1. Industry Numbering Committee (INC) Report to the NANC Dyan Adams, INC Co-Chair Connie Hartman, INC Co-Chair December 1, 2015

2. INC Report to the NANC 2 Overview About INC INC Meetings/Membership Sale and Brokering of Non-Toll-Free TNs between Private Entities Issue 497: Identify Changes to INC Guidelines Based on NANC’s Report and Recommendation, VoIP Service Providers’ Access Requirements for NANP Resource Assignments (July 19, 2005), and FCC Report and Order (FCC 15-70, June 22, 2015). Issue 748: Assess Impacts on Numbering Resources and Numbering Administration with Transition from Public Switched Telephone Network (PSTN) to Internet Protocol (IP). Issue 788: 555 Line Number Assignments and Reclamation. Issue 800: Update Audit, Reclamation, and Extension Procedures in 9YY-NXX Guidelines Issue 801: Update p-ANI Guidelines with direction when states do not certify VPC Providers Issue 802: Edits to COCAG regarding Valid Switching ID Information Issue 804: Update Code Reservation Criteria in the COCAG

3. INC Report to the NANC 3 About INC The Industry Numbering Committee (INC) provides an open forum to address and resolve industry-wide issues associated with planning, administration, allocation, assignment and use of North American Numbering Plan (NANP) numbering resources within the NANP area. Membership To become a member of INC or ATIS, see http://www.atis.org/membership/become.asp http://www.atis.org/membership/become.asp To understand how INC operates, see http://www.atis.org/legal/OP.asp http://www.atis.org/legal/OP.asp

4. INC Report to the NANC 4 INC Meetings Meetings Since the previous NANC meeting, INC held two face-to- face meetings in September and November 2015 and two interim meetings in October and November.

5. INC Report to the NANC 5 Sale and Brokering of Non-Toll-Free TNs between Private Entities During the September 30, 2015, NANC meeting, the NANC Chair tasked INC with addressing the email from the Chief of the Wireline Competition Bureau (WCB), regarding the sale and/or brokering of non-toll-free telephone numbers. INC reviewed a number of sources, including: NANC Chair’s July 13 th letter to the WCB. WCB’s September 30 th response. Washington Post article referenced in the July 13 th letter. Websites of the companies referenced in the article. Existing Commission rules. Existing INC documents related to this topic.

6. INC Report to the NANC 6 Sale and Brokering of Non-Toll-Free TNs between Private Entities INC provided a response to the NANC Chair on November 19, 2015. Below is a summary: The two companies identified in the Washington Post article state on their websites that they are providing account or call management services, not specifically selling TNs. INC outlined three possible scenarios for how these two companies might obtain numbers. INC is not aware of any FCC rules related to end user transactions involving non-toll-free TNs analogous to the restrictions imposed on toll-free number subscribers.

7. INC Report to the NANC 7 Sale and Brokering of Non-Toll-Free TNs between Private Entities INC Guidelines apply to service providers (SPs), not end users. INC outlined several FCC rules that appear to limit end users’ ability to engage in transactions that adversely affect number resource optimization. Although some SPs’ tariffs and/or agreements indicate that the end user has no property right to TNs, the ability to port TNs may give end users the impression they do have such property rights.

8. INC Report to the NANC 8 Sale and Brokering of Non-Toll-Free TNs between Private Entities There are legitimate reasons for transferring numbers. Rules or policies that require SPs to second-guess end users’ requests to transfer TNs between accounts could adversely affect their legitimate needs. SPs are not in the position to determine or monitor if there is a sale/brokering transaction between parties associated with transfers of TNs. The FCC’s Enforcement Bureau is the proper authority to address inappropriate transactions related to numbering resources. INC’s response to the NANC Chair is available at http://www.atis.org/legal/Docs/INC/INC_2015_00127R002.pdf. http://www.atis.org/legal/Docs/INC/INC_2015_00127R002.pdf

9. INC Report to the NANC 9 INC completed updates to 13 Guidelines pursuant to FCC Order 15-70, which allows interconnected VoIP providers direct access to numbering resources, including: Authorization for obtaining resources; Facilities readiness; VoIP Positioning Center (VPC) access to p-ANIs; and CFR references and definitions, including clarification of Intermediate numbers. INC drafted a template that interconnected VoIP providers can use to provide their 30-day notice of the intent to request numbering resources and their regulatory and numbering contacts to the states. NANPA and the PA will be submitting Change Orders to update text on the Guidelines Forms in NAS and PAS. However, INC agreed to place this Issue into Final Closure with the understanding the systems will not be updated until the Change Orders have been approved and implemented. Issue 497: Identify Changes to INC Guidelines Based on NANC’s Report and Recommendation, VoIP Service Providers’ Access Requirements for NANP Resource Assignments (July 19, 2005), and FCC Report and Order 15-70

10. INC Report to the NANC 10 Issue 497: Identify Changes to INC Guidelines Based on NANC’s Report and Recommendation, VoIP Service Providers’ Access Requirements for NANP Resource Assignments (July 19, 2005), and FCC Report and Order 15-70 INC placed the following notation on the cover page of any Guidelines containing updates not effective on November 30th: NOTE: These guidelines contain references to FCC Order 15-70. As noted in the Federal Register: The Rule will become effective on November 30, 2015, except for §§ 52.15(g)(2) [Central office code administration-Initial numbering resources] & 52.15(g)(3) [Central office code administration-Commission authorization process], which include revised information collection requirements that first require OMB review and approval. The FCC will publish a further document in the Federal Register in the future announcing the effective date of the excepted rule amendments. Once §§ 52.15(g)(2) and 52.15(g)(3) become effective, this note will be removed and all text in the guidelines will be effective.

