### North American Numbering Council

## Meeting Minutes

September 28-29, 1999 -- *final 10.20.99 *

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

***II.** ** List of Attendees:***

# [Voting Council Members]{.underline}:

1\. Beth Kistner ALTS

2\. Shawn Murphy AT&T Corp.

3\. Dan Hochvert Bell Atlantic

4\. Terry Monroe/Jonathon Lee CompTel

5\. Ron Binz CPI

6\. Lolita Smith CTIA

7\. Norm Epstein GTE

8\. Karen Mulberry/Peter Guggina MCI WorldCom

9\. Gerry Thompson Mobility Canada

10\. Erin Duffy NARUC

11\. Vincent Majkowski NARUC

12\. Amy Putnam NARUC

13\. Andrew Ulmer NASUCA

14\. Phil McClelland NASUCA

15\. Beth O'Donnell NCTA

16\. Larry Krevor/Seth Jones Nextel Communications

17\. Dan Gonzalez NextLink Communications

18\. Ray Strassburger Nortel Networks

19\. Carl Hansen Omnipoint

20\. Trent Boaldin OPASTCO

21\. Harold Salters PCIA

22\. Bill Adair/Gilbert Orozco SBC

23\. Ron Havens Sprint Corp.

24\. John Hoffman Sprint PCS

25\. Ben Walston TIA

26\. Paul Hart USTA

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

Ron Conners NANPA

Maria Estefania ATIS

Brenda Stevens CRTC

[Commission Employees]{.underline}:

Diane Griffin Harmon, Designated Federal Officer (DFO)

Jared Carlson, Alternate DFO

Les Selzer, NSD, CCB Network Services Division, Common Carrier Bureau

## Tejal Mehta, NSD, CCB

Pat Forster, NSD, CCB

Jeannie Grimes, NSD, CCB

Aaron Goldberger, NSD, CCB

***III.** **Estimated Public Attendance***. Approximately 41 members of
the public attended the meeting as observers.

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

\(1\) Agenda

\(2\) August 28-29, 1999 NANC Meeting Minutes (draft)

\(3\) NANPA 1999 CO Code Assignment Activity Report

\(4\) NANPA Oversight Working Group Report

\(5\) Revised NANC Audit Framework Recommendation

\(6\) Audits IMG -- NANPA "For Cause" Audits

\(7\) Lockheed Martin NANPA Trial Audit presentation

\(8\) Number Resource Optimization (NRO) Working Group Report --

Telephone Number Reservations

\(9\) Dan Hochvert, et al., contribution regarding telephone
reservations

\(10\) Reseller and Type 1 Wireless Forecasting and Utilization Data
proposal

\(11\) Wireless Number Portability Subcommittee (WNPSC), Key Issues &

Action Items

\(12\) WNPSC Status Report Matrix

\(13\) Local Number Portability (LNPA) Working Group Report

\(14\) LNPA WG Advisory -- Problem Identification Management (PIM)

\(15\) Slow Horse Subcommittee Report

\(16\) IMG Paragraph 165 -- Draft Final Report

\(17\) Cost Recovery Working Group Update

\(18\) NBANC Update

\(19\) Industry Numbering Committee (INC) Report

\(20\) NPAC Oversight Responsibility Recommendation

\(21\) MCI WorldCom NPAC Feature Uniformity

\(22\) Lockheed Martin Number Pooling FAQ's

***V. ** **Summary of the Meeting:***

***A.** **Opening Remarks. *** Chairman John Hoffman provided the
opening remarks, expressing his pleasure and honor to be chairing his
first NANC meeting. A few house keeping and administrative matters were
addressed. With respect to the NANC charter renewal, a public notice (DA
99-1864) was released on September 13, 1999, announcing the General
Services Administration (GSA) approval for the renewal the NANC charter
through October 4, 2001.

Chairman Hoffman stated that a presentation by Deputy Chief, Common
Carrier Bureau, Yog Varma at the PSC conference in New Orleans on
September 21,1999 was informative, and provides an excellent overview of
the critical issues facing the NANC. Copies of the presentation were
provided to all interested Council members.

Chairman Hoffman stated that his goal is to provide an advance copy of
the agenda to Council members at least a week prior to each meeting.
Additionally, going forward the agenda will be standardized as much as
possible. He suggested that the NANPA's report be placed first on the
agenda to set the stage with respect to issues that are of concern to
the NANPA and to review where the NANC may be on such matters.

***B.** **Approval of Meeting Minutes***. The August 24-25, 1999 meeting
minutes were approved following adoption of suggested changes from
Philip McClelland, NASUCA, and Norm Epstein, GTE. Additionally,
non-substantive edits were provided off-line by Dan Hochvert, Bell
Atlantic.

***C.** **NANP Administration 1999 CO Code and NPA Assignment Activity
Report. ***John Manning presented the report, which covered both NPA and
CO code assignment activity (as of Sep. 20, 1999) to the Council. The
information was reported in a series of tables. Table (1) is a
generalized summary of the total resource, including how many NPAs have
been assigned and how many are available. Tables 2, 3 and 4 provide a
summary and estimates of the number of new area codes needed for the
year 1999 (Table 2), the year 2000 (Table 3), and the year 2001 (Table
4). Tables 5 and 6 update information on the 29 codes for the year 1999
and 37 codes for the year 2000 that were projected to go into service.

Table 1 shows the following; Of the 800 NPAs in the NANP, 362 NPAs
remain available; 80 NPAs are reserved for NANP expansion; 20 NPAs in
the 37X and 96X series are set aside per the Industry Numbering
Committee (INC) NPA Allocation and Assignment; 20 NPAs are being used
for various purposes (N11 (8); non-dialable toll points (2); Mexico
roaming (8); plus "950" and "555" (for feature group B and 555 service);
12 service codes are in use; 15 additional service codes are reserved
for PCS (6) and toll-free (9); 42 NPAs are assigned outside the US; and
249 NPAs are assigned within the US. The 8 non-dialable toll point NPAs
are scheduled for return in 2001. The Mexico roaming codes are scheduled
for release/return in January 2003. Three of the service codes in use
(880, 881 and 882) are for "toll free paid sent paid" calls to enable
toll free dialing outside the US; these codes are scheduled for return
in 2004. "Assigned" NPAs are no longer available for consideration and
are removed from the balance available. 43 of the 362 NPAs remaining are
easily recognizable codes (ERCs).

Table 2 shows the new NPAs implemented in 1999, and the start date of
permissive dialing (which is the effective date of the NPA). There are 4
NPAs for which the permissive dialing date has been delayed per state
commission order or, in the case of Illinois, the activation of the
relief NPA has been delayed as a result of number pooling. Code
reclamation may change exhaust estimates.

