**North American Numbering Council **

Meeting Minutes

June 22-23, 1999 (final/approved 7/21/99)

**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, 445 12th Street, SW, Room TW-C305,
Washington, DC.

**II. List of Attendees:**

A. Council Members

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

1\. Beth Kistner ALTS

2\. Edmund Gould AT&T Corp.

3\. Dan Hochvert Bell Atlantic

4\. Ronald Binz Competition Policy Institute

5\. Adam Kirschenbaum CompTel

6\. Lolita Smith CTIA

7\. Norm Epstein GTE

8\. Peter Guggina/Karen Mulberry MCI WorldCom

9\. Gerry Thompson Mobility Canada

10\. Vincent Majkowski NARUC

11\. JoAnne Sanford/Erin Duffy NARUC

12\. Beth O'Donnell NCTA

13\. Larry Krevor/Seth Jones Nextel Communications, Inc.

14\. Dan Gonzalez NEXTLINK

15\. Joe Kingrey Nortel Networks

16\. Michelle Thomas Omnipoint

17\. Trent Boaldin/John McHugh OPASTCO

18\. Robert Hoggarth PCIA

19\. Bill Adair SBC Communications, Inc.

20\. Ron Havens Sprint Corp

21\. Jacques Sarrazin Stentor Resource Centre, Inc.

22\. Gerry Rosenblatt TIA

23\. Paul Hart USTA

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

Ron Conners NANPA

B. Commission Employees

Diane Griffin Harmon, Designated Federal Officer (DFO)

Jared Carlson, Alternate DFO

Blaise Scinto, Deputy Chief, Network Services Division (NSD)

Tejal Mehta, NSD, Common Carrier Bureau (CCB)

Patrick Forster, NSD, CCB

Jeannie Grimes, NSD, CCB

Trish Greene, Accounting and Audits Division (AAD), CCB

**III. Estimated Public Attendance**: Approximately 42 members of the
public attended the meeting as observers.

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

\(1\) Agenda

\(2\) May 25-26, 1999 Meeting Minutes

\(3\) LNPA Working Group Status Report to NANC

\(4\) Wireless Number Portability Subcommittee Report and Wireless
Pooling Alternative Evaluation

\(5\) Telcordia Presentation -- Originating LEC Query Issues on IXC
Bound Calls

\(6\) Numbering Resource Optimization Working Group Report on COCUS
Survey

\(7\) abNANPA Performance Improvement Program Highlights

\(8\) abNANPA Performance Improvement Plan Summary

\(9\) NANPA Revised First Annual Report

\(10\) FCC Public Notice DA 99-1198

\(11\) Cost Recovery Working Group Report

\(12\) NBANC NANPA Fund Performance Status Report

\(13\) Industry Numbering Committee Status Report

\(14\) NANPA Responses to May 25-26, 1999 NANC Action Items from the
1999 COCUS and NPA Exhaust Analysis Report

\(15\) NANC Recommendation to the FCC Concerning the Replacement of the
COCUS; Chairman Binz's amending language to NRO Report

\(16\) Dan Hochvert's replacement language for Section XI, NRO Report

\(17\) Audit IMG Report and Recommendation

**V. Summary of the Meeting:**

***A. Welcoming Remarks*.** Ron Binz, Co-Chair of the Council, provided
welcoming remarks.

B. ab***Approval of Minutes.* **Five changes to the May 25-26, 1999 NANC
meeting minutes were suggested and incorporated. The minutes were
adopted as amended.

***C. Local Number Portability Administration (LNPA) Working Group
Report*** Co-Chairs Shelly Shaw, Ameritech, and Anna Miller, BellSouth
Cellular, presented the report to the Council. Ms. Miller reviewed the
key wireless issues contained in the Wireless Number Portability
Subcommittee (WNPSC) Report.

Ms. Miller reported that the WNPSC spent most of the June meeting
addressing the effect of the Wireless Number Pooling Alternative on
wireless carriers. In addition, the WNPSC discussed the NPAC Release
Time Frame, and expressed wireless service providers\' preference for
two releases per year.

Ms. Miller reviewed the WNPSC's evaluation of the Wireless Number
Portability Alternative, which includes a description of the option
("Without Phase 2 LNP, wireless service providers could donate and
receive 1000 blocks from a number pool, given certain requirements."),
circumstances governing its use, and a timeframe for implementation.
Phase 1 LNP is the implementation of LNP database querying and call
routing (to the terminating carrier) capabilities for wireless carriers
by December 31, 1998; Phase 2 LNP is wireless service provider LNP
implementation by November 24, 2002.

The "real issue" considered by the WNPSC was whether wireless service
providers can participate in thousands-block pooling prior to Phase 2
LNP implementation. The WNPSC concluded that the alternative for number
pooling would not be a viable method for wireless participation in
thousands-block pooling prior to Phase 2 LNP. Implementing pooling
before porting could jeopardize compliance with the November 24, 2002,
wireless number portability implementation deadline, because of the
requirements needed to support the alternative, as well as the
associated impacts. The requirements and impacts for the alternative are
detailed in the alternative evaluation report.

Moreover, the modifications necessary to support the alternative could
not likely be implemented in a significantly shorter timeframe. The
software to support wireless LNP was not developed with pooling before
porting in mind. In fact, Phase 1 wireless LNP software is not even
available for some wireless switches, and these wireless carriers are
using default routing (the \"triggerless\" solution) in order to comply
with the requirement for wireless carriers to query LNP databases by
December 31, 1998. Ms. Miller also described a situation where a
wireless carrier (carrier A) is allocated blocks of 1000 numbers from a
Central Office code originally allocated to only one carrier (carrier
B). Carrier A\'s switch, however, would not deliver calls placed from
one to another of its numbers because the software would only recognize
that the entire block of numbers was originally assigned to carrier B.
Instead, carrier A\'s switch would attempt to deliver the call to
carrier B\'s switch. Software currently available for Mobile Switching
Centers (MSCs) considers only the first six digits of a ten-digit
telephone number when routing a call.

In response to a question by Beth Kistner, ALTS, Ms. Miller stated that,
because the MSC only examines the first six digits of the ten-digit
telephone number to determine if the number is routed to its switch or
to another carrier\'s switch, Phase 2 wireless LNP is needed to perform
a query to determine the LRN associated with the pooled number so the
call can be routed to the appropriate carrier\'s switch. Ms. Miller
added that the problem lies in the inability of switches to examine more
than six digits when attempting to route a call, where numbers within
thousands blocks are allocated to different carriers.

Vince Majkowski, NARUC, questioned why moving from 10,000 number to
1,000 number allocations was such a problem, especially when it is
basically the same functionality. Ms. Miller replied that the problem
would not likely exist if both wireless LNP software Phases were
available, and that it was dependent on the software delivered from
vendors. Some switch/ software vendors have combined the two
capabilities, querying and LNP, but only Phase 1 software has been
activated and tested. Wireless carriers that have switches with the
combined capabilities could activate the Phase 2 software. Absent both
phases of wireless LNP software, the switch would have to examine seven
digits in order to route a call to the appropriate carrier.

Ed Gould, AT&T, commented that wireless software was initially developed
with only wireline carriers porting numbers in mind, and was not written
to consider numbers ported between wireless carriers. Ms. Miller
concurred, stating that this caused vendors to develop software for each
functionality separately. Software needs to be developed to handle both
phases. Mr. Majkowski asked whether the software vendors developing
wireless LNP software are making a consistent effort to develop this
software by a specific date, who they are, and what these vendors and
the industry are doing to accelerate development and implementation of
wireless LNP software. Ms. Miller replied that an issue affecting the
timeline is that one of the major switch vendors will not have wireless
LNP Phase 1 software functionality available until 2001, and wireless
carriers with these types of switches will not even have Phase 1
capability until then. Thus, given the timeline for testing and
implementation of wireless LNP, which includes MIN/MDN separation, NPAC
turn-up and intercarrier testing, the industry should concentrate only
on wireless LNP implementation, so the November 24, 2002 deadline is not
jeopardized; total wireless LNP implementation will support pooling.

