Before the

**Federal Communications Commission**

**Washington, D.C. 20554**

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| In the Matter of                 | * | NSD-L-99-24                  |
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| Petition by the United States    | ) | NSD-L-98-80                  |
| Department of Transportation for | * |                              |
| Assignment of an Abbreviated     | * | CC Docket No. 92-105         |
| Dialing Code (N11) to Access     |   |                              |
| Intelligent Transportation       | * |                              |
| System (ITS) Services Nationwide | * |                              |
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| Request by the Alliance of       | * |                              |
| Information and Referral         | * |                              |
| Systems, United Way of America,  |   |                              |
| United Way 211 (Atlanta,         | * |                              |
| Georgia), United Way of          | * |                              |
| Connecticut, Florida Alliance of | ) |                              |
| Information and Referral         | * |                              |
| Services, Inc., and Texas I&R    | * |                              |
| Network for Assignment of 211    |   |                              |
| Dialing Code                     | * |                              |
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| The Use of N11 Codes and Other   | ) |                              |
| Abbreviated Dialing Arrangements | * |                              |
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+----------------------------------+---+------------------------------+

**THIRD REPORT AND ORDER AND ORDER ON RECONSIDERATION**

**Adopted: July 21, 2000 Released: July 31, 2000**

By the Commission:

**TABLE OF CONTENTS**

[Paragraph Number]{.underline}

I.  Introduction 1

II. BACKGROUND 3

III. DIscussion 9

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A.  Petition for Assignment of an N11 Code for Access to Intelligent
    Transportation System Services

1\. Background 9

2\. Discussion 10

B.  Petition for Assignment of an N11 Code for Access to Information and
    Referral Services

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1.  Background 17

2.  Discussion 18

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C.  Petitions for Reconsideration or Clarification

1\. International Association of Fire Chiefs and International Municipal
Signal Association Petition for Reconsideration 22

2\. BellSouth Petition for Clarification and Reconsideration 29

D.  Further Notice of Proposed Rulemaking Issues

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1.  Sale of N11 Codes 37

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a.  Background 37

b.  Discussion 39

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2.  Administration of N11 Codes 40

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a.  Background 40

b\. Discussion 43

3.  Need for Comprehensive Rulemaking 44

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IV. Procedural Matters 45

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A.  Regulatory Flexibility Act 45

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V.  Ordering Clauses 48

Comments and Replies Filed in U.S. Department of Transportation Petition
Appendix A

Comments and Replies Filed in Information and Referral Providers
Petition Appendix B

Comments and Replies Filed in *N11 First Report and Order and FNPRM*
Appendix C

# introduction

1.  N11 codes are abbreviated dialing arrangements that allow telephone
    users to connect with a particular node in the network by dialing
    only three digits. There are only eight possible N11 codes,[^1]
    making N11 codes among the scarcest of numbering resources under our
    jurisdiction. Of the eight N11 codes available, the Commission has
    already assigned two for nationwide use,[^2] and has been directed
    by Congress to assign another.[^3] In addition, three other N11
    codes are widely used by carriers across the country, but have not
    been assigned by the Commission for such nationwide use.[^4] Thus,
    at this time there remain only two N11 codes that can be assigned
    and deployed immediately.[^5]

2.  We have before us two petitions for assignment of N11 codes, as well
    as a number of other outstanding issues in the N11 proceeding.[^6]
    In this Order, we grant petitions filed by the U.S. Department of
    Transportation (DOT), [^7] and by Information and Referral
    providers[^8] seeking nationwide assignment of abbreviated dialing
    codes for access to traveler information services, and for access to
    community information and referral services, respectively. We assign
    the abbreviated dialing code 511 to be used for access to traveler
    information services, and assign the abbreviated dialing code 211 to
    be used for access to community information and referral services.
    We believe these two proposals meet the "public interest" standards
    for assignment of N11 codes established in the *N11 First Report and
    Order,* and this need is demonstrated by the wide support for the
    two petitions. Both petitioners propose to provide access to their
    services without an additional charge to callers, and each has
    demonstrated that its service provides a substantial public benefit.
    We also resolve petitions for reconsideration and/or clarification
    of issues raised in the N11 proceeding. Specifically, we deny
    petitions for reconsideration of the *N11 First Report and Order*
    filed by the International Association of Fire Chiefs and
    International Municipal Signal Association (IAFC Petitioners) and
    BellSouth. We also resolve issues raised in the *N11 FNPRM.* We
    conclude that the sale or transfer of N11 codes through private
    transactions should not be allowed at this time, and that the
    Commission should continue to make assignments of N11 codes, rather
    than delegate this authority to the North American Numbering Plan
    Administrator (NANPA) or any other entity.

# BackGround

3.  Abbreviated dialing codes enable the caller to connect to a location
    in the network that otherwise would be accessible only via a seven
    or ten-digit telephone number. The network must be pre-programmed to
    translate the three-digit code into the appropriate seven or
    ten-digit telephone number and route the call accordingly. Among
    abbreviated dialing arrangements, "N11" codes are three-digit codes
    of which the first digit can be any digit other than 1 or 0, and the
    last two digits are both 1.

4.  Prior to the 1996 Act, incumbent local exchange carriers (LECs),
    state commissions, Bellcore[^9] and the Commission performed the
    functions relating to numbering administration, including
    administration of abbreviated dialing codes. Section 251(e) of the
    Communications Act of 1934, as amended by the Telecommunications Act
    of 1996 (1996 Act), gives the Commission exclusive jurisdiction over
    numbering administration, and over those portions of the North
    American Numbering Plan (NANP) that pertain to the United
    States.[^10] This section also provides that the Commission may
    delegate all or part of its numbering administration authority to
    state commissions or other entities.[^11] In 1992, the Commission
    adopted a Notice of Proposed Rulemaking *(N11 NPRM)* proposing that
    incumbent local exchange carriers be required to provide abbreviated
    dialing arrangements.[^12] Subsequent to the *N11 NPRM,* various
    parties asked the Commission to designate N11 codes to facilitate
    network access to Telecommunications Relay Service (TRS) for
    individuals with hearing or speech disabilities, to federal
    government services, to state government services, and to
    non-emergency police services.[^13]

5.  In 1997, the Commission released the *N11 First Report and Order and
    FNPRM* in which it authorized the incumbent LECs, states, and
    Bellcore to continue to perform N11 code administrative functions
    that they performed prior to the time of enactment of the 1996
    Act.[^14] In the *N11 First Report and Order*, the Commission
    assigned 311 on a nationwide basis for non-emergency police
    services, but allowed existing non-compliant uses of 311 to continue
    until the local government in that area was prepared to activate a
    non-emergency police 311 service. In addition, at the discretion of
    local jurisdictions, the Commission allowed 311 to be used to access
    other government services, but declined to assign a separate N11 for
    this purpose. The Commission also granted the request for an N11
    code to reach Telecommunications Relay Services (TRS), assigning 711
    nationwide for this use. Finally, the Commission declined to: (1)
    mandate that N11 numbers be made available for access to information
    services; (2) mandate that an N11 code be designated for access to
    federal government agencies; or (3) disturb the current uses of 911,
    411, 611 and 811 for access to emergency services, directory
    assistance, and LEC repair and business offices, respectively.[^15]

6.  The Commission in the *N11 First Report and Order and FNRPM* also
    requested comment on a number of issues.[^16] Specifically, the
    issues to be addressed related to deployment of TRS,[^17] the sale
    or transfer of N11 codes,[^18] and administration of N11 codes.[^19]
    Subsequently, several parties filed requests for reconsideration
    and/or clarification of certain matters discussed in the *N11 First
    Report and Order*.[^20] Specifically, the International Association
    of Fire Chiefs and International Municipal Signal Association (IAFC
    Petitioners) opposed any expanded use of N11 codes for non-emergency
    and commercial uses. BellSouth sought reconsideration and/or
    clarification regarding the status of non-conforming uses of N11
    service codes, including 311 and 711, the "six-month" implementation
    requirement for 311, and requirements placed on CMRS providers with
    respect to handling 311 calls. It also sought clarification
    regarding incumbent LECs' obligations to provide 611 and 811 for
    access to repair and business offices.

7.  The U.S. DOT and the Information and Referral Petitioners seek
    assignment of N11 codes to provide gateway access to travel
    information services and community service organizations,
    respectively. The U.S. DOT does not request a specific N11 dialing
    code, whereas the Information and Referral Petitioners seek
    assignment of 211, specifically, for their proposal. Both
    petitioners contend that the provision of services using toll-free
    numbers or local numbers is not only inefficient, but limits the
    widespread use of travel information or community services
    information, and also limits the accessibility to these services.
    Both proposals enjoy widespread support from a variety of
    organizations, state and local governments, and other interested
    parties.

8.  This Order resolves issues raised in the petitions for
    reconsideration that relate to the manner in which N11 codes are
    assigned, and grants the two petitions for assignment of N11 codes
    filed by the U.S. DOT and the Information and Referral Petitioners.
    Issues raised in the *N11 First Report and Order* regarding the
    implementation of 711 are being addressed in a separate Order.[^21]
    Similarly, the Commission will address matters dealing with
    designation of 911 as the national emergency number throughout the
    United States in a separate order.[^22]

# Discussion

## Petition for Assignment of N11 Code for Access to Intelligent Transportation Systems Services

### Background

9.  On March 8, 1999, the United States Department of Transportation
    (U.S. DOT) filed a petition for assignment of a nationwide N11 code
    for use by state and local governments to deliver travel-related
    information to the public.[^23] The U.S. DOT stated that travel
    information, including the status of roadway construction, accident
    locations, and alternate routes, is currently provided by state and
    local governments across the country, primarily by telephone, often
    with each municipality and transportation agency having its own
    telephone number. The U.S. DOT explained that intelligent
    transportation systems, including advanced traveler information
    systems, are state-of-the-art information networks that provide
    real-time, route-specific information on all types of surface
    travel, which allows commuters and other travelers to make more
    efficient use of the nation's transportation infrastructure. Despite
    existence of substantial funding for intelligent transportation
    systems, these resources are under-utilized because travelers have
    difficulty remembering the numerous telephone numbers to access the
    information, particularly as they travel across jurisdictions. The
    U.S. DOT Petition contends that the assignment of a single,
    nationwide, three-digit dialing code would enable more travelers to
    remember the number to access and use the travel-related
    information. The U.S. DOT further contends that widespread use of
    this information would reduce vehicular congestion and pollution,
    lower fuel consumption, provide superior traffic management, and
    enhance roadway safety.

