**INDUSTRY NUMBERING COMMITTEE (INC)**

**Report on VoIP Numbering Issues**

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**ISSUE ORIGINATORS:** **ISSUE #: 393**

Norman Epstein, Verizon & Bill Shaughnessy, BellSouth **DATE SUBMITTED:
November 4, 2002**

Telephone #: 972 718 6297 & 404 927 1364 **DATE ACCEPTED: November 5,
2002**

**REQUESTED RESOLUTION DATE:** **WORKSHOP ASSIGNED: VoIP**

**CURRENT STATUS: Resolved**

**RESOLUTION DATE: November 3, 2003**

1.  **ISSUE STATEMENT:**

> One of the major challenges resulting from the convergence of the PSTN
> and IP networks, especially with VoIP, is how calls pass between the
> PSTN and an IP network. Due to multiple architectural configurations
> for VoIP, the current numbering paradigm may change in a VoIP
> environment. Existing industry guidelines only address number
> assignment, use and responsibilities in a PSTN environment. VoIP
> Services represent a new situation/application that may impact how
> numbers are used and administered in the future.

2.  **SUGGESTED RESOLUTION OR OUTPUT/SERVICE DESIRED:**.

> It is recommended that the INC address the numbering issues and
> challenges of VoIP in a pro-active manner and write a report that
> highlights any numbering issues that arise due to this new
> environment.
>
> There are multiple ways in which VoIP can and is being introduced
> using different technologies and architectures. INC should address
> these various scenarios and evaluate their potential impact on number
> assignment and administration.
>
> In order to support PSTN and IP network convergence, it is necessary
> that numbering issues be thoroughly examined. Thus, as new
> implementations of VoIP are introduced, issues involving numbering in
> VoIP environments need to be identified and highlighted to determine
> their impact on the administration of The North American Numbering
> Plan (NANP).

3.  **OTHER IMPACTS:** (none)

4.  **CONTRIBUTIONS WORKED AGAINST ISSUE:** VoIP-001 through VoIP-029

5.  **CURRENT ACTIVITY:**

> **INC 68:** the Workshop had its initial meeting. A Mission and Scope
> were agreed to, as well as check list of related topics. Five
> contributions were reviewed, including the original VoIP numbering
> "White Paper" presented at the November 2002 NANC meeting. (VoIP-002),
> as well as an AT&T contribution (VoIP-001) based on the "White paper."
> Contributions have been solicited to address the list of related
> topics.
>
> **INC 69:** contributions VoIP-006 through VoIP-012 were discussed.
> After review of the contributions, the workshop discussed possible
> ways to move forward. The options will be revisited at the next INC
> VoIP Workshop.
>
> **INC 70:** Contributions VoIP-013 through VoIP-018 were discussed.
> After review of the contributions, the workshop discussed possible
> ways to move forward. The options will be revisited at the next INC
> VoIP Workshop.
>
> **INC 71:** Six contributions were reviewed, (VoIP 19 - 23, and 13).
> As a result of the review, a merged matrix document was created and it
> was agreed that the merged version of the new VoIP Comparison Matrix
> document will be considered an internal working document and will
> remain so until INC decides otherwise. It is to be marked: "for
> internal use by INC until INC determines otherwise." Contributions
> were requested to update the matrix further and develop an
> introduction to the matrix.
>
> **INC 72:** The workshop agreed to put issue 393 into initial closure
> at this meeting based on a Verizon contribution. The comparison matrix
> was edited based on two other contributions from AT&T and Vonage/Level
> 3. The matrix will be appended to the issue closure statement.
>
> **INC 73:** In General Session, INC agreed to minor editorial changes
> and placed the Issue in Final Closure.

6.  **RESOLUTION:**

> INC identified and discussed many different aspects of PSTN numbering
> assumptions and assignment practices with respect to VoIP technology.
> It became evident that the widely disparate opinions would best be
> captured on a simple chart attached to this resolution statement, with
> no conclusions being drawn. INC therefore determined that there is no
> basis, under this issue, for changing INC guidelines until such time
> as regulatory decisions may provide direction or if INC is requested
> by some outside entity (i.e., NANC) to recommend such changes.

