Tuesday, 27 August 2013

Fun with numbers

Well, OFCOM are fun at the best of times, and one of those is the way numbers are allocated.

OFCOM require communications providers to use numbers in the National Numbering Plan in accordance with restrictions defined in that plan.

One of the restrictions is the use of 071 to 075 inclusive and 077 to 079 inclusive as Mobile Service which is defined: ‘Mobile Service’ means a service consisting in the conveyance of Signals, by means of an Electronic Communications Network, where every Signal that is conveyed thereby has been, or is to be, conveyed through the agency of Wireless Telegraphy to or from Apparatus designed or adapted to be capable of being used while in motion;

Now, OFCOM have made it clear they mean every signal in that. The idea that any call could terminate on a VoIP service was not acceptable. We did eventually get 07 mobile numbers, but they were very fussy. We did have mobile SIMs via Three which was on the 07 numbers.

But when we lost the mobile SIMs for voice, we asked OFCOM to confirm our plans were acceptable. We said we would only use 07 mobile numbers where the call was diverted to another operators 07 mobile number (who would also be compliant) and as such we complied. We also suggested we would route to SIP devices using DECT or other Wireless Telegraphy. OFCOM were not convinced and wanted to take away our 07 mobile block.

We then said "what about SIP devices on mobile phones via 3G data and SIP", that definitely meets the rules. No reply yet.

We know that all mobile operators break the National Numbering Plan, and hence General Condition 17.4 and hence the law (Communications Act). They provide call forwarding to a land line, and voicemail, and some even have call centres on their 07 mobile number range. All such uses are outlawed.

The latest O2 advert for "Tu go" is interesting. It appears to talk of VoIP services using 07 mobile numbers for SMS and voice on devices connected via WiFi, and even PCs not even connected via WiFi. This is almost identical to some of the ways we propose using 07 mobile numbers.


We have written to OFCOM to confirm they have relaxed their rules. We await reply.

Just to add to the fun, the latest breach we have found is Psychic Living, selling psychic readings on 0300 466 0000. AFAIK they are not a charity or non profit, but OFCOM rules for 030 are: Non-Geographic Numbers charged at a geographic rate: to be used by public sector bodies and not-for- profit bodies, calls charged at up to the same rate the customer would pay to call a UK Geographic Number, with calls to 030 numbers counting towards inclusive call minutes if the customer has remaining inclusive minutes to UK Geographic Numbers, and included in any discount structures that apply to UK Geographic Numbers

So, waiting for an answer from OFCOM on that too.

Update: "It is always helpful when we hear that numbers have been misallocated, and we will ensure that action is taken to ensure that 0300 numbers are used in line with the National Telephone Numbering Plan." so they do take it seriously.

Update: Within hours of the complaint, that web site is using an 033 number! Go OFCOM Go!

All good fun.

As for the new number tax, well, I'll blog on that later. We have, of course, deployed the obvious loophole for the number tax which means it is actually in our interests to have more customers using numbers in conservation areas so we (A&A) may do an offer on that shortly. What a wonderful scheme OFCOM have created for that.

15 comments:

  1. It isn't VoIP but my Orange phone has a feature called "Signal Booster" which is UMA over the WiFi connection. It is basically GSM/UMTS packets wedged into a VPN tunnel to the Orange servers and never hits a radio beyond the short hop over WiFi at the start.

    I get full usage of my phone when its connected like this so SMS, MMS, voice and even data if you bodge it. All of it using my regular 07 number. It even works on the tube.

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    1. As long as it is still to the mobile device and via wireless telegraphy, that is fine. O2 are talking about PCs that are clearly not designed or adapted to be used whilst mobile and may not even be connecting via WiFi.

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    2. Presumably, changing it to reference laptops using WiFi would fix the problem.

      The real solution, of course, would be for Ofcom to fix the interconnect gouging: end the surcharge for 07 termination, and profiting by wrongly allocating 07 numbers is no longer possible. Ofcom may be getting more permissive in this respect as the surcharge (and hence the profit available from abuse) declines.

      I recall chafing at the absurdity of a mobile tariff for "handsets only, no tablets", followed by various debates about how they made that distinction: I can, after all, make voice calls from both my laptop and my iPad, and the heaviest data use (streaming video) is also available to all. They also conceded that using a phone with an external monitor would be fine, while maintaining that using it with a separate laptop would not. Now we know where Kafka went to work...

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    3. Indeed, except OFCOM were (when we applied for 07s) saying that even the chance that one call could go via SIP to a non mobile device was enough not to give us the block. If their app can be used on a cable, or by wifi to a device that can't practically be used in motion, it breaks the rules. But then, so does call forward to a landline, and voicemail. I agree, there is no need for these restrictions these days with the lower interconnect costs for mobiles, but rather than "informally relaxing" the rules it would be way better if they formally changed them!

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  2. Regarding OFCOM's number tax... My home phone uses A&A VOIP with an (01531) number ported in from Gradwell some years ago. Is my phone number going to stop working at some point?

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    1. That will depend on Gradwell - if they decide it is no longer worth while because of the number tax they could return the block to OFCOM and that would stop it working. We have no control over that. It used to be that there was never any reason for any telco to return a number block, but now they cost money, that has changed.

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    2. If I got a new number from A&A, would the same problem still apply?

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    3. In that, if we decided not to continue doing VoIP and returned the number blocks, yes. Same with *any* telco. We don't have plans to pack in VoIP, but it depends how much of a pain and cost OFCOM make it.

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  3. The rules appear to be written to give the existing mobile operators carte blanche to do what they do, and anyone else is more likely to get carte rouge. That's hardly fair... they need to be consistent.

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  4. So what range of numbers are supposed to be used by devices in 'fixed' equipment which communicate using GSM/GPRS/SMS/3G etc?

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    1. Well, not 07s. Which is a good point. There are loads of devices from bus stops to alarm systems which do not meet the requirements for use of 07 numbers, but use them for SMS at least. We need to raise that with OFCOM.

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    2. A good point indeed; the new VoIP setup at work does least-cost routing by sending calls to mobiles over GSM from a big rack-mounted multi-line GSM-VoIP gateway. I'm pretty sure even Ofcom would struggle to stretch "mobile" to include "something bolted to a 19" rack running on mains power in a server room", though they'd probably try.

      Of course, by Ofcom logic, since any SIM card can be inserted in those units, this means 07 numbers must not be assigned to SIM cards. At all. Why, it's almost as if they hadn't thought the policy out properly ... surely not!

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    3. Now that is an excellent example - those calls should not use 07 as CLI.. Ha!

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    4. Ah, but the Ofcom policy is about *allocating* (or terminating) numbers to a line/device, as opposed to presenting them as CLI (indeed, I have my Skype account set to present my mobile number on outbound calls). Since they're outbound only, there doesn't seem to be an issue in this case. (Of course, it would be much better if the SIMs did show the geographic number for CLI rather than an arbitrary unused 07 number, but I don't think O2 would be very helpful there.)

      Besides, the violation lies in O2 having assigned the number to a SIM card in the first place, since those are not exclusively mobile. Any reply from Ofcom yet, given their threats over A&A's use?

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    5. Indeed - I would assume the number allocation only applied to incoming numbers but I don't see that in the numbering plan or GCs, so who knows what OFCOM think. No word from them yet.

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