On February 24, 2011, the FCC filed a Declaratory Ruling stating that “RespOrgs may not transfer toll free numbers directly from one entity to another without Commission approval.”  This ends the common practice in the toll free industry of allowing an end user to approve releasing a number to another end user. 

I was discussing a separate issue with the FCC Staff last summer and we started talking about number “negotiations.”  Since I am supposed to one of the experts, “Oregon RespOrg goddess”, as one of my client’s put it, I was embarrassed when I had to admit to the FCC that ATL did negotiations in some cases.  I have always understood the end-user control rule so I had felt that if an end-user wanted to release a number to another end-user it was OK.  Besides, it was such a common practice that I hadn’t really thought it through.  The FCC staffers told me in no uncertain terms that it was not allowed.   ATL stopped the practice and we have put up with complaints from an array of RespOrgs ever since.

I see this ruling as good news and bad news.  The good news is that it will be a way to abruptly respond to the myriad people who contact us every week because they want one of our numbers.   When you have more than a million toll free numbers under your RespOrg ID, this becomes a constant annoyance and takes time away from my reps handling their customer’s needs.  It could help manage the growing fraud issues.

The bad news is it makes it impossible to help companies with valid problems.  If a company misprints a number on their stationary and the current end user doesn’t really care about that number, we have always tried to help.  But now the poor misprint company has to go to the FCC to request that the number be moved.  I wonder how fast the FCC is going to handle these situations?  Where does one even go in the FCC to put in the request?  I am hoping to find the answers to these questions and share them with you.

I have been very lax about updates on SMS 2011, but between going to DC for the FCC meeting, working on SMS 2011, and a great Comptel show, I got a little overwhelmed.  So here is where SMS 2011 stands.

After the March 1^st meeting it seemed like the FCC was set on turning the handling of a transition team to replace the current SMS management over to the North American Numbering Committee (NANC).  They told us that this was the only process they had and it would be faster to do that than invent a new process.  Although we weren’t wild about the idea because the NANC has a reputation for being slow, at least a NANC subcommittee would mean that all participants were equals.

SMS 2011 decided to make one more attempt to get the current BOC organization to work with them.  The BOC chair said she wanted that too, but then announced a call for the industry that made no mention that there was another proposal for the transition and positioned them as being charged by the FCC with the transition plan.  The call announcement did say that the BOCs would be asking for some volunteers to give input.  SMS 2011 responded to the BOCs asking if they would be willing to let the volunteer group select their own chair and whether or not information would be shared so everyone would be on equal footing.  A copy of these questions was also sent to the FCC.  I didn’t hear back from either the BOC group or the FCC.  Once again before the call I contacted the FCC to ask if they would make some kind of decision prior to the call, but I didn’t even get a return call.  In the meantime the BOCs moved forward with the call and it was not until almost the end of the call where they allowed questions.  I asked if they had been given the responsibility to be the transition team and they had to admit that they hadn’t.

The BOCs are using a consulting firm called the Taylor Group which has selected a group of nine to work on a survey that will go out to all the RespOrgs.  We don’t know how many volunteers or how the selection was made, but I received some e-mails from others that volunteered.  The good news is they did include three people from SMS 2011.  The bad news is that SMS 2011 had suggested that taking time for a survey really didn’t make any sense.  The entire RespOrg community had been given a chance to be on a call in January and again in March and if they didn’t participate, they probably didn’t care.  Also, the survey is intended to ask detailed questions about board elections and qualifications, things that would be better handled in a small, involved small group instead of a survey.  Again SMS 2011 sent a copy to the FCC and again – nothing.  This group will meet on Monday. 

The result is that the BOCs are still calling all the shots.  Things are moving and that is a good thing, but with nothing coming out of the FCC the BOCs are taking the view that they have the power to control everything because the FCC has not said otherwise.  I am also inclined to suspect, though I don’t know for sure, that all of us are paying for things like the survey and the Taylor Group out of our $.0966 per number per month whether or not we like the direction.  The FCC has an ideal opportunity right now to have the NANC charge this group of volunteers with the responsibility for a transition plan.  Unfortunately it would be better to just let this group do it as an industry group, but then the FCC would have to make it clear that the BOCs are just participants like everyone else and let the group select their own leadership.  In the meantime we keep getting reminded by the BOCs that they have met again with the FCC and again at our expense.

