Internet Thought (on hiatus)

Speaking on Connected Television at IIC/Ofcom on May 2nd

noreply@blogger.com (Rudolf van der Berg) — Wed, 01 May 2013 09:23:00 +0000

It has been very quiet here for a while. I am of course active on Twitter, but I heard some of my readers don't use Twitter (you should, it is practical, don't tweet, just follow)

May 2nd I will be in London speaking on Connected Television. If you are around, leave a message. Maybe we can do coffee on May 3rd (or a beer late in the evening)

Connected TV and Platforms: evolution or revolution?

International Institute of Communications
UK Chapter Event

Connected TV and Platforms: evolution or revolution?
Market trends, dynamics, and policy implications

Thursday 2 May 2013, 17:00 for 17:30 Start

Kindly hosted by Ofcom
Riverside House, 2a Southwark Bridge Road, London SE1 9HA

In yet another sign that convergence is finally upon us, TV sets are increasingly connected to the Internet, and advertising for television sets seems increasingly to focus on which ‘cool apps’ they feature, rather than their size or picture quality. And it’s not just TVs: DVD players or PVRs now come connected to the Internet. The possibilities are vast, yet this is only a nascent market – and one which already raises many questions.

How prevalent will Connected TVs become in coming years? What impact will they have on the delivery of online and broadcasting content? How will broadband television change the TV market? What changes can be expect from Satellite TV? How will demand and usage patterns for connected TV evolve? Are there risks of vertical integration and generally for competition? Will the second screen be the interactive part of television? And for the legal wonks: what are the implications for content regulation and audience protection, and should the Audiovisual Media Services Directive (AVMS) be revised or renewed to accommodate the development of a connected device market?

To discuss this exciting and rapidly evolving phenomenon we will hear from a range of speakers, from different industries and from the public and private sectors:

- David Mahoney, Director of Policy Development, Ofcom, will host and moderate the discussion

- Marcel Boulogne, European Commission

- Rudolf van der Berg, OECD

- Chris Hutchins, Vice-President, EU Affairs, Liberty Global

Numbers are limited and you are advised to register as soon as possible. Attendance is free to IIC Members and £30 for non-Members.

Please note that registration for this event is now closed. Please contact j.grimshaw@iicom.org with CH1-13 in the subject heading for further information.

For IIC membership details please contact the IIC at enquiries@iicom.org.

DATE FOR DIARY: 21 MAY: 4G – Prospects, concerns and policy implications.

For further information or to register your interest contact j.grimshaw@iicom.org.

For enquiries please contact the IIC secretariat on +44 (0)20 8417 0600.

Interview and Conference on The Internet of Things

noreply@blogger.com (Rudolf van der Berg) — Tue, 25 Sep 2012 09:31:00 +0000

In COMMUNICATIONS & STRATEGIES No. 87, 3rd quarter 2012 Internet of Things: A new avenue of research there is an interview with me conducted by Martin Cave. I go into the many aspects of IoT and discuss the policy implications. The interview has been published online and you can see it here

There is also a conference at Telecom ParisTech where those who have written articles and those that were interviewed will present. http://innovation-regulation2.telecom-paristech.fr/wp-content/uploads/2012/09/Programme.pdf (the conference is tomorrow, so you need to be quick.

Presentation on M2M and market failure at Internet of Things-week

noreply@blogger.com (Rudolf van der Berg) — Tue, 26 Jun 2012 07:59:00 +0000

Last week I was invited to the European Commission's expert group on the Internet of Things to speak on OECD work. It was in Venice during Internet of Things-week, which sounds great until you realize it was 35 degrees Celsisus outside and 40 degrees inside. The European Commission currently is doing a consultation on the Internet of Things, so if you have opinions, voice them! Unsurprisingly maybe, I put the focus on market failure that currently impedes the growth of the Internet of Things.

Update: Here are some links to where I got the data:
- http://stakeholders.ofcom.org.uk/binaries/research/telecoms-research/not-spots/PA_Consulting_main_report.pdf on coverage
- https://ripe64.ripe.net/presentations/172-Mobile_Broadband_Measurements.pdf that 20% of locations are unavailable more than 10 mins/day

Policy Brief on Internet of Things and Transport

noreply@blogger.com (Rudolf van der Berg) — Wed, 18 Apr 2012 08:23:00 +0000

The International Transport Forum at the OECD is an intergovernmental organisation with 53 member countries. It acts as a strategic think tank for transport policy and organises an annual summit of ministers. For this years summit on Seamless Transport I wrote a policy brief on the Internet of Things and Transport.

Building the "Internet of Things"
In the coming years the Internet will move from connecting people to connecting things. In a new report entitled “Machine to Machine (M2M) communication: Connecting billions of devices”, the OECD analyses the
impact of this phenomenon. The report

finds new sources of growth
identifies significant barriers to the functioning of the market
proposes liberalisation to further open the mobile telecom market, to enable new entrants that may be transport, energy and healthcare companies, not telecom providers
argues to support trade and travel for manufacturers and service providers in providing these services across borders,
argues that removing barriers will result in billions in direct and indirect savings on mobile connectivity, and additional billions in new revenue from new services.

In 2017, in OECD-countries an average family with two teenagers could have 25 things that are connected to the Internet: telephones, TV, tablets, printers, sports gear and health devices. But that is not all. Companies will dramatically change the way they design machines and devices, starting from the type of data they need to operate efficiently and effectively and then building the machine or device around it. Tens of billions of connected devices by 2025 is not farfetched. The combination of the data will allow smart transport, smart
cities, smart energy and smart health. for more see http://www.internationaltransportforum.org/jtrc/PolicyBriefs/PDFs/2012-04-04.pdf

Presentation at Telecom Reform Conference 2012

noreply@blogger.com (Rudolf van der Berg) — Thu, 22 Mar 2012 16:12:00 +0000

I presented at the Telecom Reform Conference in Copenhagen. Good conference. The 1969 reference in the disclaimer is to Bill Melody's presentation at the OECD on the Carterfone decision. Bill Melody was also one of the organizers of this conference. BTW 1969 is way before I was born. Nice little anecdote, in 1969 liberalisation wasn't even an acceptable topic to the US delegation to the OECD. We've come a long way since then.

(Just noticed that the nice graphs I had on Roaming and MTR's didn't get included in the Google Docs version. If you have a solution, please mail me. If you want to see them, look here (roaming) and here (MTR)

OECD report on "Developments in Mobile Termination"

noreply@blogger.com (Rudolf van der Berg) — Thu, 01 Mar 2012 12:27:00 +0000

As part of the OECD’s ongoing work to stimulate competition and innovation in mobile phone markets (see here for most recent news release on mobile roaming), this new working paper aims to contribute to the current debate among regulators in OECD countries who are reducing or considering the phasing out of the fees telecommunication network operators pay for delivering telephone calls to mobile wireless providers, known as mobile termination rates (MTRs). This is because mobile operators have a monopoly over the termination of calls on their networks.

While it finds that rates have decreased across the OECD by 53% between 2006 and 2011, from USD 0.1406 in 2006 to USD 0.0650 per minute, there is still much divergence between countries. Rates are at zero in Canada and vary from the lowest (the United States (USD 0.0007/min), Israel and Turkey (USD 0.0203/min) to the highest, including Estonia (USD 0.142/min) and Chile (USD 0.165/min).

The complexity and difference in the way that operators charge fees makes it difficult to draw a link between rates charged and prices paid by users for voice calls in different countries. But cutting rates to zero would strengthen competition in voice and other services, says the report. It could also speed up the introduction of innovative new VoIP services and encourage providers to offer a range of tariff models to meet the needs of their users, free from prices reflecting monopoly power on the networks of others.

Developments in Mobile Termination is available at http://dx.doi.org/10.1787/5k9f97dxnd9r-en.
All the data in an excel file is available here: http://www.oecd.org/dataoecd/25/44/49805921.xlsx

The author Rudolf van der Berg is also available to answer any questions at +(33) 1 45 24 93 67, (+33) 6 58 15 85 08, or rudolf.vanderberg@oecd.org

OECD publishes report on Internet of Things and M2M

noreply@blogger.com (Rudolf van der Berg) — Wed, 01 Feb 2012 10:56:00 +0000

Look around you for a second and count the number of electronic devices, machines and gadgets. All of them -- light bulbs, cars, TVs, digital cameras, refrigerators, stereos, cranes, beds – will be connected to the Internet over the next 15 years, if they aren’t already.

Farmers will connect their livestock, machinery and fields through sensors. Medical practitioners and patients, fitness fanatics and those of us that require greater encouragement, will be monitored for everything from our heart rates to glucose levels to the special needs of pregnancy.

This is the potential of the “Internet of Things”: billions and billions of devices and their components connected to one another via the Internet. 50 billion devices by 2020, according to companies like Ericsson. The “Internet of Things” will radically alter our world through “smart” connectivity, save time and resources, and provide opportunities for innovation and economic growth.

The basic building block of the “Internet of Things” is machine-to-machine communication (M2M), devices equipped to communicate without the intervention of humans. The trends are already visible: Internet-connected TVs are now widespread; eBook readers must have a Wi-Fi or 3G connection; smart electricity meters have already become standard in many countries. More often than not, however, M2M is hiding in plain sight: information terminals in trains and buses, traffic lights and bicycle sharing systems, like the ones in Paris and London.

This new “Internet of Things” is the subject of a new OECD-report, “Machine-to-Machine Communication: Connecting Billionsof Devices”, and examines:

1. New Technology: the drivers behind connecting devices to the Internet

2. New Markets: user and business demands, and whether they are being effectively met

3. New Policies: what governments can do to promote this new source of growth

New Technology

- The Internet of Things is enabled by ever cheaper communication modules, new innovations and applications of existing technology and the fact that the Internet has become available almost anywhere that people are.

- M2M is very different from traditional telecommunication. It does not need a human to start or stop a communication. As a result it has the same economical life span as the product in which it is embedded (10 years for consumer electronics, 15 years for cars, 30 years for smart meters). It can process extremely low data volume or very high amounts.

- Different networking technologies can be used to connect M2M devices, depending on the amount of mobility needed and dispersion over an area. 2G/3G/4G mobile wireless is, however, often an ideal technology for most applications.

- SIM-cards could become the standard for authentication to use networks, as this removes or reduces the need for human interaction. Devices can be connected straight from the factory.

Table 1. Machine-to-machine applications and technologies, by dispersion and mobility

Geographically dispersed	Application: smart grid, meter, city remote monitoring Technology Required: PSTN, broadband, 2G/3G/4G, power line communication	Application: car automation, eHealth, logistics, portable consumer electronics Technology Required: 2G/3G/4G, satellite
Geographically concentrated	Application: smart home, factory automation, eHealth Technology Required: wireless personal area (WPA), networks, wired networks, indoor electrical wiring, Wi-Fi	Application: on-site logistics Technology Required: Wi-Fi, WPAN
	Geographically fixed	Geographically mobile

New Markets

- M2M creates a new player in the mobile market: the “million device” user. These new large scale M2M users will potentially manage hundreds of thousands of smart meters, cars, and consumer electronics, possibly in higher numbers than some countries have citizens.

- Large scale M2M users may offer their services in 10s to 100s of countries, selling the same devices globally. Their customers may buy the devices abroad and travel with them. As a result, manufacturers need to offer international connectivity solutions. The telecommunication industry, however, is still largely organised and regulated on a per country basis. Large M2M users will thus place new demands on telecom companies, and regulation and business models will have to adapt.

