RD359 - ETNO Reflection Document - Response to BEREC call for contributions on cross border accessibility of numbers

ETNO welcomes the opportunity to respond to this questionnaire about crossborder issues under Article 28 of the Universal Service Directive (USD). According to ETNO, there are no problems evident in the EU Member, States ETNO reiterates the difficulties and disadvantages of provisioning access to all national non-geographic service numbers between EU Member States. ETNO has serious concerns regarding, in particular, national non-geographic service numbers access provisioning at the international level.

Executive Summary:

• ETNO welcomes the opportunity to respond to this questionnaire about crossborderissues under Article 28 of the Universal Service Directive (USD). ETNOpreviously responded in January 2011 to the BEREC consultation on cross-borderissues under Article 28 of the Universal Service Directive (see ETNO Reflection Document RD340).
• According to ETNO, there are no problems evident in the EU Member States regarding cross-border accessibility of national numbers, provided that there is a real market need and that customer protection is ensured.
• It should be noted that presently there are no issues with regards to the crossborder accessibility of national numbers assigned to fixed, nomadic and mobile end users for personal communication services, for which a real market need exists.
• ETNO reiterates the difficulties and disadvantages of provisioning access to all national non-geographic service numbers between EU Member States. ETNO has serious concerns regarding, in particular, national non-geographic service numbers access provisioning at the international level. In the case of numbers associated with national-wide services (e.g. premium rate service numbers, etc.), there are many complex issues that will be exacerbated when implemented at EU level. In addition, there is a lack of market need and interest for the systematic EU-wide cross-border access such numbers, especially given the existing use and availability of ITU-T administrated global non-geographic numbers for services that need to offer international, European or global accessibility.
• ETNO highlights that, in the case of specific non-geographic national numbers associated with emergency and public utilities services, the cross-border accessibility has to be avoided, since the service centre (for instance, the PSAP for the emergency service) is usually organized to provide only the associated service to end users at the national level and not to end users abroad. In case of roaming mobile customers, access to the essential national emergency services is already available.