recommendation 
implementation  of 
E.164  would be welcomed; 

continuation  of  self-regulation  was  regarded  as  the  best  approach  to  tackle  any 
problems  occurring  with  naming  and  addressing  issues  concerning  the  Internet: 
however,  issues  need  to  be  examined  further  in  view  of  European  initiatives  to 
improve representation of European interests at the global level. 

Regarding the question of call-by-call carrier selection with the default  determined by 
the  local  access  provider  ("easy  access")  and  carrier  pre-selection  by  the  customer 

20 

("equal  access"),  the  consultation  brought  out  in great  detail  the arguments  used  by 
those who object  to equal  access and others, the vast majority  , who recommend  and 
support  it.  Without  addressing  any  of  the  other  arguments  of  this  debate  here,  it  is 
useful  to clarify  one of the main aspects of the discussion, namely the effect  of "equal 
access" on local infrastructure  competition and the views of the Commission on this. 

It is argued by a minority, based on a regulatory choice made in the past, that carrier 
pre-selection  arrangements  reduce  the  profit  margins  for  local  access  providers  by 
opening  the  market  for  long  distance  and  international  calls  to  strong  competition. 
This  would  then  suppress  the  incentive  to  invest  in  alternative  local  infrastructure, 
thus leaving the provision of local access in most cases to a single, de facto  monopoly 
provider. 

The majority  of comments say that  leaving barriers for  services competition  in order 
to  stimulate  infrastructure  competition,  on  the  contrary  does  not  lead 
to  economic 
efficiency  nor does it give  customers the best deal.  On the one hand a duopoly  for 
local  infrastructure  is  no  guarantee  for  real  competition  regarding  the  offer  of  local 
access services  and  on the other hand  , not having user friendly  instruments to pre 
select other service providers over the local network invariably  leads to service  tariffs 
staying  high.  Moreover,  residual  barriers  to  service  competition  create  an  artificial 
incentive  for  infrastructure  investment  which  may  not  be  sustainable  in  the  longer 
term. 

On  the  basis of the  arguments  brought  forward  in the  consultation,  the  Commission 
considers that  "equal  access" is the  best  instrument  for  creating  a level playing field 
for  incumbent  operators and new entrants  alike. Moreover,  as user associations  have 
pointed out, the consumer  is best  served with  user friendly  mechanisms which  offer 
access to all  services available and they do not consider call-by-call  carrier  selection 
without  the  possibility  for  the  customer  to  choose  his  own  default  as  user  friendly. 
For these reasons , the Commission  proposes the introduction  of carrier  pre-selection 
throughout  the  internal  market  by  a  set  date.  The  concern  about  having  sufficient 
investment  in  local  access  infrastructure  is  shared  by  the  Commission.  However, 
incentive  for  investment  in  the  local  loop  is  likely  to  be  driven  increasingly  by  the 
provision  of new multimedia  services  rather than by competition  in traditional  voice 
telephony.  More  importantly  ,  concerns  about  the  quality  and  availability  of  local 
access  are  considered  to  be  met  by  the  universal  service  obligations  which  are  now 
firmly  anchored  in  Community  legislation.  These  obligations  ensure  that  every 
citizen  can  access  an affordable  service  of defined  quality  wherever  they  live  in  the 
Community. 

IV.2 

Issues for further  discussion  or study 

On the basis of the comments the Commission concludes that it would not be justified 
at  this  stage  , to  oblige  local  access  providers  without  significant  market  power  to 
offer  carrier selection or carrier pre-selection. 

It  appears  that  if  such  obligations  are  imposed  on  local  access  providers  with 
significant  market  power, the market  forces  themselves  will provide  an incentive  for 

21 

local  access  providers  without  significant  market  power  to  offer  similar  facilities 
without  regulatory  obligations  or,  alternatively,  to  lower  their  tariffs  to  competitive 
levels.  If  they  would  refrain  from  doing  this,  they  would  not  be  an  attractive 
alternative  for  customers  who  would  then  stay  with  or  switch  back  to  the  access 
provider offering  such options. 
The issue of whether a broader obligation is required  , will be reconsidered  as part of 
the general review of  the functioning  of the various telecommunications  liberalisation 
and 
harmonisation  measures  (as  already  foreseen  in  the  relevant  Directives), 
scheduled for  1999. 