Areas Discussed by the INC VoIP Workshop (Issue 393)

September 18, 2003

Members of the industry represented at the INC have different
perspectives on whether or not the convergence of the PSTN with VoIP
technology has an impact on NANP numbering resources and guidelines.
Because of these divergent views, the categories and opinions noted in
this matrix represent the views of the contributors rather than an
industry consensus view.

+-------------+--------------------------+----------------------------+
| **Area      | ###### **Why A Concern** | ##                         |
| Examined**  |                          | #### **Why Not a Concern** |
+=============+==========================+============================+
| **1. Rate   | See Note 1               | See Note 2 -- AT&T         |
| center      |                          | contribution VoIP-013r1    |
| association | When VoIP providers      | proposes new guidelines    |
| of numbers, | assign numbers from a    | assumptions to address     |
| Central     | different rate center to | this concern.              |
| Office Code | their customers the      |                            |
| Assignment  | traditional association  | Not VoIP specific.         |
| Guidelines  | between locations of NXX |                            |
| ("COCAG")   | assignments and end      | Only applies to VoIP       |
| § 2.14**    | users is broken;         | service offers that extend |
|             |                          | the call beyond the rate   |
|             | Local calls to the       | center                     |
|             | subscriber will become   |                            |
|             | long distance or toll    | VoIP calls are delivered   |
|             | for callers in the       | to POI appropriate to the  |
|             | original rate center if  | rate center; extension of  |
|             | the VoIP provider        | calls to a user in another |
|             | assigns the number to a  | rate center is outside     |
|             | rate center different    | scope of COCAG.            |
|             | than where the end user  |                            |
|             | is located.              | Exceptions currently       |
|             |                          | exist, e.g. FX and         |
|             | 911 may be impacted \--  | wireless                   |
|             | For wireline 9-1-1,      |                            |
|             | there are routing and    | FX-like services, such as  |
|             | equipment issues if      | VZ's IPRS/CyberPOP, SBC's  |
|             | phone numbers are not    | VPOP-DAS Services and Q    |
|             | associated with a rate   | Business Dial and          |
|             | center. These range from | Wholesale Dial Services do |
|             | misrouting of calls to   | the same thing.            |
|             | 9-1-1 selective router   |                            |
|             | four NPA limits in some  | A number of other          |
|             | circumstances. Any       | regulatory bodies are      |
|             | service/ technology that | currently examining the    |
|             | utilizes a wider         | 911 issue. Coordination    |
|             | geographic number        | among various industry     |
|             | association (and         | forums and regulatory      |
|             | additional NPAs beyond   | bodies is necessary for    |
|             | those assigned in the    | INC involvement.           |
|             | 9-1-1 system service     |                            |
|             | provider's selective     | Directory assistance       |
|             | router) may not be       | concerns are not VoIP      |
|             | capable of utilizing the | specific.                  |
|             | existing wireline 9-1-1  |                            |
|             | network or may cause ANI | VoIP providers can make    |
|             | errors or other          | appropriate arrangements   |
|             | differences during call  | with their customers to    |
|             | processing. These are    | resolve any issues         |
|             | similar issues to those  | associated with directory  |
|             | that have been raised    | listings.                  |
|             | regarding wireline       |                            |
|             | geographic               |                            |
|             | portability/pooling      |                            |
|             | considerations.          |                            |
|             |                          |                            |
|             | Directory Assistance may |                            |
|             | be impacted because a    |                            |
|             | VoIP subscriber who      |                            |
|             | subscribes to a VoIP     |                            |
|             | service outside of his   |                            |
|             | traditional PSTN rate    |                            |
|             | center may have to make  |                            |
|             | special arrangements to  |                            |
|             | have their phone number  |                            |
|             | from that location       |                            |
|             | included in the local    |                            |
|             | directory.               |                            |
|             |                          |                            |
|             | In addition, there may   |                            |
|             | be a question regarding  |                            |
|             | who the actual           |                            |
|             | subscriber is with       |                            |
|             | respect to the directory |                            |
|             | listing --the VoIP       |                            |
|             | provider or the customer |                            |
|             | of the VoIP provider?    |                            |
|             |                          |                            |
|             | In today's environment   |                            |
|             | the assignment of a      |                            |
|             | subscriber number        |                            |
|             | outside of their rate    |                            |
|             | center is the exception  |                            |
|             | not the rule.            |                            |
+-------------+--------------------------+----------------------------+
