Telephone numbering-Future directions - ACMA

Telephone numbering-Future directions - ACMA
Telephone numbering—
Future directions

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Executive summary                                                        1

1.      Background                                                       7
1.1     The numbering work program                                       7
1.2     Pressures                                                        7
1.3     Assumptions                                                      9

2.      How telephone numbers are specified                            10
2.1     General purpose numbers                                        11
2.1.1   Geographic numbers                                              12
2.1.2   Mobile numbers                                                  15
2.1.3   Location independent communications service (LICS) numbers      17
2.1.4   Satellite numbers                                               19
2.2     Business and information numbers                               20
2.2.1   Freephone and local rate numbers                                20
2.2.2   Premium numbers                                                 21
2.2.3   Directory assistance and information services on shared numbers 22
2.3     Limited use numbers                                            26
2.4     Access codes                                                   28

3.      How the Numbering Plan is structured                           29

4.      Number management and charging                                 32
4.1     Institutional arrangements for allocation                      32
4.2     Allocation mechanisms                                          33
4.3     Scarcity of numbers                                            36
4.4     Charging for numbers                                           36
4.5     Managing numbers                                               38

5.      Supporting future flexibility                                  42
5.1     Location information and security and safety                   43
5.1.1   Future of the IPND                                              44
5.2     Switching communications providers                             45
5.3     Future monitoring                                              46

6.      Making a submission                                            47
6.1     Effective consultation                                         47
6.2     Publication of submissions                                     47
6.2     Release of submissions where authorised or required by law     47

Appendix 1                                                             48

                                                                 acma | iii
Executive summary

Historically, the regulation of numbers through the Telecommunications Numbering
Plan 1997 (the Numbering Plan) predominately reflects the physical elements of the
legacy network architecture. The existing arrangements have facilitated a range of
policy outcomes and underpinned the structure of addressing used by the
telecommunications network. The Numbering Plan has also codified many of the
operational measures that the telecommunications industry has needed to help it
manage public communications networks.

Fundamental change is now occurring in the networks and technologies delivering
communications services. The pace of change is expected to accelerate in the
foreseeable future, not least as a consequence of the rollout of the National
Broadband Network (NBN) and a range of next generation network (NGN)
technologies currently being deployed by network operators. The dimensions of these
changes in technologies, markets and behaviours are expected to have a profound
effect on how Australians use communications, the benefits that are derived from
communications and the measures that realise those benefits across the Australian
economy and society.

Today, the basket of transmission technologies collectively described as ‗internet
protocol‘ (IP) are increasingly pervasive. Increasingly the regulation of telephone
numbers based on the predominance of voice services in communications is strained
or broken. Substitute forms of electronic addressing and the growth in digital/IP
services are progressively supplementing the significance of voice services in

Through its numbering work program, the ACMA has explored the impact of these
changes on telephone numbering and sought feedback on appropriate responses to
them. The numbering work program has tested the role that regulation of numbers
plays in this changing environment. During this work, the ACMA considered the many
representations it received about numbering over recent years from consumer groups,
government agencies, existing industry participants, new players in the
communications market and potential new entrants to that market.

Through the work program, the ACMA has formed a view that the current
arrangements are under significant pressure as a result of change in technology (both
at the device and network level), commercial arrangements and consumer behaviour.
Major changes in service delivery and charging are expected to continue. Against this
backdrop, the ACMA has confronted a stark choice in considering how the existing
regulatory framework might accommodate change, namely whether to:
> pre-emptively undertake substantial transformation of the regulatory arrangements
  (perhaps, arguably, radical transformation); or
> develop an approach that aims to provide a more managed evolutionary path for

  On 29 August 2011, the ACMA released Broken concepts—The Australian communications legislative
landscape, a research paper that examines how the process of convergence has systematically broken or
significantly strained many of the legislative concepts that form the building blocks of current communication
and media regulation.

                                                                                                  acma | 1
Respondents to the consultation conducted by the ACMA as part of the numbering
work program had mixed views about the scale and scope of any variation to current
numbering arrangements. The case for pre-emptive change (that is, substantial
transformation) was supported by some newer carriage service providers (CSPs) and
internet service providers (ISPs). More established providers observed that, given the
ongoing change underway in the broader communications environment, significant
changes in regulatory arrangements would be undesirable and increase uncertainty at
this time. The ACMA also conducted research among residential and small- and
medium-sized business consumers to assess how they are now using
communications services, the information they use from telephone numbers and how
that information helps them to manage their communications services.

The ACMA has formed a view that an actively managed evolutionary path is the more
desirable approach to minimise the short-term adjustment costs to industry,
information costs to consumers and any unintended consequences from changes to
the regulatory settings—and therefore achieves the best balance. However, the
ACMA‘s view is that the Numbering Plan will need to be actively managed over the
short, medium and longer term.

The ACMA developed a set of principles to guide the continuing evolution of
numbering regulation, which was widely accepted by respondents. These principles
guided the consideration of the present—as well as any future and transitional—
regulatory frameworks for numbering, including the allocation methodologies and
institutional arrangements. The four principles for the regulatory and administrative
framework for numbering are:
> efficiency, so that it leads to the continued supply of communications services in
  accordance with the public interest, at least cost, even as preferences change and
  technologies develop over time
> flexibility, so that it is able to evolve over time and respond to the changing needs
  of the communications environment
> resilience, so that it stands the test of time
> simplicity and transparency, so that it facilitates consumers making informed
  choices about their use of communications services.

