BoR_PC07_(15) - berec

Transcription

BoR PC07 (15) 13
Transatel
192, avenue Charles de Gaulle - CS 10034
92523 Neuilly sur Seine Cedex - FRANCE
Tél : +33 (0)1 74 95 74 00
Fax : +33 (0)1 70 75 24 80
Berec
[email protected]
Date : 6 novembre 2015
Object: Public Consultation on the BEREC draft Report on Enabling the Internet of Things
Dear Sir or Madam
Transatel would like to thank the BEREC for the Public Consultation on the draft Report on “Enabling
the Internet of Things”. You will find below our contribution to the public consultation (i.e.Transatel
answers to the questions listed in Annex 3).
Of course, we stay at your disposal if any other information are necessary.
Yours sincerely,
Stephane Puyraveau
Head of Legal & Regulatory
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[email protected]
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BoR PC7 (15) 13
BEREC Draft Report on Enabling the Internet of Things
Annex 3: Questions to stakeholders
1. How do you evaluate the three options mentioned in section 2.2.1.4 (extra-territorial use of
national E.164 and E.212 numbers, use of global ITU numbering resources, use of a European
numbering scheme) for the provision of M2M services ? Which of these solutions is preferable
to address the need for global marketing of connected devices? Should these solutions be used
complementary?
Transatel position:
The three options mentioned by the BEREC are the following:
-
Extra-territorial use of national E.164 and E.212 numbers to support M2M services;
Use of global resources assigned by ITU;
Use of a European number scheme.
Our vision is that the three options above mentioned are complementary for M2M usage.
-
The use of national numbers to support M2M services should be considered as being national
roaming in the country from which the numbers are issued. So that such numbers do use the
national network (national roaming in case of a Full MVNO in this country) and when it goes
outside this country this is on the basis of an international roaming agreement. If the SIM card
is used in the territory of the EU, the roaming regulation should apply as long as this is used in
two different countries at least, and so as long this is not for a permanent roaming usage (limited
to one given country outside the home country). And when the SIM card goes outside the EU,
this is on the basis on the international roaming agreements. The extra territorial of the national
numbers in this context should be authorised;
-
The European numbers should be used in the territory of the EU by default and be considered
as being local in each country of the EU. Extra territorial use of those numbers (outside the EU)
should also be authorized. Such use in the EU territory should be considered as being local
which means that the communications being made are not subject to the EU roaming regulation
(the ability and the conditions under which the could be used is subject to the commercial
conditions agreed between the M2M service provider and the visited network operator). When
the SIM card goes outside the EU, then the international roaming framework is applicable. Of
course the permanent roaming in the UE should be explicitly authorized by the EU regulation;
and
-
The ITU numbers could be used on a worldwide basis. They are local everywhere in the world.
The permanent roaming should be authorized. The access conditions should be negotiated
country by country.
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According to Transatel:
BoR PC7 (15) 13
This is also important to note that a harmonization on the Mobile Termination Rate (MTR) in the EU,
particularly when the European resources are used, should facilitate the development of the new
innovative M2M services in the EU.
2. How do you regard the market situation in the M2M sector with regard to permanent roaming
and national roaming?
Transatel position:
In the international context, the permanent roaming should be explicitly authorized because this is for
M2M service providers a structural component of new business models (for example, in the automotive
sector).
In the national context, this is an issue for competition matters. However, the national roaming should
be also encouraged because it offers a lot of business opportunities (for example, secured
communications).
3. Which solution – OTA provisioning of SIM or MNC assignment to M2M users – do you think is
preferable to facilitate switching between connectivity providers in the M2M sector? Which
advantages, which disadvantages are attached to the two solutions?
Transatel position:
-
It has been demonstrated in the Full MVNO environment that the MNC assignment to M2M
users’ solution authorizes a switching from an operator to another operator overnight and for
massive customers bases. On the other hand, the OTA campaign are limited to the SIM cards
that are under the OTA coverage, and there are always devices that are not reachable,
particularly into a M2M context (where the SIM cards could be hidden in a connectivity module
or a machine). So the OTA campaigns are always long and not perfect because some of the
SIM cards cannot be reprogrammed, and, as mentioned in the BEREC report, this is not a
demonstrated solution as of today.
-
There is no problem of scarcity because it is possible to use a shared MNC that are unlimited
(the M2M service provider can use a technical and neutral enabler that owns its own MNC and
distributes a dedicated MNC to M2M service providers allowing them to switch their mobile
network operators overnight).
-
The operational costs of the migration seem to be very limited because the switching cost itself
is really rapid and not significant, provided the new access agreement with the new mobile
network operator is in place (so the real cost is the technical implementation of the new
agreement with the new mobile network provider, which is itself really limited in an international
roaming context).
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Transatel clearly thinks that the MNC assignment to M2M users’ solution is the best solution, for the
following reasons:
BoR PC7 (15) 13
-
The M2M service provider does not need to acquire its own (costly to manage) mobile network
infrastructure while operating its MNC, because it can use a technical and neutral enabler, which
enabler can offer a personalized and dedicated technical environment that meet the objectives
and plans of the M2M service providers.
4. Do you think there is a need to adapt Art. 13a. of the Framework Directive to address security
concern in the M2M context? If so, which adaptations do you consider to be useful?
Transatel position: we have no opinion at this stage.
5. Do you think there is a need to adapt the Privacy Directive and ePrivacy Directive to address
privacy concerns in the M2M context? If so, which adaptations? Do you think that the reform of
the Privacy Directive as foreseen in the Council’s General Approach of June 15 2015 on the
future General Data Protection Regulation goes in the right direction?
Transatel position: we have no opinion but we agree that new measures may need to be defined
particularly to protect the personal data.
6. What is the impact of open and proprietary standards on the development of the M2M sector?
What are the advantages and disadvantages of open and proprietary standards, taking into
account that M2M services may be provided on private or public networks?
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Transatel position: we have no opinion on this issue at this stage.

BoR_PC07_(15) - berec

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