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CTIA WANTS MORE FCC GUIDANCE ON LNP, OR IT WILL FILE FOR STAY

CTIA will turn its attention to implementing local number portability (LNP) and will ask the FCC for guidance on how to resolve several technical issues, Pres. Tom Wheeler told reporters Mon. CTIA still is pushing its active court challenge on LNP, but Wheeler said “it’s time to turn our attention from legal issues to operational realities.” However, NARUC said that was just another attempt to stall LNP and that there were no technical limitations to wireless carriers’ implementing LNP.

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Wheeler laid out 9 issues that he said needed to be resolved before wireless carriers could implement LNP by the Nov. 24 FCC deadline. He said if the Commission hadn’t resolved those details by Labor Day, CTIA would attempt to stay the agency’s deadline. A Labor Day deadline would give the FCC more time to resolve the issues than carriers would have to implement the order, he said.

CTIA will file a petition with the FCC today (Tues.) for resolution on the 9 issues, Wheeler said. Several involve how wireless carriers would work with LECs in providing LNP. The primary issue raised by CTIA is how porting between wireless and wireline numbers would occur under the current rate-center system. Since there are more rate centers for wireline service than for wireless, fewer than 13% of wireline-to-wireless ports would be eligible under the FCC and LEC rate center porting rules, Wheeler said. A ruling on rate-center rules is expected from the FCC.

Other issues raised by CTIA included: (1) Wireless-to- wireless porting. Only LEC-to-LEC LNP rules are in place, and Wheeler said the wireless industry needed specific rules. (2) Nationwide roaming. (3) Definition of covered markets. (4) Porting interval. While LECs routinely take 4 days, the wireless industry is looking to be able to port a number in less than 5 hours. (5) 911 callback. Porting from an LEC to wireless could mean several days when PSAPs wouldn’t be able to call subscribers back. (6) Service level agreements for testing. (7) Porting SLAs and interconnection agreements. That would be an arduous state-by-state task, Wheeler said. (8) Virtual NXX.

NARUC responded with charges that CTIA was raising “red herrings” to again try to delay LNP implementation. “This is a Hail Mary pass,” NARUC Gen. Counsel Brad Ramsay said. “It’s a last-ditch effort to get some public support behind a stay request.” Ramsay said the FCC currently was examining the definitions of covered markets and could make a decision before the deadline. He said the Commission also was looking into the rate center issues.

However, NARUC argued that there were no technical or policy problems that would prevent wireless carriers from porting numbers to other wireless carriers or for wireline carriers to port numbers to wireless carriers. (Ramsay did say there were some potential policy problems with porting wireless numbers to wireline, which he said were expected would be unlikely occurrences.) NARUC said wireless-to- wireless porting would involve the bulk of reporting requests. Ramsay said CTIA hadn’t addressed rate center issues in its previous forbearance requests to the FCC.

Several state PUC commissioners said wireless carriers already had begun to roll out LNP. Robert Nelson, of the Mich. PSC, said Cellular One already was charging consumers 97 cents each month for wireless LNP. And Neb. PSC Chmn. Anne Boyle said carriers in Neb. were ready to port carriers. Ramsay said there were no LNP issues in the E-911 rollout.