Memorandum from Kenneth Westmoreland
1. Gibraltar is currently experiencing serious
problems as a result of Spain's restrictions on its telephone
system. Spain has refused to recognise Gibraltar's international
direct dialling (IDD) code 350, which was first allocated by the
International Telecommunication Union (ITU) in the late 1960s.
When direct dialling between Gibraltar and Spain was established
in 1984, calls to Gibraltar from Spain could only be made using
the code for the neighbouring province of Cadiz, 9567, followed
by the five-digit subscriber's number in Gibraltar, starting with
the digits 4, 5 or 7.
2. Consequently, only 30,000 telephone numbers
in Gibraltar can be accessed from Spain, and 99 per cent of these
have been used up. This includes numbers for mobile telephones,
which cannot be used in Spain, owing to Spain's refusal to allow
its telephone companies to enter into "roaming" arrangements.
3. Spain argues that Gibraltar only has
a population of 30,000, and its motives in demanding more than
30,000 telephone numbers are suspect, pointing to the large number
of offshore finance companies based in Gibraltar. It also accuses
Gibraltar of wanting to offer VAT-free telephone services to Spanish
4. An additional problem for Gibraltar has
been the routing of international calls. Owing to the high cost
of using Gibraltar's telephone companies, many telecom operators
or carriers offering least cost routing, choose to cut costs by
routing their calls to Gibraltar through Spain. Owing to Spain's
refusal to recognise the code 350, the call may not reach Gibraltar,
with the caller hearing an announcement that the number dialled
"does not exist". It is also possible for overseas callers
to use the Spanish country code and area code (34 9567) for calls
5. Furthermore, Spain refuses to recognise
the IDD code 350, on the grounds that Gibraltar is a colony, and
hence, not a separate jurisdiction from the UK, and is not, therefore,
entitled to a separate telephone code. This is in spite of the
fact that these codes are intended solely for making international
telephone calls, and do not imply any recognition of sovereignty.
6. Argentina, for example, maintains a territorial
claim on the Falkland Islands, but it recognises the Islands'
IDD code, 500. Similarly Hong Kong and Macau are now integral
parts of China, but the People's Republic has always recognised
their separate IDD codes. The French Overseas Departments all
have separate IDD codes from that of metropolitan France, which
uses the code 33, although this is because of technical constraints,
as Paris retains responsibility for their telecommunications,
and treats them as part of the French telephone numbering plan.
7. The Government of Gibraltar argues that
other small jurisdiction in Europe, such as Andorra, Monaco, San
Marino and Liechtenstein, now have their own IDD codes, and are
entitled to have as many telephone lines as they wish. Previously,
these jurisdictions were integrated into the telephone systems
of their larger neighbours, with Andorra being integrated into
both the French and Spanish telephone systems.
8. The non-recognition of IDD codes, however,
is not unique to the case of Gibraltar and Spain. A notable example
of this in Europe, is the dialling arrangement from the Republic
of Ireland to Northern Ireland. Instead of using the international
access code and UK country code (0044), calls have been made using
an Irish area code, although it is now possible to use either.
In addition, while San Marino now has a separate IDD code from
Italy (378), it remains fully integrated into the Italian telephone
What's in a Number?
9. In 1998, the European Commission proposed
to the Government of Gibraltar, that Gibraltar use the UK's IDD
code 44, which would make Gibraltar part of the UK's telephone
numbering plan. This is already the case with the Channel Islands
and the Isle of Man, although they are not under the jurisdiction
of the UK's Office of Telecommunication (OFTEL.)
10. Gibraltar's two telephone companies
reluctantly accepted this proposal, but only for calls from Spain,
on the grounds that all other countries recognised the code 350.
The Government of Gibraltar rejected the proposal outright, and
reaffirmed its position that Spain must recognise Gibraltar's
IDD code. However, in the light of the worsening problem, it has
recently stated that the use of the UK's code 44 was a possibility,
but only for calls from Spain, and only then as an interim
measure, while legal proceedings were taken against Spain by the
11. The Government of Gibraltar is against
administrative integration with the UK without political integration,
arguing that Spain has a policy of not recognising Gibraltar authorities,
including its government departments, customs, police, or courts.