Earlier this month, SMS 2011, a consortium of toll-free RespOrgs, met with the Federal Communications Commission to discuss changing the sole control of the toll-free national database and the accompanying tariff from the Bell operating companies. This bottleneck, said SMS 2011, has kept toll-free from advancing with the telecom industry.

“This is very exciting for the industry,” said Aelea Christofferson, president of ATL RespOrg Services. “The FCC fully supports a more representative group to focus on the changing needs of toll-free. SMS 2011 wants to make the processes that control all toll-free calls more transparent, so companies that have never been landline-based can have more influence.”

 What’s more, many new entrants to the telecom business from the IP world don’t realize that all toll-free calls must be originated on one ofsix carriers, said Christofferson.

The process to form SMS 2011 and its missionstarted about nine years ago. Christofferson invited all 399 RespOrgs to a conference call to start the ball rolling. With almost 40 companies on the call, a group stepped up to meeting, developing, and drafting the FCC proposal. SMS 2011 includes members from Level 3, Windstream, Qwest, Telesmart, and ATL.

 “It took nine years, but finally a process originally launched by Sprint in 2002 has come to fruition,” said Christofferson.

PRESS RELEASE
FOR IMMEDIATE RELEASE:
for more information contact:
Aelea Christofferson
aelea@atlc.com
888-217-5784
www.ATLC.com
Comptel, booth 115, cell phone 541-771-8814

Toll Free Industry’s biggest change since portability in 1993

Sunriver, OR – March 21, 2011- On March 1, 2011 SMS 2011, a consortium of toll free RespOrgs, (if you need a definition of RespOrg I would be glad to help) met with the FCC to discuss changing the sole control of the toll free national database and the accompanying tariff out of the hands of the Bell Operating Companies.  This bottleneck has kept toll free from advancing with the telecom industry and kept all of us working with systems designed in the 1980’s.

“This is very exciting for the industry”, said Aelea Christofferson, President of ATL RespOrg services.”  “The FCC fully supports a more representative group to focus on the changing needs of toll free.  “SMS 2011” wants to make the processes that control all toll free calls more transparent, so companies that have never been land-line based can have more influence.  Still many new entrants to the telecom business from the IP world don’t realize that all toll free calls must be originated on one of six carriers.” Ms. Christofferson added.

The Process took nine years with many dedicated partners to accomplish. Ms. Christofferson invited all 399 RespOrgs to a conference call to start the ball rolling.  With almost 40 companies on the call a group stepped up to meeting, developing and drafting the FCC proposal.  “SMS 2011” included members from Level 3, Windstream, Qwest, Telesmart, and ATL.  “It took nine years, but finally a process originally launched by Sprint in 2002 has come to fruition.”

ATL RespOrg Services is the oldest and largest independent RespOrg serving carriers (IP included), resellers, consultants and large end users.  Prior to launching ATL in 1991 Aelea Christofferson had already been involved in toll free since the 1980’s when she was Pacific Bell’s representative to the team that designed toll free portability.
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Comptel is next week in Las Vegas.  We are making appointments with our President, Aelea Christofferson, who is looking forward to talking with people who are interested in the recent FCC meetings that will change the management of the toll free systems.  If you are a RespOrg, sell toll free, or a large end user of toll free, you need to talk with Aelea so you can be a part of the plans.  Call 800-398-5777 and ask for an appointment.

 In Monday’s blog about the FCC meeting I mentioned the three Bell Operating Companies (BOCs) had presented their own transition proposal to the FCC.  Here is a little more detail.  In January I had gathered a group of companies to start preparing a proposal for the transition.  The FCC had already told me that they were open to this, so I invited some RespOrgs, a couple management DSMI people, and the board members from the current SMS/800, Inc. (which I am going to call the BOCs for this blog). My purpose was to take a proposal to the FCC that had already been widely agreed on by the industry.  (For those of you that are a little behind on this you can see a description of SMS/800, Inc. on the proposal attached to my last blog and DSMI is the business management that runs SMS, including the contract with Sykes for the Help Desk.)