Ms. Miller declined to identify which specific vendors are unable to
meet certain software development deadlines, adding that there is no
current mandate to implement pooling, so that is not the focus of many
vendors.

Mr. Gray, GTE Wireless, stated that the issue is not whether wireless
carriers could accept a number routed into their networks based on LRN
technology, but national roaming is driving Phase 2. Wireless roaming
requires MIN/MDN separation, which supports routing and the delivery of
services. Software modified to support porting would not support
roaming.

Additionally, Ms. Miller stated that the Phase 1 query needed to route
calls could be conducted by another carrier, and that the handling of
incoming calls that have NPA-NXXs that were originally assigned to other
switches requires full wireless LNP software and MIN/MDN separation.
Gerry Thompson, Mobility Canada, added that the intent of Phase 1 is to
complete calls from a mobile switch to a ported environment. The carrier
can query an LRN database to route the call either on its own, or have
another carrier to do. With a mobile to ported call, a query must be
performed on the 10,000 number block declared ported. In a
thousands-block-pooling environment, a loop, or "two-dip" process could
be established to route the call. Mr. Thompson noted that software
development for the wireless industry is not easy, and that it is not
realistic to think a small software change can easily fix the problem.

Chairman Binz suggested that NANC members state specifically what issues
the WG needs to clarify so they can be presented at next month's
meeting. Ms. Miller stated that registration still needs to be
addressed. Paul Hart sought clarification on whether Phase 2 wireless
LNP must be implemented completely in order to participate in
thousands-block pooling. Mr. Hochvert stated that he would like to
understand which switch suppliers are developing software in phases, and
that development in separate phases seems inefficient. Chairman Binz
asked whether software development to address the number pooling
barriers Ms. Miller identified could be separated from the
implementation of wireless LNP.

Mr. Majkowski questioned, given that it is a competitive global market
that is moving to a technology neutral environment, why it is not
possible to implement this software solution, especially since it has
already been done in Europe. Ms. Miller replied that some vendors
already have, or will soon have, full wireless-LNP software available.
The other part of the equation, however, is that wireless carriers are
busy implementing Phase 1 wireless number portability and at this time
there is no mandate to implement number pooling. Resources are currently
being devoted to implementing the querying capability as soon as
possible, and then to separating the MIN/MDN so full wireless LNP can be
implemented by November 24, 2002. Lolita Smith, CTIA, stated that part
of the regulatory mandate is to support nationwide roaming, and that
this is why MIN/MDN separation was chosen. For this reason, one can not
just look at software upgrades to accomplish one function. Instead, one
needs to look at everything that must be accomplished in light of the
regulatory mandate.

Gerry Thompson stated that Europe uses a different technology \-- Global
System for Mobile Communications (GSM) with Signaling \[Message Relay\]
technology, which allows porting today. Most U.S. wireless carriers,
however, use Advanced Mobile Phone Service (AMPS) time division multiple
access and code division multiple access (TDMA and CDMA). The software
is being developed separately because the standards for Phase 1 and
Phase 2 were developed separately, and Phase 2 standards were just made
available in December 1998. Vendors do not work ahead of standards, and
there is a two to three year period needed for software development.

Chairman Binz suggested further discussion on this matter be held until
the next NANC meeting. The critical issue is whether the wireless
industry can remove the barriers to the alternative wireless pooling
method with a software approach, rather than waiting for full wireless
LNP implementation, which will require MIN/MDN separation.

Ms. Shaw presented the remainder of the report. Regarding the LNP
Problem Identification and Management (PIM) PIM Proposed Work Plan, the
WG is still working on the scope PIM, and is trying to define the depth
and ability of the WG to manage it. The team is awaiting receipt of a
"Recommendation for LNP Problem Identification and Management" letter
from the NANC. Upon receipt of the letter, the team will need one month
to finalize the scope of the PIM and an additional month for finalizing
processes. So far, the team has developed the following: (1) a form for
service providers to submit issues; (2) a way to track issues from
receipt to resolution; (3) a way to communicate unresolved issues to
other committees/groups that are better equipped to resolve the issue;
(4) a way to track closed issues for future reference, and (5) a web
site has been offered by a volunteer so the process information is
readily accessible to the industry. The team continues to have concerns
about resources, authority, and enforcement.

Ms. Kistner questioned why the PIM team is "waiting on receipt of the
official 'Recommendation for LNP Problem Identification and Management'
letter from the NANC." It was agreed that the team should consider the
previously drafted letter, on which consensus had been reached at the
April NANC meeting, to be official, and that the team should move
forward accordingly. Additionally, Bill Adair asked for clarification on
the statement that the "team continues to have strong concerns about
resources, authority, and enforcement." Ms. Shaw replied that the
concerns were not itemized in the report received from the PIM Team,
however, one such concern was whether the recommendation for the PIM
letter was to be considered to be official or just a draft. The
resources, authority, and enforcement issues are being addressed
separately. Mr. Gonzalez expressed concern about delays in addressing
LNP performance issues and asked that the group make specific procedural
recommendations, if possible, and that the NANC act upon them, so
substantive issues can then be addressed.

Mr. Hochvert read from page four of the previous meeting's minutes:
"Working group members are also concerned about authority and
enforcement issues. Chairman Hasselwander asked Mr. Sweeney to elaborate
on the authority and enforcement issues. Mr. Sweeney replied that some
of the members are not convinced that there will be a problem with
non-compliance, and would not know how it will be handled until a
problem occurs." Mr. Hochvert commented that when a working group is
asked to address an issue, it should do so, regardless of authority and
enforcement difficulties, and then let the NANC deal with the outcome.
This is what Chairman Hasselwander concluded in the last meeting \--
that if they have those concerns, let the NANC work them, but do not let
them interfere with the job.

Ms. Shaw reported that the development of the Wireline/Wireless
Integration Report is now complete, and the report will be transmitted
to NANC members via email by the end of June.

Regarding the status of NPAC/SMS Release 3.0 (National Number Pooling),
the WG has reviewed the clarifications presented in Exhibit B of the
statement of work (SOW). Of the two changes identified, one (deemed to
be minimal) was rolled into the SOW at no additional charge and the
other was minor enough to be delayed until the next release. Everything
in Exhibit B is complete and is in agreement with Lockheed Martin (LM).
The Midwest and Northeast Limited Liability Corporations (LLCs) have
both asked LM for information regarding accelerated delivery of the
Efficient Data Representation (EDR) portion of Release 3.0. The Midwest
LLC has specifically asked for a revised SOW. This is in response to
industry concerns regarding national number pooling being mandated by
state commissions prior to the necessary functionality being
implemented. The WG Pooling Subcommittee was tasked to identify the EDR
functionality (for SMS/LSMS) required to support a national number
pooling architecture, in response to the LLC goal of accelerated EDR
delivery. To complete this task and support the revised SOW request from
the Midwest LLC, the sub-team developed a timeline and deliverables,
with their first meeting to be held June 28-20, 1999 in Chicago.

Regarding the Change Management/Release Management Timeline. The current
change management process is being revised. The WG has committed to
having the flows and narratives delivered to the LLCs after the next
meeting. The Release Management process has been documented and
submitted to the LLCs for review and acceptance. The revised process
consists of a six and three-fourths quarter implementation timeframe
before stabilizing into a two SOW, two release per fixed 12 month
schedule. This is a change from the previously suggested one SOW, two
release per year schedule.