### Discussion

10. We conclude that the U.S. DOT has demonstrated that assignment of an
    N11 dialing code for nationwide access to travel information
    services is in the public interest, and we therefore assign 511 for
    this purpose. In the past, the Commission has assigned N11 codes
    upon a finding that the assignment serves the public interest. For
    example, in the *N11 First Report and Order,* the Commission found
    that assignment of 311 would reduce congestion on the national
    dialing code for emergency services, 911, thereby ensuring that 911
    circuits were not overburdened with non-emergency calls. The U.S.
    DOT Petition meets the standard we have previously employed for
    assigning N11 codes by demonstrating that there are substantial
    public benefits in assigning 511 for nationwide access to travel
    information services. We believe that assignment of 511 will assist
    state and local governments in their efforts to improve local
    transportation conditions.

11. Driver frustrations with travel conditions are distilled in a
    commonly understood phrase -- "road rage" -- that reflects a
    national tragedy. The figures cited by the U.S. DOT in support of
    its proposal are staggering. Each year, nationwide, there are six
    million accidents, 42,000 deaths, and 5.2 million injuries, at an
    approximate cost of \$200 billion annually.[^24] To deal with these
    costs, state and local governments are spending vast sums of money
    to equip the nation's roadways with intelligent transportation
    systems.[^25] They seek to provide real-time information on the
    exact status of roadways, to allow better, safer traffic and travel
    management, and to provide the traveling public with more informed
    choices on how and when to travel.[^26]

12. According to the U.S. DOT, increased state and local government
    investment in technology stems from the fact that roadways in major
    metropolitan areas are becoming increasingly congested, and building
    more roads to solve this dilemma may no longer be feasible for
    economic and other reasons. We believe that granting the U.S. DOT
    Petition will ensure more efficient use of existing roadways and
    reduce the need for expensive infrastructure investments. We have
    already seen the positive effects of providing real-time access to
    travel information services in certain jurisdictions. For example,
    after four years of use of advanced traveler information systems in
    Massachusetts, the Massachusetts Department of Transportation
    (MassDOT) found that, despite efforts to select a mnemonic
    seven-digit number and millions of dollars spent to promote it, the
    lack of awareness and inability to recall the seven-digit number
    were the biggest barriers to using the advanced traveler information
    system.[^27] Despite this limitation, a survey revealed that 85
    percent of users rated the system "8" or better on a scale of 1 to
    10; 63 percent of users avoided traffic problems, and 59 percent of
    users saved time. Almost half the callers using the system indicated
    in a survey that the information they received influenced their
    travel decisions, with 14 percent changing their time of departure,
    and 12 percent taking another route.[^28]

13. We reject GTE's contention that we must deny the U.S. DOT Petition
    because it fails to show there are no "other ways currently
    available to achieve convenient dialing that do not drain scarce N11
    resources."[^29] GTE argues that the U.S. DOT showing that callers
    have to dial different phone numbers in every geographic area is
    insufficient reason to grant the Petition.[^30] According to the
    U.S. DOT, virtually each state, metropolitan area, and transit
    agency has a separate telephone number, often having different
    telephone numbers for traffic, transit and other related information
    in the same metropolitan area.[^31] We agree with the U.S. DOT and
    other commenters that assignment of an abbreviated dialing code
    would stimulate the deployment and use of travel-related information
    by making access to such information more readily accessible.[^32]
    We also believe that assignment of an abbreviated dialing code would
    maximize the benefits of such information,[^33] which include
    decreasing traffic congestion, reducing air pollution and
    inefficient use of fossil fuels,[^34] improving the nation's
    productivity on and off the roadways, and improving traveler
    safety.[^35]

14. We are persuaded by evidence of N11 trials in various localities
    that intelligent transportation systems are substantially more
    likely to succeed when they are accessible via an N11 code than if
    they are not and therefore that the public interest would be served
    by assigning an N11 code for this purpose. The most persuasive
    evidence comes from use of an N11 dialing code in the Cincinnati and
    Northern Kentucky area.[^36] During a three-month period in 1997,
    when Kentucky residents dialed 211 to reach the traveler information
    service and Ohio residents dialed 333-3333 to reach the same
    traveler information, the Kentucky Transportation Cabinet reports
    that 72 percent more calls were made to the abbreviated dialing code
    than to 333-3333.[^37] We believe that these positive results can
    and will be duplicated nationwide,[^38] based on the widespread
    support for the U.S. DOT proposal, from metropolitan area regional
    transit groups[^39] to states with predominantly rural driving
    conditions.[^40] Accordingly, we find that the assignment of an N11
    code as requested by the U.S. DOT is in the public interest.

15. As with our allocations of 311 and 711, we conclude that a
    governmental entity may request 511 from both wireline and wireless
    providers to use for intelligent transportation systems or other
    transportation information. We encourage wireless carriers to
    negotiate roaming agreements with one another for the benefit of
    their customers, and we believe that competition among carriers will
    encourage them to do so, because it will be advantageous for
    customers to be able to reach the service as often as possible, even
    while roaming on another carrier's network. We do not specify
    parameters for cost recovery and other technical issues, contrary to
    suggestions of some commenters.[^41] Instead, we leave with federal,
    state, and local government transportation agencies the discretion
    to determine the deployment schedule and the type of transportation
    information that will be provided using 511, similar to how we
    handled this issue with respect to 311 in the *N11 First Report and
    Order.*[^42] We conclude that setting parameters for these issues
    may in fact hinder governmental entities in deploying 511. We
    encourage federal, state, and local government transportation
    agencies to work cooperatively to ensure that the transportation
    information provided using 511 is appropriate to the national scope
    of our designation and the scarcity of the N11 public resource. In
    order to put the 511 code to the best use, callers should have
    access to information that transcends municipal boundaries and that
    is easily retrievable in a single call. State public utilities
    commissions may continue to exercise jurisdiction over N11 codes to
    the extent necessary to ensure that carriers comply with
    transportation agencies' requests to deploy 511 expeditiously. We
    also note that governmental entities, working in conjunction with
    regional government transportation agencies, will need time to
    determine uniform standards for how travel information services
    should be provided to the public.[^43] We further note the efforts
    some communities have made in transitioning to an N11 code for
    travel-related information, and we are confident that communities
    across the country will be able to transition to the 511 dialing
    code.[^44] Finally, we encourage the U.S. DOT to facilitate
    ubiquitious deployment of 511 for access to travel information
    services across the country.

16. Because N11 dialing codes are such a scarce resource, however, we
    will examine and reassess our assignment of the 511 code for access
    to travel information systems five years after the effective date of
    this Order. If, at that time, 511 is not being used on a widespread
    basis for provision of travel information services, we may consider
    also designating the 511 code for other uses, or removing the
    exclusive assignment for travel information services.

## Petition for Assignment of an N11 Code for Access to Information and Referral Services 

### Background

17. On May 28, 1998, the Alliance of Information and Referral Systems,
    the United Way of America, United Way 211 (Atlanta, Georgia), United
    Way of Connecticut, Florida Alliance of Information and Referral
    Services, Inc. and the Texas I&R (Information and Referral) Network
    (collectively, Information and Referral Petitioners), filed a
    petition for nationwide assignment of an abbreviated dialing code
    for access to community information and referral services
    (Information and Referral Petition).[^45] The Information and
    Referral Petitioners contend that there is a demonstrated need for
    an easy to remember, easy to use abbreviated dialing code that will
    enable persons in need to be directed to services providing free
    information and referrals to community service organizations.
    Petitioners argue further that assigning an N11 code to such
    services would provide an important adjunct to the codes that the
    Commission has already assigned to meet other public needs.[^46] The
    Information and Referral Petitioners cite to a range of human needs
    not addressed by either the 911 code or police non-emergency 311
    code such as housing assistance, maintaining utilities, food,
    finding counseling, hospice services and services for the aging,
    substance abuse programs, or dealing with physical or sexual
    abuse.[^47] The Information and Referral Petitioners state that
    there is strong interest in several states for developing an N11
    code for this purpose,[^48] and that the tools exist to do so. The
    Information and Referral Petitioners contend that assigning an N11
    code for such purposes is in the national interest, and commenters
    overwhelmingly support the proposal.[^49]

### Discussion

18. We find that the Information and Referral Petitioners have
    demonstrated sufficient public benefits to justify use of a scarce
    public resource,[^50] and we therefore assign 211 to be used for
    access to community information and referral services. Individuals
    facing serious threats to life, health, and mental well being have
    urgent and critical human needs that are not addressed by dialing
    911 for emergency assistance or 311 for non-emergency police
    assistance. For example, the Information and Referral Petitioners
    present a call summary prepared by United Way 211 (based in Atlanta)
    for the year 1997, which indicates that seven percent of the calls
    to United Way 211 involved immediate shelter needs, 20 percent
    involved rental/mortgage assistance needs (for example, threatened
    eviction), 16 percent involved utility issues, critical in inclement
    weather, and nine percent involved the need for food.[^51] The
    remaining calls presented issues relating to counseling, medical
    aid, prescription assistance, physical and sexual abuse, and
    potential suicide. Other less urgent situations, also not addressed
    by 911 service or the current 311 service, might involve persons
    needing child care solutions, aging and hospice services, adolescent
    activities, educational programs, support groups, legal assistance,
    child and spousal abuse counseling, substance abuse programs, and
    other needs vital to the welfare of individuals, families, and
    communities.[^52]

