**North American Numbering Council**

**Meeting Minutes**

August 19-20, 1998

**I. Time, Date and Place of Meeting:** The North American Numbering
Council held a meeting, commencing at 8:30 a.m., at the Federal
Communications Commission, 1919 M St., NW, Room 856, Washington, DC.

**II. List of Attendees:**

A. [Council Members]{.underline}

[Voting Members]{.underline} [Organization]{.underline}

1\. Emily Williams ALTS

2\. Colette Capretz American Mobile Satellite

3\. Ed Gould AT&T Corp.

4\. Dan Hochvert Bell Atlantic

5\. Ronald Binz Competition Policy Institute

6\. Lori Messing CTIA

7\. Alan Hasselwander Frontier

8\. Bernard Harris/Ted Noeker GTE

9\. Peter Guggina MCI

10\. Gerry P. Thompson Mobility Canada

11\. Bruce Armstrong NARUC

12\. Jo Anne Sanford NARUC

13\. Amy Putnam NARUC

14\. Beth O'Donnell NCTA

15\. Bob Montgomery Nextel Communications, Inc.

16\. Elizabeth Lynch NEXTLINK

17\. Joe Kingrey NORTEL

18\. Jerry O\'Brien Omnipoint

19\. Trent Boaldin OPASTCO

20\. Cathy Handley PCIA

21\. Mike Bennett SBC Communications, Inc.

22\. Loren Sprouse Sprint Corp

23\. Diane Little Sprint SpectrumPCS

24\. Gerry Rosenblatt TIA

25\. Paul Hart USTA

[Special Members (non-voting)]{.underline}:

John Manning ATIS

Ron Conners NANPA

B. [Commission Employees]{.underline}

Kris Monteith, Designated Federal Official (DFO)

Jeannie Grimes, NSD, CCB

Jared Carlson, NSD, CCB

Les Selzer, NSD, CCB

Patrick Forster, NSD, CCB

Greg Cooke, NSD, CCB

**III. Estimated Public Attendance:** Approximately 24 members of the
public attended the meeting as observers.

**IV. Documents Introduced:** Each member received the following
handouts:

\(1\) Lockheed Martin-IMS Tutorial, "What are the impacts to Law
Enforcement?"

\(2\) Industry Numbering Council (INC) Report

\(3\) NANP Letter of July 30, 1998 to W. Adair, SBC, Re: New NPA Code
for 314

Geographic Split

\(4\) Local Number Portability Administration Working Group Report

\(5\) Wireline Wireless Integration Subcommittee Report

\(6\) OBF Letter of July 29, 1998 Re: OBF Issue 1182/BLG "Unique
Identifier for Each

Industry Segment

\(7\) Cost Recovery Working Group Report

\(8\) NANPA Fund Performance Status Report & Funds Projection

\(9\) Numbering Resource Optimization Working Group Report

\(10\) AirTouch, AT&T, BSCC and Sprint PCS's Comments on COCUS/LINUS

\(11\) NARUC, Bruce Armstrong, COCUS/LINUS Enforcement Recommendation

\(11\) Lockheed Martin-IMS, NANPA Contribution - Collection of Forecast
and

Utilization Data

\(12\) Chairman Hasselwander's Proposal to Interact with the NANPA, Re:
Costs and

Specifications for 1000s Block Administration

\(13\) Chairman Hasselwander's Background Paper, Re: Definition of
Reserved Telephone

Numbers

\(14\) NANPA Oversight Working Group Report

\(15\) Arter & Hadden, LLP, Letter of August 12, 1998, Re: 1000s Block
Number Assignment

and Universal Service

**V. Summary of the Meeting:**

**A.** *** Welcoming Remarks*.** Alan Hasselwander, Chairman of the
Council, provided welcoming remarks and introduced the newly appointed
designated federal official (DFO), Kris Monteith, Senior Attorney,
Network Services Division, Common Carrier Bureau.

**B.** ***Approval of Minutes of June and July Meetings***. Approved
with minor modifications.

***C. N11 Ad Hoc Working Group Update. ***Paul Hart, USTA, made a short
announcement to remind the Council that the WG did not have a report for
this meeting, and that its final report is scheduled for presentation at
the September meeting.

***D. Tutorial - Law Enforcement Issues*.** Barry Bishop, Director,
Numbering Services, Lockheed Martin-IMS, provided a handout entitled
"What are the impacts to law enforcement?" describing the effects of LNP
and number pooling in E911 situations. Specifically, because LNP may
make it difficult to determine the service provider for a particular
telephone number, it was suggested that information for ported and
pooled numbers may be obtained through a database or an Integrated Voice
Response unit (IVR) system. The IVR concept requires a PIN to be
assigned to identify the service provider of a ported or pooled number.
IVR will be deployed by the LLC in the Midwest region NPAC and is under
consideration by SBC in the Southwest region. The IVR system is now
operational in two cities (Detroit and Chicago) and has been used by the
FBI and other agencies. *See* handout for further details.

