The German regulatory authority Reg-TP has today issued a draft of a set of so-called 'Eckpunkte' (cornerstones of regulatory policy) for providers of VoIP-enabled services, specifically with regard to numbering issues. These are the subject of a public consultation.
In addition, from today (15 Nov 2004) onward, all providers that offer access to the public telephone network (irrespective of whether they control the access network or not, and including providers of nomadic VoIP-enabled services) can obtain geographic number ranges by applying for them with Reg-TP. This is a pragmatic interim leniency measure introduced by Reg-TP.
T-REGS Note: Previously, geographic numbers were only available to operators controlling the access network; this has now been changed, but the change is clearly expressed as being temporary and subject to future review.
Providers are entitled to assign geographic numbers to end-users in a particular geographic numbering area, based on a private individual's residence address or based upon the address of a company's registered office (i.e. it is still possible to give out-of-area numbers to certain company establishments, branches, etc. and to teleworkers).
This possibility to request geographic number ranges is subject to the obligation of number portability, which, under §46 of the German Telecommunications Act, is applicable to all providers of public electronic communications services (i.e. not only providers of Publicly Available Telephone Services - PATS).
One of the issues put to public consultation is Reg-TP's proposal to allocate number ranges in blocks of 100 numbers instead of 1000 numbers. For technical reasons, this will not be possible in the short term. Reg-TP expects that it will take 9 months from the entry into force of the new policy for operators to make the necessary technical changes.
Reg-TP is also considering implementing a quota system for geographic numbers, in order to prevent scarcity. Circuit-switched and packet-switched services should, according to the Reg-TP 'Eckpunkte', have equal opportunity to obtain a certain quota of geographic numbers, but conservation measures may be necessary, for instance a form of control on the amount of geographic numbers that can be assigned per end-user.
Until a final policy on numbering for VoIP-enabled services is determined, Reg-TP asks all parties to abstain from implementing geographic numbers outside the scope of the relevant numbering zone. End-users that have obtained geographic numbers outside the relevant numbering zone in the past will have to be migrated to a “conform” number within a leniency period granted until 1 Aug 2005. However, companies will still be able to use, for example, Berlin numbers in Bonn, for branch offices, etc. This is considered to fall within the scope of a “networked telecommunications system” in which case numbers can be implemented outside the numbering zones.
A public discussion on all the above matters will be held on 30 Nov 2004 (10:00h), at the Regulierungsbehörde für Telekommunikation und Post’s address (Tulpenfeld 4, D-53113 Bonn, room 0.01). Interested parties should register for this discussion before 26 Nov 2004.
Interested parties are also invited to contribute to the discussion in writing. The deadline for written submissions is 15 Dec 2004.