| **2. Impact | See Note 3               | Not VoIP specific          |
| on number   |                          |                            |
| co          | Need for NPA relief in   | Doesn't apply to all VoIP  |
| nservation, | certain NPAs may be      | service offerings          |
| NPA relief, | accelerated due to TN    |                            |
| NANP        | assignments to end users | End-users are economically |
| exhaust**   | outside the NPA          | encouraged to conserve     |
|             |                          | numbers by having to pay   |
|             | Cost of NPA relief will  | for the services that use  |
|             | be borne by those where  | these numbers. Overall, it |
|             | the NPA is rather than   | is difficult to predict if |
|             | by the end users who     | VoIP will increase or      |
|             | reside outside the NPA   | decrease number usage.     |
|             | area                     | Numbering resources are    |
|             |                          | meant to be used. VoIP     |
|             | Additional NRO measures  | providers either obtain    |
|             | may be required in areas | numbers from LECs, or are  |
|             | where there is a large   | also LECs. Thus, VoIP      |
|             | external demand for TNs  | services are compatible    |
|             |                          | with all implemented forms |
|             | Potential to assign NANP | of area code relief and    |
|             | numbers to non-NANP end  | numbering resource         |
|             | users                    | optimization.              |
|             |                          |                            |
|             |                          | Customers who have         |
|             |                          | telephone numbers assigned |
|             |                          | from the rate center will  |
|             |                          | bear the cost regardless   |
|             |                          | of their physical          |
|             |                          | location.                  |
|             |                          |                            |
|             |                          | Number pooling is working  |
|             |                          | to relieve areas that once |
|             |                          | were in "jeopardy" and has |
|             |                          | substantially extended     |
|             |                          | exhaust projections in     |
|             |                          | some NPAs.                 |
+-------------+--------------------------+----------------------------+
| **3. NRUF   | Note 4                   | Not VoIP specific          |
| reporting** |                          |                            |
|             | Lack of understanding    | Only applies to offers     |
|             | and consistency in how   | where the VoIP provider    |
|             | VoIP numbers are         | obtains numbers by         |
|             | reported by carrier(s)   | purchase of service        |
|             |                          | (specifically, the VoIP    |
|             | Potential for a new NRUF | provider is not a          |
|             | category                 | LEC/CLEC)                  |
|             |                          |                            |
|             | Should VoIP providers be | VoIP providers that obtain |
|             | required to submit NRUF? | numbers from NANPA must    |
|             |                          | meet NRUF reporting rules. |
|             |                          | If VoIP provider purchases |
|             |                          | DID service from LEC, then |
|             |                          | LEC is responsible for     |
|             |                          | reporting numbers.         |
|             |                          |                            |
|             |                          | Clarify existing rules and |
|             |                          | guidelines for carriers if |
|             |                          | there is inconsistency.    |
|             |                          |                            |
|             |                          | What about other end users |
|             |                          | that utilize numerous      |
|             |                          | numbering resources like   |
|             |                          | large corporations? Why    |
|             |                          | not subject them to NRUF   |
|             |                          | reporting?                 |
|             |                          |                            |
|             |                          | Jurisdictional issue since |
|             |                          | non-carriers are not       |
|             |                          | subject to FCC Title II    |
|             |                          | jurisdiction.              |
+-------------+--------------------------+----------------------------+
| **4.**      | Note 4                   | Not VoIP specific.         |
| **I         |                          |                            |
| ntermediate | Potential for an         | Only applies to offers     |
| numbers**   | additional               | where the VoIP provider    |
|             | classification of        | obtains numbers by         |
|             | intermediate numbers     | purchase of service        |
|             |                          | (specifically, VoIP        |
|             |                          | provider is not a          |
|             |                          | LEC/CLEC)                  |
|             |                          |                            |
|             |                          | VoIP providers either      |
|             |                          | receive numbers from LECs  |
|             |                          | or from the NANPA if they  |
|             |                          | are also a LEC/CLEC. How   |
|             |                          | those numbers are reported |
|             |                          | are solely determined by   |
|             |                          | the SP. Any ambiguity      |
|             |                          | associated with the        |
|             |                          | "intermediate"             |
|             |                          | classification is not      |
|             |                          | unique to the provision of |
|             |                          | VoIP service.              |
