Letterhead image

The Honorable David A. Gross
U.S. Coordinator for International Communications

and Information Policy
Department of State
2201 C Street, N.W.
Washington, DC 20520

Dear Ambassador Gross:

The convergence of telecommunications and computing technologies is once again presenting the United States with an important decision that will impact how our nation will maintain its world leadership in technology policy. We currently have the opportunity to participate or "opt in" to the new global domain set aside for electronic numbering (ENUM), e164.arpa. Because of the potential benefits of ENUM, the Department of Commerce through the National Telecommunications and Information Administration (NTIA) believes that the United States should seize this opportunity and take steps to participate in e164.arpa, consistent with the highest standards of security, competition, and privacy.

As a mapping protocol that links the Internet and telephony platforms through a single identifier, ENUM has the potential to facilitate convergence of communications networks by linking e-mail addresses, telephone numbers, fax numbers, and cell phone numbers for individuals or businesses. To date, thirteen International Telecommunication Union (ITU) member nations, including the United Kingdom, have opted into e164.arpa and are beginning to establish trials to provide ENUM services. The United States has been supportive of ITU work in this area, recognizing that using ENUM through a globally coordinated domain may provide efficiencies and opportunities for global interconnectivity that could benefit both industry and users. As you recall, during the September 2001 Study Group 2 meeting, the United States expressed our support for the ITU's work regarding RFC 2916, the proposed standard for ENUM, which designates e164.arpa as the top-level domain of the ENUM tree.

While NTIA recommends that the State Department continue to support work at the ITU to reach conclusion on the ENUM Recommendations and Supplement, the time has come for the United States to be more active on this issue. Specifically, the United States should move quickly to address certain key preliminary issues regarding U.S. implementation of ENUM and, if resolved satisfactorily, then formally opt in to e164.arpa.

On the domestic side, we must ensure that ENUM can be implemented in a pro-consumer, secure, and competitive manner. In August 2002, NTIA held a forum on ENUM at which industry and non-profit entities discussed the various benefits and challenges of this new technology. There was strong consensus among the forum participants in favor of the United States opting in to e164.arpa, but only if ENUM can be implemented in a way that ensures competition, interoperability, security, and privacy.

Keeping this view in mind, we have developed principles to guide domestic implementation of ENUM. The following principles have strong roots in proven telecommunications and technology policies and are intended to maximize opportunities for industry, while protecting the security and privacy of consumers in the United States:

  • Preserve national sovereignty: Any participation by the United States in a coordinated, global approach must preserve the United States' national sovereignty. That is, the United States and every other participating nation should have the right to determine whether and in what manner ENUM or any alternative is implemented domestically.
  • Support competition: Domestic implementation of ENUM must also allow for competition among providers and operators on as many levels as feasible.
  • Promote innovation: Adoption of ENUM or ENUM alternatives must encourage innovation and promote advanced voice and data services through new products, services, and vendors.
  • Protect users' security and privacy: Domestic implementation of ENUM must be done in a manner that maximizes the privacy and security of user data entered in the ENUM DNS domain. For example, ENUM providers should develop systems to ensure the authentication and authorization of users who enter and update their personal information.
  • Minimize regulation: Governance of ENUM on the international and national level must be accomplished through the least regulatory means possible. For example, a coordinated, global approach to ENUM should not give rise to a new regulatory apparatus to govern international and domestic implementation.
  • Preserve opportunity for alternative deployments: The implementation of ENUM within the United States must not preclude alternative deployments of ENUM or other solutions that may provide competitive alternatives to ENUM.
  • Allow for interoperability: In order to support competition and the emergence of alternative technologies and networks, the implementation of ENUM within the United States should accommodate alternative deployments' interconnection with the ENUM tree.
  • Preserve stability and security: Any implementation of ENUM must not diminish the stability and security of the Internet or telecommunications systems.

Before opting in to e164.arpa, we must ensure that ENUM can be implemented domestically in a manner consistent with the above principles. These factors also should play a role in the selection of Tier 1 operator(s). NTIA is committed to working with the Department of State and the relevant agencies, such as the Federal Communications Commission (FCC), to ensure that ENUM can be implemented in this manner.

Internationally, the ITU procedures to opt in require that each Member State enter its specific country code (or portion of a country code) into the ENUM tree. The United States will need to determine how best to coordinate this process with the nineteen nations in Country Code 1. Once these implementation issues are resolved, the Department of State would make any necessary notifications regarding the United States' decision to opt in. Industry can then establish trials and begin to provide ENUM services to U.S. businesses and consumers.

NTIA is committed to working diligently to resolve these implementation issues with the FCC and the Department of State. These three agencies are beginning a series of meetings to establish processes to determine how to resolve both the domestic and international questions. I look forward to working with you and Chairman Powell to ensure a successful multilateral and domestic review of ENUM so that we can soon begin to reap the benefits of ENUM within the United States.


Nancy J. Victory

cc: Chairman Michael K. Powell

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