*North American Numbering Council*

Meeting Minutes

March 21-22, 2000 (draft
4-25-00)\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

*I. Time and Place of Meeting.* The North American Numbering Council
held a meeting commencing at 8:30 a.m., at the Federal Communications
Commission, 445 12^th^ Street, S.W., Room TW-C305, Washington, DC.

II. *List of Attendees.*

Voting Council Members:

1\. Beth Kistner ALTS

2\. Ed Gould AT&T

3\. Dan Hochvert Bell Atlantic

4\. Ron Binz CPI

5\. Lori Messing CTIA

6\. Norm Epstein GTE

7\. Peter Guggina MCI WorldCom

8\. Jo Anne Sanford NARUC

9\. Jack Goldberg NARUC

10\. Thomas Dunleavy NARUC

11\. Philip McClelland NASUCA

12\. Natalie Billingsley NASUCA

13\. Barbara Meisenheimer NASUCA

14\. Beth O'Donnell NCTA

15\. Dan Gonzalez Nextlink

16\. David Bench Nortel

17\. Carl Hansen VoiceStream

18\. Trent Boaldin OPASTCO

19\. Harold Salters PCIA

20\. Bill Adair SBC

21\. Ron Havens Sprint

22\. John Hoffman Sprint PCS

23\. Gerry Rosenblatt TIA

24\. Paul Hart USTA

Special Members (non-voting):

Maria Estefania ATIS

Leo Mevel CRTC

John Manning NANPA

Commission Employees:

Tejal Mehta, Designated Federal Officer (DFO)

Jeannie Grimes, Alternate DFO

Diane Griffin Harmon, Deputy Chief, Network Services Division, CCB

Cheryl Callahan, NSD, CCB

Aaron Goldberger, NSD, CCB

Barry Payne, NSD, CCB

Les Selzer, NSD, CCB

III. *Estimate of Public Attendance.* Approximately 38 members of the
     public attended the meeting as observers.

IV. *Documents Introduced*.

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(1) Agenda

(2) North American Numbering Plan Administration (NANPA) Report

(3) NANPA Oversight Working Group Report

(4) Draft letter to Chief, Common Carrier Bureau, re: NANPA Intellectual
    Property

(5) Numbering Resource Optimization Working Group Report

(6) Local Number Portability Administration (LNPA) Working Group Report

(7) Wireless Number Portability Subcommittee Update

(8) Wireless Number Portability Subcommittee Status Report

(9) Focal Communications and MCI WorldCom Unassigned Number Porting
    (UNP) Trial Report

(10) SBC Contribution re: UNP

(11) Industry Numbering Committee (INC) Report

(12) Cox Communications letter of February 18, 2000, re: UNP Policy
     Issues

(13) NBANC Report -- NANPA Fund Performance

(14) February 22-23, 2000 Meeting Minutes (draft)

(15) Table of NANC Projects, revised 3/22/2000

(16) San Diego County Board of Supervisors letter of February 18, 2000

> to NANC Chairman

*V. Summary of the Meeting.*

A.  ***Opening Remarks***. Chairman Hoffman provided opening remarks.
    The February 22-23, 2000 NANC meeting minutes were distributed by
    hard copy for review by the Council members for approval at the
    Wednesday, March 22, 2000 session.

The VoiceStream/Omnipoint merger has been approved. In light of the
merger, Carl Hansen, formerly of Omnipoint, will continue as the NANC
representative for VoiceStream. Mobility Canada advised that Darlene
Farrow would be its new NANC representative.

A copy of the San Diego County Board of Supervisors' letter of February
18^th^ to the NANC Chairman will be provided to the Council members
later in the day.

***B. FCC Staff Overview of the Numbering Resource Optimization (NRO)
Report and Order.*** On March 17, 2000, the Commission adopted the NRO
*Report and Order and Further Notice of Proposed Rulemaking* in CC
Docket 99-200. A Common Carrier Bureau press release was issued on March
17^th^ which described the actions taken by the Commission and outlined
the issues raised in the FNPRM. The *Report and Order* is expected to be
released by March 31^st^. Presentations by Network Services Division
staff members were provided regarding the adopted definitions; report
and utilization requirements; thousands block pooling (roll out,
selection of PA and current states with delegated authority), inventory
levels, reclamation of NXX codes, and sequential numbering assignment.
Diane Harmon, Deputy Chief, Network Services Division responded to
questions and provided clarification on the FCC's decision to play a
more active role in the selection of the thousands-block pooling
administrator through a competitive bid process. Since the *Report and
Order* had not yet been released, a limited discussion of the specifics
was allowed and only general guidance provided.

Bill Adair, SBC questioned whether the adopted pooling framework
addresses the state delegated authority. Ms. Harmon stated that states
with delegated authority will have 6 months to transition to comply with
the *Report and Order* requirements.

JoAnne Sanford, NARUC questioned whether states would have access to the
utilization data reported to the NANPA. Ms. Harmon stated that States
may have access to such data from either carriers, NANPA or both.

