RURAL TELCOS FIGHT FCC NUMBER PORTABILITY EXPANSION
FCC heard 2 clear messages when it asked whether it should expand local number portability (LNP) and related 1,000-block number pooling requirements for rural telcos. In comments filed May 6, rural telcos and unlikely ally Western Wireless argued that it would be cost prohibitive to make them offer LNP if no competitors even asked for it. On other side were state regulators and competitors such as WorldCom that reminded FCC that LNP and pooling were needed to accomplish 2 important goals -- conserving telephone numbers and encouraging competition -- and the more carriers offering them the better.
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FCC in 1997 ruled that: (1) Carriers in top 100 Metropolitan Statistical Areas (MSAs) had to provide LNP but rural carriers were exempted, even if they had switches in top 100 Metropolitan Statistical Areas (MSAs), unless there was request for it. (2) Carriers weren’t required to offer 1,000-block number pooling unless they were LNP capable. Number pooling is dependent on LNP technology. FCC in Dec. reversed that policy and mandated that all carriers in top 100 MSAs provide LNP and participate in pooling, whether or not they had gotten LNP requests. In March, FCC reconsidered that new mandate and asked for comments on issue.
Many rural telcos have switches inside larger MSAs so FCC ruling would require many of them to upgrade. “The financial and administrative burden would be substantial,” National Telecom Coop Assn. said: “Many rural exchanges are very small and quite rural, even though they technically fall within the 100 largest MSAs.” National Exchange Carrier Assn. (NECA), filing jointly with OPASTCO and National Rural Telecom Assn., said requiring rural carriers to implement LNP and pooling “would not benefit either competition or number resource optimization and would serve no purpose other than to require rural carriers to expend funds needlessly.” Groups said recent NECA study showed 291 rural study areas were either entirely or partly within top 100 MSAs and only 4 had received requests requiring implementation of LNP. “The Commission should continue to allow the pace of competitive entry into local markets to determine the need for LNP implementation,” 3 organizations said. USTA said it didn’t make sense to require mandatory LNP deployment “where there is no material demand for it and deployment would constitute an unnecessary expense.”
Western Wireless, rural wireless competitor often at odds with rural LECs, said changes would “expand the scope of the LNP obligation beyond what is necessary to ensure the competitive benefits of LNP.” Western Wireless and others also expressed concern about expanding list of MSAs that trigger LNP requirement. FCC is considering adding what are known as “combined MSAs” (CMSAs), combinations of 2 smaller MSAs. NECA said their inclusion would increase number of rural study areas eligible for LNP to 303 from 291. TDS Telecom said it would cost $8 million for it to replace switches and make upgrades to achieve LNP and pooling capability for areas that were inside top 100 MSAs. “The costs and time pressures are especially unwarranted where no competitors are seeking portability at all, let alone seeking deployment on… schedule” set by FCC’s proposal, TDS Telecom said.
WorldCom argued on other side that “LNP should not be viewed as some optional feature of the public switched telephone network.” Instead, it’s “a step in the evolution of that network from one designed to accommodate the monopoly provision of local exchange service to an interconnected network of competitive networks.” WorldCom said “the Commission’s goal should be the widest possible deployment of LNP.”
PUC of Ohio recommended mandatory LNP and pooling with caveat that state regulators could grant waivers to small ILECs based on costs. Ia. Utility Board said all carriers in top 100 MSAs should be LNP-capable “in order to promote full and effective competition and to be competitively neutral.” Mich. PSC expressed strong concerns about number depletion and need for pooling, which is dependent upon LNP capability: “The development of national policy that excludes specific classes of carriers from participation in conservation measures is without merit.” Mich. PSC contended LNP shouldn’t be limited only to top 100 MSAs because “advances in telecommunications technology should not be restricted to metropolitan areas.” FCC proposal also gained support of National Assn. of State Utility Consumer Advocates, which said “the use of pooling should be as expansive as possible, both in terms of the number of participants and the areas where it is being used, so as to slow the proliferation of area codes.”