19. We believe that the Information and Referral Petitioners have shown
    a public need exists for an easy to use, easy to remember N11 code
    to efficiently bring community information and referral services to
    those who need them, providing a national safety network for persons
    to get access readily to assistance. Therefore, we find that the
    public interest standard has been met here. We are persuaded by the
    Information and Referral Petitioners' assertion that, with a large
    number of toll-free telephone numbers, confusion is inevitable and
    the increased margin for error in dialing eleven digits creates
    obstacles to use of community information and referral services,
    particularly in urgent situations.[^53] Moreover, as the Information
    and Referral Petitioners also point out, this confusion is not
    resolved when directory assistance for toll-free numbers is used,
    because directory assistance for toll free numbers lists entries by
    name, but not service or need category. We also are persuaded that
    local numbers are not viable alternatives because they are difficult
    to distinguish from the myriad of other local businesses and
    community services numbers, and may not be of service to travelers
    and the recently relocated, who often need temporary assistance.
    Moreover, people with mental or physical limitations would benefit
    from the use of a three-digit nationwide number, rather than having
    to dial various and different seven or ten digits to get access to
    help. We also note that the number of people served by the
    information and referral organizations that make up the Information
    and Referral Petitioners is quite large. The United Way 211
    (Atlanta, Georgia and the thirteen-county surrounding area) provides
    free (bilingual) service 24 hours a day, seven days a week to a
    population of more than three million people.[^54] In Connecticut,
    Infoline provides access to community resources throughout the
    state.[^55] In Texas, regional data centers -- 24-hour data centers
    linked to the 100 community information centers and each other --
    are being established to provide comprehensive health and human
    service information, allowing 18 million residents to have
    information about vital services across the state.[^56] In Florida,
    information for about 40 percent of the state's counties are
    represented in search and data features that have been included in
    an integrated database, uploaded on the Florida Alliance of
    Information and Referral Service internet site.[^57] The designation
    of a uniform national code would simplify access to information from
    these and other sources and would make such information readily
    available to new members of communities as well as existing local
    citizens.

20. We believe that providing access to community information and
    referral services using 211 has many benefits. Individuals will now
    have an easy to remember nationwide number to call when they need
    non-emergency help. Unlike 311, which is being used in some
    communities to provide access to non-emergency police services,[^58]
    the range of services that will be available using 211 is of a much
    broader scope. We are mindful that the Commission in the *N11 First
    Report and Order* gave local jurisdictions discretion to use 311 for
    access to government services that might, in some instances, overlap
    the services to be provided using 211. We are not convinced, as are
    some commenters, that this will cause confusion among callers as to
    which N11 code should be used to access what type of
    information.[^59] To the contrary, we believe that the extensive
    education campaign that the Information and Referral Petitioners and
    others have undertaken to publicize the use of 211 has and will
    continue to eliminate any potential confusion. The Information and
    Referral Petitioners have invested significant resources in
    publicizing the use of the 211 code in some areas of the country,
    and we have already seen an enormous amount of support for efforts
    to implement access to community information and referral services
    using 211 at the state and local level from citizens, government
    officials, and organizations that provide help to others.[^60] Thus,
    we believe that access to community information and referral
    services using 211 will provide a vital adjunct to existing 311
    services. We also believe that 211 service for access to community
    information and referral services will provide a useful adjunct to
    911 service by further reducing calls to 911 that do not require
    immediate dispatch of police, fire, or medical personnel.[^61]

21. We therefore assign 211 to be used to provide access to community
    information and referral services. Similar to the Commission's
    national assignment in the *N11 First Report and Order* of 311 for
    access to non-emergency police and other government services,[^62]
    we direct that, when a provider of telecommunications services
    receives a request from an entity (*e.g.*, the United Way) to use
    211 for access to community information and referral services, the
    telecommunications provider must: (1) ensure that any entities that
    were using 211 at the local level prior to the effective date of
    this Order relinquish use of the code for non-compliant services,
    and (2) take any steps necessary (such as reprogramming switch
    software) to complete 211 calls from its subscribers to the
    requesting entity in its service area.[^63] The 211 dialing code is
    currently in use in Atlanta, Georgia and parts of Connecticut, and
    we expect communities across the country will be able to make
    similar transition to 211. We expect community service organizations
    to work cooperatively to ensure the greatest public use of this
    scarce resource. Finally, we will reexamine deployment of community
    information and referral services using 211 five years after the
    effective date of this Order to determine whether this resource is
    being utilized in the manner and to the extent anticipated by the
    Information and Referral Petitioners. As with 511, if 211 is not
    being used on a widespread basis for access to community information
    and referral services, we may consider designating the 211 code for
    other uses, or removing the exclusive assignment for community
    information and referral services.

## Petitions for Reconsideration or Clarification 

### International Association of Fire Chiefs and International Municipal Signal Association Petition for Reconsideration

#### Background 

22. On March 28, 1997, the International Association of Fire Chiefs,
    Inc., and the International Municipal Signal Association (IAFC
    Petitioners) filed a Petition for Reconsideration requesting that
    the Commission reconsider the assignment of 311 as a national code
    for non-emergency access to police and local government
    agencies.[^64] The IAFC Petitioners contend that the 311 assignment
    is not supported by the record, nor is it in the public interest
    because it will result in increased caller confusion which will
    undermine and jeopardize the 911 emergency calling systems.[^65] The
    IAFC Petitioners claim that the status of N11 codes for public
    interest use is significant in the minds of callers and, if open for
    non-emergency and commercial uses, that significance will be
    diminished by rendering the codes just another form of speed
    dialing.[^66] The N11 codes, they argue, are a scarce public
    resource that should be reserved for broad-based public interest
    uses that do not threaten the emergency calling system.[^67] The
    IAFC Petitioners indicate that, with the assignment of the 311
    abbreviated dialing code, 911 emergency calling systems can
    anticipate more misrouted calls, more transfers from non-emergency
    answering points, and more multiple transfers. Furthermore, because
    the utilization of 311 by local governments is optional, the IAFC
    Petitioners predict caller confusion, particularly in large areas
    comprised of multiple jurisdictions with blurred boundaries, because
    the callers will not be able to dial 311 for access to non-emergency
    police services in all areas of those jurisdictions.[^68] In
    addition, IAFC Petitioners predict further confusion produced by the
    Commission's apparent decision to exempt commercial mobile radio
    service (CMRS) providers from 311 obligations.[^69]

23. The IAFC Petitioners also contend that the Commission's failure in
    the *N11 First Report and Order* to provide for funding of 311
    service, because of its conclusion that funding is a local issue,
    constitutes an impermissible federal mandate to state and local
    governments. The IAFC Petitioners conclude by asserting that the
    *N11 First Report and Order* also suffers from deficiencies that
    render it arbitrary and capricious because it shunts key issues to
    state and local governments, substitutes speculation for reasoned
    consideration, and is internally inconsistent.[^70]

24. The National Emergency Number Association (NENA) supports the IAFC
    Petition, alleging that the Commission's decision does not pay
    enough attention to alternatives for non-emergency calls and to the
    risks of confusion with 911 calls.[^71] NENA faults the timing of
    the Commission's decision to assign 311, noting that public safety
    studies and industry trials that could add to the record are
    pending, and that the Commission has requested the North American
    Numbering Council to study alternative abbreviated dialing
    arrangements.[^72]

#### Discussion

25. The IAFC Petitioners do not persuade us that we should abandon 311
    as the national code for access to non-emergency police and local
    government agencies. In essence, the IAFC Petitioners argue that the
    use of N11 codes other than 911 will increase public confusion and
    misdirected calls. As we discussed in the *N11 First Report and
    Order*, and herein in connection with the pending petitions for
    assignment of an N11 code, substantial societal benefit can flow
    from the legitimate use of N11 codes. Further, we agree with AT&T
    that the IAFC Petitioners' contentions that the assignment of 311 as
    the N11 code for non-emergency police services has been fully aired
    in their comments to the N11 proceeding, and properly considered and
    rejected by the Commission.[^73] Numerous comments were received in
    the N11 proceeding from fire departments across the country and
    Public Safety Answering Points (PSAPs) indicating that their 911
    systems were overloaded by non-emergency calls and supporting
    national assignment of 311 as a benefit to the delivery of their
    emergency services.[^74] In addition, the Commission found that
    various police departments and associations, as well as the National
    Sheriff's Association and the National Troopers Coalition supported
    the assignment of 311 for non-emergency purposes.[^75] Accordingly,
    we concluded in the *N11 First Report and Order* that assignment of
    a national number through which the public could gain access to
    non-emergency police and other government services was in the public
    interest.[^76]

26. We are convinced that the benefits of a national N11 assignment for
    access to non-emergency police service outweigh the implementation
    concerns, which are most appropriately addressed by local
    governments, raised by some commenters. These include user confusion
    with 911, technical issues related to implementation, costs, funding
    and the potential effects on the 911 system.[^77] As we stated in
    the *N11 First Report and Order*, some of the concerns about
    possible confusion with 911 that led to suggestions of alternatives
    to a national N11 number, such as a three-digit number without "11"
    as the last two digits, an 800 number, or a seven-digit number, are
    the same concerns that led us to find an N11 code superior to those
    alternatives.[^78] We noted that the similarity between an N11
    number and 911 would make the non-emergency number easy to use,
    resulting in greater reduction on non-emergency calls on 911
    circuits.[^79] We expressed confidence in local education programs
    in jurisdictions implementing 311 service to lessen the possibility
    of confusion between 311 and 911 by focusing on the importance of
    continuing to dial 911 in true emergencies.[^80] Without actual
    evidence that such problems exist in these communities that have
    implemented 311, we continue to believe that the benefits of 311
    outweigh these concerns. Moreover, states and localities that
    believe the use of 311 will lead to such problems have the option of
    not implementing such services.

27. Further, the IAFC Petitioners err in their assertion that CMRS
    providers are exempt from our 311 obligations. The Commission
    mandates the provision of 311 service by "providers of
    telecommunications services" and does not exclude wireless carriers
    from this definition.[^81] We note, however, due to the technical
    unfeasibility of the provision of 311 service by one-way paging
    providers, that we did not impose the 311 obligation on these
    service providers.

