On 18 Oct 2004, the German regulatory authority Reg-TP organised a forum on VoIP, attended by numerous interested parties, including T-REGS.

Reg-TP’s president Matthias Kurth made a lengthy opening speech, which was revealing on many accounts. Kurth promoted VoIP, but advocated a clear and fair framework, to be put in place 'before the introduction of services'.

He also referred to the fact that he was not in favour of a discussion regarding the “abuse of gaps in the legislation” (this was a veiled reference to the regulatory qualification as Publicly Available Telephone Services - PATS, and its definition). It was also clear that the president of the regulatory authority does not wish to support a regime which would undermine the economics of access networks. Notwithstanding, he presented the role of regulator as non-interfering.

The regulator should not be the one to decide about the success of a technology or business model. We will not decide if the winning business model is that of the bundle between access and services or that of a separate and specialised VoIP.”

Nomadic usage is clearly a hot topic, and is seen by the German regulator as a useful and innovative feature of VoIP which should receive all possible chances for deployment and success.

Kurth commented, and solicited input, on three specific issues at the forum:

  1. Emergency calls and how they should be treated for VoIP
  2. Numbering issues in relation to VoIP
  3. Unbundling of telephone access (i.e. the possibility for alternative operators to provide xDSL on a wholesale basis without the end-user requiring a PSTN/ISDN subscription from Deutsche Telekom)

Emergency Calls

With regard to emergency calls, Kurth made it very clear that he does not wish to see a prolonged discussion on who should comply with the obligation to provide emergency calls and location data to emergency services. He said that “VoIP should not become a second class service. It is possible to do emergency calls and to communicate location if there is fixed VoIP or very few gateway hops.” To this he added that he does not want a worse emergency call system than the system Germany has today.

Kurth wants to know when it is possible, how it is possible, and he does not desire a debate on whether emergency calls and the provision of location data are possible at all. Options such as the introduction of glide paths for obligations, and possible alternative technical solutions such as a central access for emergency services (as is already the case for mobile emergency calls in many European countries) can, however, be considered.

032 number range

On the issue of the assignment of numbers to providers of VoIP-based services, Kurth announced that, on 24 Nov 2004, a statement will appear in the Amtsblatt of the Reg-TP with regard to the use of non-geographic (032) numbers. From this date on, it will be possible to request numbers in this number range for VoIP purposes.

There will be a one month sunrise period in which all requesting parties will be treated as having requested their numbers simultaneously, with a lottery system for the assignment of numbers requested by multiple parties. After the one month sunrise period, numbers will be assigned on a first-come first-served basis.

In Jan 2005, the 032 numbers will become effectively available.

Geographic numbers for VoIP

With regard to the availability of geographic numbers, Kurth made it very clear that Reg-TP does not wish to, and did not wish to in the past, impede or prohibit the use of geographic numbers. This of course refers to an earlier decision of the Reg-TP on which we reported previously. In this decision Reg-TP explicitly banned operators from using geographic numbers outside the scope of the geographic boundary they were originally intended for (i.e. a number of companies were using Hamburg numbers in other parts of Germany).

Kurth said that the Reg-TP’s decision to institute this ban was based on the fact that today, for all intents and purposes, numbers do have a geographic significance and it would only make sense to detach the numbers from their geographic location if this connection would not be meaningful to the population anymore. In the follow-up to the regulators' debate, in the afternoon session of the forum, Freenet explained that the reason why Freenet had used numbers outside of the defined number area was driven by a desire to be economical with numbers, and not utilise only a fraction of number blocks.

This point was addressed by Kurth who stated that this problem is a legitimate one, but that it could be solved by allowing the assignment of smaller number blocks, and that there would then be no need to use geographic numbers belonging to one number zone in another number zone.  There are technical issues for Deutsche Telekom and for Reg-TP to be solved in order to make it possible to assign smaller number blocks; this is a matter that will be addressed at a later stage.

Reg-TP has now temporarily severed the obligatory link between the physical access point and the attribution of numbers: numbers can be assigned on the basis of the residence of an end-user or the legal residence of a company. This means that the Reg-TP will allow a geographic number to be attributed to a physical network termination point, even if that network termination point is outside the corresponding number zone, if the address given by the residential user or the company address stated by the business user is within that given number zone. This is however still a temporary measure and the position is still under review.

The most interesting statement by President Kurth in this matter was that the assignment of geographic numbers for nomadic services is not seen as a problem by Reg-TP so far. This, for all intents and purposes, is the same as having a telephone transferred to another location, according to Kurth. Kurth underlined that there may be issues regarding emergency services and the transmission of location data in this context, but that this should be seen as a separate issue from numbering. A priori Kurth does not see a numbering issue with regard to the assignment of geographic numbers to nomadic services.

An Eckpunkte papier (policy paper) will be presented by the Reg-TP on this matter as soon as possible.


The third and last aspect addressed by Kurth concerns the issue of unbundling. The concept of "unbundling" in this context is unrelated to the concept of the unbundled local loop. What is meant is the access to a wholesale product which separates the xDSL access from the voice service provided over that same access line.

A large number of interested parties have expressed their need for a wholesale product which does not require the end-user to have a PSTN/ISDN subscription from Deutsche Telekom.

Kurth responded to this issue by saying that Reg-TP first needs to analyse Market 12 (wholesale broadband access - this will happen at the beginning of 2005), and only then can a discussion take place on the issue and the possibility for “unbundling.” Kurth did in this context state that “It can however already be said that it is a misconception that the end user will see his access cost drop, the costs will certainly be allocated to the DSL access. There will be no cheap wholesale variant.”

For a discussion of other points addressed in the Reg-TP forum, please contact Alexa Veller.