Direct Access to Numbers Trial Limits, Results & Conclusions Of the Six-Month Technical Trial

Direct Access to Numbers Trial

Limits, Results & ConclusionsOf the Six-Month Technical Trial

John ViscloskyJune 17, 2014NANC Meeting

FCC Headquarters445 12th St. SW

Washington, DC 20536

Direct Access Trial Established

April 18, 2013: Commission releases Direct Access NPRM, Order, and NOI, establishing a 6-month technical trial to allow interconnected VoIP providers direct access to telephone numbers

Trial intended to test whether direct access would raise issues relating to number exhaust, number porting, VoIP interconnection, or intercarrier compensation

Trial Parameters

Participants in the trial were required to:•Submit a numbering proposal to WCB and each relevant state commission: (1) certifying participant would comply with the terms and conditions of the waiver, (2) identifying the rate centers or LATAs in which participant was seeking numbers, and (3) describing the phase-in process to implement the trial•File monthly reports with the FCC throughout the duration of the trial•Comply with the Commission’s number utilization and optimization requirements and maintain at least 65% number utilization across its telephone number inventory

Trial Parameters (cont’d)

• Comply with industry guidelines and practices, including abiding by the numbering authority delegated to state commissions and filing NRUF reports

• Provide the relevant state commission(s) with regulatory and numbering contacts

• Consolidate and report all numbers under its own unique OCN

• Provide customers with the ability to access all abbreviated dialing codes (N11 numbers) in use in a state

• Maintain the original rate center designation of all numbers in its inventory

Trial Participants

• Vonage• SmartEdgeNet, LLC• WilTel Communications,

LLC/Level 3• IntelePeer, Inc.• Millicorp

Steps to Obtain NumbersIn order to obtain numbers, trial participants were required to:1.Obtain an OCN registered with NANPA2.File an application with NPAC3.Apply for a CO code and a Location Routing Number (LRN)4.Insert rates and routes into the Business Integrated Routing and Rating Database System (BIRRDS) to make them available to carriers in the Local Exchange Routing Guide (LERG)5.Conduct a testing phase once LRNs became effective

Direct Access NPRM, Order & NOI released

April

18,

2013

Eligible VoIP providers must submit to WCB and state commissions numbering proposals within 30 days of release of Direct Access Order

May

20,

20

13

WCB approves proposals of Vonage, SmartEdgeNet (SEN), WilTel/Level 3 (WilTel/L3), IntelePeer, and Millicorp and allows them to participate in a limited direct access to numbers trial

June

17,

20

13

Vonage requests numbers from NANPA

Augu

st 7

,

2013 Se

pt. 6

, 20

13

Trial ends

Dec

. 17,

2013

WCB reports to Commission on results of trial

Jan.

31,

201

4M

arch

3,

2014Ju

ne 1

9,

2013

WilTel/L3 requests numbers from NANPA

July

15,

201

3Ju

ly 2

7, 2

013

SEN requests numbers from NANPA

Public comments due on WCB report to Commission 30 days after report is placed in the record

Direct Access Trial Timeline

Millicorp requests numbers from NANPA

IntelePeer requests numbers from NANPA

Amount of Numbers Used in Trial

VonageSEN

Millicorp

IntelePeer

WilTel/Level 3

30k numbers

1k numbers

3k n

umbe

rs

3k

num

bers

Total numbers: 97k

Numbers and LATA Locations

Vonage•1k numbers in Phoenix, AZ•1k numbers in Atlanta, GA•1k numbers in Boston, MA

SmartEdgeNet•1k numbers in Dallas, TX•1k numbers in Key West, FL•1k numbers in Celebration, FL

IntelePeer•1k numbers in Los Angeles, CA

WilTel/Level 3•10k numbers in Boston, MA•10k numbers in Los Angeles, CA•10k numbers in Rochester, NY•10k numbers in Charlotte, NC•10k numbers in Dallas, TX•10k numbers in Denver, CO

Millicorp•10k numbers in Savannah, GA•10k numbers in Fort Myers, FL•10k numbers in Boca Raton, FL

Map of Trial Areas

Los Angeles, CA

Denver, CO

Phoenix, AZ

Dallas, TX

Rochester, NY

Boston, MA

Charlotte, NC

Savannah, GA

Atlanta, GA

Key West, FL

Fort Myers, FL

Boca Raton, FLCelebration, FL

Legend

Vonage

WilTel/L3

SEN

Millicorp

WilTel/L3 & Vonage

WilTel/L3 & SEN

WilTel/L3 & IntelePeer

Limits on Trial

Following completion of the trial, participants may not obtain direct access to additional numbers unless and until the FCC changes the applicable rules.

While trial participants are not required to return the numbers received during the trial, the FCC reserves the right to order the return of these numbers.

Participants may continue to assign numbers to end-user customers that the participant obtained during the trial. However, they MAY NOT port-in a number for a new customer, they must use a CLEC partner when porting in a new number.

Participants must port-out directly-held numbers upon request.

Trial Results

Vonage•Placed numbers into service in Atlanta and Boston

•Placed 1,072 new numbers into service

•116,948 port-in requests

•821 port-out requests for directly held numbers

•Completed bulk ports without problem

•100% of port-ins and port-outs successful

•No routing failures or billing or compensation disputes

Level 3•Placed numbers into service in Boston, Los Angeles, Charlotte, Dallas, and Rochester

•Placed 2,821 new numbers into service

•22,669 port-in requests

•21 port-out requests for directly held numbers

•100% of port-ins and port-outs successful

•No routing failures or billing or compensation disputes

Trial Results (cont’d)Millicorp•Placed 40 numbers into service in Savannah, GA as of Jan. 15, 2014

•Completed “voice testing” in Boca Raton, FL

•Reports no problems, issues, or billing or compensation disputes

SmartEdgeNet•Began voice testing phase

•IXC interstate traffic has completed to its network without issue

•Local and toll calls are completing from incumbent lines tested in Key West, FL and Dallas, TX

•One number assigned for LRN and one for testing in Key West and Celebration, FL

•One number assigned for LRN and 11 for use in Dallas, TX

IntelePeer•Has begun operational testing with internal telephone numbers to assess call routing, but has not started provisioning new customers or transitioning existing customer numbers to the IntelePeer OCN

Trial Issues

• Interconnection Issue• Limited Scope of Trial• VoIP Interconnection• Facilities Readiness

Conclusions

It is technically feasible for interconnected VoIP providers to obtain telephone numbers directly from the numbering administrators

No routing failures or billing or compensation disputes reported during the Trial

The Trial did not identify any technical problems regarding number porting or VoIP interconnection

To the extent that porting and interconnection disputes arose, WCB believes that additional clarity and guidance can be given in pending rulemakings that address those topics