As a key component of that framework, the Numbering Plan has been subjected to
considerable scrutiny throughout the numbering work program. It is generally regarded
as a cumbersome legislative artefact that has the potential to unnecessarily raise
information costs for industry and—to the extent that it is unnecessarily complex and
prescriptive—raise barriers to innovation. To assist with the evolution of the
Numbering Plan, the ACMA has developed the following design principles:
> broad-based use of numbers, so that the use of numbers is not unduly restricted
  by the Numbering Plan
> technical neutrality, so that the specification of numbers based on the technical
  characteristics of the service or the platform over which it is provided is minimised
  in the Numbering Plan
> price transparency, so that where it is necessary to use numbering to facilitate
  end users recognising the costs of calls, this is supported by the structure of the
  Numbering Plan
> clarity, so that the structure of the Numbering Plan is simple and capable of being
  readily understood.

These principles will inform future work. As the first step, on 11 October 2011, the
ACMA announced that it would commence consultation on a package of short-term
measures intended to improve flexibility and remove redundant provisions and unused
number ranges. As part of this package of near-term measures, the ACMA also

2 |   acma
commenced further consultation about changes to charging arrangements for
freephone and local rate numbers. This package of near-term measures is available
on the ACMA website.

This future directions paper sets out the ACMA‘s vision for medium to longer term
changes to the Numbering Plan, consistent with the principles for the regulatory
framework. It also indicates what specific actions could be taken and identifies when
these could occur or, alternatively, what might be the triggers for change.

The ACMA‘s broad vision for how the regulation of numbers might evolve is depicted
in Figure 1. It shows the transformation of numbering regulation from the current
arrangements that are technology- and service-specific, complex and rigid to
arrangements that allow the flexible use of telephone numbers in the long term beyond
2020. The medium term shows an increasingly broad-based use of numbers,
improved price transparency and clarity.

                                                                              acma | 3
Figure 1 The evolution pathway for numbering arrangements

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There are key points on the evolutionary path described above. Applying the above
principles to specific issues identified in the numbering work program has led the
ACMA to the following future directions:
1. Rationalise number ranges over which like services are provided (where they are
   currently separated only because of technical characteristics of service delivery) to
   allow for the broad-based use of numbers and improve technical neutrality in the
   structure of number ranges.
2. Remove redundant number ranges and return unused numbers to the pool for
   reallocation to improve efficiency in the use of numbers.
3. To the extent that numbers continue to be used to provide price signals — these
   should be clear and consistent.
4. Work towards a Numbering Plan that reflects key objectives, principles and
   legislative requirements, with a staged migration of procedural rules to codes and
5. Simplify and clarify the Numbering Plan to minimise the costs associated with the
   management of numbers.
6. Provide for an enhanced service provider role in the allocation and administration
   of numbers, but with adequate governance and appropriately managed risk.
7. Minimise potential distortions in the charging arrangements for numbers.
8. Maintain an evaluation and monitoring role in relation to the changing environment
   for numbering regulation, so that changes can be made as new issues emerge, in
   the expectation that change will continue for the foreseeable future.

The application of these future directions to specific matters raised in the numbering
work program, which the ACMA regards as medium- to long-term issues, are identified
in detail in the paper, along with supporting actions and indicative time frames for
change. These actions are summarised at Appendix 1.

In conducting the numbering work program, the ACMA has also identified some
matters for which change will be more gradual and/or may be contingent on particular
triggering events. For example, the future of the Integrated Public Number Database
(IPND), which is currently subject to government review, falls outside the scope of the
future directions set in this paper. Over time, the existing IPND arrangements can be
expected to be challenged by new networks and commercial models. Similarly,
regulation of untimed local call arrangements might be expected to decline in
significance as more and more fixed-rate national call offerings become available—
pricing on the basis of data rather than time is expected to become increasingly
prevalent. More broadly, the future use of numbers specified in the Numbering Plan
can be expected to be increasingly challenged by alternative electronic addressing
schemes, which might require quite different responses from government, industry and

Figure 2 shows how the individual actions proposed in this paper sit within the broader
context of communications. The individual actions are depicted below the timeline
arrow, while changes anticipated in the wider communications landscape are depicted
above the arrow.

The ACMA‘s approach to these more contingent future possibilities is to continue to
observe change and evaluate the need for intervention as required. The ACMA has
appreciated the high level of engagement on numbering experienced through the
numbering work program and will continue to work with stakeholders to achieve
optimal interventions.

                                                                              acma | 5
Figure 2 Summary of proposed actions in an environmental context

6 |   acma
1. Background
1.1     The numbering work program
During 2010 and 2011, the ACMA examined a wide range of issues related to the
regulatory framework for telephone numbers. This was in response to:
> issues raised by consumers and industry through the ACMA‘s Numbering Advisory
> pressures as a consequence of technical innovation, innovation in services and
  business models, and changes in consumer behaviour, many of which have been
  raised during consultations by the ACMA about numbering and related matters
> difficulties faced by industry participants in achieving compliance with current
  numbering obligations, or the undesirable consequences of achieving compliance
> the complexity of present numbering arrangements.

