WASHINGTON-The North American Numbering Plan Billing and Collection Inc. has officially asked the Federal Communications Commission to justify bills for work done by an independent contractor.
“To the best of NBANC’s knowledge, no public notice or order discussing the standards for retention of a consultant has been provided by the [FCC]. As no such information has been provided to NBANC or to the public, NBANC is unable to answer questions regarding why carrier-contributed funds are used to supplement FCC staff activities that appear to be more properly characterized as commission activities (i.e. a request for proposal design) rather than [North American Numbering Plan] administration. … As the use of outside consultants appears to be preferred by FCC staff to address specific numbering issues, NBANC foresees that the FCC may consider more arrangements of this type in the future. … NBANC asks [the FCC] to provide explicit guidance as to what constitutes appropriate activities for NBANC to bill and collect monies from all U.S. carriers,” said NBANC in a document filed Friday at the FCC.
The FCC is using consulting agency Mitre Corp. to assist it with number pooling issues. To date, Mitre has received about $403,000 for consulting on who should administer the nation’s telephone numbers. The agency signed a contract with Mitre on Sept. 15, according to a letter signed by Yog R. Varma, deputy bureau chief of the FCC’s Common Carrier Bureau. The FCC believes it was able to contract with Mitre because of a rule that allows federal agencies to contract for services when there is an urgent need. “Running out of numbers is an urgent need,” said Michael Balmoris, spokesman for the FCC’s Common Carrier Bureau.
Until recently, money collected by NBANC was paid exclusively to NeuStar Inc. as the North American Numbering Plan Administrator, but the FCC changed the rules in December to allow payments to be made to other entities. Mark Oakey of the FCC’s Office of the Managing Director, which signed the contract with Mitre, said the FCC’s Office of General Counsel authorized NBANC to make payments to Mitre using number-pooling administration funds.
Telecom carriers pay money to NBANC using a formula based on their revenues. NBANC collects money from carriers to pay for numbering administration activities. In the document filed on Friday, NBANC requested the FCC allow it to collect $14.7 million for these activities.
Since the NANP also allocates telephone numbers for Canada and countries in the Caribbean, these countries also pay fees to NBANC. NBANC proposes that Canada pay nearly $139,211 and the total Caribbean nations pay about $27,409. This leaves a balance of $9.8 million to be paid by the U.S. telecommunications industry, or $00.000043 per subscriber. The United States pays more than Canada and the Caribbean nations in part because the U.S. requires certain number audits and is preparing for number pooling.
Number pooling allows telephone numbers to be assigned in 1,000 blocks rather than the 10,000-block basis established when North America created area codes in 1947. There are 10,000 numbers in each exchange-denoted by the first three numbers of a seven-digit telephone number. Old wireline technology required that a new exchange be assigned for each rate center.
When competition came to the wireline industry-not to mention the proliferation of second lines, fax machines and wireless devices-numbers started running out since wireline competitors were required to get an entire 10,000-number block for each rate center they wanted to serve. When new competitors didn’t sign up customers at the rate they thought they would, this often meant that several thousand numbers in some blocks were left unused.
The FCC has said it hopes to implement nationwide number pooling as soon as a contract can be awarded to handle the technical difficulties associated with the task. The FCC put out a request for proposals, designed by Mitre, for a nationwide number-pooling administrator in December and expects to make a decision by this summer.
In the meantime, NBANC is collecting funds to pay the administrator, but some have questioned whether an FCC consultant should be paid out of these funds. The NBANC board of directors last month decided to specifically mention the controversy in its contribution factor request. NBANC files this document in early May each year.
Typically this document is put out for public comment and then the FCC releases an official order approving the amount.
If the FCC approves NBANC’s request, NBANC will bill carriers in late June with payments due July 12. Carriers with bills totaling more than $1,200 may opt to pay in monthly installment payments.
