exv10w3w1



 











Exhibit
10.3.1








 









 





	 	 	 
	

	 	Federal Communications Commission 

Washington, D.C. 20554

	 

	 	September 8, 2006






Thomas M. Koutsky

Chair, North American Numbering Council

c/o Phoenix Center for Advanced Legal and Economic Public Policy Studies

5335 Wisconsin Avenue, NW

Suite 440

Washington, D.C. 20015




Ms. Amy L. Putnam

Director, Number Pooling Services

NeuStar, Inc.

3519 North Fourth Street

Harrisburg, PA 17110



Dear Mr. Koutsky and Ms. Putnam:




     This letter addresses a recommendation by the North American Numbering Council (NANC) that
NeuStar, Inc. (NeuStar), the current Pooling Administrator, serve as the Interim Routing Number
Authority (Interim RNA) for the pseudo Automatic Number
Identification (p-ANI) codes1 used for
routing emergency calls.2 After review of the materials supplied by the NANC, the
Wireline Competition Bureau (Bureau) agrees with the NANC’s recommendation and finds it would be in
the public interest to assign NeuStar to be the Interim RNA. Furthermore, the Bureau concludes that
the p-ANI administration function falls within the broad scope of NeuStar’s existing Pooling
Administration Contract.3 Accordingly, the Bureau hereby





 




			
	1	 	A p-ANI is a number, consisting of the same number of digits as Automatic Number
Identification (ANI), that is not a North American Numbering Plan (NANP) telephone directory number
and may be used in place of an ANI to convey special meaning to the selective router, public safety
answering point (PSAP), and other elements of the 911 system. See
IP-Enabled Services, E911
Requirements for IP-Enabled Service Providers, WC Docket Nos. 04-36, 05-196, First Report and Order
and Notice of Proposed Rulemaking, 20 FCC Rcd 10245, 10252-53, para. 17 (2005) (VoIP 911 Order); 47
C.F.R. § 9.3.
	 
	2	 	See Letter from Hoke Knox and Karen Mulberry, pANI Issues Management Group Co-Chairs,
to Robert C. Atkinson, NANC Chair (Sept. 2, 2005) in Letter from Robert C. Atkinson, NANC Chair, to
Thomas J. Navin, Chief, Wireline Competition Bureau, FCC (Sept. 8, 2005) (NANC Sept. 8 Letter);
p-ANI Issues Management Group, NANC, pANI Interim Assignment Guidelines for ESQK (issued Sept. 1,
2005) (Initial Interim Guidelines) in NANC Sept. 8 Letter. The Initial Interim Guidelines were
revised by the NANC on December 5, 2005. See Letter from Robert C. Atkinson, NANC Chair, to Thomas
J. Navin, Chief, Wireline Competition Bureau, FCC (Jan. 5, 2005) at 2; p-ANI Issues Management
Group, NANC, pANI Interim Assignment Guidelines for ESQK (revised Dec. 5, 2005)
<http://www.nanc-chair.org/docs/nowg/Jan06_pANl_Guidelines_(Revised).doc> (Interim
Guidelines).
	 
	3	 	See generally Pooling Administrator — NeuStar, FCC Contract No. CON01000016, signed by
Sonna Stampone, Contracting Officer, Federal Communications Commission (dated June 15, 2001)
(Contract). We note that the Thousands-Block Pooling Contractor Technical Requirements are set
forth in Section C of the Contract. See id. Section C (Contract Technical Requirements).






 









 







directs NeuStar to perform the p-ANI administration function. NeuStar must perform this
function in accordance with the NANC’s Interim Guidelines and the instructions in this letter. This
assignment is interim in nature until a permanent p-ANI solution is in place, the expiration of
NeuStar’s performance as Pooling Administrator, or further notice, whichever occurs first.




     As you know, the Federal Communications Commission (FCC) ordered providers of interconnected
voice over Internet Protocol (VoIP) service to supply their customers with enhanced 911
capabilities.4 The NANC proposes temporary measures for the administration and issuance
of p-ANI resources. Specifically, the NANC recommends that NeuStar administer the p-ANI function on
an interim basis until NANC’s p-ANI Issue Management Group proposes a permanent recommendation. In
addition, the NANC proposes Interim Guidelines that would apply to the Interim RNA’s administration
of p-ANI resources, and to entities that seek to obtain p-ANI from the Interim RNA.



     The Bureau accepts, as set forth below, the NANC’s proposed temporary measures for the
administration and issuance of p-ANI resources. The Bureau recognizes, however, that a permanent
solution to this issue will best serve the public interest. The Bureau therefore directs the NANC
to advise the Bureau, no later than October 10, 2006, as to the date the NANC will recommend to the
Bureau such a permanent solution.



     The Bureau agrees with the NANC that NeuStar should serve as the Interim RNA. Given its
experience as the Pooling Administrator, NeuStar is qualified to perform this role. Moreover, the
Contract encompasses this additional function. The Contract in general assigns NeuStar
responsibilities over assignment of thousands-block numbering resources — pools smaller than
ten-thousands blocks or central office codes administered pursuant to other agreements.5
In addition, Section 2.5 of the Contract provides that the FCC “may issue rules, requirements, or
policy directives in the future, which may increase, decrease or otherwise modify the functions to
be performed by the contractor.”6 Section 2.5.1 further states that “the FCC, the NANC,
and/or the [Industry Numbering Committee] may establish NANP numbering resource plans,
administrative directives, assignment guidelines (including modifications to existing assignment
guidelines) and procedures that may have an effect on the functions performed by the
contractor.”7



     The Bureau therefore directs NeuStar to serve as Interim RNA until: (1) a permanent p-ANI
solution is in place; (2) the expiration of NeuStar’s performance as Pooling Administrator; or (3)
further notice, whichever occurs first. During this interim period, however, NeuStar is not the
sole provisioner of p-ANI resources. Carriers or other entities that have been voluntarily
providing p-ANI may continue to do so until a permanent solution is found.





 




			
	4	 	See generally VoIP 911 Order, 20 FCC Rcd 10245.
	 
	5	 	Contract Technical Requirements, § 1.1.
	 
	6	 	Id, §2.5.
	 
	7	 	Id., § 2.5.1; see also id., § 1.4 (“The contractor shall also ensure that
domestic numbering administration shall be effective.”).




 









 










     The Bureau further requires NeuStar, in its capacity as Interim RNA, to comply with the
NANC’s Interim Guidelines, except as explained in this paragraph. Section 3.3 of the Interim
Guidelines states that Part 52 of the FCC’s rules8 (which governs numbering) does not
apply to p-ANI except as provided in the Interim Guidelines.9 NeuStar shall not follow
this section. Until the Commission determines that Part 52 does not apply to p-ANI or makes some
other ruling on the topic, we require NeuStar to operate consistently with the requirements of Part
52.10 Accordingly, an entity seeking p-ANI from NeuStar must have appropriate authority
to access numbering resources in general. The entity must be licensed or certified by the FCC or a
state commission to operate as a telecommunications carrier and must provide NeuStar with evidence
of such
authority.11  Thus, “Eligible Users,” as defined in the Interim Guidelines, shall be no
broader than indicated in this paragraph. Furthermore, NeuStar may assign p-ANI to VoIP service
providers that can provide such evidence of carrier status as well as to carriers that provide
wholesale 911-related services to VoIP service providers. Requests for waivers of this requirement
may be filed by any entity that certifies that it fully remits 911 emergency service fees into all
state and local 911 funds, and fully contributes into universal service mechanisms.



     Finally, the Bureau directs NeuStar to submit a Change Order Proposal on this issue to begin
the contract modification process. Section 2.5.3 of the Contract directs that “within a period of
not more than 30 calendar days” from the date that the FCC modifies the functions to be performed
by the contractor, “[t]he contractor shall... provide the Contracting Officer, state PUCs, and the
NANC with written notice regarding these changes and summarize the potential impact of the changes
upon service and cost, if any.”12 Therefore, NeuStar must submit the Change Order
Proposal within 30 calendar days of the date of this letter.



     Please let me know if you have any questions regarding this matter.



	 	 	 	 	 
	 	Sincerely,

 	 
	 	/s/ Thomas J. Navin
 	 
	 	Thomas J. Navin 	 
	 	Chief

Wireline Competition Bureau 	 
	 





 




			
	8	 	47 C.F.R. §52.1 et seq.
	 
	9	 	Interim Guidelines, § 3.3.
	 
	10	 	Cf. Numbering Resource Optimization, CC Docket No. 99-200, Report and Order and
Further Notice of Proposed Rulemaking, 15 FCC Rcd 7574, 7591, paras. 31-32 (2000) (placing wireless
E911 emergency service routing digits (ESRD/ESRK) in the general category of administrative
numbers, which includes “any numbers used by carriers to perform internal administrative or
operational functions necessary to maintain reasonable quality of service standards”).
	 
	11	 	Id. at 7615, para. 97.
	 
	12	 	Contract Technical Requirements, § 2.5.3.






 









 





pANI

Interim Assignment

Guidelines

for ESQK




Prepared by the pANI IMG

for the NANC




Revised December 5, 2005




Issued September 1, 2005




 









 





	 	 	 
	pANI Interim Assignment Guidelines for ESQK

	 	September 14, 2005






 





Table of Contents




	 	 	 	 	 	 	 
	 	 	 	 	Page	 
	Section	 	 	 	 
	1
	 	Preface 	 	 	3	 
	2
	 	Disclaimer and Limitation of Liability 	 	 	4	 
	3
	 	Purpose and Scope of This Document 	 	 	4	 
	4
	 	Assumptions and Constraints 	 	 	5	 
	5
	 	Assignment Principles 	 	 	7	 
	6
	 	Criteria for the Assignment of ESQK Numbers 	 	 	8	 
	7
	 	ESQK Assignment Functions 	 	 	8	 
	8
	 	Responsibilities of ESQK Number Applicants and Holders 	 	 	9	 
	9
	 	Assignment Procedures 	 	 	10	 
	10
	 	Interim 9-1-1 RNA Responsibilities 	 	 	11	 
	11
	 	Conflict Resolution and Appeals Process 	 	 	12	 
	12
	 	Maintenance of These Guidelines 	 	 	12	 
	13
	 	Future Considerations 	 	 	13	 
	14
	 	Glossary 	 	 	14	 






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	pANI Interim Assignment Guidelines for ESQK

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Preface



On October 5, 1995, the Federal Communications Commission (FCC) established the North
American Numbering Council (NANC), by filing its charter with Congress, to provide advice and
recommendations to the FCC and other governments (including Canada and Caribbean countries) on
numbering issues.



Since its inception, the Council has provided the Commission with critically important
recommendations regarding numbering issues. These recommendations have addressed a myriad of
issues, including wireline/wireless integration for local number portability, abbreviated dialing
arrangements, the neutrality of toll free database administration, the feasibility of local number
portability for 500/900 numbers, methods for optimizing the use of numbering resources, the
assignment of Feature Group D Carrier Identification Numbers to switch-less resellers, and
technical specifications for a National Pooling Administrator and the North American Numbering Plan
Administrator. Recently the Council has been reviewing the issue of integrating the numbering
resource needs of IP enabled service providers, commonly referred to as Voice over Internet
Protocol (VoIP), into the existing numbering resource rules and regulations. The council has
recently provided recommendations to the FCC on VoIP Service Providers’ Access Requirements for
NANP Resource Assignments.



On June 3, 2005 the FCC issued the First Report and Order under FCC docket 05-196 that requires
VoIP providers to supply enhanced 9-1-1 (E9-1-1) service capabilities to their customers. When
evaluating the access of VoIP users to Public Service Answering Points (PSAPs) several parallels to
the access of wireless users to PSAPs can be seen; primarily the users can be nomadic and the
telephone number assigned to the user may be foreign to the PSAP the call should be directed to.
The wireless industry has traditionally addressed these issues through the use of pseudo ANIs
(pANI) to establish access for a nomadic user with a foreign telephone number to the correct PSAP.
It is anticipated that VoIP will use a similar methodology to provide VoIP user’s access to PSAPs.