+-------------+--------------------------+----------------------------+
| **5.**      | Note 5                   | Not VoIP specific.         |
| **NANP      |                          |                            |
| exhaust     | Demand for additional    | Only applies to offers     |
| forecasts** | VoIP numbers (2nd, 3rd,  | where the VoIP SP obtains  |
|             | etc.) may impact NANP    | numbers by purchase of     |
|             | exhaust                  | service (specifically, the |
|             |                          | VoIP provider is not a     |
|             |                          | LEC/CLEC)                  |
|             |                          |                            |
|             |                          | Projections of exhaust are |
|             |                          | influenced by a myriad of  |
|             |                          | factors. Exhaust           |
|             |                          | projections fluctuate      |
|             |                          | using existing formulas.   |
|             |                          | VoIP providers use of      |
|             |                          | telephone numbering        |
|             |                          | resources raise no new     |
|             |                          | issues with such           |
|             |                          | projections.               |
|             |                          |                            |
|             |                          | Still possible to project  |
|             |                          | exhaust as forecasting is  |
|             |                          | still possible even if     |
|             |                          | users are obtaining        |
|             |                          | numbers from distant rate  |
|             |                          | centers.                   |
|             |                          |                            |
|             |                          | Non-carrier VoIP providers |
|             |                          | must pay a SP for the      |
|             |                          | telecom service associated |
|             |                          | with the number.           |
|             |                          | Accordingly, there is a    |
|             |                          | built-in incentive to use  |
|             |                          | numbering resources        |
|             |                          | efficiently.               |
|             |                          |                            |
|             |                          | Numbers exist to be used   |
|             |                          | and should not be denied   |
|             |                          | on the basis of the        |
|             |                          | success of a new service.  |
|             |                          |                            |
|             |                          | VoIP could result in       |
|             |                          | reducing the need for      |
|             |                          | telephone numbers as       |
|             |                          | flexible IP-based systems  |
|             |                          | allow consumers to utilize |
|             |                          | fewer telephone numbers to |
|             |                          | support more devices.      |
|             |                          |                            |
|             |                          | Existing NRUF reporting    |
|             |                          | obligations allow the      |
|             |                          | industry and regulators to |
|             |                          | isolate and identify       |
|             |                          | potential exhaust concerns |
|             |                          | in advance.                |
+-------------+--------------------------+----------------------------+
| **6.**      | Issues are already       | Not VoIP specific in that  |
| **Number    | arising as a result of   | porting FX-like services   |
| po          | subscribers wishing to   | results in similar issues. |
| rtability** | port their numbers to    |                            |
|             | VoIP providers who are   | VoIP providers that are    |
|             | not listed as SPs in the | also CLECs or LECs will    |
|             | NPAC. In other cases     | adhere to number           |
|             | VoIP subscribers are     | portability rules within   |
|             | attempting to port       | the rate center where      |
|             | numbers across rate      | numbers are assigned. VoIP |
|             | centers.                 | providers that obtain      |
|             |                          | numbers from carriers rely |
|             |                          | on the underlying carrier  |
|             |                          | for number portability     |
|             |                          | capability and have no     |
|             |                          | impact on the ability of   |
|             |                          | the carrier to comply with |
|             |                          | number portability         |
|             |                          | obligations.               |
|             |                          |                            |
|             |                          | Seems to be a customer     |
|             |                          | education issue and not an |
|             |                          | INC concern.               |
+-------------+--------------------------+----------------------------+
| **7.**      | Note 6                   | Existing system addresses  |
| **Cost      |                          | any concern. Under current |
| recovery    | The cost impact of       | system, each carrier       |
| for number  | increased VoIP numbering | contributes to cost of     |
| admin       | demand leading to code   | number administration.     |
| istration** | relief needs to be       | When a carrier offers VoIP |
|             | addressed. This          | based service, it is       |
|             | situation is especially  | already contributing to    |
|             | important where the      | cost recovery to the       |
|             | demand stems from VoIP   | extent the service relies  |
|             | providers whose          | upon NANPA resources.      |
|             | customers may reside in  |                            |
