Comments on the Draft ECC Recommendation (12)04 – Numbering for VoIP services

Comments on the Draft ECC Recommendation (12)04 Numbering for VoIP services
by VON Europe, November 2012 Preliminary Remarks
The Voice on the Net Coalition Europe (‘VON’) welcomes the opportunity to comment on the ECC Recommendation 12(04) on Numbering of VoIP Services (hereafter the ‘Recommendation’). VON welcomes the Recommendation as it encourages the use of existing numbering ranges of national numbering plans for VoIP services, both as regards fixed and mobile numbers. VON does however consider that a few additional elements could usefully be integrated in this Recommendation and has therefore included in Annex some suggestions for amendments to the proposed text. We refer you to our detailed remarks below and we thank you in advance for taking consideration of these views. Feel free to contact Herman Rucic, VON Europe, by phone (+32 (0)478 966701) or email ( should you need further information.

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

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Comments on the Draft ECC Recommendation (12)04 – Numbering for VoIP services

Detailed Remarks
1. Important elements set out in the Recommendation VON fully supports the ECC’s statement in the Introduction that “existing numbering ranges facilitate easy and quick implementation which is needed to ensure interoperability”. VON would like to point out that interoperability is however not the only need that is met by such an approach. There is a clear end-user demand to use regular numbering resources without restrictions, as set out in our comment in Section 3 sub (a). VON also agrees with the statement in Recital (g) of the Recommendation that “the existing approach in countries having a specific numbering range for nomadic VoIP services appears to have had a limited commercial success”. In general, VON believes that no separate numbering range should be required for new innovative services and applications, including offerings that make use of VoIP to make outbound calls. Experience shows that consumers are reluctant to call to (or call back to) new numbers (as there is uncertainty about the retail price) or switch to new numbers. In addition, established operators have often restricted or substantially delayed (in several cases by many years) the implementation of specific numbering ranges for nomadic VoIP . VON also broadly agrees with the enumeration set out in Recital (f), though we do suggest in Annex some amendments in order to bring the text more in line with Article 10 paragraph 1 of the EC Framework Directive 2002/21/EC and Art. 6 par 1 of the EC Authorization Directive 2002/20/EC. Finally, VON considers Recommendations (1) and (2) themselves to go in the right direction. Nevertheless, we believe that in order to comply with its mission the ECC should adopt a more forward looking approach by treating all numbers in a technology neutral manner.1 Hence our addition of a third paragraph to the Recommendations (see our comments in Sections 3 (a) and (b) and suggestions in Annex).

1 The ECC’s mission is a.o. “to harmonise the efficient use of the radio spectrum, satellite orbits and numbering resources across Europe”. According to the ECC’s website, the “ECC’s approach is strategic, open and forward-looking, and based on consensus between the member countries. It applies its expertise in partnership with all stakeholders, the European Commission and ETSI to facilitate the delivery of technologies and services for the benefit of society”, See, EEC. (n.d). ECC Mission statement. Retrieved at,

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Comments on the Draft ECC Recommendation (12)04 – Numbering for VoIP services 2. The need for modifications VON considers that some statements in the Recommendation could be further refined, namely:  Introduction to the Recommendation: ‘New type of voice services’: VON would like to point out that, although obviously traditional circuit-switched voice is much older than VoIP, the use of VoIP technology in an offering to end-users does date back to at least 1995, when a small company called Vocaltec Inc launched their InternetPhone product, which allowed users to call each other via their computer. It is true, however, that the type of applications and services using VoIP have since continuously evolved, improved and that this has been characterised by rapid and major innovation.  Introduction to the Recommendation: “Today nomadic VoIP based services are usually delivered over fixed broadband internet access, but they will increasingly be based on a mobile broadband data access”: We do not believe that ‘usually’ in this sentence reflect the reality of the past couple of years. Though it is fair to say that VoIP is still used mainly on fixed lines, a 2011 study by Infonetics shows that mobile broadband subscribers surpassed fixed broadband subscribers in 2010 (558 million vs. 500 million).2 Moreover, analysts expect that the growth of VoIP over the next 3-4 years will mainly be driven by the broad adoption of mobile VoIP and that this will result in an active user base of approximately 30 million users in Western Europe by the end of 2015, as demonstrated by the chart below from Analysys Mason.