The aim of the numbering work program was to identify what, if any, changes are
needed to the current telephone numbering arrangements to enable it to be a flexible,
efficient and effective framework for the future communications environment. The
numbering work program was not concerned with the use of numbering, naming and
addressing in all IP communication networks and services, and specifically is not
concerned with the arrangements for electronic addresses or application-specific

Four consultation papers were released:
1. Structure of Australia’s telephone numbering plan (October 2010) examined the
   pressures on the structure of phone numbers, including the cost of calls from
   mobile phones to freephone and local rate numbers (which are commonly used by
   organisations to provide crisis help lines).
2. Customer location information and numbering data (January 2011) examined the
   derivation of customer, service provider and location information from numbers,
   especially by emergency services organisations, and how the objectives of these
   users may be met in an evolving and converging communications market.
3. Allocation and charging of numbers (March 2011) examined the administration of
   numbering and associated institutional and charging arrangements.
4. Implications of research into consumer issues (May 2011) examined the use of
   information in numbers by end users, including for assessing the cost of calls,
   identifying callers and identifying the location of a called party.

Anyone who wishes to explore the issues raised here in more detail are encouraged to
refer to these papers and the submissions received in response to them, which are
available on the ACMA website.

1.2     Pressures
The current regulatory arrangements for telephone numbers have their antecedents in
the operational rules established by the government provider of telecommunications in
the 1960s. During the 1990s, modifications were made to the arrangements to
accommodate competition in supply, but these also reflected the technologies and
supply models of that time. Today, these arrangements are under pressure from
changes in network and device technology, business models, charging arrangements,
and user expectations and behaviour. In some cases, these changes have made the
regulation of telephone numbers redundant. In other instances, information intended to
provide transparency to consumers has failed to do so when consumer behaviour has
changed or where this information was not understood in the first place.

                                                                             acma | 7
There have been significant changes in the kinds of services available to residential
and business users, and in how these services can be used. For example, the framing
of current regulatory arrangements pre-date the widespread availability of the internet
and the growth of packetised transmission technologies, which are now fundamental
to delivering telephony as well as other communications services. In many respects,
the existing regulation imposes rules for an analog world on a digital one. One effect of
the fundamental shift in transmission technologies is a decline in the significance of
telephone numbers to route calls. This decline is expected to accelerate as existing
network technologies are replaced by next generation network—or IP-based—
technology in both fixed and mobile networks.

The telephony choices available to users have also changed significantly over the last
20 years. Use of digital mobile services has grown strongly and VoIP services are
being adopted more broadly. While the number of mobile services in Australia
                                                                     3                  4
continues to grow (from 23.4 million in 2009 to 25.99 million in 2010 ), fixed services
(which use geographic numbers) are in a slow decline in number (from 10.67 million in
2009 to 10.59 million in 2010). . However, a majority (77 per cent) of Australians
continue to have both a mobile and a home phone in their household.

The ACMA‘s research indicates that consumer attitudes to these services have also
changed. Today, the home phone is not as important to most people—mobile phones
are now regarded as the main communication service for nearly half of all Australians
(47 per cent compared to 34 per cent for landlines).

Changes in the available retail packages and bundles have also been significant. In
2010, two out of five Australians had a plan, cap or deal for their home phone, while
more than half of Australians (55 per cent) bundled two or more services together.

A key effect of these changes, together with changes in consumer expectations and
behaviour, appears to be decreasing consumer visibility of, and sensitivity to, the price
and location information embedded in telephone numbers. A substantial proportion of
Australians (34 per cent) now no longer pays attention to individual landline call costs.
Younger Australians (18–24 years) are less likely to know whether a local call from a
landline is timed (50 per cent compared with 73 per cent for the rest of the

Collectively, these pressures reflect a fundamental shift in the environment within
which numbers are used to provide communications services. It is in the interests of
end users and service providers that the regulatory arrangements supporting the
provision of communications services do not pose an unnecessary impediment to
ongoing change and innovation.

  A packetised transmission technology breaks up a piece of communication into small individual packets of
data and sends them using the most efficient route at the time of transmission. This means that the various
packets of communication may travel over many different routes before being reassembled. Unlike circuit-
switched calls, packet-switched calls do not require a dedicated circuit and therefore use network resources
much more efficiently.
  ACMA, Communications report 2009–10, p. 34.
  A service may relate to multiple phones.
   ACMA, Communications report 2009–10, p. 30.
  ACMA, Implications of research into consumer issues, p. 14, footnote 12.
  ibid, p. 14, footnote 11.
  ibid, p. 21, footnote 29.
  ibid, p. 23, footnote 32
   ACMA, Community research into consumer behaviours and attitudes towards telecommunications
numbering and associated issues, p. 54.

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1.3         Assumptions
In developing future directions for telephone numbering, the ACMA has relied on a set
of underlying assumptions. The ACMA‘s first consultation paper issued as part of the
numbering work program—Structure of Australia’s telephone numbering plan—set out
the key assumptions that would be used to guide the work program and to provide
some indication of the scale and scope of anticipated changes. In summary, these
assumptions were:
> the ongoing need for numbers—that there is likely to be a continuing role for
  telephone numbers for the foreseeable future
> changes to numbers—the ACMA does not anticipate a need to increase the
  overall supply of numbers by increasing the length or otherwise changing numbers
  at any time in the foreseeable future
> internet names and addresses, and application-specific identifiers—the
  transition to alternative identifiers in the long term was outside the scope of this
  work program. These identifiers are expected to complement rather than replace
  telephone numbers in the short to medium term and so will not have a material
  effect on the numbering arrangements during this time. The ACMA will continue to
  observe this evolution and evaluate any need for intervention as required.
> globalisation of communication—the need for international collaboration and
  coordination of numbering, naming and addressing schemes will become
  increasingly important in managing the limitations of national jurisdictions, and
  achieving policy goals of security, safety, competition and consumer protection
> no changes are anticipated to:
      >       the government‘s broad communication policy goals of consumer protection,
              competition, security and safety including the untimed local call
      >       emergency numbers or arrangements for the use of private numbers
      >       the role of the ACMA and Australian Competition and Consumer
              Commission (ACCC) in regulating the telecommunications industry.

