Direct Access to Numbers Trial Limits, Results & Conclusions Of the Six-Month Technical Trial John Visclosky June 17, 2014 NANC Meeting FCC Headquarters th 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 Numbers In order to obtain numbers, trial participants were required to: 1.Obtain an OCN registered with NANPA 2.File an application with NPAC 3.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, 2013 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, 2013 Vonage requests numbers from NANPA August 7, 2013 Sept. 6, 2013 Trial ends Dec. 17, 2013 WCB reports to Commission on results of trial Jan. 31, 2014 March 3, 2014 June 19, 2013 WilTel/L3 requests numbers from NANPA July 15, 2013 July 27, 2013 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 numbers 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, FL Celebration, 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