Industry Numbering Committee (INC) Report to the NANC October 22, 2010 Adam Newman, INC Chair Natalie McNamer, INC Vice Chair
INC Meetings • INC Meetings: INC held three face to face meetings since the last NANC report. • Next INC Meeting: December 6-10, 2010 (Virtual) • Details on all future meetings can be found at: www.atis.org/inc/calendar.asp
CO/NXX Subcommittee – Correspondence from State Commission (GS-655 & GS-658) • INC received two correspondences from state commission/staff (GS-655 and GS-658) noting a number of concerns. • INC had successful meetings with the active participation of a number of state commission staff at its June and August meetings. • Some of the concerns INC is addressing with new issues, some concerns are outside INC’s purview or would require federal action, and others were addressed through discussion.
CO/NXX Subcommittee – Correspondence from State Commission (GS-655 & GS-658) • INC is addressing the following concerns: • State review of applications during administrator processing timeframes • Thousands-block application processing timeframe was not changed • Issue 698 – Auto-populate total numbering resources on TBPAG MTE form • Issue 693 – SP periodic review of inventory to maintain six month supply • Issue 697 – Voluntary code transfers for LRN purposes when feasible • OCN use in mergers and acquisitions • Issue 691 – Requesting NXXs & NXX-Xs after a merger/acquisition
CO/NXX Subcommittee – Correspondence from State Commission (GS-655 & GS-658) • Issues INC is addressing (cont’d): 3. Volume of codes assigned for LRN purposes • Issue 697 – Voluntary code transfers for LRN purposes when feasible 4. Dedicated codes • Issue 632 – Updates to the dedicated code section of the TBPAG and COCAG • Issue 685 – Evidence of dedicated customer for CO code assignment in a pooling environment • Issue 693 – SP periodic review of inventory to maintain six month supply • In Service vs. Activation • Issue 696 – Clarify the definition of In Service in the Guidelines
CO/NXX Subcommittee – Correspondence from State Commission (GS-655 & GS-658) • Issues INC is addressing (cont’d): 6. Ability of SP to adjust forecasts at application submission • INC explained the necessity for SPs to adjust forecasts • States recognized they have the ability to work with individual SPs when concerns arise 7. Allocation of resources to SPs without NRUF on file • An enhancement in November 2010 to NAS will systematically prevent the allocation of resources to an SP that does not have a complete NRUF on file 8. Reclamation • Issue 693 – SP periodic review of inventory to maintain six month supply • Issue 696 – Clarify the definition of “In Service” in the Guidelines
CO/NXX Subcommittee – Correspondence from State Commission (GS-655 & GS-658) • INC was not able to address the following concerns: • Donation of blocks in single SP rate center in advance of the second SP acquiring numbering resources • The FCC exempts a single SP in a rate center from pooling until a second SP receives numbers in the rate center • States may be able to solicit donations from single SPs prior to second SP entry • Reporting of Intermediate numbers • Intermediate numbers have been defined by the FCC • In Jan. 2003, the NANC requested the FCC to establish a rule making proceeding to clarify Intermediate numbers
CO/NXX Subcommittee – Correspondence from State Commission (GS-655 & GS-658) • Issues INC was not able to address (cont’d): 3. Change of LRN routing architecture to 7-digits • LRN architecture was ordered by the FCC; changes to the 6-digit routing basis of the PSTN are beyond the scope of INC but would require upgrades/replacements of every switch in the PSTN • INC thanks the state commission staff members for their participation.
CO/NXX Subcommittee – Issue 632: Updates to Dedicated Code Section of TBPAG and COCAG • The guidelines previously only directed that a code for a dedicated customer becomes pooled when blocks are donated to the pool. The guidelines did not detail how this was to be done. • Language was added to the guidelines detailing the steps needed to return blocks to the pool from a previously dedicated code. • Outlining the process may help to facilitate the return of unused blocks.
CO/NXX Subcommittee – Issue 685: Evidence of Dedicated Customer for CO Code Assignment in a Pooling Environment • Previously, there was no requirement for SPs to provide documentation to support a customer request for a dedicated code in a pooling area. • A requirement was added to the COCAG and TBPAG that an SP shall provide on its customer’s letterhead documentation of the need for 10,000 consecutive numbers to the PA along with the dedicated code request.