Secondly, the Commission  considers that the need to oblige mobile operators  to  offer 
carrier  selection,  carrier  pre-selection  and  number  portability  needs  to  be  further 
examined,  especially  as  it  would  require  technical  changes  to  the  GSM  standard 
(which  are  currently  being  examined  by  ETSI) and  could  involve  high  introduction 
costs.  Despite  the  high  degree  of  competition  in  various  national  mobile  markets 
allowing  fair  consumer  choice,  many  other  markets  are still  in  the  early  stages  of  a 
development  process  and  it  remains  to  be  seen  what  level  of  competition  will  be 
reached.  For these reasons, the Commission finds that  it would be  reasonable  to re 
evaluate  the  need  for  introduction  of  new  numbering  mechanisms  facilitating 
consumer choice in the mobile sector  by the end of 1998. 

Furthermore the Commission concludes that  further  study is needed on : 

an appropriate  cost sharing mechanism  for number portability: 

how  the  eventual  introduction  of  an  intelligent  network  solution  for  number 
portability  can be facilitated  and how inter-operability requirements can be met; 

technical  and  cost  aspects of the  implementation  of carrier  selection  and  number 
portability  in mobile networks: 

the  costs  and  benefits  and  technical  aspects  of  a  harmonisation  of  national 
numbering plans in view of a long term European numbering plan. 

22 

V. 

PRIORITIES FOR ACTION 

V.l  Numbering and ensuring effective competition 

The  consultation  has  shown  that  there  is  broad  agreement  on  the  importance  of 
appropriate  numbering  schemes  and  mechanisms  to  allow  users  to  benefit  from 
competition in a liberalised market. 

In addition to the general  application of competition rules under the Treaty, the legal 
framework  for  telecommunications  establishes  obligations  for  Member  States  with 
regard  to numbering. The  Commission  Directive  with  regard  to the  implementation 
of  full  competition  in  telecommunications  markets  requires  that  adequate  numbers 
are  made  available  for  all  telecommunications  services  before  1 July  1997.  The 
reiterates  this  requirement  and  also  stipulates  that 
Interconnection  Directive 
"National regulatory authorities shall  ensure that numbering plans  and procedures 
are  applied  in  a  manner  that  gives  fair  and  equal  treatment to  all  providers  of 
publicly  available telecommunications  services'"  and  that  there  shall  be  no "undue 
discrimination in the number sequences used to give access to the services of other 
telecommunications operators." Moreover, the  Interconnection  Directive already sets 
a  deadline  of  1 January  2003  for  the  introduction  of  operator  number  portability  at 
least  in  all  major  centres  of population  , but  the  consultation  has  indicated  that  this 
date  should  be  brought  forward. 
In  any  case,  according  to  competition  rules  as 
recalled in  directive 96/19/CE, the numbering policy of the Member States shall not -
inter  alia  -  lead  to  maintain  barriers  to  entry  at  an  artificially  high  level,  so  that  a 
dominant  position  would  be  acquired,  maintained,  or  strengthened,  even  though 
special or exclusive rights would have been abolished. 

1. 

Carrier selection / carrier  pre-selection 

In a multi-operator environment,  users must be able to access simply and cheaply  the 
operator  of  their  choice, even  where this operator  does not provide  a direct  line  into 
the customer's office  or home. In this context carrier selection and interconnection  are 
two  sides  of  the  same  coin.  If  we  agree  that  it  is  important  to  oblige  incumbent 
operators to offer  interconnection  to new entrants, we should also make sure that the 
users  have appropriate instruments to reach  the interconnected new entrants. 

The consultation showed wide support for the early introduction of carrier selection as 
an  immediate  step  and  the  subsequent  introduction  of  carrier  pre-selection  to  allow 
equal access. 

8 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. 
9 Directive 97/  /EC of the European  Parliament and the Council on interconnection in 
telecommunications with regard to ensuring universal service and interoperability through  application 
of the principles of open network provision (ONP) (awaiting formal  adoption) 

23 

Whilst  the  Interconnection  Directive  does  not  determine  whether  the  default  service 
provider  should  be  chosen  by  the  customer  or  by  the  local  access  provider,  it  does 
require  that  fair  and  equal  treatment  regarding  numbering  is  given  to  all  service 
providers. In practice this means that Member States must at least  create a system of 
pre-fixes  by which customers can reach other service providers  than their local access 
providers. 