Table 3 summarizes projected new NPAs for the year 2000. The table
indicates that 45 relief NPAs are anticipated, several of which have
already been assigned. The projected exhaust dates for each relief NPA
are based on the 1999 COCUS. Table 4 summarizes projected new NPAs for
the year 2001; 31 relief codes are anticipated, with estimated exhaust
dates between 3Q2001 and 2Q2002.

Mr. Manning noted that, although Tables 2 and 5 each show 31 relief NPAs
for 1999, there is not a direct correlation in the NPAs identified on
each table. Table 5 shows the NPAs identified for relief in 1999 as
reported in the April NANP Exhaust Study. Table 6 shows the NPAs
identified for relief in 2000 as reported in the April NANP Exhaust
Study.

Mr. Manning discussed improvements in the NANPA's operations. The NANP
web site contains a variety of information including the status of NPA
relief activity, planning meetings, etc. A copy of the Aug/Sep 1999
NANPA newsletter has been issued. The newsletter discusses central
office code and NPA code assignment, and provides a list of other
industry and regulatory web sites. Also, the NANPA is moving from fax
distribution to application and assignment by electronic interface.

Mr. Manning discussed several action items from the August NANC meeting.

[Three-way split of Arizona NPA 602]{.underline}. Permissive dialing
began in March 1999. 37 NXX codes were duplicated in each of the two new
NPAs (480 and 623), although not the same NXXs were duplicated in each.
As of September 20, 1999, there are 228 available NXXs in 602, 512 NXXs
in 480, and 659 NXXs in 623. Carriers assigned NXXs prior to 5/1/99
could have requested to have a code duplicated in one of the new NPAs up
until 9/1/99. No additional codes will be duplicated in these NPAs.

Karen Mulberry, MCI WorldCom, asked whether there was a grandfathering
process in place to allow the alarm industry additional time to migrate
all of their customers. This question will be referred to the code
administrator for the 602 region and will be discussed at the next
meeting.

["Pent up" Demand]{.underline}. Large requests for CO codes in NPAs
coming out of rationing in the first half of 1999 were examined.
Approximately 200 to 250 NXX code assignments were estimated to be the
result of pent up demand. Mr. Manning cautioned that each NPA code
should be examined individually, because the actual demand in each NPA
varies.

Bill Adair, SBC, requested a status update on the Minnesota 602 and 610
relief situation. Mr. Manning will provide information on the number of
NXXs duplicated as a result of the split to the Council by e-mail.

Norm Epstein, GTE, questioned whether relief activity and activation of
new codes would be minimized in the last half of 1999 due to Y2K
concerns. Mr. Manning responded that he assumes the industry accounts
for Y2K concerns in establishing relief plans; he has heard of no
Y2K-related problems to date.

[August NXX code assignments]{.underline}. There were 1,386 gross NXX
assignments in August \-- this figure does not reflect any reclamation
that may have occurred; 1478 NXX assignments were made in July 1999.
NANPA introduced the issue of large volume CO code requests at the INC
September meeting. INC agreed to address what additional information the
NANPA could request to substantiate when the request does not match up
with the six-month history or the 12 month projected forecast. INC is
addressing this matter and NANPA will continue to work with INC. NANPA
is continuing to receive large CO code requests and, as a result, has
implemented a process to work with the service provider for additional
information and keep the FCC informed.

Bill Adair raised an issue regarding the Texas PUC's order for relief in
the 409 NPA. The Texas order alluded that the NANPA may not be willing
to conduct all the necessary implementation activities, and directed SBC
to facilitate the implementation process. The initial meeting will take
place in about one month, but several meetings beyond the initial
planning meeting are normally required to complete an NPA relief
project. It is NANPA's position that it is required to be involved only
with the first implementation and planning meeting for the introduction
of a new area code; thereafter, the service providers are responsible
for any additional meetings. SBC has asked NANPA to facilitate all of
the meetings needed for the entire relief process. It is NANPA's view
that this would be considered an enterprise service that it would have
to offer to everyone, and it is currently trying to gauge what the
demand is for this type of service. A NANC IMG previously addressed the
issue of NANPA's responsibility for the implementation process *vis à
vis *the NANPA requirements document and the FCC's rules and orders. By
the next NANC meeting, NANPA will clearly state a position on what it
believes to be its responsibility for participating the relief planning
process.

***D. NANPA Oversight Working Group.*** Pat Caldwell, Co-Chair, provided
the report to the Council. Mr. Caldwell gave an update on four areas
identified as needing improvement in the 1998 NANPA performance review:
(1) NANPA has established a mechanized way to distribute documentation
(access through the NANPA web site is explained in NANPA newsletter);
(2) NANPA's enterprise service for administrative OCN will be developed;
(3) review of the improved COCUS plan has been completed; and (4) NANPA
has created a training module for its relief planners to improve their
skills in administering or facilitating meetings.

A preliminary schedule has been established for the 1999 NANPA
performance evaluation. A survey is being developed and will be
presented to the NANC for its concurrence in November. A workplan and
entire survey package will be presented to the NANC at the December
meeting. The survey will be distributed to service providers on January
3, 2000. Distribution of the survey will be accomplished through key
industry associations and directly to each service provider using
NANPA's distribution lists. The surveys and the NANPA's annual report
are due in February. The WG will develop a draft performance evaluation
report during the first week of April for delivery to the NANC by the
May 23-24, 2000 meeting.

Two new issues will be addressed by the WG: (1) the volume of CO code
applications generated in California jeopardy situations, and (2)
NANPA/industry intellectual property rights. The first issue was raised
by Walter Mosely in a letter distributed by e-mail on September 15,
1999. The letter states that 9,000 of the year's nearly 24,000 CO code
applications through mid-September were in California. California
requires re-submission of a code request each month in order to be
eligible for the lottery, which results in a high volume of code
requests (currently a third of the nation's CO code applications). This
could trigger an increase in the cost of CO code administration
nationally because under the current fixed price contract, LM assumed an
average of 10,000 CO code requests per year over the five-year period.
If LM exceeded that amount by 120% it would be permitted to come back to
the Council and FCC for a price adjustment. The IMG wants to address
whether procedurally, the NANPA has to perform the full scope of
administration for the re-submittals month after month. The WG is
seeking concurrence from the NANC to monitor this situation and be
prepared to address it if necessary. Chairman Hoffman stated that it
should be monitored; more facts should be gathered and more analysis on
the practice and the associated costs should be done.

Karen Mulberry, MCI WorldCom, added that the California jeopardy
procedure and application process may be required under California law,
and offered to investigate the issue. Dan Hochvert, Bell Atlantic,
stated that California probably required this process with the goal of
establishing a more effective code assignment process based on
demonstration of a continuing need by each service provider. NANC should
first consider California's goal and whether the goal has been met. If
not, the process is just an administrative burden. If the goal has been
met, however, maybe the procedure should be expanded. Harry Monroe,
CompTel, requested clarification on whether California may be
considering eliminating the re-submission requirement, or if that in
fact happened. Mr. Caldwell responded that the requirement has not been
eliminated.

