The “Safety Valve” process” Delaying Customer Service

1. The “Safety Valve” process”Delaying Customer Service A discussion of the Safety Valve Process and the need for change. Mike Whaley Qwest NANC - November 4, 2004

2. Meeting the Customer’s Need for Numbers • New technology can drive customer demand for telephone numbers upward • Large businesses continue to need blocks of sequential numbers. • New opportunities like VoIP require numbering resources. • The industry is growing and expanding in new ways.

3. Meeting Customer’s Need for Numbers • Rules must evolve in support of the consumers • Speed of getting service to the customer is a must in a competitive environment. • Carriers follow regulations when obtaining numbers. • The Safety Valve regulation needs to be reviewed and changed for the customers. • Safety Valve delays can be avoided.

4. The Safety Valve • The FCC has established a “safety valve” mechanism to allow carriers to obtain numbering resources when they do not otherwise qualify.* • The FCC delegated authority to state commissions to hear and resolve waivers filed under the safety valve process.* * From the FCC’sThird Report and Order and Second Order on Reconsideration in CC Docket No. 96-98 and CC Docket No. 99-200

5. The Safety Valve • The FCC recognized that failure to address a request for additional numbering resources can impair a carrier’s ability to expand or for customers to meet business needs.* • The FCC advised the states that a ten business day interval from receipt of a detailed and complete safety valve waiver request is sufficient time to review and act upon the request.* * From the FCC’sThird Report and Order and Second Order on Reconsideration in CC Docket No. 96-98 and CC Docket No. 99-200

6. When is the Safety Valve is Used • The Safety Valve is used when: • Carriers cannot satisfy the demand from within their existing inventory. • Large major customers need entire sequential blocks of numbers to grow. • NANPA and the Pooling Administrator reject requests when months to exhaust or utilization levels are not met. • Only after rejection can waiver be filed.

7. What needs to be changed? • The safety valve waiver process requires carriers obtain waivers from state commissions for customer specific requests. • Safety Valve waivers may not have the highest priority with state regulators. • Delays prevent carriers from providing numbering resources in a timely manner to the customer. • By giving authority to the NANPA or PA to approve customer specific requests will permit carriers to meet today’s market demands.

8. A Minimal Rule Change Needed • Rule change is needed because: • Carriers are already required to provide documentation from the customer with the current proof of utilization to obtain waivers from state regulators. • The current documentation is sufficient. • Waivers are not for vanity numbers, but for contiguous blocks of numbers.

9. A Minimal Rule Change Needed • For Customer Specific Request Waivers • The safety valve regulatory review process varies from state to state. • The process creates an unnecessary amount of regulatory involvement resulting in delays in getting customer’s their service. • The eminent exhaust of the NANP was delayed due to the NRO orders.

10. Why Change the Rule? • Waivers delay meeting customer needs • Qwest’s experience shows the interval for these requests has varied from as little as 5 days to as many as 313 days with over 70 waivers filed, averaging 35 days each. • Only 9 request were processed in 10 days or less, less than 13% of the time . • Every waiver for a customer specific request was approved.

11. Why Change the Rule? • To satisfy customer specific requests • Our experience demonstrates the Safety Valve Process for customer specific requests needs to be revisited. • Very important in light of the rapidly growing demands for numbers and for applications such as VoIP. • Process should be consistent across all states.

12. An Easy Rule Change • In most cases, the waiver request provides the same information as the application and the process used for an NXX or a 1K block. • By providing one additional piece of information – the customer specific request – to the NANPA or the Pooling Administrator, valuable time will be saved. • Every waiver filed by Qwest for customer specific requests has been approved.

13. A Simple Solution • Give NANPA and the PA authority to grantcustomer specific requests. • The customer letter should satisfy the FCC’s requirement of the customer’s need. • It can be handled in the 10 day processing cycle for NANPA and the PA. • Reduces rejections by the NANPA and PA. • Eliminates delays in serving customers. • Saves Regulator’s time and the regulators have approved all of the waiver requests.

14. The Change Improves Customer Service • By changing the Safety Valve process to speed up customer specific requests: • Means that existing customer’s needs can be met. • Permits more rapid deployment of new services that customers demand today. • Maintains the integrity of the NRO orders. • Reduces regulatory delay.