In  order  to  achieve  effective  competition,  the  Commission 
considers  that 
national  implementation  measures  must be in  place  on  the  basis  of  the  current 
regulatory framework  to ensure that 

•  a non-discriminatory  and  user friendly  mechanism  for direct selection  by the 
customer  of  a  long  distance  and  international  calls  carrier  is  offered  by  all 
fixed  local access  providers with  significant  market power by  1 January  1998 
in  all  Member  States  where  liberalisation  of  voice  telephony  is  required  by 
that date. 

• 

long  distance  and 
international  service  providers  may  negotiate  pro-
competitive  cost  calculation  and  billing  arrangements  with  the  incumbent 
operator. 

Further Community measures will be needed to achieve that: 

•  carrier  pre-selection  is  available  for  customers  of  all  fixed  local  access 
providers  with  significant  market  power  by  1 January  2000  in  all  Member 
States. 

The  need  for  extension  of  carrier  selection  or pre-selection  to  mobile  operators 
must be re-evaluated  by the end of  1998  and the need  for an extension  to  fixed 
local  access  providers  without  significant  market  power,  must  be  examined  in 
the 1999 review. 

2. 

Number portability 

The  need  to  change  telephone  numbers  when  changing  network  provider  has  been 
identified  as  an  important  deterrent,  both  for  business  and  residential  users.  The 
availability  of operator  number portability  will be crucial  to  stimulating  competition 
the  local  loop.  The  introduction  of  number  portability  is  already  a  legal 
in 
requirement  under  the  Interconnection  Directive  by  1 January  2003  at  the  latest  for 
major  centres  of  population..  While  there  is  broad  agreement  on  the  need  to 
introduce  number  portability  , divergent  views emerged  in the consultation  as to the 
coverage and timetable for its  introduction. 

24 

On the basis of the consultations the Commission believes that  the 
Interconnection Directive should be amended  to 

•  require  all  operators  who  issue  non-geographic  special  service  numbers  ( 
freephone,  shared  costs  and  premium  rate )  to offer  operator  portability  for 
such numbers by  1.1.2000. 

•  require all local fixed access providers to offer operator number portability by 

1 January 2000 at the latest. 

In  view  of  these  requirements 
accompanying measures will be needed.  In particular,  it will be necessary to 

,  the  consultation 

indicated  that  certain 

•  develop  guidelines  by  1998  on  fair  and  pro-competitive  arrangements  for 
assessing  and  sharing  the  costs  of  number  portability  between  operators 
involved. 

•  study  possible minimum criteria and  standardisation requirements in view of 
guaranteeing  interoperability  within  a long term  number  portability  solution 
(intelligent network solution). 

With  regard  to  any  further  extension  of  number  portability  .  the  Commission 
draws the following conclusions from the results of the consultation: 

•  taking  account  of  studies  conducted  by  ETSI,  by  the  end  of  1998  the 
desirability  of  and  a  possible  date  for  requiring  mobile  operators  to  offer 
operator number portability must be re-evaluated. 

• 

it  would  not  be  desirable  to  have  location  number  portability  or  number 
portability  between  different  service  categories  (between  fixed  and  mobile), 
where  this  would  lead  to  a  loss  of  tariff  information 
for  the  user.  In  this 
context  it would  be necessary to study how a system of on-line, per call tariff 
information for the user can be implemented in a multi-operator  environment 
where numbers no longer give reliable indications for the tariff of a call. 

3. 

Opening national numbering plans to competition 

The  consultation  on  the  Green Paper  has  stressed  once  again  the  great  importance 
attached  by  operators  and  service  providers,  and  in  particular  new  entrants  and 

25 

incumbents  with  a  pan-European  strategy, 
to  open,  non-discriminatory  and 
transparent  national  numbering  plans  to  be  managed  by  independent  authorities. 
These  requirements  are  fully  recognised  by  EC telecommunications  legislation  and 
obligations have been imposed on Member States accordingly. 

in 
the  Commission  will  scrutinise  the 
Under  the  full  competition  Directive 
national  numbering  plans  to verify  that  they  have  been  sufficiently  adapted  to 
the  new  competitive  environment.  Part  of  the  factual  input  needed  for  this 
assessment will be provided by a study which ETO is currently conducting. 

— — — — — — _ _ _— 

•••  —• —•  -—— 

•• 

On the basis of the  ETO study,  and after  discussion with  all interested  parties, 
the Commission  should  propose recommendations  for any further  restructuring 
of national  numbering  plans needed to  accommodate the numbering  needs of a 
multi carrier environment  in an equal, non-discriminatory way. 

