NUMBER RESOURCE OPTIMIZATION Page 2

1. In their comments, several state commissions indicated support for LINUS because of its quarterly reporting requirement and greater granularity. These states argued that reporting at this higher level of detail is necessary to monitor numbering use and forecast NANP and NPA exhaust. The Hybrid model has broad support within the industry. Indeed, as we noted above, the NANC recommended adoption of this model to the Common Carrier Bureau. Several proponents of the Hybrid model, such as Ameritech and GTE, argue that the reduced reporting requirements contemplated by the Hybrid model are fully justified given its intended use. These parties argue that the data needed by the NANPA for predicting NPA and NANP exhaust is significantly less than the data needed for other analyses such as audits. Ameritech explains that reporting necessary to predict NPA exhaust requires aggregate information at frequent intervals while data used for audits requires specific data at more detailed levels upon demand. Others support adoption of the Hybrid model over LINUS on the basis of cost, although these parties provide no direct cost estimates to support their contentions.
2. We decline to adopt either the LINUS or the Hybrid model as the basis for our mandatory data reporting requirement. We find that reporting for seven categories of use and quarterly reporting, as proposed with the LINUS model, would substantially increase costs to both the carriers and the NANPA without providing commensurate benefits. Our objective is to request the minimal amount of data to enable us to meet the regulatory objectives identified above. We find the detailed and frequent reporting under the LINUS to be unduly burdensome.
3. Although we find some aspects of the Hybrid model, such as semi-annual reporting, to be reasonable, we also decline to adopt it as our reporting model. As described below, we believe that all utilization data should be reported at the thousands-block level. We also find that reporting only the category of "numbers unavailable" will provide insufficient information for the NANPA, states, and this Commission to carry out our numbering administration responsibilities.
4. The data collection procedures we adopt, which shall replace the COCUS model currently being used by the NANPA to collect forecast and utilization data, are detailed below. As with the COCUS model, the NANPA shall continue to serve as the single point of contact for collection of forecast and utilization data. The NANPA’s neutrality and ongoing interaction with code holders makes it the ideal repository for these data. Moreover, the NANPA is responsible for allocating numbers within the NANP and making forecasts of exhaust, and must rely on this data to carry out these functions.
5. The NANPA shall, within 15 days of the release of this Report and Order, develop a reporting form for both utilization and forecast data reporting and submit it both in paper and electronic form to the Common Carrier Bureau for review and submission to the Office of Management and Budget. The form shall incorporate the reporting requirements we establish in this Report and Order. In addition to the utilization and forecast data, the NANPA shall ensure that it has a means of associating each carrier’s reported data with carrier identification information. This information shall include: company name, company headquarters address, OCNs, parent company OCN(s), and the primary type of business in which the numbers are being used.
6. The NANPA indicates that the costs of the data collection will be minimized if the data are reported electronically. Therefore, we will require all carriers filing data to file electronically. We understand that currently not all carriers will be able to file electronically initially, and that some carriers may have a long-term difficulty establishing electronic filing capability. Nonetheless, we believe that electronic filing is the most efficient and least costly method available. We have had ex parte discussions with the NANPA regarding this issue and we have been assured that electronic filing by carriers of all sizes and technical capabilities can be accommodated. The NANPA has contemplated three alternative methods for collecting data. For large and mid-sized carriers, the preferred method of reporting would be an electronic file transfer. The NANPA also believes that it can develop a spreadsheet format that could be used by smaller carriers that only have personal computers. As a second option, the NANPA indicates that it could develop Internet-based online access to the data base. Carriers could, in a secure fashion, use the Internet to log into the NANPA’s website and enter their data manually into an electronic version of the reporting form. We note that every carrier that can dial up using an ISP can use this method, and that this method is not any more burdensome on a carrier than paper filing. Finally, as a last resort for very small carriers that do not have access to an ISP, the NANPA is considering permitting them to fax their data submissions and the NANPA would, as an enterprise service, transcribe the data into an electronic format. We direct the NANPA to develop and establish these data entry mechanisms within 45 days of the publication of this Report and Order in the Federal Register.
7. The NANPA shall examine each data submission for inconsistencies or anomalies. The NANPA shall work with the NANC to formulate criteria for determining what types of submissions should be deemed inconsistent or anomalous. If the NANPA identifies any significant inconsistencies or anomalies in a carrier’s data, the NANPA shall inform the submitting carrier of its findings, after which the carrier shall have five days to explain the inconsistencies or anomalies, or to resubmit the data. If, after the discussions with a carrier, the NANPA preliminarily concludes that that carrier’s data are insufficient, then the NANPA shall report that preliminary conclusion to the commission in the state where the carrier is providing service, and to the Common Carrier Bureau. We delegate to the states the authority to make a determination on the validity of the data and to instruct the carrier on how any deficiencies should be remedied. The NANPA shall assign no additional resources to that carrier until the appropriate state commission has resolved all questions regarding the inconsistency or anomaly.
8. The NANPA shall also continue to compile, examine, and analyze the forecast and utilization data submitted by reporting carriers to carry out its NANP management responsibilities, which includes tracking and reporting on number utilization throughout the United States, and projecting the life of individual NPAs as well as the NANP. This includes, but is not limited to, conducting NPA and NANP exhaust studies, and developing a comprehensive database of NPA-NXXs that identify which numbering resources are being utilized, and which remain in the NANP inventory. We note that the NANPA is required under our rules to protect the confidentiality of proprietary data and competitively sensitive information. We clarify that this requirement shall apply to electronic data as well.
9. Further, we direct the NANC to consult with the NANPA to develop an estimate of the costs the NANPA will incur to carry out the mandatory reporting requirements and provisions, including, but not limited to, compilation, examination and analysis of such data, as set forth in this Report and Order. We request the NANC to submit this cost estimate to the Common Carrier Bureau within 30 days of the release of this Report and Order.

