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RE: Ofcom VoIP Public Forum

  • To: "Christian de Larrinaga" < >
    "Conroy, Lawrence (SMTP)" < >
    "Kennedy, Steve" < >
  • From: Richard Shockey < >
  • Date: Mon, 15 Mar 2004 21:11:25 -0500

At 01:11 PM 3/15/2004, Christian de Larrinaga wrote:


As a side bar to this fine discussion might want to have some bed time reading on the FCC NPRM on VoIP as well... all of these topics and much more are on tap here in the States.

The difference between our NRA's and yours is that ours are willing to question nearly everyting under the sun in the name of innovation.

Ofcom is essentially asking for INPUT as to whether what they call voice
over broadband services (VoB) can be PATS compliant (they think NOT but have
said they are OPEN to being told different).

Actually the problem is the old one of the Regulator thinking about an
Internet service in terms of a telephone service and so are fixated on the
Public Access Telephony Provisions as applied to a narrow range of IP voice
services which they define as VoB. (typically a steam phone connected to an
ATA box into DSL).

It is clear that PATS provisions are regarded as inflexible and you take on
*ALL* of PATS (including those bits which are clearly specific to telecoms
QoS issues and so not a good fit for Internet services) or none.

So just setting up a number plan to route 999 to an emergency number call
centre is not enough to comply with PAT. It is not clear for instance that
provisioning would answer the PAT's question even if it
answered a significant  part of the issue of access to emergency services.

Ofcom has got very concerned for the UK's babysitters.

They have described a scenario where a babysitter discovers a fire, picks up
VoB phone dials 999, nobody answers and so the unfortunate babies burn and
Ofcom have to deal with tabloids screaming "Ofcom Internet phones kill
family ..."
yep that is a problem

So the afternoon session at Ofcom concentrated entirely on taking input from
delegates how to inform consumers reliably that a phone that looks like a
phone, behaves like a phone may NOT fully behave like a phone and offer
emergency services etc.

One of the things that came out on the day is the very significant pressure
being applied on Ofcom to not only provide non geographic 056 numbers to IP
users but also full geographic numbers.

It seems that Ofcom have been approached by a significant number of telecoms
dealers trying to sign up estate agencies to VoB who apparently are
demanding they are given local telephone numbers irrespective of whether
they are using IP or PSTN devices because they wish to be known as "local"!

This issue also plays a significant part in Ofcom's consultation.  So we
should expect to see a number of consultation demands for the full UK e164
geographic number range to be used for VoB numbers and not just 056 as Ofcom

> Was it also stated that a non-PACS provider must NOT provide
> any of the other services under the normal obligations?
> Gosh!

> I had thought that the original intention was that customers
> should KNOW that they were getting a service that MIGHT not
> provide all of the good things under the obligations *as they
> are normally defined*; not that partial provision was barred.

see above.

> I do so love Regulations.


In which case you will be very pleased to learn that OFcom regard the PATS
provisions as untouchable because they form part of an EU Directive.

So it's the EU's fault :-)


Richard Shockey, Senior Manager, Strategic Technology Initiatives
NeuStar Inc.
46000 Center Oak Plaza  -   Sterling, VA  20166
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<mailto:richard(at)> or <mailto:richard.shockey(at)>
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