NANC Report to FCC Cites Hurdles to Nationwide Number Portability
Nationwide number portability raises several challenges and concerns, including about duplicative costs if carried out before the IP transition is complete, but it shouldn't affect phone number exhaustion, the North American Numbering Council said in a report Monday to the FCC. NANC recommended the commission do a more detailed public inquiry on the potential costs of nationwide number portability (NNP) and associated cost recovery; the impact on tolls, tariffs and taxes; potential negative fallout for state regulators; possible uniform 10-digit dialing; and potential federal rule changes. The report was approved without dissent among NANC's voting members.
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There's not much evidence of an NNP need, but demand is starting to emerge "as people move around -- more so on the wireless side," said Betty Ann Kane, chair of NANC and the Public Service Commission of the District of Columbia. NNP would allow users to carry their 10-digit phone numbers with them when relocating to different areas of the country (existing local number portability allows consumers to keep their numbers when changing carriers locally). Kane lauded NANC's working groups for quickly developing the report and recommendations.
NANC was responding to a request from FCC Wireline Bureau Chief Matt DelNero, who asked the group in November to study and make recommendations on regulatory and consumer issues that could arise if wireless telephone numbers are allowed to be associated with any location routing number. "We ... are carefully reviewing its recommendations on the important subject of number portability for wireless consumers nationwide," an FCC spokeswoman said Tuesday.
The Competitive Carriers Association and CTIA asked for the NANC report in a September letter to FCC Chairman Tom Wheeler that noted technical obstacles preventing consumers from porting their phone numbers to wireless providers, particularly smaller carriers, lacking facilities in the phone number's original geographic market (see 1509250058). "CTIA supports number portability as a cornerstone of wireless competition," Scott Bergmann, vice president-regulatory affairs, said in an email Tuesday. "We greatly appreciate the effort of the FCC's numbering experts in the North American Numbering Council to consider the feasibility of non-geographic number portability." CCA had no comment.
NANC said it couldn't quantify potential costs absent a technical solution, but did say "NNP would likely require changes to all existing industry databases and systems which support the routing of individual telephone calls, as well as every telecommunications carrier’s specific network facility architecture which ensures the proper routing and delivery of a call." That would likely force industry to incur "significant costs" and seek price increases from consumers, supported by regulators, the report said. "Deploying NNP prior to the completion of the IP Transition could result in unnecessary and duplicative costs, thus its timing should coincide with implementation of the all-IP network," NANC said. It backed a more detailed FCC public inquiry on NNP costs and cost recovery, one of several such recommendations.
The group warned of "potential adverse impacts" on the assessment of telecom fees that rely on the physical address of the service location: "For example: mandated 911 service, state universal service, and telecommunications relay service fees for all segments, except for wireless and interconnected VoIP services." Allowing "a wireline or wireless service customer to port their telephone number to another rate center, LATA [local access and transport area] or state, will likely preclude the original assessing jurisdiction for such fees to retain such assessment jurisdiction based on the original physical location of the service even though the telephone number’s area code and exchange code appear to be tied to the original service location," the report said.
NANC said there could be negative ramifications for state regulators, including in their public-safety role overseeing emergency communications "(i.e. 911/NG911)." It also urged additional public comments on whether a uniform national 10-digit dialing plan would be needed, along with related actions by state public utility commissions, to implement NNP. Various changes to federal rules and "industry process documentation would also be required," the report said.
NNP is unlikely to affect the life of the North American Numbering Plan (NANP) or affect the FCC's Numbering Resource Utilization and Forecasting Form (Form 502), said NANC, which recommended no related actions. It did say if a new technical routing solution is developed that requires service providers to create additional local routing numbers, the life of the NANP could be affected. Local routing numbers will be needed for some time until an alternative scheme is devised, it said.