Go Slow on Nationwide Number Portability With IP Transition Underway, Industry Tells FCC

Most commenters urged the FCC to move with care on complete nationwide number portability (NPP) rules, and not impose new rules that would require carriers to invest in legacy systems while the transition to IP-based networks is in progress. In October, commissioners approved an NPRM and notice of inquiry on NPP. Commissioner Mike O’Rielly said then that he had concerns about the expense and the FCC should do a cost-benefit analysis before taking any further action.

More efficient porting of numbers, especially between wireline and wireless carriers, has been a focus of the FCC, going back almost 15 years to the wireline-to-wireless local number portability (LNP) order approved in 2003 (see 0311120023). The FCC adopted initial portability requirements in 1996. “We believe that NNP will level the playing field for many rural and regional carriers, who are disadvantaged by the difficulty or outright inability of consumers to port in to their networks,” the FCC said in the October notice.

The NPRM examines a number of technical changes. Among them is eliminating a requirement that the carrier immediately before the one that terminates a call -- the N-1 carrier -- ensures that the number portability database is queried before routing a call. The NPRM also proposes eliminating remaining interexchange dialing parity requirements. The NOI asks more general questions about changes to the rules.

“AT&T supports a transition to NNP, as it would likely lead to a modest increase in competition between service providers,” AT&T said in comments in docket 17-244. “Even AT&T occasionally is unable to port-in a wireless number for a customer that is relocating from a geographic area where AT&T has no presence.” But AT&T questioned imposing NPP on legacy networks “ill-equipped to handle it.” Imposing requirements for the public switched telephone network would “force providers to waste financial resources upgrading legacy technologies that are already at the trailing edge of their life cycles,” AT&T warned. “Until the transition to IP networks that would support NNP is complete, providers can realize the benefits of NNP through commercial agreements without burdensome and expensive steps.”

Verizon said the FCC should wait for the “ubiquitous implementation of IP-enabled networks” before imposing requirements. “In the meantime, service providers should remain free to consider commercial agreements to support nationwide number portability for their customers,” Verizon said. But Verizon also said there are actions the FCC can take now. “Removing regulatory underbrush, as proposed in the NPRM, and updating industry standards and coordination to govern service providers’ call routing arrangements can help service providers begin the longer term transition to nationwide number portability,” the carrier said.

The FCC should wait for recommendations from the North American Numbering Council’s Nationwide Number Portability Issues Working Group before acting on the NOI, CTIA commented. Consumers continue to encounter problems in some cases porting their numbers, especially when they switch from a national to a non-national carrier. But CTIA agreed the IP transition “offers the best opportunity to address the limitations for NNP that currently exist within the legacy telephone system.”

Comcast encouraged the FCC to work with industry and the North American Numbering Council on removing impediments to NPP. A first step would be establishing “a near-term deadline” for NANC to “prepare a list of the technical obstacles and other issues currently impeding NNP,” Comcast said. “Once these barriers to NNP are identified, the Commission should assign to the NANC the responsibility of developing a comprehensive plan for eliminating these impediments.”

The Competitive Carriers Association stressed the importance of NPP in comments. “In today’s mobile ecosystem, many consumers consider their wireless number a part of their identify, and believe they can port this number to any provider at any location,” CCA said. “For this reason, the FCC should further competitive policies like NNP, rather than forcing a consumer to contract with a carrier that fails to best serve its communications needs.” CCA President Steve Berry urged action, in a news release: "While a commercial solution does exist, I encourage the FCC to continue its good work with ATIS and NANC to address any potential required changes to federal and state regulation, industry practices and legacy telephone network technology to achieve longer-term nationwide number portability."

ATIS supported the rule changes in the NPRM in general. “However, it believes that these rule changes, while beneficial, are not sufficient in and of themselves to achieve NNP,” it said.