A brief discussion took place concerning NPAC issues and LLC funding and
ongoing costs for implementation of enhancements to the NPAC systems.
The actual cost of IVR implementation by LM on behalf of the LLCs is
proprietary to the LLCs and was not revealed during the presentation. It
was noted that this capability is not part of the CALEA obligations,
which prompted the question of whether the IVR functionality is required
or mandated and under what authority.

***[Discussion on Law Enforcement Issues]{.underline}***. A discussion
ensued on the role of NANC on this issue. Dan Hochvert pointed out that
the E911 public concern is separate from the CALEA wire-tapping issues.
The NPAC administrator tracks ported numbers. Paul Hart stated that this
requires wireless, resale and ported identification of the service
provider. In addition, a more generic question, indeed perhaps a global
network issue or set of questions must be asked and answered, as to how
to associate service providers with customers across multiple dimensions
of the network.

Chairman Hasselwander stated that the problem needs to be identified and
framed. It was noted that section 256 of the Communications Act,
addressing interconnectivity of the public switched telephone network,
is at issue in developing procedures for the coordination of network
capabilities to satisfy diverse requirements. Time and development costs
must be considered.

The NANC is sensitive to the 911 and LNP issue. Gary Fleming, SBC,
stated that 911 difficulty arises when there is no customer premises
information (CPI) in a no record found (NRF) situation. If a subscriber
calling for emergency services is able to give his or her address, a
problem does not arise. But in a NRF situation where a subscriber cannot
communicate his or her address to the E911 operator, the problem is
critical. Service provider identification is needed for a trace.
Currently, IVR is in use in the Midwest, and SBC intends to utilize IVR,
as well.

Bruce Armstrong agreed that there are 911 difficulties with LNP, whether
geographic or location portability, and will be feared by Departments of
Public Safety because 911 tandem switches do not know where calls are
coming from. Concerns also surround the expansion of NPAs because some
tandems can only handle up to 4 NPAs. A lot of issues must be
considered. Ed Gould added that in the current LNP environment, no
address is associated with the TN in the NPAC database.

***E. *** ***Industry Numbering Committee (INC) Report.*** Jo Gallagher
reported that the INC has not yet completed its review of 1000 number
block pooling assignment guidelines (Issue 105, Number Pooling. The
latest version, however, Draft 10, is now available on the INC web site.
The action plan for completion of the guidelines calls for completion by
the September NANC meeting. Ms. Gallagher presented the following as
agreements reached by the INC:

[Contamination]{.underline}. At the time of the establishment of the
industry inventory pool, service providers will contribute blocks to the
pool with up to and including 10% contamination (previously assigned
numbers). For contaminated blocks, block donors must perform
intra-service provider ports within NPAC to avoid having these numbers
assigned by the block recipient. This responsibility is part of the
block donor\'s enumerated responsibilities in the draft *Thousands Block
Assignment Guidelines*.

[Dual Assignment]{.underline}. A discussion was held on the issue of how
to proceed if a block donor fails to perform these intra-service
provider ports, and numbers from a donated 1000 number block, which were
previously assigned by the donor (contaminated numbers), are newly
assigned in the recipient\'s network and remain assigned in the donor\'s
network (dual assignment). INC was unable to reach a consensus on this
issue, however, but drafted three alternatives, with related
consequences, for presentation to the NANC as follows:

**Alternative 1:** The block donor has failed to meet its
responsibilities and should lose the number. The block recipient\'s
customer should keep its (newly assigned) number, and the block donor\'s
customer should have to change its telephone number. *Consequence:* The
donor\'s customer, who may have had the number for a considerable period
of time, is punished for the donor service provider\'s error. Unless the
block donor is held responsible for failing to meet its
responsibilities, donors may not have sufficient incentive to perform
the activities required when donating contaminated blocks.

**Alternative 2:** The block recipient\'s customer should have to change
its (newly assigned) telephone number. This result should be the least
damaging to involved end users. The block donor\'s customer, who may
have had the number for a considerable time, should not have to change
its number. *Consequence:* The recipient\'s customer, who has been newly
assigned the number, is punished for the donor service provider\'s
error.

