Pay-Per-Call Rulemaking: Post Workshop Supplemental Comments, FTC File No. R611016 #1b

Submission Number:
1b
Commenter:
Richard C. Bartel
Organization:
Communications Venture Services
State:
MD
Initiative Name:
Pay-Per-Call Rulemaking: Post Workshop Supplemental Comments, FTC File No. R611016

BEFORE THE UNITED STATES FEDERAL TRADE COMMISSION

PAY PER CALL RULE REVIEW

FTC File No. R611016

FINAL SUPPLEMENTAL COMMENTS
BY COMMUNICATIONS VENTURE SERVICES, INC.
AND RICHARD C. BARTEL

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:

  • a geographic intra-NANP International area code (NPA) overlay of 990 , or
  • Geographic area codes (NPAs) 900, and geographic overlays from 990 through 998, such as:
    • 900 Pay-per-Call (no International routing, domestic IP)
    • 990 USA Pay-per-Call (International routing or IP)
    • 991 Canada Pay-per-Call (International Routing or IP)
    • 992 Caribbean Pay-Per-Call (International Routing or IP)
    • 993 Pay-Per-Call outside USA, Canada, Caribbean, Pay-Per-Call (International)
    • 994-995 Reserved for expansion (International Premium)
    • Reserved for expansion (such as other Caller-Paid Services)
  • And for either option:
    • 999 or 989 Billing Inquiries dialed 1-989-NPA-NXXx or 1-999-NPA-NXXx.

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
President, & Individually
5530 Wisconsin Ave., #703/5
P.O. Box 70805
Chevy Chase, MD. 20813
(202) 728-3841