The FCC will impose a Temporary Daily Cap on 855 numbers
On August 2nd I wrote a letter to the FCC explaining that without a limit on the number of 855 numbers each organization could take during the 855 release, the disparity between regular phone companies and the aggressive vanity number resporgs who play by different rules, have developed increasingly high speed capacity would cause increased hoarding and irreparable harm to the public.
Just because a couple resporgs have developed the capacity to suck up over 10,000 toll free numbers per minute doesn’t mean they should be allowed to. I initially proposed that each resporg administrator should have a daily limit of 1,000 numbers per day for the month of October. Upon lengthy reflection I think the limitation should be 500 per resporg administrator, for the first day and then 1000 per day for just 1 week. Faster resporgs will get their numbers first, but this will allow regular phone companies to get an equal number of requests in per day. It will also reduce dramatically the strain on the SMS800 database.
FCC Looks for Comments on 855 Allocation
On Friday August 27th, the FCC sought public comments on the 855 Toll Free Code Opening Allocation. They only allowed 1 week for the comments and received 65 comments. I included my original August 2nd letter to the FCC and sent this the customers who requested 855 numbers from us. Over 60 of our customers made comments that were included although I think there were a couple times that many people trying to submit comments from the emails I received. Not being familiar with the FCC comment system, I didn’t explain how to do it properly. At the end of the week I also sent an update.
It’s not that easy to find the comments if you’re not familiar with the FCC public notice system, so I’ve linked to all of the comments below to make it easier for everyone. Perhaps the most interesting one is the letter from the DSMI (Database Services Management, Inc.) which says that, “more and more companies using automated tools to target ‘desirable’ numbers more quickly and efficiently. In such an environment, DSMI believes it would be useful to have in place an 855 number reservation allocation scheme that would help not only protect the SMS/800 system itself, but would also be useful in assuring a fair and equitable allocation of 855 reservations.” The letter goes on to explain that they already have an allocation system in place which can be activated within two weeks.
This isn’t going to make the vanity number resporgs that were planning to grab up tens of thousands of the best 855 numbers happy, but it makes sense both for the end customers and the system itself. With the preponderance of comments and the DSMI recommending it too, it seems clear that the FCC will likely impose a temporary cap on the number of 855 numbers. There’s another week to post reply comments until September 10th. Here’s a link to post comments:
http://fjallfoss.fcc.gov/ecfs/upload/begin?procName=&filedFrom=X
I also think this validates our approach of sending the 855 requests to the customers regular phone company too. Someone else commented in this that I’m certainly working very hard for my $8. I have worked hard on this for sure, but I think it’s important because the little customer is the one that would get screwed if the vanity number brokers, were allowed to take as many of the best 855 numbers as they wanted up front. This isn’t going to just help little customers, but all real toll free customers and the industry as a whole.



Bill Quimby (678 comments.) says:
September 4, 2010 at 5:48 pm
There were a lot of other letters that didn’t show up here. I’ll list a few of them here:
http://www.tollfreenumbers.com/855-release/kim-kyung.pdf