The second new issue is the identification of transferable intellectual
property rights under the NANPA contract. The NANPA has identified
software and intellectual property and related hardware. Some in the
industry opine that any major investment that was made with industry
money belongs to the industry and is therefore transferable. The WG
believes this issue will require regulatory and or legal analysis to
determine what intellectual property would transfer to a different
NANPA.

Paul Hart, USTA, commented that early on there was considerable
discussion about this issue and asked whether the WG had reviewed the
record to determine what commitments were made and whether they are
insufficient to address the concerns raised today. Karen Mulberry added
that there are different interpretations of the FCC's language in the
*Third Report and Order* and in the NANPA contract. There may be a need
for some additional legal advice to explain or interpret what the
language of the rule actually means.

Paul Hart suggested that the facts need to be assembled from formal
agreements and other records to properly address the issue. Chairman
Hoffman suggested that the WG better define the issue between now and
the next NANC meeting, identifying the different positions of the two
sides. Pat Caldwell responded that the WG brought it now without all the
details to alert the NANC that it is coming. The WG knows that it will
need some interpretations and will not be able to resolve the issue
simply from the documentation to be gathered.

Mr.Caldwell continued with an overview of the audit framework document.
The WG created a clearer definition of "for cause audits." The WG was
also tasked with addressing the issue of regulatory requirements as a
part of the audit. The final report was presented for NANC approval and
the WG recommended forwarding the final document to the Industry
Numbering Committee (INC). The definition was read into the record:
"*For cause audits are audits conducted on an entity to verify
compliance with established industry guideline(s) or conducted when
'unforeseen circumstances' arise related to NANP resources. The scope of
a 'for cause' audit will be limited to the circumstances related to the
cause identified. For cause audits can be initiated by the NANPA or by
the appropriate regulatory authority." *

Norm Epstein, GTE, stated that the term "unforeseen circumstances" is
vague and too open ended without examples. Mr. Caldwell responded that
the WG discussed using examples, and that all of the examples they
thought of were really foreseen \-- it is difficult to give examples of
things that are unforeseen.

Gilbert Orozco, SBC, noted that there is no discussion for companies
that do not submit forecast or utilization data to the NANPA, which was
part of the original problem in not getting accurate COCUS data. Failure
to report data should be a trigger for something \--an audit, for
example. Mr. Caldwell questioned whether that should be added to the
definition, since it is a process issue.

Beth Kistner added that failure to provide COCUS data should result in
non-assignment of the resource, not trigger an audit. Karen Mulberry
added that the recent NANC recommendation in response to NPRM Paragraph
38 addresses some of these issues, as well as the NRO Report on the
COCUS replacement tool, which also recommended similar changes going
forward. In practice today, however, there is no automatic denial of
assignment of NANP resources for not submitting COCUS information.

There was discussion on whether the definition should remain broad or be
narrowed to cover specific matters. Other issues addressed were the need
for an explicit statement that there is a reason for the audit (to
distinguish for cause from random audits); what entities are included in
"appropriate regulatory authorities"; who pays for the audits; what
guidelines will compliance be measured against; and whether the auditor
can seek information from resellers/end users.

There was additional discussion on NANPA's role in determining whether
there has been a violation and thereby triggering an audit, and on
states' ability to trigger an audit. Vince Majkowski stated that states
can initiate show cause audits, and that the industry should not try to
narrow the definition in a manner that takes away the states' regulatory
responsibility for the public interest. Colorado subpoenaed information,
and it worked. Utility commissions have that responsibility and will
exercise their audit responsibility.

In response to a concern raised, the IMG agreed to clarify that the
audits will only address numbering issues. The role of the auditor is to
verify data -- what the service provider reports and that the end user
got what it asked for. Chairman Hoffman stated that the document gives
states the right to ask for an audit, which they will use to get
information to supplement a broader state proceeding. Karen Mulberry
added the WG was trying to address is the situation in which carriers
are obtaining resources without the appropriate state certification. For
a for cause audit, NANPA must first suspect something.

Shawn Murphy commented that the framework document is a good document
and should be forwarded to the INC. The Council agreed to finalize the
document at the next meeting. Comments and suggested edits are to be
sent to the OS WG Co-Chairs by October 15, 1999.

***E. NANPA Interim Audit Process Results. ***Ron Conners, Director,
NANP Administration, provided the report to the Council. Bell Atlantic
volunteered to be one of the first service providers for the trial
audit. The trial attempted to get service providers to volunteer from
each industry segment because each industry segment manages its
resources slightly differently. The results of audit are confidential;
the point was to learn more about creating an audit program. NANPA
looked at 5 NPAs with 21 recent code requests to verify the existence of
the Months-to-Exhaust (MTE) forms. Results are confidential and may be
shared with regulators, but in general audit data is not made public.
There were no penalties to be levied in the trial audit process.
Chairman Hoffman questioned whether an officer of the company was
present. Dan Hochvert stated that since this was a trial audit Bell
Atlantic did not have an officer present.

Beth Kistner asked whether NANPA was able to establish a cost for the
audit based on the length of time required. Mr. Conners responded that
it would be very hard to predict, adding that auditing is a
labor-intensive process. With respect to staff estimates, it required
one staff month of Ron Conners and Bruce Bennett to conduct the audit.
Switch data could be used to substantiate number utilization, which was
not part of this trial audit.

***F. Number Resource Optimization (NRO) Working Group Report. ***Mike
Whaley, Co-Chair, presented the revised report on reserved telephone
number reservations. The modifications as directed at the last NANC
meeting were incorporated. Dan Hochvert, with Ron Havens, Bill Adair and
Philip McClelland, worked the issue, and provided a document that
recommends a threshold of 30 reserved numbers for mandatory customer
notification.

Beth Kistner asked whether there is data on how many existing
reservations are for 30 or more numbers. Dan Hochvert responded that the
majority of reservations are for a few numbers, and that reservations
for less than 30 numbers have been easily resolved. Ron Binz stated that
the discussion was going off course; the Council had not yet agreed to
set a threshhold. He added that the intended purpose of a LEWA was to
reduce the number of problems associated with the porting of reserved
numbers to another service provider, not consumer protection. Dan
Hochvert commented that the intent was to make sure customers were
protected and to reduce administrative burden. Tracking of all reserved
numbers should be a priority for all service providers from business
standpoint. The limit on reserve numbers per customer is by NPA and
further delineated by NXX.

Chairman Hoffman called the question of setting the threshold level at
30. There was consensus to modify the report accordingly. Sprint opposed
a notification requirement at any level; SBC and MCI WorldCom opined
that all customers should be notified. The characteristics for reserved
numbers will be added to the report. The policy will be effective going
forward and for existing number reservations. The NANC will forward the
report to the INC Moderator with a cover letter. The report will also be
forwarded to the Chief, CCB for information and will be filed with
Office of the Secretary as an *ex parte* in CC Docket 99-200.