- Companies creating innovative M2M-based services are currently locked into 10-30 year mobile data contracts and high roaming fees; this dependency hinders the role out of new services and innovation.

New Policies

- Governments hold the key to set large scale M2M users free, by giving them access to wholesale markets. They will need to change the rules so that large M2M users can have access to numbers and SIM-cards, just like telecom companies have now. This will open up the market, break lock-ins, make large M2M users responsible for their own innovation and create a competitive market for roaming for M2M services. This liberalisation of the market will be a major paradigm shift, but might by some estimates lead to billions in savings and new services.

- Privacy and security need to be designed into products from the start. M2M could allow a detailed view of people’s lives, and parliaments have already curbed or changed some projects as a consequence. For example, cars are increasingly using onboard M2M services (GM Onstar, Ford Sync, BMW ConnectedDrive) and the European Union is now mandating their own service (eCall) to be built into every car from 2014. Since EU legislation requires telephone companies to record a person’s location at the start of each mobile communication, and since turning a M2M car on will itself start a communication, these companies will be inadvertently tracking the start and end of any trip! The current challenge requires privacy by design, because as this example shows, even if the automobile company does not register the location, the telecommunication company by law will have to.

- Governments have tried to make spectrum policy more flexible in recent years, allowing companies to change networking technologies when new technology becomes available. M2M may rigidify spectrum policy, however, because any time M2M uses a particular networking technology, it expects the spectrum to be there for the lifetime of the device, which is 10 to 30 years. The consumer-oriented wireless technology works on a timescale of a maximum 10 years.

- Countries may run out of phone numbers in their current numbering plans as a result of M2M, because 2G and 3G equipped M2M devices require an E.164 telephone number to work. Only when 4G is used can M2M work with just an IP-address.

- It is unclear which country should issue telephone numbers for any given device. Is it the country that device is used in, the country of the mobile operator, or the country of the large scale M2M user?

- Combining data generated by M2M devices may offer great insights to improve society. Cars could notify local governments of icy roads or bottlenecks in infrastructures. This may not always be seen as positive, however, as shown by a case in The Netherlands where anonymous and aggregated data from GPS-systems was used by the police to identify prime locations for speed cameras, which led to a public outcry.

What is certain from the report is that governments will have to change regulations in the telecommunications market, will have to be vigilant to apply privacy and security regulation and stay innovative to make use of the many possibilities it offers. Doing so promises to transform the economy, promote growth in the telecommunications sector, and produce growth and efficiency savings in government and society.

Slides available: BEREC expert workshop on IP-Interconnection (Peering and Transit) in cooperation with OECD

noreply@blogger.com (Rudolf van der Berg) — Tue, 20 Dec 2011 10:18:00 +0000

Update: BEREC website was redesigned and the slides fell off. They can still be found here in this open directory http://berec.mp.bi.lv/files/doc/berec/oecd/
On November 2nd, BEREC organized a workshop on IP-interconnection together with the OECD. All the slides are now available online. And to save you from reading the whole post, here they are:

Dennis Weller, Senior Advisor, Navigant Economics "IP Traffic Exchange; Market Developments and Policy Challenges"
Martin Levy, Director, Hurricane Electric "The Background of Internet Interconnection"
Scott Marcus, Director, WIK-Consult, "IP interconnection, traffic trends, and wholesale and retail prices"
Bill Krogfoss, Strategy Director, Chief Technology Office Alcatel-Lucent "Internet Economy and Content Peering"
Falk von Bornstaedt, Head of Peering, Deutsche Telekom "IP Interconnection and differentiated QoS."
Patrick Gilmore, Chief Architect, Akamai
Eric Ralph, Chief Economist of the Wireline Competition Bureau, FCC (Video message
and teleconference); (no guarantee that the video works).

This was a direct result of the OECD High Level Meeting on the Internet Economy in June, where through conversations in the halls we noticed that there was a difference in the way regulators and Internet peering coordinators discussed interconnection. The workshop was a huge success, several people from the internet peering community flew in from Vienna for one day even though there was a RIPE-meeting going on too.

A couple of points to take away from the meeting are:

Peering agreements are for 95%+ handshake agreements, without any involvement of lawyers. They take 3 minutes to set up technically.
Both content providers and eyeball networks are working on getting content closer, faster and cheaper to the consumer. This benefits both parties. An interesting example were Google Global Caches which are now placed in networks around the world, but whose effect can most profoundly be seen in Africa where for instance the traffic over the Kenya Internet Exchange Point increased by several hundreds megabit/s peak after a cache was installed, saving the local internet community hundred thousands of dollars every month
The market for peering and transit is highly competitive and highly dynamic, with switching barriers being extremely low. A change in routing from one transit provider to another can literally be done in minutes. The effect of a peering agreement is almost immediate.
The people whose job it is to interconnect IP-networks speak of themselves as a community, even though some of them disagree quite considerably on how it should be done and who plays what role.
Peering and transit is done between all kinds of networks, even the European Commission has an AS-number and could set up it's own peerings.

I think everyone looks back at a very successful event, that was seated to capacity.

BEREC expert workshop on IP-Interconnection in cooperation with OECD

November 2nd, Bloom Hotel Brussels, 9:00-17:30

The goal of the workshop is to bring experts from the IP- interconnection community in contact with experts on interconnection from national regulatory authorities and to discuss future interconnection in an all-IP world.

The Internet’s way of using peering and transit as the basis for commercial negotiations differs considerably from the telephony’s world of Calling Party’s Network Pays. As a result even when talking the two worlds seem to be speaking about different things even when using the same words.

BEREC has been looking into these different approaches to interconnection in a series of papers since 2007 (ERG Report on IP-Interconnection 2007, ERG Common Statement on Regulatory Principles of IP Interconnection 2008, BEREC Common Statement on NGN future charging mechanisms, 2010). The OECD has studied Internet traffic exchange in a series of reports in 1998, 2002, 2005 and in a forthcoming paper in 2011. Furthermore, it has studied Internet traffic exchange in relation to the development of local content in cooperation with UNESCO and it has also organized a workshop on the topic in 2001 in cooperation with the German government. IP-interconnection markets are global markets crossing national borders and even continents. Therefore the OECD is singular in its analysis of trends in Internet interconnection taking a global perspective. Following the same objective of safeguarding competition, BEREC and the OECD take this workshop as a starting point hopefully to be continued in the future.

The format of the 4 session is intended to allow for an extensive discussion with the audience.

Programme
9:00-9:30 Registration and Coffee

9:30 – 10:00 Opening words by Monica Ariño, BEREC and Sam Paltridge, OECD

10:00-11:30 Session 1: The background of Internet interconnection
The goal of this session is to outline the basics of Internet interconnection.
Technical background: Peering (paid or free), transit, partial transit, variants (reciprocal transit
etc.), “Public” versus private, application needs for QoS.

Dennis Weller, Senior Advisor, Navigant Economics "IP Traffic Exchange; Market Developments and Policy Challenges"
Martin Levy, Director, Hurricaine Electric "The Background of Internet Interconnection"

11:30-12:00 Coffee break

12:00-13:00 Session 2: IP interconnection, traffic trends, and implications for
wholesale and retail prices
The interconnection of internet networks has been described in terms of two-sided networks.
The network provider stands in the middle and can receive money from either the content
provider or the consumer. Is this description of the market accurate? What can the theory of
two-sided markets teach us? What contribution can content providers give to the deployment
of networks or alternatively what is the role of network providers in content?

Scott Marcus, Director, WIK-Consult, "IP interconnection, traffic trends, and wholesale and retail prices"
Bill Krogfoss, Strategy Director, Chief Technology Office Alcatel-Lucent "Internet Economy and Content Peering"

13:00-14:00 Lunch

14:00-15:30 Session 3: IP Interconnection and differentiated QoS

Mike Blanche, Program Manager - Network, Peering and Content Distribution, Google,
Falk von Bornstaedt, Head of Peering, Deutsche Telekom "IP Interconnection and differentiated QoS."
Patrick Gilmore, Chief Architect, Akamai

15:30-16:00 Coffee Break

16:00-17:10 Session 4: The Future of Interconnection
The Internet hasn’t done away with telephony as a very important means of communication. The growth of mobile telephony has even been more dramatic than the growth of Internet. There have been calls in academic journals and on regulators directly to both impose the Internet’s way of interconnection on telephony and vice versa the telephony’s way interconnection on the Internet.

Can we expect the market to evolve into one model or the other for all traffic?
Could a hybrid model evolve?
What role will new services on networks play? Will new demands be placed on
interconnection?
What characteristics of both models should survive?

Panel:

Eric Ralph, Chief Economist of the Wireline Competition Bureau, FCC (Video message
and telco);
Andreas Sturm, De-Cix;
Mike Blanche, Falk v. Bornstaedt, Patrick Gilmore; Martin Levy

17:10-17:30 Wrap-up

Cara Schwarz-Schilling, BEREC and Rudolf van der Berg, OECD

Will speak at FTTH Forum Budapest on Nov 9

noreply@blogger.com (Rudolf van der Berg) — Tue, 08 Nov 2011 11:46:00 +0000

I will speak at the FTTH Forum in Budapest tomorrow. Always interested in meeting up with people. Many people of the so called Fiber Ring will be there ie Benoit Felten, Costas Troulos and James Enck

New presentation on Machine to Machine communication

noreply@blogger.com (Rudolf van der Berg) — Thu, 30 Jun 2011 16:47:00 +0000

I recently gave a presentation on Machine to Machine Communication to the Dutch Telecommunication User Group, BTG. This was based on work I have done at Logica. The presentation represent my own thoughts and not those of my employer. I am still working on the topic and am interested in hearing anyones views on the topic.

M2 m implications for btg

View more presentations from Raindeer

Born: Tycho Rudolf Willem

noreply@blogger.com (Rudolf van der Berg) — Sun, 12 Jun 2011 12:01:00 +0000

The blog is on semi-hiatus, but I thought some of you would appreciate this news. On Wednesday June 8th our son Tycho Rudolf Willem was born in Almere, The Netherlands. He is the little brother of Grace :-) Mother and son are doing great. Pictures available on request :-) And yes, I was present, the two days before were spent in OECD working groups in Paris, discussing two papers I wrote with member countries.

I'll be speaking on WIK's conference on Bundling and Multi-Play

noreply@blogger.com (Rudolf van der Berg) — Sat, 28 May 2011 22:38:00 +0000

I'll be presenting at "Bundling and multi-play: Does it require a new regulatory paradigm?". This conference organized by the German WIK-Consult is held Monday and Tuesday in Brussels. I'll present OECD-work on Bundling, which was published last year. It's not my work, but the responsible colleagues were otherwise disposed or had changed to other jobs. The line up of speakers is quite interesting.

First blogpost for the OECD... on International Women's Day (of course)

noreply@blogger.com (Rudolf van der Berg) — Thu, 10 Mar 2011 09:39:00 +0000

Working for the OECD may mean this blog is on hiatus, but that doesn't mean I stop blogging completely. Fortunately the OECD has some blogs and I've been allowed to write on International Women's Day. It's not a topic I'm an expert in, but as always I can have an opinion and I've got some skills in writing it down, so for your pleasure:

May the best (wo)man win

MARCH 10, 2011

by Guest author

8 March is the centenary of International Women’s Day. This year, we mark the occasion with a series of blog posts about initiatives to strengthen gender equality worldwide. In this post, Rudolf van der Berg of the OECD’sScience, Technology and Industry Directoratediscusses sex discrimination in management.

