On April 4, the FCC issued a request for comments on the release of the 844 toll free NPA.  The comments were focused on the process used for the 855 release: 100 numbers per day per RespOrg entity.  The word entity is very important in the toll free world.  ATL has over 300 RespOrg IDs, but we have only one entity, AU.  That is the only part of the five digit ID that means anything to the SMS.

When 855 was released, ATL supported the 100 per day plan.  Although it didn’t seem quite fair that a large RespOrg like ATL with 1.7 million numbers received the same allotment as a RespOrg with 50 numbers, it was a big improvement on prior releases where some companies got all the “good” numbers because they designed their systems to suck up large quantities of numbers as part of their business.  Often that was the business of hoarding or selling numbers, not the business of being a RespOrg.

Unfortunately this attempt to put some sanity in the process of allocating numbers didn’t work either because companies opened multiple RespOrg entities to have access to more than the 100 numbers per day.  So we, the guys in the white hats, owe a big thank you to 800 Response who had the foresight to prepare a comment aimed directly at this issue.  In the filing, 800 Response asked the FCC to do the following:

“Direct SMS/800 to amend its tariff to prohibit the participation by multiple Responsible Organizations (“RespOrgs”) affiliated by common ownership  from reserving or otherwise participating in the allocation of toll free numbers  during the 844 code release.”

800 Response not only took the time to do this, they got almost 50 companies, including ATL, to sign on with them.  I hope the FCC and SMS/800 Inc. fully cooperate with this request.  Although many companies have multiple entities for valid reasons, such as through mergers and acquisitions, there are companies that have opened entities just to game the system for situations like this one.  The industry is well served by ensuring that allocation is fair to everyone.

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On April 18, the FCC released their NPRM addressing availability of local numbers to companies other than traditional telecom companies.  What do the 82 pages tell us about how the FCC might be looking at future changes and what the industry might begin to expect?  Remember, this filing only applies to local numbering resources. Toll free was designed differently because any company can become a RespOrg and get their own numbers through SMS.

The Notice of Inquiry filed with the NPRM asks a number of questions of the industry pertaining to assignment of local numbers. The questions are a very good clue to the direction the FCC is considering, but the big announcement is the order attached to the NPRM to start a technical trial allowing Vonage and some other VoIP providers to directly access local numbers from the North American Numbering Plan Administrator (NANPA).

Since the Communications Act of 1934, only providers who had a state certification and/or an FCC license could directly access local numbers.  These rules were put in place to promote efficient allocation and to closely connect the actual needs of the customers to the availability of numbers. As more IP carriers moved into voice services, these companies were competitively disadvantaged because they didn’t have this type of licensing requirement, but needed access to local numbers for their customers.  The April filing is the FCC’s solution, or at least trial of a solution, to this competitive issue.

This filing is so important that we will be covering other issues raised in it in future newsletters and blogs, but the direction of the FCC is clear from the opening paragraph of the filing. “Telephone numbers are a valuable and limited resource…” and “….the Commission is engaged in a broad-ranging effort to modernize our rules in light of significant ongoing technology transitions in delivery of voice services, with the goal of promoting innovations, investment, and competition for the ultimate benefit of consumers and businesses.”

These statements, combined with the Vonage decision, make it clear that the FCC recognizes that the future is not in the landline and the landline providers.  This is a major undertaking for a government bureau that has regulated landlines since 1934. We need to ensure that the industry follows what is happening and speaks up if we want to mold how telecommunications will be seen for the next eighty years.

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I was contacted by a carrier/reseller who is having a fraud problem and wants to know if others are experiencing the same thing.  That company is getting a large number of calls, all from different caller IDs, that when the call is answered there is just music, possibly Asian, played and touchtone beeps.  The beeps sound like what you would hear from an auto-dialer.

If your company is experiencing any of these kinds of complaints, can you respond to this blog, or if you would rather not have it public, let me know at [email protected].