***G.** **Reseller and Type I Wireless forecasting and utilization
data****. *Vince Majkowski, NARUC, presented the report to the Council.
A position statement was developed on this issue by Gilbert Orozco,
Karen Mulberry, Peter Guggina and Norm Epstein and e-mailed to Council
members prior to the meeting. Paragraph two of the statement was read
into the record:

*The code/block holders to whom the numbering resources are assigned
shall be responsible to report the name and contact information to the
NANPA of any reseller/type 1 wireless carriers who have obtained
numbering resources of more than 1,000 per NXX. The reseller/type 1
wireless carriers shall then be responsible to report their utilization
and forecast data to the NANPA directly; unless otherwise specified in
an interconnection agreement, business arrangement, contract or tariff."
*

TRA was not involved in this recommendation. Terry Monroe, CompTel and
Beth Kistner, suggested that the obligation to report number utilization
and forecast data could be limited to reseller/Type 1 wireless carriers
who have obtained individual blocks of number of more than 1,000 per
NXX. After some discussion the Council agreed to edit the statement to
add "of more than 1000 per NXX" at the end of the first sentence. Norm
Epstein commented that the recommendation is in concert with the
recommendation proposed by the INC, which places the reporting
obligation on the user of the resource. Mr. Majkowski added that
categorizing the numbers as "used" is considered utilization as well as
forecast data. Trent Boaldin commented that the INC asked NANC to
clarify the reseller obligation and that the report does this. If they
have questions they will come back to us at a later time. It was agreed
that the recommendation would be forwarded to the INC Moderator.

***H.** ** Local Number Portability Administration (LNPA) Working Group
Report. ***Charles Ryburn, SBC, Co-Chair, and Shelly Shaw, Ameritech,
Co-Chair, presented the LNPA WG Report. Anna Miller, BellSouth Cellular,
presented the Wireless Number Portability Subcommittee (WNP SC) Report.
Ms. Miller first reviewed the key issues addressed in the most recent
WNP SC meeting in September 1999. The Test Plan sub-working group met
for three days and identified 90 inter-carrier test scenarios in an
attempt to define inter-carrier testing areas for implementing wireless
number portability. The reseller options issue was closed with no change
to the current porting process, in which resellers port subscribers
through their facility based provider. In addition, Anne Cummins, AT&T
Wireless, was elected WNP SC Co-Chair. The WNP SC also reviewed Network
Interconnection Interoperability (NIIF) Issue 0130 and agreed to monitor
and to update as needed the NIIF LNP guidelines to incorporate wireless
LNP.

The following action items were reported on: (1) standards overview for
T1S1.6, TR45.2, and T1P1.5 committees \-- the missions, scopes,
published standards, and work plans of these committees will be
distributed to members prior to the October meeting; (2) continuation of
the Inter-carrier Test Plan development; (3) Operations and Billing
Forum (OBF) activity addressing directory listing requirements in an LNP
environment; (4) liaison letters for test coordination were sent to the
Regional Operation Teams, updating the Wireless Number Portability
Timeline for completing inter-carrier test coordination plans, and
including the WNP SC\'s recommendation for the inter-carrier
communication process; and (5) Co-Chair elections \-- Anne Cummins was
elected. Chairman Hoffman stated his belief that NANC approval is not
necessary for selection of task force or subcommittee chair positions,
only for working group level chair positions.

Anna Miller gave the WNP SC status report updates. Item one reflects
continuing work on the inter-carrier test scenarios. Item three regards
the standards overview presentation in the October WNP SC meeting. Item
nine, a newly added item, concerns WNP SC monitoring of NIIF LNP issues
and guidelines, and contributions to the NIIF, as needed, to reflect
decisions that affect wireless number portability implementation.

Mr. Ryburn continued with the LNPA WG Report. The LNPA WG has developed
a LNP Problem Identification Management (PIM) Process advisory letter
that was sent to the NANC, and will be sent to the NIIF, OBF, Committee
T1S1.6, the Regional Operation teams, the LLCs, INC, and ATIS. The
advisory was prepared to reflect the NANC's recommendation regarding the
PIM process. It includes items for which the LNPA WG is and is not
responsible. The advisory also explains the process for submitting
issues electronically using hyperlinks. In addition, the advisory
includes the LNPA WG meeting schedule for the remainder of 1999, copies
of documentation contained on the Issues web site (e.g., LNP PIM Scope,
the Issue Submission Form), and a hyperlink to the LNPA WG issue
tracking matrix.

Beth O\'Donnell, NCTA, asked whether the LNPA WG has established time
frames for the evaluation, resolution, and referral of issues. Mr.
Ryburn replied that the LNPA WG needs at least two weeks prior to the
LNPA WG meeting to address an issue. Ms. O\'Donnell expressed concern
about the delay that is often encountered in resolving problems that
occur daily. In one instance, the issue had not been resolved, and
instead had just been referred to the LNPA WG. Ms. O\'Donnell stated
that the ideal situation would be to have issues resolved within a
certain time frame, and that she did not want to see the LNPA WG to
become a dumping ground for issues that other groups did not want to
resolve. Mr. Ryburn concurred and stated that he would ask the LNPA WG
to develop a time frame for resolving issues. Ms. Shaw added that an
issue will be considered closed after three meetings if the party
responsible for raising it does not continue to provide information
concerning the issue or is not present to address the issue. To prevent
issues from being dropped inadvertently, Ms. Shaw stated that the issue
tracking matrix forms will be posted on the web site, where they can be
viewed and/or updated by any entity.

Trent Boaldin, OPASTCO, stated that Ms. Shaw\'s description of the
process raises concerns for small companies since an entity that raised
an issue may not be able to attend all the meetings during which that
issue is addressed. Ms. Shaw responded that PIM is now a standing agenda
item with a fixed starting time and call-in number so smaller companies
can fully participate, or can have a stand-in to champion their issue.
Mr. Ryburn replied in the affirmative to Ron Havens\', Sprint, question
whether other forums, such as NIIF, would receive the advisory. Norman
Epstein, GTE, suggested that the location and call-in number be
publicized. Mr. Ryburn noted that such items would be posted on the
Issues web site, and reiterated that the advisory will be sent to the
NIIF, OBF, Committee T1S1.6, the Regional Operation teams, the LLCs,
INC, and ATIS this week.

Beth Kistner asked how the advisory would be delivered to carriers that
do not participate in wide-spread forums. Mr. Ryburn stated that the
LNPA WG had not addressed that issue and could look into it. Paul Hart
volunteered USTA's services to assist with dissemination of information,
if necessary. It was also suggested that a link to information could
also be posted to the NANC web site, but care must be taken to avoid
confusion about the origin of a document.