As we celebrate the centenary of International Women’s Day, in OECD countries still only 5%-30% of senior management is female. This is often discussed in the context of right and wrong. But let’s look at it from the perspective of competences and economic performance.

The argument for there being so few women in management positions is that they just aren’t available and that the best person for the job needs to be promoted. However, with educational equality being the norm and girls and women actually performing better than boys and men in education, this argument seems to hold less than it did a hundred years ago on the first International Women’s Day.

The simple conclusion we have to draw from the numbers is that if competences and chances were distributed equally, we would see roughly 50% women on boards. Unfortunately we aren’t seeing this. We still see far less.

The sobering conclusion is that if our societies were more equal, 40% of the men in some form of management today wouldn’t be in that position. They are not competent enough, given the pool of talented women. However, since managers are continuing the practice of selecting men over women for any management position in the organization, this means they are dipping deeper into the pool of available men and pushing lesser qualified men up to positions they shouldn’t have been in.

The consequence of this is that the position of men in organizations is supported by a whole column of lesser qualified men, crowding out women and in their own self-interest keeping those women out.

That this has negative effects on the performance of companies is clear. In a series of studies byCatalyst, Fortune 500 companies with more women board directors are shown to have significantly better financial performance, including 53% higher returns on equity, 42% higher returns to sales, and 66% higher returns on invested capital.

If shareholder value or government effectiveness and efficiency is dependent upon having the right people in the right place, it is time CEOs and Ministers start looking around and down and wondering which of the men they see in management is the weakest link, and where in the company the more qualified woman has ended up.

Useful links

OECD work on corporate affairs

OECD work on gender

WikiGender

Wikiprogress

This blog is going on (semi-)hiatus

noreply@blogger.com (Rudolf van der Berg) — Wed, 05 Jan 2011 14:44:00 +0000

It has been a blast to be writing blogposts here. It was conceived as a way for me to vent of the ideas in my head and to be in contact with others who are interested in telecoms. Over 350 people now subscribe to my feed, articles get read and linked to. I've actually become a bit known in the industry because of you my readers, reacting and forwarding the articles.

However, as you know, I've started a new job at the OECD. It is a fantastic workplace with brilliant people and high level discussions of telecommunications policy. It also means that no matter what I blog about in the telecom industry, it is directly related to my work. The consequence of that is, that it will be very hard to separate the two and so I've decided to put the blog on semi-hiatus for the time that I work in Paris. I may write and Twitter occasionally or link to something I've published elsewhere. So don't delete me from your feed readers and Twitter just yet.

If you are in Paris anytime, send me note. I love to meet people and actually will go and have dinner tonight with someone I met through the blog!

Celebrating Bill St. Arnaud and his wireless vision

noreply@blogger.com (Rudolf van der Berg) — Mon, 03 Jan 2011 22:14:00 +0000

James Enck used to call the readers of his blog "Eurotelcoblog", super mega über valued readers or something of the like, when they provided him with interesting tidbits and insight. In Bill St. Arnaud's case the list of superlatives that I would need to give him in thanks to his efforts would be a bit too long and not do him justice. Ever since I published about how opening up the market for MVNO's to end-users, Bill has been a major supporter of the idea, often blogging about it. Today he wrote such a great post on what universities and research networks could do with the idea, that I have to give him his own article, anything else would just be too little.

If you want to know where the future of innovation in networks is, then read Bill's blog of today. It's very enlightening, about how networks could be build that seamlessly integrate traditional mobile and wifi networks can be integrated into one large network, that could support many innovations.

Without readers and supporters, this blog wouldn't be anywhere so that's why I'm celebrating Bill today!

The truth about 3 digit Mobile Network Codes (MNCs) E.212

noreply@blogger.com (Rudolf van der Berg) — Wed, 29 Dec 2010 22:51:00 +0000

Despite the title, I don't know the full truth about Mobile Network Codes and whether they can be 2 digit or 3 digits long. However, I'm getting an ever bigger suspicion no one really does. So after talking to experts from various telco's and standardisation organisations for more than a year and just before I head into a new world, I thought I write down everything I've learned about Mobile Network Codes as defined in ITU recommendation E.212. This is not all there is to know and I hope others will chime in. There is so much misinformation and Fear, Uncertainty and Doubt, that it is hurting the development of the industry as a whole. I do have the sincere feeling, I'm the first person in a decade to fundamentally look at these numbers and the impact they have on the telecommunications market. I haven't seen any studies by any other researcher looking at these numbers at all. (Please prove me wrong, I would so love to see some other nutcase who looks at this stuff in-depth, preferably one who is way better than me and teaches me something new).

You're a policy maker and you need to know what to do

Before dismissing the potentially billions of euros of unrealized potential in the market and not changing a damn thing to the way MNC's are assigned, please ask a very very good and honest researcher to look into this. As far as I know there is no reason to be against this plan. But I am one person. I'm often right, but I may not be. After a year of searching though nobody I met who has serious mobile network knowledge has said I'm seriously bonkers and it cannot be done. Here is what I know. Don't be afraid to be critical. Do know, no one is paying me for this position.

A Mobile Network Code is digits 4 to 6 of a 15 digit IMSI.
As you may know, your SIM-card carries a unique number, the 15 digit IMSI number. (there are more unique numbers for an IMSI, but this is the important one). This number is used in the network to identify the mobile subscriber. Based on the IMSI the network knows whether the SIM should be allowed access, the type of access it should be granted and where to route the bits too.

The pre-paid SIM-card from the Dutch supermarket MVNO Albert Heijn I bought yesterday as a temporary replacement has IMSI: 204122030140166. Decoding it leads to the following knowledge:

204 is the Mobile Country Code of the Netherlands. Why it is necessary for mobile networks to know countries, I don't know. But it is in the spec. There are some operators like Digicel, who use one MCC 338 for their whole network in many different countries, deeming it too hard to work with an MCC for every Caribean Island and technically speaking they are right. Vodafone could easily use on MCC for all nations it operates in. Nothing breaks if you use an Italian MCC in Vatican city. Though it somehow is against best practices and the ITU doesn't like you doing it and wants operators and regulators to report extra territorial use of MCC's and MNC's
12 is the Mobile Network Code of Telfort. This used to be an indepent MNO with its own mobile network. It was bought by KPN, who switched of Telforts network and now Telfort is an MVNO on KPN's network. MNC's are issued by national regulators. In Vatican City this may well be Radio Vatican or the pope himself. The combination of MCC and MNC uniquely identifies the network. The E.212 spec says that the number can be 2 or 3 digits long. In Europe it is two digits long. In the rest of the world Wikipedia seems to show 3 digits are used as well. For instance Honduras, Columbia and the United States.
2030140166 is the Mobile Subscriber Identitification Number: In this case it is 10 digits long, per the standard it could also be 9 digits long. That gives every mobile operator at least a billion and up to 10 billion numbers. Though it could be issued completely at random, it does seem there is further logic in the number. For instance I heard that the first x digits are sometimes used to point at a specific Home Location Register, which keeps track of where SIM-cards are in the network. It seems HLR's can only accomodate x million devices per HLR. If you expect more than x million devices, using the first digits allows for easy internal routing of traffic. Furthermore specific MVNO's, like my supermarket MVNO may get their own range, so maybe 2030 is unique to Albert Heijn. Again, if they grow, it becomes easier to shift them to different or dedicated HLR

MCC + MNC are also broadcasted by the network base stations.

Apart from being used on the SIM-card, the MCC+MNC is also broadcast by the networks base stations. Your mobile phone receives these announcements and will select these networks either based on a list of preferred networks that it has listed on the SIM or by just trying all these networks. The number broadcasted should always be 5 digits I heard. This has something to do with base stations, for instance those used for CDMA. It is hard to get good information on this, but it seems to be a hard restriction for some networks. It may be more than just legacy in the core network, it may be that this is hardcoded into end-user devices too. So it may be that your phone only expects to see a 5 digit number broadcast from a base station and will not respond to a 6 digit one. What this doesn't mean is that your device only logs on to a network that has the same MCC+MNC combination as the one broadcasted. Again, take my phone. The SIM uses 20412 as MCC+MNC, but it doesn't latch on to Telfort's network anymore. That network doesn't exist anymore instead it chooses to work on 20408 or 20410, which are KPN's. It shows this in the home screen. In a foreign country, a phone is very promiscuous and latches on to whatever network has the strongest signal, that is willing to give it access.

Proposition to let large scale end-users manage own Mobile Network Codes.

As said in previous posts, I propose to open up access to MNC's to anyone wanting to become an MVNO for instance for their smart metering project. The benefits are enormous. It would allow:

- easier switching of mobile operators, without having to physically switch the SIM-cards of one operator for another

- better coverage and less black spots through national roaming

- cheaper international roaming through more competition

- more innovation, because it is the end-user who is in charge.

This is scary stuff.. or to quote a telco guy it is quite extreme, controversial and maybe can not or should not be implemented. The main reason why I think it could work is that no argument is ever made against the 4 points as being something a customer needs. Even better, the 3GPP is researching solutions for these problems, except it only looks at technical solutions and these technical solutions fail because of the administrative overhead they require and the fundamental breach of GSM security models. The proposition looks at changing the rules under which someone can get a number, instead of trying to change numbers post-hoc. Every argument against it seems to focus on how hard it could be and how this is untested.

The proposition isn't untested. All I'm proposing is roaming

What everyone seems to forget is that mobile roaming is doing exactly what I'm proposing. Every telco has hundreds of roaming agreements. Every telco allows hundred of thousands if not millions of devices on its network every day, with whom it has absolutely no relationship what so ever. The only thing the network is interested in is; what network does this SIM belong to. Do we have a roaming agreement with it. If yes, grant access and start billing. If no, deny it access.

The arguments agains doing this are mostly based on FUD.

A well known tactic in the IT industry to discredit any product or idea is to use Fear, Uncertainty and Doubt. The proposition discussed here has seen its fair share. The work I did on it was mostly aimed at finding out if there was any basis for this FUD, so that it was valid criticism. The easiest to dispel are arguments about:

Demand: Critics say customers don't want this, we never heard them ask for it. First of all, for a regulator this should be irrelevant. Limiting supplies to a resource shouldn't be about whether or not someone wants it or not, but about whether they could get it if they wanted it and whether or not that would be a problem. And yes there is demand in the market, quite a lot actually. The Dutch Defense department already has its own MNC and is very happy with it. (but they have guns, so its a different request)
Operational difficulty: Critics say that running a telco is hard. Customers can't be trusted to run HLRs etc. This is true, operations are hard. That is why many telcos outsource their operations to companies like Ericsson. Yes you heard it right. Ericsson runs many networks totalling well over 750 million active customers. So why can't an end-user hire Ericsson, Huawei or a smaller company to do the same for it.
It is too expensive: Not what I heard. Seems you can be done with a figure in the low hundred thousands euro for a full set up. Some speculate it could become less if the market becomes bigger.
It will become too big and need too many numbers. I tried to find out the numbers and it seems most people I speak to intuitively think the amount of interested companies is too big for this to work. However, just looking at the statistics for the Netherlands, out of 844,000 companies in The Netherlands only 15,000 have over 50 employees, and only 7850 of those over a 100 employees. Most of these companies aren't interested in these new ideas. They are accountants, schools, NGO's etc. I guessed that for the Netherlands the upper limit would be 1500, but a realistic number for the next 15 years is closer to 200 or even lower. The Netherlands might run out of MNC's, but the whole of Europe, with dinky toy countries like Luxembourg, Andorra, Liechtensteyn, Jersey, Guernsey etc. could get very far. And really, if I could get 50,000 end-user MVNO's online in the next three decades, with this idea, I would be ecstatic. Just imagine the competition and the benefits. But to counter this and to not get into prolonged negotiations in the ITU for nations to reform the way MCC's are used, I propose to move to 3 digit MNC's and according to some, this will unleash network Armageddon, shatter the space-time fabric and as a result destroy the entire functioning of the mobile network. This last one is rather nasty and based on a GSM Europe letter from the year 2000, that I will delve a bit deeper into.