Regarding the Slow Horse Update, Steve Addicks, MCI WorldCom, was
elected as committee chair. The team agreed to the following work plan:
(1) Complete analysis of March, April, and May Slow Horse data; (2)
develop a recommendation to the WG based on the data analysis; (3)
develop LSMS interface performance requirements, and (4) determine and
recommend who the enforcement authority for LSMS interface performance
requirements should be. Also, determine and recommend who the LSMS
certification entity will be.

The next LNPA WG meeting will be held July 12-15, in Ottawa, Ontario.

***D. N-1 Query Issue. ***Adam Newman and Marcia Guza, Telcordia
Technologies, gave a presentation on the Originating LEC Query Issue on
IXC Bound Calls. Mr. Newman reviewed the history of the T1S1.6 Working
Group's activity on this issue. The issue arose in a letter ballot
comment in August 1998 by SBC in which it suggested that the originating
local exchange carrier (OLEC) should be allowed to do the LNP query even
when the call is to be IXC-routed. Telcordia, at the April 1999 meeting,
proposed modification in the switch requirement, and agreed to bring a
revised contribution to the June NANC.

Mr. Newman summarized the proposed capability for IXC-routed calls --
the OLEC can specify whether to perform the LNP query, on a per-IXC
basis. That is, the contribution proposes that the query result would be
forwarded where there is agreement with the IXC to do so. This differs
from the April 1999 contribution, which provided that an OLEC could make
a query and that an IXC could request that the result of the query be
suppressed for any call bound for its network.

Peter Guggina, MCI WorldCom, asked for clarification on what the term
"on a per-IXC basis" meant in the first bullet and where such capability
would be used. The OLEC would perform the query only if the IXC
requests. Mr. Hart cited to and quoted from language in the March 11,
1997, FCC *Memorandum Opinion and Order*, CC Docket 95-116, supporting
the idea of queries being performed only where a business arrangement is
in place. In light of the FCC Order which provides that carriers should
negotiate among themselves which carrier should perform the query, Mr.
Hart opined that there is no NANC business here.

Mr. Newman continued through the report, reviewing the motivations for
the OLEC query and the responses to concerns raised during the May 1999
NANC meeting (listed pages 5 through 8 of the presentation); reviewed
several of the LNP performance criteria from the FCC's LNP *First Report
and Order*, and concluded that the proposed enhancement meets all of the
FCC performance criteria. The report's final conclusion was that the
contribution does not seek to change established FCC or NANC policies.

Mr. Guggina questioned whether parity would be effected; that is,
whether the IXC would be able to select a third party vendor as easily
as having the originating LEC perform the query. Ms. Guza replied that
it should not affect parity, that it is just another option for the IXCs
to contract with the OLEC to perform the query. Further, in response a
question whether there would be any difference in call processing if the
query option is suppressed, such as post-dialing delay, Ms. Guza said
that there should not be, but the carrier could specifically ask a
vendor.

Additionally, Mr. Newman noted that the LEC only charges for the queries
if there is a contractual agreement and if it performs the query. Ms.
Kistner commented that LEC query tariffs contain two rates, one for a
contracted query, and one for a default query, and that the lack of a
contractual agreement does not necessarily preclude a charge. Ed Gould,
AT&T, stated that an OLEC should be allowed to perform the LNP query on
all dialed calls, but can charge another carrier for such queries only
if there is a contractual agreement in place. Mr. Newman replied that
the contribution, in its current form, states that the query is only
performed when there is an agreement with the IXC in place.

Mr. Hart commented that for location portability, a query must be
"backed up" and that it is an important option for carriers to decide
where the query is performed. Mr. Newman advised that the contribution
has already been changed and submitted twice, but as yet has not been
accepted as a contribution by T1S1.6. It is likely that it will undergo
additional changes. If the contribution is accepted, then vendors could
begin development and offer these features to customers.

Mr. Epstein suggested that this is not an issue the NANC should be
debating because it is not a T1S1.6 issue that would impact a standard.
Brian Foster, T1S1.6 Chair, stated that, under the T1S1.6's standard
operating procedures, changes may be made up until the contribution goes
out for balloting, and not all companies that participate in balloting
participate in developing the contribution. Mr. Guggina commented that
the NANC is addressing this issue because MCI WorldCom previously asked
several questions at T1S1.6 that were not answered. Also, at the last
NANC meeting, it appeared that the contribution had the capability to
change the paradigm of where the query is performed, which caused
significant concern. Mr. Guggina also questioned whether standards are
in place governing passing information from the originating carrier to
the IXC that require modifications. Ms. Guza replied that they have
found no standards that require modification. If there is any such
information, then it exists in the Bellcore Generic Requirements, and
these would not have to be changed. Ms. Guza commented that page 4 of
the presentation, which outlines the motivation for the contribution,
was also presented in the April NANC T1S1.6 meeting.

As a result of the presentation and discussion, Chairman Binz suggested
a follow up letter to T1S1, closing the concerns raised in the June 10
letter which stated, in pertinent part, that at the May 1999 meeting
NANC discussed some of the issues raised by T1S1.6's proposed action on
this item. NANC's position is that this issue should not be assumed to
be merely a technical one, and until NANC has an opportunity to
investigate the potential policy issues that may be associated with the
Telcordia contribution, it was suggested that T1S1.6 refrain from
developing any modifications to the existing LNP requirements or LNP
queries. It was agreed that a letter should be sent to T1S1.6 stating
there are no policy issues raised by the proposed changes to the
Telcordia contribution. Mr. Guggina concurred, and requested that the
letter also include a statement that there should be no mandatory
language in the standards, but that the requirements should be invoked
only with mutual agreement between carriers. Chairman Binz concurred and
stated that a draft letter would be prepared. The information presented
today should remove concern this will be done in the absence of a mutual
agreement between carriers. How the standard is implemented is then up
to the carriers.

It was further clarified that the default is the current process, in the
absence of a bilateral agreement. Mr. Hart expressed concern about the
NANC's involvement in the standards process. Chairman Binz concurred and
stated the letter will serve to establish boundaries for T1S1.6
regarding this issue. If a standard is eventually adopted in this area,
then the NANC could become involved at the appropriate time. Mr. Hart
reiterated his concern with NANC's involvement in the standards process,
adding that how this is implemented depends on carrier choice. In this
case the FCC has statements as to how this is to occur and the process
in T1S1 is consistent with that. How a standard is implemented is then
up to the carriers.

***E. Numbering Resource Optimization (NRO) Working Group Report.****
*Co-Chairs Beth O'Donnell and Mike Whaley provided the report to the
Council. The final version of the report distributed at the meeting was
slightly changed from the soft copy circulated by Chairman Binz (a
substitute page 5 was distributed, which carries into the Executive
Summary the major substantive change to the final paragraph on page 35).
The reserved number issue will be discussed at the July 1999 NANC
meeting.

Mike Whaley reviewed the report. The report responds to the NANC's
request, and evaluates 3 alternative proposals to the current COCUS and
proposes a fourth model, the Hybrid model. The WG analyzed the cost and
feasibility of all 4 models. Based on this analysis, the WG concludes in
the report that "the Hybrid approach appears to provide the optimum
balance of keeping the data collection and reporting burden on service
providers at a manageable level, while providing the NANPA with the
additional resources needed to provide more accurate exhaust
projections."

