Number Portability for Mobile Services
Comments on OFTA Consultation Paper
Hong Kong Coalition of Service Industries
August 1997

1. The Hong Kong Coalition of Service Industries welcomes the opportunity to examine and respond to the OFTA consultation paper on number portability of mobile services. The following comments are based on consultation with members of the HKCSI Information Services Committee.

Desirability for number portability

2. The HKCSI agrees with OFTA's view that there are considerable merits in introducing number portability for mobile services for Hong Kong. We share the view that the inability of the subscriber to change operators without changing their telephone number is a barrier to competition which should be removed. We therefore support introducing number portability for mobile services as soon as practicable.
   

Architecture and re-routing options

3. There does not seem to be a compelling reason why the method of passing calls across networks has to be the same for all operators. Modern digital networks may choose to use an intelligent network platform while analogue networks could make longer term use of the call forwarding techniques applied during the fixed network "Interim Solution". The main criteria should be that the calls should arrive at the gateway between networks in an agreed or standardised format. How the calls get there would be up to the originating network operator who should be responsible for using the most appropriate method available to so deliver the call to the network interconnect gateway. We believe this would be in line with Option 1 of the OFTA paper on re-routing ported calls.
   
   
4. From our knowledge and understanding of the OFTA "non-centralized, homogeneous, off-line reference database" standard for FTNS number portability, (which the fixed network operators designed and agreed with OFTA then implemented successfully) this method is equally applicable to mobile operators and would enable fixed, mobile and international gateway operators to integrate into the same overall number portability management system. Ideally, all calls originating on one network, whether fixed or mobile, will be routed directly to the final destination network where the subscriber resides without any "tromoboned" or "spaghetti" calls via the original donor network. This should be in line with the way it now occurs with the fixed networks.
   
   
5. We would therefore favour an arrangement whereby the portability management system for mobile services would conform to and integrate with the agreed fixed network reference database system and performance.

Cost recovery

6. On cost recovery we believe the same principles as applied to the fixed networks should be conformed to.
   
   
7. As to mobile operators which may have a technical difficulty in upgrading their network capabilities, we agree with OFTA's initial view that these operators be permitted to rely on other fixed networks on commercial terms to perform the required translations on their behalf. Commercial competitive differences may however, make it unlikely to be agreeable to do this with another mobile operator.
   

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If you have any question, free to email us at csi@hkcsi.org.hk