The M2M Consultation, issued in March 2013 and reported in our previous ezine, raised concerns that unless action was taken, Ireland's already scarce numbering resources would be depleted by the increasing proliferation of M2M services on existing voice numbers. ComReg was therefore proposing to introduce a dedicated new number range for M2M purposes. However, this has now been parked.
Reasons cited for ComReg's decision include: the significant divergence of views of industry players, cost implications and practical difficulties of adopting a new number range as well as 'critical new information' that has come to light. Instead, ComReg is proposing a series of 'number conservation' measures including:
- setting effective utilisation targets
- reducing the sizes of blocks in allocations from 100,000 to 10,000 to encourage applicants to think more carefully about the quantity they actually need
- charging for numbers
- shortening the interval between assignments
- greater use of retrieving unused numbers.
ComReg has said it will meet with the Number Advisory Panel (NAP) to discuss which number conservation techniques offer the greatest benefits and efficiency.
If, however, it looks as if these techniques are not working, ComReg will look again at introducing a new number range for M2M services. M2M providers and others keen on seeing a new numbering range introduced should monitor and document their views, once the conservation measures are in place.
A practical issue with M2M services is that many manufacturers of M2M devices would prefer to install M2M identification functionality at the point of manufacture. One solution discussed is to issue shared Mobile Country Codes (MCCs) eg, the 901 MCC already in issue.
Again, ComReg is going to wait it out for an ITU recommendation on shared MCCs, following which it would take into account "the outcome, its benefits, its impacts on industry and what steps ComReg may need to take to support the use by Irish SPs of shared MCC/MNCs". Interestingly, the statement refers to ComReg supporting the use of shared MCC/MNCs "by Irish SPs", which leaves some uncertainty as to how MCC/MNCs used by non-Irish SPs might be treated in Ireland.
Another interesting feature coming out of the response to Consultation is the recognition by one MNO that it does not use telephone numbers for most new M2M applications at all, but instead relies on the International Mobile Subscriber Identity (IMSI) embedded in SIM cards. ComReg is yet to make any comment on the regulatory ramifications of this approach, but no doubt this is an issue which will need to be addressed in the near future.
Direct Allocation of MNCs
Another key consideration of the Consultation was the direct allocation of Mobile Network Codes (MNCs) to M2M providers. The argument goes that where M2M providers require access to an MNO's MNC, this places them at a disadvantage when seeking to negotiate access terms. Again, ComReg intends to await an ITU recommendation on this point and does not intend to allocate MNCs directly to M2M providers in the meantime, in the absence of more compelling reasons.
Although number portability is seen as a fundamental entitlement of M2M number holders, ComReg has recognised the difficulties of ensuring this in a M2M context eg, physical switching of SIM cards to change M2M provider could well be costly, timely and potentially unworkable. ComReg has therefore proposed that the existing mobile number portability process should be supplemented by a mobile block re-allocation process (ie, where large contiguous blocks of numbers are re-assigned from one operator to another). It is hoped this will go some way to relieve the burden of number portability for M2M providers.
M2M providers might well be disappointed, that despite so much talking, so little has been done. It is hoped that in the event the ITU goes ahead with shared MCCs/MNCs Ireland does not lose out to other jurisdictions that might be seen as more supportive of M2M services.
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