We had two participants from DSMI and one of the BOC board members on our calls designing the proposal.  I had been told during this period that the BOCs were going to take their own proposal, but these three continued to work with us.  On February 8 the BOCs took their proposal to the FCC.  They shared the proposal with us the next day and then told us that they were no longer going to participate with us.  They also ordered DSMI not to participate.  The DSMI people had not only been participating, but had accepted the invitation to go to the FCC with us, but since they work for the BOCs, they had no choice but to do as ordered.  After they exited the call the rest of us reviewed the reasons they gave for pulling out and agreed they made no sense.

In our meeting with the FCC we asked if they had suggested that these groups no longer participate.  Not only did the FCC staff say no, they said that things would have been so much easier if the industry had come with only one proposal.  We repeated that we agreed and had hoped for that too.  No one in the room, not the FCC staff nor our group, could come up with why the BOCs made the decision they did even after our giving the reasons the BOCs had given us. 

So we are all left with the question, “Why would the BOCs do that.”  If the FCC orders a more representative group work on the transition, and it is my opinion they will, all that the BOCs accomplished was to take what could have been a simple request to the FCC and turned it into a much longer more complicated process.  Hmm, maybe I’ve got something there.

The first big step to changing the management of SMS and regulatory control of the RespOrg tariff happened in Washington, DC on Tuesday. For almost two hours six staff from the FCC’s Competition Policy Division, including Deputy Division Chief Ann Stevens, met with eight of us from the industry. The participants are listed on the attached proposal plus two of Level 3’s attorneys. Level 3’s support has been really wonderful and crucial in our discussion of the limitation of only six companies with nationwide CICs.

Most of the discussion centered on what the process should be to transition the current SMS/800, Inc. board of three members, one from each of the Bell Operating Companies (BOCs), to a more representative leadership. No one disagrees that this needs to be done, but the SMS/800, Inc. members would like that transition to be planned by the three of them while our group wants the transition planned by a broader group. We had found out earlier in the month that the BOCs were ready to take their own proposal to the FCC on March 8, but we didn’t find out until Tuesday’s meeting that they asked there not even be public comment on their proposal. The good news is since our meeting that won’t happen.

We haven’t received final word yet, but I think it is safe to say that there will be a broader group involved in the planning and the FCC staff feels that this warrants a short time frame (maybe six-months) to require the new board to be in place. We are hoping for the official order shortly.

FCC Proposal

Presented slide show

The FCC meeting to present the proposal to change the management of the toll free industry is less than a week away. We need the industry to speak up to support this proposal. The three Bell Operating Companies have filed their own proposal stating that the transition should planned by just the three of them.

To be included on the list of companies supporting the proposal for a more widespread industry involvement in this change we need you to follow the instructions below.

Go to your browser and put in
http://groups.google.com/group/sms800NewManagement
• Join the group
• Then to post your comment you send an e-mail to sms800NewManagement@googlegroups.com. That will send a copy to the members of the group and post it.

Your comments don’t need to be long. All you have to say is that you support SMS 2011’s proposal and that we need to get this done now.

Thank you to all of you that have already posted

FCC Proposal

The attached draft proposal will be presented to the FCC on March 1, 2011. This is an important change for the industry because it would, for the first time, be allowing companies other than the Bell Operating Companies to be represented in the management and regulatory control of the toll free industry. A Google group has been set up to get your input, sms800newmanagement@googlegroups.com. Please join this group to see all documents and updates on this process, but more importantly to give your input on these important changes.

It will be important at the FCC meeting to provide industry input. SMS 2011 will also consider your input for inclusion in the proposal if it is received prior to February 23.

The new SMS rates will be reflected on ATL’s March 15, 2011 invoices. SMS pass-through is billed in arrears.