Mr. Whaley reviewed the assumptions contained in Section II of the
report. The 1999 enhanced COCUS is the baseline model. A major weakness
of this model is that inaccurate data will not result in a good
forecast. Section IV describes the deficiencies in the current COCUS.
Each of the alternatives listed in Section V, with a comparison against
the desired attributes to each alternative, Section VI, were discussed
at the last meeting. Section VII contains table 3, which compares the
level of compliance of each alternative with the desired attributes. Ms.
O'Donnell clarified that all 4 alternatives should be in the "Does Not
Meet" category for the ability to accommodate mergers and acquisitions.

Section VIII assesses the relative costs and utility of each
alternative. Cost estimates were invited, and NANPA provided information
for table 4, which summarizes relative costs as compared to the 1999
enhanced COCUS. Mr. Whaley clarified that the costs provided by NANPA
are based on estimates to develop, deploy and do COCUS; service provider
costs are additional costs that service providers would incur, and there
is quite a range on what service providers say it will cost them.

Section IX recommends the Hybrid approach. It also recommends a
threshold for increased reporting forecasting and utilization data, and
reporting on a semi-annual basis where NPAs have less than 5 years to
exhaust, and where there is a significant increase in code consumption
over and above what was projected. General concerns were raised about
the level of reporting, and the WG feels that it could reach consensus
on this issue. Section XI discusses implementation considerations; the
WG feels that NANPA needs explicit enforcement authority to conduct the
COCUS. Section X lists the tasks needed for implementation.

Chairman Binz reminded Council that CCB Deputy Chief Yog Varma requested
a recommendation from the NANC and suggesting that the NANC needs to
take the report and fashion it as a NANC report. Mr. Whaley interjected
that there is not consensus on some issues; however, Chairman Binz
indicated that lack of WG consensus should not keep the NANC from
reaching agreement. NANC's endorsement of the recommendation may depend
on changing certain aspects of report.

Mr. Majkowski supported adopting the recommendation. Mr. Guggina agreed,
but asked to discuss the utilization data issue, referring to footnote
#18, which states that some service providers supported reporting
utilization data at the NPA-NXX level, while others supported reporting
at the NPA level, and service providers always have the option to report
at more granular levels. Mr. Guggina opined that providers should have a
standardized expectation of what level should be reported. Mr. Whaley
stated that there is consensus on the level that should be reported in
pooling areas, but not in non-pooling areas.

Beth Kistner raised the issue of whether categories other than
"unavailable" would be reported. Ms. O'Donnell stated that NANC members
were asked to submit their thoughts electronically at the May 1999 NANC
meeting, and the WG reached consensus that only unavailable numbers
would be reported. Norm Epstein stated that GTE prefers to report at the
NPA level, and sees no benefit in more granular reporting unless there
is pooling. Ms. Kistner suggested that additional granularity would
provide important information in a non-pooling environment because there
is no way to look at data by rate center.

There was further discussion on what level of granularity would give
NANPA the best information and utility of reporting at the NPA-NXX
level. John Manning stated that the primary benefit of more granular
reporting is with pooling; such data is necessary to plan to start
pooling. In response to Chairman Binz's question about whether reporting
at the NPA-NXX level would improve exhaust projection for NPAs within
the exhaust window, Mr. Manning replied that it would give a better and
more accurate picture. Mr. Epstein raised the issue of the costs
involved, and added that some of this data already exists. It was
suggested that because additional granularity is not significantly more
expensive, NXX-level data should be collected. Bill Adair, SBC, stated
that he sees no benefit in a non-pooling environment, and it would be
onerous on some small companies to provide such data. Ms. Kistner
suggested that reporting at the NPA level, as with the current COCUS,
has not worked (citing to numerous surprise exhausts), and that
collecting data in the same fashion will leave NANPA with the inability
to make accurate forecasts. Mr. Hochvert stated that all companies have
to collect utilization data to run their businesses, so reporting at the
NPA-NXX level should not be a significant additional burden. Lolita
Smith, CTIA, noted for the record her concern about the burden of
reporting at the NPA-NXX level in non-pooling areas that would result
for wireless carriers.

Mr. Majkowski observed that the 3 year implementation time line seemed
long; Mr. Guggina agreed, and suggested that the WG reconsider the time
line. Ms. Kistner asked who submits the detailed cost information (task
\# 3 from page 35) and for what purpose. Mr. Epstein replied that the WG
was attempting to determine costs if the function is not out-sourced;
NANPA would provide this cost information. Chairman Binz added that it
is unsettled in the report whether NANPA or a subcontractor would
conduct the COCUS. Mr. Epstein stated that the WG would decide, based on
a detailed requirements document yet to be developed, whether it should
be bid or sole source.

There was further discussion on what type of mathematical model needs to
be developed, and what other implementation steps, including software
development, are needed. Mr. Gould suggested that the 1999 enhanced
COCUS algorithms be used until a model is available. Mr. Guggina
suggested that information should be collected in an RFI in advance of
an RFP instead of the industry attempting to do it at the non-expert
level, and that the detailed requirements could be used for the
procurement process.

Chairman Binz asked for further discussion on the 3 year implementation
time line. Mr. Hochvert observed that LNP was implemented in less than 3
years, and further suggested that the period could be shortened if
driven externally by parallel effort and sufficient industry resources.
Chairman Binz also asked whether the report comports with the FCC NRO
NPRM. Ms. O'Donnell responded that the report does not recommend some of
the FCC's tentative conclusions in that NPRM.

It was suggested that the Council try to close out at least the two
major issues -- the level of reporting and the 3 year development time
line. Mr. Majkowski agreed that the report should be forwarded with
editorial changes, and asked if the industry was comfortable with the 3
year time line. NANPA has indicated that it will take approximately 18
months, without questioning the cost involved. Mr. Hochvert indicated
that, given that there are no requirements developed yet, a 3 year
outside limit may be the best estimate. Mr. Guggina stated that a time
line is needed for each phase; Mr. Adair agreed, stating that collection
of data and data manipulation are two different things. The program to
"plug" the data into can be developed later. The Council reached
consensus that the report would be submitted in its current form; that a
paragraph describing a range of time for implementation would be
inserted (avoid committing to a 3 year time line, but also not
committing to another time frame).

There was further discussion on the granularity issue. Mr. Epstein asked
for more information on what the additional benefits of more granular
data would be, and the trade-offs associated with it. Other details
discussed were NPA vs. CO code exhaust; further disaggregation of the
"number unavailable" category; standardization of information;
information on reserved numbers; and verifying the accuracy of
reporting. Larry Krevor, Nextel, stated that the value of this exercise
would be undercut by limiting the data and spreading implementation out
for 3 years.

Chairman Binz called the question of whether the category of unavailable
numbers should be disaggregated into the 6 INC categories; 9 were in
favor, 9 opposed. The question was rephrased as whether all reporting
inside the exhaust window should be disaggregated into the 6 INC
categories in pooling areas; 12 were in favor, 8 opposed. In non-pooling
areas inside the exhaust window, the Council voted 17 in favor and 3
opposed to reporting at the NPA-NXX. No vote was taken on the reporting
level for non-pooling areas outside the exhaust window.

Chairman Binz suggested that the document be revised and proofed by the
WG co-chairs and the Chairman of the NANC. The cover memo should include
a notation on disaggregation. Chairman Binz further stated that the
assumption is that the COCUS report would be produced every 6 months;
however, Mr. Manning added that something could trigger NANPA to do a
COCUS more frequently. In response to a question about whether Council
members would get another chance to review the report before it goes to
the FCC, Chairman Binz stated that he could commit to distributing the
revised report 2 days prior to submission, but that the Chairman would
likely be reluctant to make any substantive changes.

