A new Transition Team is now in place to start the design process for expanding representation on the SMS Board.  For those of you coming into this issue just now, SMS/800, Inc. has been managed by a board comprised of the Bell Operating Companies since the beginning of toll-free portability.  This year the Bell Companies, other companies in the industry, and the FCC concluded that it was time to open board participation to other participants. 

To date, the effort has been managed by the current SMS/800, Inc.  Tuesday the new Transition Team held its first conference call.  Participants included representatives of twelve companies that comprise this new group:  800 Answer, 800 Response, Advanced Communications Integrated, Inc., ATL RespOrg Services, csf Corporation, Grande Communications Networks, Inc., Level 3 Communications, Excel Telecom, TeleSmart, Verizon Business, WorldLink Services, and Windstream.  The group is well supported by Michael Wade and Anil Patel from DSMI and Muareen Callan who is the present chair of SMS/800, Inc.  We are tasked, over the next five or six months, to develop a process to fill these new board seats.  We already have the survey that was done by an independent consultant hired by SMS/800, Inc. to serve as a guide so, as it appears now, much of what we will be doing is fine-tuning that process.

The team selected Dale Schneberger of Grande Communications, and me as co-chairs.  The Transition Team members will all meet in person for the first time August 2.  I am very optimistic about the positive impact this change can bring to our industry and would be glad to get input from all of you regarding what you feel might be needed.  The team clearly indicated a desire to be transparent and so I will keep you up to date as we go.

There have been rumors that the Public Switched Telephone Network (PSTN) is going away but I think the rumor has become fact.  Recently the FCC’s Technical Advisory Council (TAC) told the FCC that it was ready to recommend a date for the PSTN sunset.  They based the date on studies that show that by 2018 only 6% of the population will be using landlines.  I personally am not ready to lose my landline connection and still think it is the gold standard.  But, let me relate a personal story.

I have a 20-year old son who has Attention Deficit Disorder (ADD) and I don’t mean the often misdiagnosed sort of scatter-brained.  Tom and I know – we have seen the brain scans.  A cell phone for him is a problem because it is always lost, dead, stolen (?) or something else that makes it unavailable.  I got so tired of trying to reach him I decided to suggest a landline.  So I said, “Patrick, how about I get you a phone that plugs into the wall so you can always find it.”  His reply, and he wasn’t kidding, was, “What a great idea!”  I was on a roll so I also suggested that I get him a phone attached to the wall with a machine that will blink and that blinking means “your mother called”.  He thought that was a great idea, too.

A week later his number had been busy for more than a day so I went by his work and told him his phone was “off the hook”.  He didn’t know what I meant so I told him it meant “the top of the phone and the bottom of the phone were not united”.  He asked me if I had stopped by his house because “how else would I know that this was what had happened?”

Cute kid, but we have five kids between 18 and 28 and none of them has a landline.

Next blog, what does this mean to the FCC and the way we fund universal service?

Last week I went to New Orleans, with a couple of other interested parties, to meet with some of the leaders of the Local Number Portability (LNP) Working Group.  One of ATL’s customers, Telecom Recovery, a product manager from Neustar, and I have been discussing what options there might be for establishing a process to better manage local ports in emergencies, including carrier outages. Scott Mah, from Telecom Recovery, highlighted a recent carrier failure in Seattle that disrupted incoming calls to a number of organizations, including portions of the City of Seattle, Harborview Medical Center, and the University of Washington.  Impact during this extended outage could have been mitigated if it was possible to quickly port affected prefixes to alternate carrier facilities that were already in place at each of the sites. 

For years I have questioned why the LNP process was set up with no end-user customer control. I met with the committees planning local porting in the late 1990’s, but no one seemed interested in lessons learned in the decade of porting that had already taken place in toll-free calling.  There was, and still is, an insistence that there are no similarities between the two.  I am not an attorney but I think the FCC considers local numbers to be under end-user control in much the same way that end-user control is clear in toll-free.  The gentleman from Neustar calls this the “democratization” of local porting.

I am interested in your comments on this issue.  Is this a concern to you?

I recently invited my employees over to our house for dinner.  When one of the children couldn’t reach the table, I suggested getting the telephone book.  I thought all of us were raised using a telephone book (or multiple telephone books, if the child was really small) as a booster seat to enable the child to reach the table when eating.  My 20-something employees looked at me as if I were crazy.  Why did I need a telephone book?  Why?  None of them use telephone books as booster seats or to look up numbers – they use the internet so they don’t even readily know where their telephone book is!