28. Moreover, we decline to reconsider our conclusion that funding of
    311 is a local issue. In reaching this conclusion in the *N11 First
    Report and Order*, the Commission noted that states and local
    government may deploy 311 through their 911 centers or devise
    alternative procedures for routing and answering 311 calls.[^82] The
    Commission acknowledged that a telecommunications services provider
    may incur certain costs in implementing 311 service and concluded
    that, since 311 calls, like 911 calls, are typically intrastate,
    states would regulate cost recovery in most instances.[^83] In doing
    so, we do not believe that the Commission imposed any affirmative
    obligations on those state and local authorities. Moreover, because
    the Commission did not require states or localities to deploy
    personnel or facilities to respond to 311 calls, we conclude that
    our assignment of 311 is not an unfunded mandate to the states.
    Instead, we have made available a federal numbering resource, the
    311 code, to assist local law enforcement and public safety efforts.

### BellSouth Petition for Clarification and Reconsideration

#### Background 

29. On March 28, 1997, BellSouth Corporation filed a Petition for
    Clarification and Reconsideration of the *N11 First Report and
    Order* requesting clarification of the manner in which N11 codes are
    to be provisioned and reconsideration of the six-month
    implementation requirement established for the provision of
    311.[^84] Specifically, BellSouth seeks clarification that, under
    the Commission's definition of "assignment," existing providers of
    local information services using 311 and 711 are "current users" of
    the numbers that may continue their use of the previously unassigned
    codes, and that the Commission's assignment of 311 and 711 is not a
    national recall of these codes.[^85] BellSouth also seeks
    clarification that the 311 code may continue to be assigned by LECs
    and states for non-conforming local uses until a request is made for
    a conforming local use of that code.[^86]

30. BellSouth argues that the Commission did not address, in its *N11
    First Report and Order*, how 311 service should be provisioned.[^87]
    BellSouth expresses concern that requesting entities might interpret
    the *N11 First Report and Order* to require that 311 calls be
    handled in the same manner as 911 calls.[^88] BellSouth seeks
    clarification of this matter, pointing out that, although the
    Commission stated that states and local governments may deploy 311
    through their 911 centers, it also allows for alternative procedures
    for routing and answering 311 calls.[^89] BellSouth argues that 911
    features, such as Automatic Number Identification (ANI) and
    Automatic Location Identification (ALI) information, are unnecessary
    in the non-urgent context of a 311 call.[^90] BellSouth also seeks
    clarification of whether CMRS providers are required to furnish 311
    dialing capability to non-subscribers or roamers in the absence of a
    roaming agreement.[^91] Furthermore, BellSouth seeks clarification
    of whether, because states have no jurisdiction to approve wireless
    rates, CMRS providers may set prices and charge their subscribers
    for 311 service or calls made to local government 311 service
    providers, without regulation by the state authorities.[^92] AT&T
    and CTIA support BellSouth's request for clarification.[^93]

31. BellSouth indicates that its requests for reconsideration of the
    Commission's six-month implementation requirement for 311 is
    necessitated by the absence of any single uniform solution for the
    implementation of 311 and the possibility that multiple requests for
    its use will be submitted that will require resolution by the state
    commissions.[^94] The time needed for implementation, it argues,
    depends upon several factors, including the number of jurisdictions
    requesting the use of 311, the type of service requested by the
    jurisdictions, the architecture that will be needed to support those
    service requests, the LECs' ability to disconnect existing
    non-conforming uses, and the need to refile tariffs to remove the
    311 code from non-conforming service offerings.[^95] It explains
    that compliance with the six month implementation requirement will
    be practically impossible if multiple requests from different
    entities within the same geographic areas are received, possibly
    requiring the state commission to initiate a proceeding to decide
    how 311 will be implemented.[^96]

32. Finally, BellSouth requests that the Commission clarify that
    BellSouth may meet its obligations for 311 implementation by
    providing tariffed, local calling area-based service to requesting
    311 entities pursuant to the terms and conditions of its
    tariffs.[^97] If any type of architecture change is required by the
    requesting 311 entity, BellSouth argues, the Commission should
    postpone implementation until:

```{=html}
<!-- -->
```
(1) the underlying architecture is established;

(2) any switch upgrades or software enhancements that are required by
    the underlying architecture selected are in place;

(3) issues resulting from multiple requests in the same service area
    have been resolved by the state commission through a final order;

(4) a state commission-approved funding mechanism has been established;
    and

(5) appropriate contractual agreements have been established between
    CMRS providers and the 311 service provider for 311 service.[^98]

#### Discussion

33. In the *N11 First Report and Order*, the Commission states that
    "assignment" means that an announcement is made to the industry that
    a particular number will be used for certain, defined services to
    warn current users of that number that they will need to relinquish
    their use of the number when the new assignment is implemented. We
    clarify that "current users" in our definition of "assignment" are
    those entities currently employing 311 for "other uses;" *i.e.*
    purposes other than for non-emergency police calls and other
    government services*.*[^99] Local information service providers,
    among other entities currently using 311 for various purposes,
    clearly would fit within this definition of "current users."

34. Indeed, when announcing assignment of 311 as the N11 code to be used
    to reach non-emergency police services on a nationwide basis, the
    Commission stated that, wherever 311 is currently in use for other
    purposes, it would allow that use to continue until the local
    government in that area requests activation of 311 for the assigned
    purpose.[^100] Also, because the record indicated that 311 was being
    used for purposes other than non-emergency police access in several
    jurisdictions, the Commission stated in the *N11 First Report and
    Order* that it would allow nonconforming uses of the 311 code to
    continue for a reasonable period to ensure that there is no
    unreasonably abrupt disruption of those uses.[^101] Finally, when
    denying requests for grandfathering of nonconforming uses of 311 at
    the local level, the Commission noted that the use of 311 for other
    purposes prior to the effective date of the *N11 First Report and
    Order* may continue until the local government in that area is
    prepared to activate a non-emergency 311 service.[^102] As the
    Commission stated in the *N11 First Report and Order*, its actions
    in this regard were consistent with existing Bellcore guidelines,
    which permitted local use of N11 codes provided that such
    assignments and use could be discontinued on short notice.[^103] In
    light of the foregoing, we clarify that the Commission's assignment
    of 311 is not a national recall of that code that requires
    discontinuance of its use for other than the assigned purposes in
    jurisdictions that have not implemented conforming services using
    311.

35. With respect to BellSouth's assertion that the Commission's *N11
    First Report and Order* might be interpreted to require that 311
    calls be handled in the same manner as 911 emergency calls, we
    recognize that all implementation issues for 311 have not been
    resolved.[^104] In our *N11 First Report and Order*, CTIA contended
    that the Commission must define the scope of 311 services so that
    CMRS providers are technically capable of providing those
    services.[^105] The Commission agreed with CTIA that carriers should
    not necessarily be required to provide the same features or the same
    terms for 311 as are provided for 911, and stated that it did not
    intend to impose the same types of obligations on wireless providers
    with regard to 311 as it did with regard to 911.[^106] We therefore
    clarify that there is no Commission mandate that 311 calls be
    provisioned in the same manner as 911 emergency calls.

36. Additionally, we decline at this time to change the requirement that
    a provider of telecommunications services must ensure that, within
    six months of receiving a request from an entity to use 311,
    entities that were assigned 311 for nonconforming uses discontinue
    use of the code for those purposes, and must take the necessary
    steps to complete 311 calls for entities seeking to provide access
    to conforming services using 311. We continue to believe that six
    months is an appropriate implementation period following a request
    to provide 311 service, and hereby reaffirm that finding.

## Further Notice of Proposed Rulemaking Issues

### 1. Sale of N11 Codes {#sale-of-n11-codes .unnumbered}

#### Background

37. Section 251(e) of the Communications Act of 1934, as amended by the
    Telecommunications Act of 1996, gives the Commission exclusive
    jurisdiction over the administration of numbering resources,
    including N11 codes. The Commission has recognized that the N11
    abbreviated dialing codes are scarce numbering resources. Like other
    numbering resources, the Commission concluded they are public
    resources and not the property of carriers.[^107] We have reiterated
    that carriers do not own N11 codes or other numbering resources,
    although they have administered them for the efficient operation of
    the public switched telephone network.[^108]

38. The Commission has recognized that the limited supply of N11 codes
    and the demand for them makes N11 codes a valuable resource. To
    capitalize on this value, in the *N11 NPRM* the Commission suggested
    that those entities using N11 codes may wish to sell or transfer the
    use of these abbreviated dialing codes to others.[^109] Upon review
    of the record, we issued the *N11 Further Notice* and tentatively
    concluded that because they are a national public resource, N11
    codes should not be sold or transferred through private
    transactions.[^110] We sought comment on our statutory authority to
    sell the right to use N11 codes. We asked parties to distinguish the
    statutory authority to sell the right to use N11 codes from the
    right to sell other abbreviated dialing arrangements.

#### Discussion

39. 

40. We affirm the Commission's tentative conclusion that the sale or
    transfer of N11 codes through private transactions should not be
    allowed at this time. Most commenters agree that the sale of N11
    codes would not be in the public interest,[^111] and some suggest
    that we lack the statutory authority to permit such sale or
    transfer.[^112] Our exclusive jurisdiction over the North American
    Numbering Plan (NANP) as it pertains to the United States gives us
    broad authority over NANP resources, and we believe that this broad
    authority permits us to use market-based economic strategies to
    optimize the use of NANP numbering resources in the United States.
    Nonetheless, we need not resolve this issue in the present context
    because of our conclusion that N11 codes may not be sold or
    transferred through private transactions .