|             | other locations than     | Non-carrier VoIP providers |
|             | where the relief is      | obtain numbers from SPs as |
|             | required.                | an end user through the    |
|             |                          | purchase of telecom        |
|             |                          | services. It is up to      |
|             |                          | carriers to pass through   |
|             |                          | the cost and therefore     |
|             |                          | proper cost recovery is    |
|             |                          | already accounted for on   |
|             |                          | the part of the            |
|             |                          | non-carrier VoIP provider. |
+-------------+--------------------------+----------------------------+
| **8.**      | Some VoIP providers have | Doesn't apply to all VoIP  |
| **911       | specifically noted to    | service offerings.         |
| service**   | their customers that     |                            |
|             | they do not support 911  | Not limited to VoIP        |
|             | service. This can be a   | services.                  |
|             | problem if the           |                            |
|             | subscriber has replaced  | Interim measures to        |
|             | their basic telephone    | provide 911 emergency      |
|             | service with VoIP.       | service have been          |
|             |                          | identified and implemented |
|             | In addition some VoIP    | and continue to evolve.    |
|             | providers say that their | \-- Additional details are |
|             | customers can travel     | provided in regard to the  |
|             | with their Internet      | following statement        |
|             | adaptor and obtain       | "Interim measures to       |
|             | service through any      | provide customer access to |
|             | broadband connection. It | emergency services have    |
|             | is not clear whether 911 | been identified and        |
|             | service would follow     | implemented". The          |
|             | them in this situation.  | implementation referred to |
|             |                          | utilizes call forwarding   |
|             |                          | to 10-digit public safety  |
|             |                          | answering point phone      |
|             |                          | lines. If the user has     |
|             |                          | moved without updating the |
|             |                          | record or is temporarily   |
|             |                          | using another location for |
|             |                          | service, the call          |
|             |                          | forwarding method will     |
|             |                          | route to the same 10-digit |
|             |                          | public safety answering    |
|             |                          | point phone lines as       |
|             |                          | assigned for the original  |
|             |                          | location, unless updated   |
|             |                          | by the VoIP provider's     |
|             |                          | customer.                  |
|             |                          |                            |
|             |                          | A number of other          |
|             |                          | regulatory bodies are      |
|             |                          | currently examining this   |
|             |                          | issue. Coordination among  |
|             |                          | various industry forums    |
|             |                          | and regulatory bodies is   |
|             |                          | necessary for INC          |
|             |                          | involvement.               |
|             |                          |                            |
|             |                          | The underlying 911 system  |
|             |                          | requires upgrades to       |
|             |                          | support certain VoIP       |
|             |                          | deployments. The selective |
|             |                          | routers that handle E911   |
|             |                          | calls, in certain          |
|             |                          | instances, may not be able |
|             |                          | to handle SS7 calls let    |
|             |                          | alone SIP. VoIP providers  |
|             |                          | are simply not capable of  |
|             |                          | resolving all the issues   |
|             |                          | associated with 911. See   |
|             |                          | "*A Report on Technical    |
|             |                          | and Operational Issues     |
|             |                          | Impacting The Provision of |
|             |                          | Wireless Enhanced 911      |
|             |                          | Services*" prepared for    |
|             |                          | the FCC by Dale N.         |
|             |                          | Hatfield and filed on      |
|             |                          | October 15, 2002           |
|             |                          | ("Hatfield Report").       |
+-------------+--------------------------+----------------------------+
| **9**.      | Is it valid to assign    | The INC should not rush to |
| **Potential | NANP numbers for         | judgement on VoIP, but     |
| regulatory  | non-PSTN use? (i.e.      | should monitor the         |
| issues**    | totally on the Internet, | development of VoIP in the |
|             | not interconnected with  | marketplace and stand      |
|             | the PSTN).               | ready to act if and when   |
|             |                          | specific VoIP              |
|             | What is the definition   | numbering-related issues   |
|             | of an end user with      | arise. As FCC and state    |
|             | respect to VoIP service? | regulators have            |
|             | Is it the VoIP provider  | recognized, premature      |
|             | or their customer?       | action in this area may    |
|             |                          | only have unintended       |
|             | Are VoIP calls to NANP   | consequences.              |