This week I saw a blurb in Miller-Isar’s “Regulatory Review.”  If you don’t know Miller-Isar, you should.  It is a great option for outsourcing those pesky government filings and a lot of other things.  Anyway, the article said that the California Public Utilities Commission (CPUC) is allowing Verizon to quit automatically delivering White Page Telephone Books to their customers.  Verizon will monitor the directory assistance statistics to see if the change has any “adverse impacts to subscribers.”  I bet they will find that today’s subscriber’s, those that haven’t already gone to cell phones only, won’t even notice.

So here is your Insider Information hot stock tip – buy stock in booster seats!  There’s going to be a run on them.

Every week ATL gets calls from people complaining that they are getting called by a toll-free number and they want it stopped.  The toll-free number is showing up on their caller ID.  It is difficult to explain to people not in the industry (and sometimes to people in the industry) that a toll-free number can’t make an outgoing call and so it is not calling them.  This practice, known as “spoofing”, exploded a couple of years ago when low-cost devices were introduced, which made it very easy for anyone to “spoof” their Caller ID.

I have been irritated about this issue for a long time and, apparently, Congress got irritated, too.  I appreciate Michelle Wood, from Compliance Solutions, giving me a heads up on this.  Last year Congress passed and, President Obama signed into law, the Truth in Caller ID Act, which prohibited caller ID “spoofing with harmful or fraudulent intent” and directed the FCC to adopt rules implementing the Act.  Friday the FCC issued the new rules.  Under these new rules:

· Violators are subject to up to a $10,000 fine for each violation or three times that amount for each day of continuing the violation, to a maximum of $1 million for any continuing violation.

· The FCC may assess fines against entities it does not traditionally regulate and they can do this without first issuing a Citation.

· The FCC can impose penalties under this act more readily than it can under other provisions of the Communications Act.

Under the Truth In Caller ID Act, callers are still permitted to alter caller ID information if their purposes are not harmful or fraudulent.  For example, domestic violence shelters may have important reasons for not revealing the actual number of the shelter and doctors responding to after-hours messages from patients may choose to transmit their office numbers rather than their cell phone numbers.

Hooray to the Congress, the President, and the FCC!  ATL’s first action, based on this Act, will be to immediately let our clients know when we have received a call about a spoofing incident.  In many cases ATL’s clients are carriers or resellers so we will ask them to contact their client.  If ATL gets a second call we will disconnect the toll-free number until we have been notified of the resolution of the situation.

I hope other RespOrgs will follow suit on this.

For the entire Public Notice: http://transition.fcc.gov/Daily_Releases/Daily_Business/2011/db0623/DOC-307891A1.pdf

I need to take a break from vacation writing for a bit if business.  The 800/SMS restructuring committee, being run by the BOCs, is a little stalled.  In March when the BOCs and SMS2011 each met with the FCC, SMS 800 said they wanted to have a new board in place within six months.  The BOCs said they would get it done by the end of the year.  Since the difference in the times we were looking at was not completely out of line, those of us from SMS 2011, who had been selected to be on the restructuring committee, decided we should go forward and hope for the best.

Things looked good initially, although some of us felt that the survey process was not the best use of time.  The first meeting was April 11 and the survey was done fairly quickly.  However, when we were called back together on May 4 to hear the results, there were no results!  The consulting firm reported they had no results because “there was not enough time to get the results managed”.  This was an online survey so I am certain the software would have spit out at least the number of responses there were to specific questions.  Now the consultant will be tied up and the next meeting isn’t until May 25.  This puts our first look at the survey results out almost six weeks from the first meeting.  Since there are only 109 survey participants this seems excessive.

I am crossing my fingers that this isn’t the beginning of continuing delays that prove participation in the BOC controlled process was a mistake.  When SMS 2011 requested that the FCC move the process to the NANC, our only concern was they might be too slow!

After a few days here you get into the rhythm of the place.  First, you have to remind yourself that you are on vacation.  You don’t ever need to be in a hurry and sitting and doing nothing is not only allowed, it’s the whole idea!  Second, you learn to plan your day around what you now know:  you don’t have water from the time you get up until some random time in the afternoon because of the construction going on behind the condo; you have great, fast internet until about 4:00PM and then it is sketchy; there is a reason that Latin America’s take a siesta during the hottest part of the day.  But, the most important thing we have learned is this: if you want to drink with monkeys overhead in the trees, you go to the bar at 5:00PM when they come out but before it gets too dark (and/or you have too much to drink) to see them.

