FCC mandated number pooling and 9-1-1
By Rick Jones
(FYI-please distribute as feel appropriate.)
For those who wish, the entire FCC order can be viewed or downloaded here:
Word 97 zip file for downloading
In case the footnotes from the order do not carry over to this message, I have also attached theappropriate 6 paragraphs from the order available here.
Word 97 zip file for downloading
The FCC has issued a Report & Order & Notice of Proposed Rulemaking
(00-104) stemming from its Number Resource Optimization docket (99-200),
Number Resource Optimization.
Basically, the newest order mandates nationwide number pooling with a
rollout beginning in approximately mid-2001.
Number pooling is one of the least disruptive to 9-1-1 of all the various
methods that were/are being considered to slow down number exhaust, which
has been causing area code splits and overlays throughout the country.
However, it can dramatically increase the amount of local phone numbers
which cannot be identified as to service provider, because the prefix (NXX
part of NXX-XXXX) cannot be used as the identifier.
As of the end of March, 2000, there were approximately 6.5 million local
phone numbers nationwide involved in porting/pooling. The prefix (NXX) can
no longer be used to identify which service provider to contact, for these
numbers.
Currently, this number is increasing by more than 1/2 million monthly. With
nationwide number pooling beginning in mid-2001, this total could increase
dramatically.
The FCC in the current order stated “Because of its potential impact on
accessibility to telecommunications services, we decline to address the
nationwide implementation of IVR in this Report and Order. We do, however,
reserve the right to implement this requirement in future proceedings.”
In the original rulemaking regarding this new order, the two national
organizations to file comments (jointly, also) were APCO and NENA. The
Illinois chapter of NENA also filed comments regarding the IVR.
No national, state or local public safety/law enforcement
organizations/associations filed comments. That is unfortunate but
understandable, since virtually all of these groups are unaware of the
existing and increasing problem.
If 9-1-1 receives a “no ALI record found” on a “no voice contact” call, a
service provider must be contacted to get an address.
If law enforcement needs to do a phone line interrupt/takeover, the correct
service provider must be contacted. If law enforcement needs to get a court
order/subpoena to either get existing phone records or do a trap/trace, the
correct service provider must be known.
Without the Neustar IVR, each instance mentioned above could require a
phone call to 15 to 20 local service providers in an area with local
service competition, in order to complete the function.
To further convince the FCC of the importance of the Neustar IVR, we must
seek support from national/state/local law enforcement organizations.
Any advice or offer of assistance regarding this would be greatly
appreciated.
I am willing to take part of phone calls, conference calls, and meetings
(subject to resolving travel costs) and to write articles, e-mails,
whatever. Thanks for any assistance.
Rick Jones, ENP
Loves Park (IL) 9-1-1
office 815-654-5011
fax 815-633-0555
email [email protected]
Following are excerpts from the FCC order that pertain to 9-1-1 and public
safety. The first four paragraphs are together in the order. The fifth and
sixth paragraphs are found in separate parts of the 143 page document.
4. Public Safety Impacts
In the Notice, we solicited comment on whether the National Emergency
Number Association (NENA)-recommended standards, as well as the T1S1.6
recommended restriction on the porting of E911 routing numbers, are
sufficient to ensure the reliable provision of E911 service where
thousands-block number pooling is implemented. We sought this information
because several commenters to the NANC Report expressed concern about
thousands-block number pooling’s impact on the provision of E911 services,
and upgrades and changes to E911 systems if thousands-block number pooling
is implemented.
In response to comments received from the NENA community regarding the
potential problems with implementing thousands-block number pooling in a
geographic area beyond the traditional rate center, we conclude that each
thousands block pool should be confined to a rate center, which denotes the
smallest geographic area used to distinguish rate center boundaries. Thus,
each rate center would contain a separate pool of numbering resources.
This architecture will allow the maintenance of current wireline call
rating mechanisms associating an NXX with a particular geographic area
(i.e., rate center).
Because thousands-block number pooling will be limited to the traditional
rate center area, we do not envision widespread disruption to E911 service
in this country. Moreover, we also note that the T1S1.6 did not
specifically identify any impact on the provision of E911 service
associated with the implementation of thousands-block number pooling in
their Technical Requirements for thousands-block number pooling. We do,
however, ask that routing numbers to which E911 calls are translated not be
ported. If the routing number to which the E-911 calls are translated is
ported, we ask that a new 911-routing number be assigned to the recipient
switch, if necessary. Therefore, we conclude that the NENA-recommended
standards, as well as the T1S1.6 recommended restriction on the porting of
E911 routing numbers are sufficient to ensure the reliable provision of
E911 service where thousands-block pooling is implemented.
Commenters also recommended that NeuStar’s Interactive Voice Response (IVR)
unit be implemented nationally to address telephone company identification
problems. IVR is a system that would enable a PSAP (public service access
point) to access the NPAC data, which indicates what company owns each
ported telephone number. Because of its potential impact on accessibility
to telecommunications services, we decline to address the nationwide
implementation of IVR in this Report and Order. We do, however, reserve
the right to implement this requirement in future proceedings.
(UNP = unassigned number porting; ITN = individual number pooling)
We permit carriers, however, to engage voluntarily in UNP where it is
mutually agreeable and where no public safety or network reliability
concerns have been identified. Despite arguments raised by parties that
even voluntary UNP arrangements will skew utilization forecasting and
impact SCP capacity, we conclude that the volume of ported numbers will
not likely be high enough to affect carriers’ inventories and SCP capacity
appreciably. Furthermore, we encourage the states, the National
Association of Regulatory Utility Commissioners (NARUC), NANC and INC to
continue to study ITN and UNP and forward their recommendations to us by
January 1, 2001. We remain interested in the possibility of implementing
either of these pooling methodologies as part of the national numbering
resource optimization strategy if they are shown to have sufficient promise
and feasibility.
At this time, we do not address issues raised in the Notice regarding
audits, rate center consolidation, ten-digit dialing, and the use of
technology-specific overlays. We emphasize that in the interim, our
existing rules and policies with respect to these optimization measures
(including the prohibition on technology-specific area code overlays)
remain in effect. We also emphasize that the optimization measures we
adopt here today should not be viewed as substitutes for area code relief
where it is required due to area code jeopardy situations. We intend to
address these issues, as well as other numbering resource optimization
strategies, in subsequent orders in this docket. We also seek comment on
several matters relating to our findings in this Report and Order in an
accompanying Further Notice.