Anyone that has watched an episode of the original NCIS will be familiar with Special Agent Leroy Jethro Gibbs’ rules. I don’t have a particular favourite, but in the context of recent news about number portability in the UK, Rule 39 would appear to be somewhat pertinent to number portability today.
There’s no such thing as coincidence.
On the face of it, the news that a grant of £700k has been made available to the Office of Communications (Ofcom) to explore the potential for blockchain technology to solve the well known inefficiencies in the process is very welcome. Where’s the coincidence? Well, BT have recently launched a proof of concept of blockchain in number management and portability. This is a proof of concept that has not been well received by all in the industry because of its fundamental bias against addressing the most substantive problems. Instead it initially focuses on elements of the process that work better in comparison. More specifically, it’s aimed at the residential market at the expense of the business market.
OK, so it’s just a proof of concept. And innovation in this area has been sorely lacking for many years.
But there’s a few wounds this is likely to pick at.
- The regulator mandated central database for number portability circa 2006 was overturned in court. BT enthusiastically cheer-leaded Vodafone’s appeal. The industry has a memory that would make an elephant proud.
- The billion-pound Broadband Development UK (BDUK) scheme was perceived by some as rewarding BT for historic under-investment.
- Some accuse BT of ongoing attempts to re-monopolise . There are some important, esoteric, reasons why manoeuvring yourself to be front and centre in number management and portability would help achieve this; especially as the former incumbent. (I won’t go into them here for fear of boring my readers more than normal).
Now, despite feelings that sometimes the regulator is soft on BT, there is absolutely no doubt in my mind that the application for the grant is very well intentioned and Ofcom will try to discharge their statutory obligation for fairness as best they can. After all, the industry has been banging on the regulator’s door for years about problems with number portability. Any innovation and improvement derived from a level playing field here is welcome.
However, the problem with number portability in the UK, first and foremost, is not one of the architecture. Day in, day out, thousands of numbers are exchanged between sensible, willing, co-operative networks without a problem. A nexus of professional relationships in those willing networks means issues are often addressed and resolved quickly by senior technical people.
The problem is where you have networks that are not willing participants in a grown-up porting regime, or dealing with them is like wading through treacle. Economically, they are well incentivised to hold onto a departing customer for as long as possible. This may seem like an esoteric problem, but I have seen individual cases where this has cost the public purse tens of thousands of pounds. It’s not uncommon for a network to forget it has exported a number and effectively cut someone off. Worse still, they can then go an reallocate the number to some random third party.
The current regulatory regime doesn’t lay down any rules for how long it should take to get a porting agreement between networks. I’ve seen it take two years – all that time, a business wanting to switch to a superior product or make a saving is held back. I’ve seen the definition of fair and reasonable stretched to include negotiating a porting agreement by post. You read that right; no emails of markups back and forth, but using the Royal Mail as an intermediary. There are no specific guidelines on fault resolution in porting either. Yes, the Office of the Telecommunications Adjudicator has a working group that publishes a very good best practice manual. But it has no force in regulation and is often ignored.
You can have a gold-plated, diamond encrusted, block-chain based process powered by unicorns but unless the regulator deals with the loop-holes which are so often exploited in switching, then nothing will improve. To that end, it is essential that this initiative has a specific scope. I would suggest as follows;
- Any improvement to the mechanics and architecture must be matched by a corresponding, universal, improvement in the service wrap.
- The funding available must not be used, directly or indirectly, to reward operators for historical under-investment or railroading previous attempts to improve the paradigm
- There can not be any inherent discrimination in the development of a process, between residential and business providers, small or large, single line or multi-line.
Personally, I think £700k would be better spent funding Ofcom intervening in the paradigm and setting more specific rules on overcoming real pain experienced by providers, consumers and businesses day in day out. The market will solve the architectural problems itself. Working together to comply with a revised regulatory environment is one of the UK industry’s unique selling points. But that ship has clearly sailed.
So instead, BT and Ofcom will attract the suspicious gaze of a beleaguered industry; like the Eye of Sauron, there’s going to be an intense focus on this development.
Normally I would now add a call to action to drive some business my way. Instead, here, it’s a matter of such significance, I would encourage you to engage with (or join) a trade association. ITSPA is an obvious choice, with ISPA and FCS also being worthy candidates depending on your niche.
In the meantime, I very much look forward to an End User benefiting paradigm shift in UK number portability. Who knows, Fulham might even win the Premiership too.