|             | numbers labeled as       |                            |
|             | telecommunications       | INC statements can have    |
|             | service or information   | ramifications in           |
|             | service?                 | regulatory proceedings and |
|             |                          | litigation throughout the  |
|             |                          | industry.                  |
|             |                          |                            |
|             |                          | The definition of an "end  |
|             |                          | user" is a policy question |
|             |                          | better left to regulatory  |
|             |                          | or legislative bodies.     |
|             |                          |                            |
|             |                          | The definition of VoIP     |
|             |                          | services as an             |
|             |                          | "information" or           |
|             |                          | "telecommunications"       |
|             |                          | service is also outside    |
|             |                          | the scope of INC's         |
|             |                          | purview.                   |
|             |                          |                            |
|             |                          | The regulatory             |
|             |                          | classification of VoIP     |
|             |                          | services is an open        |
|             |                          | question at the state and  |
|             |                          | federal level and INC must |
|             |                          | wait for determinations by |
|             |                          | federal and state          |
|             |                          | regulators to make policy  |
|             |                          | decisions.                 |
|             |                          |                            |
|             |                          | INC must stay true to its  |
|             |                          | mandate which is to        |
|             |                          | consider and resolve       |
|             |                          | technical numbering issues |
|             |                          | and not pre-judge          |
|             |                          | questions relating to the  |
|             |                          | regulation of VoIP.        |
+-------------+--------------------------+----------------------------+
| **10.**     | Should VoIP applications | Absent a better            |
| *           | be limited to geographic | explanation of what are    |
| *Geographic | numbers only?            | the specific concerns,     |
| and         |                          | this should be deleted.    |
| Non         | How will 800 or 900      |                            |
| -Geographic | numbers maintain their   |                            |
| NPAs**      | identity in a VoIP       |                            |
|             | environment?             |                            |
+-------------+--------------------------+----------------------------+
| **11.**     | Need to address sections | We recommend deletion as   |
| **Review    | 2.1, 2.4, 3.1, 3.5, 4.1, | this would only occur if   |
| COCAG and   | 4.1.1, and 4.2.1.        | we agree that there are    |
| identify    |                          | issues associated with     |
| changes**   |                          | VoIP. This should be the   |
|             |                          | subject of a separate      |
|             |                          | contribution if and when   |
|             |                          | this occurs.               |
+-------------+--------------------------+----------------------------+
| **12.**     | Today's NRO techniques   | Not VoIP specific.         |
| **New NRO   | are all based on numbers |                            |
| measures    | being used in the rate   | Doesn't apply to all VoIP  |
| may be      | centers where they are   | service offerings          |
| necessary** | originally assigned.     |                            |
|             | This may not be the case | End-users are economically |
|             | in the future and new    | encouraged to conserve     |
|             | NRO measures may be      | numbers by having to pay   |
|             | required to address this | for the services that use  |
|             | different situation.     | these numbers. Overall, it |
|             |                          | is difficult to predict if |
|             |                          | VoIP will increase or      |
|             |                          | decrease number usage.     |
|             |                          | Numbering resources are    |
|             |                          | meant to be used. VoIP     |
|             |                          | providers either obtain    |
|             |                          | numbers from LECs, or are  |
|             |                          | also LECs. Thus, VoIP      |
|             |                          | services are compatible    |
|             |                          | with all implemented forms |
|             |                          | of area code relief and    |
|             |                          | numbering resource         |
|             |                          | optimization.              |
+-------------+--------------------------+----------------------------+
| **13.**     | Should SPs verify that   | Not VoIP specific.         |
| **Use of    | their numbers are being  |                            |
| NANP        | used for customers in    | Only applies to VoIP       |
| numbers in  | their designated rate    | service offers that extend |
| countries   | center in North America? | the call beyond the rate   |
| outside     |                          | center                     |
| NANP        |                          |                            |
| region**    |                          | VoIP calls are delivered   |
|             |                          | to POI appropriate to the  |
|             |                          | rate center; extension of  |
|             |                          | calls to a user in another |
|             |                          | rate center is outside     |
|             |                          | scope of COCAG.            |
+-------------+--------------------------+----------------------------+