**Alternative 3:** Eliminate the donation of contaminated blocks. Not a
viable alternative.

[Discussion]{.underline}. The discussion focused on the action which
should be taken if a dual number assignment occurs, the best means of
resolving the problem, incentives for preventing such a mistake from
occurring in the first instance, and who should be financially
responsible in the event a dual assignment occurs. Chairman Hasselwander
acknowledged that no one supported Alternative 3; instead, only
Alternatives 1 and 2 presented viable alternatives. Following a full
discussion, consensus was reached that Alternative 2 represents the
appropriate action to be followed in the event of a dual number
assignment, under which the recipient\'s customer would have to change
its newly assigned number. NANC members agreed that this action would
have the least impact on the customer who was originally assigned the
number by the block donor.

NANC determined that the best way to prevent a dual number assignment
from occurring was to require service providers donating 1000 number
blocks to perform intra-service provider ports within NPAC to register
their assigned numbers. NANC also determined that the recipient of the
1000 number block should be referred to the NPAC for the latest status
of the numbers in the donated block. To prevent any confusion about the
status of numbers in the donated block, the donor service provider would
not provide any other list to the recipient. The NPAC would be the only
source for determining the status of numbers in donated blocks.

While NANC members agreed that incentives for preventing dual
assignments from occurring are needed, they were unable to reach a
consensus on what incentives should be put in place. Chairman
Hasselwander stated that this issue should be dealt with by NANC, but
that members should submit contributions for discussion. In addition, no
consensus was reached on the issue of who should bear the financial
responsibility when a dual number assignment occurs. Members should
address this issue as well in their contributions on the subject.

***F. Discussion of 314 Area Code Split****.* Chairman Hasselwander
introduced the issue that had been brought to the NANC\'s attention
regarding the proposed 314 NPA split in St. Louis, Missouri. Chairman
Hasselwander reported that the NANPA has not released a new NPA based on
the 33 year difference in the projected lifetimes of the new NPA, and
the re-drawn boundaries of the 314 NPA. (Note that during this
discussion, Ron Connors, Lockheed Martin, noted that the 23-year
difference in projected exhaust dates stated in the letter from Lockheed
Martin to SBC represented a clerical mistake, and that the projected
difference in exhaust actually is 33 years). Mike Bennett noted that SBC
and Southwestern Bell would recuse themselves from the deliberations,
except to provide factual information if requested.

Sheila Lumpe, Chair, Missouri PSC (by conference bridge), stated that
the area code split was an issue that had been worked on for a year, and
included public surveys and hearings in the St. Louis area. The public
indicated a strong desire for the split. The proposed new boundary line
for 314 follows the Metropolitan Calling Area (MCA) for St. Louis \-- an
area in which there presently exists a flat-rate for all local calls. If
number conservation measures are in effect, Ms. Lumpe noted that the
predicted date of exhaust of the 314 NPA is 2012. Ms. Lumpe indicated
that the conservation measures considered were rate-center
consolidation, number pooling, and sequential number assignment.

Ms. Reynolds noted that the 33 year difference in the projected exhaust
dates of the two NPAs assumed wireline pooling implementation by January
1999, and wireless pooling by January 2000. Ms. Reynolds further
explained that evidence at the PSC indicated that without any number
conservation measures, the newly drawn 314 would exhaust in 2002, and
the new NPA would exhaust in 2009. With conservation, NPA 314 is
estimated to exhaust in 2012, and the new NPA in 2045. The estimate for
the new NPA relies heavily on pooling.

The growth predicted for the new NPA (which includes outlying counties
such as Jefferson and Lincoln), in terms of population and new offices
exceeds that of the area covered by the new 314 boundary, according to
Ms. Lumpe. Mike Bennett, however, noted that SBC\'s predictions
indicated that 75% of the NXXs to be assigned would be in the 314 NPA,
and only 25% in the new NPA.

In response to a question from the Missouri PSC regarding the
significance of the NANP guidelines, Chairman Hasselwander noted that
while the guidelines are not law, they are taken very seriously.

Dan Hochvert added that the possibility of 314 exhaust in only 2-3 years
was unfair to others within the NANP. Furthermore, forecasting a longer
life for an NPA predicated on untried relief methods was problematic.
Ms. Reynolds confirmed that the predictions assumed that rate-center
consolidation occurs immediately upon assignment of the new NPA. She
also stated that the 2002 and 2009 dates, which assume that no
conservation methods are in place, were based on estimates from Bill
Adair, SBC, and she that is unclear as to the basis of the data behind
these estimates.

