Industry Numbering Committee (INC) Report to the NANC

1. Industry Numbering Committee (INC) Report to the NANC September 15, 2011 Natalie McNamer, INC Chair Dana Crandall, INC Vice Chair

2. INC Meetings • INC Meetings: INC held one interim Document Management/Maintenance (DMM) Subcommittee meeting and two INC face-to-face meetings since the last NANC report. • Next INC Meeting: October 18-21, 2011 (St. Louis, MO) • Details on all future meetings can be found at: www.atis.org/inc/calendar.asp

3. Resource Assignment and Management (RAM) Subcommittee Issue 698: Auto-Populate Total Numbering Resources on TBPAG MTE Form • Issue 698 was accepted to address some state public service commission staff concerns regarding the validation of a Service Provider’s total resources on the thousands-block months-to-exhaust form. • Today, the validation must be performed manually; there is no automated validation in the Pooling Administration System (PAS). • INC reached consensus that the PA shall create a new “Total Numbering Resources” report to be made available for viewing or downloading in PAS that will demonstrate and calculate the total numbering resources by state, NPA, and rate center for each OCN in the user’s PAS profile. • The Total Numbering Resources report will be available for viewing or downloading in PAS by the Service Provider/SP consultant, authorized state public service commission staff for that particular state, and the FCC staff. • The NANPA shall add a “Pooled Code Indicator” to its existing CO Codes Utilized Report posted on the NANPA website to further assist Service Providers and states in validating the total resources calculation. When a non-pooled code becomes pooled, the PA shall notify NANPA. • This issue resolution produced NANPA Change Order #22 and PA Change Order #22, both of which were submitted to the FCC on August 5, 2011. • Implementation of the issue resolution is contingent on the FCC’s approval of the Change Orders. 3

4. RAM Subcommittee Issue 714: Consider Revisions to Administrator Application Processing Timeframes & State Approval of Applications • At the March 2011 NANC meeting, the NANC Chair noted a concern raised by some state public service commission staff that the 7-calendar day application processing timeframe is too short for staff to review code and block applications. • The NANC Chair requested that the INC Chair reach out to a specific state public service commission staffer to further understand the concern. • After such consultation, Issue 714 was drafted by INC leadership and accepted for work by the INC. • Issue 714 addresses the following recommendations and requests: • States recommend that INC change the application processing timeframe from 7 calendar days to 7 business days. • States request that they be given authority to approve all individual and multiple block/code requests prior to allocation by NANPA and the PA. • States may request application “materials” under 47 CFR§52.15 (g) (5), but do not always receive such materials; states may request that NANPA or the PA deny the application. 4

5. RAM Subcommittee Issue 714: Consider Revisions to Administrator Application Processing Timeframes & State Approval of Applications • INC declined to change the application processing timeframe or give states authority to approve all individual and multiple block/code requests because: • Extending the application processing timeframe extends the total quantity of days before a code or block becomes effective, and thus is not in the best interest of consumers. Access to numbering resources is key to carriers being competitive, and any increases to the timeframe could delay a carrier’s ability to serve customers. • The FCC contracted with the NANPA and PA to review and approve or deny SPs’ applications for resources, thus it is unnecessary and contrary to the FCC’s establishment of a national and neutral numbering administration to add another layer of approval. • FCC 00-429 ¶ 123 describes the states’ limited role with regard to numbering resources applications: “Finally, we clarify that our grant to state commissions of access to numbering resource application materials is not intended to delay the processing of carriers’ applications for numbering resources. Notwithstanding the state commissions’ role in determining the validity of data submitted pursuant to our mandatory reporting requirements, our intent is not to give state commissions a veto over approval of applications, nor is it to introduce an additional layer of review for applications.” • With regard to states requesting and receiving application materials under 47 CFR § 52.15 (g) (5) from applicants, INC made text changes to the COCAG and TBPAG to establish a one-business-day timeframe for SPs to supply the requested documentation. 5