On July 25, 2005 the Alliance for Telecommunications Industry Solutions (ATIS) Emergency Service
Interconnection Forum (ESIF) submitted to the industry and to NANC a set of “Routing Number
Authority (RNA) for pANIs Used for Routing Emergency Calls — pANI Assignment Guidelines and
Procedures’”1.
On August 5, 2005 the NANC Future of Numbering Working Group established the pANI
Issue Management Group (IMG) to address the request by ESIF and provide a recommendation to NANC.



The IMG concurs with the basic recommendations of the ESIF to establish an Interim 9-1-1 Routing
Numbering Administrator (Interim 9-1-1 RNA) to administer pANI numbering resources and envisions
this to be a two stage process.






 




			
	1	 	© 2005 by Alliance for Telecommunications Industry Solutions) created by the
Emergency Services Interconnection Forum (ESIF).





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	pANI Interim Assignment Guidelines for ESQK

	 	September 14, 2005






 




Stage I consists of this document (which incorporates concepts and information from the ESIF
document and uses it along with ATIS Industry Numbering Committee (INC) document templates) to
provide interim guidelines for the issuance of resources from the North American Numbering Plan
(NANP) to enable VoIP services providers to comply with the requirements of FCC Order 05-196.



Stage II will be the development of complete guidelines and administrative procedures by INC, in
cooperation with the ESIF, for the use of pANIs in all modes of communication.



The interim guidelines will apply to the Interim 9-1-1 RNA and any entities that seek to obtain
numbers from the Interim 9-1-1 RNA until such time as the INC in cooperation with the ESIF can
develop and publish complete guidelines and administrative procedures concerning pANIs.



NANC members include representatives from local exchange carriers (LECs), inter-exchange carriers,
wireless providers, manufacturers, state regulators, VoIP providers, consumer groups, and
telecommunications associations.




1 Disclaimer and Limitation of Liability



The information provided in this document is directed solely to professionals who have the
appropriate degree of experience to understand and interpret its contents in accordance with
generally accepted engineering or other professional standards and applicable regulations. No
recommendation as to products or vendors is made or should be implied.




2 Purpose and Scope of This Document



In an effort separate from this IMG, the ESIF, a technical committee of ATIS, has been
evaluating the need to standardize the specific numbers used in the implementation of pANIs,
specifically Emergency Service Query Keys (ESQKs) for use during VoIP 9-1-1 calls. The purpose of
this document is to define the interim guidelines that shall be used by any entity that is
assigning ESQKs for VoIP. The duration of this interim period shall be decided separately by NANC.



ESIF has recommended2, and the INC has concurred3 that ESQKs





	 	•	 	Should be in the format of NPA-NXX-XXXX and that they should be from the
number sets of NPA-211-XXXX and NPA-511-XXXX if the NPA-211-XXXX is
exhausted.


	 
	 	 	 	

 and







 




			
	2	 	ESIF Issue 25 on the Use of Pooled or Ported Numbers as ESRKs
	 
	3	 	INC Issue 429 Non-Dialable ESRDs or ESRKs





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	pANI Interim Assignment Guidelines for ESQK

	 	September 14, 2005






 






	 	•	 	Should be from the pools of NPA’s that are valid for the Selective Router they will
be used for.




These guidelines recommend that ESQKs (pANIs utilized for VoIP) should be from the pools of
NPA-211-XXXX or NPA-511-XXXX with 211 being utilized before 511.



This document specifies interim guidelines developed with ESIF for the assignment of ESQK to those
Eligible Users complying with the FCC order requiring VoIP customers to have access to enhanced
9-1-1 (E9-1-1). The designated interim ESQK Numbering Administrator (referred to as “Interim 9-1-1
RNA”).



These guidelines apply only to the assignment of ESQKs within geographic numbering plan areas
(NPAs) under the jurisdiction of the FCC. This does not preclude a future effort to address
non-geographic NPAs in the same guidelines. ESQKs are assigned for use at a Selective Router for
which the VoIP Service Provider (VSP) has approval from the 9-1-1 Governing Authority4
to route E9-1-1 traffic for termination to a PSAP. While the ultimate delivery of any call to a
PSAP must be based upon the geographical location of the originating caller, by necessity the
association of the geographical location, of the originating telephone number and the ESQK is
typically made at an Emergency Routing Data Base (ERDB).



In areas where E9-1-1 System Service Providers (E9-1-1 SSPs)5 had performed this
function prior to the establishment of the Interim 9-1-1 RNA, that role may continue until such
time as a permanent 9-1-1 RNA is determined. In developing these guidelines, ESIF and the pANI IMG
foresee that these entities should only exist during the transition period until a permanent 9-1-1
RNA is established.




3 Assumptions and Constraints



The development of these guidelines includes the following assumptions and constraints:





	3.1	 	pANIs (and specific to these guidelines, ESQKs) in the format NPA-NXX-XXXX are by
definition6 in the format of a Central Office code and are therefore administered
by the North American Numbering Plan Administrator7 under Guidelines developed by
the INC8.






	3.2	 	In Stage II the NXX-211-XXXX and NXX-511-XXXX should be identified in 47 C.F.R. §
52.13.(d) as a unique sub-set of NANP resources known as pANIs.







 




			
	4	 	The term “9-1-1 Governing Authority” means “an entity designated under state law or
regulation to have decision-making and oversight responsibilities for a 9-1-1 Emergency Number
System for one or more PSAPs.”
	 
	5	 	Generally speaking, an E9-1-1 SSP is in the majority of cases an ILEC but there are other entities that perform that function.
	 
	6	 	47C.F.R. § 52.7(c)
	 
	7	 	 47C.F.R. § 52.15(a)
	 
	8	 	 47C.F.R. § 52.15(d)





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	pANI Interim Assignment Guidelines for ESQK

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	3.3	 	Although pANIs are believed to be a North American Numbering Plan resource the existing
requirements of “47 C.F.R. § 52 Numbering” do not apply unless specifically indicated in these
interim guidelines. The specific sections of 47 C.F.R. § 52 that should apply to pANIs will be
determined in Stage II.
	 
	3.4	 	These interim guidelines are for use in cooperation with various North American Numbering
Plan numbering guidelines developed by the INC and the recommendations of ESIF and NANC.
	 
	3.5	 	The Interim 9-1-1 RNA will work with other entities administering ESQKs to transition
administrative functions to the Interim 9-1-1 RNA according to a mutually agreeable timetable
for transition.
	 
	3.6	 	ESQK numbering resources shall be assigned to permit the most effective and efficient use of
a finite numbering resource in order to prevent premature exhaust. Efficient resource
management and number conservation are necessary due to the industry impacts of expanding the
numbering resource.
	 
	3.7	 	If at any point the FCC rules require regulatory certification, the applicant must be able to
demonstrate that regulatory authorization has been obtained for the issuance of ESQK numbering
resources.
	 
	3.8	 	These guidelines do not address the issue of who will fulfill the role of Interim 9- 1-1
RNA. The NANC pANI IMG developed these interim guidelines with ESIF without any assumption on
who should be the Interim 9-1-1 RNA.
	 
	3.9	 	The NANC developed these interim guidelines as a temporary guide for the industry pending
development of permanent INC guidelines in cooperation with ESIF.
	 
	3.10	 	Administrative assignment of the ESQK numbering resource to an ESQK holder does not imply
ownership of the resource by the Interim 9-1-1 RNA, nor does it imply ownership by the ESQK
holder to which it is assigned.
	 
	3.11	 	Interim 9-1-1 RNA and numbering resource administrators are responsible for managing
numbering resources in accordance with these guidelines and the orders of applicable
regulatory authorities.
	 
	3.12	 	An applicant is not required to provide any additional explanation or justification of
items to which he/she has certified. However, that explanation/justification alone may not
provide the Interim 9-1-1 RNA with sufficient information upon which to make a decision
regarding pANI number assignment, and additional dialog and written documentation may be
required. The Interim 9-1-1 RNA is still obligated to reply within five business days. [
	 
	3.13	 	Should the FCC delegate authority to state commissions, state commissions shall have access
to Eligible Users’ inventory assignments and their use of ESQKs in each Selective Router for
the purpose of ensuring the correct application of these numbering resources. Should the FCC
delegate authority to state commissions, state commissions may request an accounting of
inventories from the Eligible Users operating within their states, and Eligible Users must
comply with such state commission requests. Entities that fail to comply with a state
commission request for ESQK information shall be denied ESQKs should the FCC delegate such
authority to state commissions.





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	pANI Interim Assignment Guidelines for ESQK

	 	September 14, 2005






 






	3.14	 	The Interim 9-1-1 RNA will survey existing usage to ensure that unique ESQKs are being
assigned.
	 
	3.15	 	These guidelines do not describe the method by which the unique ESQKs as identified in
this document are transmitted across and processed by networks. Such arrangements may be
contained in other standards, documents, or business agreements.





4 Assignment Principles



The assignment principles defined below will be used by any entity assigning ESQKs
during the interim period.





	4.1	 	An Eligible User is any entity that provides the appropriate documentation identified in
these guidelines for the need for ESQKs to perform routing or data retrieval functions
associated with emergency services. In the context of these guidelines, an Eligible User shall
include a VSP or an entity providing VPC service acting on behalf of VSP(s). An entity that
has not obtained approval from the 9-1-1 Governing Authority will not be considered an
Eligible User.
	 
	4.2	 	ESQKs are assigned for use at a Selective Router for which the Eligible User has approval to
route E9-1-1 traffic for termination to a PSAP or an Emergency Service Zone (ESZ) within a
PSAP.
	 
	4.3	 	ESQK NPA-211-XXXX should be used before ESQK NPA-511-XXXX unless ESQKs from NPA 211 have been
assigned and are being used where the NPA will coincide with the NPA of the Selective Router.
These ESQKs shall be considered non-dialable in the Eligible User’s network.
	 
	4.4	 	ESQKs are assigned uniquely to individual Eligible Users.
	 
	4.5	 	At the discretion of the 9-1-1 Governing Authority, a VPC operator that processes 9-1-1 calls
originating from various VSP networks is not required to acquire and use separate ESQKs for
each VSP as long as the VPC enables clear identification of the originating VSP in the display
of the caller’s information at the PSAP.
	 
	4.6	 	ESQKs will be assigned in contiguous ranges (where possible), and in quantities requested by
the applicant. However, the Interim 9-1-1 RNA does not guarantee that all ESQKs will be
assigned in contiguous ranges.
	 
	4.7	 	Any entity assigning ESQKs will:






	 	4.7.1	 	Assign ESQKs in a fair, timely and impartial manner to any
Eligible User.
	 
	 	4.7.2	 	Assign ESQKs on a first come, first served basis from the
available pool.
	 
	 	4.7.3	 	Make all ESQK assignments in conformance with these guidelines.
	 
	 	4.7.4	 	Treat all information received from applicants as proprietary and
confidential. The Interim 9-1-1 RNA is permitted to provide the contact
information for the assigned user of any given ESQK(s) to law




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	pANI Interim Assignment Guidelines for ESQK

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	 	 	 	enforcement agencies, PSAPs, and E9-1-1 SSPs as well as any state or
federal agency that has direct regulatory responsibilities over E9-1-1.






	4.8	 	Information that is requested of an Eligible User in support of an ESQK
application shall be uniform and kept to a minimum.





5 Criteria for the Assignment of ESQK Numbers



The assignment criteria in the following sections shall be used by the Interim 9-1-1 RNA in
reviewing an ESQK assignment request from an Eligible User for initial and/or additional ESQKs.





	5.1	 	ESQKs are assigned to entities for use at a Selective Router for which the Eligible User has
approval from the 9-1-1 Governing Authority to route E9-1-1 traffic for termination to a PSAP.
	 
	5.2	 	The potential Eligible User must self-certify that it is able to route traffic to the
appropriate Selective Router before receiving its first grant of ESQK numbering resources.
	 
