Delaying the Process
Wireless number portability (WNP) has been delayed more than once. The FCC first extended the deadline by nine months in 1998, and then again in 1999, at the request of the Cellular Telecommunications & Internet Association (CTIA). Last July Verizon Wireless filed a forbearance petition with the FCC, trying to extend the time frame further. The FCC wants portability to further promote competition, yet Verizon contends there is already significant competition in the wireless space.
Verizon's petition had a dramatic impact on the industry's movement with WNP compliance and placed wireless providers in a holding pattern of sorts, says Marc Abbott, senior vice president of marketing and product management at Evolving Systems, a company that makes OSS and LNP software. "Ever since the petition went in, the wireless carriers have postponed buying decisions on hardware and software. They would not want to expend that money if compliance is either totally eliminated or even significantly delayed," he says. "There are some wireless carriers that had already made buying decisions on software and network equipment before the forbearance petition, but for those that haven't, our indication is that they have postponed or at least stopped those activities until they know."
Opportunity Knocks
Not everyone in the industry sees WNP as a burden. Some wireless providers are working toward compliance (see "Leap Jumps Into the Fray"), and billing and OSS vendors are building the functionality into their products. David Packhem, president of billing vendor Infotech Solutions, says most carriers have always viewed number portability as a real problem-a regulation that would just drive everyone crazy. "Everyone has dragged their heels and been troubled about the whole thing," he says. "But at some point you wake up and say, 'It's coming-now what are we going to do to make sure that our company and our customers are positioned so they can use this as an opportunity for their business?'"
Packhem believes providers should view WNP as a way to earn customers, not lose them. "I think the more enlightened carriers right now are saying, 'I can't wait until this happens, because the first thing I'm going to do is convert some really good business customers who would never convert because they wouldn't want to give up their telephone number,' " he says. "There needed to be an attitude change. It's not evil. It's good, and the ones that look at these things as opportunities are the ones that will make out."
Australia: Lessons Learned
Australia's deadline for WNP hit last September, and providers such as Virgin Mobile saw this as an opportunity. According to ADC, which provides billing for Virgin Mobile in Australia, WNP had an impact on Virgin's deployment in the region. "I think if this legislation hadn't have come in, I don't know if Virgin would have launched their network," says Bernie Woodcroft, vice president for consulting services at ADC's Software Systems Division. Virgin wanted WNP as quickly as possible, he says: "Their view is that there's a lot of pent-up distaste for the incumbent carrier."
Woodcroft notes that in Australia, the bigger the market share of the incumbent, the more resistance the provider likely put up. "All the incumbents will try very hard to say that is extremely difficult to do technically," he says. And while Woodcroft does not downplay the technical challenges, he notes the importance of the regulatory drive to make sure people are staying with carriers for the right reasons, not just because they are obligated because they cannot change.
Initial trends in Australia revealed carrier frustration. "There were more delays with people porting out than numbers being ported in," Woodcroft points out. "It's an enforced regulatory change that isn't really in their best interest." Woodcroft estimates that while subscriber counts could shift greatly at first, the shifts will eventually steady out.
The Cost
Another reason why providers are digging in their heels is the cost implications. Sprint PCS estimated in its comments to the FCC that operating costs alone to implement WNP would total at least $50 million annually, with more than $35 million to simply comply with WNP. And Cingular Wireless estimated that it would spend $250 million over the next five years to support WNP.
"It's an awful lot of capital to grab onto in today's environment," says Abbott at Evolving Systems. "I appreciate the challenge they face." Software support would be a minority cost, in his view; the big crunch comes from significant changes in the capacity of certain network components, such as upgrading switches and supporting management of ported numbers. "It's a rigorous and costly process," Abbott says.
The cost is not just in dollars, but also human resources. The number of engineers tasked with ensuring compliance is great. These are resources that carriers could otherwise dedicate elsewhere to keep up in the competitive wireless space. All the same, ADC's Woodcroft contends that the dollar amounts WNP would cost carriers probably are inflated, if they come from the carriers that don't want it to happen.
The Regulatory Load
Providers seeking a delay say that, in combination with other regulatory mandates, WNP is too much of a burden. "This comes at a time that I [as a wireless provider] have been reminded by the national regulatory body that my failure to meet the initial target dates for initial levels of performance to the E911 capability is also a drain on my capital budget, which is getting increasingly difficult to obtain in this economic situation," Abbott says. "I also have capital expenditures staring me straight in the eye as I try to maintain my competitive position in deploying next-generation services. I can see business reasons why I would not, if I were a wireless carrier, be in favor of doing this."
