1. The Safety Valve process Delaying Customer Service A discussion of the Safety Valve Process and the need for change. Mike Whaley Qwest NANC - November 4, 2004

2. 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. 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. 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. 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. 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.

7. 7 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. 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. 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. 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.

11. 11 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?

12. 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. 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. 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.