Comreg wishes to cripple VoIP

Sponge Bob

No number portability proposal, what kind of joke it this ??

While the initial VoIP regulation philosophy was to my mind one of the few proposals that reflected favourably on Comreg as a regulator , their 'mid life review does not. It is so weak that they should not have bothered.

Give us clean clear number portability or nothing.

read the proposals here and wonder (as did I) why they bothered with this at this time ??? ....apart from assuaging their new Aussie mates maybe

Objections may be registered online here

probe

Sponge Bob wrote:

No number portability proposal, what kind of joke it this ??

While the initial VoIP regulation philosophy was to my mind one of the few proposals that reflected favourably on Comreg as a regulator , their 'mid life review does not. It is so weak that they should not have bothered.

Give us clean clear number portability or nothing.

read the proposals here and wonder (as did I) why they bothered with this at this time ??? ....apart from assuaging their new Aussie mates maybe

Objections may be registered online here

Comreg are no different to their previous guise when they were called the “ODTR”. They came out of Telecom Eireann and they are there to protect the rebranded eircom in the same fashion. They are all in the ancient Dept of P&T bloodline with the post office! Over time, every phone subscriber will wake up to VoIP with its significant cost savings over eircom PSTN and ISDN call charges, and most will want to retain their existing geographic numbering space when the move to VoIP. While 076 is convenient to allow people to experiment with VoIP it is not really usable for widespread adoption – particularly for business subscribers who will wish to retain their existing numbering plan – including DDI.

Comreg have kept Skype out of the market by requiring that they set up a place of business in Ireland before they can sell Irish numbers to their customers. Intelligently run countries such as Sweden, Denmark, Finland, Estonia – and even otherwise dumb ones such as Britain and the USA, have no restrictions on Skype using their numbering space.

Comreg have been either grossly incompetent in loop unbundling or they are again just playing to eircom whose highest in the world line “rental” and expensive broadband rates – combined with the implied threat that if you want to move broadband suppliers you may find yourself without BB for a month or more has strangled the market.

If unbundling worked efficiently as it does in, say, France, Babcock & Brown would have no interest in buying eircom’s shares – because eircom in their current mode would be losing customers as fast as France Telecom (ie about 20,000 per week) to competitors who provide triple play 24 Mbits/sec broadband and VoIP phone from as little as EUR 19.99 per month. The take-over value remaining in eircom is a function of rip-off Ireland’s appalling regulatory system.

If you go to the eircom BB line checker and enter your number, it tells you that it is either available or more often not available in the case of lines outside the main cities. If they wanted a punter to get broadband, they would ask you perhaps for an e-mail address so that they could measure the interest in an area and contact you when the product became available. EIRCOM DON’T WANT YOU TO GET BROADBAND. EIRCOM DON’T WANT YOU TO GET VOIP. And Comreg appear to be happy to back them up by making life difficult for people at their end of things – VoIP numbering, allowing porting delays etc.

probe

Sponge Bob

Ths most objectionable bit is their bald claim that number portability in Ireland , as it is now, works as per the USO directive ...which sez it must work. This is codswallop and as long as Comreg refuse to accept this then it never will because they are starting off from the wrong asumption anyway.

The key issue of who the number belongs to (me or at worst Comreg I would say and not Eircom) is never addressed.

Other crap in there is that they recognise port blocking as an issue but not traffic shaping which can cause as much grief as port blocking.

Then there is the issue of the unused 03 range which is where all voIP should have been from day one, not in the 07 band at all .

cgarvey

Sponge Bob wrote:

The key issue of who the number belongs to (me or at worst Comreg I would say and not Eircom) is never addressed.

Exactly. Even though eircom do have line numbers, they claim to use a phone number to identify a line. That is a non-unique, non-static number that doesn't belong to them. Is that anyone other than eircom's fault/problem? Not in my book, so let them deal with it. Claims that portability works now are laughable.

Sponge Bob

cgarvey wrote:

Claims that portability works now are laughable.

Then they follow that by saying , in effect, that if a VoIp operator REALLY wants number portability to them they must reclassify their operation as a PATS operation not an ECS operation (as at present) and accept the large and currently unquantifiable cost stack that goes with that .

Blaster99

I can't say I know what PATS or ECS is, but it seems to me that it's fair that everybody should be classified the same or eircom would be at a competitive disadvantage.

dubadubdub

Blaster99 wrote:

I can't say I know what PATS or ECS is, but it seems to me that it's fair that everybody should be classified the same or eircom would be at a competitive disadvantage.

There's a first time for everything I suppose!

Sponge Bob

Blaster99 wrote:

I can't say I know what PATS or ECS is

There is a glossary at the end of the consultation document that I kindly linked above. Should you require a further explanation you could always ask for one

Blaster99

So the only mandatory service, apart from the telephony, is the provision of an emergency service. I presume eircom gets paid for that service? Either way, it can be outsourced to any ol' service provider or run by the civil service.

