BEFORE THE UNITED STATES FEDERAL TRADE COMMISSION PAY PER CALL RULE REVIEW FTC File No. R611016 FINAL SUPPLEMENTAL COMMENTS These final post-workshop comments are filed pursuant to a Notice of Proposed Rulemaking published October 30, 1998 (F. Reg. Vol 63, No. 210, pp. 58524-58568) with regard to proposed amendments to 16 C.F.R. 308. This is a final amendment based upon experience gained at the FTC Workshop, review of FCC and Industry NPA guidelines, and a holding of the record open until 6/4/99. FINAL SUPPLEMENTAL COMMENTS Refining comments we made during the Workshop, the FTC and the FCC should coordinate the assignment of geographic area code (NPA) overlays specifically for use by Pay-per-Call, Caller-Paid, and/or Premium services. The area codes could be:
This single elegant numbering administration action by FTC (Part 308) and FCC (Part 52), implemented by the North American Numbering Plan Administrator (NANPA), should provide simple minimum consumer notice that such area codes beginning with 99x involve an international premium call, caller-paid access beyond transport, and/or other premium rate(s). These area codes for these purposes should be required for any transport dialing pattern or carrier access method (i.e. 101xCIC-1-NPA-NXX-xxxx). Each NPA provides over 7 Million line numbers, and assignments could include other caller paid and/or premium billing methods such as Caller Paid Cellular / PCS, measured or flat rate Internet access (ISP), caller-paid pager, and other LEC billed premium services. Billing-specific code assignments are technology neutral. June 3, 1999 Richard C. Bartel |