V.2  Numbering and the single market 

Obviously,  from  the  present  situation  where  telecommunications 
services  and 
networks  are  still  very  much  organised  and  operating  within  national  borders,  it  is 
difficult  to think ahead and forecast  the requirements of a unified European market for 
telecommunications  services.  Only  a  few  respondents  have  been  able  to  make  this 
leap in time  and  to recognise  the needs and  the opportunities  of a single  market  for 
telecommunications services. 

Practically  all respondents underlined  the need  to allow for  long to very  long periods 
in case of  significant  changes in numbering plans.  This means that numbering  plans 
are  not  a  commodity  which  can  be  easily  and  quickly  adjusted  to  changing  needs, 
especially where changes are required to at least fifteen numbering plans 

1. 

Implementation of European Telephony Numbering Space 

The best arbitration mechanism  to decide which of  the divergent assessments of the 
future  demand  for pan-European services is the correct one will be the market itself. 
However,  in  order  to  allow  the  market  to  reply, 
the  availability  of  pan-European 
numbers must precede the demand. 

10 Commission  Directive 96/16/EC amending Commission  Directive 90/388/EEC regarding the 
implementation of full competition in telecommunications markets, OJ L 74, 22.03.1996, p. 13. 

26 

The Commission considers appropriate to 

•  aim at establishing  the European Telephony Numbering Space by  1 January 

1999 on the basis of the '388' country code. 

•  define  a broad  spectrum  of services which  may  be operating  under the '388' 
code, while at the same time ensuring that users can easily distinguish between 
various types of services and their tariffs. 

•  charge  a structure within CEPT /ECTRA with the processing of  applications 

for pan-European numbers and the settlement of disputes. 

2. 

Convergence of national numbering plans 

The  consultation  showed  that  harmonisation  in  itself  was  not  seen  as  a  sufficient 
ground  for  changing  national  numbering  plans. At the  same  time,  the  merits  of  a 
certain  degree  of  harmonisation  were  recognised  but  to  achieve  this,  a  gradual  , 
natural  convergence  on  the  basis  of  consensus  was  advocated.  Therefore  the 
Commission  believes  that  future  changes  in  numbering  plans  should  be  based  on 
agreed common guidelines with a dual competition and convergence purpose. In this 
way  the growth  and expansion  of the pan-European  dimension  within  the  European 
numbering  environment  can  be  achieved  without  having  to  undertake  any  major 
additional changes in national numbering plans. 

The  recommendations  which  the  Commission  intends  to  give  for  further 
restructuring  of  national  numbering  plans  needed  to  achieve  equal  qualitative 
and  quantitative  access to number  resources for  all market players (see above), 
should  also  incorporate  criteria  ensuring  an appropriate  degree  of  convergence 
between national numbering plans. 

3. 

Long term European numbering plan 

27 

The consultation  on the Green Paper has shown that there  is considerable  uncertainty 
about the costs and benefits  of a unified  European  numbering environment,  and  that 
further  study is therefore required. 

In  the  light  of experience  gained with  a liberalised  single  market  and with  the 
European  Telephony  Numbering  Space,  by  the  end  of  1999,  the  Commission 
will contract a detailed study of the costs and benefits likely to be associated with 
a unified European numbering environment. 

4. 

Alphanumeric dialling 

The  general support for a common approach to alphanumeric dialling on the basis of 
International  Telecommunications  Union  recommendation  E.161  , option  A,  should 
be translated in a common standard. 

Consumers have expressed  an interest  in harmonisation  of the "*" and "# "  function 
codes  as  well.  This  is  a  somewhat  different  and  more  complicated  type  of 
harmonisation  since it requires a common  standard for  these codes to be available  as 
functions  in  the  network.  Therefore  it  involves  cooperation  and  agreement  of  all 
network operators. ETSI is currently undertaking  work towards a common standard. 

The  Commission  believes  that  ETSI  should  endeavour  to  adopt  common 
standards , both on alphanumeric dialling and the "*" and "#" codes by the end 
of 1997. 

5. 

Internet naming and addressing 

Although  there  was  broad  agreement  on the  significance  of  naming  and  addressing 
within the Internet and the problems which have occurred, no consensus has emerged 
about  the  nature  and  scope  of  initiatives  or  measures  which  should  be  taken.  The 
Commission  sees this outcome as support for an informal  but active  contribution to 
be made by the Commission ,  with a view to defend  European interests in the global 
discussion. 