Another problem as such with VoIP is that the providers don't seem to offer a directory service, i.e I can't get a phone directory listing. The whole thing should be structured in such in a way that I get the same service no matter who my phone provider is and number porting should work between all operators and it should be fast. Not this 4-8 weeks plus secret handshakes and numbers can only be ported to/from eircom crap that goes on now.

Sponge Bob

Blaster99 wrote:

So the only mandatory service, apart from the telephony, is the provision of an emergency service.

Exactly.

There are 4 side issues which needed to be resolved before this consultation was even attempted.

1. Should number portability work from each to every licenced operator. I would say the answer is yes with the sole proviso that you must have been the 'owner' of the number for a year. After that you may choose to move it. This principle of owned numbers works uncontroversially in Mobile Number Portability already why should it be different with geos

2. Should the system to which a port is made be a PATS not an ECS I say NO. As long as the port is made in the full foreknowledge of the limitations of the system then there should be no issue. While it may have been of importance once I would point out that if I need to dial 112 I can always use my mobile if I need to. I do not depend exclusively on a VoIp as I would depend on my landline back in in 1983 . Regulations should reflect that.

3. Should Irish numbers (VoIP or Otherwise) be available to a telco outside the state, such as Skype. Yes except for 15nn numbers.

4. Is the 03 range to be made available for VoIP instead of shoehorning it into 07 along with Donegal and Sligo. I say YES and concentrate on completing the now stalled migration of Geos away from 07 into 09 and release 07 back to usage in 3 or 4 years. In the interim nothing is on the hroizon AND needing numbers, except VoIP which should be given 03

None of the above have been addressed , and should be IMO as a prerequisite, so this consultation veers beween irrelevant and downright dangerous and with no long term clarity to the stakeholders or a resolution save to Eircom who can still bugger us around with what really should be our numbers not an operators numbers .

I am on record as praising Comreg for their regulation 101 some years back. I fear that regulation 201 is a disgraceful , weak and counterproductive step and should be withdrawn in its entireity right now.

Blaster99

What happens when I dial 999 from a mobile? Do I get to a service run by my MNO or do I get to eircom's service? It seems a centralised service accessible from all phones is the way to go.

Are you planning to respond to ComReg's consultation? If not, I might base IOFFL's response on your comments, seeing as you know what you're talking about...

I'm not sure the whole 076 thing is a big deal, at least not in the short term. Nobody really wants a non-geo number I would have thought.

Sponge Bob

When you dial 999 from a mobile you get into eircoms service, the one they say cost them €7m a year and that they do not want to run any more because its their €7m . Its the one single eircom moan where I actually agree with McRedmond ....who is chief moaner in this case.

That 112 system is a separate issue again.

I understand that our Nice Liberal and Fluffy Minister McDowell has taken it off Comreg . A 112/999 service is part of the security infrastructure of the state after all .

aaronc

Sponge Bob wrote:

Exactly.

There are 4 side issues which needed to be resolved before this consultation was even attempted.

1. Should number portability work from each to every licenced operator. I would say the answer is yes with the sole proviso that you must have been the 'owner' of the number for a year. After that you may choose to move it. This principle of owned numbers works uncontroversially in Mobile Number Portability already why should it be different with geos

Isn't that the case now? Every ECS operator can effectively port numbers. As to the phrase "number portability work" it does but ... (and here a book could be written although simply copying the Mobile porting process would be better)

Sponge Bob wrote:

2. Should the system to which a port is made be a PATS not an ECS I say NO. As long as the port is made in the full foreknowledge of the limitations of the system then there should be no issue. While it may have been of importance once I would point out that if I need to dial 112 I can always use my mobile if I need to. I do not depend exclusively on a VoIp as I would depend on my landline back in in 1983 . Regulations should reflect that.

That's also currently the case and as far as I'm aware, as soon as the number is allocated to you by a provider for any length of time you can port it to whoever will take it.

Sponge Bob wrote:

3. Should Irish numbers (VoIP or Otherwise) be available to a telco outside the state, such as Skype. Yes except for 15nn numbers.

There probably does need to be some way to keep track of who is dishing out the numbers and it's not very onerous to become an ECS, it's a two page application form. I don't think the reason stopping Skype offering Irish numbers is regulatory, there's not much difference in that regard between Ireland and the UK.

Aaron

Sponge Bob

aaronc wrote:

Isn't that the case now? Every ECS operator can effectively port numbers. As to the phrase "number portability work" it does but ... (and here a book could be written although simply copying the Mobile porting process would be better)

But no aaron. Portability to ECS operators is not allowed which is why if I wish to port a number today from eircom to blueface it must go 'via' a certain route into which I will not dwell save to say that Comreg are perfectly aware of this 'via' route and allude to it in that consultation doc. It seems to have 'come to their notice' from some angle.