The NANC discussed number conservation and its effect on accurate NPA
exhaust forecasting. Mike Bennett noted that while differing assumptions
based on the efficacy of number conservation might indeed lead to a
situation in which the 15-year guideline was not violated, an assumption
of exhaust in 2002 for the newly drawn 314 area violated yet another
guideline that requires that new NPAs last for a minimum of five years.
He further stated that the 2012 estimate for the newly drawn 314 NPA
assumed that 14 rate centers would be collapsed into one. Ron Connors
confirmed that area code relief should last five years. Bruce Armstrong
added that Colorado\'s experience regarding rate center consolidation
was painstaking. Mr. Armstrong noted that relief from rate center
consolidation is primarily forward-looking; that relief does little to
prolong the life of an older NPA.

Chairman Hasselwander stated that throughout the discussion, it was
clear that the data regarding the potential life of NPAs is disputable;
for this reason, by some accounts it is not clear that the guidelines
would be violated. As a result, Chairman Hasselwander suggested that
perhaps the NANC should recommend to the FCC that a new NPA be released,
with a strong plea that if Missouri proceeds with the proposed split, it
look carefully at preserving the NPA for as long as possible, even if
that means re-drawing the boundary between the 314 NPA and the new code
subsequent to the release of the new NPA. Consensus was reached that the
NANC would send a letter to the FCC outlining the NANC\'s
recommendations. (*See* Action Item 1).

**G.** ***LNPA Working Group***. Tom Sweeney reported that the WG had
been restructured, and that the WWITF had combined with the LNPA T&O
group to form the LNPA Working Group. A new wireless subgroup opened
within the LNPA WG to address wireless issues.

On July 29, the pooling subgroup delivered updated pooling process
flows, and on August 17, it delivered updated pooling FRS. Mr. Sweeney
reported that the next face-to-face meeting will be in Baltimore on
August 25 though August 28. Mr. Sweeney reviewed the current status of
NPAC Release 2. When questioned about what the LNPA WG would do in the
event of a problem with Release 2, Mr. Sweeney stated that he would keep
the NANC informed as issues arise.

Mr. Sweeney also provided an update on OBF Issue 1182. Specifically, Mr.
Sweeney stated that OBF Issues 1182 involves a proposed unique
identifier for each industry segment that would require storing line
level identification beyond line-level LNP (e.g., reseller, unbundler,
wireless, etc.). This information is required for billing of access for
local interconnection, resale, and unbundled network elements.

Mr. Sweeney noted that this issue appears to be beyond the scope of the
LNPA WG, and that NPAC databases do not support OBF-required
information. As a result, a discussion ensued, centering on why the
issue was sent to the LNPA WG. A representative of ATIS stated that
letters went to various groups to determine whether anyone possessed the
requested data. Chairman Hasselwander suggested replying to the OBF
letter by stating that although NANC did not see the synergies between
the OBF-required information and the information stored in the NPAC,
that the NANC and the LNPA WG are ready and willing to cooperate in the
future. (*See* Action Item 3).

[WWISC Report]{.underline} \-- Paula Jordan stated that at the August
9-10 WWISC meeting, the sub-committee reviewed and updated the NANC
provisioning flows to include wireless; identified issues involved with
large-customer ports; analyzed the porting process for wireline to
wireless and wireless to wireline; reviewed the OBF LNP process flow;
reached initial agreement on treatment of Type 1 numbers in a number
portability environment; developed an outline for the second integration
report to the FCC; and established a subcommittee to develop wireless
LNP implementation milestones.

Ms. Jordan explained that a Type 1 number connects to an end-office and
typically uses a partial NXX. Generally, the LEC is shown as the code
holder. The agreement in implementing wireless LNP is that Type 1 number
agreements will need to be dissolved, and converted to Type 2 numbers.
The question of how wireless carriers will be notified of this
requirement is the subject of a forthcoming report to the NANC.

***H. Cost Recovery Working Group Report.*** Ms. La Lena reported that
the CRWG is developing recommendations on how costs for number
administration and pooling should be allocated for 1,000 block and
individual telephone number pooling in the United States. Cost
allocation, as used in this context, refers to how vendors are to
recover costs, not how service providers will recover costs. Ms. La Lena
also reported that the billing and collection agent for the NANPA,
NBANC, has begun the process of billing and collecting for the upcoming
year. NBANC will update NANC on this effort on a monthly, or as needed,
basis. With respect to collection of payments from non-U.S. carriers,
Ms. La Lena noted that only the payments of the Dominican Republic and
Canada are outstanding.

Cathy Handley, Vice Chair, NBANC Board of Directors, noted that, among
U.S. carriers, 234 have not reported to the NBANC. She also noted that
FCC approval of the 1999 data collection form would not be completed by
August 1, 1998. (It should be noted that a letter send by the Staff of
the Network Services Division revising NBANC\'s preliminary schedule to
more accurately reflect the time needed by the FCC receive OMB approval.
This revised schedule does not change the date on which NBANC expects to
begin billing).