Norm Epstein, GTE questioned whether the PA IMG would be involved in the
evaluation of the bids under PA competitive bid process. Ms. Harmon
stated that the Bureau will continue to rely on NANC to assist with the
technical requirements. With respect to rollout, Philip McClelland,
NASUCA questioned whether pooling would be limited to the top 100 MSAs
or would it be allowed in other areas. Ms. Harmon stated pooling would
be required in LNP capable areas. Other areas may be considered, but
would not be a priority on the pooling schedule.

> With respect to assignment of initial codes and numbering activation,
> Greg Pattenaude, NARUC, questioned what the facilities readiness
> requirement applied. Ms. Harmon stated that carriers must demonstrate
> readiness within 60 days. In response to a question regarding
> reclamation, the NANPA will determine which resource should be
> reclaimed. Beth Kistner, ALTS questioned whether the determination of
> a carrier's need for blocks of numbers would be made by NANPA. Ms.
> Harmon stated that NANPA could question a carrier about a specific
> customer order.
>
> Chairman Hoffman ended the discussion at this point. The Order will be
> released and NANC will be in a better position by the April meeting to
> determine its next steps. It is not clear what the OGC and OMD are
> going to assume regarding the PA procurement process. There are
> questions regarding whether the NANPA and PA contracts should be
> co-terminus contracts. Chairman Hoffman asked Ms. Harmon whether the
> FCC is looking to combining the two for the next bid. Ms. Harmon
> stated that the intent is to keep the functions separate. Ms. Harmon
> stated that the nature of the task would be better defined going
> forward. The auditor selection will be addressed in the *Second Report
> and Order*. Carl Hansen commented that with the PA contract expected
> in the next 8 months with a mid-2001 roll out of pooling, there could
> be NANP administration turn over problems should another entity be
> selected at the end of the current NANPA term in November 2002.
>
> Ms. Harmon added that the Cost recovery WG should look at new
> framework on COCUS and modify its estimates accordingly.
>
> ***C. North American Numbering Plan Administration (NANPA) Report***.
> John Manning provided the update to the Council beginning with an
> update on the COCUS 2000 progress. As of March 15^th^ NANP had
> received 1095 COCUS submissions. Some of the problems encountered were
> missing or incorrect OCNs and, multiple submissions with different
> data reported from the same service provider. It appears that the
> larger the carrier or company, the fewer the utilization data
> received. By March 15^th^ if carriers do not have a 2000 COCUS on file
> with NANPA they will not receive numbering resources. CO Code
> administration procedures have been developed, as part of the CO code
> application review process, which requires verification of all CO code
> applications to check that the requesting entity has a COCUS
> submission on file with NANPA. In cases where there is no COCUS on
> file, the application for resources will be suspended and the service
> provider will be notified.
>
> [Michigan Update]{.underline}. At this time, the Michigan PSC has no
> jurisdiction over NPA relief. NANPA determined that the 810 NPA will
> exhaust by the 2Q2000. The FCC questioned whether NANPA and the
> industry alone were empowered to conduct area code relief planning
> without the benefit of public comment. It was determined that NPA
> relief in the 810 NPA must have regulatory approval. On March 9,
> NeuStar filed a petition with the FCC to facilitate the process of
> building a record with public comment on the 586 overlay/810 relief
> plan. The FCC will conduct the regulatory review and will soon place
> the petition on public notice with a comment cycle. In the meantime,
> NANPA has reviewed all the NXXs in the 810 NPA to determine if any of
> the unavailable codes could be made available for assignment. Over 22
> codes have been returned to NANPA for assignment, increasing the
> overall number available for assignment to 40.
>
> Tejal Mehta commented that the Common Carrier Bureau plans to act on
> the petition just as soon as possible once the comments are received.
> Area code relief planning is not something that the FCC would normally
> be involved in -- the FCC has appropriately, delegated that authority
> to the states because such decisions are better left to state
> government and its citizenry. Beth Kistner, ALTS asked what is being
> done in Michigan with respect to future area code relief matters? Ms.
> Mehta stated that the FCC has asked the Michigan PSC to speak to its
> legislature.
>
> [State Specific CO Code Administration Processes and
> Procedures]{.underline}. In response to an action item from the
> February 22-23 NANC meeting, NANPA prepared a list of all states where
> exceptions to the CO Code Administration guidelines were in effect.
> The NANPA was requested to indicate whether each exception was as a
> result of delegated authority or state order. The state exception
> report includes a description of measures in effect in the following
> jurisdictions: Arizona, California, Colorado, Connecticut, Florida,
> Illinois, Maine, Massachusetts, Minnesota, New Hampshire, New Jersey,
> New York, Ohio, Oregon, Tennessee, Texas and Washington.

Chairman Hoffman stated that the report provided was responsive to the
action item and suggested that the NANPA Oversight Working Group work
through the report, and advise the NANPA if it identifies problems. Beth
Kistner suggested that the NANPA Oversight WG take it one step further
and identify where NANPA has been directed and acted outside the
guidelines, and then go through this report and determine the deviations
from policy that need to be addressed. Norm Epstein stated that this
report is a catch up on what has already happened. John Manning added
that because there are constant changes, the report provided already
needs to be updated.