A few additional edits to the report were suggested. Mr. Gould reminded
the Council of an open item -- what mathematical model would be used to
analyze the data. Mr. Manning stated that he envisioned NANPA starting
with what was used for the 1999 enhanced COCUS, and modifying it as
needed. Chairman Binz stated that the NANC would give the FCC
provisional time lines. Robert Hoggart, PCIA, acknowledged the effort of
the NRO WG in development of recommendation. Finally, attachment 1
(description of the Hybrid approach -- included for clarification) will
be removed, and the report will be revised accordingly. Attachment 2
(excerpts from the Thousand Block Pooling guidelines) will also be
removed.

***F. NPRM Workplan Discussion. ***Chairman Binz referred to email
guidance from Chairman Hasselwander suggesting how NANC should to
proceed to handle its assignments under CC Docket 99-200. NANC members
were requested to consider how to proceed on the issues overnight for a
fuller discussion at June 23, 1999, session. The tasks were outlined by
NPRM paragraph number and the nature of the response required was
highlighted. Some issues will require NANC to report before the end of
the comment date of July 30, 1999, while others require a report or
recommendation by the reply comment date of August 30, 1999.

The tasks to be worked are as follows:

Paragraph 38, directs NANC to make a recommendation regarding what
measures discussed in Section IV (Administrative Measures) should be
adopted as FCC rules. The NANC response is due by the August 30th reply
due date. It was suggested that a short term IMG should be formed to
respond to this issue.

Paragraph 88, seeks comment on whether to direct NANC to select an
entity to audit carrier number utilization and forecast data using a
competitive bid process. NANC will await report by the Audit IMG
schedule for June 23, to determine if the presentation is responsive to
the paragraph 88 tasking. It was also noted that the NANPA Oversight WG
have been assigned to audits in general.

Paragraph 90, directs NANC to report its progress on audits. It was
suggested that the Audit IMG report scheduled for June 23 may be
responsive to this request. The NANC response is due by the July 30th
comment cycle.

Paragraph 165 seeks NANC conclusions or recommendations regarding
pooling, including pooling by CMRS carriers, based on NANPA's
\[exhaust\] projections or the Team's findings), NANC will refer this
matter to the SG for recommendation development for later review by the
full NANC at the July NANC meeting.

***G. NANPA Oversight Working Group Report.*** Co‑Chair, Andrea Cooper,
reported on the status of the NANPA performance improvement work plan
presented at the March 16-17 NANC meeting. As requested, NANPA responded
with a work plan within 60 days; the WG has been working with NANPA and
supports the work plan. The WG will continue to monitor NANPA's
performance of the work plan monthly.

Ron Conners, LM, reviewed the highlights of its performance improvement
program. First, NANPA has developed a close working relationship with
the WG. Communication with the WG is good and NANPA will continue to
propose changes and get input from the WG. NANPA's goal is to get an
"outstanding" rating from the WG. Steps taken by NANPA include revising
its Annual Report by adding updates and financial data; improving
customer response timing and educating employees through sensitivity
training on customer service; facilitating the new outreach effort to
the PSCs and industry with roundtable meetings; and meeting with state
commissions to understand their needs. Staffing changes include the
hiring of Brent Struthers; Cathy Handley, formerly of PCIA; and John
Manning, formerly with ATIS. Both are working on improving internal
infrastructure issues and assisting with compliance to the NANPA
Oversight WG compliance matrix.

NANPA NPA relief notification process improvements include calling
jeopardy in a timely manner; and beginning relief and publishing
planning letters expeditiously. Increased staffing levels have enabled
NANPA to be more responsive and distribute NPA relief planning documents
to the interested parties quickly. Also, improvements are underway to
make the NANPA.com web site more user friendly and to post updates on a
weekly basis or as needed. Additionally, copies of the NANPA performance
improvement plan summary matrix and its revised first Annual Report.

***June 23, 1999***

***H****. ****Cost Recovery Working Group Report.*** Co‑Chair Anne La
Lena, MCI WorldCom, presented the report to the Council. The issues
under review are further elaboration and/or development of cost
recovery/allocation work products, and support for IMG pooling activity
efforts. The issue of the cost allocation recommendation for ITN and UNP
is on hold. Ms. La Lena reviewed the WG's recommendation for a business
arrangement between NANPA in pooling administrator role and the NPAC.
The WG is not asking the Council to adopt the recommendation today; the
WG will elaborate on the recommendation and seek approval from the
Council at the July 1999 NANC meeting.

There is no current payment arrangements through the NPAC of any sort
existing now. The purpose of the suggested business arrangement is to
(1) avoid 1K pooling and administration cost under the LNP cost
allocation formula. *See* August 1998, CRWG recommendation that the LM
cost to the industry for 1K block pooling be distributed among service
providers and collected by the NBANC under the NANPA cost allocation
formula. This recommendation was adopted by the NANC. (2) Provide clear
understanding of activities to be undertaken by NPAC with prices and
terms as necessary; (3) aid billing and collection activity by NBANC,
and (4) aid in delineation of responsibilities if more than one entity
performs of the functions.

Ms. La Lena explained that if the NPAC does not expect any payment for
development or services or functions performed to support 1K block
pooling and administration activity, any agreement between the two
entities would have service terms and conditions but no dollar value.
Questions or comments on this contributions can be entertained between
now and next month. The item will be modified somewhat, but the core
recommendation will not change.

[NBANC Report]{.underline}. NBANC Chair Vincent Majkowski, NARUC,
provided the report to the Council on the fund status and significant
NBANC activities. The current fund balance is \$2.03 million; projected
receivables total \$2.04 million, with payments to LM to date total
\$1.07 million, with remaining payments totaling \$3.21 million for a
total fixed contract for this year of \$4.28 million. Payments to NECA
total \$64K to date with remaining payments totaling \$193K. Board
expenses are \$5,258; this includes member reimbursement of \$4,373 and
meeting expenses of \$878. Payments to an external auditor, Price
Waterhouse Coopers for year one was \$16K, with year one remaining of
\$6K and year two will be \$22K.

The Dominican Republic contribution of \$17.8K has been paid. For the
1999 Funding Process, the Dominican Republic made its contribution of
1999 as well. Alfred Oyog, Cable & Wireless, has agreed to coordinate
and assist with NBANC collections from the remaining 12 countries. As of
June 3, 1999 3,810 forms have been received; reporting gross revenues
now total \$232 billion, with net revenues totaling \$188 billion. In
the 1998 NBANC operations audit Price Waterhouse Coopers found NBANC
financial statements to be a fair presentation of the financial position
of the corporation at the end of the fund year.

***I.* *Industry Numbering Committee (INC) Report.*** INC Co-moderator
Shawn Murphy AT&T, presented the report to the Council. Issues going to
final closure are listed on page 3 and issues in initial closure are on
the page 4 of the report. The results of the Interim LNPA workshop
meeting were noted \-- the ported-out numbers definition was removed
from the thousands-block-pooling administration guidelines and glossary,
as well as any associated forms and appendices; there was a
recommendation to modify Form 1B of the Thousand Block (NXX-X) Pooling
Administration Guidelines so it can be used for both block activation
and block change processes at the NPAC.

INC seeks further clarification from the NANC on what it meant by
"business arrangement" in its November 1998 decision that all issues of
reporting of forecast and utilization information by resellers and Type
1 carriers should be addressed through business arrangements made with
the code holder. Mr. Murphy noted the differences between wording in the
NANC decision and in the NRO Report on COCUS. The NRO Report states that
reporting will be done consistent with "existing business arrangements."
INC raised several questions on page 8 of the report; the heart of the
issue is whether it is reasonable to expect resellers/Type 1 SPs to
provide forecast/ utilization data to potential competitors. INC also
raised several concerns on page 9 of the report whether the NANC
decision is inconsistent with the principle of neutral third party
number administration and this appears to be a step backward. The
November NANC decision does not support the objective of obtaining
complete and reliable forecasts from all carriers; legal and
jurisdictional issues -- for example, interconnection agreements are
under state jurisdiction.