 

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SMS/800, Inc. and the SMS/800 Number Administration Committee constantly track how many numbers are removed from the SMS spare pool so that the industry doesn’t experience a shortage of toll free numbers.  Based on that tracking, in April 2012, it was believed that the 90% in-use trigger for releasing the 844 prefix would occur in the first quarter of 2014 with full exhaustion in the fourth quarter of 2015.  Consequently, it was decided to release 844 around February 2014.

Suddenly, in March 2013, almost a million numbers were reserved from spare: 800,000 numbers.  That left just over 4 million toll-free numbers available, or approximately 10.5% of the numbers.  Now the industry is under pressure to get 844 released sooner, get the numbers back, or proceed to control reservations.

Who needed nearly a million numbers in a couple of weeks?  I will bet, without  knowing as a fact, that these reservations were not spread over several RespOrgs.  I would bet that the reservations were made by one or just a few RespOrgs.

The FCC has talked about hoarding issues for years, but not much has happened.  I am a little concerned that if the FCC steps in without careful consultation from a wide range of industry experts, the real culprits will not be the ones that suffer.  I know this from experience with trying to respond to the investigation a couple of years ago.  I admitted to having six numbers that got missed when I sold my CLEC and I was informed that that qualified as hoarding.

It is time that the regulations on the sale and hoarding of numbers is addressed, but not just by the FCC coming down on the issue through regulation and fines, but rather through a true discussion with the industry about technical issues that allow hoarding and a realistic look at the sale of numbers.

The issues are not as simple as the last group of questions the FCC used in their investigation. We need long term, well planned solutions.

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And it needs to be before March 29!

In September 2012, we all came together to convince the FCC to approve the election of a new board to SMS/800, Inc.  Well it hasn’t happened and now the FCC needs more convincing to finish the job.   YOU DON’T NEED TO BE A RESPORG OR NEED A LAWYER TO LET THE FCC KNOW WHAT YOU THINK!  If your company cares about the future of toll free, please follow these simple instructions.

I have attached everything you need. (Just click the link to download the file)

  1. Easy instructions to file online with the FCC
  2. A sample letter for filing as an attachment
  3. A copy of the FCC’s request for comment
  4. Some history for those of you new to this

Please file today.  If you have any questions or need any help, e-mail [email protected].

Thank you

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In the late 1980’s, when we on the SMS/800 committee were developing toll free number portability, we realized there would be some risk of taking customers out of service during the porting process.  This interruption in service could happen because the receiving RespOrg could not provision the service until they had RespOrg control, and so having the releasing RespOrg consider the port an immediate disconnect would take the customer out of service.  Since the committee also had recognized the possibility of an independent RespOrg, the need to clearly indicate that the change of RespOrg and the change of carrier were two different things was paramount.

Even more important than those reasons was the level of importance the FCC put on end-user control of their toll free numbers.  In the orders the FCC issued and has issued since, the end-user control has been supported except in the rare circumstances surrounding shared and bundled use services.

Following the FCC’s orders the SMS/800 Guidelines issued in 1993 made the following statement.

3.2 Change of RespOrg

3.2.1 A change of RespOrg should not be confused with changes to the Toll Free Service(s) or choice of Toll Free Service Provider(s).  It is the responsibility of the Toll Free Subscriber to separately advise its Toll Free Service Provider(s) of any proposed changes to the Toll Free Service(s), including but not limited to, disconnection of service. The Toll Free Service Provider may not disconnect or in any way interrupt Toll Free Subscriber’s service based solely upon a change of RespOrg.

3.2.2 Responsibilities of the Toll Free Subscriber

  • Establish a business relationship with the Submitting RespOrg.
  • Provide the Submitting RespOrg a valid, signed Letter of Agency (LOA) as described in 3.2.3.
  • Notify the Submitting RespOrg of the requested date for the RespOrg change to occur.
  • Notify its Toll Free Service Providers of any changes in service arrangements including, but not limited to, disconnection of service.

