North American Numbering Council Summary: Toll Free Assignment Modernization Report & Order (R&O) WC Docket No. 17-192 CC Docket No. 95-155 Matthew Collins Attorney Advisor Wireline Competition Bureau Competition Policy Division December 4, 2018 Hello My name is Deborah Salons. I am an attorney advisor in the Wireline Competition Bureau, Competition Policy Division. I am an attorney on the BDAC team, and I am also one of the attorney’s that worked on the Wireline Infrastructure Item that I am going to talk to you about today. 1

Toll Free Assignment Modernization – Background First-come, first served rule 833 Code Opening Notice of Proposed Rulemaking Comments and replies NANC Report Report and Order Forthcoming Public Notices 2 More specifically, the Wireline Item contains 3 parts: a Notice of Proposed Rulemaking, a Notice of Inquiry, and Request for Comment The Notice of Proposed Rulemaking proposes rules related to: Pole Attachment Reforms Expediting the Copper Retirement Process Streamlining the Section 214(a) discontinuance process, The Notice of Inquiry asks questions and seeks comment on: Using Section 253 Authority to Preempt State and Local Laws Inhibiting Broadband Deployment Preemption of State Laws Governing Copper Retirement Request for Comment Seeks Comment on Reversing a Previous Declaratory Ruling expanding the interpretation of what constitutes a “service” for purposes of the Section 214(a) Discontinuance Process. There is a lot in this item and I am going to give you a quick summary of each section.

Toll Free Assignment Modernization – R&O The Toll Free Assignment Rule Prior rule Toll free numbers shall be made available on a first-come, first-served basis unless otherwise directed by the Commission. Revised rule Toll free telephone numbers must be made available to Responsible Organizations and subscribers on an equitable basis. The Commission will assign toll free numbers by competitive bidding, on a first-come, first-served basis, by an alternative assignment methodology, or by a combination of the foregoing options. Section 251(e)(1) test 3 More specifically, the Wireline Item contains 3 parts: a Notice of Proposed Rulemaking, a Notice of Inquiry, and Request for Comment The Notice of Proposed Rulemaking proposes rules related to: Pole Attachment Reforms Expediting the Copper Retirement Process Streamlining the Section 214(a) discontinuance process, The Notice of Inquiry asks questions and seeks comment on: Using Section 253 Authority to Preempt State and Local Laws Inhibiting Broadband Deployment Preemption of State Laws Governing Copper Retirement Request for Comment Seeks Comment on Reversing a Previous Declaratory Ruling expanding the interpretation of what constitutes a “service” for purposes of the Section 214(a) Discontinuance Process. There is a lot in this item and I am going to give you a quick summary of each section.

Toll Free Assignment Modernization – R&O The 833 Auction: Introduction Auction as experiment Auction framework Public Notices will establish full auction procedures Design Single round, sealed-bid Vickrey auction Auction eligibility Any party interested in a number may bid directly or through a RespOrg Application process Disclosures and certifications Procedures Prohibition on certain communications Upfront payments and default payments 4 More specifically, the Wireline Item contains 3 parts: a Notice of Proposed Rulemaking, a Notice of Inquiry, and Request for Comment The Notice of Proposed Rulemaking proposes rules related to: Pole Attachment Reforms Expediting the Copper Retirement Process Streamlining the Section 214(a) discontinuance process, The Notice of Inquiry asks questions and seeks comment on: Using Section 253 Authority to Preempt State and Local Laws Inhibiting Broadband Deployment Preemption of State Laws Governing Copper Retirement Request for Comment Seeks Comment on Reversing a Previous Declaratory Ruling expanding the interpretation of what constitutes a “service” for purposes of the Section 214(a) Discontinuance Process. There is a lot in this item and I am going to give you a quick summary of each section.

Somos will serve as auctioneer Toll Free Assignment Modernization – R&O The 833 Auction: Auctioneer and Proceeds Somos will serve as auctioneer Duties Auction infrastructure Bidder outreach Application review Working with bidders Commission oversight Auction proceeds Offset cost of numbering administration 5 More specifically, the Wireline Item contains 3 parts: a Notice of Proposed Rulemaking, a Notice of Inquiry, and Request for Comment The Notice of Proposed Rulemaking proposes rules related to: Pole Attachment Reforms Expediting the Copper Retirement Process Streamlining the Section 214(a) discontinuance process, The Notice of Inquiry asks questions and seeks comment on: Using Section 253 Authority to Preempt State and Local Laws Inhibiting Broadband Deployment Preemption of State Laws Governing Copper Retirement Request for Comment Seeks Comment on Reversing a Previous Declaratory Ruling expanding the interpretation of what constitutes a “service” for purposes of the Section 214(a) Discontinuance Process. There is a lot in this item and I am going to give you a quick summary of each section.