Moving to three digits will not lead to mobile network Armageddon

In the past Europe and the USA have discussed moving to three digit mobile network codes. This was always faced with heavy opposition from the GSM Association and its predecessor. Though the people at the GSMAs central office are very nice, I do have some misgivings about its perspectives on public policy and the functioning of the mobile market. Mobile roaming or Mobile termination access anyone? ;-)

The argument is outlined in a letter from 2004 which is available on the ATIS-website. The nice thing is that it is a letter which has enabled track changes. Running it through Google docs and looking at the HTML, the entire text is below the fold. It turns out the original letter is one sent to CEPT/ECTRA in 2000. And yes the letter is still seen by some as valid as I've seen these points pop up in discussions and even saw some points quoted verbatim in mails. There is also a message from the 3GPP on the topic, which provides a bit of background. However it was written after the letter to CEPT/ECTRA and it quotes those points directly, so I'm not thinking it was written indepently.

The argument is:

Call back of the released 2-digit SIM card – this could affect all current GSM users (around 500 million in Europe).
The handset display may not be ready for such a change – this could cause severe confusion with all existing GSM handsets.
Change of all existing roaming agreements with the need to re-run all the performed tests.
Enormous efforts in terms of investment and manpower in order to change network elements and billing systems, thereby reducing the innovation power of mobile operators.
Inability for many operators to roam with the second operator where 3-digit MNCs have been issued in a country with no ability to identify an operator by the first 2 digits.

None of these arguments is true. They can be debunked I think. (If you feel otherwise, please tell me so)

Callback of all SIM-cards isn't necessary. The proposal isn't to split all existing two digit MNC's in 10 3 digit MNC's and hand these out to different organisations. So the plan isn't to split 20412 into 20412X and to let Telfort only keep 204120 and give 204121 to a smart metering project. Nope, what has been issued has been issued. So none of the SIM-cards have to be revoked.
The handset display has developed massively in the last 10 years. But even then. We aren't talking about changing existing networks. It might even be necessary for backwards compatibility to let those that run networks still use 2 digit MNC's by effectively giving them a block of 10 consecutive 3 digit MNC's. Nothing says this can't be done.
Roaming agreements only need to be tested for new networks using the three digit MNC, as all existing networks will remain doing the same thing they did before. So no changes there. Furthermore roaming agreements are tested regularly. Things always change in networks. Testing is essential to this.
An enormous effort in network elements and billing systems. This may be true, but only for those networks that didn't comply with the standard. According to my sources, some networks assumed standards compliance in their networks and needed to identify more digits then 6 to find MVNO's and HLR's anyways, so they are ready for any length of an MNC. Furthermore, that is business. Things change. Windows versions get upgraded and loose backwards compatibility. If this was a real argument, cars still wouldn't have safety belts.
Inability to roam seems rather unlikely. The 15 digit IMSI is what is used. That doesn't change by looking at either the 5th or the 6th digit. And as said, it isn't necessary to change the base stations. If they need 5 digits, that can still be accomodated.

Loose end: Global Title Translation

Realizing I don't know everything. Do know I see Global Title Translation as a loose end. I don't know precisely how it works, but it feels from the descriptions that there shouldn't be a fundamental difficulty there either. It may however require some work.

Update Loose end: How it is processed "on the air"
Good point by my friend TT. A serious question is how an MNC is sent over the air. Is it that it is sent as part of an IMSI string and indistinguishable from the rest of the IMSI, if so the network wouldn't care about the length of the MCC+MNC bit. If not, the length may be of interest. He found in some ETSI documentation that the IMSI is broken down into separate parts of MCC+MNC+MSIN. The MNC is sent separately over the air as 3 digits. That is nice, because this means that three digits should be understood by the network as it gets a 3 digit field that it needs to deal with. Will investigate further.

So what to do

GSM Association

Mr. Alain Doisneau

Chairman Project Team Numbering

Subject: Mobile Network Codes (MNCs) – Change from 2digits to 3 digits

Dear Mr. Doisneau,

GSM Europe has recently been following the developments concerning CEPT/ECTRA’s intention to formally adopt a Decision on the expansion of Mobile Network Codes from 2 to 3 digits (draft Decision attached).

GSM Europe is the European regional interest group of the worldwide GSM Association, the premier global body behind the world’s leading wireless communications standard. GSM Europe represents around 159 mobileoperators in 50 regions in Europe with around 200 million subscribers.

I understand that the adoption of ECTRA’s Decision, which was originally scheduled for the CEPT/ECTRA meeting on 21st June 2000, was postponed further to concerns raised by industry. Further to its preliminary analysis, GSM Europe shares such concerns and believes a change in MNC from 2 to 3 digits is most likely to have severe implications for almost the entire GSM system (See Annex). The main consequences from our point of view would be:

¨ Call back of the released 2-digit SIM card – this could affect all current GSM users (around 200 million in Europe)

¨ The handset display may not be ready for such a change – this could cause severe confusion with all existing GSM handset

¨ Change of all existing roaming agreements with the need to re-run all the performed tests

¨ Enormous efforts in terms of investment and manpower for the changes in the network elements and the billing system, thereby reducing the innovation power of mobile operators

GSM is not convinced of the urgend need to initiate those changes. It does not feel that the costs and risks to be incorporated by the operators only are in any way justified by potential advantages. Especially new operators, operators which a dense infrastructure to provide special home services and operators building up a UMTS network could face more problems for migration than others.

In light of the abovementioned issues, GSM Europe strongly supports the idea of having a workshop open to all parties concerned in order to identify the technical difficulties and assess if and when these problems can be overcome. Such discussions, it is felt, would bring some clarifications to CEPT/ECTRA and other parties concerned on the real implications of an alteration in the MNC digits number. With regards to the timeframe, it would seem appropriate to hold a workshop organized by ETO in September 2000, so that adequate measures can be taken in a timely manner.

You will find attached in annex an analysis paper drafted by our experts expressing the views of GSM operators. The paper seeks to outline the technical issues relating to the introduction of 3-digit Mobile NetworkCodes and the possible consequences associated to this change.

I hope the attached document will be of interest to you.

Yours sincerely,

……..

Copie: Marco Bernardi

Alisdair McLead

Leo Koolen

Annex

Technical Issues Relating to the introduction of Three Digit Mobile Network Codes (MNCs).

Introduction / Background

The MNC is a component of the IMSI (International Mobile Subscriber Identity), the other components been the Mobile Country Code (MCC) and the Mobile Station Identification Number (MSIN).

Figure 1 IMSI Structure

The MNC is an inner element in the IMSI with a defined length of 15 digits. The whole IMSI is marked on the SIM-card. To this extend, the IMSI must not be mismatched with the subscriber's number which is e.g. in GSM an E.164 number.

Various GSM entities will interpret the extra MNC digit as part of another field (MSIN), which will consequently lead to inconsistencies within the interaction between various parts of the whole GSM System.

The IMSI is used to:

· Identify a (roaming) customer, for

· Network internal purposes used in all signalling in the PLMN, in

· Interaction with the Mobile Terminal and for

· BackOffice applications like charging, billing and accounting

As the National Regulatory Authorities (NRAs) are responsible for the establishment and publication of conventions for IMSIs (IMSI = MCC + MNC + MSIN), the change of the current MNC allocations (e.g. 03 may become 030 or 003) may lead to severe problems as the length of the IMSI is fixed and the structure / usage of the MSIN is subject to each individual operator.

It should be noted that for the time being, out of a total of 300 MNCs actually in use, 14 are 3 digit MNCs. Furthermore, there are no assignments for 3 digit MNCs outside the US, where 5 US Operators where assigned such MNCs. In terms of operators this corresponds to 1.7 % of the GSM Operators.

It should be noted that this paper does not claim to be exhaustive and further in depth analysis is required.

Technical implications for the introduction of 3-digit MCNs:

SIM Cards:

The IMSI is an inherent part of all SIM cards,. This would hence require a replacement of all existing SIM cards with new ones. Taking into account the number of mobile users and prepaid cards, such exercise is practically not feasible (e.g. in Germany about 35 Millions of SIM Cards are produced, or are submitted to the customers, with a rapidly increasing proportion of prepaid cards). The costs of this procedure are expected to be quite high due to production of new SIM cards, SIM card distribution and logistics, customer service, activation of the new SIM cards, and customer handling. The activation/provisioning part raises questions about the capacity of the IT and networks systems. It would be quite likely that most operators would be forced to build up additional capacity to be able to manage the migration. Some customers would experience problems and would temporarily unable to use their mobile, which means loss of revenue from the operator's point of view. In addition to this it is doubtful, that SIM card chips can be produced to serve all carriers in due time.

As a result the co-existence of 2 and 3 digit MNCs can only be the subject of further analysis.

Handsets:

The introduction of a 3 digit MNC will certainly result in a number of compatibility problems between existing mobile equipment and the SIM, and also very likely between MS and the network. With respect to compatibility problems in the interface between SIM and the software of ME, two cases can easily be identified:

1 SIM with a new IMSI structure built up by three digit MNC combined with an ME running old software that isn't prepared for the new IMSI structure. The ME will in this case attempt to read the extra MNC digit as part of another field. This case will be difficult to solve as there are about 250 Million legacy mobiles in operation throughout Europe.

2 SIM with an old IMSI structure build up by two digits MNC combined with a ME running new software, expecting the new IMSI structure. Here it is much easier to find a solution, but the problem has to be addressed in order to find some kind of IMSI type identification on the SIM.

In other words, either a large number of terminals would have to be replaced, a very long lead time (longer than the typical life span of a mobile terminal) would have to be allowed, or the problems in the transition phase would have to be accepted by users and operators.(Further Input is welcome by other GSMA groups !!!!)

Network:

The IMSI analysis would need to be redefined .

All subscriber records would need to be modified to change the MNC from 0X to 0X0 or 00X. In the case of multiple HLRs, as is the case with nearly all operators, the level of planning and coordination would be substantial.

IN the case of redundant HLRs redundancy the data would need to be changed on both the live and backup locations.

In addition to this, many of the operators would have to reconfigure their Base Station Subsystem so that it transmits a LAI which contains the new 3 digit MNC. This causes operational costs. In addition it would demand additional operational capacities, which especially operators, who are still in the phase of 2G network rollout or who have (some additionally) plans to built up a 3G network may not be manage in a sufficient way, so that customers will not be frustrated.

If FNR was in service it would also need updating.

