Policy Statement & Submission

Our ref : 51/WKC/071
20 September 2002

Mr Francis Chan
Senior Telecommunication Engineer (EA1)
Office of the Telecommunications Authority
29/F Wu Chung House
213 Queen's Road East Wanchai
Hong Kong

Dear Mr Chan

Special Number Arrangement

Thank you for inviting the Chamber to comment on the above subject. The current consultation paper has moved much beyond the previous one in 1997. We have considered both the 1997 and the current paper and our comments are as follows.

Principle

Telecommunications number is a public resource. As certain numbers command a special value, part of that value should go back to the public, instead of being enjoyed exclusively by the users. We support, therefore, the principle that the allocation of special numbers should be regulated, and that the funding generated from the allocation process should be used for some public purpose.

The design of the most appropriate regulatory regime should, we believe, be guided by the principles of simplicity, fairness and transparency. We are not persuaded that a complicated structure and elaborate system is needed to administer the allocation of special numbers – a picture which seems to be outlined by the consultation paper. In our view, a relatively simple and straightforward system already exists in the case of auctioning of “lucky” vehicle plate numbers, which should provide a useful reference in the design of the allocation system for special numbers.

Two tier structure

Using the broad framework laid down in the 1997 Consultation Paper, we propose that the special telephone numbers be allocated under a two tier system, as follows.

Tier one: publicly administered special numbers. These should include the “golden numbers” corresponding to the primary special numbers, as well as the special number blocks and access codes.

The typical “golden” numbers should be auctioned by OFTA.
As in the case of vehicle plates, only individuals should be allowed to bid for end-user telephone numbers. There should be no time-limit on ownership but the numbers should not be transferable.
For business users, whether for an end-user telephone number or a special block/access code, the numbers should be allocated through auction but on a rental basis, i.e. OFTA should retain the right to re-gain and re-auction it after a period of time.
For currently owned special numbers, the existing right should be grandfathered.
The special numbers, once allocated, should be fully portable between network operators.
In the consultation paper it is proposed that the funding raised should be used for education and research in telecommunications. Although we have no objection to that, considering the current fiscal climate, we would also support the fund being channeled back into General Revenue.
Tier two: special numbers to be allocated by the market. These include the secondary special numbers and the consumer-requested special numbers. In both cases allocation would be administered by the network operators.

The “merit” or “golden” element for secondary special numbers is, as the name implies, secondary. OFTA should devise a simple mechanism to allocate these to network operators en bloc as well as generate revenue from these numbers. The operators should then be allowed to dispose of the numbers through the normal market mechanism.
Issues of transferability and portability of these numbers should also be decided by the market.
Some of the special numbers would be requested by consumers for a special reason, e.g. birthday. Their allocation should thus be a purely administrative matter and should be best left to the market.
I hope you find the above views useful.

Yours sincerely

Eden Woon
CEO