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					                         North American Numbering Council
                       c/o Columbia Institute for Tele-Information
                               Columbia Business School
                                     1A Uris Hall
                                    3022 Broadway
                              New York, NY 10027-6902

                                   September 8, 2005

Mr. Thomas Navin
Chief, Wireline Competition Bureau
Federal Communications Commission
445 Twelfth Street, S.W.
Washington, D.C. 20554

                       RE: pANI Recommendation for VoIP E911

Dear Mr. Navin:

The purpose of this letter is to advise the Federal Communications Commission of the
solution developed by the telecommunications industry and other stakeholders to satisfy
the Commission’s requirement that VoIP service providers must supply their customers
with enhanced 9-1-1 service by November 28, 2005.

Attached to this letter are two documents:

      A copy of a document entitled “pANI Interim Assignment Guidelines for ESQK”
       (“Interim Guidelines”)

      A letter from NANC’s pANI Issues Management Group (pANI IMG) to me
       explaining how the Interim Assignment Guidelines were developed and the next
       steps that need to be taken (“IMG Letter”).

Both of the documents provide a comprehensive background explanation of the situation.
Copies of both documents were sent to the Commission staff at the time they were sent to
me on September 2.

I wish to draw your attention to the following schedule which is contained in the IMG

         Date                                     Event

 August 26, 2005       pANI IMG recommendation to the NANC and FCC that
                       the Pooling Administrator serve as the Interim RNA (IRNA).
                       Appointment of the Pooling Administrator to serve as the
 September 6, 2005     IRNA by the FCC.
                        Start of 30 day interval from IRNA appointment to operational
 September 6, 2005      start date to commence ESQK assignments to VoIP
                        NANC approval of and recommendation to the FCC that the
 September 6, 2005      “pANI Interim Assignment Guidelines for ESQKs” be adopted
                        as quickly as possible.
                        NENA will provide the notification to PSAPs of IRNA and
 September 7, 2005      pANI Interim Assignment Guidelines for ESQKs as soon as
                        they have been approved by the FCC.
 September 16,2005      ESIF due date for NPA-211 use survey results to be sent to
                        the pAIN IMG, NANC and the IRNA.

 October 3, 2005        Date that ESQK assignments by the IRNA must begin in
                        order to accommodate PSAP and VoIP provider testing and
                        turn-up requirements to meet November 28th deadline.
 November 28, 2005      VoIP implementation due date for E9-1-1.

I also wish to draw your attention to this statement in the IMG Letter:

       All parties involved in the pANI IMG including the Subject Matter Experts
       (SMEs) agree that an immediate NANC and FCC approval of the Guidelines
       may allow enough time for the VoIP Service Providers (VSPs) and Public Service
       Answering Points (PSAPs) to meet the VoIP E9-1-1 due date of November 28,
       2005. (emphasis supplied)

Please consider this letter to be NANC’s approval of the Guidelines. Because of the
support for the Interim Guidelines already expressed by a number of NANC Members
and because there has been no objection to them, I am confident that NANC will formally
approve the Interim Guidelines at its regularly scheduled meeting on September 20.
Therefore, in view of the urgency of this matter, the FCC, the industry and other
stakeholders should proceed now as if the NANC had formally adopted the Interim

I therefore urge the Commission promptly to take whatever procedural actions are
deemed to be necessary so that these Interim Guidelines may take effect.

Please feel free to contact me if you or members of your staff have any questions.



Robert C. Atkinson
NANC Chair

cc:   Narda Jones, FCC
      Cheryl Callahan, FCC
      Regina Brown, FCC
      Marilyn Jones, FCC
      Sanford Williams, FCC
      NANC Members

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