> With respect to the CO code returns taking place in the BellSouth
> region, Mr. Manning advised that NANPA is contacting service providers
> to verify the list of codes assigned
>
> \-- the ultimate goal is to return those codes to the pool by
> mid-April.
>
> Beth Kistner, noting that the NRO R&O does not have fill rate
> requirements, questioned when fill rates are established what would
> happen to states which have state specific fill rates in place. Tejal
> Mehta stated that those states would be required to conform to the
> rates established by the FCC in a subsequent R&O.
>
> In response to a question regarding the situation in Arizona, where
> the Arizona Commerce Commission (ACC) has requested review and
> approval of all large quantity code (5 or more in a single
> submission), Ms. Mehta stated that theACC and the Common Carrier
> Bureau are working on this issue.
>
> Chairman Hoffman requested that NeuStar provide a copy to the Council
> of any public statement or news release it may develop in reaction to
> the FCC *Report and Order*.
>
> ***D. North American Numbering Plan Administration (NANPA) Oversight
> Working Group***. Pat Caldwell, Co-Chair, provided the report to the
> Council. In light of the adoption of the NRO R&O, which does not
> address the audit issue, a question was raised whether the WG should
> continue on its current schedule to develop the auditor requirements
> document. Diane Harmon stated that the WG should stay on its proposed
> schedule. Mr. Caldwell reported that the WG had met with three
> auditing firms, KPMG, Deloitte & Touche and PricewaterhouseCoopers, to
> assist in the development of the technical aspects of the auditor
> requirements document. Each firm provided contributions. Going
> forward, several meetings are scheduled to finalize the requirements
> with a completed Audit Requirements Document to be delivered to NANC
> at the June 20-21 meeting. Thereafter, the Audit RD will be forwarded
> to the Chief, CCB for placement on public notice to solicit questions
> from potential bidders. Unless directed otherwise, it is estimated
> that August 15 will be the closing date for bid responses. A schedule
> has been established for the review and evaluation process. *See*
> handout for further details.
>
> [NANPA Performance Review]{.underline}. The WG has received 72 survey
> responses of which 15 were from state public utility commissions. The
> draft baseline report will be provided to NANPA in late April for its
> preview; a preview has been scheduled with the FCC staff for the week
> of May 15^th^. The finalized report will be presented to the Council
> at the May 23-24 meeting.
>
> [NANPA Intellectual Property Rights]{.underline}. Hank Hultquist,
> Chair, Legal Expertise Working Group (LEWG) provided a read out on the
> IPR issue and presented a draft letter to the Chief, CCB for NANC
> review. The letter seeks clarification on what intellectual property
> and associated hardware from the current NANPA would transfer to a
> successor NANPA. Because of the timing of the development of the next
> NANPA Requirements document, this issue needs to be resolved by
> September 2000. Council members were asked to review the letter
> overnight. Chairman Hoffman added that the issue here is, in the case
> of a change in administration to a new NANPA, who would own the
> property. The contract says it belongs to the FCC -- does that include
> any off the shelf software, and would it become the property of the
> next NANPA? NANC has been unable to resolve this issue with NANPA and
> is now seeking FCC guidance.
>
> With regard to how to handle future bid processes with less
> non-disclosure, Chairman Hoffman stated that he hoped the bid process
> going would not require non-disclosure agreements (NDAs). Hank
> Hultquist, LEWG, spoke with the OGC staff regarding the NDAs and the
> NeuStar concern was that existing bid information may later be
> discoverable from the FCC. Chairman Hoffman further added that NANC
> needs to understand the division of responsibility of the work
> assignment between the Office of the Managing Director (OMD) and NANC.
> All signatories to the NDAs should continue to hold bid information as
> confidential.
>
> John Manning stated that NeuStar counsel will send a letter to all NDA
> signatories to reclaim the information provided during the NANC and
> IMG work effort. Peter Guggina noted that although some elements are
> proprietary, not all the information was -- much of the information
> was provided in response to a non-proprietary bid requirements.
>
> ***E. Numbering Resource Optimization (NRO) Working Group***. Beth
> O'Donnell, Co-Chair, provided the report to the Council. As part of
> its ongoing monitoring responsibility, the WG provided a report out on
> number pooling trials. The handout listed the activities in Illinois,
> California, New Hampshire, Maine, Texas, New York, Florida,
> Massachusetts, Ohio, Connecticut and Wisconsin. Ms. O'Donnell stated
> that 12 states have petitions for pooling trials pending before the
> FCC. States with existing authority may proceed with their trials
> until the national pooling roll out commences.

Ms. O'Donnell stated that in light of the NRO R&O, the NRO WG will
revisit the COCUS requirements, and adjust its work accordingly. The WG
finalized components of the forecast algorithm. Utilization data will be
used for two possible reasonableness checks of forecast data.
Additionally, the WG is working on developing the components of a
mechanical interface. Carl Hansen asked whether the electronic file
transfer (EFT) security issues have been addressed with NANPA. Mike
Whaley responded that the WG has talked to NeuStar about EFT security.

The WG has informed the Cost Recovery Working Group (CRWG) that it
cannot provide enough information to form the basis of any cost project
for purposes of the NBANC calculations.