     See pp 16–19 of Structure of Australia’s telephone numbering plan.

                                                                                 acma | 9
2. How telephone numbers are
                                                Future directions
       1      Rationalise number ranges over which like services are provided (where they are currently
              separated only because of technical characteristics of service delivery) to allow for the broad-
              based use of numbers and improve technical neutrality in the structure of number ranges.
       2      Remove redundant number ranges and return unused numbers to the pool for reallocation to
              improve efficiency in the use of numbers.
       3      To the extent that numbers continue to be used to provide price signals—these should be clear
              and consistent.

The ACMA‘s first consultation paper, Structure of Australia’s telephone numbering
plan, identified that changes in both network and device technology and consumer
behaviour are blurring the boundaries between the general purpose services types, for
providers and consumers. It also identified that, in some cases, the technological
descriptions and distinctions included in the service descriptions and their rules for use
may be:
> restricting the flexible use of numbers
> preventing efficient use of the number resource by industry
> confusing for consumers and not meeting their service or information needs.

The ACMA considers that numbering arrangements should minimise the use of
technology descriptions and distinctions in the specification of numbers and the rules
for their use to the greatest extent possible—as they restrict both the flexible and
efficient use of numbers.

This section examines a migration path for the current specification of more than 40
service types in the Numbering Plan to a technology-neutral plan with as few as four
service types. It looks at specific areas within each service type where technology
descriptions and distinctions and rules are restricting the flexible use of numbers by
industry and consumers.

This section has been divided into the following parts:
> general purpose numbers—those numbers most commonly used by residential
  and retail consumers including geographic, mobile, satellite and location
  independent communication service (LICS) numbers
> business and information numbers—includes freephone, local rate and premium
  numbers, and directory assistance and information services provided on shared
> limited use numbers
> access codes.

The following subsections describe changes to individual number ranges in some
detail. These changes recognise the continued role that numbers play in providing
information to consumers about the distinctions between the costs of calls. This
underlying observation will guide change over the foreseeable future, but it is an
observation that should itself be tested in five years.

10 |   acma
Figure 3 How numbers are specified

2.1     General purpose numbers
General purpose numbers are the telephone numbers most commonly used for
residential and retail services. They include geographic, mobile, satellite and location
independent communication service (LICS) numbers. Historically, general purpose
numbers were specified by technology type because they were provided using
different network technology. The Numbering Plan provided each network technology
with a separate number range and specific rules about their use.

                                                                               acma | 11
2.1.1     Geographic numbers
The particular form of geographic numbers in the Numbering Plan largely reflects, and
locked in, the historical switching structure and hierarchy of Telecom Australia and its
predecessors prior to 1991. It provides little flexibility. The untimed local call obligation
was also a significant driver of the structure of the Numbering Plan. This is because
numbering was convenient for suppliers to use in meeting the obligation, and for
consumers in understanding which calls were likely to be untimed local calls (charged
at a fixed rate regardless of the length of the call). This is perhaps the largest single
contributor to the size and complexity of the current Numbering Plan.

However, numbering is not the only strategy available for CSPs to meet the untimed
local call obligation. One alternative is for providers to geographically encode customer
locations in their billing systems and use that information to ascertain whether or not
an individual call is eligible. Another, possibly easier and already increasingly
prevalent, method is to have a charging option that provides untimed calls for all local
calls as part of overall packages (or ‗plans‘). Many VoIP providers already have
charging arrangements in which national calls (to geographic numbers) are untimed.

The ACMA‘s consumer research suggests that these kinds of charging arrangements
are already widely prevalent and popular. It may be that in the not too distant future
they become the dominant method for the purchase of communications services,
including fixed telephony. It is possible to envisage circumstances in which telephony
call costs are entirely covered by a payment of a fixed fee or bundled with other

Some respondents, including iiNet and Internode, felt that untimed local calls were a
‗legacy requirement‘ and should be removed. Vodafone Hutchinson Australia (VHA)
felt a ‗simpler charge model could apply to all calls between geographic numbers‘ and
could provide more certainty ‗especially (so) in an NBN environment‘. However, Skype
noted that some countries (including France) have successfully implemented
wholesale-level obligations, which Skype suggested has delivered results superior to
direct legal or regulatory intervention at the retail level. Current arrangements limit the
changes that can be made to geographic numbers and may affect how CSPs choose
to offer retail service packages on the NBN.

Under these circumstances, the ACMA questions whether the Numbering Plan is the
best way to support the untimed local call obligation in the medium term. The provision
of an untimed local call option by CSPs is a requirement under the
Telecommunications (Consumer Protection and Service Standards) Act 1999 (TCPSS

   Part 4 of the Telecommunications (Consumer Protection and Service Standards) Act 1999 requires CSPs
to offer customers using a standard telephone service (other than a mobile or satellite service) the option of
an untimed charge for any call between two points for which, prior to 1997, the call would have been
charged at an untimed rate.
   For example, Internode‘s standard call rate for local and national calls to a fixed line anywhere in Australia
is 18c per call untimed.