11. INC Report to the NANC 11 Issue 748: Assess Impacts on Numbering Resources and Numbering Administration with Transition from Public Switched Telephone Network (PSTN) to Internet Protocol (IP) INC continues to discuss a possible whitepaper on non-geographic number assignment to supplement the LNPA WG whitepaper on non-geographic number portability. Based on initial discussions, a concern has been raised that if non-geographic number assignment and non-geographic number portability are implemented, they should be done simultaneously to avoid arbitrage and facilitated in a manner that does not disrupt or delay the LNPA transition.

12. INC Report to the NANC 12 Issue 788: 555 Line Number Assignments and Reclamation On June 17 th, the moratorium on all new assignments of 555 line numbers went into effect. On June 19 th, NANPA issued a Planning Letter (PL-483) that serves as the final notice to assignees before the resources are reclaimed. To date, NANPA has not received confirmation that any 555 line numbers are in service. As of November 13 th, 2,576 assignments have been either returned or reclaimed. Approximately 3,000 remain assigned. NANPA will continue its outreach efforts, with the goal of attempting to directly contact all 555 line number assignees, with the expectation to complete the effort by April 2016. Upon completion of the outreach, NANPA will submit to INC a proposal concerning the 555 line number resource.

13. INC Report to the NANC 13 Issue 800, Update Audit, Reclamation, and Extension Procedures in 9YY-NXX Guidelines The 9YY-NXX Guidelines were updated with regard to auditing, reclamation, and extension procedures to be consistent with all other INC Guidelines. Eliminated administrator ability to grant extensions to activate 9YY- NXX codes. Added the ability for 9YY-NXX code assignees to request extensions from the FCC. Added an administrator responsibility to provide a reminder notification to the assignee of the Part C due date. Revised guidelines so that the FCC directs the administrator to reclaim 9YY-NXX codes not activated within the required timeframe. Added an administrator responsibility to refer possible issues of non- compliance to a designated auditor or appropriate regulatory agency.

14. INC Report to the NANC 14 Issue 801, Update p-ANI Guidelines with direction when states do not certify VPC Providers FCC Order 15-70 permits VPC providers to receive p-ANIs from the RNA when states do not otherwise certify VPC providers. INC updated the p-ANI Guidelines to outline the appropriate documentation that VPC providers shall provide the RNA in those circumstances.

15. INC Report to the NANC 15 Issue 802, Edits to COCAG regarding Valid Switching ID Information An assignment assumption in the COCAG states that “CO codes (NXXs) are assigned to entities for use at a Switching Entity or Point of Interconnection they own or control”. The Guidelines were updated to allow an applicant to submit a CO code request utilizing another service provider's switch/POI when the applicant has a contractual arrangement to use that switch/POI and provides the appropriate supporting documentation.

16. INC Report to the NANC 16 Issue 804, Update Code Reservation Criteria in the COCAG INC updated the COCAG to make block and CO code reservations generally consistent and to ensure efficient use of CO code resources. INC updated the guidelines to: Limit code reservations to situations where an SP has submitted a safety valve waiver request to the appropriate regulatory authority and is awaiting the outcome of that request. Shorten the timeframe that a CO code can be reserved. Require an SP that has reserved a CO code to cancel the reservation if the CO code is no longer needed or the safety valve waiver request is denied.

17. INC Report to the NANC 17 Issues in Initial Closure and Initial Pending Initial Closure Issue 497, Identify Changes to INC Guidelines Based on NANC’s Report and Recommendation, VoIP Service Providers’ Access Requirements for NANP Resource Assignments (July 19, 2005), and FCC Order 15-70 (June 22, 2015) Issue 797, Updates to the INC Guidelines Forms Issue 800, Update Audit, Reclamation, and Extension Procedures in 9YY-NXX Guidelines Issue 801, Update p-ANI Guidelines with direction when states do not certify VPC Providers Issue 802, Edits to COCAG Sections 4.1, 5.2.1, 7.1, 7.2 and COCAG Appendix C Sections 4.7(d) and 5.6(e) regarding Valid Switching ID Information Issue 803, NANPA no longer sends 5XX and 9YY contact information to the NGIIF Administrator Issue 804, Update Code Reservation Criteria in the COCAG

18. INC Report to the NANC 18 Issues in Final Closure Issue 799: Allow SPs to request to have excluded rate centers updated to optional for ISP Block Porting

19. INC Report to the NANC 19 Relevant INC Web Pages INC Homepage: http://www.atis.org/inc/index.asphttp://www.atis.org/inc/index.asp INC Issues (historical and active): http://www.atis.org/inc/incissue.asp http://www.atis.org/inc/incissue.asp INC Published Documents: http://www.atis.org/inc/incguides.asp http://www.atis.org/inc/incguides.asp Anyone interested in information on INC or INC documents may contact Jackie Voss, ATIS INC Manager, via email at jvoss@atis.org or (913) 393-0891jvoss@atis.org