There is no number portability to or from an ECS operator, as such, at present. Nor will there be.

This doc proposes forcing an ECS to go PATS to get portability , this is in itself a highly complex issue but is overkill as things stand today. Nor will VoIp ever develop properly in the absence of a clear numbering and portability strategy which is enforceable by Comreg .

probe

Sponge Bob wrote:

4. Is the 03 range to be made available for VoIP instead of shoehorning it into 07 along with Donegal and Sligo. I say YES and concentrate on completing the now stalled migration of Geos away from 07 into 09 and release 07 back to usage in 3 or 4 years. In the interim nothing is on the hroizon AND needing numbers, except VoIP which should be given 03

03 is reserved for general expansion and rationalisation of the national numbering plan AFAIR. (One route might be to use 03 for the 01 area and get rid of area codes completely as several European countries have done (eg Spain, Denmark, Norway, and Portugal)

Possible scenario using “03” numbering space

01 234 5678
becomes 312 345 678

021 234 5678
becomes 212 345 678

056 234 5678
becomes 562 345 678

087 234 5678
becomes 872 345 678

1 800 234 567
becomes 800 234 567

VoIP is just a different transport/switching methodology to PSTN or ISDN. Like the change from crossbar electromechanical exchanges to digital or changing from PSTN to ISDN. They didn’t set up a new NDC for people connected to digital exchanges when they first appeared. And now everybody is connected to a digital exchange. At some stage most if not all telephone traffic will be processed by VoIP.

While a separate optional NDC is useful (eg 076) while people experiment with VoIP, as the technology matures and more people receive good quality (ie reliable) broadband into their homes the option of porting one's PSTN or ISDN geographic number to VoIP may well be come the default choice – particularly for business subscribers.

Comreg seem to be obsessed with the fear that having a Killarney 064 geographic number for VoIP may become fashionable all over China! They don’t seem to appreciate that punters will have to pay a monthly service fee if they want a VoIP service with a geographic number in a particular town. This guarantees that only those with some connection with the place will be taking up geographic numbering space.


probe

Sponge Bob

probe wrote:

03 is reserved for general expansion and rationalisation of the national numbering plan AFAIR.

I knew about that national renumbering argument years ago but bringing Dublin alone out to 8 digits (and the rest to 7) after the area code will sort the matter out .

Currently the dubs have a mangy 10M numbers to play with , 8 digits would bring them to 100m or 100 numbers for everyone in the city. Sure they even could go all multicultural in Comreg and give Chinatown the 5619 and 8888 area codes ....not that Feng Shui principles should dictate our area codes but that Feng Shui is probably more intelligent than Comreg is , normally

Release the 3 now !!!

aaronc

Sponge Bob wrote:

But no aaron. Portability to ECS operators is not allowed which is why if I wish to port a number today from eircom to blueface it must go 'via' a certain route into which I will not dwell save to say that Comreg are perfectly aware of this 'via' route and allude to it in that consultation doc. It seems to have 'come to their notice' from some angle.

There is no number portability to or from an ECS operator, as such, at present. Nor will there be.

This doc proposes forcing an ECS to go PATS to get portability , this is in itself a highly complex issue but is overkill as things stand today. Nor will VoIp ever develop properly in the absence of a clear numbering and portability strategy which is enforceable by Comreg .

Page 20. from the afore mentioned doc:

Following the decision to allow allocation of geographic and non-geographic numbers to ECS service providers, ComReg decided that as a condition of allocation, those service providers are required to support number portability. This is currently achieved using existing processes.

So if ECS providers are required to support number portability it would also be assumed/hoped that they have the right to it.

As far as I can see with porting out of the equation this would then leave the differential between a PATS and an ECS as:

- Right to uninterrupted guarantee to emergency services (that's kind of tough for anyone to guarantee especially given the amount of building going on but in the context of internet vs PSTN there is no doubt user expectation from the PSTN World cannot yet be met with public VoIP systems),
- Right to directory service listings and enquiries,
- Right to CallerId,
- Rigth to a certain level of quality of service.

An ECS may or may not be able to provide the above services whereas a PATS must. When a user is choosing a service they will know where they stand if a provider states they are a PATS. If the provider does not claim to be a PATS and is therefore an ECS they will need to review further.

Going back to the original point on porting as far as I'm aware it can be taken as a given that any provider, ECS or PATS, allocating Geo or Non-Geo (where non-Geo doesn't include 076) numbers supports porting.

Aaron

Blaster99

So have you porting agreements with all other ECS's and PATS's?

aaronc

Blaster99 wrote:

So have you porting agreements with all other ECS's and PATS's?

Since you've seen the other posts on porting in these forums I'm pretty sure that's a rhetorical question.

