Three ILEC trade groups told Sen. McCain (R-Ariz.) it would be a ...

the agency hadn’t resolved in that area. “The only real deadline for WLNP implementation should be the point in time at which the Commission effectively addresses the foregoing implementation issues,” the groups said. USTA, the Independent Telephone & Telecommunications Alliance and the Western Alliance said in a July 22 letter to McCain that they had “grave concerns” about the lack of FCC guidance. Keeping to the current deadline with those issues unanswered “would invite chaos into what should otherwise be an orderly implementation process,” the groups said. Unresolved issues they cited included: (1) Enhanced 911 calls, which they said wouldn’t be transmitted to a public safety answering point with the requisite valid call-back number “without additional Commission action.” (2) Inadvertent toll charges. The groups said that as numbers were ported between wireless and wireline networks, it would become harder for consumers to determine whether the call they were placing was local or toll. They said the FCC hadn’t taken steps to minimize that potential source of consumer confusion. (3) The FCC hadn’t created a standardized intercarrier communication process or a porting interval to resolve the technical and operating issues that stemmed from wireless and wireline LNP. The groups said the wireless industry had worked on protocols for porting numbers between wireless operators, but said wireline-wireless porting still had several unresolved issues, including the implications for rate centers, communications protocols, porting intervals and dispute resolution. “To date, the Commission has not resolved these issues,” they said. “Practically speaking, it has left itself little choice in the matter if it is to keep to its pending November 24 deadline since any real intermodal communication protocols would likely take longer to develop and would require active Commission oversight.”