See Infonetics Research. (2011). Mobile Broadband Subscribers Overtake Fixed Broadband. Available at,

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Comments on the Draft ECC Recommendation (12)04 – Numbering for VoIP services

Figure 1: Active subscribers of OTT VoIP services by primary means of access, Western Europe, 2006–2015 (Source: Analysys Mason)

 ECC Recommendation – Recital (c): “that many providers of new services based on VoIP technology aim for these services to be a substitute for traditional voice services”: This sentence does not reflect the aim of many VoIP players, whose ambition is not to duplicate or substitute the old voice services but rather to create new means of communication that combine instant messaging, voice, video, multi-party, video, file transfer and other data, images, etc.. We would highly recommend that this sentence be replaced to reflect the user demand of being accessible everywhere, all the time, on every device, in the most convenient and ubiquitous manner, as set out in our comments in Section 1 and in our proposed amendment in Annex. Indeed, the creative use of IP technologies, such as VoIP, and the increased availability of broadband Internet access have resulted in a variety of new products, applications and services that include communications features. The following are examples of some of these innovative offerings: o One-way VoIP services – using a PC, mobile phone or another device with an Internet connection to either make calls to national numbering plan numbers (outbound-only service) or receive calls from national numbering plan numbers (inbound-only service); o Click-to-call services – adding a feature to a website to permit a call to a customer support help desk or a product information line, or to a software application like a


See Analysys Mason. (2011). Research Report Mobile VoIP: Operators Must Re-evaluate Their Core Portfolio. Available at,

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Comments on the Draft ECC Recommendation (12)04 – Numbering for VoIP services personal information manager or contacts database that permits a pre-programmed PSTN number to be called; o Interactive voice response systems (IVR) – enabling a business to use VoIP to offer telephone access to voice-activated automated customer service, reservations, and product information systems containing stored content; o Software applications that include online communications functions, such as online games with VoIP and chat, and virtual worlds, or videoconferencing; and, o Web-based voicemail systems – these systems store voicemail messages from voice or VoIP calls. The user may access the voicemail message at a website or via email or SMS. 3. Missing elements in this Recommendation Numbers have been, are and will remain a critical resource for communication services and applications. A well designed and forward looking numbering plan will support innovation, accommodate growth, bring consumer benefits and promote competition. Most national numbering plans, devised more than 30 years ago, are unlikely to be adequate to cope with new trends and developments. In general, VON believes that the ECC’s proposed Recommendation does not entirely and/or sufficiently embrace new evolutions triggering high growth in demand for numbers, proliferation of new services and applications, market liberalisation, customer expectations, and an expansion in the finality of numbers (from location identifiers to personal and service identifiers and access codes to new applications). The approach to numbering should not be one of obligations versus rewards. Nor should it be one that is unable to encompass and embrace the imminent changes brought by convergence of all networks and the switch to an all-IP environment, and the increasing role of Internet applications on fixed and mobile devices. The ECC should therefore consider reviewing more fundamentally its entire approach to numbering, through a dialogue initiated with all stakeholders, including end-users. Such approach could be designed along the lines set out below. (a) Removing the link between numbers and geographic location In VON’s opinion, location information of geographic numbers should be discarded, and the members of the ECC should be encouraged to take the necessary steps to this avail in this Recommendation.

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Comments on the Draft ECC Recommendation (12)04 – Numbering for VoIP services Location information of geographic numbers is a legacy from the Plain Old Telephony Services. However, in reality geographic numbers are increasingly not representative of the location of a called party: for example, with call forwarding, a call to a number supposedly located in a specific geographic region, could very well be forwarded to an entirely different place. Moreover, in recent years, people have become more flexible, ready to move and travel at any time. Many users increasingly want to be connected all the time, everywhere and on any device. Mobile phones are overtaking fixed phones and calling your plumber happens more often than not on his mobile phone. Who knows: soon, your toilet might be able to call the plumber on its own initiative! The rules for geographical numbers were historically and traditionally designed for legacy circuitswitched networks and the associated exchange architecture. These rules are obsolete, highly prescriptive and limit flexibility for new innovative services. IP networks do not require restrictive numbering rules to switch and route calls. (b) Removing access to mobile numbering capacity for innovative services A number of EU Member States are reserving the allocation of mobile numbers, to operators controlling mobile spectrum (MNOs) and/or to operators or service providers offering mobile services on the basis of a contractual arrangement with an MNO, such as MVNOs. Such an approach constitutes a violation of the European regulatory framework, as these restriction are an unjustified discrimination between providers of mobile services depending on the technical configuration they use. This is also inconsistent with the objective that regulation should be technologically neutral, and prevents innovation in mobility-enablement, thereby depriving users of new types of