### Administration of N11 Codes

#### Background

41. Prior to the 1996 Act, incumbent LECs, state commissions, Bellcore
    and the Commission performed the functions related to numbering
    administration, including administration of N11 codes. Although the
    1996 Act gives the Commission exclusive jurisdiction over number
    administration, it authorizes the Commission to delegate all or part
    of its numbering administration authority to state commissions or
    other entities.[^113] In the *N11 First Report and Order*, the
    Commission authorized the incumbent LECs, state commissions, and
    Bellcore to continue to perform N11 code administration related
    functions that they performed at the time of enactment of the 1996
    Act.[^114]

42. Number administration functions previously performed by Bellcore,
    namely Numbering Plan Area (NPA)[^115] assignments and NPA relief
    planning, have been transferred to a neutral North American
    Numbering Plan Administrator (NANPA).[^116] AT&T and Bellcore, while
    serving as the NANPA, designated 411, 611, 811, and 911 for national
    use. In the *N11 First Report and Order*, the Commission concluded
    that it would not disturb the 411 and 911 designations.[^117] Since
    use of 611 and 811 was less ubiquitous than use of 411 and 911,
    however, the Commission concluded that carriers could continue the
    current uses of these N11 codes until they are needed for other
    national purposes.[^118] The Commission exercised the authority
    previously exercised by AT&T and Bellcore, to assign N11 codes (311
    and 711) for nationwide use.

43. Many LECs assigned N11 codes for local use consistent with the AT&T
    and Bellcore designations or as otherwise authorized by state
    commissions. In 1998, CO code administration functions previously
    performed by the incumbent LECs were transferred to the neutral
    NANPA.[^119] In the *N11 Further Notice*, we sought comment on
    whether N11 administration, to the extent performed prior to the
    1996 Act and otherwise continued, should also be transferred from
    the incumbent LECs to the neutral NANPA.[^120]

#### Discussion

44. We conclude that the Commission should continue to designate and
    assign N11 codes for nationwide use, rather than delegate that
    authority to the NANPA or any other entity. We find that it is not
    necessary to transfer N11 administration functions from the
    incumbent LECs to the NANPA or any other entity. Commencing with the
    *N11 First Report and Order*, we have made three national
    assignments of N11 codes.[^121] Once we assign or designate an N11
    for national use, essentially all that remains to do is to implement
    that assignment and monitor the uses of the N11 codes.[^122] We do
    not at this time decide what role, if any, state commissions may
    play once we make a national assignment. That role will necessarily
    be determined on a case by case basis as we make national
    assignments. We clarify, however, that states will be allowed to
    continue to make local assignments that do not conflict with our
    national assignments.

### Need for Comprehensive Rulemaking 

45. Several commenters contend that that we should initiate a
    comprehensive review of our rules and practices relating to
    abbreviated dialing arrangements, due in part to the "competing"
    petitions,[^123] and other existing users.[^124] We decline, at this
    time, to do so because we find such a rulemaking proceeding to be
    unnecessary. In this Order, we resolve issues that pertain to the
    two pending requests for assignment of N11 codes. With the exception
    of one outstanding petition,[^125] we also have resolved in this
    Order most of the outstanding issues relating to the N11 proceeding.
    We also note that in the three-year period following the *N11 First
    Report and Order*, we have received only two petitions for
    assignment of the remaining N11 codes, both of which are resolved
    herein,[^126] and both of which enjoy overwhelming support. We
    therefore decline to initiate a rulemaking and review of our rules
    and practices relating to abbreviated dialing codes at this time.

# Procedural matters

## Regulatory Flexibility Act 

46. As required by the Regulatory Flexibility Act (RFA),[^127] an
    Initial Regulatory Flexibility Analysis (IRFA) was incorporated in
    the *N11 First Report and Order and FNPRM*. The Commission sought
    written public comment on the proposals in the *N11 FNPRM*,
    including comment on the IRFA. The IRFA requested written public
    comment on two issues: (1) the technical feasibility of implementing
    711 access for telecommunications relay services and (2) the
    proprietary nature of N11 codes and the transfer of the
    administration of N11 codes.

47. The first issue concerning the technical feasibility of implementing
    711 access is being addressed in a companion proceeding captioned
    the *Second Report and Order*. Therefore, we will not address that
    issue in this proceeding.

48. The second issue concerning the sale or transfer of N11 codes and
    the administration of N11 is addressed in this proceeding. We
    conclude that the sale or transfer of the N11 codes through private
    transactions should not be allowed at this time, and that the
    Commission should continue to make assignments of N11 codes, rather
    than delegate this authority to another entity. Therefore, we
    decline to make any revisions or modifications to our rules at this
    time. The RFA requires that a Final Regulatory Flexibility Analysis
    be completed "\[w\]hen an agency promulgates a final rule . .
    .."[^128] Because we are not adopting any new rules and are not
    making any changes to existing rules, a FRFA is not required.

# Ordering Clauses

49. Accordingly, IT IS ORDERED, pursuant to Sections 1, 4(i), and
    251(e)(1) of the Communications Act of 1934, as amended, 47 U.S.C.
    §§ 151, 154(i), and 251(e)(1), that this *Third Report and Order and
    Order on Reconsideration* is hereby ADOPTED.

50. IT IS FURTHER ORDERED, that the Petition for assignment of an N11
    for access to travel information services filed by the U.S.
    Department of Transportation is GRANTED, and that the Petition for
    assignment of 211 for access to community information and referral
    services filed by the Information and Referral providers is GRANTED.

51. IT IS FURTHER ORDERED, that the Petitions for Reconsideration and/or
    Clarification filed by Arch, BellSouth, Interactive Services
    Association, and International Association of Fire Chiefs and
    International Municipal Signal Association are DENIED.

52. IT IS FURTHER ORDERED, that 511 is ASSIGNED as a national
    abbreviated dialing code to be used exclusively for access to travel
    information services as of the effective date of this *Third Report
    and Order*.

53. IT IS FURTHER ORDERED, that 211 is ASSIGNED as a national
    abbreviated dialing code to be used for access to community
    information and referral services as of the effective date of this
    *Third Report and Order*.

54. IT IS FURTHER ORDERED, that this Commission shall reexamine the
    deployment of 511 for access to traveler information services, and
    of 211 for access to community information and referral services
    five years after the effective date of this *Third Report and
    Order*.

    FEDERAL COMMUNICATIONS COMMISSION

> Magalie Roman Salas
>
> Secretary

**Appendix A**

Comments and Replies Filed in Petition by the United States Department
of Transportation for Assignment of an Abbreviate Dialing Code (N11) to
Access Intelligent Transportation System (ITS) Services Nationwide

CC Docket No. 92-105

NSD L-99-24

211 Collaborative Reply

AAA

American Association of State Highway and Transportation Officials

Maryland Department of Transportation, Mass Transit Administration

Altamont Computer Express

Association for Commuter Transportation

AT&T Corp. (AT&T)

AT&T Reply

San Francisco Bay Bay Area Rapid Transit District (BART)

BART Reply

BellSouth Corporation

Bi-State Development Agency

Capitol Region Council of Governments

Capital District Transportation Authority

Cellular Telephone Industry Association Reply

Charlotte Transit

Chittenden County Metropolitan Planning Organization

Clark County-Springfield Transportation Coordinating Committee

Greater Cleveland Regional Transit Authority

Communications Venture Services, Inc.

Cox Enterprises, Inc.

Central Ohio Transit Authority

Dallas Area Rapid Transit

Des Moines Area Metropolitan Planning Organization

Government of the District of Columbia

Escambia County Area Transit

Economic Development Council of Northeastern Pennsylvania

Evansville Urban Transportation Study

Foothill Transit

Fort Worth Transportation Authority

I-95 Corridor Coalition

Intelligent Transportation Society of Florida

Intelligent Transportation Society of America, American Public Transit
Association, and American Association of State Highway and
Transportation Officials -- Joint Reply

Kentucky Transportation Cabinet

GTE Service Corporation

Kalamazoo Metro Transit System

Kansas Department of Transportation

Kentucky Transportation Cabinet

Landstar System, Inc.

Lee County, Department of Transportation

Transit Authority of Lexington, Kentucky

Livermore/Amador Valley Transit Authority

Central Florida Regional Transportation Authority

Maricopa Association of Governments

Massachusetts Bay Transportation Authority

Massachusetts Highway Department

MCI WorldCom, Inc. (now WorldCom)

METRO Regional Transit Authority

Southern California Regional Rail Authority, Metrolink

Rock Island County Metropolitan Mass Transit District

METROPLAN ORLANDO

Metropolitan Transportation Commission

Mississippi Department of Transportation

Minnesota Department of Public Safety

Minnesota Department of Transportation

Intelligent Transportation Society of America, Minnesota

Monterey-Salinas Transit

Mid-Ohio Regional Planning Commission

Marc Racicot, Governor, State of Montana

Mike Johanns, Governor, State of Nebraska

Jeanne Shaheen, Governor, State of New Hampshire

North Carolina Department of Transportation

Port of Oakland

Metropolitan Transportation Commission

Ohio Department of Transportation

Ohio-Kentucky-Indiana Regional Council of Governments

Ohio Public Utilities Commission

Sybille H. Phillips

Port Authority Trans-Hudson Corporation

Potomac and Rappahannock Transportation Commission

Regional Transportation Commission

Rhode Island Department of Transportation

Red Rose Transit Authority

Sacramento Area Council of Governments

San Mateo County Transit District

San Diego Association of Governments

San Francisco Public Transportation Department Municipal Railway

Silicon Valley Smart Corridor Steering Committee

Ron Gonzales, Mayor, City of San Jose

Santa Clara Valley Transportation Authority

Santa Cruz Metropolitan Transit District

SmartRoute Systems, Inc.

