P-ANI Administration Guidelines

ATIS-0300089

P-ANI Administration Guidelines

September 30, 2011

(The Guidelines will take effect March 19, 2012, when the permanent Routing Number Administrator (RNA) function is implemented.)

Copyright  2011 by the Alliance for Telecommunications Industry Solutions, Inc.

All rights reserved.

The P-ANI Administration Guidelines dated September 30, 2011 is copyrighted, published and distributed by ATIS on behalf of the Industry Numbering Committee (INC). Except as expressly permitted, no part of this publication may be reproduced or distributed in any form, including electronic media or otherwise, without the prior express written permission of ATIS.

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The Industry Numbering Committee (INC) provides an open forum to address and resolve industry-wide issues associated with planning, administration, allocation, assignment and use of North American Numbering Plan (NANP) numbering resources within the NANP area.

This document is maintained under the direction of ATIS and the INC. Suggestions for improvement of this document are welcome. They should be sent to the Alliance for Telecommunications Industry Solutions, INC Staff, 1200 G Street NW, Suite 500, Washington, DC20005. All changes to this document shall be made through the INC issue resolution process and adopted by the INC as set forth in the ATIS Operating Procedures.

The INC wishes to acknowledge the cooperation of the ATIS Emergency Services Interconnection Forum (ATIS ESIF) in the development of these Guidelines.

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The information provided in this document is directed solely to professionals who have the appropriate degree of experience to understand and interpret its contents in accordance with generally accepted engineering or other professional standards and applicable regulations. No recommendation as to products or vendors is made or should be implied.

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NOTE - The user’s attention is called to the possibility that compliance with this standard may require use of an invention covered by patent rights. By publication of this standard, no position is taken with respect to whether use of an invention covered by patent rights will be required, and if any such use is required no position is taken regarding the validity of this claim or any patent rights in connection therewith.

TABLE OF CONTENTS

1.0 Purpose and Scope

2.0 Assumptions and Constraints

3.0P-ANI Assignment Principles

4.0Eligible User Responsibilities

5.0 RNAResponsibilities

6.0 Forecast and Annual Reporting Requirements

7.0 Assignment of p-ANIs

8.0Reclamation and Return of p-ANIs

9.0 Conflict Resolution and Appeals Process

10.0 Maintenance of These Guidelines

11.0 Glossary

12.0 Reference

P-ANI FORMS

Attachment 1: Part 1 P-ANI Application Form (ATIS – 0300089.at1)

Attachment 2: Part 3 RNA Response/Confirmation Form (ATIS – 0300089.at2)

Appendix 1: P-ANI Forecast Report (ATIS – 0300089.ap1)

Appendix 2: P-ANI Annual Report (ATIS – 0300089.ap2)

1.0 Purpose and Scope

This document specifies guidelines for the administration and assignment of non-dialable pseudo Automatic Number Identification (p-ANI) numbers[1]to Eligible Users in areas where access to such numbering resources has been ordered or implemented. P-ANIs are typically used for call routing and location display of callers that subscribe to a service that is either mobile, nomadic, or that involves a user telephone number containing an NPA that is foreign to the serving E9-1-1 selective routing system.

All p-ANI requests and necessary forms will be submitted by p-ANI Applicants to the Routing Number Administrator (RNA)[2] by filling out the appropriate request and/or form provided on the RNA Web Site ( No requests and/or form submissions will be accepted via fax, paper, voice, or e-mail, except if previously agreed to by the RNA. An industry database (see Section 5.1) will verify the password and access level of the user. All electronic submissions from an authorized user will be considered as an electronic signature and will be verified for authenticity utilizing criteria maintained in the RNA System. In addition, these guidelines outline the processes used between the RNA and:

• P-ANI Applicants
• Eligible Users
• P-ANI Assignees

• Governmental Agencies

P-ANI number resources, in the context of these guidelines, allows for the assignment of p-ANI numbers from the pool which consists of both NPA-211-XXXX and NPA-511-XXXX. When the 211/511 resources exhaust (See Section 5.7) within an NPA, the INC will make another NXX available to the RNA to use to replenish the p-ANI inventory. When the next available NXX is opened for the first time, the INC will determine the next non-dialable resource[4]to be utilized for p-ANI purposes.

These guidelines apply to the assignment of p-ANI numbers within geographic numbering plan areas (NPAs) under the jurisdiction of the Federal Communications Commission (FCC). These guidelines do not preclude any future effort to address non-geographic NPAs, but it is recognized that some toll-free NPA-N11-XXXX numbers are assigned to subscribers and therefore cannot be used as p-ANIs.

P-ANIs are assigned for use in a selective routing system for which the Eligible User has approval from the 9-1-1 governing authority to route E9-1-1 traffic for termination to a Public Safety Answering Point (PSAP). While the ultimate delivery of any call to a PSAP must be based upon the geographic location of the caller, by necessity the association of the geographical location of the caller’s telephone number and the p-ANI is typically made using the Selective Routing Data Base (SRDB).

In instituting these guidelines, all entities formerly assigning p-ANI resources will discontinue such practices and transition administration and control of formerly assigned non-dialable p-ANIs to the RNA in accordance with schedules and deadlines mutually set between the affected entities and the RNA.