[Note 1]{.underline}:

COCAG paragraph 2.14 states: "It is assumed from a wireline perspective
that CO codes/blocks allocated to a wireline service provider are to be
utilized to provide service to a customer's premise physically located
in the same rate center that the CO codes/blocks are assigned.
Exceptions exist, for example tariffed services such as foreign exchange
service."

[Note 2]{.underline}:

The contribution proposed the addition of two new assumptions in certain
INC guidelines:

# 

# Assumption #1:

> CO codes/blocks allocated to a service provider are to be utilized to
> provide service either to a customer's premises physically located in
> the rate center where the CO codes/blocks are assigned or to a service
> provider's point of interface (POI) appropriate to the rate center
> where the CO codes/blocks are assigned.

# Assumption #2:

Since the ultimate delivery of any call to a CO code/block need not be
geographically identified, the extension of a call beyond the POI to a
final destination outside the rate center where the CO codes/blocks are
assigned is not in conflict with these guidelines.

[Note 3:]{.underline}

The need for NPA relief may be determined by demand generated by
subscribers who do not live in the area from where the numbers are
allocated. This may influence regulators to deny assignments to
subscribers located elsewhere. Should non-resident subscribers be
charged a premium for such number assignments. This may lead to new
criteria for number assignments or for requests for numbering resources
that are destined for use in a foreign location whether it be elsewhere
in the US or in another country.

The assignment of NANP numbers to non-US residents is already happening.
Is this a valid use of NANP numbers? Some international VoIP providers
already advertise to provide entities with virtual numbers in major
cities worldwide. (e.g. www.interlocal.com). Such assignments
demonstrate the value of a NANP number in the international arena.

Finally, the assignment of numbers from "foreign" could lead to
subscribers requiring a minimum of two numbers (one "local" and one
"foreign"). Should this practice become prevalent it will increase
number demand.

# [Note 4]{.underline}:

There is a concern regarding how numbers assigned to VoIP applications
are categorized and reported on NRUF. Given the minority paper submitted
at NANC by the California and Michigan commissions, their opinion is
that there are two types of intermediate numbers: -- those assigned to
customers by carriers and those assigned to customers by non-carrier
entities. Today the INC NRUF guidelines do not identify these as
separate categories. Who is responsible for reporting TNs used by
non-carrier entities? This is an administrative issue that needs
clarification in INC guidelines. The NANC has described and forwarded
this issue to the FCC.

[Note 5]{.underline}:

If many subscribers request multiple numbers in areas outside of their
home rate center and demand for multiple numbers takes off there will be
an impact on NANP Exhaust. In addition since the VoIP end user can be
located anywhere in the country ( or in the world) there is an unlimited
potential for an increased demand for numbers. It is almost impossible
to forecast such a demand. It is not prudent to wait for this demand
materialize before addressing the problem. This is an issue that
requires a proactive approach rather than a reactive one. The press is
already anticipating growth in the VoIP market so the industry should be
addressing this impending demand.[^1]

[Note 6:]{.underline}

Many VoIP providers classify themselves as Enhanced Service Providers
(ESPs) and they claim that they therefore do not have the same NANP
resource obligations as do traditional SPs.

[^1]: **Calling via Internet Has Suddenly Arrived,"** Paul Davidson*,
    USA Today,* July 7, 2003, pp. B-01

    Stating that "calling via the Internet has suddenly arrived, and
    it's poised to rock the telecom industry," this article in USA Today
    reports that technological advances and the growth of broadband have
    made calls on the Net or Internet-like private networks, roughly
    equivalent to traditional phones in terms of service. The article
    notes that the number of U.S. households making Internet calls with
    standard phones is expected to grow from about 100,000 today to 4
    million in 2007, according to In-Stat/MDR.