Southern California Association of Governments, Southern California
Rideshare

Sprint Spectrum L.P., d/b/a Sprint PCS

David E. Stein

Sunline Transit Agency

Lawrence T. Tai

Transit Authority of River City

Tompkins Consolidated Area Transit

Texas Department of Transportation

Transportation Operations Coordinating Committee

Tri-County Metropolitan Transportation District of Oregon

Triangle Transit Authority

Tulsa County, Board of County Commissioners

University of Florida, Transportation Research Center

United Way of Connecticut

Utah Transit Authority

Utah Department of Transportation

U.S. DOT

Valley Metro Regional Public Transportation Authority

Virginia Department of Transportation

Washington State Department of Transportation

Sweson Yang

**Appendix B**

Comments and Replies Filed in Request by Alliance of Information and
Referral Systems, United Way of America, United Way 211 (Atlanta,
Georgia), United Way of Connecticut, Florida Alliance of Information and
Referral Services, Inc., and the Texas I&R Network for Assignment of 211
Dialing Code

NSD-L-98-80

American Public Communications Council

Ameritech

Area Agency on Aging

Brazos County Community Council

Brazos County Emergency Communications District Services

Ask-2000, a Program of the Hawaii Community Services Council

Chris Bell, Houston Council Member

BellSouth Corporation

Big Bend Hospice

Border Families Are Valued Project

Mary Brennan, Florida House of Representatives

The Bridge, A Refuge for Women

Lee P. Brown, Mayor, Houston

City of Calgary, Community and Social Development Department

Bill Campbell, Mayor, City of Atlanta

Capital Area Healthy Start Coalition

Center for Advocacy for the Rights and Interests of the Elderly (CARIE)

Carnegie Library of Pittsburgh, HelpLine

Information and Referral Midland, Casa de Amigos of Midland, Texas

Center for Information & Crisis Services, Inc.

Cincinnati Bell, Inc. (CinBell)

CinBell Reply

Children's Forum

Lawton Chiles, Governor, State of Florida

Coalition for the Homeless of Houston/Harris County, Inc.

Community Connection of Northeast Georgia

Community Council of Greater Dallas

Communities in Schools of Georgia

Community Service Council of Chester County, Inc.

Community Services Planning Council, InfoLine Sacramento

Dick Armey, Representative, Texas

Michael Bilirakis, Representative,

George Brown, Representative, California

Charles T. Canady, Representative, Florida

Rosa L. DeLauro, Representative, Connecticut

Sam Gejdenson, Representative, Connecticut

Newt Gingrich, Representative, Georgia

Darlene Hooley, Representative, Oregon

Kay Granger, Representative, Texas

Eddie Bernice Johnson, Representative, Texas

Nancy L. Johnson, Representative, Connecticut

Nita M. Lowey, Representative, New York

James H. Maloney, Representative, Connecticut

John W. Olver, Representative, Massachusetts

Louise M. Slaughter, Representative, New York

Community Connection of Northeast Georgia

Connecticut Department of Public Utility Control

CONTACT, Bucks County

CONTACT Community Services of Camden County, New Jersey

CONTACT Telephone Helpline, Inc.

The Council on Alcohol & Drug Abuse/Houston

Crisis Intervention Center of Houston, Inc.

Council of Community Services

Donald R. Craig

Crisis Line Information and Referral, Inc.

Crockett Resource Center for Independent Living, Inc.

Crossroads: Community Partnership for Youth, Inc.

Linda S. Daily

Danbury Regional Commission on Child Care, Rights and Abuse

Texas Disability Policy Consortium

Richard Recht

El Paso Community Resource Coordination Group

Gene F. Eriquez, Mayor, City of Danbury

Family Resource Center

Family Service America, Inc.

Free Information and Referral System Telephone

First Call for Help, Daytona Beach, Florida

First Call for Help, Portage County, Ohio

First Call for Help, Sarasota, Florida

First Call for Help, Spring Hill, Florida

First Call for Help, Central Minnesota

Florida Alliance of Information and Referral Service

Florida Department of Children & Families

Florida Developmental Disabilities Council, Inc.

Walter Schoenig

Florida Department of Juvenile Justice

Freeborn County Family Services Collaborative

Georgia Emergency Management Agency

Gold County Telecare, Inc.

Jack Guynn, President, Federal Reserve Bank of Atlanta

Hands on Atlanta

John A. Hardiman

The Haven of Religious Community Services, Inc.

State of Hawaii, Executive Office on Aging

Heart of Florida United Way

Heart of Illinois United Way

Helpline, Tulsa, Oklahoma

HELPLINK Information and Referral Service

Homeward

Houston Area Women's Center

Human Services Council

Human Services Information & Referral Program of Northern VA Planning
District Commission

United Way of Metropolitan Atlanta

Incarnate Word Heal System

Metropolitan Atlanta Council on Alcohol and Drugs

Illinois Alliance of Information and Referral Systems

Info Line, Inc.

INFO LINK Orange County

Information & Referral of Douglas County

Information & Referral Services, Inc.

Information & Referral Services, Midland

Information London

Information and Referral Centre of Greater Montreal

INFORMation services Vancouver

J. Bulow Campbell Foundation

Jean Kelley, Houston City Council Member

Kenosha Human Development Services, Inc.

Kiwanis Club of College Station

Ann Kramer

Cyndi Taylor Krier, County Judge, Bexar County, Texas

Lafayette Crisis Center

Jack Latvala, Senator, Florida Senate

Low Tech Designs, Inc.

Vigo County Lifeline, Inc.

Lutheran Social Services of North Florida

Milwaukee Council on Alcoholism and Drug Dependence, Inc.

MCI Telecommunications Corp. (now WorldCom)

WorldCom Reply

Mecklenburg County Department of Social Services

Mental Health Association in Waukesha County, United Way of Waukesha
County & Waukesha County Department of Health and Human Services

Mile High United Way

Zell Miller, Governor, State of Georgia

National Emergency Number Association and National Association of State
Nine-One-One Administrators

National Telephone Enterprises, Inc. (NTE)

NTE Reply

Marilyn Kemeny Nathan

Robert W. Neumann, Sheriff, Palm Beach County

North Central-Flint Hill Area Agency on Aging

North Carolina Alliance of Information and Referral Systems

New York State Alliance of Information and Referral Systems

OMB Watch

Orange County Rescue Mission

Michael T. Petrik

Howard W. Peak, Mayor, City of San Antonio

Philadelphia Corporation for Aging

Sallie Parks, Commissioner, Pinellas County Board of County
Commissioners

Planning Council for Health and Human Services, Inc.

John Portela

Mark O'Conell, President, United Way of Metropolitan Atlanta

Regional Contractors Commonwealth of Virginia Human Services Information
& Referral System

Joe Roach, Houston City Council

Carroll G. Robinson, Houston City Council

John G. Rowland, Governor, State of Connecticut

Walter Schoenig

Daniel K. Akaka, US Senate, Hawaii

Christopher J. Dodd, US Senate, Connecticut

John Glenn, US Senate, Ohio

Bob Graham, US Senate, Florida

Phil Gramm, US Senate, Texas

Senior Services (five different submissions by executive personnel)

Shepherd Center of Tarpon Springs, Inc.

Sioux Empire United Way

Southwestern Bell Corporation (SBC)

Southwest Louisiana Education and Referral Center, Inc.

Jon Spacht

Strategic Interfaces

The Support Network, Edmonton, Alberta

Switchboard of Miami, Inc.

Tarrant County 911 District

Team Metro

Telephone Counseling & Referral Service

Texas Department of Protective and Regulatory Services

The Information Center, Inc., Family Resource Place

Triangle United Way

Tull Charitable Foundation, Inc.

United Way of Allegheny County

United Way of Amarillo and Canyon

United Way of America

First Call, United Way of Adroscoggin County

United Way of Asheville and Buncombe County

United Way of Bucks County

United Way California Capitol Region

United Way/Capital Area

United Way of Central Florida

United Way of Central Georgia

United Way of Central Indiana

United Way of Central Maryland

United Way of Central Massachusetts

United Way of Central Virginia

United Way of Coastal Bend

United Way/Crusade of Mercy, Inc.

United Way of Metropolitan Dallas, Inc.

United Way of Dane County

United Way of Davis County

United Way of Greater Dayton Area

United Way of Essex and West Hudson

United Way of Northern Fairfield County

United Way of Florida (two letters from executive personnel)

United Way Fox Cities

United Way of Greater Greensboro

United Way of Illinois

Greater Kalamazoo United Way

United Way LINK, Lake County, Ohio

United Way of Lubbock

United Way of the Midlands

United Way of Minneapolis Area

United Way of Monmouth County

United Way of Puerto Rico (Fondos Unidos de Puerto Rico)

United Way of San Antonio and Bexar County

United Way of Southeastern Pennsylvania

United Way of Sterling-Rock Falls

United Way of Summit County

United Way of Metropolitan Tarrant County

United Way of Texas

United Way of the Texas Gulf Coast

United Way of Thomas Jefferson Area

United Way of Tyler/Smith County

United Way of Virginia

United Way of Westchester and Putnam, Inc.

United Way at Work Advisory Council

United Way Services, Metropolitan Atlanta

United Way Services, Cleveland

United Way Services, Richmond

University Of Houston, Victoria

University of Texas at Austin University of Texas, Houston, Health
Science Center

Volunteer and Information Agency

Larry E. Walton

Whatcom Crisis Services

The Women's Center of Tarrant County, Inc.

YWCA

**Appendix C**

Comments and Petitions Filed in *N11 First Report and Order and FNPRM*

CC Docket 92-105

[Comments]{.underline}

Ameritech

AT&T Corp. (AT&T)

Bell Atlantic and Nynex

BellSouth Corporation (BellSouth)

Cellular Telephone Industry Association (CTIA)

David J. Nelson (Nelson)

GTE Service Corporation

Maricopa Association of Governments (Maricopa)

MCI Telecommunications Corporation (MCI)

Mitchell D. Travers

National Association of the Deaf (NAD)

Pacific Telesis Group

Southwestern Bell Telephone Company (SBC)

Sprint Corporation (Sprint)

Telecommunications for the Deaf, Inc. (TDI)

United States Telephone Association (USTA)

US West, Inc. (US West)

[Petitions for Clarification and Comments]{.underline}

Arch Communications

Ameritech

BellSouth

CTIA

Interactive Services Association

International Association of Fire Chiefs and the International Municipal
Signal Association (IAFC Petitioners)

NENA

US West

[Reply Comments]{.underline}

AT&T

Nelson

NAD

Council of Organizational Representatives on National Issues Concerning
People who are Deaf or Hard of Hearing (COR)

Georgia Public Service Commission (Georgia PSC)

SBC

[^1]: N11 codes "011" and "111" are unavailable because "0" and "1" are
    used for switching and routing purposes.

