Billing Q&A with Jim O'Neill

Q-I understand that when a market has local competition it is possible for the CLEC to port one of the incumbent telephone company's numbers to its service. How does this work? What happens to that number when the ported number is subsequently disconnected at the CLEC?

A-That is a really good question. As number portability is still not universal in North America (and barely underway in many other countries), I will give you a little background on the whole process.

In 1996 the FCC formalized the requirements for number portability as a result of the Telecommunications Act of that year. Basically there were three objectives:

o To promote local service competition

o To allow customers (whether business or residential) to change their local telephone service provider and keep their number

o To introduce number portability without degrading telephone service.

As you can imagine, this required all telephone companies, not just new competitors, to upgrade their networks. Prior to Local Number Portability (LNP), the network knew what switch a number resided in by looking at the NPA-NNX. Once a single number was ported to another switch, however, a new location tracking method was required. That led to new switch designators, new systems for reporting on ported numbers and huge regional databases that house the location of ported numbers.

Eventually the FCC decided that ILECs would be allowed to recover the costs of implementing and providing telephone number portability. They could do it either by charging CLECs who use the ILEC switches as resellers, or by a fixed monthly charge to end users. Starting in February 1999, companies were allowed to start applying the fixed monthly charges, but only in areas where LNP had been introduced. These charges are intended to allow incumbents to recover costs of creating new facilities, physically upgrading or improving the existing public switched telephone network and performing the ongoing functions associated with providing number portability. Current rules require that these fixed charges can only be imposed on end users for a period of five years. The charges are generally applied to all customers, even if they have not requested their number be ported. The rationale is that it gives them an opportunity to consider using a competitor of the ILEC and therefore get lower rates or access to additional services.

If your company is just getting into LNP, there are a number of things you should be aware of:

o There are special charge considerations for business customers with multiple lines.

o The monthly charge cannot be imposed on any customer who is part of the Lifeline Assistance Program.

o Be sure that you do not refer to these charges as any sort of tax. The FCC allows the charge, but does not receive any part of it.

o You cannot move a number to another city or town outside the local "wire center"-the area defined as local.

o You cannot move a number from an ILEC or CLEC to a wireless service provider, or vice versa.

o Wireless number portability has similar but separate implementation rules.

As to the second question, when a ported number is disconnected at a CLEC, ownership and control of that number reverts back to the ILEC. (The reverse is also true, since CLECs are assigned their own number ranges; it is possible for a CLEC number to be ported to an ILEC.) Once a ported number is disconnected, the originally assigned "owner" of the number range can immediately put the number back in service for another subscriber or quarantine it for a time.

The official document that has all the details is the "FCC Number Portability Report and Order, CC Docket 95-116, July 1996." You can obtain a complete copy at www.fcc.gov.