Direct Access to

1
Direct Access to Numbers Trial Limits, Results
Conclusions Of the Six-Month Technical Trial
John Visclosky June 17, 2014 NANC Meeting FCC
Headquarters 445 12th St. SW Washington, DC 20536
2
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

3
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 Commissions number utilization
  and optimization requirements and maintain at
  least 65 number utilization across its telephone
  number inventory

4
Trial Parameters (contd)

• 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

5
Trial Participants

• Vonage
• SmartEdgeNet, LLC
• WilTel Communications, LLC/Level 3
• IntelePeer, Inc.
• Millicorp

6
Steps to Obtain Numbers

• In order to obtain numbers, trial participants
  were required to
• Obtain an OCN registered with NANPA
• File an application with NPAC
• Apply for a CO code and a Location Routing Number
  (LRN)
• 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)
• Conduct a testing phase once LRNs became effective

7
Direct Access Trial Timeline
Eligible VoIP providers must submit to WCB and
state commissions numbering proposals within 30
days of release of Direct Access Order
IntelePeer requests numbers from NANPA
Vonage requests numbers from NANPA
SEN requests numbers from NANPA
WCB reports to Commission on results of trial
WilTel/L3 requests numbers from NANPA
Millicorp requests numbers from NANPA
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
Direct Access NPRM, Order NOI released
Public comments due on WCB report to Commission
30 days after report is placed in the record
Trial ends
July 15, 2013
July 27, 2013
April 18, 2013
Sept. 6, 2013
Jan. 31, 2014
June 19, 2013
June 17, 2013
Dec. 17, 2013
May 20, 2013
August 7, 2013
March 3, 2014
8
Amount of Numbers Used in Trial
Vonage
SEN
Millicorp
3k numbers
3k numbers
30k numbers
1k numbers
IntelePeer
WilTel/Level 3
Total numbers 97k
9
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

10
Map of Trial Areas
Boston, MA
Rochester, NY
Denver, CO
Charlotte, NC
Los Angeles, CA
Atlanta, GA
Phoenix, AZ
Dallas, TX
Savannah, GA
Celebration, FL
Boca Raton, FL
Fort Myers, FL
Legend
Vonage WilTel/L3 SEN Millicorp WilTel/L3
Vonage WilTel/L3 SEN WilTel/L3 IntelePeer
Key West, FL
11
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.

12
Trial Results

• 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

• 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

13
Trial Results (contd)

• 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

14
Trial Issues

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

15
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