Friday, September 16, 2005

Tucows TPR Response Second Round 

I pointed yesterday to the submission of Tucows to the Telecom Policy Review - A Consultation Paper (pdf) from Industry Canada published in June 2005.

Also yesterday a second paper was published by Tucows and Tim Denton:

Second Round Comments of Tucows Inc. in the federal government of Canada's Telecommunications Policy Review September 15th, 2005

This set of comments concentrated upon the interest of government in the matter of network addressing and routing schemes, and the dynamic shift away from the telephone numbering system and to the DNS as the primary identifier-addressing scheme.

This document is therefor of even more interest to me and eventually also for the readers of this blog, because it deals also with E.164 numbers and ENUM ;-)

Some citations:

Question F.1 What other issues should the Panel take into account in making its recommendations? Please provide specific facts, analysis and suggestions that you think are relevant to the Panel's recommendations?

1. Heretofore the basic function of telecommunications regulation was to control the behaviour of economic entities within the jurisdiction of the state. The general problem was the monopolistic tendencies of communications economics, which was characterized by declining unit costs and greater returns the larger the network. Regulation was focussed inward to the territory of the state to control the behaviour of the national economic actors.

2. The current debate in the submissions before the TPR dwell on the ways to address the problem of market power of incumbents. Some favour sectorspecific regulation, while others favour an approach based in competition policy principles, or some different combination than we currently have.

3. This debate about the proper tools to control market power is important and interesting, and Tucows has made specific recommendations in our original submission on these matters. Nevertheless we will venture to say that this issue, however important it may be now, will decline in relative importance as the Internet revolution proceeds. We do not doubt that the control of market power will always be of great, indeed of central importance to telecommunications policy, for a long time to come. Nevertheless we are persuaded that the bundle we have labelled “identifier issues” will grow in importance.

4. Identifiers are the names and addresses whereby machines locate end-points of the network where the person sought can be found. Telephone numbers, which are under the jurisdiction of the CRTC, and derive from the ITU, have traditionally served as these identifiers. Now identifiers are being created and shaped by institutions like the Internet Engineering Task Force1, and influenced by such entities as ICANN. The IETF is not under any particular national jurisdiction, and ICANN functions in a complicated relationship to the US Government. In addition, private, non-universal systems, such as Skype and Instant Messaging, are being created.

5. The Internet revolution has been accompanied by new forms of identifiers, of addressing and naming systems, which are not tightly bound to national jurisdictions. These identifiers have been created – and are being created - in forums in which governments in the past have had little influence, and may not be able or even wish, to exercise much influence.

6. The Canadian government has a legitimate interest in the universality of the communications network. The basic bargain that created the Bell system in 1919 was “universal service”, which gradually ended the islands of subscribers to municipal systems who could not communicate with each other. The price that was paid to obtain the one integrated end-to-end system was the Bell system monopoly in long-distance. Now that voice telecommunications is a horizontally disaggregated application riding on a transport layer, universal naming and addressing systems do not need to come at the price of monopoly in the transport layer.

7. The interest of the government in universal addressing and naming system or systems does not mean either of the following:

• That the definition of universal service should be restricted to time-division
multiplexed (TDM) PSTN service over copper pair, nor
• That private, non-universal addressing and naming systems should be
restricted or somehow disfavoured.

8. The interests of the government in naming and addressing systems may be more extensive than the preservation of universal service or services only. The arrangements for the governance of the telephone numbering system are overseen in order that they may not be used as a source of undue competitive advantage. As the telephone numbering system shifts into a domain name-based scheme over the next few years, naming and addressing systems will be a matter where the government will want to be aware of the changes and keep an eye out
for anti-competitive behaviour.

9. The current arrangements for the assignment of telephone numbers to users will probably not continue unchanged if these arrangements become a source of undue competitive advantage for one class of carrier over another. Moreover, if a universal system of identifiers, such as telephone numbering, is to be maintained while the technical basis of using those numbers undergoes the transformation to IP-based technologies, then it is likely that this quiet backwater of numbering administration will need to be more actively managed or looked after by government than it is now.


Question B.26 Over the next 10 years, is there likely to be a new method of assigning addresses to telecommunications devices which would replace traditional numbering? If so, what might that method be, who should administer it, and how?

Naming and addressing and the Future of Telecommunications:


11. There are five principal types of naming and addressing scheme at use or proposed in the world today relevant to telecommunications policy. (Many others addressing schemes exist of course, such as postal addresses and universal product codes, which we exclude from this discussion):
  • The e164 telephone numbering system
  • The IP addressing system
  • The Domain Name System, which converts human-readable words into IP addresses
  • Peer-to-peer schemes, such as Skype, and Instant Messaging
  • Conversion databases, such as ENUM, which translate e164 numbers into domain names and the DNS look-up system

13. The main points we wish to make about the DNS and newer network identifiers, most of which are based in IP addresses, are as follows :
  • They support innovation by third parties in applications or namespaces without permission
  • They are devised in technical forums outside of Canada, outside of national jurisdictions, and outside of the treaty-based ITU;
  • They will replace or supplant telephone numbers in a much faster time-frame than some intervenors appear to contemplate;
  • They will become the means whereby « calls » are terminated, or to use a less phone-centric term, the way machines will locate humans through the Internet;
  • So that, while telephone numbers will still exist, the technologies which make them work, that is, resolve to persons or devices, will be grounded in the Domain Name System (the DNS) and a set of standards and standards-making bodies in which governments have had little say or interest to date, and
  • If governments want to have a voice in these developments, they will need to develop capacities to act, directly or indirectly, in international or nongovernmental forums where national jurisdiction may not be asserted.


18. ENUM is a translation database that takes telephone (e164) numbers and translates them into domain names. They may be pictured as a telephone number, written out in its normal form, [e.g. 1-613-992-4210] but printed as a hyperlink in coloured ink, which, when activated, leads to instructions as to how to reach a person.

19. As the PSTN collapses under its own inherited costs, carriers will seek to move the function of call completion to a DNS-based architecture. This avoids the inter-carrier settlement regimes of the PSTN. It allows cable companies and others to route calls without ever passing through the PSTN.

20. Once the Internet Engineering Task Force developed Session Initiation Protocol (SIP), it was a foregone conclusion that consumers would eventually use the Internet for voice communications. SIP-based VoIP constitutes the deployment of an efficient, more robust, and functional communications, which will bemarketed to consumers and will seamlessly combine voice, video, text and whatever new technologies may come along in the near and distant future.

21. Naming and addressing mechanisms for the PSTN and the Internet are not the same. VoIP calls that originate on one service provider’s network, and which must terminate on another VoIP network, must default to the PSTN for completion. In other words, there is no authoritative database mapping e164 telephone numbers to SIP Uniform Resource Indicators (URI).

22. ENUM, whether it is made available to subscribers, or remains a purely carrierbased implementation, will allow calls between various VoIP providers to be completed without the need to make the address look-ups in the PSTN. They will also enable different forms of carrier to complete “calls” without the transmissions ever passing through the equipment of the PSTN. Thus cable operators, for instance, or anyone else, could provide a universal telephone service, using e164 numbers, without having to rely on the obsolescent PSTN.

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