These guidelines do not supersede appropriate North American Numbering Plan (NANP) area governmental or regulatory principles, procedures, and requirements. For interpretation of these guidelines, see Section 9.0.

2.0 Assumptions and Constraints

The development of these non-dialable p-ANI administration guidelines is based on the following assumptions and constraints:

2.1P-ANI resources covered in these guidelines are collectively managed by the telecommunications industry with oversight by the appropriate governmental agency in areas served by the NANP.

2.2The RNA will obtain the necessary Eligible User documentation to establish and administer the p-ANI resources.

2.3The p-ANI resources are considered a public resource and are not owned by the p-ANI Assignees or the RNA. Consequently, the resources cannot be sold, brokered, bartered, or leased by the p-ANI Assignee for a fee or other consideration. If a resource is sold, brokered, bartered, or leased for a fee, the resource is subject to reclamation (See Section 8.0).

2.4These guidelines apply only to the assignment of p-ANI resources to Eligible Users for use in 9-1-1 selective routing systems and/or for E9-1-1 display purposes.

2.5P-ANI resources shall be assigned to facilitate the most effective and efficient use of a finite numbering resource in order to prevent premature exhaust of p-ANI resources.

2.6Each individual NPA is considered a separate pool of p-ANI numbers even in cases where an NPA overlay situation exists because of technical limitations (e.g. many selective routers can only support a maximum of four NPAs).

2.7A p-ANI Applicant requesting resources from the p-ANI inventory:

a)shall provide, as part of its application for p-ANIs, evidence demonstrating that the p-ANI Applicant is an Eligible User of p-ANI resources. An Eligible User is defined as an entity that:

1)Demonstrates that it is permitted under applicable law to access p-ANI resources in the area for which the p-ANI resources are sought;

• Awireless service provider applicant shall provide the RNA a copy of its FCC license, showing that it is authorized to provide service in the area in which it is seeking resources.
• An interconnected VoIP service provider applicant shall provide the RNA copies of pages 2 and 36 of its FCC Form 477,showing that it is authorized to provide service in the area in which it is seeking resources.
• Any entity that requires p-ANIs to comply with any state or federal order andthat has been certified as a CLEC by a state shall provide the RNA a copy of its state certification showing that it is authorized to provide service in the area in which it is seeking resources.[5]

2)Has received approval from the 9-1-1 governing authority to route E9-1-1 traffic for termination to a Public Safety Answering Point (PSAP)[6];

3)Has been assigned a valid Operating Company Number (OCN)[7];

4)Has been assigned a valid NENA Company Identifier (ID) 1 by the National Emergency Number Association (NENA)[8]; and

5)Self-certifies that it will provide the technical and functional capability to route traffic or provide routing instructions to enable emergency call delivery to a PSAP.

b)shall establish internal policies and practices that provide for the efficient use and assignment of p-ANIs.

2.8The schedule of holidays recognized by the RNA will affect the administration of these guidelines. Holidays posted on the RNA website will not be considered a “business day” as a part of any timing of p-ANI allocation(s) in association with these guidelines.

2.9P-ANI Assignees and the RNA are responsible for managing p-ANI resources in accordance with these guidelines and the orders of the appropriate governmental agency. Both p-ANI Assignees and the RNA are subject to audits.

2.10Audits of the RNA and p-ANI Assignees may be performed by the appropriate bureau(s) within the FCC or other appropriate governmental agency, or other designated agents to:

a)ensure uniformity in application of these guidelines by the RNA to all p-ANI requests received by the RNA;

b)ensure compliance with these guidelines by p-ANI Assignees and the RNA; and

c)ensure the efficient and effective use of p-ANIs by p-ANI Assignees and efficient and effective management of p-ANI resources by the RNA.

3.0P-ANI Assignment Principles

The following assignment principles apply to all aspects of these guidelines:

3.1The RNA will assign individual p-ANIs or p-ANI ranges from the establishedp-ANI inventory. P-ANIs will be available for assignment from both the 211 central office code (or “NXX”) and 511 NXX initially. For purposes of this provision, a p-ANI is “not available for assignment,” if it is classified as:

a)Aging

b)Assigned

as defined in the Glossary.

3.2P-ANIs are assigned uniquely to individual Eligible Users in contiguous ranges (where possible).However, the RNA cannot guarantee that all p-ANIs will be assigned in contiguous ranges.

3.3P-ANI resources in the p-ANI inventory shall be available and allocated to Eligible Users in a fair and non-discriminatory manner (i.e., on a first come, first served basis).

3.4Information that is submitted by p-ANI Applicants in support of a p-ANI assignment shall be kept to a minimum, be uniform for all applicants, and be treated as proprietary and adequately safeguarded by the RNA, pursuant to FCC confidentiality rules.[9]

3.5P-ANIs are assigned for use by a selective routing system for which the Eligible User has approval to route E9-1-1 traffic for termination to a PSAP.

3.6NPA-211-XXXX and NPA-511-XXXX formats will be used for p-ANI assignment. The NPA of the p-ANI shall coincide with an NPA valid for the serving selective routing system. P-ANIs shall be considered non-dialable in the Public Switched Telephone Network (PSTN).