***I. NRO Report.* ** Chairman Hasselwander opened the discussion by
noting that the NRO last met on August 6, 1998. He then stated that the
NANC expected to submit a report on September 23, 1998, that would
provide discussion on 1000 block number pooling and ITN, as well as on
as many of the other number optimization issues as possible by that
date. Chairman Hasselwander noted that slippages in the date on which
the report would be submitted to the Commission were possible, and that
the NANC did not want to send a piecemeal report. Chairman Hasselwander
noted that, ultimately, the NANC may forward a preliminary report on
September 23 or it may ask for more time to submit the report. Chairman
Hasselwander stated that these kinds of decisions will be made at the
relevant time, not now. He also noted that industry representation at
the NRO meetings had dwindled. Dan Hochvert requested attendance lists
for the meetings

Jerry O'Brien, Omnipoint, asked whether the 50 states also included the
territories, possessions and Puerto Rico. Amy Putnam, NARUC, stated that
the state survey only went to the 50 states. Chairman Hasselwander added
that territories and possessions have had little interest in number
optimization issues.

Mike Whaley, NRO Co-Chair, began the NRO report. Mr. Whaley referred to
handouts as he made the NRO report, specifically, to the list of NRO
documents. Mr. Whaley noted that the ITN Task Force\'s most recent
document is an August 10, 1998 number optimization paper. He also
reported that the State Issues Task Force report is 98% complete.

Mr. Whaley stated that during the August 6 NRO meeting significant
differences were aired about the contents of the September 23 report.
The discussion centered on whether the final report should contain 1000
block pooling, ITN, UNP, and other optimization and conservation
measures. A conference call discussion between Chairman Hasselwander and
the NRO Co-chairs resolved the issue, as indicated in the August 10,
1998 letter included with the NRO handout. The letter reiterates what
Chairman Hasselwander said at beginning of meeting, *i.e., *that the NRO
should strive to meet the objective date for the report, that 1,000
block and ITN pooling must be in the report, and that UNP and other
conservation measures do not have the same level of priority at the
present time.

A revised schedule was set forth in the August 10 letter, as follows:
ITN Task Force - met on August 16-17, and will meet again on August
27-28, to work on ITN, with the intent of completing the work on ITN
before proceeding to work on UNP. The report draft is due August 24-25.
Co-chairs will begin drafting the final report from all available
information from all Task Forces. Final report preparation is scheduled
for September 9-11th.

Mr. Whaley reported that the NRO handout contains the NRO WG documents
that are available electronically, and suggested that interested parties
look for the latest pooling report, the August 10 ITN report, as well as
an e-mail NRO mailing list, for the NANC participant responses.

Trent Boaldin questioned the extent of consensus reached in documents
and noted that although NRO had assured the NANC that the September 23
report would contain cost-benefit analyses of pooling, to date, only
costs have been quantified. He asked when the NRO WG\'s estimates of the
benefits would be included in the report. Chairman Hasselwander
responded that this information would be contained in the September 23
report. He then noted the direction of the report: various number
optimization plans are being analyzed, as well as the conditions under
which one number optimization solution might be appropriate, indicating
that one size does not fit all.

**Thursday, August 20, 1998**

***J. **[Lockheed Martin-IMS Announcement]{.underline}*** Jeff Ganek,
Senior VP and Managing Director, Communications Industry Services, made
a brief announcement regarding the formation of LM's Global
Telecommunications subsidiary. Mr. Ganek stated that Lockheed Martin
(CIS) recognizes the critical nature of neutrality in its role as NANPA
and NPAC, and that LM\'s planned expansion raises concerns about its
competitive neutrality. Mr. Ganek indicated that, at present, LM\'s
expansion represents an organizational change only; LM does not offer
any network products or services that it did not offer one year ago. Mr.
Ganek stated that LM will provide a report by August 28 regarding the
new LM telecommunications subsidiary and will detail the steps LM
proposes to take to maintain its competitive neutrality.

Chairman Hasselwander stated that the NANPA Oversight WG will discuss
this issue at its meeting later today.

***K. NRO Discussion (continued)****.* Chairman Hasselwander offered
some initial observations: Within the ITN group there has been some
discussion indicating that ITN will take 3-5 years to implement. The WG
also is working on UNP, and there was discussion on whether full
discussion of UNP would be included in report. Chairman Hasselwander
then stated that the NRO WG should attempt to include an analysis of all
number optimization options, but the report [must]{.underline} contain
an analysis of 1000 block pooling and ITN.