	5.3	 	The potential Eligible User must submit an ESQK request form certifying that a need exists
for the assignment for use with a specific Selective Router.
	 
	5.4	 	The Interim 9-1-1 RNA will not issue ESQKs to an Eligible User without an Operating Company
Number (OCN)9. The OCN cannot be shared with another Eligible User.
	 
	5.5	 	All applications for numbering resources must include the company name, company headquarters
address, OCN, parent company’s OCN(s), and the primary type of business in which the numbering
resources will be used.10
	 
	5.6	 	All applications for numbering resources must include a National Emergency Number Association
(NENA) provided Company ID to be associated with the ESQKs
	 
	5.7	 	ESQKs will not be reserved.
	 
	5.8	 	Information that is requested of an Eligible User in support of an ESQK application
shall be maintained by the Interim 9-1-1 RNA.





6 ESQK Assignment Functions



The Interim 9-1-1 RNA (s) shall:





	6.1	 	Produce and make available upon request information regarding ESQK Administration
processes, guidelines, interfaces and services.
	 
	6.2	 	Provide, upon request of the ESQK applicant, information on how to obtain documents related
to pANI Numbering Administration by either referring the applicant to web sites where it will
be possible to download electronic copies or







 




			
	9	 	FCC 01-362, 47 C.F. R. § 52.15 (g)(4).
	 
	10	 	FCC 00-104, 47 C.F.R. § 52.15 (g)(1).




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	pANI Interim Assignment Guidelines for ESQK

	 	September 14, 2005






 










	 	 	OCN must be provided, if applicable12. The applicant can get OCN
information by calling NECA.13
	 
	7.2	 	A NENA provided Company ID to be associated with the ESQKs.
	 
	7.3	 	The information associated with ESQK assignment may change over time. Such changes may occur,
for example, because of the transfer of an ESQK from a VSP to a VPC.
	 
	7.4	 	The holder of ESQKs assigned by the Interim 9-1-1 RNA, or acquired by merger or acquisition,
must use the ESQKs consistent with these guidelines. If the Eligible User no longer provides
service in the area, the Eligible User must notify the Interim 9-1-1 RNA.
	 
	7.5	 	The Interim 9-1-1 RNA will retain copies of such notifications and deliver them to the
permanent 9-1-1 RNA for use in reclamation proceedings. The Interim 9-1-1 RNA must be
immediately notified of any changes to the information contained in the application.





8 Assignment Procedures



Entities requesting initial ESQK assignments and entities already assigned one or more ESQKs
shall comply with the following:





	8.1	 	An ESQK Applicant requesting resources from the Interim 9-1-1 RNA, shall:






	 	a)	 	provide the VoIP ESQK Interim Request Form (attached as an Exhibit to
these interim guidelines) that it is an Eligible User:
	 
	 	b)	 	complete the ESQK application form per these guidelines.






	8.2	 	An applicant must apply to the Interim 9-1-1 RNA (contact details provided below). An
applicant should follow all application instructions found on the application form. At a
minimum, the form will request:






	 	a)	 	The full legal name of the applicant as it appears on the VESA
certification, interconnection agreement, letter of certification, or legal
documents provided to any regulatory authority having oversight.
	 
	 	b)	 	Any names under which the applicant does business (d/b/a’s)
	 
	 	c)	 	The name and contact information (address, telephone number, and
email address) of the individual making the request on behalf of the Applicant;
	 
	 	d)	 	A list of the NPAs associated with the relevant Selective Router
for which ESQKs are needed;
	 
	 	e)	 	A list of the PSAPs to which the ESQKs requests are related,
including the state, county, and municipality in which the PSAP is located; and
	 
	 	f)	 	The quantity of ESQKs being requested for each NPA.







 




			
	12	 	FCC 01-362, 47 C.F.R. § 52.15 (g)(4).
	 
	13	 	NECA assigns Company Codes that may be used as OCNs. Companies with no prior CO Code or
Company Code assignments may contact NECA (800 524-1020) to be assigned a Company Code(s). Since
multiple OCNs and/or Company Codes may be associated with a given company, companies with prior
assignments should direct questions regarding appropriate OCN usage to the TelcordiaTM Routing
Administration (TRA) on 732 699-6700.




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	pANI Interim Assignment Guidelines for ESQK

	 	September 14, 2005






 








	8.3	 	Any applicant denied an ESQK assignment under these guidelines has the right to
appeal that decision (see Section 11 for procedures).





9 Interim 9-1-1 RNA Responsibilities





	9.1	 	The Interim 9-1-1 RNA will track and monitor ESQK assignments and assignment procedures,
and recommend appropriate and timely changes to these guidelines, if they are found to result
in inefficient or inappropriate use or assignment of ESQKs. However, any changes to these
guidelines must be approved by the INC with guidance by ESIF if appropriate.
	 
	9.2	 	The Interim 9-1-1 RNA will not engage in audits or reclamation.
	 
	9.3	 	Initial Implementation: Before it begins assigning ESQKs, the Interim 9-1-1 RNA must ensure
that the ESQKs it assigns are not presently in use. Because it is believed that few ESQKs have
been assigned from the 211 NXXs, the Interim 9-1-1 RNA will assign ESQKs only from the 211
NXX unless extenuating circumstances exist. To avoid duplication, the Interim 9-1-1 RNA will
first perform the following steps in order until it can determine what numbers are available
to be assigned:






	 	    1.	 	Ask existing mobile position center (“MPC”) and VPC vendors to provide a
list of all the entities that have been assigned pANIs in the 211 NXX, and the entity
(and contact information) that assigned the pANI.
	 
	 	    2.	 	Ask each wireless service provider to respectively identify the entity
that provides pANIs to it.
	 
	 	    3.	 	Ask each E9-1-1 SSP to identify any pANI and entity that it has assigned a
p-ANI to from the 211 code. In addition, ask each E9-1-1 SSP to identify any other
entities that may perform pANI assignments within its territory (including
independents).






	9.4	 	Once it has compiled a list of entities that assign numbers, the Interim 9-1-1 RNA will
canvass those entities to determine what, if any, pANIs they have assigned from the 211 NXX.
The remaining available pANIs in the 211-NXX in all NPAs will constitute the available pool
from which the Interim 9-1-1 RNA will assign ESQKs.
	 
	9.5	 	The Interim 9-1-1 RNA will ensure the completeness of each application and
accompanying documentation before it assigns resources.
	 
	9.6	 	The Interim 9-1-1 RNA will process each application within 5 business days, on a first in,
first out basis, and inform the applicant of the result by an identifiable email form. If the
application is denied, the Interim 9-1-1 RNA will provide a detailed explanation of the
denial.




Page 11









 





	 	 	 
	pANI Interim Assignment Guidelines for ESQK

	 	September 14, 2005






 







10 Conflict Resolution and Appeals Process





	10.1	 	Every attempt will be made at the time of assignment to avoid conflicts with
existing pANIs.
	 
	10.2	 	Disagreements may arise between parties affected by these interim guidelines in the context
of the administration and management of these guidelines. In all cases, the parties will make
reasonable, good faith efforts to resolve such disagreements among themselves, consistent with
the interim guidelines, prior to pursuing any appeal.
	 
	10.3	 	If a conflict is determined to exist, the following escalation process should be
followed:






	 	a)	 	The affected party should contact the entity with whom the conflict exists
and attempt a resolution
	 
	 	b)	 	If resolution cannot be achieved among the involved affected parties, the
issue should be escalated in the following order:






	 	i.	 	the Interim 9-1-1 RNA for a recommended
solution;
	 
	 	ii.	 	The state regulatory authority having oversight, if
any;
	 
	 	iii.	 	the NANC; 
	 
	 	iv.	 	the FCC .






	10.4	 	Questions regarding interpretation or clarification of these Interim Guidelines may be
referred to NANC for resolution. Unless otherwise mutually agreed to by the parties, these
questions will be submitted in a generic manner protecting the identity of the appellant.
	 
	10.5	 	Reports on any resolution resulting from the above options, the content of which will be
mutually agreed upon by the involved parties, will be kept on file by the Interim 9-1-1 RNA.
At a minimum, the report will contain the final disposition of the appeal, e.g., whether or
not an ESQK was assigned.





11 Maintenance of These Guidelines





	11.1	 	These guidelines may be updated to reflect changes in industry practices or
national regulatory directives.
	 
	11.2	 	Requests for changes to these guidelines should be directed to the appropriate
industry forum, currently the INC.






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	pANI Interim Assignment Guidelines for ESQK
	 	 
	 	September 14, 2005  






 









12 Future Considerations





The issues identified in this section will not be the responsibility of the Interim 9-1-1
RNA, however it is imperative that these issues be examined when adopting permanent guidelines.



12.1 pANI Number Resource Management





	 	a)	 	The Interim VoIP Architecture for Enhanced 9-1-1 Services (i2)
currently
posted on the NENA web site for public review/comment contains ESQK
processing, utilization and administration principles proposed as industry
standard. The final i2 standard should be a consideration in the
development of permanent guidelines.
	 
	 	b)	 	With over 6000 PSAPs and an unknown number of Eligible Users, it is
vital that the permanent 9-1-1 RNA employ pANI allocation practices that
support the efficient and effective use of the pANI numbering resources.





12.2 Segregating wireless (ESRKs) and VoIP (ESQK) pANI Numbering Resources





	 	a)	 	There are substantial benefits from segregating wireless pANIs
(ESRKs)
and VoIP pANIs (ESQKs) into separate NXX codes. Accordingly, they
should be so segregated wherever possible. As a general matter ESQKs
should not be drawn from an NXX that has already been opened for
ESRKs, and when a code is exhausted for either ESQKs or ESRKs, it is
preferable to open a new code rather than to assign ESQKs and ESRKs
from the same code.
	 
	 	b)	 	Public safety agencies rely on the particular NXX to make important
distinctions. For example, where 511 (or 211) is used for ESRKs, 511 on a
“No Record Found” query identifies the caller as wireless. If 511 were
used in the same area for ESQKs, this distinction would be lost.
	 
	 	c)	 	Public safety agencies also key on the NXX to create reports. If
ESRKs
and ESQKs are drawn from the same NXX, creating such reports for
wireless-only or VoIP-only will not be possible. In some cases these
reports are used to ensure accurate billing.





12.3 Other Consideration



Should the CLLI code associated with the relevant Selective Routers and the appropriate NPAs be
identified on the ESQK request form?





Page 13









 








					
	pANI Interim Assignment Guidelines for ESQK
	 	 
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13
Glossary




	 	 	 
	9-1-1 Governing Authority

	 	An entity designated
under state law or
regulation to have
decision-making and oversight
responsibilities for a
9-1-1 Emergency
Number System for
one or more PSAPs.
	 
	 	 
	Applicant

	 	Eligible Users who
submit a ESQK Request to
the Interim 9-1-1
RNA for the purpose
of being assigned ESQKs for
their use.
	 
	 	 
	Central Office (CO) Code

	 	The sub-NPA number
in a TN, i.e., digits D-E-F
of a 10-digit
NANP Area address.
Central office codes are in
the form “NXX,”
where N is a number
from 2 to 9 and X is a
number from 0 to 9.
Central office codes
may also be referred to as
“NXX codes.” (47
C.F.R. §
52.7(c))
	 
	 	 
	Conservation

	 	Consideration given
to the efficient and
effective use of a
finite
numbering resource
in order to minimize the
cost and need to
expand its
availability in the
introduction of new
services,
capabilities and
features.
	 
	 	 
	E9-1-1 System Service Providers 

(E9-1-1 SSP)

	 	Generally speaking,
an E9-1-1 SSP is in the
majority of cases an
ILEC but there are
other entities that perform
that function.
	 
	 	 
	Eligible User

	 	An Eligible User is
any entity that provides
the appropriate
documentation
identified in these
guidelines for the need
for ESQKs to
perform routing or data
retrieval functions
associated with
emergency services. In the
context of these
guidelines, an
Eligible User shall
include a VSP or an entity
providing VPC
service acting on
behalf of VSP(s). An entity
that has not obtained
approval from the
9-1-1 Governing Authority
will not be
considered an
Eligible User.
	 
