Friday, April 29, 2005

Austrian Regulator NOT"unfathomable" 

Thilo Salmon posts on his blog about the "unfathomable" aspects of the Austrian VoIP regulation. I consider this very unfair, because the Austrian Regulator is one of the most advanced wordwide regarding VoIP and innovative services in general. Not by coincidence Austria was the first country to launch an ENUM trial and to start commercial service with ENUM. One should also not forget that the regulator has to follow the law in force and tries his best. The Austrian Regulator is also monitoring the European and international discussion regarding VoIP intensively. And one should not forget: a regulator should not act in favor of any operator, but in favor for the customer and the economy as a whole (by law).

In addition, the Guidelines for VoIP Service Providers of the 2nd Consultation on VoIP I referenced in a previous post is as its name suggests a consultation only and everybody is invited to make comments. It also is not self-evident that this draft guidelines are not in German, but in English, and comments are accepted in both English and German.

Thilo is also criticizing the Austrian numbering ordinance (KEM-V), released last summer and which is one of the most advanced, including already VoIP and ENUM.

Before I go into a detailed response, I have to explain especially for my readers used to the North American Numbering plan, that first Austria is not Australia and therefore a very small country. That means that the difference between local (=regional) calls and "long-distance" calls is marginal, that local calls are also metered and charged per minute, and most important, mobile phones are behind special number ranges (non-geographic numbers, and are charged with much higher rates than calls to fixed lines. In exchange there is no air-time. I consider this un-fair, but it was one reason for the tremendous growth in mobile phone usage. In Austria there are more mobile phones already than fixed lines. An example for the tarifs:

One minute in prime time local=4,9c, national=5,9c and to mobile 21c
One minute in non-prime local=1,35c, national=2,6c and to mobile still 21c
(all prices in Eurocent)
There are zillions of differnt prices and bundles and free minutes, so the above just should give you the basic idea.

Now to Thilos rant:
According to KEM-V these numbers are to be used to provide a service 'at a fixed location' with the additional obligation for the communication service to use technical measures to enforce on site usage.
This is not unusual in other countries too, Thilo should basically start complaining in Germany ;-)

And RTR basically thinks it is not sufficient to check a box with subscription confirming that you are a resident (ala Skype in France)

For the avoidance of doubt: I support Thilo's request that virtual geographic numbers are available for non-residents too, because the related problems can be solved. Anybody else supporting this is requested to submit a comment to RTR in time.

But the next statements from Thile are either half-truth or simply wrong:
Alternative numbering resources are available, but
o incur higher costs for the calling party
This is only partially true. Currently the alternative numbering ranges (0)720 and (0)780 (will be available and routed! from Mid of May) will be charged the same rate as calls to the nationwide corporate numbers, which is between regional and national calls. Since Austria is not really a big country, the difference marginal, as we have seen. Calls from mobile phones charge the same rate to all Austrian fixed numbers anyway.

Since calls to mobile numbers are much more expensive (as we have seen), the Austrians are used to high tariffs for certain number ranges, so these prices are considered cheap. Calls from out of Austria to these numbers are charged like calls to geographic numbers and NOT like calls to mobile numbers. If not, you have a talk with your originating operator.
o are almost never accessible from outside of Austria (not likely to change soon)
o may not be accessible from all Austrian networks (all networks are required to route them in theory, but let us not ignore reality.
Now this is a nice one, so lets check whats going on here.

Calls to (0)720 are almost
ALWAYS accessible from outside Austria, at least as long as your operator sticks to normal routing. My +43 720 number is at least reachable from Germany (fixed and mobile) and also from
UK (fixed and mobile) - I have verified this. This is valid for any country, as long as the originating operator chooses to use the international transit network for any call to +43.

If of course an originating operator chooses not to route this number range, or chooses to route this number range or all calls to +43 via TDM or IP by-pass directly to a national Austrian operator, and now this national Austrian operator is NOT routing this number range, who is to blame?

This is the reason why (0)720 cannot be reached by sipgate and Skype.

So please talk to your national VoIP gateway operator, wake him up, because he is sleeping and loosing traffic and money and tell him to open up the number range.
o bear the psychologial disadvantage of "feeling non-local" to the calling party
The feeling of non-local is not really an issue in Austria (see above) and not at all for non-Austrians
The immediate implications for extraterritorial communication services providing access through 3rd party networks are:
o customers migrating to extraterritorial communication services are required to renumber
This is nonsense: customers "migrating" to "extraterritorial" communication (I think you mean nomadic services here) can only be existing residents now having geographic numbers. If you read the proposed guide carefully, you will see that these customers do not need to migrate. They may port their numbers to
VoIP and also use the geographic number in a nomadic way. They only need in addition a non-geographic number if they want to make out-calls to display this non-geographic number to emergency services as an indication for not being at the home location.

This makes sense as long as we do not have implemented other means of presenting location information to the emergency services.

Since the regulator in Austria does NOT charge (currently) for numbering resources (like in Germany), it is up to the provider if he charges in addition for this number.

So geographic numbers are basically a problem for non-residents and they may as well choose a non-geographic number from the beginning.

As I stated above, the "non-local" feeling is not such an issue in Austria (considering that in Austria more mobile subscribers exist than local subscribers, and they all have a "non-local" feeling.
So what?
o customers migrating from extraterritorial communication service may choose to port their newly assigned non-geographic numbers
I do not really parse this statement. Customers migrating from extraterrestrial communication to what? Do you mean porting of these numbers? Porting is possible.
o severe marketing disadvantage due to psychological barriers caused by "strange looking numbers"
Again, these numbers look as "strange" as mobile numbers and these are the majority, looking quite normal to Austrians. It is basically just another "mobile" number range, and to surprise, surpise, a much cheaper one ;-)

And last but not least my favourite twist: All this is considered to be "technology-neutral", because even mobile operators could use geographic numbers if they only rewired their wireless customers :->
This is the last thing mobile operators want, because they would loose this nice high termination charges

But this will happen anyway with IMS and fixed-mobile convergence

Comments: Post a Comment

This page is powered by Blogger. Isn't yours?