Network Element Access for ENUM Provisioning A.M. Rutkowski VeriSign, Inc Document: Expires: 9 Oct 2002 9 Apr 2002 FACILITATING PRIVATE COMPETITIVE PROVISIONING OF ENUM AS A PREFERRED TECHNICAL, OPERATIONAL, AND REGULATORY CHOICE Status of this Memo This document is an Internet-Draft and is subject to all provisions of Section 10 of RFC2026. Internet-Drafts are working documents of the Internet Engineering Task Force (IETF), its areas, and its working groups. Note that other groups may also distribute working documents as Internet- Drafts. Internet-Drafts are draft documents valid for a maximum of six months and may be updated, replaced, or obsoleted by other documents at any time. It is inappropriate to use Internet-Drafts as reference material or to cite them other than as "work in progress." The list of current Internet-Drafts can be accessed at http://www.ietf.org/ietf/1id-abstracts.txt The list of Internet-Draft Shadow Directories can be accessed at http://www.ietf.org/shadow.html. Abstract ENUM is an Internet information service for the benefit of private users of the Internet. It makes use of authoritative E.164 telephone number data maintained among public telecommunication service providers to enable some useful value added messaging services on the Internet. Anyone can (and several companies do) provide these ENUM services competitively today without government involvement or regulation. Other providers can enter the marketplace. Although one ENUM provisioning option is to denominate a particular Internet offering worldwide as "public" and "authoritative," there are significant technical, operational, and regulatory burdens and costs created that make the prospect rather daunting at best. It is also unnecessary. A more effective alternative is to facilitate ENUM service providers' access to authoritative E.164 number and customer information through fair and non-discriminatory contractual arrangements with public telecommunication service providers, and leave the rest to a competitive ENUM provider marketplace and the commercial relationships between Internet Service Providers and public telecommunication carriers. 1. ENUM as an exclusive authoritative PUBLIC service on the Internet ITU-T Recommendation E.164 exists for the purpose of coordinating the use of Public Telecommunication Services worldwide according to typically heavily regulated national provisioning arrangements for these services. The Internet by contrast is a means for private users of computers to share resources and effect applications among themselves. Internet uses do not constitute Public Telecommunication Services. Typically in most countries, as well as public international law, Internet users and their service providers are not subject to substantial regulation. ENUM is a means for private Internet users to potentially obtain some additional enhanced services via the Internet using E.164 public telecommunication plan numbers. Some existing Internet service providers have begun to offer these ENUM services to Internet users. The ENUM technology, standards, and marketplace are constantly changing, and will continue to do so in uncertain ways. It is typically not an arena where government intrusion is advisable. Some parties propose that ITU's Study Group 2 and all of its Member States give recognition to and implement an exclusive, global, authoritative, public ENUM service. It is asserted that this is necessary to provide individual Internet users with an uncomplicated, accurate single service option. In this conjunction, the same parties desire the Telecommunication Standardization Bureau be used as a clearinghouse among Member States for a private party implementation of the public ENUM service. What such a proposal ignores, however, is the specific, special purpose of E.164 numbers for the Public Telecommunication Services that are tailored to significantly different national provisioning and regulatory requirements in every Member State. Those differences among Member States today are harmonized through complex commercial relationships among public telecommunication providers worldwide that provide for sharing information to effect specific services among the providers. Operationally, there is no hierarchical tree; and today's Public Switched Telecommunications Network using the Intelligent Network is a testament to how distributed protected databases and commercial relationships can provide robust and effective capabilities analogous to ENUM. It also seems dubious that the ITU and all its Member States must adopt a single, globally recognized and regulated public ENUM schema - based on the premise that individual private Internet users will be configuring and maintaining all their complex ENUM service and identifier mapping information. More likely, it will be public telecommunication carriers and Internet Service Providers providing maintaining the technical configuration information based on customer preferences and provider contractual relationships - just as it is done today. 