New N.Y. Law Targets Hidden Net LD Tolls

From owner-nanog@merit.edu Fri Aug 19 14:26:54 2005
From: "Stephen Sprunk" <stephen@sprunk.org>
To: "Robert Bonomi" <bonomi@mail.r-bonomi.com>
Cc: "North American Noise and Off-topic Gripes" <nanog@merit.edu>
Subject: Re: New N.Y. Law Targets Hidden Net LD Tolls
Date: Fri, 19 Aug 2005 14:20:59 -0500

Thus spake "Robert Bonomi" <bonomi@mail.r-bonomi.com>
[ attribution to me missing ]
>> That's why some states (e.g. Texas) require that all toll calls be
>> dialed as 1+ _regardless of area code_, and local calls cannot be
>> dialed as 1+. If you dial a number wrong, you get a message telling
>> you how to do it properly (and why).
>
> In some places that "solution" is _not_practical_. As in where the same
> three digit sequence is in use as a C.O. 'prefix', *and* as an areacode.
> (an where, in some 'perverse' situations, the foreign area-code is a
> 'non-toll' call, yet the bare prefix within the areacode is a toll call.

We don't have that problem because all nearby area codes are reserved as
prefixes. For instance, if 214 and 817 are nearby, there exist no 214-817
or 817-214 numbers (or 214-214 or 817-817). Duh?

All well and good.

*UNTIL* you get assigned an NXX NPA that is _already_ in use as a prefix.
  773, 847, and 630 were _all_ in use as prefixes within the 312 area-code
  (and in the split-off 708 areacode as well) before those sequences were
  "legal" as an area-code.

"Now What?" applies. <wry grin>

That isn't even necessary, though; if 214-817 existed, there's no way of
confusing it with 817-xxx because all calls are either 10D or 11D.

Maybe in *your* territory. :slight_smile:

In 312/708/630/847/773/224, dialing patterns are 7D or 11D ( 847/224 is
11D only)

                                                                    Such a
tactic is only needed during the transition from 7D to 10D local dialing,
which happened here a decade ago.

Lots of places have *NOT* made that transition. It is fairly _expensive_ for
the telcos to implement.

For the same reason, we no longer have an excuse for not using 0XX, 1XX, and
X11 as prefixes.

"Speak for yourself, John" applies. _Mandatory_ 10D dialing does *not* exist
(yet) in *many* areas

Mandatory 10D dialing does have non-trivial costs associated with it -- both
to the telco, and to the customers thereof.

There _is_ a significant performance issue -- and directly related increased
costs -- in supporting mixed 7D and 10D dialing.

To use 1+ for "toll alerting", in locales where intra-NPA can be toll, and
inter-NPA can be local, you have to incur one of those sets of increased
expenses. And the 'inconveniences' to the customer.

It is a trade-off as to which is 'worse' for the customer. <wry grin>
Different utility commissions have decided that issue in different ways.

                  We're already using [2-7]00 prefixes, but I'm not
surprised we don't yet (AFAICT) have 800 and 900 prefixes. We could
probably drop an entire area code if they started assigning those "reserved"
prefixes.

1-800-800, at least, has been in use for a number of years.
and I'm pretty sure I've seen 1-800-900 numbers.

> It also becomes 'utterly meaningless', when _all_ calls incur a usage
> ("message units" or something similar) charge.

Our PUC would be thrown out on their heads if they suggested that was even
an option; I'd suggest you look a little closer at your own and possibly do
some lobbying.

You need a more cosmopolitian view -- This scheme has been in effect for
20 years, locally. *NO* chance of getting it reversed. In other major
metro areas something very similar has been in effect for much longer.
Most big-city systems have charged on such a basis for a long time now.,

here's a fairly big one: uunet public tech support 1-800-900-0241.

Not really. Billable status of a call is known up front in today's
all-digital NANPA coverage area (to my knowledge, the last mechanical and/or
electromechanical switch disappeared before 2002, and it was somewhere in
rural Quebec). In fact, I ran into a telco recently in a 10D/1+10D dialing
area that -- only if the customer subscribed to the unlimited domestic LD
plan -- allowed dialing any US number without the leading 1 as simply 10D.

Conversely, some jurisdictions are very strict about use of the leading 1 to
indicate toll status thanks to localized court cases establishing that
"hidden" tolls are a Bad Thing.

> To use 1+ for "toll alerting", in locales where intra-NPA can be toll, and
> inter-NPA can be local, you have to incur one of those sets of increased
> expenses. And the 'inconveniences' to the customer.

Not really. Billable status of a call is known up front in today's
all-digital NANPA coverage area [...]

I had another (private, but informative) follow-up I wrote to send you, but
since you're posting from an address not accepting mail from non-whitelisted
senders, you've now wasted my time.

(IMNSHO, you don't belong on public lists if you aren't willing to accept
responses. We all appreciate e-mail cowards who want to speak but avoid
listening.)