Ms. O'Donnell added that the pooling trial matrices will be updated and
will be posted to the NANC Chair web page (NANC-Chair.org) as well as
under the NRO document section of the INC (ATIS.org) web site.

Lori Messing, CTIA questioned whether the NRO WG meeting minutes on the
ATIS site discuss the methodology of the information check to be
performed. Ms. O'Donnell stated that this is red flag test to check for
information -- less formal than an audit. Mike Whaley added that it is
an opportunity to look for the reasonableness of information. Carl
Hansen stated that there could be numerous red flags. Chairman Hoffman
added that as he understood it, that this is just a sanity check and not
an audit point. Mr. Whaley commented that this is a tool for NANPA to
use, and that the carriers know what the parameters are.

Greg Pattenaude, New York Public Service Commission, stated that New
York now has a state wide pooling schedule which includes every NPA (and
the dates for implementation by NPA) until August 2001.

Co-chair Mike Whaley announced after 2 years as co-chair he will be
stepping down after the April NANC meeting. Mr. Whaley stated that there
is a continuing need for cooperation and contributions to drive the
process to provide information to the NANC and FCC.

***F. Local Number Portability Administration (LNPA) Working Group
Report***. Shelly Shaw, Co-Chair, provided the report to the Council on
the wireline/wireless integration report, NPAC release status, problem
identification management (PIM) and slow horse. Anna Miller provided a
read out of the Wireless Number Portability Subcommittee (WNP SC)
report.

[Wireless Number Portability Subcommittee]{.underline}. Ms. Miller
provided an update on the NPAC testing schedule; WWIT 3^rd^ Report open
issues; wireless number portability report. NeuStar gave a presentation
on the testing schedule for 2000 through 2002 and identified a potential
resource problem for 2001 because Release 4.0, wireless turn up testing,
and regression testing on Release 3.0 occur during the same period.

[3^rd^ Wireline Wireless Integration Report]{.underline}. The SC has
concluded that there is no wireless slamming issue for prepaid porting
given the current validation process required by the old service
provider to confirm the port request.

[Wireless Number Portability Report]{.underline}. The SC has begun
review of the first draft of the WNP report; the draft has been edited
and reformatted to focus on implementation requirements.

Additionally, a CTIA industry forum reviewed and approved the wireless
inter-carrier communications report. The inter-carrier test plan has
completed a major portion of the test scripts and is on schedule for
completion of the test plan by June 30, 2000.

[Wireline/Wireless Integration Report]{.underline}. The WG is continuing
to work on shortening the porting interval and will review the cost and
time associated with the redesign of the existing processes used by the
wireline industry. With respect to E911 issues, the three alternatives
for an early activation by the wireless industry are being examined. The
assistance of the National Emergency Number Association (NENA) has been
solicited on this matter - NENA has been invited to participate in the
April WG meeting.

[NPAC/SMS Release Status]{.underline}. Release 3.0 development is on
schedule and the project plan for region by region roll out and service
provider testing has been updated. A copy of this project plan is
available on the NPAC.com web site. The LLCs voted to request the
Statement of Work (SOW) from NeuStar for the Release 4.0 functionality.

[Problem Identification Management (PIM)]{.underline}. There are two
open issues - PIM 0001 and PIM 0005. PIM 0001 has to do with multiple
service providers -- the WG and OPSWest are working together with to
resolve this outstanding item. PIM 0005 was opened 2 months ago.

[Slow Horse Update]{.underline}. The subcommittee (SC) is working on the
availability requirement which is expected to be completed in April. The
SC is waiting on LLC action to request SOW 17 (NPAC performance data),
in order to complete the performance requirement, which may be completed
by May.

***G. Cost Recovery Working Group Report***. Anne La Lena, Co-chair
stated that there was no formal report to provide to the Council at this
time, and added that the CRWG had been waiting for a response the NRO WG
to its memorandum regarding COCUS development costs for consideration in
the adjustment to the NBANC factor.

***F. Unassigned Number Porting (UNP)Trial Report.*** Dan Meldazis,
Focal Communications, and Jim Joerger, MCI Worldcom presented the report
to the Council. Two handouts were provided \-- an overview and a
detailed report. Mr. Joerger stated that two scenarios were tested: (1)
specific customer requests to port unassigned numbers from one carrier
to another, and (2) establishing carrier footprints with small
quantities of numbers. The scenarios were tested in the Chicago, New
York and Los Angeles LATAs. Mr. Joerger opined that UNP moves spare
numbers between carriers, and benefits competition and conservation. UNP
may be used for specific customer requests or establish rate area
footprint. This description of UNP places a limit of 25 numbers per
request. UNP is not intended for inventory building.

Mr. Joerger stated that the key goals of the trial were to demonstrate
that the current local service request (LSR) process can handle UNP;
determine whether a third party administrator is needed; ensure that LNP
supports porting spare numbers; show that systems can reserve and donate
numbers, and test the customer request and carrier footprint scenarios.
The trial determined that LNP systems can support UNP ports; and if a
carrier can mark working numbers as ported out, it can mark numbers as
UNP-ported out.

