800 INDUSTRY SEEKS TO RELEASE 855 RESERVATIONS

September 12, 2002

Wireline Competition Bureau
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554

Re: CC Docket 95-155; 855 Easily Recognizable Code (“ERC”)

Dear

The purpose of this letter is to advise the Federal Communications Commission (“Commission” or “FCC”) of the current circumstances of many Responsible Organizations (“Resp Orgs”) regarding customer requests for reservations in the 855 ERC and, to request the Commission’s assistance in the form of a written communiqué supporting the industry’s release of those requests. Due to the Commission’s indefinite delay of the 855 ERC opening on November 17, 2000, Resp Orgs have been holding customer requests, in some cases, for over 36 months. This extended period of time has contributed to customer confusion and several other issues identified in more detail below. The Alliance for Telecommunications Industry Solutions (“ATIS”) Ordering and Billing Forum (“OBF”) SMS/800 Number Administration Committee (“SNAC”) believes that the best course of action is to allow Resp Orgs to release customer requests for 855 reservations and to accept requests again, if, and when, the Commission has lifted the delay and a new release schedule has been established by the industry.

The 855 ERC was originally scheduled to be opened on April 8, 2002, shortly after the opening of the 866 ERC. However, the Commission delayed opening the 855 ERC, at the request of the SNAC, until November 18, 2000 due to potential problems with the first-come, first-serve functionality of the SMS/800 system. After the FCC determined the new opening date for the 855 ERC, Resp Orgs began accepting customer requests for 855 toll free numbers accordingly. On November 17, 2000, the Commission delayed indefinitely the 855 ERC opening. If the Commission decides to open the 855 ERC, the SNAC has requested that the Commission allow the industry to determine the new release date, as was done previously with 800, 888, 877 and 866 ERCs, in order to ensure a successful code implementation. To this date, the Commission has not commented further on the 855 ERC opening.

As previously stated, the SNAC believes that the best course of action is to allow Resp Orgs to release customer requests for 855 reservations and to accept requests again, if, and when, the Commission has lifted the delay and a new release schedule has been established by the industry. The Resp Orgs have been holding customer requests for a lengthy period of time. Therefore, customer contact information may be outdated in many instances. A customer may have determined, for business and other reasons, that it no longer wants a requested number without notifying the Resp Org. Furthermore, the customer may have gone out of business. Under these scenarios, it would be extremely labor intensive, as well as cost and time prohibitive, for a Resp Org to ensure that it has the proper customer contact information for each request it has received.

Accordingly, the SNAC is requesting the assistance of the Commission through the issuance of the appropriate communication indicating that Resp Orgs may appropriately release customer requests for 855 ERC reservations. While the SNAC does not believe there is an explicit requirement on the Resp Orgs to maintain the 855 ERC customer requests, the group would feel more comfortable proceeding with the Commissions’ acknowledgement, given the responsibility of ensuring a first-come, first-serve scenario for all code openings.

***

There is no mention of contacting 855 reservation holders if the SNAC's request is approved.

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