".tel" versus "e164.arpa"
Competition At Risk
Two competing visions are being advanced within
the Internet community for providing a top-level domain to address a critical addressing
challenge for the emerging IP-Communications industry.
The Pulver/Peek/Marschel ".tel" TLD application described in this document is the
outgrowth of a three year intellectual property, technology development and standards
body effort initiated by the NetNumber.com team back in early 1997. Note: the
Pulver/Peek/Marschel ".tel" application is one of three ".tel" TLD applications currently
under review by ICANN.
"e164.arpa" Implementation: As an alternative
to the ICANN TLD process, the IETF's ENUM working group lead by co-chair Richard
Shockey of NeuStar Communications is working with the International Telecommunications
Union (ITU) to establish the sub-domain "e164.arpa" as a pseudo TLD for registering
telephone numbers on the Internet.
The goal of both ".tel" and "e164.arpa"
is to provide an ENUM compliant (RFC 2916) top-level domain supporting a globally
distributed directory solution that enables end-users to register their phone numbers
on the Internet and associate those phone numbers with a list of IP-enabled communications
services and devices: (IP-telephony, IP-fax, e-mail, PDA, Mobile SMS, etc.)
Beyond this common vision, there are critical differences between these two implementations
that have long-term implications for the deployment of IP-Communications services
on a global basis. This document seeks to crystallize the core differences
between the two models and recommends a solution for allowing market forces and the
Internet Community to determine the superior approach.
The key difference
between ".tel" and "e164.arpa" focuses on control over the ENUM services registration
1. Under the ".tel" implementation, the international non-profit "Internet-Telephony
Addressing Board" (www.i-tab.org) defines policies for the TLD guaranteeing open
and free competition for the provisioning of ENUM services on a global basis.
2. Under "e164.arpa", control over the ENUM registration process is delegated
to the 240+ national regulatory agencies that currently administer the PSTN on a
country-by-country basis. Under this model the key question for the Internet
"Will the 240+ national PSTN regulatory agencies that are being
given control over the ENUM registration process under the "e164.arpa" model set
policies that advance the best interests of the emerging IP-Communications industry?"
believe the answer is clear: Distribution of control of "e164.arpa" to 240+
PSTN regulatory agencies will tend to maximize the best interests of the world's
incumbent PTT's at the expense of the emerging IP-Communications industry.
Concern For Emerging IP-Communications Industry
(a) Under the "e164.arpa" model,
national PSTN regulatory agencies are placed in a position to grant incumbent PTT's
exclusive control over the provisioning of ENUM services for the telephone numbers
that fall under their control.
- A recent Internet-Draft
presented to the ENUM working group clearly articulates this as a viable implementation
scenario under e164.arpa.
(b) Incumbent PTT's can be expected to use the power
that may be granted to them under the "e164.arpa" model to control, protect and limit
the provisioning of ENUM services by ISP's, ASP's, and other emerging IP-Communications
service providers. As a result:
- New IP-Communications
entrants are likely to encounter roadblocks in registering ENUM addresses for services
that compete with incumbent PTT's around the world. This should be no surprise
to anyone. Given power, any company will act in its best interest to limit
- Incumbent PTT's with exclusive control
of ENUM services will have an incentive to set prices high enough to discourage competition
from emerging IP-Communications providers that will need access to the "e164.arpa"
ENUM services. (i.e.: Unified messaging ASP's, IP-Telephony ASP's, etc.)
is the ".tel" proposal for addressing these concerns about "e164.arpa"?
Give the Internet community the ability to decide between ".tel" and
"e164.arpa" after fully exploring the tradeoffs of the two implementations.
How can this outcome be achieved? If ICANN takes this opportunity to award
a ".tel" TLD, then the Internet community will be put in a position to determine
which solution best meets the industry's long-term interests. If ICANN misses
this opportunity to approve one of the three pending ".tel" applications, then control
over global ENUM services will be distributed to 240+ national PSTN regulatory bodies
without the benefit of appropriate public review of the decision.
is an issue-by-issue summary of the competing visions:
".tel": IETF-ENUM compliant.
".tel": Derives authority from ICANN
Derives authority from ITU
Policy Control &
".tel": ICANN and ITAB define policies on
a global basis ensuring end-user control over ENUM registration.
"e164.arpa" 240+ PSTN regulatory bodies set policies on a country-by-country
focused on meeting the needs of the emerging IP-Communications industry.
"e164.arpa": Mixes the competing interests of PTT's and the IP-Communications
open and fair competition for ENUM registration services on a global basis.
"e164.arpa": Allows each national PSTN regulatory body to determine
if competition will be supported.
Incumbent PTT's Role:
Guarantees that incumbent PTT's can choose to provide ENUM services without blocking
"e164.arpa": Allows PSTN regulatory
bodies to award exclusive ENUM registration rights to incumbent PTT's.
".tel": Guarantees end-user control over registration
of ENUM services.
"e164.arpa": Allows each national regulatory
body to decide if choice will be supported.
Internet community benefits:
Regardless of which implementation wins in the end, the best interests of the
Internet community will be served by allowing the issues to be evaluated by the market
over a reasonable period of time. If ICANN approves one of the three pending
".tel" applications then the opportunity will exist for an open and fair review of
the merits of each solution. If ICANN does not select one of the ".tel" applications
for a new TLD then "e164.arpa" will proceed without debate. No decision by
ICANN at this time is in effect a final decision to select "e164.arpa" before the
issue can be reviewed in a public forum.
- Let the
ICANN TLD definition process work.
- Let competition and the market process work.
The Internet community will be the winner.