Mr. Joerger stated that LERG information establishes who the potential
donor is for the number requested. The framework for UNP does not
require the use of NANP administration. The trial suggests that UNP and
1K pooling could co-exist. Mr. Joerger further stated that UNP is a
utility that allows a customer to pick a service provider and not have
to shop for a specific number. Cooperation between service providers is
key towards making UNP a viable option.

[SBC UNP Contribution]{.underline}. Bill Adair, SBC provided a handout
entitled "UNP won't work using today's LNP systems and procedures." SBC
opposes UNP and is concerned that absent restrictions, UNP could result
in a free-for-all grab for numbers. In a pooling environment, service
provider inventories are significantly reduced and therefore the impact
of UNP on the remaining inventory could be huge. Service providers would
be compelled to augment their forecasts to accommodate unanticipated
inventory drain due to UNP. Despite claims to the contrary, UNP will be
used to export large quantities of sequential numbers from service
provider inventories. UNP is in direct conflict with efficient data
representation (EDR) contained in LNP software, Release 3.0. UNP would
require modifications to the service order, OSS and number inventory
systems. The current service provider systems are designed to handle
huge volumes of port transactions, efficiently with minimal human
intervention to prevent errors.

Barbara Meisenheimer, NASUCA noted that such a small block (quantity of
25) may not contain very attractive numbers. Dan Hochvert agreed with
SBC on some points, and added that if the volume is kept low and it
works fine. However, with a per entity (25) limit times the number of
CLECs, it could become unmanageable.

Shawn Murphy added that AT&T supports UNP in the context of a low volume
footprint request. AT&T has provided a UNP contribution to INC. Peter
Guggina noted that Jim Joeger proposed a UNP ad hoc meeting be held
within NANC or outside, if there is interest. This would be an
opportunity to flesh out some of the concerns raised and take Bill
Adair's input and see what it would take to find a workable solution.
Does NANC have an interest in doing this? Chairman Hoffman requested the
Council to hold off on the assignment decision until after the INC
report is delivered. Tom Dunleavy stated that the New York PSC has
supported the use of UNP in conjunction with pooling and added that the
Focal/MCI WorldCom joint trial effort is appreciated. Chairman Hoffman
added that UNP has the potential to unlock numbers in contaminated
blocks that can not be donated to the pool.

***I. Industry Numbering Committee (INC) Report.*** Shawn Murphy, INC
Moderator provided the report to the Council. Mr. Murphy announced Norm
Epstein's selection as the INC Assistant Moderator. The INC has agreed
to develop a document which would describe, based on a common
understanding and through industry consensus, a definition and
assumptions for UNP. To date, INC has received contributions from MCI,
SBC, AT&T and GTE. Norm Epstein reminded the Council that INC is driven
by contributions. At this point, the INC UNP report is only outlined \--
substantial information will be sifted into the report. The INC intends
to highlight policy issues as they come up and bring them to the
Council.

Chairman Hoffman noted that the Council is looking for the right forum
to work this issue; SBC raises some good issues, today's systems will
require change. Is this a 4 to 6 months or 4 to 6 years process? There
is industry resistance associated with the system(s) modification costs.
There are many questions to be answered, such as- what are the benefits
of UNP, and does mandatory 10-digit dialing free up more numbers.

Norm Epstein stated that interim meetings have been requested at INC for
this particular topic. Bill Adair reiterated that UNP needs to be
defined. Beth Kistner stated that the technical investigation has been
done which demonstrates there is a purpose for UNP.

Chairman Hoffman questioned what is the purpose, precisely? Ms. Kistner
added that the Cox memorandum states that there is a need for a
fundamental policy determination.

Paul Hart responded, noting that INC has a lot to do with the pooling
guidelines. Two carriers have proved that UNP works in this trial, and
the FCC has said it may be used on a voluntary basis. Mr. Hart opined
that the UNP structure should remain voluntarily to avoid situations
where carriers are yielding numbers against their will. Before policy
decisions can be made, the Council must understand the technical
concerns. Chairman Hoffman agreed that the Council needs to look at this
first at a higher level and gather the facts and to present to the FCC.

Beth O'Donnell stated that the Cox memorandum (request) is based on a
regulatory order that all entities have to play fair through competition
and consumer choice. It should also be noted that portability volumes
have not been what were expected.

Shawn Murphy added that AT&T has conducted internal trials. As far as
assignment to INC is concerned, INC needs a NANC directive and it will
be responsive to it.

Norm Epstein added that there were questions raised by the AT&T
contribution document and that it is important to put those points (and
others) down in writing, and not to work one issue in isolation. Peter
Guggina noted that some entities do not want to work on the UNP process.
There are different flavors of UNP and it needs to be defined. Last year
NANC looked at this and progress has been limited; there are policy and
operational aspects that need to be fleshed out.

Chairman Hoffman agreed that NANC should keep pushing INC forward on the
definitional issues in April or May to see what is going on. MCI is
willing to host an ad hoc meeting on UNP issues. Chairman Hoffman also
complimented Focal and MCI WorldCom on its initiative and noted it was a
great beginning with the technical trial. Putting aside the definitional
issue for a moment, the cost of implementation should be compared using
a cost benefit analysis.