12 |   acma
Additionally, although the numbering arrangements for geographic numbers do not
specifically restrict the technology with which services can be provided, the current
arrangements have placed restrictions on the flexible use of the numbers. For
example, the location rules mean that Australians are mostly unable to take their home
telephone number with them when they move house, despite three in five (61 per
cent) indicating that they would like to do so.

Working within the parameters of the legislative obligations set out under the TCPSS
Act, Structure of Australia’s telephone numbering plan explored what, if any, changes
could be made to increase the flexibility and efficiency of geographic numbers. The
> identified that removing sector boundaries in capital cities could improve efficiency
  without impacting a CSP‘s ability to meet its obligations under the TCPSS Act and
  asked if there were any disadvantages to this option
> asked what information conveyed by geographic numbers is of value
> asked when geographic numbers could be converted to flexible general purpose
  numbers and what strategy should be used to for transition
> asked what would be required to guarantee transparency of call costs.

> Removal of sector boundaries was broadly supported except by the market
   research industry, which uses this information as one of the many factors in sample
> Some respondents found location information associated with telephone numbers
  important for charging and emergency services. However, newer entrants no
  longer used location for charging, and instead provided national calling.
> The Communications Law Centre noted that in the long term:
          … the geographic significance of such numbers will be unimportant. The reasons for
          the diminution of geographic significance are related to separated network and service
          provision, as well as customers‘ nomadicity.
> Symbio Networks noted that:
          … in the not too distant future, all general purpose numbers including landlines as well
          as mobiles will not be location dependent at all. By then geographic numbers will be
          pretty meaningless and consumers will not associate a general purpose number with a
          fixed location. The distinction in the Numbering Plan related to nomadicity by then will
          not be relevant in the context of general purpose numbers.
> Most respondents noted that there would be a variety of benefits to customers in
  allowing location portability. Some noted that there would be some disadvantages,
  mostly the facilitation of charging for untimed local calls, but went on to say that
  these issues may become less problematic in an NBN environment.

   Section 3.4 of the Numbering Plan provides that geographic numbers must be used by local services, and
the most common use for them is by traditional fixed-network voice services, such as a home phone.
However, geographic numbers may also be used for non-traditional services that are an exact or close
substitute for fixed-network voice services (such as some two-way VoIP services) and for some services
that are not a close substitute (such as one-way VoIP services and non-voice calls such as fax calls and
dial-up internet). Some of these non-traditional services are able to be nomadic on an occasional or regular
basis. Part 5 of Schedule 7 provides guidance on when geographic numbers can be used by nomadic
   ACMA, Community research into consumer behaviours and attitudes towards telecommunications
numbering and associated issues, p. 68.
   ACMA, Structure of Australia’s telephone numbering plan, See p 32 Question 6
   See p 30 Question 4 Numbering: Structure of Australia’s telephone numbering plan.
   See pp 33 & 37 Questions 7, 8 & 11 Numbering: Structure of Australia’s telephone numbering plan.

                                                                                                 acma | 13
> Some respondents, including Internode, indicated that geographic numbers could
  be converted to flexible numbers now. Others, including Telstra, indicated that this
  conversion could not occur until price differentiation is removed and could not
  foresee a time when this would occur.
> If geographic numbers were converted to flexible general purpose numbers,
  respondents saw some issues with the provision of the untimed local call
  obligation. Some providers (iiNet and Internode) suggested that this could be
  addressed by expanding the eligible area of untimed local calls to the whole
> Optus noted that:
           Maintaining these mandatory obligations for longer than is needed along with the
           associated numbering arrangements may impose costs of industry and block benefits
           to consumers. In particular the mandated obligation to supply untimed local calls
           should be dealt with as soon as possible, as this may push unnecessary costs and
           complexity into the future.
      In addition to the feedback from submitters, the ACMA‘s research indicated that
       there is general confusion about the cost of landline and mobile calls because of
       the prevalence of a wide and varied range of packages for both these services.
       Focus group research suggests that there is some confusion about what
       constitutes a ‗local call‘. Many participants thought that it was in their local area but
       were unable to define what the borders for this area might be.

In addition to enabling CSPs to meet their obligations under the TCPSS Act, law
enforcement and emergency agencies have advised the ACMA that geographic
numbers currently play an important role as a proxy for location information. While
they note that this is not the only source of location information available to them
today, and that alternative sources will be developed in the future, they anticipate that
they will continue to use this information until alternative sources mature and/or the
location information embedded in them becomes unreliable.

When this occurs, the ACMA considers that it will be appropriate to consider whether
the location restrictions that apply to geographic numbers are required, as they restrict
the flexible and efficient use of the numbers.

Some incremental changes have already been made to the arrangements for
geographic numbers that increase the flexibility with which they can be used. This
means that in certain circumstance, services using these numbers are permitted to be
occasionally nomadic and to be used in an alternative location; however, further
flexibility could be provided. For example, the restriction that geographic numbers
must be used within certain sectors of the metropolitan area could be removed without
implications for the untimed local call obligation.

The removal of sector boundaries in metropolitan areas was well supported by
industry as it will increase the flexibility and efficiency of its number use. While the
argument by the market research industry that such a change would increase
sampling costs is noted, other survey methodologies and sampling mechanisms are
available to achieve similar outcomes, and this argument was not considered a
compelling reason to continue to restrict the more flexible use of geographic numbers.

Several providers noted that location information is unlikely to be needed for charging
or routing in the long term (indeed some of them do not use it now) and removing it

  Following amendment to the Numbering Plan in 2011 to insert sections 4A and 4B, geographic numbers
may be used in an alternative location if a customer has been informed of how call charges will be affected
and their ability to port the number to another provider.

