Comreg have a useful Idea. 076 Numbers to be allocated for VoiP use.

spongebob

Consultation is Here . €ircon will no doubt object vehemently ......always a sign that Comreg may be doing something right.

Nevertheless there is still scope for Comreg to **** everything up like they usuallly do , maybe by handing a million numbers over to porn dialler scammers 'by accident'

Responses to this very promising consultation must be in by 30/07/04 and should be a mandatory exercise for all WISP or GBS groups. Remember that Personal numbers were a non runner in Ireland because Comreg allowed Eircom to margin squeeze them to death at the outset.

1. by email to oonagh.oreilly@comreg.ie

2. or online through this form Here which works .

Comreg should allocate some of these numbers as Personal Voip numbers and some as Network based ones and some as pseudo geographic to provide alternative pricing models to compete, they have 9,999,999 of them to play around with for 4 million people after all .

Here are the questions...out of context unless you read the doc itself .

Q. 1. Do you agree with ComReg that geographic numbers could be allocated for VoIP
purposes in specific cases (see also Q21)?
Q. 2. Do you agree that if geographic numbers are made available for VoIP use (See
Q1), they should follow the same rules as for PSTN (i.e. only one number per ‘line’ or
termination point, allocated from the MNA in which the customer is based)? .......
Q. 3. If geographic numbers are made available for VoIP use, would you consider that this should be limited to VoIP services that qualify under the current definition of PATS (i.e. have the rights and corresponding obligations - as far as those can be applied - of PATS)? 16
Q. 4. Do you agree with ComReg that Personal numbers could be allocated for VoIP
purposes in very specific cases (e.g. where justification can be provided for allocating a number to a natural person using an IP connection)? ..
Q. 5. Do you agree with ComReg that other non-geographic numbers and mobile
numbers should not be allocated for VoIP purposes – at least at this point in time?.....
Q. 6. Do you agree that a new number range should be opened for VoIP services?...... 16
Q. 7. If so, do you agree that this new range should be the 076 range? If not the 076 range, which range do you think would be more appropriate? ......
Q. 8. Do you agree that the number length should be 3+7 digits long? If not, please
suggest your alternative. Please explain your answers giving practical examples of how you see the numbers being used where appropriate (e.g. assigned to terminals, persons,
gateways ................. 16
Q. 9. Do you consider that ComReg should support ENUM using a distinctive number
range (which could be a sub-set of a range designated for VoIP, or a separate range with its own access code)?
Q. 10. Do you prefer designation of the first digit(s) of the VoIP subscriber number to
achieve this (i.e. the digits immediately following the VoIP access code), or the allocation
of a separate access code (e.g. 079)? Note: your answer to this may be a reflection of
how large you anticipate the (medium term) growth of demand to be for ENUM numbers.
18
Numbering for VoIP services
45 ComReg 04/72
Q. 11. Do you support the broad principle that end-users who wish to avail of this ENUM
number range should be obliged to “opt-in” to the ENUM protocol, and would lose the
number if subsequently opting out?........................................................................................................ 18
Please explain your responses with practical examples where feasible.................................... 18
Q. 12. Do you consider that ComReg should allow or support the differentiation of
different VoIP service types using distinctive number ranges? .................................................... 19
Please explain your response with practical examples where feasible...................................... 19
Q. 13. Do you agree with the opinion that the selection of a number range to facilitate
the provision of VoIP services should not be predicated on the quality of those services?
If you disagree, please give your opinion as to why it should be based on voice quality. 19
Q. 14. If not by number range, how can consumers be best informed about the
expected quality of service? ....................................................................................................................... 19
Q. 15. ComReg invites comments on the Number Portability (NP) issues. a) Do you
agree that NP should be required between PSTN and VoIP operators for geographic
numbers? Please comment on your answer. b) Do you agree that NP should not be
required between PSTN and VoIP operators for personal numbers (if these are permitted
to be used for VoIP purposes), in view of the existing complexity of personal numbers
even without taking inter-technology issues into account? c) If existing number ranges