We are really looking forward to tomorrow.  Tom and I love to fish and we go frequently at home.  We don’t like “sports fishing” – none of that “catch and release” stuff for us.  Our favorite part is catching the fish, taking them home and eating them!  Luis and Maria have made arrangements with a local fisherman, who has a small boat, to take us fishing in the bay right by where we are staying.  It will be very different (and fun) to fish someplace where, if you get too hot, you can dive into the water without freezing.  And, hopefully it will be “catching” as well as “fishing”!

For the ATL staff:  We are leaning towards the monkeys made out of coconuts with glasses on (yes, it’s an inside joke.)

These blogs are going to be sort of a first for me.  I have been criticized because I never blog about anything but business so, if you like those blogs, you may not want to read these.

Tom and I are in Costa Rica for almost two weeks.  This is huge for us.  In the 22 years we have been married, we have only had one vacation longer than a week and that was about five years ago.  Before we arrived in Chicago to change planes for the East Coast one of our kids got suspended from school another got caught driving the family car, of course not 16 yet, so we gave up traveling for a while!

We arrived in Costa Rica on Wednesday, May 4th.  A really great client and friend of ours loaned us his condo in Coco Beach.  It’s a great little town right on Coco Bay.  The condo is within  walking distance of the downtown area and the beach is right out the front entrance.

The first afternoon didn’t go too well. Tom and I had just spent sixteen hours en route and had had little sleep and little to eat.   But, we were anxious to see the sites and totally ignored the fact that, as we were landing, they announced that it was 90 degrees outside!  We changed into shorts and T-shirts and headed out to find a margarita and some food.  Remember, we live where it hasn’t yet been more than 55 degrees this year and at an altitude of 4000’ with no humidity.

Needless to say, by the time we got to the restaurant area, I had become, as my daughter used to quote when she was three, a “btcih” (wonder where she heard that!!), threatening Tom that if he didn’t find me some water and food immediately I would pass out right where we were.  Then we discovered that Tom only had a credit card with him and the first couple restaurants didn’t take credit cards.  When we finally sat down I was too sick to eat and had no interest in a Margarita.  A memorable way to start our first vacation in such a long time!

We took a cab back to our air-conditioned condo, went for a cooling swim and then felt ready to start again.  We’ll pay attention to the weather reports from here on!

More to come ….

How fast should your numbers be ported from one RespOrg to another?

The tariff that all RespOrgs are charged to abide by says the following:

“The current Resp Org will release the toll-free subscriber’s SMS/800 records to the receiving (new) Resp Org within two (2) days of the receipt of the request…”  How long does it take you to port numbers?  Last quarter ATL ported 87% of our customer’s numbers with 48 hours and 98% within 72 hours, so yes, we are not yet in FCC compliance, but that’s our goal.  All we need is the cooperation of every other RespOrg.

How many carriers can originate traffic throughout North America?

Four; AT&T, Level 3, Sprint, and Verizon (the 0222 CIC code).  The other Verizon CIC codes, Qwest, Global Crossing, and Matrix have it almost covered.  I guess with Level 3’s purchase of Global Crossing things may change.  The bottom line is everyone else is reselling some of their network off the Carrier Identification Code (CIC) routing of these carriers.

Why would a RespOrg Outsource their work to another RespOrg?

The cost of being a RespOrg work is heavily affected by scale and experience.  Even large RespOrgs have found it much less expensive to outsource their work to ATL while keeping their RespOrg ID and identity.  Besides, they get much faster revenue due to our porting expertise.

How can you fix a toll free network outage in minutes?

This is perhaps one of the best kept secrets.  By setting up multi-carrier routing before any kind of outage, natural disaster or network issue, a company has protected itself from losing their client’s or their own valuable toll free calls.  As ATL demonstrated in Hurricane Katrina, toll free traffic can be recovered in minutes, even if the disaster is at the calling end.  Why spend thousands to duplicate networks into your building only to have the network fail where your customers or clients are?  If you are a government entity or an insurance company it is more likely the problem will be at the callers end.

I didn’t realize I never answered this after the blog.  I did answer it in the newsletter, but I guess I can’t expect everyone to read everything I write.

LADWAB is an acronym for “Like a dog with a Bone.”  Like the name ATL, LADWAB has a long history but a great story.  As a new, young business person I was excited as I walked across the stage to receive an award from Ted Saenger, then the CEO of Pacific Bell.  I held my breath as Mr. Saenger turned to the audience and said, “Aelea is like a dog with a bone.”  While he meant it kindly as recognition of the determination I applied then and still apply to every customer, it always stuck as a strange description to be used in front of 500 people.  Many years later it is still considered ATL’s foundation for customer service.  Every employee is measured on LADWAB on their appraisals.  So now besides using NASC and CIC as verbs with your reps, you can use, “Have you LADWAB’d that?”