 

This language was still included when the Guidelines were updated in May 1012.  Why then, twenty years later, are there still companies that take a RespOrg change to mean a disconnect?  Do these companies not understand that the FCC’s interest is in ensuring that the end-user’s toll free calls are not brought down before the customer is finished with their service ?  Is it too much trouble for the releasing carrier to confirm this before they put the customer out of service?

This is especially a problem for ATL.  ATL has been around since 1993, and we are one of the ten largest RespOrgs.  It is no secret that we are not a carrier of any kind and that our service provides an outsourced RespOrg option.  Why then would a carrier releasing a number to us decide that their customer is automatically disconnecting their service?  In many cases our clients have decided they want to have their numbers under their control and are not making a carrier change at all, but because the carrier doesn’t know or doesn’t care about the rules or the customer, they disconnect them.  Not a good idea to irritate your customer like that.

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For years, ATL Communications has been involved in the quick recovery of toll free traffic from localized network outages and currently we are working with several companies to find new ways to provide that same quick recovery for outgoing traffic.

While working on these projects, I was surprised to learn how many outages occur and how many carrier customers are affected. We all heard about the 250,000 lines out for 40 days after 9/11 or the 1.4 million after Hurricane Katrina, which by the way, ATL recovered them for the state offices in about an hour. These other small outages go unnoticed, except by the people they affect and their carriers or resellers who don’t have what is necessary to recover quickly.

What is even more disturbing is how few alarm companies, emergency services, including government emergency services, and insurance companies have the kind of back up needed.  ATL hears over and over how these companies are reassured by their vendors that because they spent enormous amounts of money getting alternate paths into their buildings they have “end to end” recovery capability when in fact just one end was handled.

As Louisiana state officials learned, these alternate paths do nothing if the outage is at your client’s or customer’s end.  Think of all the outages that could have been avoided or reduced in time for a total of just $200 to recover thousands of calls in only a few minutes, but it didn’t happen because no one told the emergency services how to do it.

Here is a snapshot of just two months of outages.

Date

Location

# of Lines Down

Time to Repair

7/6 Bremerton, WA 40,000 6 Hours
7/3 Pocono, PA Not Published 17 Hours
7/3 Oak Park, ND 3,000 1-4 Days
7/2 North Star, MN 192 21 Hours
7/1 Burr Ridge, IL Not Published 34 Hours
6/29 Palm Springs, CA 1,200 8 Hours
6/27 Rapid City, SD Thousands 4 Hours
6/22 Lincoln, NE 23,000 11 Hours
6/21 Southeast, NE Not Published 2.5 Hours
6/17 Carlisle, SC 455 24 Hours

There have been cost-effective ways to protect your toll free traffic since 1993 and work is going on right now to bring that same security to local traffic.  Do you have customers in any of the cities above.  Were you ready to help them?

Call us, we can help you. And our toll free number, 800-398-5777, is never down.

 

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We recently experienced a problem using templates on Canadian origination.  The whole idea of using templates is that you can update all the records associated with that template with one change and it happens almost immediately.  Unfortunately, it is not necessarily true when you change the Canadian carrier.

It turns out that Bell Canada’s  SCP BX01 is not really set up for templates.  When you load a number on a template, Bell Canada converts it back to a CAD in their system so it can be processed.  If you make a change to the template, the change is not recognized by BX01 so that traffic will continue to be carried by the original carrier.  Actually this only happens if the dip goes to BX01.  If the dip goes to Telus EU01, then the number will be routed properly as Telus’s SCP is template compliant.   That is why it was confusing to us that some of the traffic was going to the new carrier, but not all.

I think it is about time that Bell Canada think about upgrading its SMS database to become more compliant.  If you agree and have significant toll free traffic originating in Canada, you should contact the Canadian Radio-Television and Telecommunications Commission (CRTC) and voice your opinion.

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As they say, timing is everything.  Earlier this week, ATL’s newsletter came out with information about “spoofing.”  In case you didn’t read the article, “spoofing” is the practice of replacing the Caller ID with another phone number, something that is subject to fines from the FCC if done for illicit purposes.  A week ago, I became a victim of spoofing and they spoofed the wrong person this time.

