The “Safety Valve” process”

Delaying Customer Service

A discussion of the Safety Valve Process and the need for change.

Mike WhaleyQwest

NANC - November 4, 2004

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Meeting the Customer’s 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.

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Meeting Customer’s 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.

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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 FCC’sThird Report and Order and Second Order on Reconsideration in CC Docket No. 96-98 and CC Docket No. 99-200

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The Safety Valve

• The FCC recognized that failure to address a request for additional numbering resources can impair a carrier’s 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 FCC’sThird Report and Order and Second Order on

Reconsideration in CC Docket No. 96-98 and CC Docket No. 99-200

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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 today’s market demands.

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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.

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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 customer’s their service.

• The eminent exhaust of the NANP was delayed due to the NRO orders.

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Why Change the Rule?

• Waivers delay meeting customer needs• Qwest’s 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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• 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.

Why Change the Rule?

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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.

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A Simple Solution

• Give NANPA and the PA authority to grant customer specific requests.• The customer letter should satisfy the FCC’s

requirement of the customer’s 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 Regulator’s time and the regulators have

approved all of the waiver requests.

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The Change Improves Customer Service

• By changing the Safety Valve process to speed up customer specific requests:• Means that existing customer’s 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.