When Verizon filed its forbearance petition in July, one argument was that thousand-block number pooling to conserve the amount of available numbers shared the same November 2002 deadline as WNP. Some say that if providers are forced to implement WNP too quickly, network performance could be jeopardized. CTIA spokesman Travis Larson says that "immediate flash-cut deployment of porting and pooling does pose risks to network reliability."
Although wireless operators have always favored number pooling to ensure enough numbers to go around, they contend that the simultaneous mandates divert resources that could be put toward pooling.
Some suggest that supporters of thousand-block number pooling are being selfish if they do not recognize that number portability is also another way to free up available numbers. Besides, it would cost carriers a great deal more if numbers were not conserved and providers had to alter every database within their systems to support a 14-digit numbering plan.
In addition, some companies find that the same hardware and software must be tweaked to support both pooling and porting, so they are tackling them simultaneously. "For us, they were similar, and it was sensible for us to do them at the same time," says Infotech's Packhem. "If we are going to open up all the code to do the pooling, then we might as well do the number portability while we're in there. It is more elaborate to do the number portability, but it is inefficient to go back and do it again later."
Burdening Rural Carriers
In theory, WNP is useless unless all carriers can support it. The ability of rural and smaller carriers to comply is an issue, as they often have fewer resources. Packhem likens the porting situation to roaming. "A lot of rural carriers didn't permit roaming because they didn't have agreements. [Porting] is a matter of opening up a carrier's network to accept a ported number," he says. "The situation is going to be more about administration, where rural carriers are going to have to introduce into their day-to-day administration roaming coordinators, and at some point they are going to have enough volume that they are going to have ported number coordinators to make sure their network is open to these numbers that are coming into their network. … Administratively, it will just be kind of a pain for a while, but thereafter, it will just be second nature."
Doubling the Numbers
The single greatest technological challenge will be to separate the mobile identification number (MIN) and the mobile directory number (MDN) for each individual customer. The mobile identification number has historically been the number that has been used to do everything from routing to clearing to roaming. That number will still exist, but a new number must be used that can be ported-the mobile directory number. "Everything in our code is based on one number," Infotech's Packhem says. "What we need to do is now create two."
After porting is implemented, the MIN would still be used for routing and clearing, yet the billing information would be based on the MDN. "The MDN will be a dialable NANP [North American Numbering Plan] directory number, and will be the portable number. The MIN will be retained by the service provider and is not portable," explains Lori Messing, CTIA director for numbering issues. Assigning two numbers to each customer this way would allow the billing information to be processed by the customer's carrier. MIN-based carriers must complete MIN/MDN separation prior to entering the testing phase of implementation, Messing notes.
MIN/MDN separation is the biggest challenge for the billing vendor as well. To be able to generate bills for subscribers who have ported in their phone numbers, billing vendors have a lot of work to do.
"Separating the MIN and MDN forces us as a billing vendor to change our view of the subscriber," says Joe Cudo, senior programmer in charge of the effort by Alltel Information Services to support WNP within its billing system. "We need to identify him both by his MIN and his MDN, and that touches all the components of our billing software."
Management of MINs and MDNs alone is a hefty task for systems. Number management must be able to track both numbers; ported numbers must be tracked for special processing. Providers must have an available MIN pool and be able to manage directory numbers that have ported in and out. MDNs that are ported out need to be marked unavailable so they are not assigned to other customers. MDNs must be tracked so that either they can be recycled if service with the associated MDN is canceled or the number is not assigned to another customer. Also carriers to which MDNs are ported must assign a MIN to that MDN, since MINs are not ported.
The point-of-sale component needs to report a customer's MIN and MDN to a provisioning component for switch updates after selling an MDN. A switch would page out with an MIN to find the subscriber. Call processing would have to be able to link an MIN with an MDN for billing.
Other Billing and OSS Impacts
WNP entails other all-encompassing changes to many elements of billing and operations support systems.
"With the expansion of the AMA records, networks should be evaluated to determine if the expansion will cause network congestion," says Chris Metz, Alltel Information Services account manager. "Current networks may not be able to handle the increased volume caused by the new record size. Fraud management and churn management systems may need both MDNs and MINs sent in order to associate the switch traffic, which carries the MIN, with the MDN. And these are just a few examples."