(e.g. geographic or personal numbers) are allowed for use with VoIP services, do you
agree that NP should be required between different (but compatible) VoIP operators? d)
If (a) new number range(s) are designated specifically for VoIP and/or other new
technologies, do you consider that NP should be required for these between different (but
compatible) operators of such services, either from the outset or at a later more mature
stage of the market? Please explain your views on these NP issues as succinctly as
possible. ............................................................................................................................................................ 21
Q. 16. Do you anticipate any undue difficulties in respect of commercial negotiations
between operators (whether existing or new market entries) in respect of the
development of tariffs for new VoIP services, whether based on existing or new number
ranges? If so, please explain and if possible suggest your solutions to these...................... 22
Q. 17. If yes, what broad criteria should be applied to these tariffs?...................................... 22
Q. 18. Specifically, would you agree with ComReg’s proposal that the maximum retail
tariff for calls from PSTN to VoIP destinations in Ireland (i.e. where the PSTN/VoIP
gateway or the final destination is in Ireland) should not exceed national rate for the
originating PSTN network? Please comment on this and on the corresponding situation where any VoIP network that may be subject to regulation originates such a call, where the termination may be on a) PSTN or b) IP. If you feel national rate is excessive for
VoIP, would you alternatively consider that local rate is a practical alternative maximum amount to set down?........
Q. 19. Alternatively, is there merit in allowing totally free market competition to set the
retail tariff without any number-related indication for customer transparency of the
maximum permitted retail prices? If ‘yes’, is it also your view that commercial
negotiations can generally be concluded sufficiently quickly without such a retail ‘starting
point’? 22
Q. 20. Do you agree that the wholesale settlement and retention arrangements that
would apply to any usage of existing number ranges for VoIP purposes should follow
existing PSTN arrangements, or do you consider that VoIP represents a special case
which would necessitate changes? Please explain your views in the latter case. ................. 25
Q. 21. Do you agree that retail, settlement and retention principles that would apply to any new VoIP non-geographic number range could be quickly determined based on Numbering for VoIP services existing arrangements for other non-geographic services (and not taking account of the
special case of Premium Rate services)? Please explain your views, with suggestions if appropriate. ..
Q. 22. Respondents are invited to comment on the above section 4.9, dealing with
interconnection: Do you agree with ComReg’s position on the VoIP interconnection
issues of opening of number ranges, call termination and call origination? If not, please comment..........................
Q. 23. Do you agree with ComReg’s view that unless the unaltered status of CLI on
VOIP services can be guaranteed with a very high degree of certainty, it should either come with a ‘health warning’ to this effect, or else not be displayed – and in any case should be ‘Unavailable’ for PSTN purposes? Please comment on this topic, which has potential importance for billing, data security and privacy, emergency services, fraud prevention and customer service levels. ..............................................
Q. 24. Do you agree with ComReg’s view that in principle VoIP origination is
incompatible with CPS, while PSTN origination to VoIP numbers can follow principles
already established for other non-geographic numbers?................................................................
Q. 25. ComReg invites responses from interested parties on the topic of Directory
Enquiry entries for VoIP users availing of public telephone numbers. a) Should a listing in a publicly available directory be available to all subscribers to these VoIP services? b)Should this directory be linked to the National Directory Database (NDD), if separate?...
Q. 26. ComReg calls for comments regarding these terms and conditions. Do you feel
that these are appropriate to the proposed use of numbers for VoIP services? Are there any conditions of use that are unnecessary or (conversely) omitted from this set?

raeGten

Yeah, Yeah, Yeah....that's fine, whatever....I just want a VOIP connection that other landlines can dial in to....How long is itgoing to take them to sort that out??

oscarBravo

Originally posted by raeGten
Yeah, Yeah, Yeah....that's fine, whatever....I just want a VOIP connection that other landlines can dial in to....How long is itgoing to take them to sort that out??

