Number Porting Fight Reignites as New FCC Time Limit Takes Effect

North American Numbering Council Chairman Tom Koutsky told us the group will likely submit a report to the FCC on porting procedures sometime in October. While the May order gave NANC 90 days to complete the report, the clock did not start until the order went into effect this week, since the order wasn’t published in The Federal Register until the first week in July. “We fully expect to meet that deadline and probably beat it, frankly,” Koutsky said. “The working group is working on having something they can submit to the full NANC in the middle of September, probably.” NANC started discussions on May 14, the day after the order was adopted (CD May 15 p4).

Koutsky said the question of what constitutes a business day is one of several difficult issues that must be worked through. “It is obviously complicated topic that involves a lot of different industry players,” he said. “Just about everybody in the industry has approached this from the stand point of, OK, the FCC has given us a new role, let’s do what we can to get this implemented in the most efficient and effective manner possible, and everybody has taken that approach.”

In comments, AT&T urged the FCC to expand the definition of a simple port. Market changes and technology advances have “have rendered many of the existing exceptions obsolete,” including carveouts for ports involving more than one line, complex switch translations, resellers and unbundled network elements, AT&T said. “When there are fewer exceptions, there will be fewer excuses; when there is clarity, an injured party will be on firmer ground when seeking enforcement.”

T-Mobile urged the FCC to redefine simple ports and adopt a standard interval for complex ports. “In 2000, the NANC defined simple ports as single line ports that do not include, among other things, complex switch translations, such as remote call forwarding or multiple services on the loop, or a reseller,” the carrier said. “This definition no longer matches the technology or carrier systems available today and provides a broad loophole for carriers that have an interest in delaying porting.”

But midsized wireline companies seem hesitant to expand the term’s scope. Qwest urged the FCC not to make any new rules until the NANC finishes new LNP process flows as required by the commission. The FCC should review the finished report and, “if appropriate,” seek comment on its conclusions, it said. “Fundamentally, one-business day porting is not easy for wireline carriers, and accuracy is essential for all porting applications,” said CenturyLink. “Any applications requiring additional steps may necessitate some additional time.”

Competitive local exchange carriers said subjecting more complex ports to the one-day interval could harm consumers and burden CLECs. An expanded definition “could well result in more porting errors, causing more customers to lose dial tone and/or access to 911 for days,” Cbeyond, Integra Telecom and One Communications said in joint comments.

Meanwhile, MetroPCS said the FCC should phase in, over 18 months, a requirement that ports be completed in the same two and one-half hour interval that wireless carriers follow. “MetroPCS urges the Commission not to rest until all simple intermodal telephone number ports occur as quickly as, or more quickly than, the current voluntary wireless industry standard,” MetroPCS said. “Even though a one business day porting interval is considerably better than the current standard, it still deters wireless substitution. If a customer requests a port Friday afternoon, the number will not be available until Tuesday, almost four days later.”

Comcast, Verizon and AT&T said the one-day interval should apply to competitive local exchange carriers and other reseller customers. “Wireline-to-wireline and intermodal ports from resellers already follow the same NANC LNP Provisioning flows as single line ports from interconnected VoIP providers, which are considered simple ports,” Verizon said. UNE ports have become “routine” technically, Comcast said. But XO Communications said involving an unaffiliated reseller “complicates the porting process and frequently requires additional communications between the relevant parties that can slow the porting process.” Ports involving UNE loops require “substantial carrier coordination” and “can often take much longer” than a business day, said Cbeyond, One and Integra.

Debate flared between the biggest companies over the handling of ports involving two to 20 phone lines. Verizon said multiline ports shouldn’t be called simple and the FCC could require a four-business-day interval for them. But AT&T supported applying the one-day limit, saying “nothing in AT&T’s experience would indicate that porting one entire account with up to 20 telephone numbers could not be accomplished within short order.” Comcast agreed, saying it’s important to reduce the interval for multiline ports to a day, so more consumers see the benefits of a shorter limit.

CLECs said multiline ports are anything but simple. “The time involved in processing a port of a multi-line account is much greater than the time involved to port one single-telephone-number account because of the additional validation and processing that must occur for each telephone number,” said XO Communications.

AT&T urged the FCC to adopt an industry-sponsored process for handling number port requests. Verizon said the FCC should require all providers to use the same porting request form and to return customer service records within 24 hours. XO Communications recommended the FCC consult with ATIS’s Ordering & Billing Forum, which is working on a standard set of required data fields for ports.

T-Mobile urged the FCC to mandate a uniform set of administrative criteria for porting “limited to information strictly necessary” for another carrier to complete the port. “This means that even if each ILEC uses a different Local Service Request form, it should only be able to require the porting-in carrier to complete the fields contained on a list of approved administrative criteria,” T-Mobile said. While the FCC order did not ask NANC to make recommendations on standardizing the provisioning process “it is our understanding that the NANC intends to include such recommendations in its report.”

T-Mobile also said the FCC should require immediate disconnection when a subscriber requests a port. “This would help ensure that customers are not double billed and forced to call customer service, which is frustrating for consumers and unnecessarily consumes carrier resources that drive up costs,” the carrier said.

Sprint Nextel agreed with T-Mobile on the need for simplicity in the information required to make a port, but disagreed on when a customer should be disconnected. “Some carriers disconnect a porting customer’s service before the port is complete -- despite industry ‘best practices’ stating that disconnection is not appropriate until the old service provider has ‘evidence that the port has occurred,'” Sprint said. “To protect consumers from having their service discontinued prematurely (including the ability to dial 911 in an emergency), the FCC should rule that old service providers may not disconnect service prior to receiving the … ‘activation’ message, which indicates that the new service provider has already activated service for the porting consumer.” Sprint added the FCC should clarify that previous service providers may not charge new service providers for processing port requests.

The Nebraska Public Service Commission also endorsed calls for a standard data field for ports. “The NPSC believes uniformity is necessary given the wide variations in carriers’ interpretation of existing Commission orders and the amount of detail some carriers still require,” the commission said. “The variation of information required from company to company has led to confusion. The NPSC is also concerned that despite the shortened porting interval for simple ports, some consumers will still face considerable barriers which may prevent them from switching carriers due to the lack of uniformity in fields required for a port and how the validation fields are used.”

CenturyLink said porting forms are already “reasonably standardized,” but the FCC “should focus its attention on preventing the imposition of unreasonable miscellaneous conditions impacting the LNP process.” For example, some carriers require specific documentation to appear in the subject line of a request, typed in all capital letters, it said. “The Commission should strive to discourage LNP conditions that do not fulfill legitimate business needs but instead have a primary effect of unreasonably delaying action on port requests and/or imposing unreasonable additional cost on providers seeking to port numbers on behalf of their customers.”

The FCC should prohibit carriers from delaying or rejecting ports because of pending service orders or certain account features, said Vonage. In cases where a customer disconnects service and then asks for a port in seven days or less, the FCC should require carriers to reactivate the number and complete the port, it added.