by Eamon Holley, Senior Legal Consultant, DLA Piper (Dubai)

How can something infinite still be a scarce resource?  In telecoms that’s exactly what numbers are considered, and they are managed carefully by regulators and operators alike.  And with the advent of many more new communications services, this regulation and management is becoming ever more complex and necessary.

Pennsylvania 65000

Anyone who has made a phone call or owned a phone (everyone reading this?), has had to call a phone number or be called on a phone number – it can be a powerful identifier.  Do you remember a home phone number from your childhood?  Do you remember the number of your favourite takeaway?  But do you remember the number of your spouse?  Or your friend’s new number?  Or are these numbers just stored in your smartphone under their name or photo?

From a technical point of view, numbers are necessary to route calls to their destinations.  Traditionally, they identify locations – from countries, to regions, cities, local areas and exchanges and, finally, the premises.  With the advent of mobile phones, numbers became identified with SIM cards and also became mobile, although still identified to a network. Internet Protocol and IP addresses changed the game again, by identifying devices which can be also mobile or at least portable.

Lucky 7s

Numbers are necessary for the sending of a message from point A to point B. Given their bland technical necessity, one might wonder why people become so emotionally attached to a number. Also, given the advent of smart phone technology and other forms of communications services that don’t rely upon the end user remembering a number (Skype, Whatsapp etc.), the significance of a number for the end user may be diminishing somewhat.

Some numbers are still considered to be socially valuable, such as emergency services numbers, and there is almost a taboo against their abuse (if not an actual offence).  Some numbers are considered “nice” numbers, and are considered by some to be very financially valuable – recently the number 77777777 was auctioned in the UAE for 7,877,777 dirhams  (about US$2,100,000).  Clearly, the buyer saw the value in callers having to only press the lower left hand digit on a dial pad eight times.

So a phone number can be more precious than many people, at first blush, might think.  The popularity of number portability, the ability to carry a number from one place to another, or one network to another, is evidence of how much stock people place on keeping a number with them, if only because they don’t need to advertise to everyone they know about their new phone number.

1 in 26 billion

With the explosion of the human use of mobile phone services around the world combined with the new wave of M2M services and the anticipated “Internet of Things” (“IOT”), numbering resources are becoming ever more important, and strained. Their management, if only to avoid confusion in identifying locations or objects, is vital for the system to work. Gartner expect that by 2020 there could be up to 26 billion devices connected to the internet. Each one will need an identifying number.

So what is a numbering resource? Isn’t it just 1, 2, 3, 4, 5… until the never end? How are they managed?

At the top level, telephone numbers are managed by the International Telecommunications Union, which has issued a recommendation known as E.164, for international public telecommunications.  E.164 “provides the number structure and functionality for the five categories of numbers used for international public telecommunication: geographic areas, global services, Networks, groups of countries (GoC) and resources for trials[1].”

In turn, national regulatory bodies manage their domestic numbering plans, between regions, operators, and services; for example, emergency services, so called “free phone services”, or short code phone numbers that might be used for free calls to competitions or companies etc.

In most of these national systems the numbers are considered scarce national resources and are deemed to be the property of the government. They are not owned by the operator or the end user. However, although it might not be “your” number, many systems allow some form of portability, as discussed above. This flexibility has its limits, and so it is highly unlikely that you can, for instance, gift your phone number to a loved one in a will.

The number crunch

As more devices are connected to the internet, and these devices converge more services together, the management of numbers is becoming more complex.  In the CEPT/ECC Working Group for Numbering and Networks 2013 Greenpaper (“Greenpaper“), the working group anticipates that E.164 will remain the international standard for numbering[2]. However, a major transition will be the replacement of the prevalence of numbers as identifiers for people, with names and photos.  This conversion will be handled by technologies such as ENUM or mapping numbers using SIP addresses.   The ENUM system allows phone number to be mapped on a Domain Name System, effectively making them part of the internet system.

However, while that might work for people based interfaces, M2M services will still need numbers, and as most M2M services use SIM cards they will likely use E.164 numbers. The anticipated explosion of M2M services and the eventual IOT, is expected to put a strain on these numbering systems. Some regulatory bodies have taken action in this regard.  For instance, the Saudi Arabian regulator has implemented an M2M numbering range in its national numbering plan (coupled with a license for Automated Vehicle Location Systems).  However other regulatory bodies don’t appear to be facing up to this issue yet. This raises an interesting prospect: as numbering plans run out of numbers, but the demand for M2M services increases, CEPT/ECC anticipate that some M2M players may use the numbering ranges of another country, which the working group sees as potentially “…causing many problems in areas such as numbering plan administration, number portability, law-enforcement, localisation in case of an emergency call and possibility to evade from national regulatory requirements”[3].

Your number is up

The convergence of services and technology means that there has also been a convergence of various numbering regimes of traditional telephony with IP numbering and various mapping systems that allow these numbers to convert to other identifiers such as names or addresses.  Apart from simple human interactions, M2M services and the IOT are expected to mushroom and put further pressure on all communications resources, including numbering.  It remains to be seen how this will be actively managed, but one thing seems certain; the days of a telecom regulator’s traditional numbering plan seem, well, numbered.

(PS. We dialled the UAE number, 77777777, which is, unsurprisingly, “disconnected”)