CO/NXX Subcommittee – Issue 697: Voluntary Code Transfers for LRN Purposes When Feasible • Some state commission staff are concerned with the quantity of new NXX codes being opened for LRN purposes. • INC added text to the COCAG and the TBPAG to encourage an SP that needs to be the code holder of an NXX for LRN purposes to investigate the feasibility of a voluntary code transfer from another SP as an alternative to opening a new NXX code. • The Guidelines note that there may be some issues with such transfers that need to be considered. • The Guidelines do not obligate the current code holder to transfer the code.
LNPA Subcommittee – Issue 693: SP Periodic Review of Inventory to Maintain Six Month Supply • Federal rules require that all SPs maintain no more than a six-month inventory. • Some state commission staff are concerned that SPs are too infrequently reviewing their inventories and donating/returning unneeded resources. • Text was added to the COCAG and TBPAG to require SPs to review their inventory semi-annually, at a minimum. • In its Guidelines, INC reiterated that an SP shall donate or return any eligible blocks 10% or less contaminated that are not needed for the SP’s six month inventory per rate center.
RAM Subcommittee – Issue 691: Requesting NXXs and NXX-Xs after a Merger/Acquisition Some state commission staff are concerned with carriers retaining and using non-surviving carriers’ company codes/OCNs when requesting resources post-merger/acquisition. INC Guidelines hadn’t previously addressed OCNs on applications for resources after a service provider merges with or acquires another service provider. 13
RAM Subcommittee – Issue 691: Requesting NXXs and NXX-Xs after a Merger/Acquisition (cont’d) INC added text to the Guidelines to outline the process for changing the OCN associated with numbering resources after a merger or acquisition. INC added guidance in the event a carrier opts to change the company name associated with the company code/OCN. The industry standard for company codes/OCNs allows the acquiring company to retain the non-surviving company codes at its option and use of combined entity company codes/OCNs is also optional under that standard. 14
RAM Subcommittee – Issue 696: Clarifying the Definition of “In Service” in the Guidelines Some state commission staff are concerned that some service providers do not understand that administrative numbers do not satisfy the “In Service” requirements. INC modified the definition of “In Service” in its Guidelines and added clarification on the Part 4 In Service forms to assist service providers in understanding that only Assigned numbers to end users satisfy the “In Service” requirement. New In Service definition: “A code or block for which local routing information appears in the LERG Routing Guide, and one or more telephone numbers within the NXX code or NXX-X block has been Assigned to an end user (FCC 00-104, ¶240). Numbers that are categorized as Administrative, Aging, Intermediate, Reserved, or Available cannot also be Assigned and do not satisfy the In Service requirement.” 15
RAM Subcommittee – Issue 692: Update the 5YY Requirements for Resources The demand for 5YY numbers has increased substantially over the past few years as demonstrated by the implementation of the 533 NPA in 2009 and the anticipated introduction of the 544 NPA in 4Q 2010. INC accepted Issue 692 to review and update the PCS 5YY NXX Code Assignment Guidelines to ensure NANPA and 5YY applicants have a clear understanding of the criteria necessary to obtain these numbers. INC recognizes that the use of these numbers is evolving with technology, and as such INC is working to update the service description for these resources in Issue 702. 16
NARP Subcommittee – Issue 664: Review NPA Allocation Guidelines to Consider NPA Sharing When INC investigated the feasibility of Sint Maarten entering the NANP, feedback was received from several NANP members that NPA sharing should be considered to conserve NANP resources. The INC accepted Issue 664 in October 2009 to investigate potential impacts of providing for the sharing of NPAs among NANP members. The INC members have performed an investigation to determine technical, billing, international settlement, and other operational impacts of sharing an NPA between two or more countries and have noted that significant work would be required to allow sharing of an NPA between countries. 17