In response to questions about what would happen if the report does not
fully treat all 14 measures/options, Chairman Hasselwander stated that
the intent was to ask that the FCC not release for comment anything that
is not complete, *i.e.,* that does not discuss all 14 items. He
reiterated that if the NANC needs to ask the FCC for additional time in
which to complete its work, NANC would consider that question at its
September 23 meeting, rather than now. NANC expressed the view that a
bifurcated report on number conservation measures should not go forward
to the FCC and that the absence of information puts industry in somewhat
of a "what if" game.

Trent Boaldin noted that the original Metzger letter requested a report
on pooling, not on the other number optimization options, and that
reporting on those options was not a first priority. Chairman
Hasselwander stated that the NANC has two alternatives with respect to
the report. First, NANC could submit a report on pooling only, and
request that the FCC not put it out for comment until the NANC submits a
report on the remainder of the options. Second, NANC could ask for
additional time in which to complete the entire report. Mr. Boaldin
requested that the NANC follow the first alternative and stated that he
believes that because the industry cannot implement ITN by December
1999, every effort should be put into 1,000 block pooling.

Brent Struthers, Co-Chair, State Issues Task Force, cautioned that the
SITF report data contains dated information from 37 surveys and would
need to be updated if the NRO report is submitted to the Commission much
later than September 23. Mr. Struthers also noted that the SITF is
scheduled to meet again on August 21, and that, at this point, its
report is 90% complete.

Fred Gaechter, Bellcore, Co-chair of the ITN Pooling Task Force,
reported that the ITN TF expected to complete its report the week of
August 24. Thereafter, the Task Force would move to consideration of
UNP. He did not expect the analysis of UNP to take as long as the
analysis of ITN. He also reported that the ITN TF would deliver as
complete a UNP report as possible by September 7.

The draft NRO report will be provided to the Council by September 11. It
was noted that ITN and ATF need broader representation at their
meetings. Chairman Hasselwander stated that he will make phone calls to
address this issue. Chairman Hasselwander closed the NRO portion of the
meeting by summarizing that the pooling portion of the NRO report was
progressing on schedule, but whether the report would include an
analysis of the other number optimization items remained to be
determined.

Emily Williams, ALTS, expressed concern about the final report and
recommended that the Council continue consideration on questions of
competitive neutrality, and press to look at other methods to conserve
numbers, including UNP.

Recognizing that there are widespread implications with respect to some
conservation measures, Chairman Hasselwander expressed the view that the
report is intended to be a useful document to be used state-by-state and
that the report should prove useful to industry and the FCC, as well as
to the states. Chairman Hasselwander also stated that the Council will
not forward recommendations that are based on any premature or
incomplete work. Mike Bennett stated that the INC number pooling report
represents a significant body of work on the subject of 1,000 block
pooling and suggested that it be attached as an appendix to the final
NRO report.

With respect to the cost questionnaire that industry received last week,
it was noted that number optimization measures have not been
sufficiently detailed to allow cost estimates to be made. Because of the
perceived lack of specific, tangible description of the different
measures, the cost/benefit analysis will be difficult to perform.

Paul Hart added that he believes that it is important that the report
contain sufficient detail of the pooling structure for deployment of
that structure by December 1999. Mr. Hart suggested that the
prioritization of work should be based on what we currently know because
both ITN and UNP have competitive issues.

***L. Steering Group Report.*** Chairman Hasselwander provided a read
out of the SG's meeting held on August 19, from 6:00 - 8:30 p.m. The SG
discussed Chairman Hasselwander's proposal on how to go forward with the
LM/NANPA to put together the specifications and pricing for 1,000 block
number pooling. The SG concluded that a firm, fixed price should be
provided by year end 1998. The NRO-WG will have finished its work on
developing a matrix to review LM\'s performance by the end of October.
It was agreed that Norm Epstein, GTE, and Pat Caldwell, BellSouth, will
put together a management plan for the SG to work within the
above-mentioned time parameters.

Chairman Hasselwander reported that the SG had discussed the issue of
access to the unredacted version of the LM response to the Requirements
Document. After a full discussion, the SG supported the use of a
non-disclosure agreement to protect LM\'s interest in any confidential
information and determined that vendors will not be able to look at the
unredacted version of LM\'s responses to the Requirements Document.

Chairman Hasselwander also raised the issue of preport (PP) and port on
demand (POD), stating that NANC had agreed at its July meeting to place
development of POD subsequent to PP with EDR. Both Bell Atlantic and US
WEST agreement that they no longer have an objection on this matter.

The Council accepted the SG recommendations as described.