Billing & Customer Care Systems:

The billing systems of most networks use the IMSI for the generation and gathering of billing information. A change in the MNC would require severe modification to billing systems and protocols. All effected subscriber records would need to be modified TAP-Files (TAP-Incollect/Outcollect) TAP 2 / TAP 2+.

Roaming:

Regarding Roaming, the IMSI analysis for all European operators (e.g. approximately 100 in Eircell’s case) will have to be changed in every MSC.

All roaming testing would have to be redone and would be more complex.

Finally, operators would have to change their roaming contracts with each of their roaming partners. This will have an effect on almost countries using GSM.

Hence, if the roamed-to network cannot scrutinise 3-digit MNCs , roaming would stop overnight

Fraud Prevention / Management:

The impact from a Fraud & Security point of view would be the cost of modifying Fraud Management Systems and the length of time it would take to run the additional reports required.

(Further Input is welcome by other GSMA groups on specific issues relevant to their groups!!!!)

The GSM Association (GSMA) has recently been following the developments on the expansion of Mobile Network Codes (MNCs) from 2 to 3.

The GSMA, as the premier global body behind the world’s leading wireless communications standard, protects and enhances the interests of 678 GSM mobile operators from 209 countries and territories with more than 1 billion customers throughout the world today.

The GSMA has concerns related to the allocation of MNCs and its change in some cases from 2 digits to 3 digits and would like governments and regulatory authorities to take these concerns into account when allocating numbers to operators.

European operators have been issued 2-digit MNCs by their regulators for many years, therefore they have built their systems/infrastructure to support 2-digit MNCs.

In the past only North America and a few other countries have used 3-digit MNCs. These 3-digit MNCs always ended in '0' (zero) and therefore could be treated as 2-digit MNCs. The '0' (zero) is dropped/ignored and operators are able to uniquely identify their roaming partner based on the first two digits of the MNC.

The GSMA is now aware of countries where multiple 3-digit MNCs have been issued by regulators where the first two digits are exactly the same. Although according to the specifications this is acceptable it is a problem for many operators whose systems are only set up to accept 2-digit MNCs.

Enlarging the length of the MNC to accommodate 3-digit MNCs (filename length, field and record length) is a major change to the entire systems such as the rating engine, the TAP engine, the billing system and the data warehouse.

Further to its preliminary analysis, the GSMA shares such concerns and believes a change in MNC from 2 to 3 digits is most likely to have severe implications for almost the entire GSM system (please see Annex). The main consequences from our point of view would be:

Ø Call back of the released 2-digit SIM card – this could affect all current GSM users (around 500 million in Europe).

Ø The handset display may not be ready for such a change – this could cause severe confusion with all existing GSM handsets.

Ø Change of all existing roaming agreements with the need to re-run all the performed tests.

Ø Enormous efforts in terms of investment and manpower in order to change network elements and billing systems, thereby reducing the innovation power of mobile operators.

Ø Inability for many operators to roam with the second operator where 3-digit MNCs have been issued in a country with no ability to identify an operator by the first 2 digits.

Therefore we strongly encourage governments and regulators to undertake a cost/benefit analysis when allocating MNCs. We would suggest allocating either 2-digit MNCs or alternatively 3-digit MNCs where the operator can be uniquely identified by the first 2 digits.

You will find attached an analysis paper expressing the views of the GSMA operators. The paper seeks to outline the technical issues relating to the introduction of 3-digit MNCs and the possible consequences associated to this change.

I hope the attached document will be of interest to you.

Yours sincerely,

Tom Phillips

Government & Regulatory Affairs Officer

GSM Association

For any questions, please feel free to contact Isabelle Mauro, Programme Director, GSM Association: Tel: +44 207 518 0548; Fax: +44 207 518 0531; E-mail: imauro@gsm.org

Annex

Technical Issues Relating to the Introduction of

Three Digit Mobile Network Codes (MNCs).

1 Introduction / Background

According to IMSI structure defined in ITU E.212 an MNC can have two or three digits.

The IMSI structure and format are as shown in Figure 1.

(Figure 1 IMSI Structure)

The IMSI is used to identify a (roaming) customer, for network internal purposes used in all signalling in the PLMN, in interaction with the Mobile Terminal and for BackOffice applications like charging, billing and accounting.

As the National Regulatory Authorities (NRAs) are responsible for the establishment and publication of conventions for IMSIs (IMSI = MCC + MNC + MSIN), the change of the current MNC allocations (e.g. 03 may become 030 or 003) may lead to severe problems given that the length of the IMSI is fixed and the structure / usage of the MSIN is subject to each individual operator.

It should be noted that for the time being, out of a total of 300 MNCs actually in use, 14 are 3-digit MNCs. Furthermore, there are no assignments for 3-digit MNCs outside the US, where 5 US Operators where assigned such MNCs. In terms of operators this corresponds to 1.7 % of the GSM Operators.

2 Technical implications derived from the introduction of 3-digit MCNs

Below we find some of the technical applications derived from the introduction of 3-digit MCNs. However this paper does not in any case try to be exhaustive and further in depth analysis is required.

2.1 SIM Cards

The IMSI is an inherent part of all SIM cards. This would hence require a replacement of all existing SIM cards with new ones. Taking into account the number of mobile users and prepaid cards, such exercise is practically not feasible (e.g. in Germany about 35 million of SIM Cards are produced, or submitted to the customers, with a rapidly increasing proportion of prepaid cards). The costs of this procedure are expected to be quite high due to necessary production of new SIM cards, SIM card distribution and logistics, customer service, activation of the new SIM cards, and customer handling. The activation/provisioning part raises questions about the capacity of the IT and networks systems. It would be quite likely that most operators would be forced to build up additional capacity to be able to manage the migration. Some customers would experience problems and would temporarily be unable to use their mobile, which means loss of revenue from the operator's point of view. In addition to this, it is doubtful that SIM card chips, which are already due to the strong demand in short supply, can be produced to serve all carriers in due time.

As a result of this, the co-existence of 2 and 3-digit MNCs can only be the subject of further analysis.

2.2 Handsets

The introduction of a 3-digit MNC will certainly result in a number of compatibility problems between existing mobile equipment and the SIM, and also very likely between the mobile station (MS) and the network. With respect to compatibility problems in the interface between SIM and the software of mobile equipment (ME), two cases can easily be identified:

1) SIM with a new IMSI structure built up by three digits MNC combined with an ME running old software that isn't prepared for the new IMSI structure. The ME will in this case attempt to read the extra MNC digit as part of another field. This case will be difficult to solve, as there are about 250 Million legacy mobiles in operation throughout Europe.

2) SIM with an old IMSI structure build up by two digits MNC combined with a ME running new software, expecting the new IMSI structure. Here it is much easier to find a solution, but the problem has to be addressed in order to find some kind of IMSI type identification on the SIM.

In any case a large number of terminals would have to be replaced and very long lead time (longer than the typical life span of a mobile terminal) would have to be allowed.

2.3 Network

The IMSI analysis would need to be redefined. All subscriber records would need to be modified to change the MNC from 0X to 0X0 or 00X. In the case of multiple Home Location Registers (HLRs), as is the case with nearly all operators, the level of planning and coordination would be substantial.

In the case of redundant HLRs, the data would need to be changed on both the live and backup locations.

In addition to this, many of the operators would have to reconfigure their base station subsystem so that it transmits a Location Area Identity (LAI) which contains the new 3-digit MNC.

2.4 Billing & Customer Care Systems

The billing systems of most networks use the IMSI for the generation and gathering of billing information. A change in the MNC would require severe modifications to billing systems and protocols. All effected subscriber records would need to be modified TAP-Files (TAP-Incollect/Outcollect) TAP 2 / TAP 2+/TAP3.

2.5 Roaming

Regarding roaming, the IMSI analysis for all European operators will have to be changed in every MSC. All roaming testing would have to be redone and would be more complex.

Finally, operators would have to change their roaming contracts with each of their roaming partners. This will have an effect on nearly every country using GSM. Hence, if the roamed-to network cannot scrutinise 3-digit MNCs, roaming would stop overnight.

2.6 Fraud Prevention / Management

The IMSI is a data element commonly used by the operator community to detect fraud. To change the format of the IMSI would render most detection and prevention useless thereby exposing networks to increased financial loss.

Historical searches for IMSIs spanning the transition will have to be split into two reports, one before and one after search. Usage variation alarms for all the numbers that change will effectively start from scratch. Similarly, any IMSIs that had previously been hot-listed for the purposes of fraud monitoring would need to be replaced.

One impact, from a fraud and security point of view, would be the cost of modifying fraud management systems that are currently used by home networks to monitor for fraudulent calling patterns based on individual IMSIs. It also likely that the length of time it would take to run the additional reports required would increase.

GSM operators currently have mechanisms in place that allow for the exchange of IMSIs, and other data, which may identify fraud. Such exchanges can be transacted electronically through the use of near real time data exchange systems across the SS7 signalling network. Such systems would need to be upgraded to accommodate changed MNCs.

Leaving Logica to go and work for the OECD in Paris

noreply@blogger.com (Rudolf van der Berg) — Fri, 24 Dec 2010 05:52:00 +0000

It is with mixed emotions that I’m telling you that I’m leaving Logica to go to work for the Organisation for Economic Co-operation and development in Paris as an economist/policy analyst in the information, communications and consumer policy division. Logica has given me great opportunities to work in the fields of telecommunications and utilities. I had the pleasure to work on a variety of projects ranging from shaping the Belgian energy sector, to smart metering and Machine to Machine communications and the future of ENUM in the Netherlands.

I’ll start at the OECD on January 3^rd, initially for a period of 13 months. I will work on the high level meeting on the future of the internet economy, which will be held in June, and on other subjects regarding telecommunications policy. It’s an exciting step. I don't know yet how this will affect this blog as I don't know the OECD's approach to new media yet. It might be that the blog and twitter will go on hiatus.

I still hope to write two blogposts:

1. everything I know about 3 digit MNC's. There is hardly any information available about it and what is there is mostly misinformation

2. How we should get rid of the difference between public and private networks in most of our telecommunications law.

And I'm tempted to write a third as a reaction to the Berec mobile roaming consultation

So many ideas, so little time.

Wrote an article for Gigaom on Apple and SIMs

noreply@blogger.com (Rudolf van der Berg) — Sun, 21 Nov 2010 12:07:00 +0000

Gigaom just published an article by me called: "How to bypass carriers Apple style", on what Apple could do with the SIM-idea I developed for M2M. Apple is only in there because of the marketing value, Samsung, Sony, Philips, LG, Asus, all of them could be doing this. It works best for laptops and other data devices. These devices often don't have data roaming enabled, even if you use a dongle.

Have fun reading it!

GIGAOM Readers: please have a look at some of the other articles I wrote on the topic:

A very simple presentation to introduce the idea given at the Telco2 conference (click or scroll down)
A more in depth management summary of the idea, focussed on embedded M2M
There is also a 55 page document for the government of the Netherlands (in Dutch)

Other things I wrote:

The common errors of Telecom CEOs

a primer on peering and transit

Telecom Cool Wall

Why all telecom marketing and product management is wrong

The GSMA changes opinion on programmable SIM-cards

noreply@blogger.com (Rudolf van der Berg) — Thu, 18 Nov 2010 14:49:00 +0000

In a surprise move, the GSMA today announced that it will standardize a new form of embedded SIM. This will allow remote activation and updates. The spec will be ready in January 2011. No word yet on whether or not the IMSI will be changeable after initial activation. This is however a complete reversal from the GSMA's position from the past:

Appendix A of 3GPP TR 33.812 V9.2.0 lists the opinion of the GSMA as
[…]Furthermore, one of the major concerns of MNOs is the potential weakening of the well-established and trusted SIM-based GSM/3G security architecture. Extended OTA (any kind and via any bearer of over the air data download to the USIM) capability to facilitate download of new subscriber keys and possibly authentication algorithms represents such a potential weakening of security.[...] not allowing MNOs to fulfil their obligations towards regulatory and other governmental authorities to guarantee secure authentication and billing.