2. A Better Approach: Facilitating accurate private ENUM provisioning Public Telecommunication Private Network Networks and Services Resources and Services Intelligent Network Internet ------------------- -------- distributed authoritative ENUM implementations in E.164 number databases <---------> diverse DNS zones ^ | | |_| ENUM Service Providers | obtain access to Intelligent | Network E.164 Network Element | databases on fair and non- | discriminatory terms Figure 1 Under current law, policy, and business practices in most countries, the Intelligent Network based E.164 Network Element databases for Public Telecommunication Services remain authoritative. This is the information resident on the left side of the above diagram. Administrations and Public Telecommunication Service providers have an interest in assuring to the extent possible, that ENUM service databases on the Internet reflect accurately, authoritative E.164 Public Telecommunication Service information. An effective course of action is to facilitate Internet ENUM services via a standard interface service whereby all ENUM service providers could obtain access to those Network Element databases. The Intelligent Network access interface could be provided on fair and non-discriminatory terms that provide for proper security, accounting, and consumer protection. This would serve as an effective, far less administratively and operationally burdensome alternative to a single, exclusive Internet "public" DNS ENUM. This alternative would also allow existing telecommunication carriers to provide, if they choose, the ability for customers to create ENUM DNS resource records within the Intelligent Network, for porting to Internet ENUM services providers using Internet-friendly protocols such as SIP. Such a result would allow each national administration or region to maintain its autonomy and regulatory approaches. It would facilitate the rapid emergence of flexible and dynamic markets in Internet-based value-added mapping services beyond just ENUM. Appropriate liaison with Study Group 11 should occur to enable this work, to the extent that these interfaces do not already exist in Q-series recommendations. 3. ANNEX - E.164 Operational and Policy Frameworks 3.1 Public Telecommunication Networks The global framework for numbering for international public telecommunication services is currently manifested in ITU-T Recommendation E.164. It came into existence and evolved over the past 50 years in conjunction with Q-series signalling standards that have grown and evolved to constitute the Signalling System 7 based backplane and myriad associated Intelligent Network database systems. [1,2] This E.164 framework allows national administrations to maintain independent, autonomous numbering plans that are integrated with associated national provisioning and regulatory schema. For example, in some countries such as the USA, E.164 numbers are defined by statutory law to constitute Network Elements with attendant regulatory and extensive provisioning infrastructures that have come into existence and evolved over the past fifteen years to encourage open provisioning of E.164 related information. [3] Typically in many countries, the access and use of the databases is subject to extensive national and local requirements related to competition laws, emergency services, national security, lawful interception, and consumer protection. These requirements typically have been put into place over many years through extensive public rulemaking proceedings. This complexity of the E.164 database infrastructure arises in large part because these databases are "public" and support public telecommunication services. The use of the term "public" and the associated services also has significant implications under ITU public international law treaty instruments. These E-Series and Q-Series Recommendations and their regional and national counterparts that have become incorporated into telecommunication industry products and services through vast deployments of Intelligent Network infrastructure. This infrastructure provides authoritative E.164 based information that has high security, reliability, availability, and privacy protections, while at the same time providing stable business-oriented contractual arrangements among all providers concerning use of the shared data. It has brought a degree of innovation and innovation to the public telecommunications infrastructure that in some ways rivals that of the Internet. [3] The providers in the marketplace have relied on customary contractual and business arrangements to synchronize and authenticate their databases with the authoritative ones resident on the SS7 Intelligent Network. 3.2 The "Private" Internet The Internet is substantially different from the public telecommunications infrastructure. It is an open, private shared user network based on the TCP/IP protocol where users can autonomously share their computer-based resources. [4] It was created and has grown and evolved as an ensemble of largely privately provided resources that are autonomously shared among what are now hundreds of millions of users. Unlike the public telecommunications networks, the Internet has no universal "public" services. The growth of Internet messaging services, especially IP telephony, has produced a demand for gateway services to the public telecommunications infrastructure. Part of that demand has included the creation of E.164 based value-added information services that borrow data from the existing authoritative Intelligent Network E.164 based databases and seek to provide additional functionality. Many different E.164 based Internet value-added services have evolved over the past ten years, employing diverse protocols and feature sets. Some make use of the Internet Domain Name System (DNS) protocol, and those implementations exist in the marketplace worldwide.