Mr. Ryburn presented the Wireline/Wireless Integration Report portion of
the LNPA WG Report. At the August NANC meeting, GTE brought in a
contribution expressing concern about E911 and slamming problems
connected with the alternative to shorten the wireline to wireless
porting interval. The LNPA WG decided to accept the report in last
month\'s meeting, but with the caveat that the LNPA WG would continue to
examine the E911 issues raised by GTE. The LNPA WG will deliver a
revised report to the NANC by second quarter 2000. This is due to the
prioritization of change orders and the requirements development for
release 4.0.

Dan Hochvert, Bell Atlantic, asked whether the E911 issue only concerns
accelerating the porting interval, and not all other potential E911
problems. Mr. Ryburn replied affirmatively and stated that the E911
concerns are caused by the period of mixed service, where the wireless
phone has been activated, but the wireline phone has not been
disconnected. Mr. Ryburn stated that if the phone is disconnected on the
wireline side at the same time it is connected on the wireless side,
then there are no problems. Mr. Hochvert suggested that the real problem
is that some wireline carriers cannot yet shorten the porting interval
to less than four days. Mr. Ryburn replied that the real problem is
activation in the NPAC before complete disconnect in all operating
systems of the wireline carrier.

Mr. Ryburn continued with the LNPA WG report presentation. The LNPA WG
previously recommended to the NANC that a Y2K quiet time be established
from 11/1/99 to 3/1/2000 for NPAC/SMS release. LNPA WG members expressed
concern about the ramifications of the quiet period. Notably, since new
service providers would only be able to access the NPAC via dial-up to
the LTI or through an existing service bureau\'s connectivity, this
would limit the ability of new service providers to implement and test
any new connectivity during the quiet period. Gene Johnson, LM,
clarified that the NPAC would be able to work with any new provider
requiring connectivity or testing during the quiet period as long as the
carrier did not require any hardware installation and did not perform
any software upgrades to the current system that would invalidate Y2K
testing.

The LNPA WG has begun change order prioritization for Release 4.0, and
will begin to develop change order requirements over the next few
months. Anne LaLena, MCI WorldCom, reported that the Southwest LLC
expects to attempt to vote on Release 3.0, already approved by one LLC,
at its October meeting. The pooling activation problems that were
encountered with the installation of Release 2.0 in the Mid-West Region
were not caused by a lack of regression testing, but were mainly related
to the lack of detailed Methods and Procedures (M&Ps) and problems with
status updates. These issues are currently being addressed. Ameritech
identified three areas of the installation process that needed updates:
(1) Lack of status updates, (2) SP regression testing, and (3) pooling
activations. These three steps noted in the NPAC/SMS Release Status
Report will be added to the Status Update project plan.

Paul Hart asked what entity coordinates the upgrade to the new release.
Mr. Johnson stated that there is no oversight project person. Mr.
Johnson also noted that, previously, the pooling M&Ps were not
coordinated with NANPA release implementation guidelines, but this has
since been remedied, and pooling is no longer done at the same time a
release is implemented. Discussion of the issues concerning the
consolidated management team and Statement of Work 15 was deferred until
the Wednesday, October 20, meeting.

Regarding the majority of the LLCs not accepting Release 3.0, Anne
LaLena stated that, even after consolidation, there is no guarantee that
the other 4 LLCs will accept Release 3.0.

Steve Addicks, MCI WorldCom, presented the Slow Horse report to the
Council. Second drafts of two Local Service Management System (LSMS)
requirements have been completed. NPAC modification is required in order
to monitor and measure LSMS availability. This and other change orders
being considered for Release 4 will be addressed in the next LNPA WG
meeting. For the LSMS performance requirement, the speed of telephone
number (TN) broadcasting to LSMS during NPAC processing of ported number
activation is needed. The Northeast LLC requested this information from
the NPAC vendor, which has provided a statement of work. Also, the NPAC
vendor is considering whether it is appropriate to release this possibly
proprietary information to a public forum. The Slow Horse Subcommittee
has also considered an alternative to the peak LSMS performance
requirement, which involves an NPAC modification to smooth the rate at
which ported TN information is broadcast. This NPAC modification is not
trivial, however, and may not be the best approach.

#### September 29, 1999

***I. Paragraph 165 IMG **--** CC Docket 99-200 Final Report. ***Tony
Pupek, USTA presented the report to the Council. The IMG focused on the
effect of pooling during its conference call. Chairman Hoffman asked
whether the IMG proposed sending the entire document to the FCC. Mr.
Pupek responded that the report, which contains two sections, could be
sent to the FCC in its entirety

Chairman Hoffman noted that paragraph 165 is a little confusing, but
seems to be asking for NANC input in the form of general comments on
pooling, and specifically on CMRS. The first section of this report
shows NANC's general support for pooling, and the second part goes on to
show wireless pooling issues. The comment period is closed, but the
feeling is that these issues are too important to remain silent on. It
was suggested that the report be provided to the FCC as late filed or as
an *ex parte* so that the Commission has the NANC view on this matter.
Vince Majkowski stated that NARUC did not provide direct input to the
IMG report, but is willing to accept this as a compromise position. Mr.
Majkowski further noted that with regard to LNP and non-participation in
pooling, lots of state initiatives have been to do pooling and
sequential number assignment in areas outside the top 100 MSAs.

Norm Epstein added that Section II.B recommends further refinements or
embellish-ments to the NANP Exhaust model. Chairman Hoffman stated that
the NANPA Exhaust model should be considered a work in progress; we need
to refine the assumptions as we look at results, and keep refining the
model as we know more. A formal NANC action item to tell NANPA to keep
refining the model does not seem necessary. Mr. Pupek expressed concern
that there was no schedule or prioritization to look at these items \--
enhancements to model, additional modules, etc.

Paul Hart, USTA, suggested that it is extremely important that NANC have
an ongoing, formal interaction with LM on those activities. Chairman
Hoffman suggested that he personally could work (within the next 30
days) with NANPA on these issues. That is, find out what they are doing,
what progress is being made, what is the schedule they are operating on
and what are their goals. The feedback on those questions could be part
of the standing NANPA report to be provided by John Manning at the
October meeting. There was no objection to this suggestion. Tony Pupek
added that the message should be clear that the industry and NANC want
to work with LM on the Exhaust model and come to agreement on the model.

Beth O'Donnell, NCTA, suggested that the report address an issue raised
in correspondence from the Council to the Chief, Common Carrier Bureau
in 1997, which sought guidance on defining the term technology neutral.
In response to this issue, some Council members opined that paragraph
165 does not deal with the technology neutral issue.