	 	 
	Emergency Services 

Interconnection Forum (ESIF)

	 	ESIF, of the
Alliance for
Telecommunications Industry
Solutions
(ATIS), is the primary
venue for the
telecommunications
industry,
public safety and
other stakeholders to
generate and refine
both technical
and operational
interconnection issues to
ensure life-saving E9-1-1
services are available for
everyone in all
situations.
ESIF enables many
different
telecommunications entities
to fully
cooperate and
interconnect with each
other to determine the
best practices
and solutions necessary to
effectively and
promptly deploy
E9-1-1 services nationwide.
ESIF’s mission is to
facilitate the
identification and
resolution of both
technical and
operational
issues related to
the interconnection of
telephony and
emergency
services
networks.







Page 14









 








					
	pANI Interim Assignment Guidelines for ESQK
	 	 
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	Emergency Service Query Key
(ESQK)

	 	Emergency Service Query Key (ESQK) — The ESQK identifies a
call instance at a VPC, and is associated with a particular SR
and PSAP combination. The ESQK is delivered to the E9-1-1 SR
and as the calling number/ANI for the call to the PSAP. The
ESQK is used by the SR as the key to the Selective Routing
data associated with the call. The ESQK is delivered by the
SR to the PSAP as the calling number/ANI for the call, and
is subsequently used by the PSAP to request ALI information
for the call. The ALI database includes the ESQK in
location requests sent to the VPC. The ESQK is used by the
VPC as a key to look up the location object and other call
information associated with an emergency call instance. The
ESQK is expected to be a ten-digit North American Numbering
Plan Number.
	 
	 	 
	Industry Numbering Committee
(INC)

	 	A standing committee of the Alliance for Telecommunications
Industry Solutions (ATIS) that provides an open forum to
address and resolve industry-wide issues associated with
the planning, administration, allocation, assignment and
use of numbering resources and related dialing
considerations for public telecommunications within the
North American Numbering Plan (NANP) area.
	 
	 	 
	North American Numbering 
Council (NANC)

	 	North American Numbering Council — On October 5, 1995, the
Federal Communications Commission (FCC) established the
North American Numbering Council (NANC), by filing its
charter with Congress, to provide advice and
recommendations to the FCC and other governments (including
Canada and Caribbean countries) on numbering issues.
	 
	 	 
	NANP (North American
Numbering Plan)

	 	A numbering architecture in which every station in the NANP
Area is identified by a unique ten-digit address consisting
of a three-digit NPA number, a three digit central office
number of the form NXX, and a four-digit line number of the
form XXXX.
	 
	 	 
	NANPA
(North American Numbering 
Plan
Administration)

	 	With divestiture, key responsibilities for coordination and
administration of the North American Numbering/Dialing
Plans were assigned to NANPA. These central administration
functions are exercised in an impartial manner toward all industry segments while balancing the utilization of a
limited resource.







Page 15









 









					
	pANI Interim Assignment Guidelines for ESQK
	 	 
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	NANP Area

	 	Consists of the
United States, Canada and
the Caribbean
countries
(American Samoa,
Anguilla, Antigua,
Bahamas, Barbados,
Bermuda, British
Virgin Islands, Canada,
Cayman Islands,
Dominica, Dominican
Republic, Grenada,
Jamaica, Montserrat,
St. Kitts &
Nevis, St. Lucia, St.
Vincent & Grenadines,
Turks & Caicos
Islands, Trinidad &
Tobago, and the United
States
(including Puerto
Rico, the U.S. Virgin
Islands, Guam and the
Commonwealth of the
Northern Mariana
Islands).
	 
	 	 
	Numbering Plan Area (NPA)

	 	Numbering Plan
Area, also called area
code. An NPA is the 3
-digit code
that occupies the A, B,
and C positions in the
10-digit NANP
format that applies
throughout the NANP Area.
NPAs are of the
form NO/ 1X, where
N represents the digits
2-9 and X represents
any digit 0-9.
After 1/1/95, NPAs will be
of the form NXX. In
the NANP, NPAs
are classified as either
geographic or non-geographic,







	 	a)	 	Geographic NPAs
are NPAs which correspond
to discrete
geographic areas
within the NANP Area.
	 
	 	b)	 	Non-geographic
NPAs are NPAs that do not
correspond to
discrete geographic
areas, but which are
instead assigned for
services with
attributes,
functionalities, or
requirements that
transcend specific
geographic boundaries. The
common
examples are NPAs
in the N00 format, e.g.,
800.





	 	 	 
	Operating Company Number

(OCN)

	 	An Operating
Company Number is a four
place alphanumeric
number that
uniquely identifies
providers of local
telecommunications
service. OCN assignments
are required of all
Service Providers
in their submission of
utilization and
forecast data
(FCC 00-104,
¶ 41 and
Public Notice DA 00-1549).
Relative to CO
Code assignments, NECA
assigned Company Numbers
may be used as
OCNs. Companies with no
prior CO Code or
Company Number
assignments contact NECA
(800 524-1020) to be
assigned a
Company Number(s). Since
multiple OCNs and/or
Company
Numbers may be
associated with a given
company, companies
with prior
assignments should direct
questions regarding
appropriate
OCN usage to the
TelcordiaTM Routing
Administration (TRA)
on 732
699-6700.

	 
	 	 
	Pseudo-Automatic Number

Identification (pANI) Codes


	 	Used generically in
this document to include
any of the other more
specifically
descriptive acronyms
associated with numbers
used for
routing emergency
calls today, such as but
not limited to: ESRD,
ESRK, ESQK, PSAP
routing numbers, etc.
	 
	 	 
	Service Provider

	 	The term “service
provider” refers to a
telecommunications
carrier or
other entity that receives
numbering resources from
the NANPA, a
Pooling Administrator or a
telecommunications
carrier for
the purpose of providing
or establishing
telecommunications







Page 16









 







	 	 	 
	pANI Interim Assignment Guidelines for ESQK

	 	September 14, 2005








 





	 	 	 
	 	 	service (FCC 00-104, § 52.5 (i)).
	 
	Unassignable Code

	 	
An unassignable number is an NXX code
designated by the administrator which will
not be made available for assignment to
any number applicant. For example, the
number “9-1-1” will not be assigned as a
central office code so as to avoid
potential conflict, with emergency
services.
	 
	 	 
	VPC

	 	VoIP Positioning Center.
	 
	 	 
	Wireless E9-1-1

ESRD/ESRK Number

	 	A 10-digit number used for the
purpose of routing an E9-1-1 call to the
appropriate Public Service Answering Point
(PSAP) when that call is originating from
wireless equipment. The Emergency Services
Routing Digit (ESRD) identifies the cell
site and sector of the call origination in
a wireless call scenario. The Emergency
Services Routing Key (ESRK) uniquely
identifies the call in a given cell
site/sector and correlates data that is
provided to a PSAP by different paths,
such as the voice path and the Automatic
Location Identification (ALI) data path.
Both the ESRD and ESRK define a route to
the proper PSAP. The ESRK alone, or the
ESRD and/or Mobile Identification Number
(MIN), is signaled to the PSAP where it
can be used to retrieve from the ALI
database, the mobile caller’s call-back
number, position and the emergency service
agencies (e.g., police, fire, medical,
etc.) associated with the caller’s
location. If a NANP TN is used as an ESRD
or ESRK, this number cannot be assigned to
a customer.






Page 17









 






					
	pANI Interim Assignment Guidelines for ESQK
	 	 
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VoIP
Interim ESQK Request Form




	 	 	 	 	 	 	 	 	 
	 	 	 	 	 	*Required Entries	 	 
	Applicant Information
	 	 	 	 	 	 	 	 
	 
	 	 	 	 	 	 	 	 
	Applicant Company () Legal Name
	 	 	*	 	 	 	 	 
	DBA Name(s)
(if any)
	 	 	*	 	 	 	 	 
	Operating Company Number (OCN)
	 	 	*	 	 	 	 	 
	NENA ID
	 	 	*	 	 	 	 	 
	Contact Name
	 	 	*	 	 	 	 	 
	Contact Address1
	 	 	*	 	 	 	 	 
	Contact Address2
	 	 	 	 	 	 	 	 
	Contact City
	 	 	*	 	 	 	 	 
	Contact State
	 	 	*	 	 	 	 	 
	Contact Zip
	 	 	*	 	 	 	 	 
	Contact Telephone Number
	 	 	*	 	 	 	 	 
	Contact E-Mail Address
	 	 	*	 	 	 	 	 
	 
	 	 	 	 	 	 	 	 
	PSAP Information 
	 	 	 	 	 	 	 	 
	 
	 	 	 	 	 	 	 	 
	PSAP Name
	 	 	*	 	 	 	 	 
	PSAP State
	 	 	*	 	 	 	 	 
	PSAP County
	 	 	 	 	 	 	 	 
	PSAP Municipality
	 	 	 	 	 	 	 	 
	 
	 	 	 	 	 	 	 	 
	9-1-1 Governing Authority Contact Name

	 	 	*	 	 	 	 	 
	9-1-1 Governing Authority Contact Tel#
	 	 	*	 	 	 	 	 
	9-1-1 Governing Authority Contact E-mail
	 	 	 	 	 	 	 	 
	 
	 	 	 	 	 	 	 	 
	# ESQKs Requested
	 	 	 	 	 	 	 	 
	 
	 	 	 	 	 	 	 	 
	Valid NPAs for the area being served
	 	 	*	 	 	 	 	 
	NPA in which ESQK(s) have been requested
	 	 	*	 	 	 	 	 
	Total Number of ESQKs Requested
	 	 	*	 	 	 	 	 






Page 18









 






					
	pANI Interim Assignment Guidelines for ESQK	 	 
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Applicant Certification



I hereby
certify that I have read the “pANI Interim Assignment Guidelines for ESQK” and meet the
criteria required to obtain the requested number of ESQKs.




	 	 	 
	 

	 	VSP Authorized
Electronic Signature, or
	 

	 	 VPC Authorized Electronic Signature






Assignment (To be Completed by Interim 9-1-1 RNA)




	 	 	 	 	 
	A list of the ESQKs assigned
	 	 	 	 
	Date Assigned
	Assigned By	 	*	 
	 
	Interim 9-1-1 RNA Contact Name
	 	 	*	 
	Interim 9-1-1 RNA Contact Telephone Number
	 	 	*	 
	Interim 9-1-1 RNA E-mail Address
	 	 	*	 







By
applying for this resource, the applicant hereby certifies that it
has
obtained approval from the appropriate 9-1-1 Governing Authority to provide
routing or data retrieval for E9-1-1 traffic to the applicable PSAP. Should it
later be determined that such authority has not been obtained, the applicant will
be reported to the FCC and the appropriate state commission, and may be denied
further resources.



Page 19









 











 









 













 









 














 









 









			
	 	 	 
	 
	 
	 	
	 





National Pooling Administration




Change Order Proposal #46

(INC Issue 517 — “Denying NXX assignment to a service

provider that has opted into pooling”)




Companion to NANPA Change Order #6




September 19, 2006




	 	 	 
	 
	NeuStar, Inc.