communications solutions. Numbers for mobile services can universally be reached from all national and international networks, and only such numbers enable the problem-free inter-network and billable reception of voice, SMS and MMS. VON considers that this Recommendation offers a great opportunity to state that it should not be compulsory to use a radio network for establishing connections from/to mobile numbers and that providers which are not mobile network providers may also become original assignees of mobile numbers.

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Comments on the Draft ECC Recommendation (12)04 – Numbering for VoIP services

Annex – Suggested Amendments
Note: Additions are marked in bold and underlined. Deletions are indicated by using strikethrough.
INTRODUCTION New Innovative types of voice services are being developed that use the internet either via fixed and/or mobile connections rather than the traditional circuit switched networks. These services are commonly referred to as “Voice over IP” (VoIP) applications by service providers without control of the underlying network, i.e. the access to VoIP service is location independent. For many of these new services the interoperability with traditional voice services (i.e. telephone voice services supported by Public Switched Telephone Network (PSTN) like ISDN, or mobile networks like GSM) is a critical success factor and this means that these services need adequate access to numbers for their subscribers. Although many of these new services started by offering outgoing calls only, some VoIP providers are now asking for numbers to support incoming calls and so the issue is now high on the agendas of many regulators. Existing numbering ranges facilitate easy and quick implementation which is needed to ensure interoperability. Today end-users are using different kinds of applications and underlying networks. From market and competition point of view the end-users should be able to port their numbers between different service providers and applications, noting that there are national limitations within number portability, e.g. fixed-mobile portability may not be allowed. Where technically feasible, national limitations should be technologically neutral and avoid creating unnecessary hurdles. Today nomadic VoIP based services are usually still mostly delivered over fixed broadband internet access, but though they will are increasingly be based on a mobile broadband data access. In this Recommendation “nomadicity” is understood as a feature of a service which is not linked to a particular physical location. The service can be provided from potentially any fixed and/or mobile network access point in the world for incoming and outgoing communication. Within nomadicity call handover is not possible. Mobility has the same characteristics as nomadicity but with additional call handover function. In this Recommendation numbering schemes for operators which offer services based on IP technology on their own network are not considered. ECC RECOMMENDATION OF (12)04 ON NUMBERING FOR VoIP SERVICES “The European Conference of Postal and Telecommunications Administrations, considering a) b) that this Recommendation only addresses Voice over IP (VoIP) services from service providers without control of the underlying physical network; that VoIP services in this Recommendation are considered as nomadic services interworking with the Publicly Available Telephone Service (PATS);

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Comments on the Draft ECC Recommendation (12)04 – Numbering for VoIP services
c) that many providers of new services based on VoIP technology aim for these services to be a substitute for traditional voice services;that users increasingly expect to be able to communicate using numbers regardless of the location, network or device they use; that such services continue to grow and have significant potential to increase competition; that such services are not linked to a particular physical location and that the services can be provided potentially from any fixed and/or mobile network access point (nomadicity), a technical reality that responds to a user demand and must be reflected in the numbering plans; that number assignments should be   user-friendly, transparent, objective and non-discriminatory between service providers and on equal and proportionate conditions,  informative to the user, especially with regard to tariff transparency,  facilitating portability; that the existing approach in countries having a specific numbering range for nomadic VoIP services appears to have had a limited commercial success;

d) e)



recommends 1. that the NRAs should ensure that VoIP services can be provided using the existing numbering ranges of the national numbering plans; 2. that without prejudice to any existing specific nomadic VoIP numbering ranges the NRAs should assign either fixed or mobile numbers depending on the specific features of the service in question in accordance with the existing national numbering plan. 3. that the NRAs should remove any remaining obstacles to the assignment of all numbers, both fixed or mobile, that violate the principle of technological neutrality, including any requirements that the allocation of mobile numbers be reserved to operators controlling mobile spectrum (MNOs) and/or to operators or service providers offering mobile services on the basis of a contractual arrangement with an MNO.

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