Even customer care is affected, as customer care screens need the ability to do inquiries for an MIN or MDN. What's more, the customer care process may take on the task of trying to keep customers from porting out and changing carriers, or it may be used to understand why customers are migrating to other providers.
Infotech began preparing for WNP last April, devoting about 6 of its 40 employees to the process. The company's entire business plan has been impacted by its efforts to support WNP.
"Generally, we go through a product upgrade every six months," explains Packhem. "This year, because of [WNP], it will be a year delay instead of six months, because we are devoting so much effort to wireless number portability."
"It's been a big undertaking for us," he says. "I can just imagine what it is for some of these huge companies."
The Carrier Connection
One of the biggest challenges carriers will face is communicating porting activity with one another. It is no longer the customer's responsibility to terminate service with the existing provider and activate with the new provider. The customer can walk into a store and place the burden on the new provider, so it becomes the carrier's responsibility to coordinate the termination and porting out with the old provider and the activation and porting into their system. Carrier-to-carrier communication regarding wireless number portability has not been necessary before.
CTIA has already worked to create a process for this pre-port activity to support carrier-to-carrier communications.
In addition, moving numbers between wireless and wireline carriers ("interspecies" porting) presents challenges. The time frame that many wireless providers have committed to in number porting is 2.5 hours, while the wireline side may take up to four or five days. Achieving the wireless time frame will be a daunting task. "This means all validations for the porting request by both carriers; Number Portability Administration Center [NPAC] notification for new routing information; 'porting out' termination by the old carrier; 'porting in' activation by the new carrier; and MIN assignment have to all occur within 2.5 hours," says Alltel's Metz. "The coordination of the termination of old service and activation of the new service has to be seamless, so the customer does not get billed for service by both carriers for the same time frame or does not have service for a specific period of time. New practices have to be developed to handle the different scenarios that can occur."
"Supporting number portability is a huge cost to the wireless industry, but it is not without its effect on the wireline space," notes Abbott at Evolving Systems.
CTIA's Messing also points out that there is a disparity of local calling between the wireline and wireless providers, thus creating complicated operational hurdles to complete requests for ports. "Many of the issues associated with wireless to wireline calls are unresolved and continue to be discussed in industry working groups," she says.
The Road to WNP
While providers have fought the acceptance of WNP, customers want the flexibility of keeping their phone number whether they remain with a provider or not, and regulatory bodies want to promote competition to ultimately ensure better service overall. Providers and vendors alike will all eventually struggle to reach WNP compliance by dedicating precious capital and staff resources. The outcome is that, despite the expense and hassle a provider may go through to support WNP, there is no guarantee that its customers will remain.
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Bring it on-that's what Leap Wireless has to say when it comes to wireless number portability. While most mobile providers align with Verizon Wireless, which wants to see the FCC extend the current deadline for compliance, Leap wonders what providers were afraid of. The company's Cricket service covers 39 less-than-metro markets in the United States and offers one-rate unlimited wireless calling plans poised to be competitive with local wireline carriers. Leap's plan is to offer a cordless phone on steroids, and its strategy is to win over wireline customers in the hope the consumer will eventually "cut the cord" and enter the all-wireless dimension. According to Laurie Itkin, Leap's director of government affairs, 7 percent of Leap's customers no longer subscribe to wireline, compared to the industry average of 2 to 3 percent . She believes this number would increase if wireline customers could take their numbers with them. Hence, Leap has a stake in making sure customers can take their number and run, if they so choose. A major argument for WNP is to foster competition. Itkin believes that customers would readily welcome number portability with their wireless phone. If customers "knew their own provider was stalling, I think they'd be really mad," she says. "If [providers] are really interested in competition, why would they not want their customers to take their business to the best provider? I think with WNP, they are going to have a net loss of customers, and not a net gain." Both Leap and Nextel opposed the Verizon forbearance petition. Leap has planned to move forward regardless of the FCC's WNP deadline decision. Itkin says intercarrier testing is the most time-consuming process, because a provider must test with every single major local exchange carrier in its market. Yet being able to port is dependent on all carriers doing so. Leap's ability to move forward hinges on other carriers' compliance. When it comes to carriers' complaints about not having enough free capital to invest in WNP, Itkin says, "It's all prioritization. I understand capital markets are a little dry, but there's no reason to think they can't afford this. Every provider has a bunch of projects ongoing at the same time." |