Trent Boaldin, OPASTCO, opposed the use of UNP because it is fraught
with potential abuse, and further stated, that if NANC is to investigate
it further, it is important to understand what it is and come to a
common understanding, and not to prejudge the outcome. Chairman Hoffman
commented that with respect to potential abuse, that perhaps UNP needs
an administrator to avoid abuse. It is important to conduct a
fact-finding in order to make a determination.

Dave Bench, Nortel Networks urged Focal and MCI WorldCom to bring their
contribution to the INC. Jack Goldberg commented that Connecticut has
turned down requests to use UNP due to a lack of information and
suggested NANC investigate the potential. Bill Adair added that the INC
report should also focus on the costs and benefits of UNP. The matter of
whether UNP is competitive access to numbers or is it optimization
should be determined before moving ahead on this issue.

Chairman Hoffman stated and the Council agreed that INC is the right
entity to come up with the UNP definition, and that the MCI WorldCom ad
hoc effort will generate some movement on this issue. The Council
supported working this issue on both tracks and that the two efforts
should be conducted in parallel.

Chairman Hoffman stated that the Assumptions IMG would present a draft
report at the April meeting. Norm Epstein will provide an overview of
the expansion effort and options and will discuss the transition
triggers. The report will appear early on next month's agenda. Chairman
Hoffman noted that when reading the IMG's meeting notes -- breaking
those issues down into sub-blocks and listing items, was very helpful.
If the MCI WorldCom, in its approach to the UNP ad hoc effort, could go
at it in the same way, it would be very helpful \-- then make the cost
judgments. Conference call meeting notes should be posted on the NANC
Chair-org. web site.

*[INC Report continued]{.underline}*. Mr. Murphy stated that the 1K
pooling report has incorporated the NANC recommendation for sequential
number reporting. Chairman Hoffman asked whether the Council needed to
provide a directive to INC to revise 1K guidelines. Mr. Murphy stated
that the INC would like a written directive from the Council.

Peter Guggina added that with the change to a competitive bid process,
NANC would have to modify the requirements and guidelines to reflect two
entities, a NANPA and a Pooling Administrator (PA). Tony Pupek, USTA
stated that INC needs a directive to change the flow from the current
direction (sole source/NANPA) to a separate entity as the PA.

Chairman Hoffman and Peter Guggina will draft a letter to INC moderator
requesting modifications to the INC pooling guidelines based on the FCC
order. Mr. Murphy stated that the INC guidelines were scheduled for
re-release on April 10-14 but will be stayed based on FCC NRO *Report
and Order* decision to go to a competitive bid process.

***J. North American Billing and Collection (NBANC) Report.*** John
Ricker, Chief, Executive Officer, NBANC provided the report to the
Council. With respect to changes to the contribution factor, NBANC will
file a revised factor with the FCC by May in anticipation of the COCUS
replacement. However, NBANC will need direction from the NANC by the end
of April in order to develop, in early May, the numerator and
denominator to be used by NBANC. The Cost Recovery Working Group will
present a recommendation to the NANC at the April meeting. NBANC is
paying attention to the FCC order and it will await the CRWG
recommendation and the NANC concurrence.

[NANPA Fund Peformance Status Report and Fund Projection]{.underline}.
The current fund balance is \$437K; projected receivables are \$16.1
million (for year 3). Payments to NeuStar to date total \$4.28 million
for year 2. Payments to NECA in year 2 totaled \$257K; Board expense for
year 2 total \$14,830 and payment to an external auditor total \$19,500.
With respect to the 2000 funding process, 4,406 bills were rendered on
February 23, 2000. As of March 17^th^, \$2.7 million has been received
due to a majority of carriers paying their annual contribution in full.

# **Wednesday, March 22, 2000**

The February 22-23 meeting minutes were approved with minor
modifications. The draft letter prepared by the Legal Expertise Working
Group, regarding the intellectual property rights issue was approved by
the Council and will be sent to the Chief, Common Carrier Bureau.

***K. Steering Group (SG) Report.*** Jack Goldberg, NARUC was selected
as the SG Co-Chair. Norm Epstein provided a quick review of changes to
the NANC Table of NANC Projects matrix based on the actions taken by the
Council on March 21. The revised table will be posted to the NANC
Chair.org website.

***L. Number Pooling Issue Management Group (IMG)***. Peter Guggina, IMG
Chair stated that the IMG is to be tasked with coming up with a
technical section for the interface to be added to the PA Requirements
document. However, the IMG needs instruction from the FCC and sample RFP
for the format. Tejal Mehta stated that the guidance would be provided.

Chairman Hoffman stated that it would be beneficial to use the PA IMG
same staff and noted that the IMG has done a remarkable job on this
issue over the last 15 months. Peter Guggina stated that there needs to
be a separate discussion with the NANPA concerning the PA interface. Ed
Gould commented that the interface is a key issue, which will require
NeuStar's cooperation to develop. Mr. Guggina added that since NeuStar
will be one of the bidders, we have to be careful. Because this is such
a sensitive situation, Chairman Hoffman suggested all face to face
meetings and conference calls should include staff from the FCC Office
of General Council (OGC) and Office of the Managing Director (OMD), in
addition the Legal Expertise WG should also be included in such
discussions. Tejal Mehta stated that the procedural next steps and
process will be discussed with OGC and guidance will be provided to the
Council as soon as possible.