	 	46000 Center Oak Plaza

Sterling VA, 20166
	 















 









			
	 	 	 
	Nat’l PAS — Change Order #46 (INC Issue 517)
	 	September 19, 2006
	 





Table of Contents




	 	 	 	 	 
	1 Introduction
	 	 	3	 
	2 Industry Numbering Committee (INC) Proposed Changes
	 	 	4	 
	3 The Proposal
	 	 	8	 
	4 Assumptions and Risks
	 	 	8	 
	5 Cost
	 	 	8	 
	6 Conclusion
	 	 	9	 






					
	 	 	 	 	 
	 
	© NeuStar, Inc. 2006
	 	NeuStar Proprietary and Confidential
	 	-ii-
















 






			
	 	 	 
	Nat’l PAS — Change Order #46 (INC Issue 517)
	 	September 19, 2006
	 




1 Introduction



1.1
Purpose and Scope


In accordance with NeuStar’s National Pooling Administration contract1 and our constant
effort to provide the best support and value to both the FCC and the telecommunications industry,
NeuStar, as the National Pooling Administrator (PA), hereby submits this Change Order Proposal to
the Federal Communications Commission (FCC) for approval. This change order complies with the
contractual requirements set forth in Attachment B, Section C of the Thousands-Block Pooling
Contractor Technical Requirements, dated November 30, 2000, Sections 2.5 through 2.5.4, which read
as follows:





2.5 Changes in the Environment




The FCC may issue rules, requirements, or policy directives in the future, which may increase,
decrease or otherwise modify the functions to be performed by the contractor. The contractor is
additionally subject to the provisions of the changes clause in Section I.




2.5.1 Process




Accordingly, after a contractor is selected, the FCC, the NANC and/or the INC may establish NANP
numbering resource plans, administrative directives, assignment guidelines (including modifications
to existing assignment guidelines), and procedures that may have an effect on the functions
performed by the contractor.




2.5.2 Changes




The contractor shall review changes when numbering resource plans, administrative directives,
assignment guidelines, and procedures are initiated or modified to determine if there is any impact
on the functions that they must perform.




2.5.3 Notifications




The contractor shall then, within a period of not more than 30 calendar days from said event (e.g.,
the date INC places an issue into Final Closure), provide the Contracting Officer, state PUCs, and
the NANC with written notice regarding these changes and summarize the potential impact of the
changes upon service and cost, if any.




2.5.4 Roles




The NANC shall review the notice and provide a recommendation to the FCC regarding the effect of
the contractor’s notice and supporting documentation.




The contractor shall comply with state regulatory decisions, rules and orders with respect to
pooling, as applicable, as long as they are not in conflict with FCC decisions, orders, and rules
and are within state jurisdiction.


 





1 FCC Contract Number CON01000016




					
	 	 	 	 	 
	 
	© NeuStar, Inc. 2006
	 	NeuStar Proprietary and Confidential
	 	-3-
















 






			
	 	 	 
	Nat’l PAS — Change Order #46 (INC Issue 517)
	 	September 19, 2006
	 




This document provides the information required by the contract, such as identifying the new
requirements of the expanded scope of work as a result of the Industry Numbering Committee’s (INC)
disposition of Issue 517 and NANPA change order #6 by offering our proposed solution, and
addressing its cost, risks, and assumptions. This change order is being created at the request of
the FCC prior to the INC final closure (section 2.5.3. of the technical requirements).




2 The Industry Numbering Committee (INC) Proposed Changes



On June 6, 2006, INC placed issue 517 into Initial Closure. In response, NANPA submitted change
order #6 to address how this issue affects both the NANP Administration System (NAS) and NANPA
operations. To comply with INC issue 517 and the NANPA change order #6, the PA will need to produce
daily information that will allow NANPA to determine the specific OCNs that are currently
participating in pooling in optional pooled rate centers, which is discussed in the proposal
section of this change order. The FCC has requested that the Pooling Administrator submit this
change order proposal at this time to enable the FCC to understand the complete process.





	•	 	Issue 517: Denying NXX assignment to SP that has OPTED into Pooling




The official INC issue statement is stated below and can also be found on the ATIS website
(www.atis.org):




A) ISSUE STATEMENT



NANPA has no way of knowing whether an SP has opted into pooling in a specific rate center, so it
is possible for that SP to request CO code resources in a rate center in which they have already
opted into participation in pooling.




B) FOLLOWING RESOLUTION FROM INC



The following changes were made to the COCAG and the TBPAG to resolve this issue:




COCAG Changes:



A new section 3.10 was created:





			
	3.10	 	If an SP has chosen to participate in thousands-block number pooling in a voluntary rate
center outside of the top 100 MSAs, the SP cannot withdraw from pooling in a voluntary rate center
once the SP has submitted a forecast, a donation, or has been assigned a thousands-block. Once an
SP chooses to participate in thousands-block number pooling in a voluntary rate center, all
numbering requests must be submitted directly to the PA.




4.1.1 The applicant must certify a need for NANP numbers, e.g., provision of wireline or wireless
service in the Public Switched Telephone Network.




					
	 	 	 	 	 
	 
	© NeuStar, Inc. 2006
	 	NeuStar Proprietary and Confidential
	 	-4-
















 







			
	 	 	 
	Nat’l PAS — Change Order #46 (INC Issue 517)
	 	September 19,2006
	 




In order to obtain CO codes, an applicant must submit or have submitted a
 North American Numbering
Plan Numbering Resource Utilization/Forecast (NRUF) Report (See NRUF Reporting Guidelines) to the
NANPA for the NPA(s) in which the CO code(s) is being
requested.2 This requirement shall not apply
in instances where an NPA has been implemented since the last NRUF Report and the Service Provider
has submitted a NRUF Report for the NPA(s) previously serving the geographic areas involved.



The applicant must submit an NXX request form certifying that a need exists for an NXX assignment
to a point of interconnection or a switching entity due to routing, billing, regulatory, or tariff
requirements. The NXX request form must provide an Operating Company Number (OCN), which uniquely
identifies the applicant. The NANPA will not issue numbering resources
to a carrier without an OCN.3 The OCN cannot be shared with another service provider.



If NANPA determines from the report provided by the PA that an applicant is participating in
pooling in that rate center, NANPA will deny the application. Once an applicant chooses to
participate in thousands-block number pooling in a voluntary rate center, all numbering requests
must be submitted directly to the PA.



5.2 Receive and process applications (CO Code (NXX) Assignment Request Form Part 1) for CO
codes (NXX) within the geographic NPA(s) for which the CO Code Administrator is responsible.


For rate centers transitioning to pooling:





	•	 	The CO Code Administrator will only process NXX requests received at least 33 calendar
days prior to the Pool Start Date.
	 
	•	 	Within the 33 calendar days prior to Pool Start Date, applications for codes/blocks will not
be
accepted. However within this 33-day interval, the NANPA will continue to process code applications
for:






	 	•	 	CO codes awarded via lottery;
	 
	 	•	 	LRN requests;
	 
	 	•	 	full CO code request for a single customer;
	 
	 	•	 	CO code expedite requests;
	 
	 	•	 	petition/safety valve requests;
	 
	 	•	 	any requests from non-pooling capable carriers; and
	 
	 	•	 	PA requests to the NANPA.




After Pool Start Date, all pooling-capable carriers will apply to the PA for numbering resources.



Once an SP chooses to participate in thousands-block number pooling in a voluntary rate center,
all numbering requests must be submitted directly to the PA. NANPA
will not assign a CO code (NXX) to an SP for a voluntary pooled rate center in which that SP has



 





2 FCC 00-104, § 52.15 (f) (4) (5).



3 FCC 01-362, §52.15(g)(4).




					
	 	 	 	 	 
	 
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	Nat’l PAS — Change Order #46 (INC Issue 517)
	 	September 19, 2006
	 




either submitted a forecast to the PA, submitted a donation to the PA. or has been
assigned a thousands-block in that rate center.



TBPAG Changes:





	2.4	 	These administration guidelines apply only to the assignment of thousands-blocks to Block
Applicants providing service within specific rate areas:






	 	a)	 	where SP Location Routing Number (LRN) Local Number Portability (LNP) has been implemented;
	 
	 	b)	 	where thousands-block number pooling has been mandated by the appropriate regulatory body; 
	 
	 	c)	 	where an SP has chosen to participate in thousands-block number pooling in a voluntary rate
center outside of the top 100 MSAs, the SP cannot withdraw from pooling in a voluntary rate center
once the SP has submitted a forecast or donation, or has been assigned a thousands-block. Once an
SP chooses to participate in thousands-block number pooling in a voluntary rate center all
numbering requests must be
submitted directly to the PA4.






	5.1.1	 	The PA, upon request, shall provide information and answer questions for clarification
regarding thousands-block number pooling administration processes, procedures, interfaces, and
services. Additionally, the PA shall provide, upon request of the thousands-block number pooling
participant, information on how to obtain documents related to thousands-block number pooling
administration. This can be accomplished by either referring the SP to web sites where it will be
possible to download electronic copies, or by providing electronic copies via e-mail.


The PA shall:






	 	a)	 	be responsible for activities associated with industry inventory pool establishment;
	 
	 	b)	 	assure the availability, based upon industry established criteria, of numbering resources
within the industry inventory pool for a given rate area;
	 
	 	c)	 	add to the resources in the industry inventory pool when necessary by requesting additional CO
Codes from the CO Code Administrator using Months to Exhaust Certifications Worksheet-1000 Block
Level (Appendix 4);
	 
	 	d)	 	work with the CO Code Administrator in the planning and implementation of NPA code relief
(e.g., update the PA’s industry database to reflect any changes




 





4 The PA will provide a report to NANPA of the SPs participating in pooling in a
voluntary rate center outside of the top 100 MSAs. If NANPA determines from the report that an SP
is participating in pooling in a voluntary rate center, NANPA will deny a CO Code application for
that rate center.




					
	 	 	 	 	 
	 
	© NeuStar, Inc. 2006
	 	NeuStar Proprietary and Confidential
	 	-6-
















 










			
	 	 	 
	Nat’l PAS — Change Order #46 (INC Issue 517)
	 	September 19, 2006
	 






resulting from NPA relief activity). For specific details, see NPA Code Relief Planning &
Notification Guidelines (ATIS-0300061);




	 	e)	 	provide copies of the Thousands-Block Number (NXX-X) Pooling Administration Guidelines
(ATIS-0300066) when requested by Block Applicants, including timely notification of changes;
	 
	 	f)	 	assist the CO Code Administrator in analyzing and helping to resolve problems related to
misrouted calls and calls that cannot be completed;
	 
	 	g)	 	track reported switch cut-overs and thousands-block reassignments and perform other
operational functions (e.g., thousands-block reclamation);
	 
	 	h)	 	make available on their web site the PA-recognized holidays and distribute as necessary;
	 
	 	i)	 	log and track all thousands-block applications using a tracking mechanism which will enable
the PA and Block Applicant to identify a specific thousands-block request; and
	 
	 	j)	 	build and maintain an industry data base which includes appropriate security for confidential
data. The database will be accessible through an appropriate mechanism and, at a minimum, include
the following information:
	 
	 	1)	 	all pooled thousands-blocks in the industry inventory pool (i.e., NPA-NXX-X level information
displayed),
	 
	 	2)	 	status of the thousands-blocks (i.e., allocated/assigned, available),
	 
	 	3)	 	identification of the SP to which the thousands-block has been allocated, whether or not a
thousands-block is contaminated,
	 
	 	4)	 	user profile(s) that contain the SP contact information, OCN, and level of access permitted.
An SP may need multiple individual profiles and passwords (See Appendix 5 — User Profile
Application).
	 
	 	k)	 	set the “Pool Indicator” on the CO Code ACD screen in BIRRDS for those NXX codes from which
thousands-blocks have been donated to the pool after Block Donation Date.
	 
	 	l)	 	provide a report to NANPA of the SPs participating in pooling in a voluntary rate
center outside of the top 100 MSAs. NANPA shall deny any CO Code application from an SP
that is participating in pooling in a voluntary rate center.





					
	 	 	 	 	 
	 
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	 	NeuStar Proprietary and Confidential
	 	-7-
















 









			
	 	 	 
	Nat’l PAS — Change Order #46 (INC Issue 517)
	 	September 19, 2006
	 




3 The Proposal



NeuStar’s National Pooling Administrator has reviewed INC issue 517 and NANPA Change Order #6 from
both the operational and technical perspectives. The proposal set forth below will conform to the
changes in the INC guidelines and the NANPA change order while meeting the requirements of the
industry in a cost-effective and efficient manner.



