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'
Date: 1997-10-29
Institutions: European Economic and Social Committee
Subjects: communications policy, new technology, research and development, telecommunications, telephone

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4.7.
The problem of transalpine traffic is of great
importance to the development of intermodality in
Europe. But some of this sector falls outside the EU’s
sphere of influence. This can stand in the way of an
effective European policy on intermodality.

A new, ‘intermodality-based’ approach to trans-
4.8.
port will require a re-organization of the transport
chain. New actors will be active, logistical concepts and

systems will change. This in turn will alter the level and
structure of transport costs. It is not clear whether or in
what way such developments will influence the price of
transport and quality of service, and perhaps with it the
competitive position of Europe. Whatever happens, it is
important to learn from the experiences of existing
intermodal transport services and build on them as
much as possible. Solutions should be found for existing
obstacles so that intermodality becomes more efficient
and attractive.

Brussels, 29 October 1997.

The President

of the Economic and Social Committee

Tom JENKINS

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

The Economic and Social Committee issued its

1.3.
opinion on 28 May 1997 (1).

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.

1.4.
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 (2) was issued in 1987.

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

(1) OJ C 287, 22. 9. 1997, p. 15.
(2) Towards a dynamic European Economy — Green Paper
on the development of the common market for telecom-
(COM(87) 290
services and equipment
munications
final) — ESC Opinion: OJ C 356, 31. 12. 1987, p. 46.

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

— There may be alternative solutions offering better
‘value for money’ (for both consumers and oper-
ators).

— The results of certain ongoing studies proposed by

the Commission were not complete.

— More information was needed on many of the
issues raised and these may well need

technical
additional studies.

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 develop-
ment situation in individual Member State’s own net-
works.

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

— Some of the timetables proposed were unacceptable

2.4.1. 1 J a n u a r y 1 9 9 8

(from too early to too late).

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

— 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.

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

2.4.2. 1 J a n u a r y 1 9 9 9

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.

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.

The Commission communication on the consul-
1.7.
tation 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.

2.4.3. 1 J a n u a r y 2 0 0 0

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.

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

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

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.

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3. General comments

in the EU, the prospects for the intended uniform
numbering plan actions will be materially reduced.

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 num-
bering plans and procedures are required by the ‘Full
Competition Directive’ (1) and the ‘Interconnection
Directive’ (2).

these
The responsibility for achievement of
3.4.
objectives belongs to the National Regulatory Auth-
orities (NRAs). The Committee points to the responsi-
bility of the Member States to have the required
independent NRAs in place and fully operational on
time. Without the NRAs and common rules applicable

(1) 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.

(2) Directive 97/33/EC of the European Parliament and of the
Council of 30 June 1997 on interconnection in Telecom-
munications 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.

4. Specific comments

4.1. Carrier Selection

The Commission proposes that this be the
4.1.1.
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 (3) (point 4.1.1.4) it felt consider-
ation of selection and pre-selection ‘must include com-
prehensive 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
it makes sense for this to be re-evalu-
operators,
ated/examined in 1998/1999 reviews.

4.2. Number portability

(in its previous opinion,

4.2.1.
The inability for a user to keep his number
when changing service provider is seen as an important
the Committee
deterrent
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 Intercon-
nection Directive (2). 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.

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

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Studies are being undertaken by ETSI(1) for
4.2.3.
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.

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. How-
ever 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 net-
works in the United Kingdom).

4.5. Long-term European numbering plan

4.5.1.
The consultation indicated considerable uncer-
tainty about the costs and benefits of a unified European
numbering environment and that further study is there-
fore required.

4.6. Alphanumeric dialling (2)

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

4.4. National Numbering Plans

4.7.

Internet

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

(1) European Telecommunications Standards Institute (ETSI).

4.7.1.
that the situation should be kept under active review.

The Committee agrees with the Commission

(2) 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’.

Brussels, 29 October 1997.

The President

of the Economic and Social Committee

Tom JENKINS