ENUM: The Collision Of Telephony And DNS Policy

Abstract:     
ENUM marks either the convergence or collision of the public telephone network with the Internet. ENUM is an innovation in the domain name system (DNS). It starts with numerical domain names that are used to query DNS name servers. The servers respond with address information found in DNS records. This can be telephone numbers, email addresses, fax numbers, SIP addresses, or other information. The concept is to use a single number in order to obtain a plethora of contact information.

By convention, the Internet Engineering Task Force (IETF) ENUM Working Group determined that an ENUM number would be the same numerical string as a telephone number. In addition, the assignee of an ENUM number would be the assignee of that telephone number. But ENUM could work with any numerical string or, in fact, any domain name. The IETF is already working on using E.212 numbers with ENUM.

ENUM creates multiple policy problems. What impact does ENUM have upon the public telephone network and the telephone numbering resource? For example, does this create a solution or a problem for number portability? If ENUM truly is a DNS innovation, how does it square with the classic difficulties experienced with DNS and ICANN? Is ENUM, while presenting a convergence solution, also encumbered with the policy problems of both the DNS and telephony worlds?

IETF ENUM proponents suggest that ENUM needs a single unified database administered through national and international government sanctioned monopolies. The IETF took the unusual step of requesting that the International Telecommunications Union (ITU) regulate an aspect of the Internet, that is, participate and have authority over the international ENUM service provider. But this notion of establishing a new communications monopoly collides with the deregulatory efforts of the Telecommunications Act of 1996, the attempts to privatize DNS through ICANN, and US policy that the Internet should be left unregulated. ENUM is an unproven innovation with no evidence of commercial viability. It faces a strongly competitive market of other directory assistance innovations and services. Proponents are asking governments to sanction one competitor over others.

ENUM offers two lessons. First, involving the government in a standards process is fraught with problems and delays. It starts with the cliche of having too many cooks in the kitchen, producing a mediocre cake at best. And it ends with a cumbersome bureaucratic process resulting in fatal delay and ultimately collapsing in upon itself. Similar efforts in the past rose to grandiose levels and failed. These include X.500 and OSI.

Second, a number by any other name remains a number. A significant portion of the DNS wars has been focused on resolving who has the right to a name. Is it first come, first serve, a trademark holder, someone using the domain name pursuant to free speech rights, or perhaps some other right? With ENUM, the question presented is who has the right to a numerical string. ENUM attempts to resolve this question by convention, concluding that the assignee of a telephone number has rights to an ENUM number. But an ENUM number is not a telephone number. A telephone number is an address used on a telephone network to reach a telephone. An ENUM number is a token used to access a database. Transferring a numerical string from one context to another does not likewise transfer the rules and regulations of the original context. Rules and regulations created for telephone numbers assume a particular purpose in a particular context; they do not apply to numerical strings in a foreign context with a different purpose. It is illogical and dangerous to transfer the policy concerning one type of number to a different type of number. This means, among other things, that the regulatory authority over telephone numbers has no more jurisdiction over ENUM numbers then when telephone numbers are used to rent videos or access savings clubs at the grocery store.

US policy has been to keep information technology unregulated to permit it to innovate at the speed of the market and not at the pace of bureaucracy. Yet ENUM proponents beg for government entanglement. It would be unprecedented for the government to sanction a monopoly for something as unproven as ENUM where the appropriateness of a government monopoly has not been demonstrated. Were such government involvement in fact approved, the delay experienced would likely be fatal to the innovation.

There are those who are strong advocates of an ENUM unified database. An ENUM unified database can likely be achieved by private industry through some level of a joint venture devoid of government entanglement. This is the best hope for ENUM achieving the goal of a swift implementation.

Keywords: Internet, ENUM, DNS, NANP, ITU, IETF, FCC

JEL Classifications: K0, K2, K3,

Working Paper Series