Solution



To satisfy the requirements identified in the INC issue, the PA will produce daily information that
will allow NANPA to determine specific OCNs that are currently participating in pooling in optional
pooled rate centers. On a daily basis, the National Pooling Administrator (PA) will provide NANPA
with a file containing the following information: NPA, rate center(s) where pooling is voluntary
(also known as optional), and the Operating Company Number(s) (OCN) of those service providers that
are participating in pooling in the identified voluntary rate center(s).



4 Assumptions and Risks



Part of the PA’s assessment of this change order is to identify the associated assumptions and
consider the risks that can have an impact on our operations. 

This change order does not affect the system nor will it have any impact on our day-to-day
application-processing operations.



5 Cost



As with any change order proposal, we also considered the associated costs that would potentially
be incurred in implementing the proposed solution. These costs include the resources required to
complete the milestones on a timeline for implementing the processes and system delineated in this
change order. The timeline includes preparation, proper documentation updates, development,
testing, monitoring, and execution of the solution.
 

The anticipated cost to implement this proposed solution is $3200.00, which includes the price for
the overtime staff hours that will be required to perform this task. The PA staff members are
already carrying heavy workloads, due to the steady rise in volumes, which have increased
significantly over the past few months. We respectfully request that this change order be approved
giving the PA authorization to charge straight overtime for the staff members involved in the
project.



The alternative would be to hire a temporary employee for this project, but we have considered and
rejected that option because it would not facilitate timely completion of the project, or keep
costs down, for the following reasons:



•  it would add the time of posting the position,
interviewing, and obtaining the appropriate
security clearance for the person



•  training time would be needed.




					
	 	 	 	 	 
	 
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	 	NeuStar Proprietary and Confidential
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	Nat’l PAS — Change Order #46 (INC Issue 517)
	 	September 19,2006
	 




6 Conclusion



In conclusion, the Pooling Administrator offers a viable solution that meets the requirements of
both INC issue 517 and the NANPA change order #6. In accordance with our contract terms, and we
request that the FCC review and approve this change order.




					
	 	 	 	 	 
	 
	© NeuStar, Inc. 2006
	 	NeuStar Proprietary and Confidential
	 	-9-
















 




















 























 






















 













	 	 	 
	 

	 	Contract No. CON01000016
	 

	 	Modification
No. Twenty-Four (24)
	 

	 	Page 4 of 4





1. FAR Clause 52.217-9, Option to Extend the Term of the Contract, is hereby
incorporated for the Option Periods and reads as follows:




52.217-9
Option to Extend the Term of the Contract (Mar 2000)



(a) The Government may extend the term of this contract by written notice to the Contractor within
five (5) business days; provided that the Government gives the Contractor a preliminary written
notice of its intent to extend at least seven (7) business days before the contract expires. The
preliminary notice does not commit the Government to an extension.



(b) If the Government exercises this option, the extended contract shall be considered to include
this option clause.



(c) The total duration of this contract, including the exercise of any options under this clause,
shall not exceed five (5) months.














 























 






















 























 






 





 





National Pooling Administration




Change Order Proposal #44




(INC Issue #486 — “Contaminated or Pristine Assigned

Block Returns”)




December 7, 2005




	 	 	 	 	 
	   
	NeuStar, Inc.
	 	 	 	46000 Center Oak Plaza
	 
	 	 	 	Sterling VA, 20166
	 





 









 






	 	 	 	 	 
	Nat’l PAS — Change Order #44 (INC Issue 486)

	 	 
	 	December 7, 2005
	 





Table of Contents




	 	 	 	 	 	 	 
	1

	 	Introduction
	 	 	3	 
	2

	 	Industry Numbering Committee’s Proposed Change
	 	 	4	 
	3

	 	The Proposal
	 	 	6	 
	4

	 	Assumptions and Risks
	 	 	6	 
	5

	 	Cost
	 	 	6	 
	6

	 	Conclusion
	 	 	6	 
	 
	 	 	 	 	 	 





	 	 	 	 	 
	 
	© NeuStar, Inc. 2005

	 	NeuStar Proprietary and Confidential
	 	- ii -






 









 






	 	 	 	 	 
	Nat’l PAS — Change Order #44 (INC Issue 486)

	 	 
	 	December 7, 2005
	 





1 Introduction




1.1 Purpose and Scope



In accordance with NeuStar’s National Pooling Administration
contract1 and our constant effort to provide the best support and value to
both the FCC and the telecommunications industry, NeuStar, as the National Pooling
Administrator (PA), hereby submits this change order proposal to the Federal
Communications Commission (FCC) for approval. This change order complies with the
contractual requirements set forth in Attachment B, Section C of the Thousands-Block
Pooling Contractor Technical Requirements, dated November 30, 2000, Sections 2.5
through 2.5.4, which read as follows:





2.5 Changes in the Environment




The FCC may issue rules, requirements, or policy directives in the future,
which may increase, decrease or otherwise modify the functions to be
performed by the contractor. The contractor is additionally subject to the
provisions of the changes clause in Section I.




2.5.1 Process




Accordingly, after a contractor is selected, the FCC, the NANC and/or the
INC may establish NANP numbering resource plans, administrative
directives, assignment guidelines (including modifications to existing
assignment guidelines), and procedures that may have an effect on the
functions performed by the contractor.




2.5.2 Changes




The contractor shall review changes when numbering resource plans,
administrative directives, assignment guidelines, and procedures are initiated
or modified to determine if there is any impact on the functions that they must
perform.




2.5.3 Notifications




The contractor shall then, within a period of not more than 30 calendar days
from said event (e.g., the date INC places an issue into Final Closure), provide
the Contracting Officer, state PUCs, and the NANC with written notice regarding
these changes and summarize the potential impact of the changes upon service and
cost, if any.




2.5.4 Roles




The NANC shall review the notice and provide a recommendation to the FCC
regarding the effect of the contractor’s notice and supporting documentation.





 




			
	1	 	FCC Contract Number CON01000016





	 	 	 	 	 
	 
	© NeuStar, Inc. 2005

	 	NeuStar Proprietary and Confidential
	 	- 3 -






 









 






	 	 	 	 	 
	Nat’l PAS — Change Order #44 (INC Issue 486)

	 	 
	 	December 7, 2005
	 






The contractor shall comply with state regulatory decisions, rules and
orders with respect to pooling, as applicable, as long as they are not in
conflict with FCC decisions, orders, and rules and are within state
jurisdiction.


This document provides the information required by the contract, such as identifying the
new requirements of the expanded scope of work as a result of the Industry Numbering
Committee’s (INC) disposition of Issue 486, offering our assumptions and proposed
solution, and addressing its cost and risks.




2 Industry Numbering Committee’s Proposed Change



On November 25, 2005, INC placed Issue 486 into Final Closure. As a result of
this resolution of INC Issue 486, a remarks field was added to the Part 1A form.
Therefore, PAS will need to be updated to reflect the addition of the remarks field.




INC Issue 486 Contaminated or Pristine Assigned Block Returns



Quoted below are the INC official issue statement and final resolution, which can
also be found on the ATIS website (http://www.atis.org):





A) Issue Statement




Today, when the PA assigns a thousands-block to a block holder, the
PA must complete the ‘Block Contaminated (Yes or No)” field on the Part 3
form. However, when blocks are returned back to the Pool via the Part 1A
form, the block holder does not need to indicate if the block is
contaminated or not. Therefore, changes should be made to the TBPAG and the
Part 1A form, requiring block holders to indicate if the thousands-block
being disconnected is contaminated or pristine.




B) Final Resolution




The following underlined text was added to the TBPAG Section 9.1.2:



9.1.2 The Block Holder to which a thousands-block(s) has been
assigned from the industry inventory pool shall return the
thousands-block(s) via the Part 1A form to the PA if:




	 	a)	 	it is no longer needed by the entity for the purpose
for which it was originally assigned;
	 
	 	b)	 	the service it was assigned for is disconnected; or





	 	 	 	 	 
	 
	© NeuStar, Inc. 2005

	 	NeuStar Proprietary and Confidential
	 	- 4 -






 









 





	 	 	 	 	 
	Nat’l PAS — Change Order #44 (INC Issue 486)

	 	 
	 	December 7, 2005
	 






	 	c)	 	the thousands-block(s) was not placed in service within six months
of the original block effective date returned on the Part 3 and entered
onto the BCR/BCD screen in BIRRDS.






The block holder is required to notate in the Remarks field on the Part
1A form whether the thousands-block is contaminated or pristine.



In addition, a new “Remarks” field is to be added to Part 1A as shown below:




1.5 Type of Request




Initial block for rate center: Yes                    , If Yes attach evidence of authorization and proof

of capability to provide

Service within 60 days




Growth block for rate center: Yes                    , If Yes, attach months to exhaust worksheet




Change
block: Yes                    , If Yes, indicate NPA-NXX-X, type of and reason for change:




      




Disconnect block: Yes                      , If Yes, list NPA-NXX-X                                        




Remarks:




 




I hereby certify that the above information requesting an NXX-X block is true and
accurate to the best of my knowledge and that this application has been prepared in
accordance with the Thousands-Block (NXX-X) Pooling Administration Guidelines
AT1S-0300066




	 	 	 	 	 
	 

	 	 
	 	 
	Signature of Block Applicant

	 	Title
	 	Date     
	 





	 	 	 	 	 
	 
	© NeuStar, Inc. 2005

	 	NeuStar Proprietary and Confidential
	 	- 5 -






 









 





	 	 	 	 	 
	Nat’l PAS — Change Order #44 (INC Issue 486)

	 	
	 	December 7, 2005
	 





3 The Proposal



NeuStar’s National Pooling Administrator has reviewed INC Issue 486 from both the
operational and technical perspectives. The proposal set forth below will conform to the
changes in the INC guidelines and meet the requirements of the industry in a cost-effective
and efficient manner.




Solution



Add a new remarks field to the Part 1A form in PAS to allow the block holder returning the
thousands-block to indicate whether the thousands-block is contaminated or pristine.




4 Assumptions and Risks



Part of the PA’s assessment of this change order is to identify the associated assumptions
and consider the risks that can have an impact on our operations.



This change order affects only the system, and would have no impact on our day-to-day
operations.




5 Cost



As with any change order proposal, we also considered the associated costs that would
potentially be incurred in implementing the proposed solution. These costs include the
resources required to complete the milestones on a timeline for implementing the processes and
system delineated in this change order. The timeline includes preparation, proper
documentation updates, development, testing, monitoring, and execution of the solution.



The cost to implement our proposed solution would be $ 4,793.00.




6 Conclusion



In conclusion, the Pooling Administrator offers this viable solution to conform the PAS
to INC Issue 486, and, in accordance with contract terms, requests that the FCC review and
approve this change order.




	 	 	 	 	 
	 
	© NeuStar, Inc. 2005

	 	NeuStar Proprietary and Confidential
	 	- 6 -







 










 





 








 





National Pooling Administration




Change Order Proposal #47

(INC Issue 516 —  “Update the TBPAG Part 4 Form”)




October 10, 2006




	 	 	 
	 
	NeuStar, Inc.

	 	46000 Center Oak Plaza
	 

	 	Sterling VA, 20166
	 





 









 





	 	 	 
	Nat’l PAS — Change Order #47 (INC Issue 516)

	 	October 10, 2006
	 





Table of Contents




	 	 	 	 	 	 
	1

	 	Introduction .
	 	 	3
	2

	 	Industry Numbering Committee (INC) Proposed Changes
	 	 	4
	3

	 	The Proposal
	 	 	6
	4

	 	Assumptions and Risks
	 	 	6
	5

	 	Cost
	 	 	6
	6

	 	Conclusion
	 	 	6






	 	 	 	 	 
	 
	© NeuStar, Inc. 2006

	 	NeuStar Proprietary and Confidential
	 	- ii -






 









 





	 	 	 
	Nat’l PAS — Change Order #47 (INC Issue 51 6)

	 	October 10, 2006
	 





1 Introduction




1.1 Purpose and Scope



In accordance with NeuStar’s National Pooling Administration contract1 and our
constant effort to provide the best support and value to both the FCC and the telecommunications
industry, NeuStar, as the National Pooling Administrator (PA), hereby submits this Change Order
Proposal to the Federal Communications Commission (FCC) for approval. This change order complies
with the contractual requirements set forth in Attachment B, Section C of the Thousands-Block
Pooling Contractor Technical Requirements, dated November 30, 2000, Sections 2.5 through 2.5.4,
which read as follows:





2.5 Changes in the Environment




The FCC may issue rules, requirements, or policy directives in the future, which may
increase, decrease or otherwise modify the functions to be performed by the contractor. The
contractor is additionally subject to the provisions of the changes clause in Section I.




