The Regulatory Environment Toll Free Services

Transcription

1 The Regulatory Environment Toll Free Services David Greenhaus Director of Regulatory Affairs Jay Carpenter President

2 Regulatory / Industry Standards FCC Toll Free Rulings North American Numbering Council (NANC) Future of Numbering Working Group (FoN) ATIS / SMS Number Administration Committee (SNAC) Interface with SMT and DSMI Guidelines For Toll Free Number Administration

3 SMS/800 Database Service Management Team (SMT) Verizon, AT&T, Qwest (BOCs) SMS/800 SMS/800 Help Desk DSMI Telcordia Services provided to: Resp Orgs SCP Owner/Operators

4 Key FCC Orders Docket /11/97 Second Report and Order Second Report and Order: Adopted rules governing the reservation, activation, disconnection, warehousing, and hoarding of toll free numbers. Also sought comment on who should administer the SMS/800 database system. 3/31/98 Fourth Report and Order Required that vanity numbers in the 877 toll free code and future toll free codes shall be assigned on a first come, first served basis as each code is deployed. 12/7/00 Wade Letter to DSMI Modifying SMS/800 functions to preclude transfers of Toll Free numbers directly between subscribers. 12/21/07 Order on Reconsideration Toll Free Service Access Codes. Denied a number of outstanding petitions for the reconsideration of Commission orders concerning the Toll Free administration system and the Commission's Toll Free rules

5 North American Numbering Council (NANC) FCC Advisory Committee created to advise the Commission on numbering issues and to make recommendations that foster efficient and impartial number administration. Future of Numbering Working Group (FoN) explore changes to the numbering environment, including new and future technologies, the impact of market place and/or regulatory changes and innovations on telephone numbering.

6 ATIS SMS/800 Number Administration Committee (SNAC) The SMS/800 Number Administration Committee (SNAC) identifies, develops and implements the resolution of issues impacting existing toll free products and services and evolving technologies affecting future developments in the toll free industry. The SNAC is comprised of volunteer members representing providers and users of the 800 Service Management System (SMS/800). The Committee provides recommendations to the owner/manager of the SMS/800 regarding design and management issues that have a direct effect on the system users. The SNAC maintains the Industry Guidelines for Toll Free Number Administration and is a leader in developing standards and procedures for the interaction between Resp Orgs, Customers, and Service Providers. The SNAC interfaces with other committees as needed to address the impact of their work to toll free products and services. Courtesy of the Alliance for Telecommunications Industry Solutions:

7 Industry Guidelines for Toll Free Number Administration While compliance is voluntary, deliberate abuse of these guidelines may be referred by any participant to the Federal Communications Commission of the United States government, or to the Director General, Spectrum Engineering, Industry Canada, as appropriate. *Portions of the Guidelines are CODIFIED in accordance with FCC Rulings Courtesy of the Alliance for Telecommunications Industry Solutions:

8 2.2 Basic Principles Industry Guidelines con t Toll Free Service numbers are fundamentally a resource of the North American Numbering Plan Administrator. Toll Free Service numbers are assigned by Resp Orgs to their Customers from a common pool of available numbers Toll Free numbers are not to be treated as commodities which can be bought or sold, and no individual or entity is granted a proprietary interest in any Toll Free number assigned. Resp Orgs and Toll Free Service Providers are prohibited from selling, brokering, bartering, or releasing for a fee (or other consideration) any Toll Free number. Reserving, Assigning, or activating (Working) Toll Free numbers by Resp Orgs, Toll Free Service Providers, or Customers for the primary purpose of selling, brokering, bartering, or releasing for a fee (or other consideration) that Toll Free number is prohibited. C The reservation of a number serves as certification that a RESP ORG has an identified Subscriber agreeing to be billed for service associated with each Toll Free number. Resp Orgs found to be in violation of this warehousing* rule risk penalties including forfeiture, fine, imprisonment and/or Resp Org decertification. If a Subscriber hoards numbers that Subscriber s Toll Free service provider must terminate service because hoarding* is contrary to the public interest, leads to depletion of Toll Free numbers and number brokering, and is contrary to the rules adopted in the Second Report and Order. (Ref: FCC , Paragraphs 25 42). Courtesy of the Alliance for Telecommunications Industry Solutions:

9 Industry Guidelines con t However, the Toll Free Service End User Subscriber has the ultimate right to control its Toll Free Service, and its reserved, active, or assigned Toll Free Service numbers. NOTE: For Shared Use toll Free or Bundled Services, the Shared Use Toll Free or Bundled Service Provider is treated as the Toll Free Service End User Subscriber, and is responsible to notify its purchasers of these services of this fact. NOTE: The statements above should not be interpreted as inhibiting the sale, resale, brokering, or bartering of Toll Free Service. * Warehousing occurs when Resp Orgs directly or indirectly reserve Toll Free numbers from the SMS database without having an identified Toll Free Subscriber. 2.3 Specific Toll Free Number Requests Specific Toll Free number requests are honored based upon availability, on a first come, firstserved basis, at the time the reservation request is initiated by a Resp Org into SMS/ C A specific Toll Free number may be reserved for a maximum of 45 calendar days on behalf of a Resp Org's Customer. However, if the Toll Free number status in SMS/800 does not change to Assigned or Working prior to the end of the Toll Free number reservation period, SMS/800 will automatically change the status on the number back to Spare and return it to the general pool for assignment. This process supports the need to recover ten digit Toll Free numbers for use by all Resp Orgs and their Customers The Resp Org may mark the toll free number with the special Resp Org ID, XXX99 (i.e. XXX representing the Resp Org entity) to notify all Resp Orgs that conditions exist that may require extra verification before the toll free number can be ported either 1) between Submitting and Executing Resp Orgs or 2) through SMS/800 Help Desk Resp Org change request procedures. Courtesy of the Alliance for Telecommunications Industry Solutions:

10 Industry Guidelines con t Toll Free Service End User Subscribers are able to retain use of their Reserved, Assigned, or Active Toll Free Service numbers despite changes in their Resp Org and/or Toll Free Service Provider(s). When Toll Free Service End User Subscribers initiate a change in Resp Org and/or Toll Free Service Provider(s), the SMS/800 status of the numbers will remain the same. (See Section 3 of these guidelines.) Reservation, Assignment or Activation (Working) of Toll Free numbers may only be made by a Resp Org based upon negotiations with a specific prospective Customer. When the Resp Org learns of the Customer s decision not to utilize the Reserved or Assigned Toll Free number, the Resp Org must release the Toll Free number back to spare status and the pool of numbers available for assignment within 48 hours of Customer notification. C Note: The FCC orders that each reservation serve as certification that there is an associated and identifiable Customer agreeing to be billed for the associated service for each number When the Toll Free Service is disconnected or canceled, the Toll Free number must be recovered, returned to the common assignment pool (SMS/800), and made available for reassignment to other potential Toll Free Service End User Subscribers. Toll Free Service disconnects and cancellations require Toll Free number recovery to provide fair and equitable treatment for Toll Free number assignment among all Resp Orgs, Toll Free Service Providers, and Toll Free Service End User Subscribers. C Resp Orgs may not retrieve disconnected numbers and return them to working status at the expiration of the disconnect interval. C As a result of FCC Order , in order to return transitional numbers to the Toll Free resource pool, aging is reduced to four (4) months as the business norm. Courtesy of the Alliance for Telecommunications Industry Solutions:

11 Current SNAC Issues Issue 2617 Anti Slamming Protective Measures Introduction of a new 00 Resp Org Code to signify numbers for which an advanced phone call will be made by the Help Desk prior to making a Help Desk Resp Org change. Issue 3119 Industry Standardization of Toll Free Aggregated Traffic & Issue 3120 TF Industry VOIP Originating ANI Requirement These issues address a concern that toll free traffic, routed according to originating ANI cannot be properly routed as numbers are increasingly being assigned outside the traditional geographic area and as mobility of people and their telecommunications devices continue to increases. This is becoming more of an issue with local number portability, cell phones and VOIP. Issue 3328 Preparation for the Next Code Release Tracking toll free number exhaust and determining how much time and preparation is needed to implement a new code for the industry.

12 Current SNAC Issues con t Issue 3354 Release Version 14 of the Guidelines A task force has been formed to review the Industry Guidelines and bring them up to date Toll Free Guidelines Update Availability and Distribution Other Issues Being Discussed: Asking FCC to codify sections of the Guidelines related to Resp Org change procedures Considering additional sections of the Guidelines for FCC codification Asking the wireless industry to implement standards for allowing cellular phones to dial toll free numbers greater than 10 digits. Vanity numbers dialed via mobile phone qwerty keyboards.

13 Current FoN Issues FTN #004 Geographic Issues Impacting Numbering Policy Decisions FTN #5 Commons vs. Market Place Model for Toll Free Numbers

14 FTN 005 Description Accepted December 12, 2008 Determine whether a shift from the current Commons Model (no individual property rights) to a market based Property Rights Model (individual property rights with a free and open marketplace) would result in a more appropriate and desirable method for the assignment, management and allocation of NANP Toll Free Numbers. Investigate the pros and cons to determine how each method could impact Numbering Resource Optimization (NRO) and could better serve a vibrant and efficient marketplace. The objective of this analysis is to provide a recommendation to the NANC as to the desirability and feasibility of adopting a Property Rights Model for portable NANP Toll Free Telephone Numbering Resources possibly operating in conjunction with the current Commons Model of allocation.

15 FTN 005 Action Plan List real and perceived rights of end users employing Toll Free portable telephone numbers for legacy and new services. Review existing examples of other property rights models (i.e. Australia) Develop approach for identifying Pros and Cons of each model, for comparative analysis. Identify Pros and Cons for each, Commons and Property Rights Model Prepare paper and distribute to Industry Members for input Identify tentative conclusions regarding numbering policy, NRO and possibly where each model fits best for known services. Present to NANC for further direction

16 ENUM What is it? Why should we be interested in ENUM? When will it be implemented? Basics of ENUM db96 4bc1 901c 4d504a1be9c7/File/Gary%20Richenaker.pdf

17 Courtesy of Gary Richenaker, Telcordia Technologies

18 Courtesy of Gary Richenaker, Telcordia Technologies

19 Courtesy of Gary Richenaker, Telcordia Technologies

20 Courtesy of Gary Richenaker, Telcordia Technologies

21 Courtesy of Gary Richenaker, Telcordia Technologies

22 Courtesy of Gary Richenaker, Telcordia Technologies

23 ENUM Industry & Forums CC1 ENUM LLC ENUM Forum ITU Private ENUM Providers

24 Legislative Action Possible Lobbying Congressional Involvement Alliance with other Industry Groups Regulatory Action

25 Getting Involved AFTA Membership SNAC Membership Participation in FoN NANC Meetings Contact FCC Open to: Individual Companies Industry Associations