You may "just want" it, but I want it done properly. I'll be responding to the consultation.

spongebob

Originally posted by raeGten
I just want a VOIP connection that other landlines can dial in to....How long is itgoing to take them to sort that out??

If you ask for it nicely I'd say that Comreg could have it all sorted by November/December (this year ) or so ......but you must ask nicely .

They are awaiting responses to consultation all this month as I explained , on holidays in August, responding to the responses to the consultation in September/October , consulting on their interpreted responses to this consultation in October/November ......etc. etc.

M

Urban Weigl

What about number portability? I want to move my existing 094 numbers over to a VoIP provider for example, which I could do in the US. As a business, it would also be good to have an 01 number.

oscarBravo

Originally posted by Urban Weigl
What about number portability? I want to move my existing 094 numbers over to a VoIP provider for example, which I could do in the US. As a business, it would also be good to have an 01 number.

Looking at the consultation document, they are talking about the possibility of geographical number portability - but only within the geographical area. In other words, providers offering 094 numbers would have to be satisfied that the subscribers were in the 094 area. You can't move an 01 number to an 094 area at the moment, so it's unlikely to be allowed with VoIP.

The burning question remains: how is this to be enforced? Hence the consultation.

spongebob

My opinion is that they should allocate the 076 range thus . Once 074 and 071 have been retired (they are the only ones still in use) and mapped onto 09n numbers instead there will be stacks of numbering capacity to play around with .

076

0761 > 01 Dublin (General Licencees and WISPs and Voip Carriers)
0762 > 02 Cork (General Licencees and WISPs and Voip Carriers)
0763 > Personal (Completely portable to all WISPs and Voip Carriers/Enum )
0764 > 04 Nth and Ctrl Leinster (General Licencees and WISPs and Voip Carriers)
0765 > 05 SE and S Leinster (General Licencees and WISPs and Voip Carriers)
0766 > 06 Midwest (General Licencees and WISPs and Voip Carriers)
0767 > Personal (Completely portable to all WISPs and Voip Carriers/Enum)
0768 > (WISPs and Voip Carriers Only )
0769 > 09 The Wesht (everybody in de house say ahhh ahhh)
0760 > (WISPs and Voip Carriers Only )

Then , Comreg should introduce 5 digit short dial codes from mobiles beginning with 7 as the numbers above will have 10 digits and a Mobile can only store 20 digits per destination on a sim. a Short dial is allocated to the target PSTN/VoIP gateways that convert the calls to VoIP .

M

Urban Weigl

Originally posted by oscarBravo
The burning question remains: how is this to be enforced? Hence the consultation.

I think the burning question is actually: why should it be enforced? If a business wants a phone number in Dublin at the moment, for example, they can already set up forwarding. The only difference is that people would no longer need to pay Eircom for such a service.

oscarBravo

Originally posted by Urban Weigl
I think the burning question is actually: why should it be enforced? If a business wants a phone number in Dublin at the moment, for example, they can already set up forwarding. The only difference is that people would no longer need to pay Eircom for such a service.

It's a good point, and one I had thought of - I had a number forwarding from another area code for some time myself. But geographical numbering seems to be a core regulatory concept for Comreg, and I think it will take more than a VoIP consultation to change that.

spongebob

There is enough address space to allow both pseudo geographic and non geographic numbering in the first phase of 07n allocations . By the time the 10 million numbers (076 and 7 digits) are used up we have problems of success

Having no numbers is the biggest problem of all.

M

spongebob

Bump. Meant to bump yesterday but the site was down

Answers over the weekend would probably be acceptable if dated today ....mail servers can be very odd.

M

damien

Muck wrote:

Answers over the weekend would probably be acceptable if dated today ....mail servers can be very odd.

I've found Comreg quite good with giving you a slight extension when you want to reply to a consultation.