Industry Numbering Committee (INC) Report to the NANC

1. Industry Numbering Committee (INC) Report to the NANC May 17, 2011 Natalie McNamer, INC Chair Dana Crandall, INC Vice Chair

2. INC Meetings • INC Meetings: INC held one interim General Session and one face-to-face meeting since the last NANC report. • Next INC Meeting: June 27-30, 2011 (Overland Park, KS) • Details on all future meetings can be found at: www.atis.org/inc/calendar.asp

3. NARP Subcommittee Issue 709: Updates to the p-ANI Guidelines and Forms In December 2010, the FCC provided clarification to the PA regarding certain issues and assumptions and directed the PA to submit a Change Order for the implementation of the permanent RNA Administration function for p-ANIs. On May 3, 2011, the INC held a joint meeting with ATIS ESIF to discuss clarifying points and update the p-ANI Guidelines to conform to the FCC clarifications. The clarifications include the identification of the appropriate regulatory authority and acceptable licensing/certification documentation for an Eligible User requesting p-ANI resources. INC continues to refine the Guidelines. 3

4. RAM Subcommittee Issue 710: NANC Action Item “multi-OCN Issue” At the December 2010 NANC meeting, PA PUC staff requested that the NANC address the “multi-OCN issue” within states, and the INC received an Action Item to work with the PA PUC staff on the issue. Since then, INC has been working with the PA PUC staff to address staff’s concerns. To assist state commission staffs with identifying the relationship of a service provider’s multiple OCNs in a given state: INC added the Parent Company OCN field to the CO Code and Pooling Part 3 forms. NANPA and the PA will add the Parent Company OCN and the Parent Company OCN name to their Part 1, Part 1a and Part 3 Reports provided to the states. These actions are expected to result in NANPA and PA change orders. INC also added text to the CO Code Guidelines and the Pooling Guidelines giving the states guidance to provide written direction and supporting documentation to the NANPA and the PA to deny numbering resources to an applicant when the state is aware that the applicant’s jurisdictional certification or license has been revoked. Finally, the INC also added text to the CO Code Guidelines and the Pooling Guidelines giving the NANPA and the PA direction to deny resources to an applicant when the appropriate regulatory authority has provided such written direction and supporting documentation. 4

5. RAM Subcommittee: State Concerns At the March 2011 NANC meeting, Chairman Kane noted a couple of concerns raised by state commission staff. One concern raised was that some state commission staff want companies with both ILEC and CLEC affiliates in the same rate center to share blocks and codes across multiple OCNs rather than acquiring additional resources per OCN. There are regulatory, legal, and technical barriers that prevent companies with both ILEC and CLEC affiliates in the same rate center from sharing resources. ILECs have non-discrimination requirements. Combining or sharing resources is no simple task; provisioning systems and other operational support systems would have to be modified. Separate networks exist and need to be maintained because there are different regulations for ILECs and CLECs. There are also various reporting implications when combining numbering resources within multiple networks. 47 CFR 52.15 (g) requires that service providers apply for resources on a per OCN basis. INC’s work under Issue 710 may alleviate some state concerns. 5

6. RAM Subcommittee: State Concerns Another concern raised was that some state commission staffers believe the 7 calendar day application processing timeframe is too short for staff to review code and block applications. Staff suggested that INC extend the time or consider state furlough days and state holidays in the timeframe calculation. Per Chairman Kane’s request, the INC Chair reached out to a specific state commission staffer to further understand this concern, and staff provided some written information and other suggestions for INC’s consideration. INC leadership will bring an issue to INC’s next meeting in June so that INC may fully discuss and consider these suggestions. 6

7. Issues Remaining in Initial Pending • Issue 534: The Development of pANI Guidelines

8. Issues in Initial Closure Issue 699: Review and update the acceptable forms of proof of facilities readiness Issue 705: Update CFR references and similar citations in the TBPAG and associated forms Issue 707: Need to remove all abandoned code records from NPAC prior to transfer Issue 708: Inclusion of a definition of Trunk Access in the Carrier Identification Code (CIC) Assignment Guidelines Issue 710: NANC Action Item “multi-OCN Issue” 8

9. Issues in Final Closure • Issue 706: Update Section 8.7 to make the remarks optional on the Part 1A when an SP is submitting a request to become the block holder on an over contaminated block

10. Relevant INC Web Pages • INC Homepage (front page to all INC links): http://www.atis.org/inc/index.asp • INC Calendar (future meeting logistics/agendas): http://www.atis.org/inc/calendar.asp • INC Issues (historical and active): http://www.atis.org/inc/incissue.asp • INC Meeting Records: http://www.atis.org/inc/mtgs_current.asp • INC Published Documents: http://www.atis.org/inc/incguides.asp