***M. Reserved TN definition*.** Chairman Hasselwander provided a
background paper on the definition of reserved TN, which was emailed to
Council members prior to the meeting. Discussion followed on the
definition of a \"reserved number,\" and unassigned number porting. The
first issue discussed was whether Omnipoint\'s question of whether
\"reserved numbers\" included DIDs, Centrex or non-geographic numbers.
According to Bell Atlantic, reserved numbers include only geographic
numbers. The discussion then centered around the Legal Working Group
recommendation that only numbers reserved pursuant to a legally
enforceable written agreement must be ported. Questions were asked about
whether the \"written\" requirement should be dropped, and what might
constitute a \"legally enforceable written agreement.\"

NANC members expressed some support for a letter of agreement between a
customer and service provider. Peter Guggina added that a requirement of
a written agreement would protect both service provider and customer. It
was noted that the original service provider might forget that it had a
particular reserved TN and that NANC should consider a policy to require
a written agreement. Amy Putnam added that the reservation standard for
porting is one issue, but that the reservation and pattern of practice
for a oral agreement is another. It is likely to be contingent on how
much time and money the customer is willing to spend. NARUC would favor
a written agreement, going forward, so as not to put more customers at
risk.

Consensus was not reached on this issue. Chairman Hasselwander stated
that this subject would be raised again. The NANC needs contributions on
this issue, to be addressed at the September meeting, and seeks comments
from both the industry and the states. Ron Binz suggested that
interested parties should state the purpose of their contributions, and
the principles to be served.

***N. NANPA Oversight WG Report.*** Andrea Cooper and Brent Struthers,
Co-Chairs, provided the NANPA Oversight WG Report. The WG organizational
meeting was held on July 23 and co-chairs were elected. The WG reviewed
a proposed work scope which states, "The NANPA Oversight WG will develop
and manage a process to track and ensure the NANPA discharges its
responsibilities in accordance with the Requirements Documents." In
addition, the WG will rely on documents other than the requirements
document, such as questions for clarification submitted during the
evaluation process and current industry guidelines. Two sub-task groups
were established to (1) develop a compliance matrix and (2) to summarize
FCC orders.

Ms. Cooper reported that the WG workplan objectives are as follows: (1)
identify the FCC requirements for NANPA; (2) outline the NANPA
responsibilities; (3) develop and populate a compliance matrix; (4)
develop a proposal for NANPA performance evaluation; (4) meet with
LM/NANPA to review the performance evaluation and process, and (5)
present a proposal to NANC for concurrence. After an evaluation is
actually conducted, a report will be submitted to the NANC. It was noted
that, at present, a timeline has not been established for this workplan.

Ron Conners commented that LM has concerns about what constitutes the
appropriate requirements documents. LM would like to see a "Master
Requirements Document," which would include any related industry
guidelines, as they change.

Chairman Hasselwander complimented the WG on its rapid progress, also
noting that, to date, the CO Code Transition Task Force, chaired by Char
Meins, and Doug McCullough, is continuing to work well.

The NANPA Oversight WG liaison to the NRO is Brent Struthers on audit
issues. The next meeting will be held on August 20, following the NANC
meeting. The NANPA Oversight WG also is scheduled to meet on September**
**24.

***O. NANPA COCUS/LINUS Enforcement Recommendations***. Two additional
contributions were offered on how data carrier reporting under
COCUS/LINUS would be validated and how accurate reporting would be
enforced. NARUC provided one of the contributions and the other was
presented jointly by AirTouch, AT&T, BSCC, and Sprint PCS.

NARUC\'s proposal included the following key provisions: (1) the NANPA
must remain as a neutral party; (2) the NANPA must have the capability
of performing both scheduled and unscheduled audits of code/block
holders; (3) NANPA must work within all appropriate industry guidelines
for handling any anomalies found pursuant to an audit; (4) NANPA shall
forward unresolved problems to the appropriate regulatory body; and (5)
penalties shall be imposed for non-compliance.

Trent Boaldin asked whether and why penalties should be imposed on
carriers not requesting numbers. Bruce Armstrong indicated that full
industry compliance was needed to understand industry resource
utilization. Jerry O'Brien asked whether the NANPA would be held
responsible for incorrectly reporting non-complying carriers to a
regulatory authority. He also raised questions regarding data
confidentiality and dispute resolution. Peter Guggina noted that both
misleading forecasts and the use of misleading underlying data should be
addressed.

The joint AirTouch, AT&T, BSCC, and Sprint PCS proposal made a number of
different recommendations. It recommends that: (1) service providers
receiving NXXs, rather than resellers, be responsible for reporting
forecasts and utilization data; (2) the NANPA be given a greater role in
monitoring and enforcing industry numbering guidelines; (3) the FCC
should be the ultimate enforcement authority although the states will be
involved; and (4) only the NANPA should receive carrier specific data.

