Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554
In the Matter of )
)
Numbering Resource Optimization ) CC Docket No. 99-200
)
REPLY C0MMENTS OF NENA
The National Emergency Number Association (?NENA?) hereby replies to
certain comments of others in the captioned proceeding. NENA wishes to add its support
and pledge assistance for any FCC-sponsored national workshop regarding rate center
consolidation (?RCC?), as suggested by several commentators. We offer brief remarks on
college/university campus phone systems and the need to maintain speedy access to
emergency services. Also, we expand on comments regarding service-specific area code
overlays and briefly discuss 9-1-1 system upgrade costs arising from number resource
optimization methods, such as RCC.
Acknowledgment of RCC effects on 9-1-1
In NENA's original comments, we listed certain criteria necessary to minimize the
impact of RCC on 9-1-1 and the public's speedy and reliable access to needed emergency
services. We were pleased to see recognition of the issue from both consumer advocates
and service providers. The National Association of State Utility Consumer Advocates
(?NASUCA?) stated that ?if rate center consolidation is performed, it must be done
without jeopardizing the functioning of certain other telecommunications services, such
as E911, and without increases to the consumers' local telephone bill." (Comments, 13) It
also stated that ?there are technological issues with regards to E911 provisioning and the
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network's ability to recognize telephone numbers and properly route calls in a system
with consolidated rate centers." (Comments, 17) SBC, Winstar and Global NAPs were
among the carriers discussing RCC effects on 9-1-1.
Several commenters requested that the FCC sponsor a national workshop
regarding RCC. This idea was supported by a state coordination group representing
utility commission staff of several states, including California, Connecticut, Florida,
Indiana, Maryland, Maine, Michigan, Nebraska, New Hampshire, New York, Oklahoma,
Texas, Utah and Vermont. Winstar said the Commission ?should also hold hearings and
workshops with state public utility commissions and the industry, including public safety
officials and incumbent local exchange carriers." (Comments, 4)
We strongly concur with the suggestions to have an FCC-sponsored national
workshop regarding RCC. We also offer NENA's support to help ensure that 9-1-1,
public safety and emergency services are represented and will be considered.
Criteria for cost-effective RCC
In NENA's original comments (page 2), we listed three criteria, which we felt
were essential to minimize 9-1-1 impacts in RCC:
(1) Upgrading 9-1-1 networks to more current technology across the country,
thereby reducing ANI (automatic number identification) failures and the
resulting default problems;
(2) Upgrading 9-1-1 database systems and the corresponding service provider 9-1-
1 processes so that they are capable of real-time changes ? such as in the
Number Portability Administration Center Service Management System --
rather than batch processing, done once daily or every several hours, resulting
in transactions taking days to complete; and
(3) Keeping RCC within common 9-1-1 default boundaries, which usually are
counties or similar areas.
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We also mentioned that costs were involved. We felt that the FCC should start
realizing and considering these 9-1-1 costs that are created because of number resource
optimization methods. One of the criteria we felt was necessary in an area of RCC was
upgrading the area's 9-1-1 network to SS7. Metrocall, a national paging company,
believes paging phone numbers should not be considered for pooling because ?requiring
competitive message carriers to employ SS7 on their networks would be enormously
expensive.? (Comments, 4) To prevent degradation of 9-1-1 networks and systems in
areas of number portability, number pooling, escalating area codes, and RCC, the
upgrade to SS7 is needed and Metrocall's statement also applies. It is enormously
expensive. The FCC should consider where the payment for these increased costs to
service providers and 9-1-1 systems is going to come from.
Global NAPs (Comments, 6) supported keeping RCC within common default
boundaries: "Global NAPs believes that implementing a mandatory federal program of
rate center consolidation is the only true solution to the numbering resource crisis," and
suggested a geographic radius minimum "of at least 25 miles." NENA recommends that
the geographic minimum should, as much as possible, conform to local 9-1-1 systems,
many of which are approximately within the 25-mile diameter or larger.
Service-specific area code overlays
NENA's original comments stated that if specialized services were unlikely to
create a 9-1-1 call, the impact on 9-1-1 could be minimized. The Ohio Public Utility
Commission?s comments in support of such overlays (pages 5-16) gave examples that
included point of sale terminals, remote ATMs, coin-operated telephones, data-only lines
(even second lines in the home strictly for computer use) and any numbers without public
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telephone number association such as numbers in a hunt group. NENA points out that,
while the listed examples may be used to eliminate the need for local 10-digit dialing as
in regular overlays, virtually all the examples cited would require changes to local 9-1-1
networks and other parts of the systems, just as with any other overlay, since they could
generate 9-1-1 calls.
Campuses and NXX assignments
The Association for Telecommunications Professionals in Higher Education said
in its Summary, arguing for permission to accumulate blocks of sequential numbers, that
"on many campuses, the association between numbers and dormitory rooms allows for
calling locations to be identified in order to facilitate implementation of E911 systems.
As a result, telecommunications administrators on college and university campuses are
able to link a specific abbreviated telephone number (usually four or five digits) with a
specific room or location. This speeds access to emergency services, including fire,
police and medical."
As the FCC considers the various number resource optimization methods, NENA
suggests that there be special provisions to ensure that those campus and other
institutional users of private switch systems providing 9-1-1 address location information
and appropriate routing not be disadvantaged by the chosen optimization methods.
Conclusion
NENA is quite willing to join with state utility commissions, local exchange
carriers and others in FCC-sponsored national workshops on RCC. We trust that the
participation of representatives for 9-1-1, public safety and emergency services will be
encouraged.
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The FCC must begin considering the costs that are impacting 9-1-1 networks,
service providers and systems throughout the country, due to local phone competition and
the need to conserve and optimize number resources. It should actively consider putting
related 9-1-1 network and data change costs, plus other local service provider-related
costs, into a national cost allocation/recovery system such as number portability/pooling.
The impact of each number resource optimization method on 9-1-1 services must be
carefully considered.
Respectfully submitted,
By _____________________________
James R. Hobson
Miller & Van Eaton, PLLC
1155 Connecticut Avenue N.W., Suite 1000
Washington, D.C. 20036
(202) 785-0600
March 5, 2001 ATTORNEY FOR NENA
Rick Jones, ENP
Loves Park 9-1-1
540 Loves Park Drive
Loves Park, IL 61111
office 815-654-5011
fax 815-633-0555
email rockford9@aol.com
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