[…]The only proposal in the TR that was acceptable to GSMA SG representatives was the Alternative 2 where operator change was performed by physical replacement of the UICC in the device.[…]

This would allow the likes of Apple to release mobile phones without removable SIM-cards. The biggest question is of course, why the GSMA changed its position and how much control they are willing to relinquish to the end-user, be they Apple or a smart metering company.

Though this will alleviate the problems I identified in my work on Machine to Machine communication, it's only 1 out of the 4 problems that I identified that now could be fixed (seeing is believing). Customers may be able to switch operators in the future, but roaming, national roaming and innovation, will probably still be limited.

Your customer wants to be mvno v2

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My presentation on M2M at Telco2.0 and my impression of the conference

noreply@blogger.com (Rudolf van der Berg) — Thu, 11 Nov 2010 22:48:00 +0000

Tuesday and Wednesday I was at the Telco 2.0 conference in London organised by STL. I was an invited speaker on the M2M track on Wednesday morning. Like many of you, I know the Telco 2.0 blog and knew of the conferences. Good friends in this community, like James Enck were on stage there before me. Other friends in this community stood at the basis of the Telco 2.0 ideas. So I was quite happy to be invited to the event.

Telco 2.0 on M2M
My presentation was part of the dedicated M2M track. Not all the attendants were there, but only those interested in M2M. The crowd was treated with a series of presentation from carriers and various forms of system integrators and suppliers.

What I found interesting in the telco presentations was, what they were and weren't about. What they weren't about is what their customers were doing and the problems that these customers were facing. What they were about is, potential use cases, the organisation of the telco's M2M unit and how it was embedded in the organisation and the design of the M2M platform. The whole reasoning was supply driven. Build it and they will have to come. As someone had warned a while ago, most telco diagrams of a problem start with their network in the upper left part of the page and the customer in the lower right part of the page. This is true. It also shows where their focus is; themselves, not their customer.

The difference between the telco's wasn't too great. Orange seems to go for a more fully integrated solution, where they will deliver the network, the platform and all sorts of other devices. Telenor has a dedicated group for M2M networking solutions, called Connexion and another group Objects that focus on service enablement, regardless of the network. So Connexion can sell to the whole market without involving Objects and vice versa.

Most of the presentations were at least of a decent quality and sometimes quite better. It deserves metntioning, because often this is different. However, the feeling these presentations give me in retrospect, is that of enormous budgets and very little idea of what the customer is looking for. This idea came from a remark by a quite brilliant and quiet Eastern European financial controller of a mobile telco, who remarked privately that his company just didn't have the size and the budgets necessary for such a platform, certainly given the 5 euro max revenue/month per SIM. This remark is so incredibly true. The large behemoths of European Telecoms are still swimming in the free cash flow. Free cash flow that is supposed to do something and might as well be spend on M2M. Running after every hype in the business, including M2M is not so much a necessity as it is a luxury.

The interactive format of Telco2.0 also means there was quite some feedback from the room, through instant polls. What it showed was that the audience was effectively split over the idea whether mobile telcos have a larger role to play in the M2M ecosystem.

My presentation on how M2M customers becoming MVNO's
I gave a presentation called "Your M2M customer wants to be MVNO". In generally the audience quite liked it. They thought it was thought provoking. I do think it was the most referenced presentation during the day. Both the facilitator and the speakers quite often referred to Rudolf or Logica. This was of course nice for my ego. I really focussed on the 4 central business problems and why becoming an MVNO was a solution.

What was also quite clear is that the industry really doesn't want to hear what I had to tell. The idea that a large scale M2M user is going to become a wholesale customer of the telco is just not done. There were some interesting comments why not:

Your customer wants to be mvno v2

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It is all about money and prices are coming down. If the price is low enough, the customer doesn't need freedom, flexibility and innovation.
It is too complex to run an MVNO (so let an MNE or Ericsson run it. Ericsson already runs most telcos)
Lock-in is everywhere, so why not with a telco? (Because people only accept a lock-in if it is because of network effects, not because of market power)
This cannot happen, because we need to make a return on our platform
This cannot happen, because competition would kill margins and then the industry would be very badly off.

The best argument against my presentation was given to me in private by a large telco. The reason we can't have private M2M MVNO's now, is because otherwise all the budgets of telco M2M plans would be killed by the executive board. Private M2M MVNO's could happen in three years, when the initial investments in M2M platforms have been done.

There were also some quite positive reactions to my presentation. Certainly those that represented large scale users (they were scarce but present) were very positive about the content of the presentation.

My impression of the Telco 2.0 conference
Last year november I spoke at Ecomm on how all telecom marketing and product management is wrong. Now I spoke about a different but also controversial subject. What was interesting was the difference in audience and their reactions. The Ecomm audience is you, hip and happening. The cluelevel of the conference is high. Unfortunately most of those attending are not of such a level yet, that they can actually implement their vision. What a difference with the Telco2.0 conference. The power level of the attendants is high. Proper CTO's, Vice Presidents, Heads. Those that can say: "Make it so".

The difference shows up in the way the problems are discussed. For the Ecomm crowd a problem is a problem. It is something that needs to be solved and removed. For the Telco2 crowd a problem is either a business opportunity or Somebody Elses Problem. And with the amount of money sloshing around in the industry, almost every problem is attacked to see if it can generate more money. If it cannot generate money, it's somebody elses problem.

The harsh reality is that those high level execs attending are grasping at every straw to see if it will generate some yield. This was clear from the discussion of clouds. Every major telco thought they were going to be big and uniquely positioned for clouds. After a while I asked out of desperation, how the assembled telcos thought to solve a very basic problem, namely getting the right people to build their cloud. You see, Amazon and Google are now sponsoring university courses in cloud computing, because finding the right people is hard. I didn't see telcos finding a person like Vijay Gill or Werner Vogels, let alone a team of them. This was well answered by Oracle, who came with a promise, that they would provide the products that could be a building block for a generic telco cloud. I personally would more expect Oracle to build it's own cloud, which it would then resell through telcos, But who am I ;-)c

And that brings me to my last bit. Who was I at the conference? I probably was a bit the court jester. The outspoken guy who challenges firm beliefs of the industry. It wasn't just clouds or M2M that I challenged the current opinions. I also got in a small verbal fight with a network vendor trying to push QoS as a solution. I've never been able to understand why anyone would use the argument: You're only right on the past 15 years, the next 3 years will prove that QoS is necessary for wireless. I was the weird guy who promoted happy pipes and mentioned Pareto distributions as the reason why we have bandwidth hogs. I don't know whether that makes me a good consultant, or just a good analyst. A good consultant seems to profit from his customer's mistake. An analyst just gives the problems and solutions as is. Keeping that in mind, I've agreed to become an analyst at the OECD in Paris in the coming year, working on M2M, peering and transit and some other stuff.

All in all great conference. Thanks to STL for having me and I hope to be back in the future.

How regulator's and Telco's are holding up the Internet of Things

noreply@blogger.com (Rudolf van der Berg) — Thu, 28 Oct 2010 21:54:00 +0000

Well, I got quite a few reactions on my work on Machine to Machine communications. Some of it was critical and deserves a reaction. Many people however are also very positive. Bill St. Arnaud has referred to me multiple times now on his blog. Telco2 has invited me to speak in London on November 9-10. The Apple and Gemalto rumor stimulated me quite a bit more to finish the piece below. BTW I think Steve should talk to me.

I'll go through the criticism point by point. It starts of with that M2M is overrated and who really wants this. The next section is, that I misunderstood technology or misidentified solutions. Then a short intermezzo to explain that even if technology was a solution, it wouldn't solve all and then I lay all the blame on regulators. To get some background, flip through the presentation

Management Summary of Onderzoek Flexibel Gebruik van MNC's

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BTW the spicy title is because it seems I get better response to spicy titles than to none spicy titles. Fear sells and I happen to know some regulators read this blog, so this may give them reason to forward the blog.

Where do we use M2M?

There are many ways of doing machine to machine communication. Much of it is already done in Scada systems and generally uses wired networks. One of these may be analysis systems for hundreds of thousands of sensors in chemical plants. All of this is wired communication. However unlike chemical plants most systems don't sit nicely in one place, they either move or are too distributed.

When going outside of individual sites like chemical plants, fields with windturbines etc and going into the general society there are still a gazillion machines that could benefit from a communication module. Such machines are:
beer ceggs in bars, to check on quality and beerlevels.
trains to check on seat availability, roundness of the wheels, info displays etc. The average Dutch train now has 4-5 communications devices
sewage pumps
water pressurizers in high rises
fire extinguishers of various kinds, sprinklers, but also gas (require specially trained personel for access)
streetlighting: A colleague is working on LED streetlights that are more energy efficient change color and intensity based on the situation. ie presence of people or to warn people of oncoming ambulances or to guide people to and from a concert.
smart meters: two types are available. Those for residential use are mostly in a pilot fase. Those for high use customers send values every few minutes to allow for peak shaving and real time trading.
consumer electronics, like the 1.4 million devices TomTom now has that are equipped with real time traffic data, or the Amazon Kindle 3G or the Kindle DX, but also other devices like digital photo frames.
Transport applications: Like eCall, OnStar, monitoring by lease and rental companies etc. Cooperative Vehicle Information Systems (CVIS) etc.

Roughly anywhere and everywhere, where there is a device that can measure something for us, do something for us, or that we want a status of.

What networking technology to use in non-fixed sites?

Having done some architectural analysis for these kinds of systems, the general conclusions on what network to choose are as follows:

For fixed locations:

Plain Old Telephone System: Always worth a look at. Not fast at 56k6, but it will be around for a while. Bad is the dependence on the owner of the location, certainly with the 20% who are mobile only now, the possible presence of ISDN or the lack of it.
piggy backing some broadband network: Relies on the owner of the building having broadband and the broadband provider allowing some easy hookup. Not useful for critical systems like smart metering or health.
Wifi: Essentially means piggy backing someone's broadband connection. Unfortunately there is no uniform standard to establish the piggy back or just to hook up to a WPA2 encrypted access point. Also in less densely build areas the coverage of wifi may be too little to find a working node
Powerline Communications: Only possible if you are the electricity company. And even then it is unfit for loading data every few minutes, ie for peak shaving. Most PLC nodes can only handle a couple of hundred hours at once every 24 hours. The fact that it uses mesh sounds cool until you actually look at what is a self organizing mesh network. This also means it only works if an entire neighbourhood is fitted with PLC.

For mobile and dispersed locations:

CDMA450: Hardly supported in Europe, but KPN has decided to build an M2M network on it.
GSM-family: Global coverage, though for 2G and 3G limited in North America and Japan. Coverage is almost universal.
Satellite: Only if you have line of sight. Which you always have everywhere, except where you're at. Also not capable of holding large numbers of users and expensive too.
Wifi: No handover capabilities at all, no coverage outside the front lawn or backyard.

