UKCTA comments to .tel application
Title: UKCTA comments to .tel application
Established on 1 July 2003, UK Competitive Telecommunications Association is a trade association promoting the interests of fixed-line telecommunications companies competing in the United Kingdom, in the residential and business markets. Its role is to develop and promote the interests of its members to Ofcom, the new communications regulator, and the UK Government.
UKCTA's primary objective is to ensure the UK communications market becomes genuinely competitive, an environment that maximises investment and innovation by all competitors. Through effective representation on issues that promote competition, UKCTA aims to ensure that consumers will continue to enjoy the full benefits of competition in voice and data services.
More information about UKCTA can be found at www.ukcta.com.
UKCTA members provide Voice over IP services, and have strategies in place to migrate existing legacy networks to IP infrastructures. Many of our members subscribe to the newsletters provided by Pulver.com.
ENUM-like technologies can be categorised into three main areas;
1) The main “user-ENUM” tree whereby individual customers choose to insert their E.164 telephone numbers into DNS. Work has been ongoing at the ITU, IETF and in a series of national fora to make this implementation under the .e164.arpa domain a reality, and commercial implementations are now starting to emerge.
2) Enterprise level ENUM-like technologies, whereby companies can use ENUM to insert their telephone numbers in a locally-controlled domain.
3) A specific case of enterprise level ENUM, specifically aimed at IP-based telecommunications providers. In this situation, telecommunications providers migrating their existing customers to IP-based infrastructures could load their numbers into ENUM, together with the associated SIP addresses. Similarly new entrants offering services on IP-based infrastructures could populate the records for their customers. This would allow voice calls to be completed via IP on an end-to-end basis, rather than potentially routeing via legacy circuit-switched style networks. This is sometimes termed “operator ENUM” or “Infrastructure ENUM”.
The Pulver.com application appears to focus on the third of these areas, but builds in elements of (1) and (2) via references to incorporating enterprise IP-PBX numbers. We would query whether any requirement for capabilities around “user-ENUM” should be channelled via the internationally accepted e164.arpa implementation, rather than creating a parallel version.
UKCTA members are broadly supportive of the concept of “operator-ENUM”, and feel this is something that we would wish to make use of in the future. In particular, it has been identified as a key enabler to providing number portability in next generation networks.
Communications providers have already started to implement enterprise level implementations of ENUM within their networks (ie where the “enterprise” is all the customers of a given communications provider). Indeed, our members have spoken with companies such as NetNumber regarding the provision of such systems. It is likely that in due course this “bottom-up” approach will provide an impetus for a “top-down” initiative to link together these enterprise-level systems so that communications providers can mutually share the relevant information.
However, UKCTA members feel strongly that such a “top-down” initiative should be driven by an impartial internationally recognised agency rather than a private, potentially profit making, company. We believe that an appropriate body to control this all-important root should be the ITU, or potentially a standards agency such as ETSI.
Our concerns about control being vested in a private company predominately centre around governance concerns. At the most basic, our members are concerned that there must be adequate safeguards to ensure that numbers assigned via regulatory agencies (in our case Ofcom) are not entered into the .tel implementation without either our, or our customers’, consent. We note that the applicants commit to putting such processes in place, but ultimately they are based in a location beyond the jurisdiction of the applicable UK regulatory controls, so we can have no guarantees that this will be done.
We have similar concerns on issues of Data Protection. We are governed by strict laws to protect our customers’ data : a company based outside the reach of EU or UK legislation may or may not choose to implement policies that are consistent with these legal requirements.
Assuming a critical mass of communications providers populate numbers into the domain, then the controller of the domain manifestly will be in a position of critical importance in the continued operation of the telecommunications networks. As UK operators, we would be unhappy with any situation where at least the primary servers handling the UK numbers were located anywhere other than in the UK. Once again, with the application as it stands, we have no guarantees of exerting control over this.
It is worthy of note that telecommunications network infrastructure plays an important role in government communications : we would be surprised if governments were happy that control of a domain which determines how their telephony calls are routed would be vested in an overseas-based private company.
If the alternative approach of using a body such as the ITU were to be followed, then stakeholders would have the opportunity to influence the manner in which the .tel implementation was structured, both from a governance and technology perspective. For example, the process adopted for .e164.arpa is that national governments must consent to numbers associated with their country codes being entered into the ENUM domain, and this provides the potential for them to exert whatever level of regulatory control they feel appropriate.
Of course, it could be argued that the concerns we are raising more point to the potential for success or failure of the Pulver implementation of .tel, rather than presenting a barrier to the Top Level Domain being awarded in the first place. The argument would be that if players are dis-satisfied with the technology implementation or the rules around inserting numbers, they simply won’t make use of the capability. However, we would disagree;
a) Even if our members choose not to put their numbers into the .tel implementation, the uncertainty of the governance process means that third parties may seek (and succeed) to enter our numbers.
b) The fact that the .tel application is granted will arguably confer some legitimacy to the implementation, allowing it to be positioned as an “ICANN-endorsed” ENUM implementation : this could distort the market.
To summarise, UKCTA members are not opposed to the general principles of the operator-ENUM implementation as outlined in the Pulver/NetNumber application. However, we feel strongly that it would be inappropriate to award such a TLD to a private company, and that any implementation should be controlled by an established agency with stakeholder engagement, e.g. the ITU.
For these reasons, we feel that the application should be rejected at this time.
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