14 |   acma
could achieve additional efficiency and flexibility. However, further relaxations will not
be considered until alternative sources of location information are established.


       #      What                                     How                          When
       1      Remove sector boundaries                 Amend Schedule 3 of the      2011–12
              from geographic numbers                  Numbering Plan
       2      Remove the requirement to                Amend Numbering Plan         When this information is no
              use geographic numbers in a              sections 3.4, 3.5, 3.7 and   longer required to meet
              specific location within a               Schedule 2                   obligations under the TCPSS
              charging district                                                     Act
       3      Remove the requirement that              Amend Numbering Plan         When alternative mechanisms
              geographic numbers must be               sections 3.4, 3.5, 3.7 and   are available to allow law
              used in a specific,                      remove Schedule 2            enforcement and emergency
              predominantly fixed location                                          agencies access to location

2.1.2       Mobile numbers
Digital mobile service numbers were the only service type identified as having the
potential to exhaust its capacity in the short to medium term. Further modelling
undertaken in 2011 has identified that if CSPs continue to apply for mobile numbers at
the rate experienced over the 18 months to mid 2011, then the current supply of
mobile numbers could be exhausted by 2017, 10 years earlier than previously
forecast. The ACMA is exploring options to expand the capacity of mobile numbers.

The numbering work program also identified that future changes to both network and
device technology and to retail packages may provide the opportunity to convert
geographic, mobile, LICS and satellite service numbers into one flexible general
purpose range. It also asked:
> if there were any other reasons for retaining a separate range for mobile numbers
  other than the cost of calls
> when mobile numbers could be converted to flexible general purpose numbers and
  what strategy should be used for transition.

> All respondents agreed that demand was likely to remain high in the future and
   alternative number ranges should be explored.
> The cost of calls was the only reason identified for maintaining a separate range;
  however, the Communications Law Centre noted that ‗the economic reason for
  having separate mobile numbers will eventually be eliminated‘.
> Some respondents, including Symbio, indicated that mobile numbers could be
  converted to flexible numbers when price differentiation is removed; others,
  including Telstra, thought there was no case for change.

Historically, technology descriptions and distinctions in service descriptions informed
CSPs about the kinds of technology that could be used to provide services. Providers
use this information for routing calls and over time have also used it for both retail and

     ACMA, Structure of Australia’s telephone numbering plan, p. 37, question 10.
     ibid, question 11.

                                                                                     acma | 15
wholesale charging. The ACMA‘s research found that mobiles are emerging as the
main communications service of adult Australians, with 47 per cent using mobiles
(either mobile voice or text) as their main form of communication, while 33 per cent
reporting that their main form of communication is their landline. Those in the younger
age group (18–24 years) are most likely to have only a mobile phone (32 per cent
compared with 13 per cent overall).

Some of the technology descriptions and distinctions may be restricting innovation and
a more flexible use of those numbers by services unconstrained by historical
assumptions about the technology. The ACMA considers that unless there are
compelling reasons to maintain them, technology descriptions and distinctions should
be removed to encourage innovation and allow the flexible use of numbers.

Removing the technology descriptions and distinctions for mobile services, the
distinctions between mobile and satellite, and between mobile and LICS, could provide
additional capacity and flexibility and may not significantly impede price transparency
for consumers.

This approach would maintain the distinction between those services that are primarily
fixed (or are nomadic on an occasional basis only), which would continue to use
geographic numbers, and those that are not fixed—those that could be regularly
nomadic or could be moved continuously without service interruption and independent
of the technology used to provide them.

There are several ways to implement this approach, including:
> removing the technical limitations on the use of mobile numbers by these services
> amending the service definitions for satellite and LICS numbers, allowing both of
  those ranges to be used by mobile services (see sections 2.1.3 and 2.1.4).

In considering this approach, the ACMA will need to have regard for the ACCC‘s
directions on portability—which apply to digital mobile services but not to satellite
services or LICS—and to the implications of any changes on the needs of law
enforcement or emergency service organisations.

   ACMA, Implications of research into consumer issues, p. 12.
   Optus offers satellite services using digital mobile numbers.
   When alternative mechanisms have been developed that give law enforcement and emergency agencies
access to location information, for all services, it may be possible to remove this distinction (if doing so
would benefit CSPs or consumers).

16 |   acma
       #     What                                   How                                 When
       4     Remove technical limitations           Amend the definition of             2013
             that restrict services using           ‗digital mobile service‘ in the
             other technologies from                Numbering Plan to remove
             using mobile numbers                   reference to the network
                                                    technology used to provide
                                                    the service
       5     Allow satellite services to            Amend Schedule 4 to allow           2013
             use mobile numbers                     satellite services to use
                                                    digital mobile numbers
       6     Allow LICS to use mobile               Amend Schedule 4 to allow           When an alternative
             numbers                                non-fixed services, including       mechanism has been
                                                    LICS, to use digital mobile         established for providing
                                                    numbers                             location information to ESOs
                                                                                        for non-fixed services other
                                                                                        than mobile

2.1.3       Location independent communications service (LICS) numbers
It is clear that the introduction of the number range for LICS has not been a success.
Structure of Australia’s telephone numbering plan asked:
> What were the reasons for the limited usage of LICS?
> To what extent is it relevant to retain a distinction in the numbering plan for the
  nomadic nature of a service?
> If LICS are retained, to what extent will the ACMA need to address the reasons for
  their limited usage?