[5] Typically these Internet telephony number mapping services are denominated "ENUM." Recently, one particular DNS protocol variant has been developed as a draft protocol specification by an Internet standards forum - the Internet Engineering Task Force (IETF) - as RFC 2916 - although it is currently being extensively revised and renamed. The protocol used in RFC 2916 began to be used by various Internet Service Providers globally to provide mapping services in various Internet DNS domains. In addition, the Internet Society's Internet Architecture Board (IAB) is seeking to denominate a specific ENUM brand as an exclusive "public" database offering under the brand name space e164.arpa, and obtain the sanction of the ITU and regulatory authorities worldwide. 4. Security Considerations The existing framework for E.164 numbers as Network Elements within the Intelligent Network is highly robust and secure. 5. References This document is also Temporary Document D.__, ITU-T, Study Group 2 meeting Geneva, 7-16 May 2002 [1] Rutkowski, Development and Basis of International Telephone Numbering, Internet Draft , 12 Mar 2001. This document provides extensive source citations to development and evolution of ITU International Telephone and Telecommunications Numbering Plans. [2] See, e.g., ITU-T Q-Series Recommendations, Switching and signalling, http://www.itu.int/rec/recommendation.asp?type=products&lang=e&parent= T-REC-Q, especially Q.1200 et seq., General series Intelligent Network Recommendation structure; International Engineering Consortium, International Intelligent Network (IN), http://www.iec.org/online/tutorials/intern_in/; Illuminet, Number Portability, , 26 Sep 2001. [3] See, e.g., European Commission, GREEN PAPER on a common approach in the field of mobile and personal communications in the European Union, http://europa.eu.int/ISPO/infosoc/legreg/docs/greenmob.html; European Commission, Telecommunications: Open Network Provision, ONP List of Standards, http://europa.eu.int/ISPO/infosoc/telecompolicy/en/englishonplist6.doc ; Communication from the Commission to the European Parliament and the Council regarding the consultation on the Green Paper on a Numbering Policy for Telecommunications Services in Europe, COM (97) 203, < http://europa.eu.int/ISPO/infosoc/legreg/docs/com97203.html; European Union, Council Resolution of 17 January 1995 on the lawful interception of telecommunications, Document 496Y1104(01), http://ue.eu.int/ejn/data/vol_c/7_resolutions/cooperation_policiere_et _douaniere/c-329-04111996-1-6-en.html; FCC, Report and Order (Computer III), 104 FCC 2d 958, 16 Jun 1986; FCC, Order (Intelligent Networks) in CC Doc. 91-246, 4 Dec 1998; U.S. Congress, Telecommunications Act of 1996, Pub. L. No. 104-104, 110 Stat. 56, codified at 47 U.S.C. Secs 151 et seq., http://www.fcc.gov/Reports/tcom1996.pdf; FCC, Implementation of the Local Competition Provisions of the Telecommunications Act of 1996, CC Docket No. 96-98, First Report and Order, 11 FCC Rcd 15499 (1996) http://www.fcc.gov/Bureaus/Common_Carrier/Orders/1996/96325err.zip, http://www.fcc.gov/ccb/local_competition/fcc96325.html; FCC, Third Report and Order and Fourth Further Notice of Proposed Rulemaking, FCC 99-23, 5 Nov 1999 http://ftp.fcc.gov/Bureaus/Common_Carrier/Orders/1999/fcc99238.pdf; FCC, Clarification Order and Second Further Notice of Proposed Rulemaking in CC Docket No. 96-115, FCC 01-247, 7 Sep 2001, http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-01-247A1.pdf; FCC, Notice of Proposed Rulemaking (Triennial Review), FCC 01-361, 20 Dec 2001; U.S. Congress, USA Patriot Act, Public Law 107-56, Nov 2001; http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-01-361A1.pdf; FCC, Notice of Proposed Rulemaking (Directory Listing Competition), FCC 01-384, 9 Jan 2002; http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-01-384A1.pdf [4] See, e.g., Souheil Marine, Telecom network migration to IP and its impact on the future of telecommunications, ITU-T/COM2/INFODOCS, http://www.itu.int/itudoc/itu-t/com2/infodocs/007.html. [5] See, e.g., Robert M. Wienski, IP Telephony Access, Transport and Gateway Fundamentals, http://www.illuminet.com/products/ngc/IPwhite4Web.pdf. [6] Dutcher & McCandless, Internet Draft, ENUM Root Domain, , 20 Feb 2002; Verisign, The DNS RBL Service - An Existing Robust Example for Effective Implementation of Multiple Domains For ENUM, ITU-T Delayed Contribution to SG2 Meeting 7-16 May 2002, Doc. D.49 . 6. Author's Address for Comments Anthony M. Rutkowski Vice President VeriSign, Inc. 21345 Ridgetop Circle Dulles VA 20166-6503 USA mailto:trutkowski@verisign.com tel: +1 703.948.4305 7. Author's Copyright Statement This compilation is expressly placed in the public domain by the author and is available to anyone for any purpose except their assertion of copyright ownership.