For anyone who felt our proposal for Toll Free Registration, critique on agency, and assertion that we already have an open market for toll free numbers came out of left field, this document should provide some much needed perspective.
Written almost 15 years ago, this FCC submission contains the original thinking that led to our call for Toll Free Registration. Nothing has changed. Highlight then in 1997, as today, we have a distinct need for:
- One set of rule prior to assignment (Public Resource a la 95-155)
- Another set of rules subsequent to assignment (Toll Free Agency)
- The right to explicitly lock in and "literally" bank on toll free numbers (Toll Free Registration)
This was a document I hadn't read for years, but as I recalled the frustration expressed by Gregg Hamerschlag at the Toll Free Summit in his inability to arrange bank financing for his ventures, I rushed to send him a copy with the section on banking highlighted. Toll Free Registration is essential, not ownership.
I've always believed that toll free numbers needn't be one way or the other -- a public resource or private property in an open market. They can be and should be both, depending on who's in control of the subscription at the time. We live this world. We understand it. All that's missing is our belief.
We must lift the cloud that hangs over toll free ownership and control with registration and educate the "industry" to of essence of agency.