The Commerce Commission and Internet NZ are united in opposing the Telecommunications Carriers Forum’s (TCF) bid to ensure New Zealand numbers can only be distributed to paid-up TCF members.
The TCF has put out for discussion a draft code in which it proposes it assumes overall governance of the numbering plan (see earlier Telecommunications Review article Changes to NZ numbers won’t force 2degrees’ hand), although the scheme itself would be administered by a new body that would replace the existing Number Administration Deed (NAD).
The controversial part of this draft code is that anyone seeking numbers must become a paid-up member of the TCF.
Under TCF rules it’s the telcos who pay the largest fees that effectively get the biggest say. The TCF Board is comprised of an independent chair and six representatives – one each from Vodafone, Telecom and TelstraClear, a representative of Tier 2 telcos and a representative of Tier 2 and 3 telcos. There is also a non-voting role for a body representing consumers which is occupied by TUANZ.
There are five submissions to the draft numbering code posted on the TCF website; all are broadly supportive of number management remaining in the private sector. However both the Commerce Commission and Internet NZ (the latter drawing on its experience administering the .nz domain names) take issue with compulsory TCF membership for those seeking +64 numbers.
“While the Commission has stated on many occasions that the TCF plays a very important role in the New Zealand regulatory landscape, it does not agree that parties who hold or require number allocations should be compelled to join the TCF,” reads the Commerce Commission’s submission.
Internet NZ calls for an independent management structure and says the neither the TCF Board nor its officers should have a role the governance or disputes process.
“Whilst the TCF is clearly a professional organisation with an independent chair it is still fundamentally owned and controlled by a subset of one segment of the telecommunications market (some Telecommunication Service Providers),” reads the Internet NZ.
TUANZ on the other hand supports to move to TCF governance, as a way of guarding against NZ numbers becoming “an easy source of cheap numbers” especially given the increasing prevalence of international VoIP operators. “We recognise that this is potentially a controversial element of the proposal,” its submission reads. “However, in our view the requirement is entirely reasonable. New Zealand is very unusual in not requiring every carrier to apply to the government for a carrier license, a process that involves a substantial fee far in excess of the annual subscription payable to the TCF.Further, the diversity of membership of the TCF has grown to the point that capture by a vested interest is very unlikely.”
TUANZ also makes a bid for its organisation to be the user representative, citing its long involvement in numbering governance.
The other submissions are from TelstraClear and Vodafone who also support the proposed governance structure, although Vodafone’s submission notes “all NAD members are not currently TCF members and, whilst it makes sense to encourage them to become TCF members, some hesitations can be voiced, especially in relation to the cost of joining the TCF.”