You'll only find one company that can even come close to answering yes.

Aaron

Blaster99

aaronc wrote:

Going back to the original point on porting as far as I'm aware it can be taken as a given that any provider, ECS or PATS, allocating Geo or Non-Geo (where non-Geo doesn't include 076) numbers supports porting.

I took this to mean that porting works across the board (which would have been news to me), but perhaps you meant that porting works with the one operator.

I'm working myself up to a response to ComReg so I wanted to make sure I hadn't missed something fundamental...

Sponge Bob

Blaster99 wrote:

I took this to mean that porting works across the board (which would have been news to me), but perhaps you meant that porting works with the one operator.

Can ECS operators actually get allocations of geographic numbers in their own right at this moment in time and can an example be provided by anyone ?

and yes Aaron I had noticed this section of page the doc but may I quote it back to you with my emphasis overlaid

Following the decision to allow allocation of geographic and non-geographic numbers to ECS service providers, ComReg decided that as a condition of allocation, those service providers are required to support number portability. This is currently achieved using existing processes.

and we all know how well these "existing processes" work ......but you neglected to post the 2 previous paragraphs on page 20 which change everything !

Number portability is a fundamental right of the user. According to the Universal Service Directive, “number portability is a key facilitator of consumer choice and effective competition in a competitive telecommunications environment”. Its availability in general is likely to drive the uptake of VoIP services, and therefore increase competition in the Irish telecommunications market.

Thats very fine except that only once carrier is a USO carrier , Eircom , and that the USO in practise is not enforced by Comreg despite their grandiose sweep of verbosity in that paragraph. I'm sure Number Portability is a right just like ....Functional Internet Access from the same Directive as scrupulously applied by Comreg.

And the next para

With respect to the obligation to offer number portability, it is both an obligation and a right between those service providers offering PATS services, regardless of which technology they use to deliver those services.

And so Eircom are not obliged to port numbers to an ECS operator only to a PATS operator and there is no existing process . Importantly a geographic number porting agreement, while in situ for an ECS if that ECS applies for and gets a Geo numbering range , does not come with a reciprocal oblication for Eircom to ACCEPT A PORT from that ECS operator as they are

1. Not a PATS operator

and

2. The number will not be accepted by eircoms billing system , nor will eircoms system allow such a number to be used on a line datafill.

so

3. Is it really portable ???

and

4. Will this consultation change that.????

NO!

Nor will the market support a forced migration to PATS compliant systems for ECS operators given the cost stack.

aaronc

Blaster99 wrote:

I took this to mean that porting works across the board (which would have been news to me), but perhaps you meant that porting works with the one operator.

I'm working myself up to a response to ComReg so I wanted to make sure I hadn't missed something fundamental...

No it means that there is probably always a way you can port a number from a to b although at the moment that will most often be through c (Eircom). The thing that concerns people most is that they don't lose their number and the point of the original statement is that to my knowledge any provider that allocates a Geo or non-Geo number can also have that number ported from them, however, I could be wrong.

Aaron

Sponge Bob

I am sure that an ECS operator would comply with the regulation but will Eircom , I very much doubt it ??

Blaster99

I am willing to bet an eaten hat that eircom will not facilitate porting of numbers through them when there's no landline involved. I suppose we should stay nice and friendly here, but eircom's present porting arrangements don't really instill me with a lot of confidence, let's put it that way.

Sponge Bob

which is why this consultation is dangerous and debilitating and disingenous .

1. Nothing proper is being done on portability, Comreg pretend it works well or else they are in breach of the 2003 EU USO directive , yet again .

2. Nothing proper is being done on national numbering and providing sufficient numbers under a light regulatory system to allow ECS diversity, the 03 range would be perfect .....but no! From ECS diversity some PATS VoIP carriers may come forth ..in time but that step is too early now.

3. The risk of being designated with SMP and being therefore obliged to provide PATS is implicit in this new regulation when it was not before .

While an expensive trip to ECAP will see Comreg off (as usual) this will have the side effect of keeping global operators out of Ireland .....never mind the fact that they cannot get numbers at present.

What the market actually needs is clean clear portability and ownership of numbers , no PATS obligation at present and lots and lots of number blocks for service diversity .

None are on offer. This document is simply designed to make Comreg look good when they stand up spouting irrelevant crap about how great they are at some interminable Euro Jolly later this year in Vienna (or maybe Madeira in October ) to bore the other Euro Jolliers about how farsighted they are.

It is not supposed to produce anything of worth and threatens the opposite. In a dysfunctional market the dysfunctional regulator is king and gets to go to lots of jollies rather than do anything of worth

GAHHHHHHHHHH!!!!!!!!!!

Sponge Bob

last 3 days to tell Comreg what YOU think of their scheming and scamming

http://www.comreg.ie/publications/respond.asp?nid=102314