Who should control New Zealand numbers?
For many years Telecom thought it owned New Zealand’s numbers, a claim it only relinquished in July 2009. Telecom’s position was in line with most incumbent telcos around the world who assumed ownership of the numbering plan when governments sold off their telecommunication networks. But from the 1990s, number administration began to change and responsibility shifted from the incumbent telco to the regulator.
In New Zealand, however, it moved to the industry in the form of the Numbering Administration Deed (NAD) which, according to a description on its website, is "a multilateral agreement, which establishes a governance body (the Management Committee) to oversee number administration".
There are 14 members of the NAD, each paying a $10,000 membership fee. They must be New Zealand citizens and intend to offer PSTN services in New Zealand within 12 months of being allocated numbers.
During its 11-year history it’s fair to say the NAD has not covered itself in glory. It was primarily set up to deliver number portability but after five years, progress was so slow that the government moved the responsibility over to the TCF, which achieved portability on April 1st 2007.
The idea was floated about a TCF/NAD merger and a working party was set up in 2008, at the behest of the Commerce Commission. In late 2009 it released a draft code which suggested that a new body be set up called the Numbering Management Group, and that this be governed by the TCF Board. Furthermore, anyone wanting to belong to the new Group had to become a member of the TCF.
The requirement to be a TCF member in order to obtain New Zealand numbers was strongly opposed by the Commission and InternetNZ in their submissions to the Code. However TUANZ supported the move, claiming that the fee to belong to the TCF (not more than $5000 per annum for non-Tier One telcos) was reasonable considering that carriers don’t have apply for a licence fee to operate in New Zealand and membership in the TCF ensures a kind of collective responsibility for the way the industry functions.
It isn’t just about the money. The TCF is controlled by the Tier One telcos who pay the bulk of its funding – Telecom funds 40%, TelstraClear and Vodafone each pay 25% and the rest make up the balance (10%). In recognition of this, Tier One telcos each get a seat at the board table, there is a seat for a Tier Two representative, a seat for a Tier Two and Three representative and a seat for a non-voting user representative, TUANZ.
Meanwhile, significant telcos such as 2degrees and TeamTalk are refusing to join the TCF on principle. But as they already have large number blocks allocated to them – 2degrees has all the numbers in the 022 number range and TeamTalk has two million numbers – they don’t need to.
The Commission’s submission also blasts the TCF working party for choosing to address governance issues over Numbering Rules, all of which appears to have left TCF CEO David Stone rather perplexed. In reply to TR’s question about whether the Commission’s view is a fair one, he wrote:
"The suggestion that TCF membership be a necessary precondition for future number allocation seemed like a good idea at the time. The reality is that if there is substantial opposition from the Commission (as there is), then that provision will be removed. The issue of governance is separate and is rather more difficult to resolve. As TCF CEO, the only position I can contemplate is that any TCF entity has to be subject ultimately to the TCF Board; anything else is bad governance. If we don’t move the NAD under the TCF then I personally am not sure what governance changes the Commissioner really wants."
So who should control the numbers – the carriers, the government, the regulator? Or should they be managed by an independent agency in the same way that InternetNZ manages the .nz domain names? (Internet NZ collects $6.5 million and, after taking care of the domain name administration, uses the money to fund advocacy work.)
And are any of these organisations capable of managing New Zealand numbers during the transition from the PSTN world to the IP world?
The numbering plan is a national resource, but is there a danger that the rules to preserve it could become too rigid and end up protecting traditional telcos at the expense of innovative VoIP providers?
That’s a concern held by Cameron Beattie, founder of Conversant – an Auckland-based company providing virtual phone systems that enable SMEs to enjoy the benefits of a PABX without having to buy the hardware. Conversant also sells numbers in other countries. For example, if a business in Wellington wants to sell its services in the US, it can rent a US number from Conversant. It works the other way too; Conversant sells New Zealand numbers to overseas businesses.
"We’re not a telco, we’re not part of the NAD, but we have relationships with telcos here and get numbers off them. For example if you’re a recruitment company in Australia; they want a New Zealand number so people who are wanting to move to Western Australia can dial a local number and it’s a free local calling number; they don’t pay anything to receive the call, they just pay for the number per month," says Beattie.
Conversant gets its numbers from 2Talk, which in turn gets its numbers from CallPlus.
TRasked Stone whether this was in line withcurrent rules. "At present the NAD rules contain requirements that parties with numbers ensure that they are portable to the extent that regulation requires them to be portable. If you sell your numbers, then you can no longer ensure their portability and you are in breach of the NAD rules. This is a NAD matter and outside the scope of the TCF."
TR referred the query onto the NAD but didn’t receive a reply by the time this magazine went to print.
Then there is the vexed issue of fixed line portability – if you port a 09 number when you move to Wellington, then those who call it won’t be aware they could be charged for making a national toll call. Even worse, the emergency services won’t have an accurate location attached to the number.
But dividing the country into local calling areas is a construct that dates back to the old Post Office days, before the internet and the idea of VoIP was even conceived. So is it time to go back to basics with number allocation?
Here’s Beattie’s view: "It’s a philosophy I guess: who’s at the centre – the customer or the telco? I would argue that the customer should be put at the centre, the customer should be in control of the number and the technical details should be worked out around that, rather than the technical details determining how it works."