The following is a list of the current participants on the PA IMG; the
IMG is open to other participants and others are encouraged to join:
Norm Epstein, Jim Castagna, Pat Caldwell, Paul Lagatutta, Karen
Mulberry, Gilbert Orozco, Tony Pupek, Shawn Murphy, Ed Gould, Jim
Joerger and Pam Connell.

Peter Guggina stated that the IMG will need a face to face meeting to
really dig into the

project elements and get organized and then go to work in view of the
FCC deadline. Carl Hansen questioned whether there is any reason that
potential bidders can not be part of the process. Mr. Guggina suggested
that perhaps a potential bidders conference could be held, but the
Council would need to first to confer with the FCC on this matter. Mr.
Hansen stated that NANC must make that all bidders understand the
requirements in the development of their bid.

Chairman Hoffman stated that with regard to the procurement process,
comments should be obtained on the requirements before the bidding
process begins. The Council should confer with NeuStar for only the
interfaces so as not to give NeuStar a leg up on any other bidders.
Diane Harmon stated that OGC's direction has been that any discussion
should be open to all bidders. Dan Hochvert stated that the interface
discussions should be open as well.

Chairman Hoffman stated that the agenda item regarding inventories in a
jeopardy situation discussion would be moved to the April meeting.

With respect to a question raised concerning the NRO R&O directive that
NANC work on the definitions in the secondary categories, Chairman
Hoffman deferred discussion of the assignment until after release of the
Report and Order. Norm Epstein noted that the definitions originally
came from INC and that INC should be included in the process.

***M. New Issue Management Groups -- Unified Messaging.*** Chairman
Hoffman opened the discussion on whether or not NANC should come up with
proposed comments on the issue of unified messaging. The Chairman
suggested forming a small group to determine the scope of the assignment
of the issue to a proposed IMG.

Beth Kistner opined that there is complete consensus to look at unified
messaging and charging for numbers. Paul Hart stated that these are
separate issues and the group should bound the areas of discussion.
Chairman Hoffman opened the discussion up on the matter of charging for
telephone numbers and unified messaging. The fundamental problem is
getting at NANP exhaust. Maybe the problem is labeling -- the market
place and unconventional use of numbers that consume the resource at
alarming rates. There are a host of solutions to approach this matter
\-- one possibility is charging for numbers, there are other ways to get
at the problem.

Phil McClelland commented that the NANC needs to think more about the
real issue. There are going to be other non-traditional uses that we
know very little about. Charging for numbers is a related issue. A group
needs to define the problem and issue before moving too quickly and be
careful not to define it too narrowly.

Dan Gonos, Winstar, stated that WinStar brought the issue to INC and
co-authored the white paper presented to NANC. Mr. Gonos stated that
geographic numbers are being used for non-geographic services, and
questioned whether it is fair to risk exhausting an NPA for
non-residents.

Chairman Hoffman stated that companies would file comments on their
individual position on this issue, but that perhaps NANC should address
it at a higher policy level and consider the premature exhaust of the
NANP. The ad hoc group of 4 or 5 people to look at the order in terms of
the comments, should come back to NANC with a determination whether or
not it is it worth NANC's effort to provide comment on the matter.

Beth O'Donnell stated that linking behavior with availability was noted
by Commissioner Fruchtgott-Roth during the open meeting. What price
changes behavior? Chairman Hoffman commented that the market should
decide these issues. Ron Havens, Sprint, stated that there should be
incentives for use of the resource without creating barriers to
competition; however, numbers can be misused -- the industry has done
that with vanity numbers.

Chairman Hoffman raised a question regarding reclamation -- in this
scenario should the NANP reclaim unused numbers; can numbers be
reclaimed if service providers have paid for them? Bill Adair offered
that this is a definitional issue and suggested that the Council not
prejudge or preordain what it should be. Chairman Hoffman asked whether
NANC should file comments on the topic and noted that there is at least
two weeks before the *Report and Order* is released.

Trent Boaldin stated his support for defining issues -- however, the
group should not overly concentrate on efficient use and allocation and
forget about availability \-- the objective here should not be to stifle
creativity. Chairman Hoffman proposed and the Council concurred, that
Phil McClelland would informally chair the discussion group to answer 2
questions; NANC to file questions to the FCC order; if so, whether it
should form an IMG to draft those comments.

Dave Bench asked if as NANC are we working INC's issue on the unified
messaging. Mr. Bench also stated that the two contributions presented to
INC will be worked further at the next workshop. Chairman Hoffman stated
that NANC should look at this issue. Mr. Bench further added that with
respect to non-geographic numbers, the INC will define what are
traditional uses.

Beth O'Donnell commented that NANC has a basic policy question that
hangs the INC work up -- that is, can you label services differently.
Peter Guggina suggested that another element should be included -- the
cost of numbering/charging -- what does it cost to turn up those
numbers; what is the cost to service providers and end users to turn up
the services.