Notably absent:

Wimax: huh, what?

So, I hope this does away with some of the criticism on why I'm looking at GSM-family only. CDMA450 is a possibility, though architecturally it is so similar to GSM that even the SIM-card is included these days and it makes use of IMSI's too. If you know of any other technology that would work, please tell me. I have major energy networks who would love to talk to you as they have tried every version of the technology listed above.

Are there really any problems with the combination of GSM and M2M?

Some people say there isn't a problem and I've got a solution looking for a problem. Yes, there are problems. Don't trust me, trust the GSMA, ETSI and 3GPP who have published on the issues that come from the use of the GSM family for M2M.

The biggest business problems have to do with the whole lifecycle of the device. What makes M2M different from consumer communications, is the lack of the consumer. The consumer can be trusted upon to change handsets every couple of years and to do all the practical work, like switching SIM-cards, choosing operators etc. Unfortunately M2M devices have to function for 30 years in the field without tender loving care. Some examples of problems identified:

1. The costs of roaming: One of the big problems, certainly for consumer electronics, but also for other devices is, that you never know where they will be used. An Italian may buy a GPRS equipped TomTom or Kindle in Amsterdam and use it Croatia. The device has to work everywhere and preferably also with the lowest roaming rate available. Working everywhere isn't a big problem with the coverage GSM offers. Getting an efficient roaming rate is however very hard. I've heard it to be compared to Sudoku multivariate analysis. No matter who you choose, if they are the cheapest in Scandinavia, they are the most expensive one in Southern Europe and if they are cheap in Eastern Europe, it's expensive in Western Europe. At the end of the analysis, all networks cost exactly the same per month The reason for this is that no network is truly global and the other networks have no reason to play nice. They just see a device that belongs to a foreign competitor, so there is no reason to drop prices. For all they know and care it's a consumer, who will be fleeced by it's home network for using data roaming abroad. The solution may be to use different devices for different countries, but then the Italian guy can't buy a TomTom in Amsterdam and use it in Croatia. Furthermore retailers don't like devices that are country specific. They want the flexibility to buy one device and distribute according to need across Europe. Producers preferably want one device for the global market. The only market that is a bit exempt of this is North America, only a few networks and continent wide coverage of some sorts.

2. Getting full coverage in a country. Unfortunately most fixed applications and some mobile applications suffer from the fact that perfect wireless coverage is almost impossible. If the telco changes antenna orientation or someone parks a truck or builds a building in the line of sight, signals can get lost. This happened for instance to a municipality who had equipped some traffic lights with GPRS to allow them to coordinate the flow of traffic, then one day the orientation of the antenna changed and service was lost to two traffic lights, gone too was a perfectly managed traffic flow and back were the traffic jams. Really bad is it that in most cases the competing networks still have perfect coverage. So how do you get a device to use the network that is available, regardless of whose it is.

3. Switching mobile operators: There are a myriad of reasons why a large scale end-user may want to switch part or all of the M2M devices from one network to another. Some of them include; switching supplier of network, merger with another company, selling of part of the M2M devices to some other company etc. Just imagine what happens if Sony would sell its eReader business to Amazon. Amazon may not want to stick with Sony's mobile network provider. Another example that got me involved in this discussion. A customer was faced with a European procurement procedure for mobile communications services and wanted to know how it could prevent future SIM-swaps as these were getting costly for their 10k devices (which most likely would grow substantially in the coming years). The costs are in the either logistical chain. First of all getting the right SIM to the right person, managing who uses what and where. Do you switch during regular maintenance or when the SIM-switch is. Regular maintenance can be once every 5 years or never in case of smart meters. All of this is problematic, difficult and often underestimated at first. So it costs serious money to fix.

4. Lack of innovation: It’s quite possible to use SIM-cards to authenticate over other networks than just the GSM network. One could think of automatic authentication on wifi-networks for instance. Unfortunately telco’s are currently blocking much of the needed innovation, because of a fear it would cannibalize their revenue in data sales.

So yes, these are some pretty big issues

Is there really no technical fix for the three issues?

People have suggested I didn't look to closely at the technical solutions, so I'll review those that have been suggested to me. Do understand that on the SIM-card there is a unique IMSI that is tied to an operator and operator specific encryption. The first six digits of an IMSI-number are used to find the network that the device belongs to and authenticate it:

Multi-SIM devices. Why not stick a SIM-card of every operator you want to deal with in the device and you're done. This solution has some appeal and may work for fixed locations. Most countries have only 4-5 physical networks. So if you disregard the MVNO's, then putting 4-5 SIM-cards in a device should do the trick. Of course when working on an international or global scale this fails quickly; there just isn't any space in the device for all the SIM-cards. Furthermore even mobile markets change, in NL alone in the last couple of years 2 networks stopped operating, when bought by competitors and likely 2 new one's will start in the coming years, when the spectrum is auctioned. So Multi-SIM is rather static. Furthermore, SIM's often carry a monthly charge regardless of them being used. This is because telco's often pay per 'activated' device to their suppliers, so this solution increases costs.
Multi-IMSI devices: Why bother with physical SIM's if you can put multiple IMSI's and associated crypto-keys on to one SIM. This might be a solution, However, telco's hate the security implications of it. There is also a question whose SIM-card it will be if all those IMSI's are present. At the moment the SIM-card is owned by one network. And it's a terrible waste of IMSI's, you need one IMSI per operator that could possibly be used. Assuming global coverage, that's more than 800 not counting MVNO's. Multi-IMSI is used sometimes, but mostly by operators with for instance a European footprint who load their IMSI's unto the SIM-card to allow for local coverage. Vodafone NL does this by loading a German IMSI unto phones of Dutch customers who want to be able to call, should the Vodafone network go down. The phone then switching to the German IMSI, which does allow for roaming anywhere in the Netherlands.
Over the Air provisioning: This has been extensively researched by the security working group of the 3GPP. They have some interesting solutions, which are described in my report. However, the mobile telco's hate it. The GSMA who represents them has said twice that it hates any form of over the air updating of SIM-cards. It sees it as an abomination. So unless they change their mind, it's a definite no no for this solution.
IP-adresses will fix this: sorry, but unfortunately being tied to a mobile operator happens at a layer below the IP-adress. So it may well be that a company can span it's corporate IP-adresses all the way to M2M devices. They may also be able to use different IP-adresses, but this doesn't fix the problem. Changing mobile operators requires that different IMSI's are used and you can't change IMSI's over IP.

So there you have it... technology doesn't save the day. Not the on the technological side and as we will see, not on the business side either.

Business problems not fixed by technology

Even if we would be able to use a technical fix, unfortunately it won’t fix all business issues. These two below are the most impartant ones.

· The price of roaming is fixed by the telco whose network you aren’t roaming on.: The biggest problem for a large scale M2M user is that he is completely dependent upon his mobile telco. The M2M user can only do what his telco allows him to do. This is true for the choice in technology, but even more so for the choice of roaming partners. The way roaming works is that telco's charge eachother a wholesale price for roaming. This wholesale price X is secret. The retail price that the large scale M2M user pays is X plus something Y. But because X is secret, Y is unkown too. So the customer only knows he's paying X+Y. It is impossible to verify if X or Y went up or both if the rates change. Also for the networks that the customer is roaming on, it's impossible to distinguish the customer based on IMSI-number. How would they know for sure that a specific IMSI belongs to that specific M2M application. All they see is that it belongs to Vodafone UK or T-Mobile NL. It might as well be a consumer. Now you might be able to bypass that with Over The Air updates, but which telco is going to allow his customer to change IMSI’s so that they can quickly hop over to another network.

· The lack of competition: Another problem, closely related, is the lack of competition for an M2M end-users business when roaming. In most countries there are 4-5 mobile operators. All of whom would love the M2M business of 50,000 foreigners roaming in their country with cars, eReaders etc. However generally all of them are contracted by the home network of the M2M user. So there are no competitive prices for the user. What the M2M user would like to do is choose 1 or 2 of those 5 networks to roam on. the cheapest ones preferably.

So why is the regulator holding up the future of the Internet of Things?

Well, as stated in the study, if large scale end-users could use their own IMSI's, then all these problems would be solved. Devices could have national and international roaming There would be competition to offer roaming. One device could be sold globally. All of this controlled by the large scale M2M user.

However regulators have created a world where it isn't easy to get access to IMSI-numbers. Only public networks can get them and public is a vague term. Changing the rules to allow private networks access to these numbers is however scary because of unfounded fears:

IMSI number scarcity: The current design of IMSI numbers allows for one million ranges to be issued. Well over half of that range hasn't been allocated to countries yet.
3 digit MNC’s:In Europe all the regulators hand out 5 digits of an IMSI to the mobile operatos as the identification of their mobile network. The standard allows for 6. Some people worry that stuff may break if we move to 6. However some parts of the rest of the world use 3 digits too. Most notably North-America. The technical people tell me it shouldn’t be a problem.
Unfair competition: If private networks could connect, they could compete with public networks in an unfair way, because they don’t have to abide by the same rules. This is completely wrong. A private network implies it’s private and therefore not directly competing with a telco in the market. It just means a company decided to take matters into it’s own hand
ITU rules or European law isn’t up to it. In my opinion it wouldn’t break European law, just bend it a little, the same with the ITU.
Etc.
The scariest thing may be that it creates a world where the regulator is less relevant at first sight. It cannot determine anymore the right to participate in the market place up front. It may find out that private networks also will call upon the regulator for its services or to have disputes settled. All of this is scary on an institutional level. Instead of the usual 10-20 people that alway show up at the regulator’s office to represent the telecom industry and 1 or 2 to represent the users, things might change drastically.
Lastly it’s scary, because it’s the internet way of doing things. All the internet cares about is whether there is a network that needs interconnection. RIPE, ARIN, LACNIC, AFRINIC and APNIC have proven with AS-numbers and Provider independent AS-numbers, that they can efficiently run a numbering space that allows everyone access and creates a dynamic and highly competitive market for interconnection that hardly needs any regulation. If we use the same rules to give access to E.164 and E.212, the telephony world would be way more competitive then it now is, with less regulator involvement.

So please, if you know a regulator, ask them to consider this. Thousands of companies and consumers will thank you later on.

Virgin Media Speedtest: 50mbit only 2 percent more revenue.

noreply@blogger.com (Rudolf van der Berg) — Wed, 27 Oct 2010 21:45:00 +0000

As you know I've been arguing for simplifying the broadband offers to the French model of 1 price that gives the highest speed to all customers. My argument being this simplifies the marketing and the back office.

Chris Marsden spotted the Virgin Media broadband subscription numbers and notices that only 3% take the 50mbps subscription. Only 90,000 subscribers are willing to pay 10 pounds a month extra for the top of the line. Only 9 percent of customers take the 20Mbps version. So a grand total of 88% take the cheapest offer. The question then is, how much this brings in extra

Top of the line: 900k extra compared to the Medium and 1,350k per month compared to the simple version
Middle of the line: 3 million a month extra compared to the medium

So roughly 52 million pounds extra a year as the result of all that differentiation. All that compared to a quarterly revenue of 660 million for the cable business. A dismal 2 percent extra these customers bring in.

The biggest problem is to assess the costs side. Is it costing them more or less than 50 million to support the complexity. But I am willing to wager it is costing them in the double digit millions to support this. Just because everything they do has to keep in mind the three offers. It's not just the back office but also the print campaign. On top of it every temporary offer to tease the customer has to take this into account. It's a proper hassle.

