New York, NY US - Replication is the option for 800 toll-free users to "grandfather" their toll-free numbers into new toll-free exchanges as they open - 888, 877 as announced yesterday by The Alliance for Telecommunications Industry Solutions (ATIS)1- and so on.
Referred to as "right of first refusal," replication was formally introduced on the scene by the FCC in its October 1995 Toll-Free Notice of Proposed Rulemaking. Deluged with concerns by large and small users about trademarks and brands, misdial costs, and lost business, the FCC finally put replication - recognition of user commercial and proprietary interest considerations - on the table.2
The FCC also opened a brief window for users to "set-aside" the 888 equivalents of their 800 numbers, pending a decision to the Rulemaking.3 No decision has yet been made. But now Congress is eyeing that "set-aside" pool of valuable vanities with its' pockets wide open - and in fact, 888 numbers are in the 1998 budget for auction.4
The industry plans to recommend "no replication" for 877 to the FCC5, and the April 1st ATIS press release announcing 877 contains no reference to replication, or early reservation, at all.5
Finally, internal industry documents note that there is no need for early reservation since there will be no pent-up demand for 877 in April '98, as there ostensibly was when 888 was introduced in March '96.
So now we're to believe that replication, and the business and consumer concerns that drive it, have disappeared. I suppose we're to believe that MCI doesn't want 877 COLLECT, AT&T, 877 COMPARE and 1-800 FLOWERS, 877 FLOWERS.
Well, think again. Those same internal industry documents that note no need for early reservation, reference plans to accommodate both early reservation, and replication.
While industry mouthpiece ATIS advises the public of an April '98 877 release date, carriers are planning to make sure their important clients - and their own interests in their vanities, of course - are well taken care of.
The Replication Have's - and the Replication Have-Nots
Savvy RespOrg's (Responsible Organizations, subscribers' agents into the toll-free database), will probably begin taking reservations for 877 numbers as early as February '98, possibly sooner. Exactly when, and for whom - big customer, average customer - matching 800 holder or competitor - or perhaps even themselves! - will in all likelihood be at their own discretion.
Not too reassuring, is it.
Approximately 3,000 888's have gone from "unavailable" -- set-aside pending the FCC's replication decision, or Congressional auction -- to SPARE, meaning available for use. Most can be presumed to reside in the matching 800 subscribers' accounts.
As these 888 releases and the original set-asides illustrate, a good working relationship with a savvy RespOrg makes all the difference between the replication have's -- and the replication have-nots.
Carriers have a regulatory obligation to neither discriminate nor show preference in the delivery of services. As RespOrgs they have a contractual agency obligation to serve your interests.
Unfortunately, the first pays lip service to regulatory wishful thinking; the second is a blatant conflict of interest. Real-world illustrations of either are hard to find.
If you want replication, you'll have to take matters into your own hands.
Start contacting your RespOrgs now. Work beyond the account execs to get to someone who knows - and can perform for you. If no one will, shop around for another RespOrg. Find one who's knowledgeable, has the necessary contacts, and is willing to treat you as a preferred customer.
Persist, insist, and demand equal treatment with the big subscribers and marketers.
Remember, your toll-free numbers are portable. Take them where they'll be nourished, and protected. And where your business will be respected.
Then, micro-manage your RespOrg relationships and accounts, to ensure you continue to be in good hands.
Reference these articles found at ICB Toll Free News. 1 - 04/01/97 - INDUSTRY BEGINS PLANNING FOR 877 2 - 10/10/95 - User Rights Goes on FCC Agenda 3 - 03/17/96 - FCC Takes Unprecedented Action, Bypasses Resp Orgs to Service Subscribers 4 - 03/17/97 - 888 Auction - It's Back! 5 - 02/10/97 - Out of Sight, Out of Mind
Author/Correspondent's Profile: Judith Oppenheimer, Publisher, ICB Toll Free (800/888) News