6. Numbering and Addressing Resource Planning (NARP) Subcommittee Issue 709: Updates to the p-ANI Guidelines and Forms In December 2010, the FCC provided clarification to the PA regarding certain issues and assumptions and directed the PA to submit a Change Order for the implementation of the permanent Routing Number Administrator (RNA) Administration function for p-ANIs. On June 17, 2011, the FCC approved the Pooling Administrator's Change Order Proposal #19 regarding implementation of the permanent RNA function. INC made changes to the p-ANI Part 1 Form, p-ANI Part 3 Form, and p-ANI Guidelines based on the FCC clarifications and further discussions with the ATIS Emergency Services Interconnection Forum’s Emergency Call & Data Routing Subcommittee (ESIF-ECDR). INC selected submission dates of April 1 and October 1 for semi-annual forecast data and annual utilization data to avoid conflict with the NRUF submission dates. On March 19, 2012, Neustar Pooling Administration will assume the responsibility as the permanent RNA. 6

7. NARP Subcommittee Issue 690: Update Toll Free Resource Exhaust Relief Planning Guidelines • INC reviewed the Toll Free Resource Exhaust Relief Planning Guidelines for updates. • After communication with ATIS Next Generation Interconnection Interoperability Forum (NGIIF) , ATIS SMS/800 Number Administration Committee (SNAC), and Database Service Management Incorporated (DSMI), INC determined the processes outlined in the Toll Free Resource Exhaust Relief Planning Guidelines are outdated. • INC determined that it is SNAC’s responsibility to forecast the projected exhaust of existing toll free resources, and thus the Toll Free Resource Exhaust Relief Planning Guidelines were no longer needed. • INC realizes that adequate industry notification is necessary to ensure a smooth implementation of a new toll free NPA. INC added text to the NPA Code Relief Planning and Notification Guidelines to outline NANPA’s responsibilities regarding industry notification.

8. NARP Subcommittee Issue 703: Reservation of Future PCS NPA Codes beyond the 5YY Series • Current non-geographic NRUF forecast data indicate that over the next four years the NPA resources set aside for 5YY will exhaust. Presently, the 522, 577, and 588 NPAs are reserved. • INC reviewed the available NPA codes to determine what additional NPA codes could be reserved. • Since 5YY resources have evolved to include application and device communications, INC determined that the use of Easily Recognizable NPA Codes (NYY) is no longer required. • INC directed NANPA to reserve all available NPA codes in the 52X, 53X, 54X, 55X, 56X, 57X and 58X NPAs for future 5YY use (a total of 22 NPAs). • INC has reached consensus to rename the PCS 5YY NXX Code Assignment Guidelines to the Non-Geographic 5XX-NXX Code Assignment Guidelines.

9. NARP Subcommittee Issue 701: Add information to guidelines regarding NPA implementation steps for new NANP Entrant There are no steps in the NPA Allocation Guidelines that a new NANP entrant and its service providers may follow to implement the new NPA once it has been assigned. There are tasks to be completed to ensure a smooth implementation of the new NPA and to ensure that calls are properly rated and routed as NANP calls. The INC added a new section to the NPA Allocation Guidelines to provide such guidance to a new NANP entrant and its service providers. INC also documented the necessary information required for the NANPA Planning Letter, and the need for semi-annual forecast data so that NANPA may project the exhaust of the NANP. 9

10. Issues in Initial Pending • Issue 534: The Development of pANI Guidelines • Issue 698: Auto-Populate Total Numbering Resources on TBPAG MTE Form • Issue 710: NANC Action Item “multi-OCN Issue”

11. Issues in Initial Closure Issue 695: Update the Vertical Service Code (VSC) Guidelines Issue 701: Add information to guidelines regarding NPA implementation steps for new NANP Entrant Issue 709: Updates to the p-ANI Guidelines and Forms Issue 713: Update CFR references and similar citations in the COCAG and other INC Guidelines Issue 714: Consider revisions to Administrator application processing timeframes and state approval of applications Issue 718: Add language to the COCAG regarding the block available date on available blocks associated with a code transfer 11

12. Issues in Final Closure • Issue 690: Update Toll Free Resource Exhaust Relief Planning Guidelines • Issue 699: Review and update the acceptable forms of proof of facilities readiness • Issue 703: Reservation of Future PCS NPA Codes beyond the 5YY Series • Issue 705: Update CFR references and similar citations in the TBPAG and associated forms • Issue 707: Need to remove all abandoned code records from NPAC prior to transfer • Issue 708: Inclusion of a definition of Trunk Access in the Carrier Identification Code (CIC) Assignment Guidelines • Issue 712: Update TBPAG Section 4.4 l) and m)

13. 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