Chairman Hasselwander proposed that the two contributions be reconciled
and combined for the next meeting. Peter Guggina proposed that any
outstanding issues be included in the consolidation.

***P. Other Business.*** Chairman Hasselwander reported on an August 12,
1998 letter received from Arter & Hadden, on behalf of TEC, concerning
1,000 block number assignment, universal service and cost recovery
issues for rural areas of the United States. Chairman Hasselwander
stated that the NANC charter does not encompass the consideration of
cost recovery measures for service providers, but instead only
encompasses NANPA cost recovery issues. Universal service-related issues
also are not within the purview of NANC.

Bruce Armstrong stated that Colorado is studying the cost of number
pooling on small ILECs, and also noted that pooling only works in
LNP-capable areas in the near term.

Trent Boaldin suggested that the issues be forwarded to the NRO as they
work 1,000 block pooling, and invited TEC to be part of the process.
Anne La Lena stated that the Cost Recovery WG is reviewing cost
allocation for the vendor with respect to 1,000 block pooling, not
service provider cost recovery. Paul Hart added that NANC should examine
the effects on smaller and mid-size companies, and look at costs as
opposed to cost recovery. Affected and interested parties should make a
contribution on this issue.

[Travel Funding for Non-Profit NANC Members]{.underline}. Chairman
Hasselwander reported that of the 22 organizations who agreed to
participate in the travel fund, 16 have responded with \$1,000
contributions, for a total of \$16,000. However, expenses from April
1998 to July 1998, total \$14,000. Chairman Hasselwander requested
additional contributions to further supplement the travel fund. The
Council agreed that NANC members whose organizations provided funding in
past should do so again.

**V. Action Items and Decisions Reached.**

1\. [314 Area Code Split]{.underline}. NANC will communicate, with the
FCC and the Missouri Commission, the following conclusions and
recommendations:

Recommend that the new NPA Code be released for Missouri's use.

Recommend that they do everything in their power to comply with the
guidelines, specifically to preserve 314 for at least 5 years. Using
best judgment, consider all available conservation methods.

Relook at the data, understand forecast data.

If it appears that 314 will exhaust before 5 years consider redrawing
the 314 boundary before requesting another NPA.

Chairman Hasselwander will draft 2 letters for NANC members to review.
PCIA opposed.

2\. [INC Issue]{.underline}. Support alternative 2 (block recipient
customer changes number).

Discuss incentives at NANC.

Contributions solicited in order to facilitate discussion concerning
appropriate incentives and how to put them in place.

3\. [OBF Letter]{.underline}. LNPA WG reviewed the OBF letter and
advised that the NPAC databases do not contain the information required;
the NPAC only contains data on ported numbers. However, NANC is
available to provide additional assistance to OBF in any appropriate
way, concerning this issue. Chairman Hasselwander will prepare a written
response to OBF letter.

4\. [Steering Group Report]{.underline}. Development of a work plan.

Norm Epstein and Pat Caldwell will develop and deliver a work plan in
September to support delivery of a firm quote for administration of
1000s block number pooling by year end 1998.

Conditions of review will be developed by the NANPA Oversight WG that
will not allow competitive vendor access to the Lockheed Martin-IMS
response to the Requirements Document.

5\. [Pre-port (PP) with Efficient Data Representation
(EDR)]{.underline}. There is no need to continue development of
requirements for port on demand (POD).

6\. [Definition of Reserved Telephone Numbers]{.underline}.
Contributions solicited for additional discussion and resolution at the
September NANC meeting.

A suggested structure for bifurcation of the issues:

\(a\) What defines a reserved number?

\(b\) What defines a legal obligation for a carrier to port a reserved
number?

7\. [COCUS/LINUS]{.underline}. The authors of four contributions: (1)
NARUC; (2) NANPA, (3) AirTouch, AT&T, BellSouth Cellular, SprintPCS, and
(4) MCI will meet and develop an integrated recommendation and will also
address confidentiality. Participants: Bruce Armstrong, Ron Conners,
Mary DeLuca and Norm Epstein.

8\. [Travel Funding for Non-profits]{.underline}. NANC members who
previously accepted an obligation to support and fund NANC non-profit
members' participation agreed to an additional billing of \$1,000 each.

9\. [Letter on Behalf of Telephone Electronics Corporation
(TEC)]{.underline}. NRO Working Group should review whether 1000 block
pooling imposes disparate costs on smaller carriers. It is, however, not
within the purview of NANC to review or recommend cost recovery
mechanisms as suggested in the letter.