This accounts for Spain's refusal to recognise identity documents
issued by the Government of Gibraltar, which have now been redesigned
with the words "United Kingdom" above the word "Gibraltar",
in spite of the fact that Gibraltar has never been part of the
12. The Government of Gibraltar sees administrative
integration with the UK without political integration as "constitutionally
retrogressive", because it undermines the competence of the
relevant Gibraltar authorities, and (supposedly) allows Spain
to demonstrate that Gibraltar is a "pure colony", and
not a separate jurisdiction from the UK. This is in spite of the
fact that Channel Islands and the Isle of Man have always had
a degree of administrative integration with the UK, in the case
of telephone, postal and broadcasting services, despite their
separate constitutional status.
13. Ironically, successive UK Governments
have denied Gibraltar the option of political integration, in
spite of the fact that this has popular support in Gibraltar,
and would be a logical conclusion to any form of administrative
There would be considerable advantages in Gibraltar
being fully integrated into the UK telephone numbering scheme,
thereby adopting the code 44 for all calls. Telephone calls between
Gibraltar and the UK could be treated as domestic long distance,
not international, requiring only the area code and number. Given
Gibraltar's strong social, economic, cultural and political links
with the UK, this might well be to its people's benefit.
14. However, there have been concerns expressed
as to how this would affect Gibraltar's ability to run its own
telephone system, and enter into commercial arrangements with
other countries' telephone companies. The Opposition in Gibraltar
has argued that having a separate IDD code from the UK gives it
a competitive advantage and flexibility, which would otherwise
be subject to outside control. Gibraltar has, for example, expanded
into satellite communications independently of the UK, but there
is, in fact, no relationship between IDD codes and satellite orbital
positionsa change of the former would not affect the latter.
Sharing a Telephone Numbering Plan: The North
15. The experience of countries that use
the North American Numbering Plan, demonstrates that being integrated
into a common numbering plan does not mean that they have any
less competence over telecommunications, nor that they are under
the jurisdiction of the United States Federal Communications Commission
(FCC). The North American Numbering Plan Administration (NANPA)
is independent of any government agency, in the US, Canada or
16. Several UK Overseas Territories in the
region, such as Bermuda, the Cayman Islands, The British Virgin
Islands, the Turks and Caicos, Montserrat and Anguilla, all form
part of the North American Numbering Plan, but like other jurisdictions,
retain sole responsibility for their telecommunications.
17. The use of a common code does not mean
that call charges are identical; in fact, call charges to Bermuda,
Jamaica, or Puerto Rico are much higher than those to the US.
In addition, while dialling arrangements between these countries
are simply long distance, eg: trunk code, area code and number,
the telephone calls can be charged as international, although
calls between the US and its territories, such as Puerto Rico
and the US Virgin Islands, are charged at US domestic long distance
18. This even applies to 1,800 "toll
free" numbers in the US and Canada, which incur international
charges when dialled from, for example, Bermuda, which is also
able to ban the use of "call-back" telephone services
from the US, which allow users access to reduced international
rates. Gibraltar could, therefore, similarly curtail use of UK
long distance carriers, by charging for calls to 0800 "freephone"
numbers used to access those services, even if it were to become
part of the UK telephone numbering plan.
19. An interesting development in 1997,
was the integration of two US territories in the Pacific, the
Northern Marianas and Guam, into the North American Numbering
Plan. Previously, they had their own IDD codes, 670 and 671, but
these were replaced by North American area codes, so that to call
these territories one must now dial 1 670 and 1 671. (A similar
scheme has been proposed for American Samoa, which would change
from 684 to 1 684). The only change that has occurred is that
calls to these territories from the US are now treated as domestic
long distance, not international, and this could serve as a possible
model for Gibraltar vis a" vis the UK.
20. The Government of Gibraltar has stated
that it will not abandon the code 350, and that ultimately, Spain
must recognise Gibraltar's IDD code, as does the rest of the world.
However, this raises questions as to the practicality of using
the UK's code 44 for calls from Spain as an interim measure. If
one were able to telephone Gibraltar from Spain using a UK area
code, then logically, this should be accessible from within the
UK, if not the rest of the world.
21. A possible solution would be to use
a code for inbound international dialling, similar to the North
American code 1 456. This allows callers outside the US
to connect to a specific carrier, for collect calls, rather than
use the US carrier chosen by the local telephone company.