Norm Epstein, GTE, commented that INC was trying to write specific
guidelines and needs to know what "business arrangements" means, so
obligations specifying who supplies what information can be formulated.
Mr. Murphy concurred, but stated this and other items, such as
interconnection agreements, were secondary concerns, which only matter
if the NANC stands by its original decision. Mr. Hart suggested that the
NANC decision may need to be changed, and that the issue could be
discussed in next month's meeting. Chairman Binz agreed, adding that the
NANC should discuss whether the issue should be reopened. Ms. Kistner
questioned whether Resellers and Type 1 Interconnection customers were
already required to provide carriers with advance notice of their
numbering needs (*i.e.*, what are the existing business arrangements?).
Mr. Murphy the carriers are not getting this data, so that assumption is
wrong. Ms. O'Donnell stated that she thought the data was already being
supplied and suggested that the meeting minutes be reviewed in order to
determine why the decision was reached before revisiting or changing the
decision.

Mr. Majkowski agreed with Mr. Hart's comment and noted that states are
responsible for arbitrating interconnection agreements. If the agreement
is not arbitrated and is a business agreement between parties, the
states will only look at neutrality and nondiscriminatory aspects. The
states will honor that agreement, as long as neutrality and
nondiscriminatory criteria are met. If the agreement is arbitrated,
however, the states will delve into the questions of utilization and
forecasting to ensure that the information is provided. From a NARUC and
states point of view, if NANPA needs the information, it does not matter
who provides the information, as long as the data is only accessible
through a confidentiality agreement.

Peter Guggina commented that there could be problems with resellers
providing their own data and that it may be more efficient if code
holders reported the data. Also, resellers should be required to provide
utilization data and capacity requirements to the underlying carrier,
otherwise the system will not work. Mr. Guggina supported revisiting the
issue at next month's meeting. Mr. Adair concurred, but noted the data
currently received from resellers does not include utilization data,
which forces carriers to guess. Ms. O'Donnell questioned whether Type 1
interconnection agreements are under state jurisdiction, the feasibility
of the NANPA studying resellers, and whether the problem was forecasts
or utilization. In response to the first question, Mr. Murphy replied in
the affirmative. In response to the second question, Mr. Binz replied
that the NANC could do something like that. In response to the third
question, Mr. Murphy replied that it was actually both, even though
carriers could, in some cases, compile utilization data. Also, it would
be easier for resellers to provide utilization data than it would be for
carriers to figure out which lines are actually in use. In response to a
query, Mr. Murphy stated that Chairman Hasselwander's statement only
talked about reporting forecast information, not utilization
information, which is needed. The INC, after analyzing the NRO Report,
concluded that the report included forecast and utilization reporting.
Thus, the INC needs clarification concerning the NANC decision and the
NRO Report.

Mr. Hart suggested that specific items could be discussed next time, and
that resellers have specific obligations for reporting information, as
does the code holder. Trent Boaldin, OPASTCO, noted the difficulty in
formulating guidelines to govern the relationship between resellers and
code holders where the NANC decision indicated that they should not
address that relationship. Chairman Binz suggested placing this issue on
next month's meeting agenda and asked who should organize and lead the
discussion. Mr. Hart suggested that the INC should led the discussion,
and Chairman Binz agreed that it should be a part of INC's report and
discussion at the July 1999 NANC meeting. Mr. Guggina suggested that
resellers, such as TRA, be invited to next month's meeting, so that the
objective -- to get an efficient collection of data for NANPA to analyze
-- can be explained. Mr. Murphy added that from his perspective, it was
a forecast and utilization issue, and suggested that the NANPA's view on
the burden of obtaining the data should be obtained.

Mr. Murphy continued with the report. The INC 500/900 Number Portability
Effort was withdrawn, as directed, effective May 28, 1999. The LNPA
Workshop will meet again on July 13, 1999 and on September 14, 1999.

***J. 1999 COCUS and NPA Exhaust Update. ***John Manning, Lockheed
Martin, provided a response to several action items from the May 1999
NANC meeting. The NANPA database of code holders was updated with the
responses to the 1999 COCUS. There are over 900 service providers in the
database -- which reflects approximately one half of the current code
holders. Currently, NANPA is collecting information in the CO code
assignment process through the Part 1 form to update the database. The
Part 1 form contains contact information within each code holder's
organization. NANPA is also working with industry associations for help
and cooperation regarding contact information.

Mr. Hochvert asked for clarification on what the following statement
"46% of the total number of CO codes assigned in the sample NPAs were to
service providers that did not provide 1999 COCUS. Mr. Manning replied
that, of the entities in the 10 NPAs surveyed that had received a code,
one-third did not provide any form of 1999 COCUS input. After totaling
the NXXs assigned to all entities in the ten NPAs, and calculating the
percentage attributable to those entities that did not respond to the
1999 COCUS, Lockheed Martin found that 46 percent of the codes were
assigned to carriers that did not respond to the 1999 COCUS.

Mr. Hochvert commented that it could be more useful to have a report
based on the response rate by industry segment. In other words, what
industry segments are not reporting? Mr. Manning replied that additional
information, such as the number of carriers in each industry segment, is
needed to provide that level of information. This effort is linked to
"purifying" the NANPA database to reflect how many carriers are
providing which type of service.

Mr. Manning confirmed that he remembered there being a request to look
at the effects of rate center consolidation (RCC) at the last meeting,
but added that one was not included in the published action items. To
consider RCC in each NPA would involve a lot of work. Chairman Binz and
Mr. Hochvert agreed that this issue was not made an action item. Mr.
Hart asked whether there is a role for the NANPA Oversight Working Group
(NO WG). Ms. Kistner asked whether there was a model NPA used in the
NANAP Exhaust Study, using an average number of rate centers, that could
be used to estimate the effects of RCC. Mr. Manning replied that this
could be done, but the results would apply to one NPA would not
necessarily apply to another.

Mr. Hochvert asked whether the NOWG is working on a code holder database
for NANPA. Ms. Cooper replied that this consolidation has not yet been
completed, but there is an effort within NANPA to do this. Ms. Cooper
added that she believes it is the NO WG's role to make sure NANPA has
the tools to get the information, but it is not the NO WG's role to
monitor who reports. Mr. Manning concurred and noted that USTA has
already provided extensive help and other associations have volunteered
to assist in the data gathering process.

***K. Continued Discussion on NRO COCUS Replacement Report. ***Chairman
Binz provided draft language in a separate handout for review. It was
agreed that the suggested edits, reflecting the discussion on June22
should be incorporated into the report. All edits will be highlighted as
NANC edits. Trent Boaldin opposed to changes to the table requiring more
granularity in data reporting. Dan Gonzalez noted that this issue was
highlighted in the previous meeting. A suggestion was made to possibly
add a footnote to express the interest of small and rural telephone
companies may have with the more granular level of reporting. The
footnote will state indicate there was a split over the level of
granularity. It was also noted that this very issue is also teed up in
the NPRM.

Beth O'Donnell suggested that the vote be reflected the vote in the
footnote and that NANC did not reverse the NRO. It was agreed that the
second sentence of footnote under NANC amendments to the NRO WG Report
would state that a majority of the membership favored a recommendation
that utilization be reported in more disaggregate categories, and that
the NANC did not reach consensus on this issue. A separate NANC cover
page will be added to reflect that edits are made within the text, in
addition of a transmittal letter. This will be re-circulated before
going to the FCC.