Lolita Smith, CTIA, stated that the FCC does not know what the technical
effect of CMRS non-participation on exhaust of the NANP is and that is
why the question was raised, *i.e.,* what is the effect of such
non-participation on the life of the NANP. The final IMG report document
answers the FCC's question. After some discussion, the Council decided
not to address the issue of technology neutral in this report.

There was additional discussion on whether to send the entire report
document forward as is or modify it by eliminating the suggestion of
further work on the NANP Exhaust model. Ron Binz, CPI, recommended that
section II.B not be included in the report because it was unsolicited
and that it appears to undercut section II.A to some extent, and that
NANC should recast the report and simply report on what the Council
agreed upon. Chairman Hoffman disagreed, having sat in on some IMG
conference calls, stating that it is relevant because the content of
section II.B does modify II.A.

Chairman Hoffman noted that the NANC discussion is similar to the
downward spiral that the IMG faced. Paragraph 165 is like the Bible \--
you can find support for whatever you want to find. Diane Griffin
Harmon, DFO, offered that the entire report would be helpful to FCC. In
light of the discussion and FCC comment, the Council reached consensus
to send the entire report to the FCC.

***J. Report of the Cost Recovery Working Group. ***Anne La Lena,
Co-Chair, presented the report to the Council. Elsa Morris, Ohio PUC was
selected as CR-WG Co-Chair, replacing Frank Meeks, SBC, and was affirmed
by the Council. Cost recovery for audits that are not "for cause" audits
will be funded by the NANP recovery process. There was some discussion
regarding whether the entire industry should pay for "for cause" audits
under NANP funding factor.

Chairman Hoffman stated that the goal is to develop a cost recovery
recommendation, which requires an audit framework as a first step. Shawn
Murphy commented that with respect to carrier audits, INC will not deal
with associated costs \-- only guidelines for conducting such audits.

Ms. La Lena stated that the CRWG is reviewing past and present audit
work and will go to NANPA OS and Audits IMG for guidance and to make
clear that no conclusion has been reached. She further stated that
anything new requiring funding in the Year 2000 that is not part of the
Requirements Document is considered an enterprise service. Chairman
Hoffman suggested that the CRWG come back with a high level
recommendation on the categories of costs associated with such audits at
the October meeting.

[NBANC Report]{.underline}. Vince Majkowski provided the report to the
Council. At the August NANC meeting, Mary Pat Brennan, NECA, reported
that a letter would be sent to all carriers explaining the change in
revenue reporting and the funding process for Year 3. A full update on
this matter will be provided to the Council at the October NANC meeting.
The matter of random audits will have to be considered in the funding
factor.

The fund status financials were read into the record. The current fund
balance is \$1.43 million; projected receivables total \$1.2 million,
with payments to LM to date total \$2.14 million, with remaining
payments totaling \$2.14 million. Payments to NECA total \$129K to date
with remaining payments totaling \$128K. Board expenses are \$8,638;
this includes member reimbursement of \$6,248 and meeting expenses of
\$2,390. Payments to an external auditor, Price Waterhouse Coopers, to
date are \$19.2K, with a year two projection of \$22K.

Chairman Hoffman provided an update on the LLC conference call that both
he and FCC staff members attended. During the call it was announced that
as of November 1, 5 LLCs will be merged into one. The first meeting of
the newly consolidated LLC will be held on November 11^th^. However,
regional NPAC contracts will still be maintained separate. With respect
to SOW 15 and Release 3.0, only one of the 5 LLCs have adopted it. It
was reported that this will be one of the issues the consolidated
management will deal with quickly. Chairman Hoffman suggested that NANC
send a letter to all 7 LLCs recommending adoption of SOW 15 and seek an
explanation as to why or why not approval has not been granted.

***K. ** **Industry Numbering Committee (INC) Report***. Shawn Murphy,
AT&T, INC Moderator, presented the INC Report to the NANC. Initially,
Mr. Murphy covered the report overview listed on page two. Page three of
the INC Report contains a list of INC meetings held since the last NANC
meeting. A full-session conference call was held August 30, 1999, during
which ten issues were closed, mostly concerning thousands-block pooling
administration guidelines. On September 10, 1999, a partial-session
Carrier Identification Code (CIC) conference call was held to address
CIC treatment with partial acquisitions. In addition, a full INC meeting
was held September 13-17, 1999, in Portland, Oregon.

Page four of the report summarizes the LNPA Workshop activity at INC45.
Two new issues were introduced, the most significant to NANC being
GS-147, which is the action item from the NANC to INC to synchronize the
guidelines with the agreements reached by the "1K Bid-IMG" team. The
Thousand Block Pooling Administration Guidelines will be reissued in
December 1999. An interim LNPA Workshop is scheduled for October 26-27.
Page five of the report lists three LNPA Workshop issues that moved to
final closure.

The first Audit Workshop meeting was held at INC45 on September 16,
1999. Page six of the INC Report contains a mission definition, and page
seven contains the Audit Workshop scope. The Audit Workshop will provide
future reports to the NANC on an as needed basis, such as when a policy
issue is encountered. Page nine of the INC Report contains an agreement
reached by participants that the frequency of audits for all numbering
resources is beyond the Audit Workshop's scope because the INC does not
address policy or cost issues. Page ten of the report contains the INC
Meeting Schedule and Logistics for the remainder of 1999.

Norman Epstein, GTE, suggested that the NANC develop guidelines for
performing audits, especially addressing frequency and cost recovery
issues. Chairman Hoffman noted that the Cost Recovery Working Group has
already been tasked to examine such issues for NBANC. Beth O'Donnell
questioned whether a formula exists to calculate the cost of audits
based on a given frequency. Without a set methodology and concrete data,
then costs can not be determined accurately. Peter Guggina, MCI
WorldCom, suggested the need for professional advice to determine the
size of the universe and frequency of audits needed. Carl Hansen,
Omnipoint, concurred, and suggested the Cost Recovery WG be supplied
with a set price for audits, and asked to determine how many audits can
be performed for that price. The NANC, not the INC, however, will
determine the frequency of audits.

Dan Hochvert suggested random audits could be performed in order to
influence other carriers' behavior concerning numbering resources. Anne
La Lena suggested that the Cost Recovery WG could give a "best" estimate
of the number of audits possible for a given dollar amount. In response
to Chairman Hoffman's question abut whether the WG will consult with
accounting firms, Ms. La Lena answered that the Cost Recovery WG will
obtain more information on audit procedures and scope from the NBANC
auditor. Norm Epstein expressed concern about the difficulty of drafting
guidelines and determining costs without knowing what an audit entails
and how many will be performed. Chairman Hoffman concurred, but said
that, nonetheless, an attempt must be made.

Peter Guggina suggested that the Cost Recovery WG is perhaps
unnecessarily working on audit requirements, which are the IMG's
purview, rather than working solely on cost recovery. Chairman Hoffman
concurred. Mr. Guggina stated that the INC should determine the
frequency and scope of audits and questioned when and how the shifting
of duties occurred. Mr. Guggina suggested that the Audit IMG is more
qualified to determine the audit performance requirements. Chairman
Hoffman noted the apparent overlap between the two groups.

