1. North American Numbering Council Summary: Toll Free Assignment Modernization Report & Order (R&O) WC Docket No CC Docket No
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

2. 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.

3. 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.

4. 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.

5. 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.

6. 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.

7. 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.

8. 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.

9. 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

10. Toll Free Assignment Modernization – R&O
Questions / Contacts:
Heather Hendrickson
Assistant Division Chief
Wireline Competition Bureau
Competition Policy Division
(202)
Matthew Collins
Attorney Advisor
(202) 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 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)