 

ATL frequently receives complaints from people that one of the toll free numbers under our RespOrg ID is harassing them with calls.  As many of you know, it is very difficult to explain to a non-telecom person that a toll free number cannot originate a call.  The problem with catching spoofers is in most cases it is impossible to track down the culprit because all you have is a non-working toll free number; that is where this story gets interesting.

 

I am on the board of the Oregon Healthcare Exchange, part of the healthcare reform process happening across the country.  Last week, I started getting calls with Oregon Caller IDs on my home phone.  The callers were leaving me messages about their views on healthcare.  The people clearly didn’t know much about the issue and I could hear them being prompted by someone else in the background.  If I answered, the caller hung up.  This would go on non-stop for a few hours then stop and then start a couple of days later.  I called back some of the people who had called me, remember, I was getting their Caller ID, and I found that all were members of one particular union and they had been led to believe that they were calling an organization and not a private residence.  Many said they were confused when they heard the greeting, “Hi, this is Aelea and Tom.”  When I asked who called them, they gave me a non-working toll free number, but they knew it to be their union.

 

As most of you know, I am not one to let a wrong go unanswered, so I started to do some research.  Other board members were getting these calls some at their businesses, some on their cell phones.  This was even more maddening because our meetings are public and if someone wants to talk to us it is very easy.  This particular union has chosen not to participate in the public meetings.

 

I looked up the RespOrg ID for the toll free number and it turned out to be owned by someone I had met a couple of years ago.  She had been plagued by this kind of use of this number until she was no longer able to use the number.

 

The next step was the FCC and an Oregon Congressman.  I had done the math according to the “Truth in Caller ID ACT” and the fines for just the calls to me add up to $900,000.  The fine limit is $1M, so with the calls to all the other board members this situation easily reached the limit.

 

So what do I want from all this?  I am not really interested in getting a union fined $1M since their misled members are the ones who pay the fine, but I am interested in the FCC levying some kind of fine so this organization and others know there are teeth in the law.  I also want the following from the organization:

 

  1. Letter of apology to the board members
  2. Settlement with the company that owns the toll free number
  3. Written agreement that this approach will never be used again

 

I’ll let you know what happens.

 

PS:  I do want to make one correction from the article in the newsletter.   It was stated that ATL disconnects a toll free number after the second complaint.  ATL can only disconnect numbers under our RespOrg ID and we always ask for the permission of our client first.

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On October 1, 2012, forty-five telecommunications companies signed in support of the petition of SMS/800, Inc. to change the composition of   SMS/800, Inc. (WC Docket No. 12-260 and

CC Docket No. 95-155.)  This was the culmination of almost two years of meetings between the FCC, a cross-industry committee, the current 800/SMS board and the new officers of SMS/800.  Through hours of negotiations, all of these entities agreed on a design for the membership of the new board and the details of the election.  There were indications at that time that the election could be held in January 2013.
Now it appears that the FCC staff has decided that the petition will need a full Commission review and vote instead of the Wireline Competition Bureau (WCB) just issuing an order.  Although this might bring a stronger order that might not succumb to any challenges, in all of the filings there haven’t been any challenges and in fact, representatives from every major carrier filed in support of the filing.

The real result of this decision is that there will be more delays and something that the industry has been working on for two years will be stalled.  I am not saying that this has just died.  We are told that there are meetings being scheduled to brief the Chairman’s legal advisor and then the current SMS/800 board will schedule meetings with each of the Commissioners’ legal advisors to ask them for support of the order and to urge a quick decision; but I guess I am no longer encouraged by those kinds of reports.

Some of us worked very hard through last summer and agreed to let go of some issues near and dear to our hearts in order to come to an agreement with the current SMS/800 board so the election could be held this month.  We went to the FCC as a united Transition Committee and a united industry.  Why isn’t that enough to get the FCC to let us move on instead of being mired in more bureaucracy?

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