The

1
The Safety Valve processDelaying Customer
Service

• A discussion of the Safety Valve Process and the
  need for change.
• Mike Whaley
• Qwest
• NANC - November 4, 2004

2
Meeting the Customers Need for Numbers

• New technology can drive customer demand for
  telephone numbers upward
• Large businesses continue to need blocks of
  sequential numbers.
• New opportunities like VoIP require numbering
  resources.
• The industry is growing and expanding in new ways.

3
Meeting Customers Need for Numbers

• Rules must evolve in support of the consumers
• Speed of getting service to the customer is a
  must in a competitive environment.
• Carriers follow regulations when obtaining
  numbers.
• The Safety Valve regulation needs to be reviewed
  and changed for the customers.
• Safety Valve delays can be avoided.

4
The Safety Valve

• The FCC has established a safety valve
  mechanism to allow carriers to obtain numbering
  resources when they do not otherwise qualify.
• The FCC delegated authority to state commissions
  to hear and resolve waivers filed under the
  safety valve process.
• From the FCCsThird Report and Order and
  Second Order on Reconsideration in CC Docket No.
  96-98 and CC Docket No. 99-200

5
The Safety Valve

• The FCC recognized that failure to address a
  request for additional numbering resources can
  impair a carriers ability to expand or for
  customers to meet business needs.
• The FCC advised the states that a ten business
  day interval from receipt of a detailed and
  complete safety valve waiver request is
  sufficient time to review and act upon the
  request.
• From the FCCsThird Report and Order and
  Second Order on Reconsideration in CC Docket No.
  96-98 and CC Docket No. 99-200

6
When is the Safety Valve is Used

• The Safety Valve is used when
• Carriers cannot satisfy the demand from within
  their existing inventory.
• Large major customers need entire sequential
  blocks of numbers to grow.
• NANPA and the Pooling Administrator reject
  requests when months to exhaust or utilization
  levels are not met.
• Only after rejection can waiver be filed.

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What needs to be changed?

• The safety valve waiver process requires carriers
  obtain waivers from state commissions for
  customer specific requests.
• Safety Valve waivers may not have the highest
  priority with state regulators.
• Delays prevent carriers from providing numbering
  resources in a timely manner to the customer.
• By giving authority to the NANPA or PA to approve
  customer specific requests will permit carriers
  to meet todays market demands.

8
A Minimal Rule Change Needed

• Rule change is needed because
• Carriers are already required to provide
  documentation from the customer with the current
  proof of utilization to obtain waivers from state
  regulators.
• The current documentation is sufficient.
• Waivers are not for vanity numbers, but for
  contiguous blocks of numbers.

9
A Minimal Rule Change Needed

• For Customer Specific Request Waivers
• The safety valve regulatory review process varies
  from state to state.
• The process creates an unnecessary amount of
  regulatory involvement resulting in delays in
  getting customers their service.
• The eminent exhaust of the NANP was delayed due
  to the NRO orders.

10
Why Change the Rule?

• Waivers delay meeting customer needs
• Qwests experience shows the interval for these
  requests has varied from as little as 5 days to
  as many as 313 days with over 70 waivers filed,
  averaging 35 days each.
• Only 9 request were processed in 10 days or less,
  less than 13 of the time .
• Every waiver for a customer specific request was
  approved.

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Why Change the Rule?

• To satisfy customer specific requests
• Our experience demonstrates the Safety Valve
  Process for customer specific requests needs to
  be revisited.
• Very important in light of the rapidly growing
  demands for numbers and for applications such as
  VoIP.
• Process should be consistent across all states.

12
An Easy Rule Change

• In most cases, the waiver request provides the
  same information as the application and the
  process used for an NXX or a 1K block.
• By providing one additional piece of information
  the customer specific request to the NANPA or
  the Pooling Administrator, valuable time will be
  saved.
• Every waiver filed by Qwest for customer specific
  requests has been approved.

13
A Simple Solution

• Give NANPA and the PA authority to grant customer
  specific requests.
• The customer letter should satisfy the FCCs
  requirement of the customers need.
• It can be handled in the 10 day processing cycle
  for NANPA and the PA.
• Reduces rejections by the NANPA and PA.
• Eliminates delays in serving customers.
• Saves Regulators time and the regulators have
  approved all of the waiver requests.

14
The Change Improves Customer Service

• By changing the Safety Valve process to speed up
  customer specific requests
• Means that existing customers needs can be met.
• Permits more rapid deployment of new services
  that customers demand today.
• Maintains the integrity of the NRO orders.
• Reduces regulatory delay.