Numbers may be set aside from auction for use for public purposes Toll Free Assignment Modernization – R&O The 833 Auction: Public Interest and Trademarks Numbers may be set aside from auction for use for public purposes Government and non-profit (501(c)(3)) entities eligible Process File petition Seek comment Bureau will apply standard of Commission precedent Lottery if multiple entities meet standard No special treatment for trademark-holders 6 More specifically, the Wireline Item contains 3 parts: a Notice of Proposed Rulemaking, a Notice of Inquiry, and Request for Comment The Notice of Proposed Rulemaking proposes rules related to: Pole Attachment Reforms Expediting the Copper Retirement Process Streamlining the Section 214(a) discontinuance process, The Notice of Inquiry asks questions and seeks comment on: Using Section 253 Authority to Preempt State and Local Laws Inhibiting Broadband Deployment Preemption of State Laws Governing Copper Retirement Request for Comment Seeks Comment on Reversing a Previous Declaratory Ruling expanding the interpretation of what constitutes a “service” for purposes of the Section 214(a) Discontinuance Process. There is a lot in this item and I am going to give you a quick summary of each section.

Toll Free Assignment Modernization – R&O Secondary Market Exception to brokering, hoarding, and warehousing rules Rules do not apply to numbers acquired in an auction Goals Promote efficient allocation of numbers Promote efficient operation of auction 7 More specifically, the Wireline Item contains 3 parts: a Notice of Proposed Rulemaking, a Notice of Inquiry, and Request for Comment The Notice of Proposed Rulemaking proposes rules related to: Pole Attachment Reforms Expediting the Copper Retirement Process Streamlining the Section 214(a) discontinuance process, The Notice of Inquiry asks questions and seeks comment on: Using Section 253 Authority to Preempt State and Local Laws Inhibiting Broadband Deployment Preemption of State Laws Governing Copper Retirement Request for Comment Seeks Comment on Reversing a Previous Declaratory Ruling expanding the interpretation of what constitutes a “service” for purposes of the Section 214(a) Discontinuance Process. There is a lot in this item and I am going to give you a quick summary of each section.

Toll Free Assignment Modernization – R&O Other Rule Revisions NANC Working Group Report Revising other toll free numbering rules Modernizing 51.101(a) – replace NASC with TFNA 52.103(a)(10) – new “Transitional Status” 52.103(f) – replace DSMI with TFNA 52.109(c) – typo correction Making consistent 52.101(e) – update “Toll Free Subscriber” definition 52.103(d) – allow numbers to go from Disconnect Status to Unavailable or Spare Status 8 More specifically, the Wireline Item contains 3 parts: a Notice of Proposed Rulemaking, a Notice of Inquiry, and Request for Comment The Notice of Proposed Rulemaking proposes rules related to: Pole Attachment Reforms Expediting the Copper Retirement Process Streamlining the Section 214(a) discontinuance process, The Notice of Inquiry asks questions and seeks comment on: Using Section 253 Authority to Preempt State and Local Laws Inhibiting Broadband Deployment Preemption of State Laws Governing Copper Retirement Request for Comment Seeks Comment on Reversing a Previous Declaratory Ruling expanding the interpretation of what constitutes a “service” for purposes of the Section 214(a) Discontinuance Process. There is a lot in this item and I am going to give you a quick summary of each section.

Toll Free Assignment Modernization – Next Steps Public Notices Auction Comment Public Notice Auction Procedures Public Notice Applications Application period Application review Qualified bidder notification Auction Bidding Winning bidder Public Notice Activate numbers in toll free database

Toll Free Assignment Modernization – R&O Questions / Contacts: Heather Hendrickson Assistant Division Chief Wireline Competition Bureau Competition Policy Division (202) 418-7295 Heather.Hendrickson@fcc.gov Matthew Collins Attorney Advisor (202) 418-7141 Matthew.Collins@fcc.gov 10 As previously mentioned, the NPRM proposes rules related to pole attachments, the retiring of legacy copper facilities and the discontinuance process. To start, the NPRM proposes to reform the FCC’s pole attachment rules to make it easier, faster and less costly to access poles, ducts, conduits, and rights-of-way necessary for building out next generation networks. First, it would propose to shorten the Commission’s existing pole attachment timeline and would seek comment on alternatives to the current pole attachment process. This could reduce the average process from 150 days/5 months to 30-60 days. The Notice also proposes changes to the Commission’s pole attachment rules that would:  reduce make-ready charges paid by attachers to utilities “make-ready” generally refers to the modification of poles or lines or the installation of certain equipment (example: guys and anchors) to accommodate additional facilities (2) codify the elimination of certain capital costs from the pole attachment rate formulas; so that pole attachers are not charge multiple times for capital costs (3) adopt a formula for computing the maximum pole attachment rate that may be imposed on incumbent local exchange carriers, proposing the ILECs should be presumptively entitled to pay a pole attachment rate using the telecommunications rate formula’ (4) establish a 180-day shot clock for Commission consideration of pole access complaints; and (5) adopt rules that would allow incumbent local exchange carriers to gain nondiscriminatory access to poles owned by other local exchange carriers. (at this time, ILECs cannot demand access to poles)