Paul Hart noted that the NANC will make the final decision and the Cost
Recovery WG has volunteered to provide the first input. Shawn Murphy
expressed support for Peter Guggina's position, but also supported
Chairman Hoffman's suggestion that the IMG and the Cost Recovery WG
could work together. Chairman Hoffman asked Ann La Lena to communicate
the Cost Recovery WG meeting schedule to the IMG. Ms. La Lena stated
that any estimates the Cost Recovery WG makes will only be at a high
level, and the WG will work with the Audit IMG.

With respect to NANP Expansion, the INC received a letter from Canadian
Radio-Television and Telecommunications Commission (CRTC) dated August
13, 1999, regarding the INC NANP expansion activity and requesting that
INC consider examining the network destination code (NDC) options and
perform a detailed analysis. Mr. Murphy stated that INC will address the
request at INC 44 and will provide an interim expansion report and
update to the NANC at the December NANC meeting following the INC
November NANP Expansion workshop. For information, a soft copy of the
CRTC letter will be provided to all the NANC members by e-mail.

***L.** **Steering Group Report. *** Vincent Majkowski, SG Co-Chair,
provided the report to the Council. With respect to the status of the LM
Warburg transfer, Diane Griffin Harmon, DFO, noted that the Commission
is continuing to work on this matter and expects to release an order in
the very near future. There was a discussion concerning the NRO WG
assignments. At this time there are no further assignments pending. Beth
O'Donnell requested consideration of a future role to monitor number
pooling, and to investigate UNP and ITN. This led to further discussion
for the possible restructuring of NANC and its working groups and the
use of IMGs versus standing working groups. The SG members were asked to
provide input as to the roles of each group to see if there is any way
to increase the efficiency of the organization.

The NANC 2000 meeting schedule was approved; meetings will be held on
the following dates: January 18-19; February 22-23; March 21-22; April
25-26; May 23-24; June 20-21; July 18-19, September 19-20; October 17-18
and November 28-29. There will be no meeting held in August or December
2000. The schedule will be posted to the NANC web page at
fcc.gov/CCB/Nanc.

With respect to technical and administrative support for the NANC
Chairman, Bonnie Baca is investigating setting up a Chairman's web page.
The web page will provide a central place for working group reports and
documents that must be available for NANC member review in advance of
the NANC meetings, and will contain links to the other related web
sites. The SG should conclude this matter at its next meeting and will
report the result to the NANC thereafter.

Chairman Hoffman introduced the idea of a public relations type campaign
as a way for the Council to articulate the challenges facing the nation
regarding number administration and the disruption of area code relief.
As an aside, Chairman Hoffman reported that the United States is not
alone in the numbering crisis matter -- that England is now going
through a third revamping of its entire number administration system.
The SG was asked to consider the initiative in light of the Yog Varma
presentation at the PCS 99 conference.

There was some discussion on the appropriateness of the NANC undertaking
such an effort. Dan Hochvert supported the concept stating that the
public is not as aware as the industry of this crisis and that it is not
too soon to get started. As individuals, NANC members and their
respective organizations have opportunities to spread the word. We know
what is going on and the public does not understand. The public would be
more receptive to changes if it fully understood what is going on. Trent
Boaldin, OPASTCO, stated opposition to a NANC PR campaign, adding that
educating the public is a carrier issue and association issue.

Chairman Hoffman referred to the New York Public Service Commission
letter of September 15, 1999 to the Chief, Common Carrier Bureau, which
states its objection to the NANC position regarding the rate center
splitting matter in Minnesota. The letter asserts that NANC took an
academic approach to the issue and did not consider the real life
situation facing PSC's \-- keeping their constituents happy. The
Chairman further opined that this enforces the Council's need to
consider its responsibility to educate the public. It is important that
the message is consistent. Several members agreed that there is a need
to heighten the public's awareness of the numbering crisis.

With regard to assignments of UNP and ITN to the NRO WG, Shawn Murphy,
AT&T, stated that the INC has accepted an issue to work UNP, but does
not want to impede its work on 1k pooling. A contribution from BellSouth
and BellSouth Cellular has been accepted. Dan Hochvert suggested and the
Council agreed that Beth O'Donnell should provide a proposed NRO work
plan outline for consideration by the SG and the full NANC at its next
meeting.

***M.** **Proposed Recommendation on NPAC Oversight Responsibilities.
***Dan Hochvert, Bell Atlantic, provided a proposal to the Council. The
recommendation suggests that the LLCs should designate a person to keep
NANC updated on its activities. Peter Guggina also provided a
contribution which de-emphasizes the LLCs and shifts the focus to the
NPAC. NANC has oversight for LNP and NANPA. NPAC feature uniformity is
critical. Chairman Hoffman questioned whether the pending LLC
consolidation would assist in this regard. Mr. Hochvert responded that
there are 7 LLCs and one in Canada with which NANC has had no regular
communication established and there is a need to get the dialogue going
particularly concerning NPAC feature enhancements. Regular communication
with the LLCs is long overdue. Carl Hansen added that with respect to
feature uniformity and NPAC upgrades, oversight should not be minimized.
Anne La Lena commented that the LLCs have in the past communicated to
the NANC. NANC's oversight responsibility in the *Second Report and
Order* was primarily for LNP implementation. Additionally, NANC has no
authority over the Canadian LLC.

It was agreed that Peter Guggina and Dan Hochvert will draft a letter
for NANC review to communicate with the LLCs concerning NANC
responsibilities pursuant to the *Second Report and Order,* and to
request that the LLCs report at the November NANC meeting regarding the
status of SOW 15 Release 3.0.

***N. ** **Other Business. ***John Manning advised that LM has developed
a list of FAQs regarding number pooling in response to numerous
inquiries on implementation of number pooling following the release the
September 15^th^ FCC orders delegating additional authority to four
state commissions to conduct number pooling trials. Barry Bishop, LM,
provided a brief overview of the content of the FAQs. LM has developed a
separate web site, numberpool.com, to facilitate getting the information
out to interested parties on the status of the Illinois number pooling
trial and others. Mr. Bishop further explained that numbering pooling
from an administration standpoint could be implemented in 2-4 months.
This does not include the full range of activities necessary for full
implementation by service providers. The amount of time needed would
vary greatly because no two service providers would have the same
issues.

Paul Hart stated that the intended message may be misunderstood due
largely to an imperfect understanding of number pooling and the status
of NPAC upgrades. Mr. Bishop explained that pooling can be done with
Release 1.4, which is now available in all regions. Release 3.0 is
scheduled for June NPAC implementation and should be fully available by
3Q 2000. It will be released in the Mid-Atlantic region for testing at
that time.