It was agreed that Phil McClelland would head an informal group with Dan
Hochvert, Dan Gonos, Beth Kistner, Harold Salters and Natalie
Billingsley. The group will wait to see the specifics on unified
messaging and charging for numbers in the FCC order, then will email the
full Council to check for further participation interest. The questions
to be addressed are as follows: Should NANC file comments with the FCC;
what should the assignment to the IMG be?

[Consideration of Rate Center Consolidation (RCC) IMG]{.underline}.
Chairman Hoffman raised this issue as a result of his discussion with
the Chief, CCB on New York PSC split and the reversal of NANC's
recommendation. Is there a conflict in the Bureau's policy to encourage
rate center consolidation (RCC) and the NANC/INC policy that splits not
be along rate center boundaries? The consensus of the some NANC members
is that this is not an IMG level issue at this time. We should be
looking at the splits on a case by case basis and determine whether or
not a specific case has a *de minimus* impact. However, given all the
other things on NANC plate, now is not the time for an IMG to study this
matter. NANC will continue to look at this issue in the future on a case
by case basis.

Tom Dunleavy stated that the New York Commission recently issued an
order regarding wide area rate centers, and the industry consensus was
to defer rate center consolidation at this time and implement
thousands-block pooling. Jack Goldberg stated that it took the
Connecticut Commission and industry two years to complete its rate
center consolidation. Natalie Billingsley stated that there are over 800
rate centers in California; consolidation would require intrastate rate
balancing. California is not eager to undergo rate center consolidation
due to revenue neutrality issues. Bill Adair added that for some areas,
rate center consolidation is very simple. It made a substantial impact
in Texas and many codes were returned as a result. Mr. Adair stated that
it is dramatically more complicated in California.

Lori Messing, CTIA agreed that to form an IMG would be premature.
Chairman Hoffman requested that the New York DPS e-mail a copy of its
order on wide area rate centers for circulation to the full NANC.
Natalie Billingsley suggested that if a NANC IMG looks at this issue in
the future that it keep in mind what happened in Minnesota.

N.  ***Other Business.*** There was discussion whether there was a need
    for 1.5 day meeting in April. Evaluate the need for a 1.5 day
    meeting.

Diane Harmon announced that the current DFO, Tejal Mehta would be
leaving the Common Carrier Bureau to work for the FCC's new Enforcement
Bureau. Ms. Mehta served as senior attorney on the NRO *Report and
Order*. Ms. Harmon added that she would not have been able to shepherd
this project without her assistance. Tejal Mehta commented that she had
attended many NANC meetings over the past year and thanked the Council
for its tremendous work, and also remarked that the Commission
appreciates and relies on the NANC recommendations.

Ms. Harmon stated that the Bureau has appointed Cheryl Callahan,
formerly with the New York Public Service Commission, as the new DFO.
Ms. Callahan commented, that having arrived at the FCC several months
ago with an extensive background on numbering that she is looking
forward to working with the Council.

***O. Next Meeting:*** April 25-26, 2000.

VII. ***Action Items and Decisions Reached.***

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1.  [NANPA Oversight Working Group]{.underline}. The WG will go through
    the NANPA state activity report to identify the actual deviations
    from the INC guidelines. Deviations will be addressed directly with
    NANPA or brought back to NANC. Co-Chair Pat Caldwell was reaffirmed
    for a second term.

2.  [Auditor Requirements Document]{.underline}. The NANPA OS WG is to
    stay on the current schedule to submit the Audit Requirements
    document to NANC at the June 20-21 meeting.

3.  Principals from NANC will consult with the FCC Office of General
    Counsel (OGC) and Office of the Managing Director (OMD) to determine
    status of present NDAs. NeuStar will request return of information
    it provided for the first evaluation sequence.

4.  [Local Number Portability Administration Working Group]{.underline}.
    NANC affirmed the WG's selection of Brian Egbert, Sprint PCS, as its
    wireless co-chair.

5.  [Industry Numbering Committee (INC) Report]{.underline}. INC will
    report to NANC at the April and May meetings the status of its UNP
    activities development. MCIWorldCom will host an ad hoc meeting to
    work UNP issues in parallel. Both will report progress to NANC on a
    monthly basis. NANC expects to make a decision in May on how to view
    UNP progress and determine next steps. Peter Guggina and Chairman
    Hoffman will draft a letter to the INC Moderator, directing INC to
    proceed with changes to PA guidelines in accordance with FCC order.

6.  [1K Pooling Issue Management Group (IMG)]{.underline}. The IMG will
    have meetings with NeuStar regarding the PA/NANPA/NPAC interfaces;
    IMG will need OGC guidance on how this activity is to be conducted.
    The IMG will require ongoing process guidance in its activities.

7.  Phil McClelland will form an informal group to consider whether NANC
    should file an *ex parte* in response to the *Report and Order and
    Further Notice of Proposed Rulemaking* question regarding charging
    for numbers. If so, should NANC form an IMG to draft a response and
    what should those comments cover.