[VoiceOps] Update on STIR / SHAKEN

[Mary Lou Carey]

Just wanted to give everyone an update on STIR / SHAKEN since it still 
seems to be so confusing to everyone. I spoke with Brent Struthers from 
ATIS again today because I've been getting a lot of questions about how 
many LATAs  Interconnected VOIP providers have to order NXXs in to 
qualify for a STIR/SHAKEN certificate.

In case you didn't read our previous discussion, the original guidelines 
for getting a STIR / SHAKEN certificate state you need to meet the 
following 3 requirements:

1. Have an OCN assignment for CLEC, ILEC, IPES, Paging, RBOC, or 
Wireless
2. Be assigned a 499 Filer ID and submit 499 filings
3. Direct Access to Numbering Resources through NANPA


In talking with Brent today, I discovered that the FCC doesn't really 
care if you order any NXXs for your company. Brent said what they really 
expect is for every carrier to have an FCC License, Authorization, or 
State Certification. Below is the type of licensing each carrier type 
needs:

- CLEC (State Certification)
- ILEC (State Certification)
- Paging (FCC License)
- RBOC (State Certification)
- Satellite (FCC License)
- Wireless (FCC License)
- VOIP (Interconnected VOIP Numbering Authorization from FCC)

So the bottom line for all you VOIP providers is that EVERY VOIP 
PROVIDER must get an Authorization from the FCC so they can acquire 
their own STIR / SHAKEN certificate. You don't need to order any NXXs to 
get a STIR/SHAKEN certificate! Getting the FCC Authorization is much 
less work than turning up a LATA with your own NXX, so please don't let 
any DID service providers talk you into using their certificate. YOU 
NEED YOUR OWN STIR/SHAKEN certificate!

One last thing regarding Interconnected VOIP Providers because I've also 
had a lot of questions regarding when it becomes beneficial to operate 
as an Interconnected VOIP Provider. First of all, let me explain the 
difference in architecture between the DID service provider and the 
Hosted PSTN Service provider. DID Service Providers allow you to order 
DIDs from anywhere in their service area. They charge per TN based on 
rate center and manage all the routing of the traffic as well as your 
NRUF reporting and number ports. Hosted PSTN service follows the same 
network architecture that the PSTN network does so it's only implemented 
by LATA / ILEC Tandem area. You get a CLLI and NXX for each LATA / ILEC 
tandem area so you can establish an LRN for that LATA. You can port a 
number from any rate center in that LATA / ILEC Tandem area to your LRN 
and you pay based on the type of traffic it is rather than the rate 
center classification. While the Hosted PSTN provider manages the 
routing of the traffic for you, you manage your own NRUF reporting and 
Number Porting. Below are my recommendations on when it becomes 
beneficial to move from a DID service in a particular LATA to a Hosted 
PSTN service in that LATA.

1. You have a lot of TNs in a particular LATA: DID service charges 
anywhere from $0.05 to $0.50 per TN. The monthly recurring charge for a 
1,000 block in each LATA varies by month but currently averages about 
$1.40 per month. You also have to figure in a few other costs, but what 
you pay is determined by the Hosted switch provider you use.

2. You port a lot of TNs in a particular LATA: DID service charges to 
port each TN. NPAC charges based on the number of ports. A port is any 
group of consecutive numbers within an NPA-NXX block. So if you wanted 
to port 100 consecutive numbers, the DID service would charge you for 
100 ports but NPAC would only charge you for 1 port. There are multiple 
options when it comes to the method of porting, so don't let that scare 
you. You can hire someone to do the porting for you or do your own 
through the NPAC LTI service, a hosted app, or a managed service that 
integrates the whole process for you.

3. You have a lot of traffic in a particular LATA and want more control 
over which carrier you route your traffic through: When you use a DID 
service provider, your only option is to use the services of that 
carrier. When you manage your own porting, if there's an issue with 
traffic blocking you can re-route your traffic to the LRN of another 
carrier that you are set up with. When you have your own NXXs they are 
associated with your own OCN so it's easier to move your traffic from 
one carrier's network to another carrier's network should you ever need 
to down the road.

So that's the scoop! Feel free to e-mail me privately if you have more 
questions.

MARY LOU CAREY
BackUP Telecom Consulting
Office: 615-791-9969
Cell: 615-796-1111