[^2]: In *The Use of N11 Codes and Other Abbreviated Dialing
    Arrangements,* CC Docket No. 92-105, *First Report and Order and
    Further Notice of Proposed Rulemaking*, 12 FCC Rcd 5572 (1997) *(N11
    First Report and Order and FNPRM),* the Commission assigned 311 for
    access to non-emergency police and other government services, and
    711 for access to Telecommunications Relay Services, or TRS. *N11
    First Report and Order,* 12 FCC Rcd at 5595, para. 35; *id.* at
    5606, para. 55. *See Appendix C* for a list of commenters, reply
    commenters*,* and petitioners on the *N11 First Report and Order and
    FNPRM.*

[^3]: The Wireless Communciations and Public Safety Act of 1999, Pub. L.
    No. 106-81, 113 Stat. 1286 ("911 Act") directs the Commission to
    designate 911 as the national emergency number and to support
    comprehensive emergency communications throughout the United States.

[^4]: *See* *N11 First Report and Order*, 12 FCC Rcd at 5599, para. 45
    (allowing continued use of 611 and 811 to access LEC repair and
    business offices; *id.* at 5600, para. 47 (allowing continued use of
    411 for access to directory assistance). *See also id*. at 5607,
    paras. 57 and 58 (stating that the Commission has exclusive
    jurisdiction over numbering in the United States, and that N11 codes
    must be allocated in a consistent manner on a nationwide basis*).*

[^5]: ^5^ They are 211 and 511.

[^6]: Specifically, we address issues raised in the *N11 FNPRM* and two
    petitions for reconsideration and/or clarification of the *N11 First
    Report and Order.* International Association of Fire Chiefs and
    International Municipal Signal Association (IAFC Petitioners)
    Petition for Reconsideration, filed March 28, 1997; BellSouth
    Petition for Clarification and Reconsideration, filed March 28,
    1997.

[^7]: *See Appendix A* for a list of commenters and reply commenters to
    the U.S. DOT Petition.

[^8]: *See Appendix B* for a list of commenters and reply commenters to
    the Information and Referral Services Petition.

[^9]: As part of the 1984 AT&T divestiture, N11 related functions
    previously performed by AT&T were transferred to Bellcore. The
    Regional Bell Operating Companies (RBOCs) that were created as a
    result of the AT&T divestiture jointly owned Bellcore. Bellcore
    performed research and development functions for the RBOCs.

[^10]: 47 U.S.C. § 251(e)(1). The Telecommunications Act of 1996, Pub.
    L. No. 104-104, 110 Stat. 56 (amending the Communications Act of
    1934, 47 U.S.C. § 151 et. seq.).

[^11]: 47 U.S.C. § 251(e)(1).

[^12]: *See* The Use of N11 Codes and Other Abbreviated Dialing
    Arrangements, CC Docket No. 92-105, *Notice of Proposed Rulemaking*,
    7 FCC Rcd 3004 (1992)(*N11 NPRM*). The same day the *N11 NPRM* was
    released, the Commission's Office of General Counsel responded to a
    petition filed by BellSouth for assignment of N11 codes for access
    to information services, which request was prompted by a request
    from Cox Enterprises, Inc. (Cox). Cox had asked BellSouth to assign
    to it an N11 code in Atlanta for the purpose of offering information
    services. The Office of General Counsel informed BellSouth that
    "there appears to be no regulatory or legal impediment prohibiting
    BellSouth from currently assigning N11 codes in a reasonable,
    non-discriminatory manner," which may include, for example,
    assigning N11 codes on a first-come, first-service basis. Letter
    from Robert L. Pettit, FCC General Counsel, to David J. Markey, Vice
    President, BellSouth, May 4, 1992.

[^13]: National Center for Law and Deafness and Telecommunications for
    the Deaf, Inc. petition, filed October 1, 1993 (seeking assignment
    of 711 for access to TRS by persons with speech and/or hearing
    disablilites and a second unspecified service code for TRS access by
    voice and telephone users); General Services Administration (GSA)
    petition for declaratory ruling, filed March 11, 1994 (requesting
    assignment of an N11 code for nationwide public telephone access to
    federal executive agencies); National Association of State
    Telecommunications Directors *ex parte* letter filed in response to
    GSA petition for declaratory ruling (requesting a single N11 code
    for access to state agencies); U.S. Department of Justice's
    Community Oriented Policing Services (COPS) letter dated August 26,
    1996 (seeking designation of 311 nationwide for non-emergency police
    calls, or other government services, at local discretion).

[^14]: *N11 First Report and Order*, 12 FCC Rcd at 5579, para. 13.

[^15]: *Id*. at 5575, para. 2.

[^16]: *N11 FNPRM,* 12 FCC Rcd at 5610-13, paras. 66-75.

[^17]: The following TRS issues were raised in the Further Notice of
    Proposed Rulemaking: (1) how competition among relay providers would
    be maintained; (2) whether implementation is technically feasible
    and, if so, the details of such implementation; (3) the projected
    costs and cost recovery; and (4) what effect implementation of a
    nationwide N11 code will have on CMRS providers and their networks.
    *Id.* at 5610, para. 67.

[^18]: The Commission tentatively concluded that N11 codes should not be
    transferred or sold through private transactions. *Id.* at 5612,
    para. 71.

[^19]: *Id*. at 5613, paras. 74-75.

[^20]: *See* IAFC Petition for Reconsideration, BellSouth Petition for
    Clarification and Reconsideration, *supra* note 6*.*

[^21]: In order to refresh the record on implementation of TRS, the
    Commission held a public forum on Wednesday, September 6, 1999.
    *See* Public Notice, *Revised Public Notice on FCC Convenes a Public
    Forum on 711 Access to TRS*, DA 99-1170, June 16, 1999.

[^22]: *See* note 3, *supra.*

[^23]: *See* Petition for Rulemaking by the United States Department of
    Transportation, filed March 8, 1999 (U.S. DOT Petition). In
    response, the Commission released a public notice requesting comment
    on the U.S. DOT Petition. *See* Petition by the United States
    Department of Transportation for Assignment of an Abbreviate Dialing
    Code (N11) to Access Intelligent Transportation System (ITS)
    Services Nationwide, *Public Notice*, DA 99-761, NSD File No.
    L-99-24, CC Docket No. 92-105 (rel. April 20, 1999).

[^24]: U.S. DOT Petition at 3.

[^25]: The U.S. DOT projects that public and private sectors will spend
    an estimated \$425 billion on intelligent transportation systems by
    the year 2015. *Id.* at 5.

[^26]: According to U.S. DOT, at least 43 states and 42 major
    metropolitan areas, and over 100 transit agencies currently operate
    traveler information systems, using the telephone as the primary
    means of communication. *Id.* at 12.

[^27]: Callers using mobile phones who only had to dial "\*1" were more
    likely to remember the access number than landline users who had to
    dial seven digits. *Id*. at 15-17.

[^28]: *Id.*

[^29]: GTE Comments at 2, *citing N11 First Report and Order*, 12 FCC
    Rcd at 5584 (para. 20).

[^30]: *Id*. at 3, *citing* DOT Petition at 12, 18 ("\[c\]urrently in
    the Washington, DC -- New York City corridor there are eleven
    different telephone numbers through which to obtain traffic and
    transit status"*)*.

[^31]: U.S. DOT Petition at 2.

[^32]: *See, e.g.,* San Francisco Bay Area Rapid Transit District (BART)
    Comments (endorsing the need for a common number in an area with
    over 25 different transit agencies, and noting also that residents
    in nine Bay area counties can access travel information with a
    common seven-digit number)*;* Landstar System, Inc., Comments at 2
    (noting that assignment of N11 will make travel information more
    accessible than information that is currently provided by some state
    and local governments).

[^33]: *Id*. at 5.

[^34]: *Id*. at 7,15.

[^35]: *Id*. at 2.

[^36]: *See* *id*. at 13; Kentucky Transportation Cabinet Reply Comments
    at 1-3; Kentucky Transportation Cabinet *ex parte* filed October 8,
    1999 (describing migration from 311 to 211 to provide traffic
    information that overlapped initiation of several major freeway
    construction projects). We also note that the Kentucky
    Transportation Cabinet was the first agency in the nation to use an
    N11 to provide traveler information.

[^37]: Kentucky Transportation Cabinet Reply Comments at 3; *see also*
    Ohio Department of Transportation Comments at 1 (describing an
    increase in calls to 211 despite having chosen 333-3333 for travel
    information service on the basis of market research that it would be
    an easy to remember number).

[^38]: *See also* Ohio Department of Transportation Comments, Exhibit A
    at 2 (users reporting 85% satisfaction rate with current 211 travel
    information number, 99% stating they benefitted from service, and
    over 80% reporting they believed they would benefit from nationwide
    use of N11 number for this service).

[^39]: *See, e.g.,* Metropolitan Transportation Commission *ex parte*
    April 22, 1999.

[^40]: *See, e.g.,* Honorable Marc Racicot, Governor, State of Montana
    Comment (describing need to standardize roadway information to make
    more accessible, and user friendly)*.*

[^41]: *See, e.g.,* WorldCom Comments at 3-4.

[^42]: *N11 First Report and Order*, 12 FCC Rcd at 5596, para. 37. In
    this regard, we reject the contention of Sprint PCS that the N11
    code assigned for use with traveler information services should be
    made available to entities other than governmental entities. Sprint
    PCS at 2-5.

[^43]: The U.S. DOT proposal specifies no contemplated DOT regulations
    to accompany assignment of an N11 code*. See generally* U.S. DOT
    Petition.

[^44]: The Kentucky Department of Transportation and the Ohio Department
    of Transportation have used the 311 dialing code for traffic
    information. *N11 First Report and Order*, 12 FCC Rcd at 5594, para.
    34.

