On Sept. 28, 2017, the Federal Communications Commission released a Notice of Proposed Rulemaking (NPRM) that seeks to permit the assignment of toll free numbers via alternative market-based approaches, including the auctioning of numbers. Furthermore, consistent with such a market-based approach, the Commission proposed the development of a secondary market allowing subscribers to reassign their toll free numbers to other subscribers for a negotiated fee. Finally, the Commission adopted proposals to modernize toll free number administration, including the revision or elimination of the current prohibitions on brokering, warehousing, and hoarding of toll free numbers.
I'd like to understand one thing: why does anyone bother with toll- free numbers any more? Don't most people have national calling plans at this point? (Especially poor people, who are as likely to have prepaid cellular as landlines these days.)
Would there be any effect on toll-free number hoarding if there was a fee of, say, $1 / month per number "owned", whether there is any service connected with that number or not? Yes, that means you and me as well as the hoarders, but the hoarders have a LOT more numbers, and I suspect this would upset their business plan.
Most people do not have *UNLIMITED* national plans, and it's really easy to burn up a few months worth of your minutes on hold with one attempt to resolve an issue with, say, an insurance company, which may involve lots of calls and many hours on hold. (I do know of one person who spent several days including an entire weekend on hold trying to contact a mortgage company to get some mess straightened out before April 15, and that call didn't resolve anything - she didn't even get through to a bot.
Your marginal cost can be a lot higher than your average cost for minutes. It gets even worse if going 1 minute over requires you to buy another $20 in minutes, even if that includes a lot of minutes for that $20. If you are usually close to your limit, go over it occasionally, and can't forecast exactly how much you're going to need for the rest of the month for talking to friends, co-workers, and family, you may be a bit reluctant to a business where you might be spending a lot of time on hold.
When Obamacare's health marketplace first started in 2014, I signed up, then spent the whole year trying to find a doctor in my network. After a few hundred calls to doctors on the insurance company's list, all of whom denied being in the network, and lots of time on hold with the insurance company and online with their web site, I never succeeded in finding an in-network doctor. I don't really believe there was one - that was a big waste of money that year for both unusable health insurance and overages on minutes.
A dollar or two a number for the limited supply of 8xx numbers would be a good approach. I have already drafted a formal Comment to that effect, for the docket which is open until Nov. 13, and perhaps others would like to submit similar Comments.
If you're talking about mobile minutes, then 800 doesn't help -- those are "airtime" minutes, not "toll" minutes, so an 800 call is still billed to your own minute quota.
The real value of 800 numbers now is as a nongeographic national number that can be intelligently routed within the carrier's network. The bulk of numbers, however, are used by "typosquatters" who are picking up calls to numbers near a real 800 user's number. At a price of free, they gobble up the bulk of the 8xx space and will gobble up whatever other space is created, unless something is done to discourage it. Like a small contribution to the universal service fund.
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