RD290 - ETNO Reflection Document in response to ECC/ CEPT consultation on Fixed-Mobile Convergence with Survey of Numbering Related Issues

ETNO has considered the arguments being raised in the ECC/ CEPT consultation on Fixed-Mobile Convergence with Survey of Numbering Related Issues and has substantial concerns on certain issues presented in this report. These relate to the characteristics of the FMC services suggested in the report, regulatory issues relevant to Interconnection and in particular voice termination and the interpretation of the concept of technological neutrality under the EU framework, as well as conclusions on CLI presentation, emergency call handling and number portability.

ETNO has considered the arguments being raised in the ECC/ CEPT consultation on Fixed-Mobile Convergence with Survey of Numbering Related Issues and has substantial concerns on certain issues presented in this report. These relate to the characteristics of the FMC services suggested in the report, regulatory issues relevant to Interconnection and in particular voice termination and the interpretation of the concept of technological neutrality under the EU framework, as well as conclusions on CLI presentation, emergency call handling and number portability. ETNO calls for an in-depth review of the CEPT Report on Fixed-Mobile Convergence.

ETNO has concerns on a number of issues raised in this report:

  • The FMC services suggested in this report are not in line with the ITU recommendation definition provided for NGN networks. Moreover the analysis of FMC services should take into consideration that both fixed and mobile operators will provide such services.
  • The conclusions on the regulatory issues of Interconnection in general and voice termination in particular, do not reflect the complexity of the issues, while a number of the statements made are either contestable or still under debate.
  • The statement that there is a problem with cost based termination because it is “not technologically neutral because costs relate to technology” seems to misinterpret the concept of technological neutrality under the EU framework.
  • The conclusions on CLI presentation, ETNO suggests that for the “so called” limited FMC services discussed in this report, normal CLI rules should apply, i.e. geographic CLI from geographic location service, mobile CLI from a mobile service. This is more accurate and reasonable approach regarding the CLI provided to emergency centres, so that call in takers, when technically feasible, will be able to call back and access the caller in need.
  • Finally regarding number portability between geographic and mobile numbers, this option cannot be successfully introduced as long as retail tariffs and wholesale interconnection agreements do not make such an option commercially viable or would mean that customers would not be able to determine the cost of a call from the number dialled.

Based on the above the numbering options presented and the conclusions made on the provision of FMC services, in the CEPT Report on Fixed-Mobile Convergence with Survey of Numbering Related Issues, should be revisited.