2.5.1 Process




Accordingly, after a contractor is selected, the FCC, the NANC and/or the INC may
establish NANP numbering resource plans, administrative directives, assignment guidelines
(including modifications to existing assignment guidelines), and procedures that may have an
effect on the functions performed by the contractor.




2.5.2 Changes




The contractor shall review changes when numbering resource plans, administrative
directives, assignment guidelines, and procedures are initiated or modified to determine if
there is any impact on the functions that they must perform.




2.5.3 Notifications




The contractor shall then, within a period of not more than 30 calendar days from said
event (e.g., the date INC places an issue into Final Closure), provide the Contracting
Officer, state PUCs, and the NANC with written notice regarding these changes and summarize
the potential impact of the changes upon service and cost, if any.




2.5.4 Roles




The NANC shall review the notice and provide a recommendation to the FCC regarding the
effect of the contractor’s notice and supporting documentation.




The contractor shall comply with state regulatory decisions, rules and orders with respect
to pooling, as applicable, as long as they are not in conflict with FCC decisions, orders,
and rules and are within state jurisdiction.





 




			
	1	 	FCC Contract Number CON01000016





	 	 	 	 	 
	 
	© NeuStar, Inc. 2006

	 	NeuStar Proprietary and Confidential
	 	-3-






 









 





	 	 	 
	Nat’l PAS — Change Order #47 (INC Issue 516)

	 	October 10, 2006
	 




This document provides the information required by the contract, such as identifying the new
requirements of the expanded scope of work as a result of the Industry Numbering Committee’s (INC)
disposition of Issue 516 by offering our proposed solution, and addressing its cost, risks, and
assumptions.




2 Industry Numbering Committee (INC) Proposed Changes



On
September 22, 2006, INC placed issue 516 into Final Closure. As a result of this
resolution of INC Issue 516, the Part 4 Confirmation of NXX-X Block in Service form was
updated to add additional fields and correspond to the NANPA Part 4 form. Because of these
changes, PAS will need to be updated to reflect the changes of the Part 4 form.





	•	 	Issue 516: Update the TBPAG Part 4 Form




The official INC issue statement is stated below and can also be found on the ATIS
website (www.atis.org):




A) ISSUE STA TEMENT



The TBPAG Thousands-Block Application Form — Part 4 Confirmation of NXX-X Block In Service
dated 8/6/01 currently does not have the Company Name or OCN fields on the form. Based on feedback
the PA received from a state regulator it would be of value to the regulators if the TBPAG Part 4
form was updated to include those fields.



Also, to be consistent with the COCAG Part 4 forms, additional updates should be made to the TBPAG
Part 4 form as well.





B) FOLLOWING RESOLUTION FROM INC


The following text changes were made to the TBPAG Thousands-Block Application Form Part 4:




Thousands-Block Number Pooling Administration Guidelines (TBPAG) Thousands-Block

(NXX-X) .Confirmation Form

Part 4




Confirmation of NXX-X Block In Service (Required)



By signing below, I certify that the block (NXX-X) specified in Section 1 below is, activated and
assignment of the numbers has commenced and is being used for the purpose specified in the original
application.2






 




			
	2	 	FCC 00-104§ 237.





	 	 	 	 	 
	 
	© NeuStar, Inc. 2006

	 	NeuStar Proprietary and Confidential
	 	-4-






 









 





	 	 	 
	Nat’l PAS — Change Order #47 (INC Issue 516)

	 	October 10, 2006
	 





Company Name:




OCN:





	 	 	 	 	 	 	 	 
	Print Name of Authorized Representative of Company/Entity

	 	Signature	 
	 
	Company Name: 

	 	 	 	 	 	 
	 
	Telephone Number: 

	 	 	 	 	 
	 
	Email:

	 	 	 	 	 	 	 
	 
	Fax Number:

	 	 	 	 	 	 
	 
	 

	 	 	 	Date 	 	 
	 
	1. NPA-NXX-X block: 

	 	 	Rate Center:	 
	 
	
2. Switch Identification (SwitchingEntity /POI)
3:

	 	 	 
	
 




	 	 	 
	 
	3. Original Effective Date: 

	 	 	 	 
	 
	4. In Service Date4: 

	 	 	 	 	 








Note: State commissions may request proof from all block holders that an NXX-X block, has
been activated and assignment of the numbers has commenced.5






 




			
	3	 	This is an 11-character descriptor of the switch provided by the owning
entity for the purpose of routing calls.  It is the 11-character COMMON LANGUAGE Location
Identification (CLLITM) of the switch/POI shown on the Part 1A form.
	 
	4	 	A code or block for which local routing information has been input to the LERG
Routing Guide and the carrier has begun to activate and assign numbers within the NXX code or
NXX-X block to end users (FCC 00-104,¶240). This form must be submitted to the PA within six months of the original effective
date returned on the Part 3, and entered on the BCR/BCD screen in BIRRDS or reclamation procedures
will commence.
	 
	5	 	FCC 00-104¶237.





	 	 	 	 	 
	 
	© NeuStar, Inc. 2006

	NeuStar Proprietary and Confidential
	-5-






 









 





	 	 	 
	Nat’l PAS — Change Order #47 (INC Issue 516)

	 	October 10, 2006
	 





3 The Proposal



NeuStar’s National Pooling Administrator has reviewed INC issue 516 from both the operational
and technical perspectives. The proposal set forth below will conform to the changes in the INC
guidelines while meeting the requirements of the industry in a cost-effective and efficient manner.




Solution



In order to address the changes in the TBPAG, the PA will modify the current Part 4
Confirmation of NXX-X Block in Service form in PAS, to include the following new fields:
company name, OCN, telephone number, email address, fax number, rate center, and original effective
date. The system will be modified to enable the telephone number, email address, and fax number to
be pre-populated from the PAS user’s profile. The company name, OCN, and rate center will be
pre-populated based on the current thousand block assignment information in PAS. In addition, the
form content will be updated to reflect the additional changes from INC.




4 Assumptions and Risks



Part of the PA’s assessment of this change order is to identify the associated assumptions
and consider the risks that can have an impact on our operations.



This change order affects only the system, and would have no impact on our day-to-day
operations.




5 Cost



As with any change order proposal, we also considered the associated costs that would
potentially be incurred in implementing the proposed solution. These costs include the resources
required to complete the milestones on a timeline for implementing the processes and system
delineated in this change order. The timeline includes preparation, proper documentation updates,
development, testing, monitoring, and execution of the solution.



The cost to implement our proposed solution would be $5296.00.




6 Conclusion



In conclusion, the Pooling Administrator offers a viable solution that meets the needs of INC
issue 516, and, in accordance with our contract terms, we request that the FCC review and approve
this change order proposal.




	 	 	 	 	 
	 
	© NeuStar, Inc. 2006

	 	NeuStar Proprietary and Confidential
	 	-6-







 









 


















 


















 


















 





 








 





National Pooling Administration




Change Order Proposal #49




(Issue 523: Pooled Blocks Pending Verification of LERG Assignee Responsibilities)




December 15, 2006




	 	 	 	 	 
	 
	NeuStar, Inc.
	 	46000 Center Oak Plaza
	 
	 	Sterling VA, 20166
	 













 





	 	 	 
	Nat’l PAS — Change Order #49 (INC Issue 523)

	 	December 15, 2006
	 





Table of Contents




	 	 	 	 	 	 	 
	1
	 	Introduction	 	 	3	 
	2
	 	Industry Numbering Committee (INC) Proposed Changes	 	 	4	 
	3
	 	The Proposal	 	 	5	 
	4
	 	Assumptions and Risks	 	 	6	 
	5
	 	Cost	 	 	6	 
	6
	 	Conclusion	 	 	6	 






	 	 	 	 	 
	 
	© NeuStar, Inc. 2006

	 	NeuStar Proprietary and Confidential
	 	-ii-














 





	 	 	 
	Nat’l
PAS—Change Order #49 (INC Issue 523)

	 	December 15,2006
	 





1 Introduction




1.1 Purpose and Scope




In accordance with NeuStar’s National Pooling Administration contract1 and our
constant effort to provide the best support and value to both the FCC and the telecommunications
industry, NeuStar, as the National Pooling Administrator (PA), hereby submits this Change Order
Proposal to the Federal Communications Commission (FCC) for approval. This change order complies
with the contractual requirements set forth in Attachment B, Section C of the Thousands-Block
Pooling Contractor Technical Requirements, dated November 30, 2000, Sections 2.5 through 2.5.4,
which read as follows:




2.5 Changes in the Environment




The FCC may issue rules, requirements, or policy directives in the future, which may
increase, decrease or otherwise modify the functions to be performed by the contractor. The
contractor is additionally subject to the provisions of the changes clause in Section I.




2.5.1 Process




Accordingly, after a contractor is selected, the FCC, the NANC and/or the INC may
establish NANP numbering resource plans, administrative directives, assignment guidelines
(including modifications to existing assignment guidelines), and procedures that may have
an effect on the functions performed by the contractor.




2.5.2 Changes




The contractor shall review changes when numbering resource plans, administrative
directives, assignment guidelines, and procedures are initiated or modified to determine if
there is any impact on the functions that they must perform.




2.5.3 Notifications




The contractor shall then, within a period of not more than 30 calendar days from said
event (e.g., the date INC places an issue into Final Closure), provide the Contracting
Officer, state PUCs, and the NANC with written notice regarding these changes and summarize
the potential impact of the changes upon service and cost, if any.




2.5.4 Roles




The NANC shall review the notice and provide a recommendation to the FCC regarding
the effect of the contractor’s notice and supporting documentation.




The contractor shall comply with state regulatory decisions, rules and orders with
respect to pooling, as applicable, as long as they are not in conflict with FCC decisions,
orders, and rules and are within state jurisdiction.





 




			
	1	 	FCC Contract Number CON01000016





	 	 	 	 	 
	 
	© NeuStar, Inc. 2006

	 	NeuStar Proprietary and Confidential
	 	- 3 -














 





	 	 	 
	Nat’l PAS — Change Order #49 (INC Issue 523)

	 	December 15, 2006
	 





This document provides the information required by the contract, such as identifying the new
requirements of the expanded scope of work as a result of the Industry Numbering Committee’s (INC)
disposition of Issue 523 by offering our proposed solution, and addressing its cost, risks, and
assumptions.




	2	 	 Industry Numbering Committee (INC) Proposed Changes





On November 17, 2006, INC placed issue 523 into Final Closure. As a result of this resolution
of INC Issue 523, PAS will no longer accept a Part 4 for a block that is assigned to the LERG
Assignee from an NXX where the LERG Assignee has not confirmed to the PA that the NXX has been
activated in the PSTN, loaded in the NPAC, and all other LERG Assignee responsibilities have been
fulfilled.



Issue 523: Pooled Blocks Pending Verification of LERG Assignee Responsibilities




The official INC issue statement is stated below and can also be found on the ATIS
website (www.atis.org):




	A)	 	ISSUE STATEMENT





Today, there are pending “RED” blocks in PAS from pooled codes for which the PA has not
received the email verification from the LERG assignee that the LERG assignee has activated the
code in the PSTN, loaded it in the NPAC, and has fulfilled all other LERG assignee
responsibilities. However, in some cases, Part 4 form(s) have been submitted for the blocks.



The LERG Assignee continues to receive the PSTN email notifications and the status of the
blocks in PAS remain pending even though there are Part 4 form(s) on file.



