The attached is the version of the KYUP FNPRM approved by the FCC. The version posted below is the Circulation Draft. Some differences-it's six pages longer than the circulation version-but I stopped trying to find them.
FWIW, I noticed a few things we discussed earlier today and during the numbering policies NPRM that are in the KYUP FNPRM. 1) It asks about defining facilities-based, in the context of only facilities based providers can originate calls, while non-facilities based providers initiate calls, but do not originate (put on to the public network) "Commission "define[d] a voice service provider as 'non-facilities-based' if it offers voice service to end-users solely using connections that are not sold by the provider or its affiliates."215 In other words, for example, a provider that owns a switch that it uses to provide voice service but does not own the fiber wire that connects the switch to the end user would be a non-facilities-based provider under that definition." 2) Use of NANP numbers is referenced but mainly in the context of STIR SHAKEN exemptions. 3) Re: attestation compliance: "Likewise, should a Telephone Number Service Provider (TNSP) that assigns numbers to a non-facilities-based provider be held responsible when the non-facilities-based provider further assigns those numbers to an initiating provider that fails to properly follow the attestation requirements?" 4) "We also seek comment on whether and how providers may determine whether a provider has been subject to numbering restrictions by the North American Numbering Plan Administrator (NANPA)." 5) Could a numbering database proposed to track chain of TN custody also be used to verify customers' association with TNs? 6) RMD certifications and re-certifications.
Thanks,
Beth
Beth O'Donnell / Corporate Executive Director / Regulatory Affairs / Law Department
Comcast Corporation / 1 Comcast Center / 35th Floor / Philadelphia, PA 19103 / 215-356-2199 mobile
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