28 

The  Commission  will  keep  the  situation  under  review  and  will  propose  non-
regulatory  initiatives where this can have an added value for the  representation 
of European interests at the global level. 

29 

VI. 

TIMETABLE 

On  the  basis  of  the  preceding  chapter  on  priorities  for  action,  the  timetable  for  the 
availability  of  carrier  selection  and  pre-selection,  number  portability  and  pan-
European numbers is as follows : 

by 1 January  1998 

Call-by-call  carrier  selection  to  be  offered  by  all  fixed 
local  access providers  with  significant  market  power  in 
all  Member  States  where  full  liberalisation  is  required 
by  that  date  and  in  Member  States  where  additional 
transition  periods  have  been  agreed,  by  the  end  of  that 
period. 

by  1  January  1999 

Establishment  of  a  European  Telephony  Numbering 
Space on the basis of country code '388' 

by 1 January 2000 

Carrier  pre-selection  , with  default  to  be determined  by 
the subscriber and with call-by-call override 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 rate services) 

In  order  to  attain  these  objectives  and  to  decide  on  any  follow-up  ,  the  following 
actions will be needed : 

by mid  1997  Adoption  of  resolutions  by  Council  and  the  European  Parliament 
confirming  the  priorities  and  timetable  for  action  which  have 
emerged from the consultation 

Commission  review  of  national  numbering  plans  in  view  of 
requirements of the full competition Directive 

by end 1997 

Proposal  for  appropriate  legislative  measures 
availability  of  facilities  for 
portability throughout the internal market by  1  January 2000. 

carrier  pre-selection 

to  ensure  the 
and  number 

30 

ETO report with detailed description of national numbering plans 

Adoption of ETSI standard concerning alphanumerical key pads 

Launch studies on  1) possible minimum criteria and  standardisation 
requirements in view of a long term number portability solution and 
2)  alternative,  on-screen/on-line  means  for  tariff 
information  for 
the user 

by end  1998 

Examine  possible 
portability  requirements to mobile operators. 

extension  of  carrier  selection  and  number 

by early  1999  Appropriate  legislative  measures  to  be  adopted  to  ensure  the 
and  number 

availability  of  facilities  for 
portability throughout the internal market by 1  January 2000. 

carrier  pre-selection 

Member  States  to  implement  '388'  for  the  European  Telephony 
Numbering Space 

Commission 
competitive arrangements for sharing costs of number portability 

to  issue  common  guidelines  on  fair  and  pro-

Commission  recommendations  on  further  restructuring  of  national 
numbering  plans  in  view  of  competition  requirements  and  gradual 
convergence 

by end  1999 

Examine desirability  of  extension  of  carrier  selection  requirements 
to fixed  local access providers without significant  market power 

early 2000 

Further  study,  in  the  light  of  experience  with  a  liberalised  single 
market  in telecommunications  and with the ETNS, of need  for  and 
costs / benefits of unified European numbering environment. 

31 

VII.  CONCLUSIONS 

The  consultation  has  demonstrated  wide  support  for  the  Green  Paper  proposals  to 
introduce  carrier  selection,  carrier  pre-selection  and  operator  number  portability  in 
order  to  enable  the  user  to  benefit  from  a  new  competitive  market  situation.  The 
comments also provided  a useful  basis to determine the most appropriate coverage in 
terms  of  services  and  service  providers, 
for  the  mandatory  requirement  of  these 
numbering  features,  as  well  as  clear  indications  concerning  the  timetable  for  their 
introduction.  The  Commission  will  propose  concrete  measures  to  ensure  that  these 
numbering  mechanisms  are  put  into  practice  by  the  deadlines  which  are  considered 
desirable and feasible. 

Moreover, the outcome of the consultation showed a strong emphasis on the need  for 
national  numbering  plans  to  allow  equal  quantitative  and  qualitative  access  to 
numbering  resources  for  all carriers. This was generally  felt  to be a key  requirement 
for  non-discriminatory  access  to  the  liberalised  telecommunication  markets.  The 
Commission will  continue to closely monitor the situation in the Member States with 
regard 
take  action  where  necessary.  In  addition 
recommendations will be issued for further  restructuring. These recommendations will 
also take account of convergence requirements. 

to  numbering  plans  and 

On  other  numbering  issues  related  to  the  single  market,  various  action  points  have 
been identified  and the Commission  will actively follow and encourage developments 
in CEPT/ECTRA  regarding the establishment of the European Telephony  Numbering 
Space. Where necessary  mandates and work requirements will be submitted  to ETSI 
and ETO on specific issues identified  in the consultation. 