> The Communications Law Centre noted that ‗in the long term, local service (based
   on PSTN) will be substituted by location independent communication services
   (related to Internet-based services and NGNs)‘, and that to provide LICS with
   geographic numbers (without geographic significance) would be ‗in accordance
   with the industry trend to universal NGN; also is more useful for customers as well
   as less complex for CSPs‘.
> The majority of respondents thought that the LICS number range should be
  scrapped due to lack of demand. Telstra indicated that it ‗has no formal requests to
  negotiate access for 0550 numbers and Telstra has no plans to use them‘.
> The reason for the limited use was because of the lack of regulatory intervention to
  mandate an originating access price. AAPT noted that:
            … location independent numbers have not been a success due to the unavailability of
            a suitable charging model that could compete with the untimed local calls regime
            available from geographic numbers.
> Symbio Networks argued that:
            … the reasons are that carriage service providers are reluctant to condition their
            respective networks to accept, analyse and route location independent numbers due to
            the huge costs involved and limited benefits.
> Skype noted that ‗the marginal use of LICS numbers in Australia comes as no
  surprise; their failure being inevitable in great part due to the practices of
  (incumbent) network operators‘, and argued that ‗should ACMA persist with a

     ACMA, Structure of Australia’s telephone numbering plan, p. 40, questions 12–14.

                                                                                            acma | 17
dedicated LICS range, it should not tolerate operator‘s abusive practices in this
> Law enforcement and emergency agencies maintained that a separate range for
  nomadic services continued to be important because of public safety.

Specification of a range of numbers for LICS is one in a series of attempts to provide a
number range for innovative services on general purpose numbers. As outlined in
2.1.2, the ACMA considers that unless there are compelling reasons to maintain them,
technology descriptions and distinctions should be removed to encourage innovation
and allow the flexible use of numbers. However, the ACMA recognises that there may
be some benefits in maintaining a range of numbers for such service innovation.

Notwithstanding the implementation problems identified with LICS numbers, it is not
possible to remove them unless the rules for either local or mobile services, or both,
are amended. This is because the Numbering Plan restricts the use of geographic
numbers to those that are fixed or are only nomadic services on an occasional basis.
Although recent changes to the Numbering Plan mean that CSPs have more flexibility
to use local service numbers in alternative locations as long as customers have been
informed about the impact, the recent amendments do not permit the use of local
service numbers by services that are nomadic on a regular basis. Any further changes
also need to have regard to the obligations set out in Part 4 of the TCPSS Act.

The definition of digital mobile numbers contained in the Numbering Plan similarly
restricts their use to services that are supplied using a network that uses digital
modulation technology. This means that while a VoIP service on a laptop connected
using a mobile data connection could arguably use a digital mobile number, the same
VoIP service would not be permitted to use a digital mobile number when connected to
a fixed IP connection.

However, if the mobile service definition was amended to allow other non-fixed
services to use mobile numbers without reference to the technology type used in
service provision, the description of LICS numbers could be removed from the
Numbering Plan.

Alternatively, given that current use trends show that digital mobile numbers may
exhaust current capacity in the next six years, it may be more efficient to amend the
number range associated with LICS to allow its use by other non-fixed services,
including mobile and satellite services. In this way, the number range could be more
broadly available for innovative services that do not fit neatly within the existing
geographic or mobile number ranges.

As with the changes to mobile numbers the ACMA will need to consider the
implications for portability and emergency services, prior to implementation of either

     Part 5 of Schedule 7 provides the guidelines for the use of geographic and location independent services.

18 |    acma

       #      What                                     How                                  When
       7      Remove technical limitations             Amend Schedule 4 to explicitly       When an alternative
              restricting other non-fixed              allow other services, such as        mechanism has been
              services, including mobile and           digital mobile and satellite         established for providing
              satellite services, from using           services, to use the number          location information to ESOs
              LICS numbers                             range associated with LICS           for non-fixed services other
                                                                                            than mobile

2.1.4       Satellite numbers
Structure of Australia’s telephone numbering plan asked whether it was necessary to
retain a separate number range for satellite services, given that many of the estimated
16,000 satellite services in Australia do not use the 014 satellite range. Instead,
these services choose to use either Australian mobile (04) numbers, or global satellite
numbers on the +881 global mobile satellite or the +882 international networks ranges.

> The cost of calls was seen as the main justification for maintaining a separate
   number range for satellite services. For example, AAPT noted that ‗the only benefit
   of having a separate number range is to indicate there are higher charges for this
   service‘, while Telstra noted that the ‗price information is valuable to callers
   because the services tend to be expensive‘.
> Optus noted that they ‗continue to offer satellite services and continue to require
  this number range. Calls to and from mobile satellite services are charged at
  distinct rates and separate numbering is required‘.
> Australian Private Networks, which retails satellite phones using both satellite
  numbers (where the caller pays for the call) and mobile numbers (where the
  satellite customer pays to receive the call), noted that ‗to date all of our customers
  have chosen 0145 (satellite) numbers and the feedback we get is they do not want
  to pay to receive calls‘‘ They go on to argue that ‗operators would be forced to
  impose charges to receive calls if the satellite number range was removed‘.
> In contrast, Internode argued that:
            … the NBN is about to make this (a separate number range for satellite services)
            insane by providing voice services via satellite where ‗local‘ and ‗long distance‘ will be a
            fake concept supported for political purposes.
> VHA stated ‗that there is no need for a spare number range for satellite services as
  mobile numbers are already being used for satellite services‘.