22. However, this raises the question of
where the call terminates. The use of a code for inbound
international dialling only, is to enable people to call their
home country, or a destination within that numbering plan. The
use of a UK area code for calls terminating in Gibraltar,
would undermine the UK's recognition of the code 350, even if
that area code were not accessible from within the UK. This could
strengthen Spanish arguments for the code 350 to be abandoned
23. In addition, given that it has been
possible to make telephone calls to Gibraltar from the rest of
the world using a Spanish code, it is questionable as to how calls
made using the UK code would be restricted. Individual carriers
are accustomed to reprogramming equipment to take account of telephone
number changes all over the world as a matter of course. There
is usually a transitional period, of up to a year, in which both
the new and old codes remain valid, before the changeover is complete.
24. If it were to their advantage to route
calls to Gibraltar using a UK code, as they already do with a
Spanish one, there would be little to prevent them from so doing.
There is, therefore, a difference between recognition of
the code 350 by an ITU member state, and use of that code
by individual telecom operators in that state.
A Compromise Solution?
25. There is in fact a solution that would
allow Gibraltar to be integrated into the UK's numbering plan
without abandoning the code 350, because while the ITU allocates
codes to countries (hence 44 for the UK, 34 for Spain, etc) there
are also codes allocated for international purposes, hence 800
for freephone numbers, 878 for personal numbering, and 979 for
premium rate services. There are already plans underway to create
a European Telephone Numbering Space (ETNS), which would allow
business and individuals to use the same telephone numbers throughout
Europe, prefixed with the code 388.
26. The geographical significance of telephone
numbers, is becoming of decreasing importance, as non-geographical
telephone numbering becomes increasingly popular. This allows
for greater flexibility than geographical numbers, which obviously
have to be changed when users move from one part of a country
to another. By contrast, calls to non-geographical telephone numbers
can terminate anywhere.
27. Hence in the UK numbering plan, numbers
beginning with 070 are personnel or "find me anywhere"
numbers, which can be diverted to any landline or mobile phone,
while numbers beginning with 0800, 0845 and 0870 are freephone,
local rate and national rate respectively. Numbers beginning with
09 are premium rate, while those beginning 05 and 06 will be used
for corporate numbering. Many businesses are also using so-called
"Alphadial" numbers, which are displayed as words, eg:
07002 736822 as 07002 RENTACAR or 07004 356937 as 07004 FLOWERS.
28. Gibraltar's code 350 could become a
pan-European code, for personal numbering, so that while one would
be able to telephone Gibraltar using the UK's code 44, one would
also be able to telephone the whole of Europe using the code 350.
This would have the effect of Spain recognising 350 for calls
to Gibraltar. Telephone users in Gibraltar would have a choice
between using the UK's code 44, or the pan-European code 350,
in much the same way as users in the UK are increasingly able
to choose between geographical and non-geographical numbers. Telephone
calls within Gibraltar, however, would only require the subscriber's
29. In fact, the European Commission proposed
the use of the code 350 for pan-European personal numbering, in
its 1996 Green Paper on the future of telephone numbering in Europe.
This envisaged a single European numbering plan, using the code
3, with codes such as 44 for the UK, 34 for Spain, and 350 for
Gibraltar becoming redundant. However, this proposal was effectively
abandoned, as it was felt that the cost and disruption would outweigh
the benefits of such a scheme, although it may be revived in the
Proposed Use of Numbering Space
350 Numbering Space (Gibraltar and the EU)
+350 010 0000-099 9999 Personal Numbering
+350 100 0000-199 9999 Personal Numbering
+350 200 0000-299 9999 Alphadial Numbering (eg
+350 300 0000-399 9999 Gibraltar Numbering
+350 400 0000-499 9999 Aplphadial Numbering
(eg +350 4FLOWERS)
+350 500 0000-599 9999 Gibraltar Corporate Numbering
+350 600 0000-699 9999 Gibraltar Mobile Numbering
+350 700 0000-799 9999 Personal Numbering
+350 800 0000-899 9999 Reserved for Future Use
+350 900 0000-999 9999 Reserved for Future Use
44 Numbering Space (Gibraltar and the UK)
+44 119 300 0000-399 9999 Residential Numbering
+44 119 500 0000-599 9999 Corporate Numbering
+44 789 600 0000-699 9999 Mobile Numbering