Regulatory Watch : CTIA Pushes FCC on LNP Issues

“Socks on a fish.”

That’s how the Cellular Telecommunications & Internet Association (CTIA) characterized the FCC’s attempts to use wireless-to-wireless number portability to increase competition between the wireless and wireline industries.

The CTIA instead wants the FCC to order wireline carriers to let their subscribers transfer their phone numbers to wireless carriers. If the current wireless LNP rules aren’t changed, the association argues, the wireless industry would have to spend billions over the next 10 years to support wireless-to-wireless portability, a plan the CTIA said would not increase wireless competition.

CTIA called on the FCC to resolve a major sticking point: whether wireline carriers can restrict a customer’s ability to port a telephone number to a wireless carrier whose service area covers the wireline carrier’s rate center.

“Figures compiled by CTIA suggest that only one out of every eight wireline consumers will be able to port their number to a wireless carrier if the wireline companies are allowed to restrict porting,” CTIA argued in released comments. The FCC gave the wireless industry until Nov. 24 to institute wireless number portability (WNP).

Technical limitations and network architecture make WNP difficult, says Dan Sheehan, senior consultant for communications practice at Acumen Solutions. The overlapping of wireless footprints with wireline rate centers, or central offices, represents major problems. “There is a lot of ambiguity in the mandate itself,” Sheehan says. “The CTIA has said the FCC has to clarify the technical matters in the wireline world, where everything is based on the central office.” In the wireline world, a phone number is assigned to a single central office. But in the wireless world, that same phone number is sent over multiple cell towers throughout other areas where wireline central offices are located. “Because the MSC [metropolitan service center] is not located in all those central offices, the wireline carriers cannot support LNP in all those central offices,” he says.

“The issue has other technical limitations,” says Brian Belforte, senior manager for communications practice at Acumen. “In the wireline world, the LNP mandate is for geographic portability; the wireline carrier can only port to a wireline carrier that is in the same rate center, or central office. If the FCC ruling is followed verbatim by the wireline community, they can refuse to port out numbers to the wireless carriers that cover their rate center but don’t have an MSC physically located in that rate center.”

Belforte argues that wireless carriers indeed will have to spend billions of dollars to comply with overall WNP requirements—requirements that affect virtually all aspects of the wireless OSS. “If the mandate is followed verbatim, the wireless world would have to establish MSCs in each of the wireline central offices and install equipment and technology they normally wouldn’t need to provide coverage.”

The costs could be enormous, he says. “WNP has been likened to the installation of a new billing system. It’s felt all across the organization. One carrier has found more than 130 systems impacted by this mandate.”

Porting wireless numbers among wireless carriers will also be expensive and technologically complex. Sprint PCS told the FCC that operating costs alone to implement WNP would cost at least $50 million a year, 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.

The single greatest technological challenge will be to separate the mobile identification number (MIN) and the mobile directory number (MDN) for each subscriber. The MIN 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 found that can be ported—the mobile directory number (MDN). What this means is wireless carriers will have to create two codes for each number.

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 MDNs will be dialable North American Numbering Plan directory numbers, 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.

Billing vendors will be challenged by the MIN/MDN separation. The difficulty lies in the management of MINs and MDNs. 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 have to be marked “unavailable” so they aren’t assigned to other customers. MDNs must be tracked so that they can either be recycled if service with the associated MDN is canceled or the number is not assigned to another customer. Carriers to which MDNs are ported must assign a MIN to that MDN, because MINs are not ported.

ENUM Gets an Area Code

The electronic numbering (ENUM) regime got a boost in January with the deployment of the Global Country code “87810”. The number will be offered to VoIP customers around the world. At its most basic, ENUM is the convergence of PSTN and IP networks; it is the mapping of a telephone number from the PSTN to Internet functionalities.

FCC chairman Michael Powell endorsed moving toward an ENUM numbering protocol in February, embracing the stance of the National Telecommunications and Information Administration, an office of the U.S. Commerce Department. In a letter to the State Department, Powell said “any implementation should involve minimal domestic and international regulation.”

ENUM can be used for resolving requests to one universal phone number. Telephone numbers are based on the International Telecommunications Union’s (ITU) E.164 country codes and are therefore considered national resources. National regulatory authorities must now designate ENUM Tier 1 registries for their national phone numbers. The 87810 country code is administered as specified by ITU SG2.

But ENUM implementation faces hurdles, especially in Europe. Germany, the United Kingdom and Austria unveiled startup concepts in October. According to the people running the trials, regulatory uncertainties and economic issues are hampering rollout of new phone number domains, necessary for ENUM. Telephone domains are needed to bring about convergence of telecom and IP networks. Users of ENUM will get access to a wide range of possible services, from simple international look-up services to communication profiles or identity management.

Sleight of Hand?

The Colorado Public Utilities Commission apparently isn’t buying a plan by AT&T, WorldCom, Sprint, Qwest and 27 local independent phone companies to reduce intrastate access charges while adding a new monthly fee to local telephone bills.

The PUC ruled that the proposal to lower per-minute access charges to long-distance companies and make up the revenue with a $1.47 per month fee on all local telephone lines was a violation of the residential rate cap under current Colorado telecommunications law.

The rate cap prohibits local residential telephone rates from rising, except in certain circumstances, above levels in place at the time Colorado's law opening the local market to competition was passed in 1995.

The PUC said the proposed monthly fee amounted to a shift in the payment of access charges from long-distance companies to customers and was a violation of the rate cap.

FTC Rejects Calls to Fight Email Spam

The FTC in February denied a joint petition filed by the Telecommunications Research & Action Center (TRAC), the National Consumers League (NCL) and Consumer Action to curb the scourge of spam email. The commission, citing limited time and resources, has decided to maintain its current level of enforcement, while working with the public to explore solutions to the deluge.

“TRAC is disappointed that the FTC rejected our petition, and feels it was within their jurisdiction to take action,” Dirck A. Hargraves, counsel for TRAC, complained in a TRAC release. “We would be pleased if they would take more aggressive enforcement action based on the criteria in our petition.”

The consumer groups had called on the FTC to initiate a rule classifying unsolicited commercial email as an "unfair and deceptive" trade practice under the Federal Trade Act. Additionally, the proposed rule would prohibit email that misrepresents the source, sender, subject, or does not give consumers a reliable opt-out.

The petition asks for an FTC rule that defines unsolicited commercial email as “deceptive and therefore unlawful” if it:

• Misrepresents the sender (in source or routing information)

• Misrepresents the subject or content of the email

• Fails to provide reliable contact information for the real party in interest

• Fails to provide a reliable opt-out system

• Is sent to an individual who has opted out or resigned from a sender's list, or to whom sending unsolicited, commercial email is otherwise prohibited by law.