1. Data Elements for Forecast Reporting

1. The current COCUS requires each reporting carrier to provide year-by-year, five-year projections of its resource needs. Although no party specifically addressed this issue, we believe that we should formally adopt this reporting requirement in our newly established reporting framework. We find that the five-year forecast mechanism provides the NANPA with sufficient information to make its NANP and NPA forecasts, while at the same time, not burdening carriers. Therefore, we require each carrier to provide a year-by-year, five-year forecast of its expected numbering requirements.
2. Initial and Growth Codes. Both the LINUS and the Hybrid models propose that forecast numbering resource requirements be reported in terms of initial and growth codes. In its comments, the NANPA continues to support this proposal, and no commenting party opposed it. This distinction is important in forecasting NANP exhaust because it permits the NANPA to distinguish between codes that are being requested to establish a footprint from those that are being used to expand service within existing coverage areas. We believe this distinction is consistent with our desire to have as complete a picture as possible of numbering resource use, and therefore require carriers to separate initial from growth codes in their forecasts.

1. Data Elements for Utilization Reporting

1. In the Notice we requested comment on the specific data elements that carriers should be required to report. We sought comment on whether all NXX code holders should be required to report the status of all telephone numbers within the NXX blocks assigned to them (using the numbering status definitions defined in the Notice), or whether more aggregated reporting would provide sufficient data to track number utilization accurately.
2. We will require carriers to report five categories of numbers: assigned, intermediate, reserved, aging, and administrative. The need for use-specific data is widely supported by the states and at least some carriers have agreed that uniform reporting of these use categories would be reasonable. We believe that the additional detail provided by reporting on these major uses of numbers will improve the accuracy of the NANPA’s projections. In addition, the NANPA’s ability to evaluate requests for new NXX blocks will be substantially improved by having detailed information on how numbers are being used. Similarly, the states, which are responsible for area code relief, will benefit from having this specific data to use in monitoring carrier requests for numbering resources.
3. We reject the assertion of several commenters who argue that only highly aggregated data need be reported." These commenters generally believe that the exclusive purpose of routine reporting of forecast and utilization data is to predict the exhaust of NPAs and the NANP, so there is no need to collect utilization information by numbering use category. We disagree; these data are especially valuable to identify carriers that are holding excessive inventories of numbers and to facilitate reclamation of those numbers. We also disagree with some of the states that argue that carriers should report on all categories of number utilization to the NANPA. As we previously noted, our goal is to balance the need for data against costs of collecting, providing, and analyzing it, and we find that requiring reporting of only the five major categories listed above properly balances these two concerns.
4. We also adopt specific record-keeping requirements for audit purposes. Although we do not, in this Report and Order, set forth auditing requirements, we anticipate doing so in a subsequent order in this docket. We believe that all carriers should maintain detailed internal records of their number usage in categories more granular than the five for which they are required to report not only as a good business practice, but to facilitate auditing by the NANPA and by state commissions in the future. We therefore require carriers to maintain internal records of their numbering resources for the additional eight subcategories of numbers identified in this Report and Order, in addition to the five categories which they must report. Carriers required to track the additional eight subcategories of numbers should maintain this data for a period of not less than five years. We clarify, however, that these additional categories of number usage need not be reported to NANPA at this time. The record does not indicate that the requirement to track the eight subcategories of numbers would be burdensome to rural carriers. But to the extent that non-LNP-capable rural carriers find this record-keeping requirement to be burdensome, we would entertain waiver requests, including joint waiver requests.

Click here for the next page

Copyright © 1995 - 2007 ICB. Inc. All rights reserved. "ICB Toll Free News" is a trademark of ICB Inc. ICB Inc. assumes no responsibility for use or misuse of information contained herein and / or accessible via this site. ICB Inc. cannot and does not vouch for the accuracy and / or usability of any of the contained or linked-to information, and assumes no responsibility for any errors or omissions.