[^45]: The Petition requested the 211 code. Request by the Alliance of
    Information and Referral Systems, United Way of America, United Way
    211 (Atlanta, Georgia), United Way of Connecticut, Florida Alliance
    of Information and Referral Services, Inc., and the Texas I&R
    Network for Assignment of 211 Dialing Code (Information and Referral
    Petition). In response, the Commission issued a public notice for
    comment on their petition. *See* Request by Alliance of Information
    and Referral Systems, United Way of America, United Way 211
    (Atlanta, Georgia), United Way of Connecticut, Florida Alliance of
    Information and Referral Services, Inc., and the Texas I&R Network
    for Assignment of 211 Dialing Code, *Public Notice*, DA 98-1571, NSD
    File No. L-98-80 (rel. Aug. 6, 1998).

[^46]: The Information and Referral Petitioners contend that assignment
    of 211 would compliment existing uses of 911 for emergency services
    and the assignment of 311 for police non-emergency uses in the *N11
    First Report and Order*. Information and Referral Petition at 5-6.

[^47]: *See* *id*. at 6.

[^48]: In an *ex parte* dated February 22, 2000, representatives of the
    Information and Referral Petitioners provided Commission staff with
    an updated state-by-state status of 211, indicating that 211 was
    active in at least one locality in Connecticut and a thirteen-county
    area in Atlanta, Georgia. The Information and Referral Petitioners
    also indicated that petitions for 211 had been filed with local
    public utility commissions in three other states (Massachusettes,
    Ohio and Wisconsin) and a county in Michigan. In addition, 211
    petitions had been approved in three other states (Alabama, North
    Carolina and Utah), with statewide information and referral models
    developed in three others (Florida, Texas and Virginia). Six states
    had made no commitment on 211, with the remaining considering 211 to
    some degree for access to community information and referral
    services.

[^49]: *See, e.g.,* Linda Daily Comments (letter from private citizen
    stating, "\[w\]hether it's a mammogram, substance abuse services,
    therapeutic recreation for a disabled child, or 1 of more than 4,000
    human services, the issue is the same. No one knows where to
    start."); Ameritech Comments at 1 (supporting Information and
    Referral Petition as meeting FCC policy of limiting national
    assignment of unused N11 codes for public purposes).

[^50]: We reject arguments to the contrary. *See, e.g.,* CinBell
    Comments at 2.

[^51]: Information and Referral Petition at 6.

[^52]: *Id*.

[^53]: *Id*. at 11.

[^54]: *Id*. at 7, 14. We also note that the United Way 211 database
    includes public and private agencies and programs in the Atlanta
    region, not just United Way member agencies or those supported by
    United Way funding. *Id.*

[^55]: *Id.* at 4.

[^56]: *Id.* at 8.

[^57]: *Id.*

[^58]: According to the Community Oriented Policing Services (COPS)
    Office at the U.S. Department of Justice, a number of communities
    have implemented 311 for access to non-emergency police services
    with the assistance of funds provided by the Department of Justice.
    These include Baltimore, Maryland; Dukes County, Massachusetts
    (Martha\'s Vineyard); Rochester, New York; Miami, Florida; Houston,
    Texas; City of Los Angeles, California \<www.lacity.org\>; Pasadena,
    South Pasadena, California; and Birmingham, Alabama. Other
    communities also have implemented 311, including Dallas, Texas;
    Chicago, Illinois; Washington, D.C.; San Jose, California; Hampton,
    Virginia; and San Antonio, Texas.

[^59]: *See* National Telephone Enterprises, Inc. Comments at 6; SBC
    Communications, Inc. Comments at 1-2.

[^60]: *See*, *e.g*., Area Agency on Aging Comments at 1; Ask-2000
    Comments at 1; Chris Bell, Houston Council Member, Comments at 1;
    Big Bend Hospice Comments at 1; Border Families are Valued Project
    Comments at 1; Brazos County Community Council Comments at 1; Mary
    Brennan, Florida House of Representatives, Comments at 1; The Bridge
    Comments at 1; Houston Mayor Lee P. Brown Comments at 1; The City of
    Calgary Comments at 1; The City of Atlanta, Georgia Comments at 1;
    Capital Area Healthy Start Coalition Comments at 1; Center for
    Advocacy for the Rights and Interests of the Elderly Comments at 1;
    HelpLine Comments at 1; Information and Referral Midland Comments at
    1-2; Center for Information and Crisis Services, Inc. Comments at 1.

[^61]: *See* *N11 First Report and Order*, 12 FCC Rcd at 5595, para. 36;
    *see also* discussion of IAFC Petition at para. 25, *infra.*

[^62]: *Id.* at 5615, para. 83. *See also* para. 5, *supra.*

[^63]: *Id.* at 5615, para. 84.

[^64]: IAFC Petition at 1.

[^65]: *Id*. at 2.

[^66]: *Id*. at 3.

[^67]: *Id*. at 5.

[^68]: *Id*. at 5.

[^69]: *Id*. at 5-6.

[^70]: *Id*. at 13-20.

[^71]: *See* NENA Comments at 1.

[^72]: *See id.* at 1-2.

[^73]: *See* AT&T Comments at 6.

[^74]: *See N11 First Report and Order*, 12 FCC Rcd at 5590, para. 28.

[^75]: *Id*.

[^76]: *Id*. at 5595, para. 35.

[^77]: *Id*. at 5596, para. 39.

[^78]: *Id*. at 5597, para. 40.

[^79]: *Id*.

[^80]: *Id*.

[^81]: *See* *N11 First Report and Order*, 12 FCC Rcd at 5598, para. 43.

[^82]: *Id.* at 5598, para. 42.

[^83]: *Id.*

[^84]: BellSouth Petition at 5.

[^85]: *Id*. at 3.

[^86]: *Id*. at 3-4.

[^87]: *Id*. at 6.

[^88]: *Id*.

[^89]: *Id*. at 6-7.

[^90]: *Id*. at 7. BellSouth also seeks clarification that CMRS
    providers are not required to provide ANI or wireless caller
    location information to the local government service provider.

[^91]: *Id*.

[^92]: *Id*. at 7-8.

[^93]: *See* AT&T Comments at 1-2; CTIA Comments at 3-4.

[^94]: BellSouth Petition at 8.

[^95]: *Id*.

[^96]: *Id*. at 9.

[^97]: *Id*.

[^98]: *Id*. at 9-10

[^99]: *N11 First Report and Order*, 12 FCC Rcd at 5595, para. 35.

[^100]: *Id.* at 5575, para. 2.

[^101]: *Id.* at 5596, para. 38.

[^102]: *Id.* at 5597, para. 41.

[^103]: *Id.*

[^104]: Rather, we have stated that the benefits of a national
    assignment outweigh implementation concerns. *Id.* at 5596, para.
    39.

[^105]: *Id*. at 5598, para. 43.

[^106]: *Id*.

[^107]: *Administration of North American Numbering Plan,* CC Docket No.
    92-237, *Report and Order,* 11 FCC Rcd 2588, 2591, para. 4
    (1992)*(NANP Order).*

[^108]: *N11 Further Notice,* 12 FCC Rcd at 5612, para. 71

[^109]: *N11 NPRM,* 7 FCC Rcd at 3005, para. 15.

[^110]: *N11 Further Notice,* 12 FCC Rcd at 5612, para. 71.

[^111]: *See, e.g.,* AT&T comments at 3.

[^112]: AT&T comments at 6; PCIA comments at 2-4; Cox comments at 4-6.

[^113]: 47 U.S.C. § 251(e)(1).

[^114]: *N11 First Report and Order,* 12 FCC Rcd at 5574-75, para. 2.

[^115]: NPAs are also referred to as area codes.

[^116]: NeuStar currently serves as the NANPA.

[^117]: *N11 First Report and Order,* 12 FCC Rcd at 5586, 5600, paras.
    23 and 47.

[^118]: *Id*. at 5599, para. 45.

[^119]: *NANP Order,* 11 FCC Rcd at 2634, para. 115. *See also*
    *Administration of North American Numbering Plan,* CC Docket No.
    92-237, *Third Report and Order,* 12 FCC Rcd 23040, 23071-72, para.
    59 (1997).

[^120]: *N11 FNRPM,* 12 FCC Rcd at 5612-13, paras. 72-75.

[^121]: In the *N11 First Report and Order*, we designated 311 for
    access to non-emergency police services and 711 for access to
    telecommunications relay service. In this Order, *supra,* paras.
    10-16 and 18-21, we assign 511 for access to advanced traveler
    information systems and 211 for access to community information and
    referral services.

[^122]: Assignment or designation involves announcement to the industry
    that a particular N11 code will be used for certain, defined
    purpose(s). This announcement alerts current users of the N11 code
    that nonconforming uses must cease as part of the implementation
    process. Implementation, on the other hand, may involve, in addition
    to discontinuing nonconforming uses, preparing and modifying
    switches to translate the N11 code and route the call accordingly,
    installing additional switching equipment, and installing or
    modifying software or other hardware.

[^123]: *See* MCI (now WorldCom) Comments at 3-4 (filed in response to
    the U.S. DOT Petition). *See also* United Way of Connecticut
    Comments (opposing assignment of 211 for travel purposes because
    this number is currently in use statewide for public and private
    community services).

[^124]: *See* Cox Enterprises Comments at 1-2, stating that
    longest-standing use of an N11 code to a commercial entity is the
    use of 511 to provide information services to consumers in Atlanta,
    Georgia*; see also* note 5, *supra.*

[^125]: *See* Ameritech Petition for Clarification, filed March 28,
    1997. We decline to address issues raised in Ameritech's Petition
    for Clarification at this time because they are not related to the
    two requests for assignment of N11 that are at issue in this Order.

[^126]: *See* sections III. A and B, *supra*.

[^127]: *See* 5 U.S.C. § 603. The RFA, *see* 5 U.S.C. § 601 *et. seq.*,
    has been amended by the Contract With America Advancement Act of
    1996, Pub. L. No. 104-121, 110 Stat. 847 (1996) (CWAAA). Title II of
    the CWAAA is the Small Business Regulatory Enforcement Fairness Act
    of 1996 (SBREFA).

[^128]: 5 U.S.C. § 604(a).