***L. Steering Group (SG) Report.*** ** **Peter Guggina provided an
update on the evaluation of the sole source bid number pooling
administration negotiations with LM. The IMG has concluded and is
recommending that the function should be competitively bid. Full
discussion by the NANC will have to be held under a closed door session
subject to non-disclosure agreement by NANC members and/or alternates.
It was agreed that the closed-door session would take place during the
July 1999 NANC meeting. Mr. Guggina emphasized that this is only a
recommendation at this point, until discussed by the full NANC. It was
also noted that in the interim, the IMG may have some ongoing
activities. In order to ensure a quorum for the closed sessions, Council
members were requested to affirm their intent to attend via email and to
acknowledge that they have signed a non-disclosure agreement.

***M. Continued NPRM Responsibilities Assignment Discussion. ***Chairman
Binz reviewed the list of NANC tasks identified in the NPRM. Paragraph
165 - pooling recommendation, the previous Exhaust Study Team along with
NANPA and any other NANC member who want to participate will take that
matter up. Paragraph 184, tentatively conclude entity to serve as the
pooling administrator adequately addresses, etc., is simply inviting
comments on whether to seek a recommendation on this issue from the
NANC.

With regard to paragraph 121, seeks comment on how to ensure that rate
center consolidation does not impact E911 systems. It was noted that
this matter has a lot of technical implications and each rate center
consolidation is unique due to the diverse conditions within each
jurisdiction. Mr. Majkowski stated that the issue transcends overlays,
splits and routers within the state, and that standardization of the
equipment in the PSAPs influences these aspects. Due to time constraints
perhaps NANC should wait for public comments before reacting. This is
really an E911 issue. Ed Gould agreed that this is a routing question
not a rate center consolidation question. It was suggested that perhaps
the language in paragraph 121 is really seeking an architecture
recommendation. The paragraph states in pertinent part, "... are the
issues that arise regarding 911 default routing sufficiently similar in
each state that we should consider referring the matters to NANC for a
*recommendation on a solution or set of solutions that could be used in
all states undertaking rate center consolidation*?" (Emphasis added).

As a result, additional discussion centered on the entity responsible
for proposed technical requirements, T1S1.6. As an example, LNP is a
national standard; when the number pooling standard is complete T1 would
be responsible to do that. The questioning of proposal technical
requirements or waiting for approval is a temporal issue. Paul Hart
stated that a stable set of standards are required before a vendor can
manufacture the software. In response to a question concerning what is
the relationship between ANSI and T1, Dan Hochvert explained that
national standards for LNP were directed to T1. The T1 specification is
the national standard. Equipment vendors built it to the national
standard. Certain specifications continue to be identified by T1S1.6 to
build or not to build the requirements. Mr. Hochvert further clarified
that T1S1 is a small part of the overall T1 committee, and that ANSI is
a group that sets up the process by which standards are agreed to and
reviews the overarching agreement to ensure that good process was used
in arriving at establishing a standard. Gerry Rosenblatt, TIA added that
ANSI conducts an accreditation process and committees may be later audit
by ANSI. Ed Gould reminded the Council that the establishment of LNP
standards was not done in a traditional manner -- but rather at the
state level.

Chairman Binz suggested forming IMG's with volunteers for approximately
2 months to tackle issue in paragraph 38, recommendation regarding
measure to be adopted with FCC rules. This issue has an August 30, 1999
deadline. It was agreed that an IMG will be formed with the following
participants: Bell Atlantic (Jo Gallagher or Jim Castagna), NARUC (Erin
Duffy); OPASTCO (Trent Boaldin); MCI WorldCom (Karen Mulberry); SBC
(Bill Adair); NCTA (Beth O'Donnell), Nortel Networks (Joe Kingrey); PCIA
(Robert Hoggarth); Sprint (Ron Havens) and Nextel (Larry Krevor). Bell
Atlantic will organize the first conference call/event.

In response to paragraph 165, exhaust model, it was agreed that an IMG
will be formed with the following participants: USTA (Tony Pupek); NCTA
(Beth O'Donnell); Omnipoint (Carl Hansen); Nortel Networks (Joe
Kingrey); CTIA (Lolita Smith); PCIA (Rob Hoggarth);

MCI WorldCom (Steve Addicks); GTE (Norm Epstein); Nextel (Bob Edgerly);
SBC (Bill Adair); AT&T (Ed Gould) and Bell Atlantic (Jo Gallagher). LM
NANPA is invited to participate. USTA agreed to facilitate the first
event. The IMG's response is due at the August 24-25, 1999 meeting so
that NANC can comment within the reply comment period.

In response to paragraph 90, audit information and procedures -- it was
agreed that this issue will be referred to the existing Audit IMG. With
regard to paragraph 88, apportionment of audit responsibility, the Audit
IMG report to NANC of June 23, 1999 is responsive to that point.

In response to paragraph 184, recommendation of what entity should serve
as a pooling administrator, the existing Number Pooling Administration
IMG, will provide its report and recommendation on the LM bid to the
full Council for discussion at the July NANC meeting. Thereafter, NANC
will forward a progress report to the FCC.

Chairman Binz reminded the Council and the newly formed IMG's that an
early report is desirable, but all reports should not exceed the August
24-25 NANC meeting for full Council approval before the August 30, 1999
reply comment period. In particular, paragraph 38 (which measures should
be adopted as FCC rules) is a very important issue and the FCC is
expecting something significant from NANC on this matter.

***N. Audits Issue Management Group (IMG) Report***. Karen Mulberry, MCI
WorldCom provided the report to the Council. The Audit IMG was tasked to
investigate issues raised in the NANPA April 7, 1999 which suggested
that NANPA was not responsible for audits, and consider issues later
raised through discussion at the May 1999 NANC meeting regarding NANPA's
obligation to conduct audits under the fixed price bid. Ms. Mulberry
drew a distinction between auditing and verification. After an audit is
performed, the NANPA may need to acquire additional information from the
service provider. With regards to the Audits IMG's recommendation,
Lockheed Martin understood, in its numerous responses, its
responsibilities to administer industry guidelines, which establishes
NANPA audit responsibilities of the application provided by a service
provider when requesting an NXX. Lockheed Martin also provided
references to the auditing framework and aging documents. These
obligations and responsibilities, however, are future responsibilities
that are not included in any existing industry guidelines. The NANC has
done some work in this area but nothing has been put in place. The Audit
IMG recommends that the NANC develop an auditing requirements document
and solicit a competitive bid from the top five accounting firms. The
requirements document should include sections on auditing the NANPA and
all service providers based on assignments.

Ms. Kistner questioned the ambiguity in the recommendation, which
suggests that the IMG determines that there are already baseline audit
responsibilities in the NANPA contract, but also recommends that
auditing requirements be opened to competitive bidding. Ms. Mulberry
replied that the IMG was trying to address the fact that the NANPA
letter mentioned some future auditing activities, which were the
auditing framework documents being developed by the NANPA Oversight
Working Group and the NANC's document on aging and administration of
numbers. These are future activities, with potential changes to industry
guidelines, and it could be useful in managing the audit process if they
were all incorporated into one requirements document. The baseline audit
responsibility would remain in the administrator's realm to verify and
ensure that the details on the application remain true and accurate.