A long term view  on a European Numbering environment  will need to be developed 
on  the  basis  of  experience  gained  with  a  liberalised  market  and  with  the  European 
Telephony Numbering Space.  The Commission will follow up on this with a detailed 
cost / benefit  study. 

The Commission  transmits to  the  European Parliament, the Council, the Economic 
the  present 
the  Committee  of 
and  Social  Committee  and 
Communication prepared on the basis of the public consultation. 

the  Regions, 

32 

Glossary 

Alpha-numeric dialling / keypad 

Carrier pre-selection 

Carrier selection 

Easy access 

•CTRA 

telephone  number  by  using 

Dialling  a 
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" 

Possibility  for  customers  to  determine  their  own 
default  carrier  on  a  semi-permanent  basis  thus 
avoiding any additional dialling 

choose  their 
The  possibility  for  customers  to 
long-distance  or  international  operator  e.g.  by 
dialling  a  code  or  by  determining 
the  default 
carrier 

Method  for  carrier  selection  whereby  the  default 
carrier  is determined  by the  local  access  provider 
with the possibility  of call-by-call  override by the 
user through dialling a code 

inter  alia 

teams  covering 

European  Committee  for  Telecommunications 
Regulatory  Affairs  created  as  one  of  the  three 
committees  under  the  Conference  des  Postes  et 
It  includes  a  number  of 
Télécommunications 
licensing, 
project 
numbering, 
mobile 
type-approval. 
communications, 
Council  Resolution 
19 
of 
November  1992 on the promotion  of co-operation 
on  Europe  wide  numbering,  identified  several 
tasks  for  ECTRA  ,  including  the  creation  of  a 
European numbering  space and the preparation  of 
positions for discussion within ITU. 

interconnection, 
testing 

and 
92/C318/EEC 

Equal access 

the  default  carrier 

Method  for  carrier  selection  whiteout  bias  in 
favour of a particular long distance or international 
carrier  whereby  either 
is 
determined  by  the  customer  with  call-by-call 
override  or  no default  carrier  is determined  and 
each  long  distance  or  international  call  must  be 
preceded  by  a  carrier  selection  prefix,  (the  latter 
method is not considered to be user  friendly) 

33 

•:TNS 

ETO 

ETSI 

Freephone service 

ITU 

ITU-T 

Non-geographic services 

Number portability 

to  he  created)  European  Telephony 
(still 
Numbering  Space 
refers  to  a  numbering  space 
which  exists  in  parallel  with  national  numbering 
spaces. Numbers from  the ETNS will be available 
and  can  be  accessed  anywhere  in  the  European 
Union ( and throughout the rest of Europe). 

European 
Office 
Telecommunications 
established  under  the  umbrella  of  ECTRA  to 
technical, preparatory work. 

do 

European Telecommunications  Standards  Institute 
charged  with  developing  Europe  wide  standards 
for the telecommunications sector 

A service that  is (can  be accessed)  free  of  charge 
to  the 
is 
customer.  The  access  code 
generally associated with  freephone. 

'800' 

International  Telecommunications  Union, 
United  Nations 
agency 
telecommunications 

specialised 

the 
for 

Telecommunications sector of the ITU. 

Telecommunications  services  that  are  numbered 
from  (national)  number  ranges  which  are  not 
assigned or associated  with a specific  region,  city 
area or local community. 

The  possibility  for  a  subscriber  to 
keep  his 
telephone  number  while changing  a) operator,  b) 
type of service or c) location. 

Premium  rate  or  shared  revenue  Service  for  which  the  caller  pays  an  extra  charge 
which 
telecommunications 
service 
operator.  The  revenues  are  shared  between  the 
latter and the  service provider. 

is  billed  by 

the 

Shared cost service 

Service  for  which  the  cost  of  the  call  are  shared 
between the  caller  and the  called  party,  generally 
resulting  in  the  caller  paying  local  rate  and  the 
called  party  being  charged  with  any  additional 
costs. 