Text need to be added to section 7.5.4 of the TBPAG to state that PAS will not accept a Part 4
form until the PA has received the email response from the LERG Assignee




	B)	 	FOLLOWING RESOLUTION FROM INC





The following modifications were made to Section 7.5.4 of the TBPAG:





	7.5.4	 	PA and LERG Assignee Tasks






	 	•	 	On the original Part 3 NXX effective date, PAS will automatically generate an e-mail
to the LERG Assignee asking that the LERG Assignee verify that the pooled NXX has been activated
in the PSTN. This means the LERG Assignee confirms that facilities and translations
are in place and a call through test2 was successfully performed. The LERG Assignee is
required to send an e-mail response to the PA within five (5) business days indicating the
status of the NXX.
	 
	 	•	 	If the LERG Assignee confirms the NXX has been activated in the PSTN,
loaded in the NPAC, and all other LERG Assignee responsibilities have been fulfilled, the PA shall,
within 2 business days, change the status of the blocks in PAS to ‘available for assignment’ to any SP.







 




			
	2	 	See ATIS-0300032, Network Interconnection Interoperability Forum Reference Document, Part 10





	 	 	 	 	 
	 
	© NeuStar, Inc. 2006

	 	NeuStar Proprietary and Confidential
	 	- 4 -














 





	 	 	 
	Nat’l PAS — Change Order #49 (INC Issue 523)

	 	December 15, 2006
	 







	 	•	 	If the LERG Assignee fails to respond, or tells the PA that the NXX has not been
activated in the PSTN, the status of the blocks in PAS remains unchanged. PAS will
continue to generate an e-mail message to the LERG Assignee requesting status of the NXX.
This e-mail will be sent every 10th  calendar day until the LERG Assignee responds to the
PA with a confirmation that the NXX has been activated in the PSTN,
loaded in the NPAC,
and all other LERG Assignee responsibilities have been fulfilled or until the code is
reclaimed by the CO Code Administrator.
	 
	 	 	 	PAS will not accept a Part 4 form for a block assigned to the LERG Assignee from an NXX
for which the LERG Assignee has not confirmed to the PA that the NXX has been activated in
the PSTN, loaded in the NPA, and all other LERG Assignee responsibilities have been
fulfilled. Once the LERG Assignee confirms that the NXX has been activated in the PSTN,
loaded in the NPAC, and all other LERG Assignee responsibilities have been fulfilled, the PA
shall, within 2 business days, change the status of the NXX in PAS and then the LERG
Assignee will be able to successfully submit a Part 4 form into
PAS.
	 
	 	 	 	PAS will accept a Part 4 form for a block assigned to a block holder that is not the
LERG Assignee on or after the LERG Effective Date of the block. However, the PA will not
change the status of any remaining blocks in PAS to ‘available for assignment’ until the
PA receives the confirmation e-mail from the LERG Assignee that the NXX has been
activated in the PSTN, loaded in the NPAC, and all other LERG Assignee responsibilities
have been fulfilled.





3 The Proposal




NeuStar’s National Pooling Administrator has reviewed INC issue 523 from both the operational
and technical perspectives. The proposal set forth below will conform to the changes in the INC
guidelines while meeting the requirements of the industry in a cost-effective and efficient manner.



Currently, when new codes are opened for pooling for LRN purposes or pool replenishment purposes,
the LERG assignee is supposed to notify the PA via email once the NXX has been activated in the
PSTN and loaded in the NPAC. Upon this notification, the PA updates the code activation indicator
in PAS from “no” to “yes.” However, LERG assignees sometimes submit a Part 4 withouth having sent
the notification. Other service providers that are assigned blocks from such a code may not be able
to activate them. Therefore the TBPAG was revised as a result of INC issue 523 to require that the
LERG assignee notify the PA of the code activation status prior to submitting the Part 4.



Solution




In order to satisfy the requirements of INC issue 523, PAS will be modified to either accept
or reject the Part 4 from the LERG assignee based on the code activation indicator in PAS. If the
code activation indicator in PAS is marked as “yes” and all other Part 4 criteria have been met,
then PAS will accept the Part 4 from the LERG assignee. If the code activation indicator in PAS is
marked as “no”, PAS will reject the Part 4 from the LERG assignee and provide a rejection message
to the user:



	 	 	 	 	 
	 
	© NeuStar, Inc. 2006

	 	NeuStar Proprietary and Confidential
	 	- 5 -














 





	 	 	 	 	 
	Nat’l PAS — Change Order #49 (INC Issue 523)
	 	December 15, 2006
	 





In addition, additional language will be added to the PSTN Reminder email notifying the LERG
Assignee of the possible rejection of any Part 4 submissions for blocks associated with codes not
activated in the PSTN.



Even though the code activation indicator in PAS is “no,” as long as all other Part 4 criteria have
been met, the Part 4 will continue to be accepted from a block holder who is not also the LERG
assignee.



4 Assumptions and Risks




Part of the PA’s assessment of this change order is to identify the associated assumptions and
consider the risks that can have an impact on our operations.



This change order affects only the system, and would have no impact on our day-to-day
operations.



5 Cost




As with any change order proposal, we also considered the associated costs that would
potentially be incurred in implementing the proposed solution. These costs include the resources
required to complete the milestones on a timeline for implementing the processes and system
delineated in this change order. The timeline includes preparation, proper documentation updates,
development, testing, monitoring, and execution of the solution.



The cost to implement our proposed solution would be $2381.00



6 Conclusion




In conclusion, the Pooling Administrator offers a viable solution that meets the needs of INC
issue 523 and is in accordance with our contract terms. Therefore, we request that the FCC review
and approve this change order.



	 	 	 	 	 
	 
	© NeuStar, Inc. 2006

	 	NeuStar Proprietary and Confidential
	 	- 6 -















 






 









 





National Pooling Administration




Change Order Proposal #50




(Issue 527: Blocks with Effective Dates earlier than the NXX



activation date of associated LRN)




December 15,
2006




 





	NeuStar, Inc.
	 	46000 Center Oak Plaza
	 
	 	Sterling VA, 20166





 





 









 







Nat’l
PAS — Change Order #50 (INC Issue 527)







December 15, 2006







 





Table of Contents




	 	 	 	 	 	 	 
	1

	 	Introduction
	 	 	3	 
	2

	 	Industry Numbering
Committee (INC) Proposed
Changes
	 	 	4	 
	3

	 	The Proposal
	 	 	4	 
	4

	 	Assumptions and
Risks
	 	 	5	 
	5

	 	Cost
	 	 	5	 
	6

	 	Conclusion
	 	 	5	 






 





	© NeuStar, Inc. 2006

	 	NeuStar Proprietary and Confidential
	 	-ii-






 









 







Nat’l PAS — Change Order #50 (INC Issue 527)







December 15,
2006







 





1 Introduction




1.1 Purpose and Scope



In accordance with NeuStar’s National Pooling Administration contract1 and our
constant effort to provide the best support and value to both the FCC and the telecommunications
industry, NeuStar, as the National Pooling Administrator (PA), hereby submits this Change Order
Proposal to the Federal Communications Commission (FCC) for approval. This change order complies
with the contractual requirements set forth in Attachment B, Section C of the Thousands-Block
Pooling Contractor Technical Requirements, dated November 30, 2000, Sections 2.5 through 2.5.4,
which read as follows:





2.5 Changes in the Environment




The FCC may issue rules, requirements, or policy directives in the future, which may
increase, decrease or otherwise modify the functions to be performed by the contractor. The
contractor is additionally subject to the provisions of the changes clause in Section I.




2.5.1 Process




Accordingly, after a contractor is selected, the FCC, the NANC and/or the INC may establish
NANP numbering resource plans, administrative directives, assignment guidelines (including
modifications to existing assignment guidelines), and procedures that may have an effect on
the functions performed by the contractor.




2.5.2 Changes




The contractor shall review changes when numbering resource plans, administrative
directives, assignment guidelines, and procedures are initiated or modified to determine if
there is any impact on the functions that they must perform.




2.5.3 Notifications




The contractor shall then, within a period of not more than 30 calendar days from said
event (e.g., the date INC places an issue into Final Closure), provide the Contracting
Officer, state PUCs, and the NANC with written notice regarding these changes and summarize
the potential impact of the changes upon service and cost, if any.




2.5.4 Roles




The NANC shall review the notice and provide a recommendation to the FCC regarding the
effect of the contractor’s notice and supporting documentation.




The contractor shall comply with state regulatory decisions, rules and orders with respect
to pooling, as applicable, as long as they are not in conflict with FCC decisions, orders,
and rules and are within state jurisdiction.





 




			
	1	 	FCC Contract Number CON01000016




 





	© NeuStar, Inc. 2006

	NeuStar Proprietary and Confidential
	 	- 3 -






 









 







Nat’l PAS — Change Order #50 (INC Issue 527)







December 15, 2006







 




This document provides the information required by the contract, such as identifying the new
requirements of the expanded scope of work as a result of the Industry Numbering Committee’s
(IN’s) disposition of Issue 527 by offering our proposed solution, and addressing its cost, risks,
and assumptions.




2 Industry Numbering Committee (INC) Proposed Changes



On November 17, 2006, INC placed issue 527 into Final Closure. As a result of this resolution
of INC Issue 527, a footnote was added to the Part 1A form to remind service providers that the
effective date of a block should not precede the activation date of the NXX related to the LRN
provided for the newly assigned block.




Issue 527: Blocks with Effective Dates earlier than the NXX activation date of
associated LRN



The official INC issue statement is quoted below and can also be found on the ATIS website
(www.atis.org):





A) ISSUE STATEMENT




The NANC LNPA WG provided a correspondence GS-536 noting that there were
cases where SPs were requesting and getting block effective dates that were
earlier than the activation date of the NXX related to the LRN provided for the
newly assigned block. This results in the network not being able route to the
newly assigned block on the effective date.




B) FOLLOWING RESOLUTION FROM INC




The following footnote viii was added to the Part 1A Form Section 1.3 of the TBPAG:




1.3 Dates




Date
of Applicationi:                    Requested Block Effective Dateviii                    
Request Expedited Treatment? (See Section 8.6) Yes                     No                    




viiiPlease
ensure that the NPA-NXX of the LRN to be associated with this block(s)
is/will be active in the PSTN prior to the effective date of the block(s):



3 The Proposal



NeuStar’s National Pooling Administrator has reviewed INC issue 527 from both the operational
and technical perspectives. The proposal set forth below will conform to the changes in the INC
guidelines while meeting the requirements of the industry in a cost-effective and efficient
manner.




 





	© NeuStar, Inc. 2006

	 	NeuStar Proprietary and Confidential
	 	- 4 -






 









 










Nat’l PAS — Change Order #50 (INC Issue 527)







December 15, 2006







 





Solution



To satisfy the requirements of the amended Thousands-Block Pooling Administration Guidelines, the
Part 1A form will be modified in PAS to include a footnote associated with the requested block
effective date. The footnote will read “Please ensure that the NPA-NXX of the LRN to be associated
with this block(s) is/will be active in the PSTN prior to the effective date of the block(s).” In
addition, the date on the Part 1A form will be modified in PAS to reflect the new date of the form.




4 Assumptions and Risks



Part of the PA’s assessment of this change order is to identify the associated assumptions
and consider the risks that can have an impact on our operations.



This change order affects only the system, and would have no impact on our day-to-day
operations.




5 Cost



As with any change order proposal, we also considered the associated costs that would
potentially be incurred in implementing the proposed solution. These costs include the resources
required to complete the milestones on a timeline for implementing the processes and system
delineated in this change order. The timeline includes preparation, proper documentation updates,
development, testing, monitoring, and execution of the solution.



The cost to implement our proposed solution would be $2381.00




6 Conclusion



In conclusion, the Pooling Administrator offers a viable solution that meets the needs of
INC issue 527 and is in accordance with our contract terms. Therefore, we request that the FCC,
review and approve this change order.









 





	© NeuStar, Inc. 2006

	 	NeuStar Proprietary and Confidential
	 	- 5 -