Mr. Guggina requested clarification on whether the NANPA would actually
visit a service provider to perform "for cause" audit of its records and
assignments. Ms. Mulberry replied in the affirmative and further
explained the types of audits to be performed by, and what are the
NANPA's responsibilities in this regard. Basically, there are three
types of audits: (1) verification during the application process; (2) an
audit triggered by something, and (3) random or scheduled audits. Future
work, and the details concerning the application of random and other
audit types are contained in the Audit Framework document that the NANPA
Oversight Working Group is currently drafting. The Audit IMG determined
that this future work that may be better managed by selecting an auditor
through a requirements document and a competitive bidding process to
select an auditor.

Ms. Kistner noted the types of audits mentioned in paragraphs 84-86 of
the FCC's Numbering Resource Optimization NPRM: for cause, regularly
scheduled, and random. Ms. Mullberry commented that these terms are also
used in the Audits Framework document. Ms. Kistner questioned whether
the group determined that the NANPA contract covered "for cause" and
regularly scheduled audits, but random audits would be performed by
another party. Ms. Mulberry replied that the NANPA contract covered for
cause audits that only concern application information needing further
scrutiny. Regularly scheduled and random audits are contained in the
draft audit framework document and are being discussed by the NANPA
Oversight Working Group.

Jim Castagna, Bell Atlantic, commented that the baseline includes
examination of the criteria and basic eligibility of a service provider
applying for resources. In performing its day-to-day activities, the
Audit IMG felt that if the NANPA had questions about service provider
eligibility, then it should have the opportunity to perform an audit.

***O. Presentation by Lockheed Martin CIS. *** Jeff Ganek stated that LM
strongly agrees with the Audit IMG's report. The LM letter of April 7,
1999, to Chairman Hasselwander inferred that NANPA is not responsible
for verification. Mr. Ganek apologized for the misunderstanding
generated by the correspondence on this issue. The intent is for NANPA
to provide all the services needed and verification of the application
process is included the fixed price bid. NANPA is available to work with
both the NANC and the industry to understand what is included in a
verification process and strive to meet those requirements. There are
extensive audits with firms qualified to conduct such audits. NANPA will
help to specify requirements and provide assistance to the Audit IMG.
NANPA agrees that it is responsible for "for cause" audits in the
application verification process.

P. ab*** Other Business.*** None

Q. ab*** Next Meeting***: July 20-21, 1999.

VI\. ab** Action Items and Decisions Reached. **

1\. ab[Local Number Portability Administration Working Group (LNPA
WG]{.underline}). NANC will continue wireless pooling evaluation
discussion at July NANC meeting. More information and input on barriers
to wireless service providers\' participation in Thousands Block pooling
absent full Phase 2 deployment is needed.

LNP Problem Identification and Management (PIM). The LNPAWG is to
consider that the April 1999 NANC recommendation concerning LNP PIM is
official, requiring LNPA WG action as outlined in the April meeting
record. The WG should not be distracted by questions of authority and
enforcement. NANC will deal with those concerns as stated in the April
meeting record. The WG should consider accelerating its process and
attempt to complete its recommendation for the July NANC meeting due to
the fact that PIM scope need not be addressed.

2\. ab[N-1 Query Issue.]{.underline} A follow-up NANC letter will be
developed for transmittal to T1S1.6 regarding the Telcordia contribution
matter. The letter will state that, based on the Telcordia presentation
at the June meeting, NANC has determined that there are no policy issues
attributable the proposed contribution.

3\. [Numbering Resource Optimization (NRO) Working Group
Report]{.underline}. NANC will forward

basic recommendation to FCC with a cover sheet explaining the origin of
the report and NANC modifications to it. Text added to the report will
be highlighted so it can be easily identified. The WG will develop pert
chart/basic time line structure for later submission to the FCC.

NANC strongly favored NPA-NXX reporting in non-pooling areas within the
exhaust window. NANC was split on disaggregated number reporting.
Negative voting parties indicated willingness to consider more detailed
reporting in the future.

Nextlink revision to footnote in the draft document provided by Chairman
Binz was accepted. Additional changes to Report pages 35 and 36 worked
during NANC meeting \-- NRO Chairs are custodians of those online
changes. For consistency, corrections will also be required in the
Executive Summary. The NANC Chair and NRO leaders will craft text/letter
forwarding to the FCC; NANC members will be accorded brief review of
details before forwarding.

4\. [Steering Group Report]{.underline}. Number Pooling IMG
recommendation for a competitive bid process was announced and will be
discussed during a closed portion of the July NANC meeting. Only NANC
members and alternates who have signed non-disclosure agreements and FCC
staff will be allowed to attend the closed session. In advance of the
July meeting, NANC members must advise via email their intention
regarding attendance at the closed portion of the meeting (primary
and/or alternate member). The non-disclosure agreement may be obtained
from Jeannie Grimes, FCC (jgrimes@fcc.gov).

5\. ab[Cost Recovery Working Group]{.underline}. Issue of business
arrangement between NANPA in pooling administrator role and the NPACs is
being worked. A draft recommendation was provided to the NANC and will
be discussed at the July NANC meeting.

6\. ab[1999 COCUS Update]{.underline}. John Manning, LM, provided
response to May 25-26, 1999 action items on 1999 COCUS and NPA Exhaust
Analysis Report. NANPA Oversight Working Group will explore its role in
collecting and acting on reporting data for industry segments.

7\. ab[Industry Numbering Committee (INC) Report]{.underline}. INC
presentation with regard to resellers reporting forecast and utilization
data on number resources. NANC will consider whether to modify its
current policy position on this issue at the July meeting in conjunction
with the INC report. NANC will attempt to invite resellers (possibly
TRA) to join discussion.

8\. ab[Assignment Responsibilities under CC Docket 99-200]{.underline}.
In response to NPRM paragraph 38, recommendation on which administrative
measures should be considered for possible FCC rules, an IMG will be
formed with the following participants: Bell Atlantic (Jo Gallagher or
Jim Castagna), NARUC (Erin Duffy); OPASTCO (Trent Boaldin); MCI WorldCom
(Karen Mulberry); SBC (Bill Adair); NCTA (Beth O'Donnell), Nortel
Networks (Joe Kingrey); PCIA (Robert Hoggarth); Sprint (Ron Havens) and
Nextel (Larry Krevor). Bell Atlantic will organize the first conference
call/event.

In response to paragraph 165, exhaust model, an IMG will be formed with
the following participants: USTA (Tony Pupek); NCTA (Beth O'Donnell);
Omnipoint (Carl Hansen); Nortel Networks (Joe Kingrey); CTIA (Lolita
Smith); PCIA (Rob Hoggarth); MCI WorldCom (Steve Addicks); GTE (Norm
Epstein); Nextel (Bob Edgerly); SBC (Bill Adair); AT&T (Ed Gould) and
Bell Atlantic (Jo Gallagher). Lockheed is invited to participate. USTA
will facilitate first event. Response due at August NANC meeting so that
NANC can comment within the comment cycle.

In response to paragraph 90, audit information and procedures -- this
will be referred to the Audit IMG. With respect to paragraph 88,
apportionment of audit responsibility, the Audit IMG report to NANC of
June 23, 1999 is responsive to that point.

In response to paragraph 184, recommendation of what entity should serve
as a pooling administrator, the Number Pooling Administration IMG at the
July NANC meeting, will provide its completed report and recommendation
on the LM bid to the full Council for discussion. Thereafter, NANC will
forward its progress report to the FCC.

9\. ab[Audit Issue Management Group (IMG)]{.underline}. NANC accepted
report provided by IMG for "for cause audits" pursuant to INC
guidelines; NANPA Requirements Document and *Third Report & Order*. NANC
will determine group to begin development of requirements document for
audits other than "for cause audits." Audit IMG will work with LM on
clear definition of responsibilities and functions.