Re: [Modern] Nationwide Number Portability MODERN Use Case Draft

Richard Shockey <richard@shockey.us> Mon, 29 February 2016 23:53 UTC

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Date: Mon, 29 Feb 2016 18:32:59 -0500
From: Richard Shockey <richard@shockey.us>
To: Henning Schulzrinne <Henning.Schulzrinne@fcc.gov>, Paul Kyzivat <pkyzivat@alum.mit.edu>, 'Modern List' <modern@ietf.org>
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Thread-Topic: [Modern] Nationwide Number Portability MODERN Use Case Draft
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Subject: Re: [Modern] Nationwide Number Portability MODERN Use Case Draft
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On 2/29/16, 5:14 PM, "Modern on behalf of Henning Schulzrinne" <modern-bounces@ietf.org on behalf of Henning.Schulzrinne@fcc.gov> wrote:

>I would have thought that the discussion about the LNP contract, foreshadowing in its acrimony and cost the current presidential contest (you pick the party...), would provide carriers with some incentive for more flexibility.


RS> It may be but it has to be balanced with the realities of the cost issue.  Shockey’s law “Money is the answer ..what is the question?”  TN allocation and management systems are deeply intrenched in the service activation systems within carriers. These OSS/BSS systems are terribly expensive and modifying them is an even more expensive proposition.  The general industry view is “If it aint broke, why do we need to fix it” given the overall CAPEX issues telecom carriers face in a era of rapidly declining over voice revenues. 

“What does this buy us?” 

Which is again the opposite of the STIR use case.. The trust model for calls is definitely broken and there is consensus that a solution is desperately needed now. Which is my point on IP interconnection data. The current system is insane and everyone knows has to be fixed. I certainly think there is progress there and the protocol could be wrapped up this year if Jon can make his drafts legible and we can see some actual examples how the INVITE’s actually look in practice. 

I just don’t see any support in the numbering community right on the allocation or NP use case especially among the industry advisory committees. Its just not a problem that needs fixing.  NG-NP is a problem now for perfectly ligitmate competitive issues that Congress has identified and informed the Commission of in no uncertain terms. The Chairman has made his views perfectly clear and the NANC, among others will work the issue in the usual manner. It may take 5-7 years but that is the reality but we can increase the size of the NANP by 20% as you well know.  

The last piece of the puzzle is one we are starting to debate in our NNI TF which is how validation data would displayed on user agents.  There are multiple approaches to the problem and multiple means of transport. What works for VoLTE, or enterprises is not what would work for cable. And there is not very much we can do for TDM networks. The issue is where can the carrier stuff the data into the INVITE as it touches the UA.   My preference is for some extension to the CALL-INFO header but in any event 3GPP is starting to look at that in SA-3 and I think we need to see where that work is going first. 


>
>I'm not sure why you consider the effort "US centric". I suspect almost all countries will be faced with the IP transition and, in particular, with upgrading the existing number portability system, if they have one, or creating one. The current number portability (whether or not it's geographic) leaves much to be desired, as recent events (https://www.fcc.gov/document/fcc-plans-296-million-fine-slamming-cramming-and-obstruction-0 makes a good read) illustrate.

RS> Well the US system for NP, is not perfect its a heck of a lot better that what I see globally, I grant that. Take the case of the UK. First the last time they had to revise the numbering plan for +44 it took out a Minister or two and every time the subject of LNP comes up our mutual friends on the Embankment run for the hills. I still have problems undertaking work where the actual user community has not weighed in on requirements. I’d feel a lot better if there was some input from BEREC for instance.

http://berec.europa.eu/


>
>Collectively, we don't do well with tech predictions. (Speaking from some experience, none of the VoIP protocols were on anybody's "gap list.") Sometimes protocols that everybody thought we needed fail to find use, sometimes they make unexpected experiences (RSVP-TE comes to mind). But having an open protocol is invariably better than winging it or letting lawyers design it.


RS> MIME? :-) 

> 
>
>One important test case is whether the MODERN proposals can implement the current industry structure, in both the geographic and 800# space. If not, there's clearly a gap. Thus, maybe you can help point out the specific features that would need to be supported to implement a version of today's policies, possibly with more formal down-delegation to facilitate tracking, and possibly multiple "registrars", as exists today in the 800# space. (As you know, today we often don't have a good idea of who is actually using a number, given informal "delegation" and reselling-that-doesn't-dare-call-itself-that.)

RS> Well you will get NO argument from me about the 800 toll free numbering problem.  That has been a festering sore in North America for eons.  If MODERN would focus on that application alone it would be worth the effort and again be a useful means to insert the technology into the industry.  My concerns are at cost to the industry first and tactically second.   My point is that MODERN would be a wasted effort if the focus centered on a use case on one wants and no one would implement driven by some political desire to undercut the structure of telephone naming and addressing in order to beat up on the carriers or promote some companies existing or future business models.  I have enough arrows in my back from the ENUM wars to speak with some authority here.  



>
>Henning
>
>________________________________________
>From: Modern <modern-bounces@ietf.org> on behalf of Richard Shockey <richard@shockey.us>
>Sent: Friday, February 26, 2016 12:47 PM
>To: Paul Kyzivat; 'Modern List'
>Subject: Re: [Modern] Nationwide Number Portability MODERN Use Case Draft
>
>
>>But us end users regard the numbers as *ours*. The fact that we must go,
>>hat in hand, to our carrier and beg for any sort of administration of
>>that number is a *problem*, not a feature. Anything that will give us
>>more control over *our* numbers is a *good* thing!
>>
>>I have no illusions that the carriers share this opinion. I do hope that
>>the FCC does.
>
>RS> There is progress. Non traditional carriers now have access to the numbering plan ( yes even Google voice) directly but even the simplest reform ..National Geographic Number Portability for instance creates a hornets nest of orthogonal issues (rate centers LATA) that have to be resolved before it can be implemented and the rules have to change ( that is a FCC Notice of Proposed Rule Making BTW) and that is a political problem not a issue for the IETF to resolve. Contrary to what Tom says the existing technology can work reasonably well for NG-NP without imposing unreasonable costs on traditional telephony service providers.  Yours truly is living through that little fustercluck right now.
>
>
>
>My contention is still that MODERN is putting the cart before the horse and looks way way to US specific. The proposed use cases are unimplementable given the current set of regulations, the structure of the industry and does not actually solve a real problem.  There is no business case here which I suspect something else is going on.  The real problem is IP interconnection data ( aka NG ENUM) a system distributed synchronized registries is desperately needed NOW and could be widely implemented quickly as a greenfield technology. Once you build on success you can add some of these other use cases as the regulatory structures evolve, which usually takes a decade and endless ex parte filings in the public record.
>
>As it stands now MODERN is trying to build something that no one wants and no carrier will ever implement ( gee sounds like 6116 ).
>
>This is the exact opposite of the STIR proposition.  STIR is actually addressing a serious international problem where there is ample evidence the regulators and the legislators are desperate for a solution.
>
>Call SpoofingBipartisan Anti-Spoofing Bill Introduced
>Sens. Deb Fischer (R-Neb.) and Bill Nelson (D-Fla.) introduced
>
>http://www.fischer.senate.gov/public/index.cfm/news?ID=F135ABD9-C427-464F-853D-E95509AFA93F
>
>Legislation
>
>https://prodnet.www.neca.org/publicationsdocs/wwpdf/22216bill.pdf
>
>
>
>
>>
>>       Thanks,
>>       Paul
>>
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>
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