September 2, 2005

Mr. Robert C. Atkinson
NANC Chairman

On July 29, 2005 the NANC received a request from the Chair of the ATIS Emergency Services Interconnection Forum (ESIF) requesting rapid NANC review of the proposal to establish a temporary Routing Number Authority (RNA) for pseudo Automatic Number Identification (pANI) codes used for routing emergency calls. The NANC then commissioned an Issues Management Group (IMG) to review the issues raised and prepare a recommendation.

The pANI IMG presented to NANC on August 26th its recommendation regarding an interim Routing Number Authority Administrator that designated the Pooling Administrator as the entity who should perform this role until the pANI IMG can present its permanent recommendation. In addition the IMG stated that it would present the NANC with the interim administrators pANI Interim Assignment Guidelines for ESQK’s on September 2nd.

Due to the urgent need to have the interim administrator designated and the pANI Interim Assignment Guidelines adopted, the pANI IMG requests that the NANC endorse the IMG’s recommendation and forward it to the FCC at its earliest opportunity. As you can see from the implementation timeline below there are several critical events that will impact VoIP 9-1-1 implementation by the November 28, 2005 deadline if the process to designate an Interim RNA does not occur soon.

Date / Event
August 26, 2005 / pANI IMG recommendation to the NANC and FCC that thePooling Administrator serve as the Interim RNA (IRNA).
September 6, 2005 / Appointment of thePooling Administrator to serve as the IRNA by the FCC.
September 6, 2005 / Start of 30 day interval from IRNA appointment to operational start date to commence ESQK assignments to VoIP providers.
September 6, 2005 / NANC approval of and recommendation to the FCC that the “pANI Interim Assignment Guidelines for ESQKs” beadopted as quickly as possible.
September 7, 2005 / NENA will provide the notification to PSAPs of IRNA and pANI Interim Assignment Guidelines for ESQKs as soon as they have been approved by the FCC.
September 16,2005 / ESIF due date for NPA-211 use survey results to be sent to the pAIN IMG, NANC and the IRNA.
October 3, 2005 / Date that ESQK assignments by the IRNA must begin in order to accommodate PSAP and VoIP provider testing and turn-up requirements to meet November 28th deadline.
November 28, 2005 / VoIP implementation due datefor E9-1-1.

All parties involved in the pANI IMG including the Subject Matter Experts (SMEs) agree that an immediate NANC and FCC approval of the Guidelines may allow enough time forthe VoIP Service Providers (VSPs) and Public Service Answering Points (PSAPs) to meet the VoIP E9-1-1 due date of November 28, 2005.

The work time spent on just the conference calls by the pANI IMG totals 226 hours. This time does not include work outside the conference calls or the work by a SME sub team to combine guideline contributions into one document. Members of the pANI IMG are listed on the following page.

Sincerely,

Hoke Knox Karen Mulberry

pANI IMG Co-ChairpANI IMG Co-Chair

cc: Regina Brown, NANC DFO

Marilyn Jones, NANC Asst. DFO

Members pANI IMG

NAME / ORGANIZATION
Atkinson, Robert C. / NANC Chair
Balch, Mike / Iowa UB
Barry, Tim / ATT
Bishop, Barry / NeuStar
Brown, Regina / FCC
Del Sesto, Ron / Vonage
Emard, Jean Paul / ATIS
Fargano, Mike / Qwest
Gray, Don / NE PSC
Guerra, George / SBC
Hicks, Tom / Intrado
Hultquist, Hank / SBC
Hunter, Dena / Level 3
Jackson, Courtney / OUR
Jefferson, John C. / SBC
Jones, Marilyn / FCC
Jones, Rick / NENA
Jordan, Debra / BellSouth
Kerrington, Jennifer
Knox, Hoke / Sprint
Lancaster, Mark J, / AT&T
Mamakos, Louis / Vonage
Manning, John / NANPA
McCallum, Fred / BellSouth
McGarry, Tom / NeuStar
McHugh, John / OPASTCO
Morgenstern, Dale C / AT&T
Mulberry, Karen / MCI
Napolitano, Maureen / Verizon
Newman, Julie / Cingular
O’Donnell, Beth / Cox
Propst, Jim / Sprint
Putnam, Amy / NeuStar
Pyott, Charles / ATIS
Sevigny, Shannon. / NeuStar
Shaughnessy, Bill / BellSouth
Shepard, Jim / HBF Group, Inc.
Smith, Dana / Verizon Wireless
Struthers, Brent / NeuStar
Sullivan, Douglas.P. / Verizon
Tiffany, Sue / Sprint
Whaley, Mike / Qwest

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