As outlined in sections 2.1.2 and 2.1.3, the ACMA considers that unless there are
compelling reasons to maintain them, technology descriptions and distinctions should
removed to encourage innovation and allow the flexible use of numbers. The ACMA
acknowledges that increasing flexibility may reduce the call cost information
embedded in the existing satellite number range. On balance, the ACMA‘s view is that,
in this case, the benefits of increased flexibility outweigh the reduction in call cost

The cost of calls was the main reason cited by submitters for maintaining a separate
number range. However, there is evidence that a separate number range is not

     ACMA, Structure of Australia’s telephone numbering plan, p. 42, question 15
     Paul Budde Communication, Australia – Mobile Satellite Service, June 2010.

                                                                                            acma | 19
required for satellite services as some satellite providers are already choosing to offer
these services on mobile numbers. There is no evidence to indicate that this trend
would not continue into the future and, given the small number of services in the
Australian market, little evidence of consumer detriment from this practice.

However, if the ACMA withdraws the 320,000 satellite numbers allocated to providers,
services to customers who use these numbers will potentially be disrupted. In contrast,
removing the technical barriers that restrict mobile and nomadic services such as LICS
from using these numbers would expand the number ranges available for these
numbers and reduce technology restrictions that no longer reflect industry practice.
Allowing other services to use the ranges associated with satellite numbers would also
make an additional 4.7 million numbers available for those services.

As with the changes to mobile and LICS numbers, the ACMA will need to consider the
implications of this change for portability and emergency services.


       #      What                           How                          When
       8      Remove technical               Amend Schedule 4 to          2013
              limitations restricting        explicitly allow digital
              mobile services from           mobile services to use the
              using satellite numbers        number range associated
                                             with satellite services
       9      Remove technical               Amend Schedule 4 to          When an alternative mechanism has
              limitations restricting LICS   explicitly allow LICS to     been established for providing location
              services from using            use the number range         information to ESOs for non-fixed
              satellite numbers              associated with satellite    services other than mobile

2.2          Business and information numbers
In addition to the general purpose numbers discussed in 2.1, the Numbering Plan
provides several service types for use by entities who wish to subsidise the cost of
calling for their customers and clients, or to allow them to charge for access to
directory, information, entertainment or other services. This section is divided into
three parts:
> freephone and local rate numbers (13/1300 and 1800)
> premium numbers (19)
> directory assistance and information services provided on shared numbers (12).

2.2.1        Freephone and local rate numbers
On 11 October 2011, the ACMA published a consultation paper, Numbering: Calls to
freephone and local rate numbers—The way forward, which indicates that it plans to
take action so that calls from fixed and mobile phones to freephone and local rate
numbers are treated in a similar manner. The ACMA‘s view is that the current
arrangements require change. Three key drivers of change have been identified:
> the desirability of reflecting changes in consumer usage of telecommunications
> the need for the arrangements to reflect the intent of the legislative scheme
  including the objects of the Numbering Plan
> the desirability of increasing price transparency for consumers.

20 |       acma
The ACMA is consulting on a proposal to amend the Numbering Plan to achieve two
key outcomes:
> that calls from mobile phones to freephone numbers are free of charge to the
  calling party
> that calls from mobile phones to local rate numbers are limited to the amount that a
  consumer would expect to pay for a local call made from a fixed phone.

The ACMA also welcomes measures by industry that avoids the need for regulatory
intervention to achieve these two outcomes.

The ACMA does not place any limit on the mechanisms that interested parties may
propose to meet these outcomes, but is interested in how these may be achieved
within the 12-month time frame identified in the consultation paper.

Readers interested in this issue are encouraged to review and respond to that paper.

2.2.2    Premium numbers
Premium rate services allow customers to pay for information, entertainment and other
services using their phone bill. The current arrangements enable these services to be
provided on six-, eight- and 10-digit number ranges with a 19 prefix, including a limited
pool of these numbers for use with age-restricted services (numbers beginning with
the prefixes 1901, 195 and 196).

At various times, premium rate services have been the subject of high levels of
consumer complaints—most commonly about the receipt of unsolicited services and
high charges. However, more recently, many of the services previously provided on
premium numbers, such as competitions and ringtones, have moved to alternative
online mechanisms.

ACMA research demonstrated that despite:
         … some confusion about exactly what services are likely to be offered on 19/1900
         numbers, consumers can generally identify that these calls are not free and are likely
         to cost more than a local call from both landline and mobile phones.

Structure of Australia’s telephone numbering plan asked:
> Is the need for premium rate numbers likely to continue into the future? If so, for
  how long?
> What are the limits to facilitating price transparency via the Numbering Plan? What
  are the possible ways to achieve price transparency of premium rate services and
  other communications services (apart from numbers)?

> The majority of respondents, including AAPT, iiNet, Skype, Optus and Telstra, note
   that although demand is declining, a separate range of numbers will be needed for
   premium services for the foreseeable future.
> The majority of respondents thought that it was no longer relevant to distinguish the
  means by which a service was accessed—however, iiNet noted that this distinction
  was still useful to them.
> The distinction for adult services was broadly supported.
> There was a range of views on price transparency—some felt the numbers were no
  longer relevant to indicate price; others that there remained some benefit to

   As required by Section 158H of the TCPSS Act 1999.
   ACMA, Implications of research into consumer issues, p. 32.
   ACMA, Structure of Australia’s telephone numbering plan See p. 50, questions 20–22.

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