NARP Subcommittee – Issue 664: Review NPA Allocation Guidelines to Consider NPA Sharing (cont’d) Although the INC did not specifically provide a recommendation that NPA sharing be considered going forward, the INC did make extensive revisions to the criteria for applications to the NANP, including: Potential recommendations for applicants seeking to join the NANP that may include terms and conditions regarding the use of NANP resources by such applicant country that foster efficient and effective use of NANP resources, including but not limited to NPA and CO Code management and conservation measures and potential NPA Code sharing by Countries, or parts of Countries, or a territory belonging to that Country. (See Section 10 of the NPA Allocation Plan and Assignment Guidelines.) 18
NARP Subcommittee – Issue 676: Review Section 6.2 of the NPA Allocation Guidelines Section 6.2 includes the requirement for NANPA to publish semi-annual NANP exhaust projections and to advise the INC and national regulatory authorities of NANP countries when the NANP is forecasted to exhaust within a 15 year time period. The 15 year period includes 5 years for NANP-wide Uniform Dialing Plan implementation, and 10 years for NANP expansion implementation. The INC published the Recommended Plan for Expanding the Capacity of the NANP in December 2001, located at http://www.atis.org/inc/increp.asp. 19
NARP Subcommittee – Issue 676: Review Section 6.2 of the NPA Allocation Guidelines (cont’d) The INC updated Section 6.2 of the NPA Allocation Plan and Assignment Guidelines to include a description of the Plan and timing necessary to implement the Plan. The INC recommendation adds a fourth digit to the end of the NPA field and an additional digit to the beginning of the Central Office code field, resulting in a twelve-digit numbering plan. The recommendation requires the implementation of the INC Uniform Dialing Plan prior to implementation of NANP expansion. The Uniform Dialing Plan is located at http://www.atis.org/INC/incref.asp. 20
Issues Remaining in Initial Pending • Issue 534 - The Development of pANI Guidelines • Issue 611 - Augmenting the NRUF Verification Procedures
Issues in Initial Closure • Issue 667 - Update PAR for Conference Bridge Access • Issue 680 - NANP Area Definition Revisions • Issue 691 - Requesting NXXs and NXX-Xs after a Merger/Acquisition • Issue 696 - Clarify the Definition of “In Service” in the Guidelines • Issue 697 - Voluntary Code Transfers for LRN Purposes When Feasible • Issue 700 - Clarification to Section 6.3.1 of the NRUF Guidelines
Issues in Final Closure • Issue 632 - Updates to the Dedicated Code section of the TBPAG and COCAG • Issue 649 - Update INC Documents for FCC 09-41, Order Reducing Simple Wireline and Intermodal Ports to One Business Day Interval • Issue 664 - Review NPA Allocation Guidelines to Consider NPA Sharing • Issue 670 - Remove attaching Part 2 form to CO Code request (Part 1) • Issue 676 - Review Section 6.2 of the NPA Allocation Guidelines
Issues in Final Closure (cont’d) • Issue 677 - Remove reference to the AOCN field on the BCR screen from the TBPAG • Issue 678 - Update INC Guideline documents to reflect NIIF Committee Change to NGIIF • Issue 679 - Update Appendix C, Section 2.11 regarding timing to updated records for code reallocation • Issue 681 - COCAG Appendix C and TBPAG Clarifications on Block Contamination • Issue 682 - Update Definition of North American Numbering Plan Administration • Issue 684 - Clarification of Submitting Part 4 for Central Office Codes
Issues in Final Closure (cont’d) • Issue 685 - Evidence of Dedicated Customer for CO Code Assignment in a Pooling Environment • Issue 686 - Update the Definition of Pooling Administrator/Administration • Issue 687 - Update the TBPAG to Specify that All Ported TNs Shall Be Accounted for in the Number of Contaminated TNs on Block Donations and Returns • Issue 688 - Update the TBPAG to Specify that the Certification Statement for Block Reservations May Be Provided "Remarkes" Field in the Part 1A
Issues in Final Closure (cont’d) • Issue 689 - Update the COCAG Appendix C to Allow Dedicated Code Returns With Assigned Blocks When the Code is Not In-Service • Issue 693 - SP Review of Inventory to Maintain Six Month Supply • Issue 694 - Update TBPAG Section 8.4.2 (changing a non-pooled NXX to pooled) to direct the Code Holder to load the NXX into the NPAC
Relevant INC Web Pages • INC Homepage (front page to all INC links): http://www.atis.org/inc/index.asp • INC Calendar (future meeting logistics/agendas): http://www.atis.org/inc/calendar.asp • INC Issues (historical and active): http://www.atis.org/inc/incissue.asp • INC Meeting Records: http://www.atis.org/inc/mtgs_current.asp • INC Published Documents: http://www.atis.org/inc/incguides.asp