So if this was a speedtest, would you really be racing for the 50Mbit offer to differentiate your product?

Update: Dutch regulator OPTA threatens hotels offering internet to guests

noreply@blogger.com (Rudolf van der Berg) — Tue, 12 Oct 2010 19:50:00 +0000

Update: 28-10: Hotels aren't telecomproviders the OPTA has confirmed. It had approached 15 organisations. Only 3 organisations who delivered ISP services to multiple hotels were asked for extra information. Hotels, conference centers and installation companies who install hardware were not deemed telecommunications providers.

Update 14-10: Only 10 hotel. chains were asked. If some of them route their own internet traffic, ie have an AS number and routable traffic, then it may be that they do have to register. But it's a big if. See Webwereld, where I perform as a pundit

Just when I was writing a longer blogpost on the outdated distinction between public and private telecoms networks (related to M2M), here comes the Dutch regulator OPTA with a reason why we should have some form distinction. OPTA is of the opinion, after a public network complained, that hotels are offering a public network if they are offering internet to their guests. This means these hotels have to register with OPTA and pay 250 euro a year. What I find shocking is that OPTA isn't able to conclude by itself that the complaining public network was completely and utterly wrong. I also wonder why McDonalds wasn't mentioned as a major infringer.

What it also means, and what the press didn't pick up on, is that, according to OPTA, hotels would have to build in lawful interception facilities for the police in hotel networks. (Doesn't mean the police can start an intercept remotely. Just that the hotel would need to have a contract with a commercial organization who, when a warrant comes, would deliver a box to the hotel that would encrypt and transfer intercepted traffic to the police.)

All in all this goes way beyond what most of us envisioned the new regulatory framework for telecoms in the EU to entail. Even the Minister of Economic Affairs saw things rather different in 2003 when he was asked questions on a similar matter with so called "calling shops": small shops where customers can call the rest of the world/third world at discounted rates. The text looks awfully familiar to me, but that might have been because I was working as a civil servant at the ministry in 2003 on lawful interception. :-) The basic reasoning is that as hotels aren't involved in the routing of traffic and just mere endpoints they are not providers of public telecommunications networks and services. If they would route and switch it, it might become different. (Apart from this, many hotels only resell a service delivered by the likes of KPN or Swisscom. The customer enters into a contract with KPN or Swisscom and the hotel receives a kickback, so that certainly rules out hotels as telecom providers)

The quotes in Dutch are:

De Minister van Economische Zaken is niet voornemens de OPTA op te dragen het toezicht uit te breiden naar belhuizen. In het Van Traa rapport worden onjuiste aannames gedaan omtrent registratieverplichting van belhuizen in het kader van de Telecommunicatiewet en tevens omtrent toezichtstaken van de OPTA op integriteit van de netwerken.

De OPTA is een zelfstandig bestuursorgaan dat toezicht houdt op de bepalingen uit de Telecommunicatiewet en de Postwet. Het gaat daarbij om bestuurlijk toezicht. Het is geen taak van de OPTA strafbare feiten op te sporen of de openbare orde te handhaven. Uiteraard kan de OPTA indien zij over aanwijzingen beschikt dat er sprake is van strafbare feiten aangifte doen bij de politie. Voor aanbieders van openbare telecommunicatie-diensten en openbare telecommunicatienetwerken geldt op grond van de Telecommunicatiewet een verplichting zich te registreren bij de OPTA. Deze registratie heeft primair als doel het de OPTA te vergemakkelijken om het aan haar opgedragen bestuurlijke toezicht te houden. Immers door de registratie weet de OPTA wie er op «de markt» zijn. Of een belhuis verplicht is zich te laten registreren hangt onder meer af van de vraag of de dienst die wordt geboden geheel of hoofdzakelijk bestaat in het overbrengen van signalen via elektronische communicatienetwerken. In die gevallen waar een belhuis zelf een deel van het transport verzorgt zal daarvan sprake zijn en dient het belhuis zich te registreren. De typische dienst van een belhuis bestaat echter uit niet veel meer dan het beschikbaar stellen van een ruimte met enkele telefoontoestellen waarmee, omdat deze zijn aangesloten op het telecommunicatienetwerk van een (registratieplichtige) aanbieder, kan worden getelefoneerd. Is dat het geval dan is er dus geen plicht tot registratie.

Zonder registratieplicht is er geen wettelijke grondslag om (deze) bedrijven toch te registreren, en zijn dwangsommen dus niet aan de orde. De bestaande grondslag in de wet zou dan eerst moeten worden verruimd. Een complicatie zou daarbij zijn dat er een hele categorie bedrijven bestaat die naar de aard van telecommunicatie eigenlijk niet zijn te onderscheiden van belhuizen bijvoorbeeld wanneer ze in hun lokaliteit een betaaltelefoon hebben geïnstalleerd (restaurants, cafés, snackbars, kappers, computershops, hotels enz., waarschijnlijk tienduizenden of meer) of internetcafés.

Naar het oordeel van de Minister van Economische Zaken zou deze poging tot registratie van deze gehele groep een buitenproportionele maatregel zijn. In elk geval zouden daarmee aanzienlijke nieuwe administratieve lasten worden geïntroduceerd. Het zou in verband daarmee tot gevolg hebben dat veel openbare betaaltelefoons waarschijnlijk zullen worden verwijderd, en dat intenetcafés zullen stoppen (omdat het voor sommigen dan te veel rompslomp wordt en omdat registratie waarschijnlijk ook niet kosteloos kan) hetgeen maatschappelijk zeer ongewenst is.

En dit staat ook allemaal nog los van de vraag of registratie bij OPTA een belhuis zou hinderen om malafide activiteiten te entameren. Een eventuele registratie van belhuizen voegt weinig toe aan de mogelijkheden van politie en openbaar ministerie bij de opsporing en vervolging van strafbare feiten.

Kortom, de telecommunicatiecontext van belhuizen biedt volgens de Minister van Economische Zaken geen bruikbare aanknopingspunten voor het aanpakken van problemen zoals door u genoemd.

The longer post on public and private networks is related to the M2M work and will follow later. I did find out today that VON Europe had asked BEREC to remove the distinction between public and private networks for numbering issues, but so far hasn't gotten anywhere. Not a happy thought.

I'll be speaking at Telco 2.0 on M2M, London, Nov. 9-10

noreply@blogger.com (Rudolf van der Berg) — Tue, 12 Oct 2010 11:54:00 +0000

I've been invited to speak at the Telco 2.0 EMEA event in London, Nov 9-10. My topic will be M2M and so I'll be part of the M2M session on the second day. Unfortunately this does mean I won't be speaking at the FTTH Forum in Budapest, which is on the same day, but that one comes recommended too. My attendance of the one and not the other is related to my employers interests.

I'll be speaking along the lines of the research I did for the Dutch government into M2M and the impact on telco business models.

For those of you in London, I'm free to meet up on the 8th and possibly on the 11th. Drop me an e-mail or a phone call if you would like to.

Killed! Milking someone else's customer: Fake voicemail.

noreply@blogger.com (Rudolf van der Berg) — Fri, 08 Oct 2010 09:15:00 +0000

Update October 12th: KPN has now killed the bad idea, because there were too many negative reactions.

KPN has come up with a brilliant way to make more money: Fake Voicemail, telecompaper reports. They need to, the financial targets are tough. (addendum: Friend of mine suggests it's a violation of common carrier status, or net neutrality. Interesting way to look at it. Imagine a fixed line and an answering machine, where this kicks in before the answering machine)

Normally if you call a mobile number and it isn't answered and the user hasn't activated the voicemail, after 90 seconds it will stop ringing. Now KPN has introduced a message after 30 seconds telling people that the phone isn't answered and that there is no voicemail. I call this fake voicemail. The fantastic thing of fake voicemail for KPN is that it can charge the 'termination rate' to someone else's customer (or its own customers for that matter), who hasn't asked for the message and was perfectly capable to understand that the other person didn't pick up the phone.

To keep you on the line longer and pay more, there is also a whole menu of options for those wanting to leave a message, that can be accessed through KPN's online portal etc. KPN is serious about this squeezing of someone else's customer and has announced it will come up with more types of services that incur a charge.

To me this just shows how easily exploited the termination rate system is and why it should be abolished altogether. The benefit of the service lies with the called network and the called person. Furthermore they have chosen to activate it on their network. If customers like this kind of service, let them become KPN customers.

I would suggest KPN to do a similar thing for all of it's fixed lines. The termination rate is less, but how hard can it be. :-) Other possible solutions would be to randomize the time the caller is sent to voicemail. Some people are way to good at guessing when to cancel the call and not be sent to voicemail. On it's own network it could send people reminder SMS's that inform them the person they called might now be available to take their call.

Another thing that bugs me is that even though termination rates are coming down, I don't see rates for calls to mobile coming down. Termination rates have dropped, but retail prices are remaining the same. It's still around 17 cents per minute to call mobiles.

Internet Thought (on hiatus)

Speaking on Connected Television at IIC/Ofcom on May 2nd

Connected TV and Platforms: evolution or revolution?

International Institute of CommunicationsUK Chapter Event

Interview and Conference on The Internet of Things

Presentation on M2M and market failure at Internet of Things-week

Policy Brief on Internet of Things and Transport

Presentation at Telecom Reform Conference 2012

OECD report on "Developments in Mobile Termination"

OECD publishes report on Internet of Things and M2M

Slides available: BEREC expert workshop on IP-Interconnection (Peering and Transit) in cooperation with OECD

Will speak at FTTH Forum Budapest on Nov 9

New presentation on Machine to Machine communication

Born: Tycho Rudolf Willem

I'll be speaking on WIK's conference on Bundling and Multi-Play

First blogpost for the OECD... on International Women's Day (of course)

May the best (wo)man win

This blog is going on (semi-)hiatus

Celebrating Bill St. Arnaud and his wireless vision

The truth about 3 digit Mobile Network Codes (MNCs) E.212

GSM Association

Annex

Technical Issues Relating to the introduction of Three Digit Mobile Network Codes (MNCs).

Introduction / Background

SIM Cards:

Handsets:

Network:

Billing & Customer Care Systems:

Roaming:

Fraud Prevention / Management:

Annex

Technical Issues Relating to the Introduction of

Three Digit Mobile Network Codes (MNCs).

1 Introduction / Background

2.1 SIM Cards

2.2 Handsets

2.3 Network

2.4 Billing & Customer Care Systems

2.5 Roaming

2.6 Fraud Prevention / Management

Leaving Logica to go and work for the OECD in Paris

Wrote an article for Gigaom on Apple and SIMs

The common errors of Telecom CEOs a primer on peering and transit Telecom Cool Wall Why all telecom marketing and product management is wrong

The GSMA changes opinion on programmable SIM-cards

My presentation on M2M at Telco2.0 and my impression of the conference

How regulator's and Telco's are holding up the Internet of Things

Virgin Media Speedtest: 50mbit only 2 percent more revenue.

Update: Dutch regulator OPTA threatens hotels offering internet to guests

I'll be speaking at Telco 2.0 on M2M, London, Nov. 9-10

Killed! Milking someone else's customer: Fake voicemail.

International Institute of Communications
UK Chapter Event

The common errors of Telecom CEOs

a primer on peering and transit

Telecom Cool Wall

Why all telecom marketing and product management is wrong