3.7Any Eligible User that is denied the assignment of one or more p-ANIs under these guidelines has the right to appeal that decision, per Section 9.0.

3.8The RNA shall accept and fulfill requests for specific p-ANIs if they are currently available for assignment from the p-ANI inventory, subject to the criteria identified in Section 7.0.

3.9P-ANI Assignees may not trade p-ANIs between themselves.

3.10P-ANIs may be transferred between Eligible Users, via the RNA,if the p-ANI is In Use and one or more of the following conditions are met:

a)merger or acquisition;

b)both entities involved mutually agree to the transfer of the p-ANI and coordinate through the RNA (see Section 7.4);

c)authorization or directive received from the appropriate governmental agency.

3.11A p-ANI returned in error to the RNA is retrievable by the p-ANI Assignee, provided the p-ANI is Aging. This is accomplished via e-mail between the p-ANI Assignee and the RNA in order to establish an audit trail.

4.0Eligible User Responsibilities

Eligible Users have several responsibilities in a p-ANI environment. These responsibilities vary depending on whether the Eligible User is a p-ANI Applicant or a p-ANI Assignee. These responsibilities are outlined below:

4.1P-ANI Applicant Responsibilities

A p-ANI Applicant is responsible for obtaining a current copy of the P-ANI Administration Guidelines[10]. A p-ANI Applicant requesting resources from the p-ANI inventory shall:

a)meet the definition of an Eligible User as defined in Section 2.7 a;

b)complete the Part 1 P-ANI Application Form (Attachment 1) per these guidelines;

c)have a current P-ANI Forecast Report (Appendix 1) on file with the RNA . A p-ANI Applicant making its first request in an NPA shall provide a P-ANI Forecast Report (Appendix 1) of p-ANI resource needs to the RNA prior to submitting the p-ANI request for the requested NPA;

d)provide a detailed explanation that documents the p-ANI Applicant’s need for said specific quantity of p-ANIs in the comments field on the Part 1 P-ANI Application Form (Attachment 1) when making a request in excess of any applicable ESIF Formula[11] or in excess of 50 p-ANIs if no formula applies. If the p-ANI applicant is requesting additional p-ANIs in a PSAP where it has existing p-ANI resources, then the applicant shall include those resources and the quantity that is being requested when determining if the request exceeds the applicable ESIF Formula or exceeds 50 p-ANIs when no formula applies. and

e)have a current P-ANI Annual Report (Appendix 2) on file with the RNA unless it is the p-ANI Applicant’s first request for any p-ANI resources.

P-ANI Applicants disputing the RNA’s decision to deny a request for p-ANI resources may appeal the RNA’s decision in accordance with Section 9.0.

All documentation submitted to the RNA will be held confidential, pursuant to FCC confidentiality rules.[12]

4.2P-ANI Assignee Responsibilities

A p-ANI Assignee shall:

a)notify the RNA via the Part 1 P-ANI Application Form (Attachment 1) of any changes made to p-ANIs retained from previous p-ANI Administrators or assigned by the RNA. For example, such a change may occur due to mergers or acquisitions or other scenarios;

b)arrange for the entry of any information to the appropriate Automatic Location Identification (ALI) databases, selective routing system databases (SRDB) and/or other databases or systems, due to receipt of a new p-ANI;

c)remove records from the applicable ALI databases, SRDBs, and/or other databases or systems for p-ANIs returned to the RNA;

d)abide by the p-ANI Assignment and Reclamation procedures outlined in Sections 7.0 and 8.0;

e)provide annual utilization data at the p-ANI level via the P-ANI Annual Report (Appendix 2) to the RNA for input in the p-ANI relief planning process (see Section 5.7);

f)maintain sufficient and auditable data to demonstrate compliance with these guidelines; and

g)return p-ANI resources not In Use to the RNA.

Information that is submitted by p-ANI Applicants in support of a p-ANI assignment shall be kept to a minimum, be uniform for all applicants, and be treated as proprietary and adequately safeguarded by the RNA, pursuant to FCC confidentiality rules.[13]

4.3RNA System Registrant Responsibilities

Each p-ANI Applicant is responsible for registering with the RNA in order to obtain access to the RNA System. The RNA has up to five business days to assign a password and notify the registrant. Each approved registrant will have a unique password for accessing the RNA System. For further information, see [

Information that is submitted by p-ANI Applicants in support of a p-ANI assignment shall be kept to a minimum, be uniform for all applicants, and be treated as proprietary and adequately safeguarded by the RNA, pursuant to FCC confidentiality rules.[14]

5.0 RNA Responsibilities

The following describes the high level responsibilities of the RNA in:

• General Administration Duties
• Forecasting and Planning Processes
• Assignment Processes
• Reporting Processes
• Reclamation Processes
• Audits
• P-ANI Relief Planning

Information that is submitted by p-ANI Applicants in support of a p-ANI assignment shall be kept to a minimum, be uniform for all applicants, and be treated as proprietary and adequately safeguarded by the RNA, pursuant to FCC confidentiality rules.[15]