ECC Newsletter April 2016 – M2M Special Edition

Numbering resources in support of M2M

Not all M2M devices will require public numbering resources but in the coming years the demand will be significant. That was the consensus of the attendees at the CEPT workshop on Machine to Machine (M2M) communications in March.

We heard from a range of speakers, and in typical numbering expert fashion, they wowed us with a multitude of statistics.

Mike Corkerry, Head of the External and Regulatory Affairs Function at AT&T EMEA, had lots of figures. He said the world is sitting on the “verge of a fourth industrial revolution being powered by the Internet of Things (IoT)”, and that Cisco estimates that 50 billion things will be connected to the internet by 2020. Such objects will range from smart meters to sensors in cars to household appliances.

The eSIM

Much of the discussion around numbering and M2M was based on embedded smart card technology, the eSIM or eUICC (embedded Universal Integrated Circuit Card).

This is a platform that is used for any mobile telecommunication system. It hosts all the tools, physical interfaces and logical interfaces to communicate between the card and the mobile device. It is not restricted to telephones and could be used to support banking applications, utilities, manufacturing and so on.

One of the keynote speakers Johannes Vallesverd, Chairman of the CEPT ECC Working Group on Numbering and Networks, said the drive for eSIMs comes from “the inherent difficulties there is when you want to change SIM cards in M2M applications”.

Despite its diminutive proportions, the eSIM could be a major solution provider, especially in solving the “operator lock-in” issue.

“It could be an economical disaster to send out technicians to change SIM cards and sometimes it can even be dangerous,” said Mr Vallesverd.

He referred to a smart meter buried in the ground, which might use a removable SIM but a sealed box makes access very difficult. Constraints like temperature, vibration and humidity mean that SIMs sometimes need to be soldered to the circuit board of the device.

The point was echoed by Xavier Piednoir, Technical Officer to the Technical Committee on Smart Card Platforms at ETSI. He gave a fascinating talk about the emergence of the eSim on a global scale.

Mr Piednoir pointed to other examples where SIMs could be difficult to reach – such as vending machines and car communication modules.

“If you cannot easily replace the card, does it translate to 'I have to stick with the network provider'? There is a need to change and manage subscriptions without having physical access to the device. We need these mechanisms to be standard,” said Mr Piednoir.

Doing so will mean convenience for consumers and convenience and cost-effectiveness for manufacturers.

This throws up issues around who owns the eSIM. At present the mobile network operator owns it, but when it is soldered into the device does ownership and responsibility transfer to the device manufacturer?

“If network operators are not choosing the SIM card anymore or assessing the security level, how will they find out that the security of the device matches their requirements? It means that the industry will have to converge to a fixed set of algorithms,” said Mr Piednoir.

The eSIM could certainly provide a platform for M2M devices to “leverage economies of scale” within the supply chain. AT&T has devices that monitor containers as they travel around the globe, checking where they are and whether they've been opened. Device manufacturers can eSIM can embed a single SIM into the product, track the device pre-sale and automatically activate it and initiate billing upon sale.

The eSIM presents a number of advantages to consumers: it gets rid of plastic as everything is handled online, according to Mr Piednoir. Also, there is no form factor jungle anymore here SIM cards come in different sizes for different devices. Though, he pointed out that there are some downsides, including no easy SIM swap and if the battery is dead it's “too bad”.

Issues are arising around interoperability.

“We need one or two years before we see products that can be used with any subscription, any device. Easy replacement does not have to translate into a lifetime contract with the card issuer,” said Mr Piednoir.

Connected cars

Mr Corkerry pointed out that, according to research from Machina, connected cars will account for 52% of all cellular M2M connections in 2024.

The connected car allows you to access information on tyre pressure and fuel, and to lock and unlock your doors remotely from a smartphone application. Gartner predicts there will be 250 million connected cars globally by 2020.

Freddie McBride, Numbering and Networks Expert with the European Communications Office also had some interesting stats about cars. He focused on eCall, the European-wide initiative bringing rapid assistance to motorists involved in a collision within the EU. This is a compelling advancement in emergency services and by April 2018 all new cars sold in the EU must to be fitted with eCall.

“We've been looking at the issue of numbering (around eCall) for two years. Does eCall need numbers at all? Cisco say that by 2019, 50% of total M2M connections in Europe will be M2M. We should also look at it from the point of view of the traffic that generates: in the overall M2M market only 3% of connections will be cellular based.”

Essentially a mobile service, eCall needs wide geographic coverage and the ability to roam between networks.

Emergency calls from “simless” devices are not supported in a lot of European countries. eCall in-vehicle systems need an International Mobile Subscriber Identity Number (IMSI) and they need a telephone number (or E.164 number) to make a call and to the emergency services and present a valid calling line identification (CLI) to facilitate callback if needed.

There are some 270 million vehicles in Europe at present and each year 5% of stock is renewed. This means that every year, from 2018, there will be a demand for approximately 13 million new mobile telephone numbers for eCall devices alone.

Mr McBride said there are a number of options: Each country can assign national numbers; there can be dedicated M2M numbers or international numbering resources assigned by ITU-T.