34 

WRITTEN CONTRIBUTIONS 

[National administrations  and National  Regulatory Authorities 

BIPT /IBPT 
Forskningsministeriet / Telepolitisk Kontor 
Bundesministerium fur Post und Telekommunikation 
Ministry of transport and telecommunications 
Ministerio de Fomento / Secretaria General de Comunicaciones 
Permanent Representation to the EU 
Department of Transport, Energy and Communications 
Ministère délie Poste e delle Telecommunicazioni 
Ministerie van Verkeer en Waterstaat 
Bundesministerium  fur Wissenschafl, Verkehr und Kunst 
Instituto das comunicaçoes de Portugal 

Telehallintokcskus/Teleforvaltningscentralen 

Kommunikationsdepartementet 
Permanent Representation to the EU 
Ministry of transport and communications 
Government of the principality of Liechtenstein - EEA 
Coordination Unit 
BAKOM (Bundesamt fur  Kommunikation) 

Belgium 
Denmark 
Germany 
Greece 
Spain 
France 
Ireland 
Italy 
Netherlands 
Austria 
Portugal 
Finland 
Sweden 
United Kingdom 
Norway 
Liechtenstein 

Switzerland 

Associations 

téléphone  et  des 

(Association 

française  des  utilisateurs  du 

AFTEL ( Association française  de la télématique multimédia) 
AFUTT 
télécommunications) 
AK Wicn (Bundcskammcr fur Arbeiter und Angestellte - Vienna) 
AOST (Association des Opérateurs de Services de Télécommunications) 
BEUC (Bureau Européen des Unions des Consommateurs) 
CEEP (Centre Européen des Entreprises à Participation Publique) 
CIGREF (Club Informatique des grandes entreprises  françaises) 
CNPF (Conseil National du Patronat  français) 
DIH (Deutscher Industrie- und Handelstag) 
ECCO (European Competitive Carrier's Organization) 
ECMA ( European Computer Manufacturers  Association) 
ECTEL (European Telecommunications Manufacturers  Asociation) 
ECTRA (European Committee of Telecommunications Regulatory  Affairs) 
ETNO (European Public Telecommunications Network Operators' Association) 
ETO (European Telecommunications  Office) 
ETSI (European Telecommunications Standards Institute) 

35 

EU Committee of the American Chamber of Commerce 
EURIM (European Informatics Market) 
FEDIM (Fédération Européenne du marketing direct) 
FEI (Federation of the Electronics Industry) 
GITEP  (Groupement  des  Industries  de  Télécommunications  et  d'Electronique 
Professionnelle en France) 
GSM MoU Association 
HDE (Hauptverband des Deutschen  Einzelhandels) 
ICSTIS (The  Independent  Committee  for  the Supervision  of Standards of  Telephone 
Information  Services) 
INTUG (International Telecommunications  Users Group) 
Joint Committee on Telecommunications 
ONP-CCP / HI F (European  Interconnection Forum) 
RNID (Royal  Institute for  Deaf People) 
UNICE (Union des Confédérations de l'Industrie et des Employeurs d'Europe) 
Union Internationale des Chemins de fer 

Telecommunications service and network providers 

ACC telecom UK 
Airtouch 
AT&T 
Belgacom 
British  Telecom 
Cegetel 
Cellnet 
Companhia Portuguesa Radio Marconi 
Debitel Kommunikationstechnik 
DeTeMobil 
Deutsche Telekom 
Easynet 
E-plus Mobilfunk 
Energis 
France Telecom 
Global One 
lonica 
Mannesmann Eurokom 
Mannesmann  Mobilfunk 
Mercury communications 
Orange 
Portugal Telecom 
Post & Telekom Austria 
Proximus 
PTT Telecom - Netherlands 
STET - Italy 

36 

Telecential communications 
Telecom Tiircann 
Telecom  Italia 
Telefonica - Spain 
Telenet operaties 
Telenor 
Unisource 
Vebacom & RWE 
VIAG 
Worldcom-  MFS 

Manufacturers 

Alcatel /Alsthom 
Olivetti 

Consultants 

Institute for Public Policy Research 
International Integrated Information  Systems 
Mr. Craig Macbride 
NCSi Datentechnik 
Dr.Clive Page 

37 

ISSN 0254-1475 

COM(97) 203 final 

DOCUMENTS 

EN 

15  01 

Catalogue number  :  CB-CO-97-234-EN-C 

ISBN 92-78-19889-7 

Office  for Official  Publications of the European Communities 

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