XPress' Comments on "Notice Requesting Comments on - THE IMPLEMENTATION OF VOICE COMMUNICATION SERVICES DELIVERED USING THE INTERNET PROTOCOL"

Transcription

1 XPress' Comments on "Notice Requesting Comments on - THE IMPLEMENTATION OF VOICE COMMUNICATION SERVICES DELIVERED USING THE INTERNET PROTOCOL" Date: 23/6/2005 1

2 XPress welcomes the opportunity to respond to TRC s consultation on "the implementation of voice communication services delivered using the internet protocol" dated 9 May As the consultation illustrates, the emergence of IP based voice communication services raises various regulatory issues that the TRC needs to deal with. XPress generally agrees with the aspects the TRC identify as relevant when considering the subject (encouraging competition, consumer issues, numbering etc). XPress' response to the questions posed in the Consultation document is set out below. 2

3 Section 2: Regulatory Approach Do you agree with the view that it is not necessary for all voice communication services to provide the same standard features as traditional telephone services? XPress agrees and believes the TRC should instead focus on enabling consumers to make informed decisions. Nowadays, such features are not available nor presented the same on all Mobiles such as Call Back when Busy Multi-party line. What is required is the basic call services, which are Call Origination, Call Termination, Calling Line ID, Call Waiting (as available). Other services including Call Hold, Call Back, Call Transfer, and Conference Calling are value added if a particular VoIP service contains it. Do you agree with the view that it is undesirable to draw a distinction between the regulation of services that are perceived by customers to be identical to traditional services and those that do not? Agreed, so long as the Service provider is duly licensed by the TRC to provide such a service. Though the TRC prefers to remain technology neutral, references could be drawn as to the standards and protocols to be deployed by the service e.g. IP, SIP, H2xx, H3xx, Megaco. Do you agree with the view that no distinction should be drawn between the regulation of secondary line services and primary services? XPress Agrees, no distinction should be drawn between the regulation of secondary line services and primary services, the service provider should specify the functionality provided. Choice means that an individual can choose VoIP for their only service if they wish. Do you think that a threshold should be set at which new voice communication services should be regulated in the same way as traditional voice communication services? If a threshold should be set, should it be after a certain period of time (yearly), when particular services are launched or when the market or technology are judged to have changed sufficiently to merit review? Also, what parameters should the TRC consider? Disagree. TRC already has the right to periodically review existing regulation and services. Services should be specified, basic features tabled and no threshold set. 3

4 Section 3: Consumer Issues Do you agree that consumer information is required where services look and feel like a traditional telephone service but not where services are clearly different (e.g. PC based services)? Agree. Do you agree with a two stage approach to consumer information, o first to ensure the purchaser is aware of the nature of the service at the point of purchase, and; o Second to ensure all potential users are aware that, for example, the service may not provide access to emergency services at the point of use? XPress agrees. Consumer information including information on the differences in the services available and the availability and reliability of emergency services provided should be generally available (by way of a media campaign for example) as well as provided at the point of sales, as well as at the point of use, as the users of the service are likely to involve a wider group of people, rather than the purchaser alone. If consumer information is required to ensure that consumer interests are protected, which of the above regulatory frameworks (self regulation or co-regulation), if any, is most appropriate to ensure it is successful? Co-Regulation. The provision of IP based voice communications services is a new and developing market, and while XPress supports the objective of industry deciding on appropriate regulation, we would like to see the TRC involved until it is clear whether the industry is able to agree on regulation in a timely and comprehensive manner. If a co-regulatory framework turns out to be ineffective the TRC may need to make a code or guidelines mandatory. What in, practice, should the roles of the network operator versus the service provider be for network integrity when the service provider has little or no direct control over the services offered over the network? Connectivity in Jordan is controllable by Interconnection and other agreements therefore some sort of QoS should be expected. The Local Loop will become a service which is regulated/ monitored by TRC. 4

5 Section 4: Numbering, Location and Access Do you agree with the intent to use both Geographic and Non- Geographic numbers for IP based voice communication services? Agree Do you agree that the numbers allocated to both Geographic and Non- Geographic numbers for IP based voice communication services should be easily identifiable? VoIP services could be either Landline (Fixed line replacement) or PC based (soft phone). For Fixed Line competition it makes sense to be geographic as for the PSTN numbering plan today. For PC based (soft phone) it will have to be given a non-geographic number range for each soft phone. For services offered by the various companies it should follow the TRC numbering plan in existence today which provides for premium rate services and free calling numbers. What approach for emergency location would take account of current technical limitations, whilst ensuring that technical advances bring benefits to emergency organizations in the long run? Only Fixed line replacement could be associated with a general location (East Amman, West Amman, Zarqa, etc), it should be provided with location based Emergency calling depending upon the flexibility of the soft switch/voip gateway translations capabilities. For Non-Geographic it should be routed back to the service provider s Customer Center for routing to the appropriate Emergency center while in Jordan. Do you agree with the view that not all voice communication services should be required to offer access to and service from emergency services but that any decision about subscribing to and using such services must be properly informed? As indicated in the above text, some IP based voice communication services would equate to mobile, others may not. Disagree. An Emergency service is there for an emergency. This facility must be available to the subscriber of the service Fixed or Non-fixed. Do you feel that there is sufficiently high value in having access to and service from emergency services that it should be the case that there is an obligation on the customer to retain at least one means of highly reliable means of access (i.e. traditional telephone service) at a given location? XPress disagrees; the liability should only extend so far as to have the service provider make the facility available to contact such services. There should be no liability if the subscriber does not select a means of reaching the service. 5

6 Should IP based numbers have access to special (08) and premium rate (09) services hosted on the existing telephone network? Should TRC allocate blocks of special (08) and premium rate (09) numbers for services offered on an IP based network so that they are identifiable by the number range that is allocated to them? Disagree. Maintain the same numbering plan and arrangement for assigning and using the numbers until there is more experience with IP based services. Is it reasonable to allow nomadicity for IP based voice communication services?, for soft phone PC/laptop/PDA/VoIP mobile based users. If so, should there be different network integrity requirements for nomadic services compared to services at a fixed location, and how should consumers be made aware of this difference? Nomadicity is not Mobility. Mobility is within a given network or roaming to another network for which there is a mutual agreement to maintain some service levels. Nomadicity is taken to refer to the soft phone type user who may be connected by internet anywhere in the world or in Jordan. For such a user outside of the country there is no service guarantee that can be promised, controlled or monitored by an operator. The subscriber must be made aware of this. Section 5: Interconnection Should actual quality of service requirements for consumers and for the point of interconnection be applied to IP based operators in Jordan? Should the TRC introduce additional quality of service requirements? The consultation document issued by the TRC on the Quality of Service (QoS) Framework covers this subject. Should the established position on Carrier Selection and Carrier Pre- Selection extend to IP based providers? 6

7 Section 6: General Issues Should all commercially offered voice communication services be subject to licensing? What quality of service information should operators record and publish? Operators will record the Quality of Service (QoS) indicators mentioned in the final and published TRC document on the Quality of Service (QoS) Framework. As for publishing those indicators, it should be upon the discretion of the operator, as Quality of Service indicators could consist of sensitive information. If the operator provides the QoS indicators as confidential information, it should be treated as such. 7