“The biggest risk is that the burden of addressing eCall devices falls disproportionately on larger European countries,” said Mr McBride. These are the countries with strong car manufacturing industries, i.e. where the bulk of cars are made.

National authorities should be engaged with MNOs and the automotive industry to lessen the risk of number exhaustion, according to Mr McBride. Recycling numbers is one way to reduce this but he pointed out that there will be no significant recycling opportunity for at least 15 years.

The WG NaN is actively participating in the European eCall Implementation Platform's Task Force “Lifecycle management” in order to raise awareness of the numbering challenges related to the SIM during the vehicle's life time, and is expected to publish a report in June. The WG NaN may follow up with guidelines in the form of an ECC Recommendation.

Number portability

The relevance of number portability for eCall, or M2M in general, is not obvious as an E.164 number is used for addressing devices rather than a personal subscription. In fact, the workshop found that while number portability is important in many aspects of telecommunications, within M2M it does not seem very relevant.

Mr Vallesverd said: “There are 167 billion addresses available and the amount of assigned numbers is only 167 million. Is there a scarcity of M2M numbering available? Probably not.”

“Number portability is not too crucial for M2M. The most important thing is that you can switch providers easily,” he added.

However, the end-user has a strong right to retain the use of theirnumber when switching, as is laid out in the EU's Universal Services Directive. With this in mind, the issue of portability and the M2M market needs careful consideration in the forthcoming review of the regulatory framework. One outcome of the M2M workshop was that it was recognised this was something worth revisiting in the future to encompass the switching of the M2M connectivity provider.

Panellists agreed that a new European Numbering solution was not necessary. Dr Julia Marquier, Member of the BEREC (Body of European Regulators for Electronic Communications) drafting team and Legal Expert/ Numbering referred to the recent BEREC report on IoT and M2M.

“From a cost-benefit perspective, BEREC believes that the introduction of a European numbering scheme does not seem to carry any significant benefits which would justify the deployment costs of setting up such a solution.”

It found that no special treatment of IoT or M2M communication appears necessary or appropriate except for roaming, switching and portability.

“The use of existing resources seems to be a realistic approach: the extraterritorial use of national numbers and the use of global numbers. There are very high costs to implement yet another layer of numbers,” she said.

However, clarification and/ or a new approach may be appropriate in certain areas. For example, in areas like switching providers, roaming or number portability.

“Roaming is very important in the IoT context because many M2M services, which use mobile connectivity, are currently based on permanent roaming,” said Dr Marquier.

Robert McDougall, Head of Enterprise Regulation at Vodafone, said the tech giant “wholeheartedly supports” BEREC's statement that the number portability obligation might not be appropriate in cases were the E.164 number of the connected device is not known by the IoT user.

Extra-territorial use of E.164 numbers is an inevitable evolution of an inherently global M2M market, however.

Mr Corkerry said: “It would be harmful to insist on ITU global numbering resources as the exclusive, or even preferred, numbering option for deploying global M2M services.”

Restriction on extra-territorial use of numbers would stifle M2M roaming, he added.

“Manufacturers would need to build between 200-700 platforms to have global coverage and each platform costs hundreds of thousands of euros.”

There may be latitude for considering the creation of a light-touch pan-EU authorisation or notification for M2M/IoT. This could, it was found, reflect customer demand and facilitate pan-EU service provision.

Use of national numbers and international ITU-numbers should be considered as complementary options for the provision of global M2M services. Some speakers said they shouldn't be promoted, imposed or prevented by regulation.

National regulation

Francesco Bernabei, Chairman of the ECC/WG NaN's Project Team on Future Numbering Issues talked about ECC Report 153 whose aim is to help National Regulatory Authorities (NRA) in their considerations on efficient numbering and addressing solutions for M2M applications

Options considered in the analysis included existing number ranges and the possible exhaustion of mobile resources in some countries; a new number range; an international numbering solution; network internal numbers and IPv6 addressing.

The report recommended that NRAs, working with market players, should establish solutions for M2M applications as part of the national numbering plan. It found that as a long term solution IPv6 addresses or numbers/addresses other than E.164 numbers should be used for M2M applications.

Permanent extra-territorial usage of E.164 for M2M services should not be prevented by national regulation. Instead, the introduction of 15-digit M2M number ranges should be recommended, it found.

“The important element here is to have a solution that can be used across Europe,” said Mr Bernabei.

At the M2M workshop, it was agreed that some of the challenges with international resources could be investigated further. However, transparency regarding the extra-territorial use of national numbers needs to be promoted, without putting disproportionate burdens on the M2M market.

Security issues

Security and protection of data was a topic that arose time and again over the course of the two-day workshop. Mr McDougall spoke about how M2M was changing the way Vodafone is looking at how it does business.

“Data has a very important role to play. We have to put the right security and safety safeguards in place,” said Mr McDougall.

Dr Marquier drew attention to the fact that personal data may be collected by a number of devices. “If you have a sensor in your heating and it collects information from you such when you are home there are security issues,” she said.

With every new piece of technology, there are still questions to be answered and issues to be solved.

Collaboration between key stakeholders is necessary to ensure that the most appropriate solution is found, according to Mr McBride.

“From a numbering plan management perspective the numbering solution should provide sufficient capacity in the long term and be efficient and sustainable.”