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 Federal  Communications  Commission  FCC  05-  20 
 CONCURRING  STATEMENT  OF  COMMISSIONER  JONATHAN  S.  ADELSTEIN 


 Re:  Administration  of  the  North  American  Numbering  Plan,  Order,  CC  Docket  No.  99-  200,  FCC  05-  20 
 I  support  this  decision  to  permit  SBC  to  pursue  innovative  network  interconnection  arrangements  through  a  limited  and  conditional  waiver  that  grants  SBC  access  to  numbering  resources  for  their  IP-enabled 
 services.  In  granting  this  relief,  I  note  SBC’s  commitment  to  comply  with  Federal  and  State  numbering  utilization  and  optimization  requirements.  I  am  also  pleased  that  this  Order  includes  a  referral 
 to  the  North  American  Numbering  Council  for  recommendations  on  whether  and  how  the  Commission  should  revise  its  rules  more  comprehensively  in  this  area.  While  I  support  this  conditional  waiver,  these 
 issues  would  be  more  appropriately  addressed  in  the  context  of  the  Commission’s  IP-  Enabled  Services  rulemaking.  Addressing  this  petition  through  the  IP-  Enabled  Services  rulemaking  would  allow  the 
 Commission  to  consider  more  comprehensively  the  number  conservation,  intercarrier  compensation,  universal  service,  and  other  issues  raised  by  commenters  in  this  waiver  proceeding.  It  would  also  help 
 address  commenters’  concerns  that  we  are  setting  IP  policy  on  a  business  plan-  by-  business  plan  basis  rather  than  in  a  more  holistic  fashion. 
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