Carl Hansen stated there is a concern that states will think that number
pooling is a way out of NPA relief planning. Mr. Bishop responded that
indeed number pooling is no magic bullet and added that the
effectiveness of number pooling will vary because no two NPAs are the
same. Peter Guggina asked whether LM would accept comments and
suggestions on the content of the FAQs handout. Mr. Bishop stated that
LM would take all comments and suggestions that are offered.

Dan Hochvert asked about the status of the FAQs, expressing concern that
some damage may have already been done. There is concern about
uniformity of NPAC releases. The emphasis should be on a path forward
with a national orientation toward pooling. Mr. Hochvert cautioned that
the LM/NPAC should not underestimate its influence and suggested closer
coordination on the dissemination of information. Chairman Hoffman added
that the document presented is meant to inform the NANC and LM has
stated it will accept changes. Mr. Bishop reminded the Council that the
FAQs is a CIS product and represents a collection of factual statements
made in response to questions received by LM.

Philip McClelland added that now that five states have been delegated
authority to do pooling it is important to track and manage and/or
monitor what is going on in each state. LM is talking to each state
about the problems they will face. Chairman Hoffman stated that states
are moving ahead, and CIS has to respond to their questions. The NANC
needs to catch up, not slow CIS down by trying to control the content of
its answers.

***O. Next Meeting: ***October 19-20, 1999.

# VI. NANC Action Items and Decisions Reached:

[1. Report of NANPA on 1999-2001 NPA Assignments]{.underline}. LM
accepts the responsibility under the fixed price contract to conduct
initial meetings to coordinate NPA relief planning, but believes that
facilitating any subsequent meetings for a particular NPA would
constitute an enterprise service (for which LM would be compensated
separately). Chairman Hoffman asked for the opportunity to review the
contract, to research the issue with LM and some NANC members, and to
report his findings at the October meeting.

LM will report on the status of CO code assignments in the 602 NPA
regarding the "grandfathering" of codes in 602 for alarm companies with
respect to the time provided for customer migration and the impact on
code duplication.

LM will provide an update on the Minnesota three way split situation
that splits rate center boundaries and provide the NANC at the October
meeting with the number of NXXs available in those NPAs and report how
many NXXs have been duplicated in order to maintain 7-digit dialing.

[2. Report of NANPA Oversight Working Group]{.underline}. Working Group
is to analyze the issue of repeated applications for NXX assignments
occurring in some lottery conditions imposed by law and determine the
associated consequences, such as increased cost to industry if the firm
fixed price of the LM contract threshold is exceeded by 120%. Identify
in what jurisdictions this is taking place, and identify the cost
consequences.

*Intellectual property*. NANC recognized that the NANPA would be
developing intellectual property of potentially significant value over
the life of the contract with LM and that, accordingly, the NANC should
resolve any confusion over ownership of that property. The NANPA OS WG
will research the LM contract and define any conflicting positions, so
that any open issues can be discussed at the NANC meeting in November.

[3. Report of Audits IMG]{.underline}. Suggested changes to the Audit
Framework recommendation are to be to be e-mailed to Pat Caldwell () and
Karen Mulberry ( Comments with specific language changes are to be
submitted by October 15. The IMG and NANPA OS WG will consolidate
comments and produce a "redlined" version for review and discussion at
the October NANC meeting. A consensus document will be delivered to NANC
at the November meeting.

[4. Report of the Number Resource Optimization Working
Group]{.underline}. Proposed changes to the Report on Telephone Number
Reservation were accepted. The final report will be forwarded to INC by
transmittal letter. A copy of the report will be sent to the Chief,
Common Carrier Bureau by separate transmittal letter. A copy of the
report will be filed with the Commission as an *ex parte* for inclusion
in CC Docket 99-200.

[5. Reseller's Code Usage and Forecasting Reporting]{.underline}. The
Reseller and Type 1 Wireless Forecasting and Utilization Data summary,
paragraph 2, was modified to read as follows:

*The code/block holders to whom the numbering resources are assigned
shall be responsible to report the name and contact information to the
NANPA of any reseller/type 1 wireless carriers who have obtained
numbering resources of more than 1,000 per NXX. The reseller/type 1
wireless carriers shall then be responsible to report their utilization
and forecast data to the NANPA directly; unless otherwise specified in
an interconnection agreement, business arrangement, contract or tariff."
*

This report was approved as modified and will be forwarded by
transmittal letter to the INC Moderator.

[6. LNPA Working Group Report]{.underline}. With respect to the Problem
Identification Management (PIM) process, the WG advisory letter will be
forwarded to industry associations to ensure broad dissemination of the
guidelines for the PIM.

[7. Report of IMG Paragraph165]{.underline}. Report dated 9/15/99 was
accepted and will be forwarded to FCC as late filed or *ex parte* of
comments in CC Docket 99-200. Chairman Hoffman will interact and discuss
issues contained in the report with LM. LM will report at October NANC
regarding progress on improvements to the NANP Exhaust model.

[8. Cost Recovery Working Group]{.underline}. Affirmed Co-Chair
selection, Elsa Morris, Ohio PUC. With respect to audits, the CRWG will
provide ballpark recommendation at the October meeting for the estimate
of cost in Year 2000. The audit recommendation will include an estimate
of reasonable expenses and the number of audits that will result. This
will be a joint recommendation of the Audit IMG and the CRWG.

[9. NBANC Update]{.underline}. Overall presentation will be provided at
the October NANC meeting. Discussion will include the thousand-block
administration true up effect on the funding factor. Further discussion
of the audits issue will take place at the October meeting.

[10. Industry Numbering Committee Report]{.underline}. INC will provide
status of NANP expansion options (technical and policy) at the December
NANC meeting. An interim report will be presented at the November NANC
meeting.

[11. Number Pooling IMG]{.underline}. IMG Chair Peter Guggina will work
with LM/CIS to identify Year 2000 pooling cost and report at the October
NANC meeting.

[12. NANC Oversight of LLCs and NPAC]{.underline}. Letter to LLCs
requesting information regarding their approval/acceptance of SOW 15,
Release 3.0, will be drafted by Peter Guggina and Dan Hochvert for
Chairman Hoffman and will be circulated to the full Council for approval
prior to delivery.

[13. Canadian Radio-Television and Telecommunications Commission (CRTC)
Letter]{.underline}. NANC members will be provided a copy of the letter
dated August 13, 1999, regarding CRTC request to INC that the network
destination code (NDC) options be examined in detail as one of the NANP
Expansion options.

[14. Steering Group Report]{.underline}. Year 2000 meeting schedule
presented and approved. Continue discussion on new replacement web site
for Chairman's postings of NANC documents.

15\. [Other Business]{.underline}. Beth O'Donnell will develop a
proposal for the NRO WG that includes a work plan for discussion at the
October NANC meeting.