Most Carriers Won’t Meet Wireless LNP Deadline

Now that courts have cleared the way for wireless number portability, the Cellular Telecommunications & Internet Association (CTIA) has listed several compelling reasons why wireless carriers won’t be ready for number portability by the FCC’s Nov. 24 deadline. In fact, the CTIA has petitioned the FCC to clear up a laundry list of problems it says are holding up wireline-to-wireless portability. The issues, which surround technical, contractual and cultural roadblocks, have to be cleared up by Sept. 1 to give wireless carriers just 90 days to meet the deadline, says CTIA President Thomas Wheeler.

“There is only one deadline for wireless portability for all types of telephony,” says CTIA spokesperson Travis Larsen, explaining why the wireline issues affect the wireless portability deadline. “The FCC has explicitly stated that the Nov. 24 wireless portability deadline is designed to increase intermodel portability.” But the FCC says wireline-to-wireless issues should not hold up the wireless-to-wireless portability deadline.

According to Wheeler, the wireline issues will prevent true portability by the deadline because the FCC has ignored wireline-wireless issues.

“These issues are not new to the FCC,” Wheeler complained in a May 13 petition asking the FCC to iron out the confusion. “Many of these issues have been before the FCC for years but still haven’t been addressed.”

A wireless bureau spokesperson made it clear that the FCC won’t back away from the November deadline. “We're currently reviewing CTIA's filing to determine whether all items listed are issues pending before us,” she says. “We're working to ensure there is a smooth, efficient process in place for wireless consumers. The deadline for this requirement is Nov. 24, and wireless carriers need to be working toward that date.”

Grudging Compliance and Real Confusion

“The wireless industry isn’t happy about having to do this, because they believe that wireless competition is already healthy,” says Dave Hoover, an analyst with Precursor Group. “A lot of wireless carriers are looking at the November date as the point to begin the process of getting number portability going rather than as the deadline,” he says. Regardless of how the FCC rules, the CTIA’s list contains real concerns that have to be overcome to make wireline-to-wireless portability work.

The work in essence requires the transferring, or porting, of phone numbers—one at a time—between two different network architectures. Wireless carriers say compliance with the order is going to be difficult, especially because they don’t know which of the cities in the targeted top 100 markets fall under the FCC order.

The proposition requires staff, software development and interface testing not only between carriers, but between the Number Portability Administration Center (NPAC) and numbering databases throughout the nation.

OSS vendors that develop number portability software agreed with some of CTIA’s complaints but say some of the problems can be solved easily. Nevertheless, the FCC’s heretofore lack of response isn’t making the situation easier.

Portability Not Available to All

The only rules presently governing number portability apply to wireline-to-wireline. But in wireless portability, wireline central offices don’t align with cell tower locations, so only wired subscribers may be able to move their number to a wireless phone. “In the wireline world, a phone number is assigned to a single central office,” says Dan Sheehan, senior consultant for communications practice at Acumen Solutions. “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 wireless carrier’s coverage may reach areas that are not served by the original wireline carrier, the LEC cannot support LNP in those areas.”

The FCC wants portability available in the top 100 markets, but it has not clearly identified those markets. For example, Baltimore and Washington, D.C. used to be separate markets [as far as the FCC was concerned], but in the 2000 U.S. census they were combined. Similar changes have altered the status of about 20 markets. The FCC attempted to clarify these rules, then withdrew its clarification. It has since sought comments on the issue but has made no decision.

As for markets other than the top 100, a consumer who ports a number and then roams into a smaller market will face the possibility of denied service. This is not a minor issue. Smaller markets served by rural carriers could become a no-man’s land where ported wireline numbers simply stop working.

According to Steve Farnsworth, executive director of the consulting practice at Evolving Technologies, identifiers within phones will not work under those circumstances.

All cell phones have two identifiers, a Mobile Directory Number (MDN) and a Mobile Identification Number (MIN). A cell phone with a ported number has a MIN that is different from the MDN. When a subscriber roams there are two interactions that are critical for proper operation: The phone must properly register with the local network so outgoing calls can be placed and incoming calls can be received. This registration is based on the MIN. If a ported subscriber roams into an area that does not support number portability, the registration signal from the cell phone will supply the MIN, which correctly identifies the subscriber's service provider. “The registration message will use the MIN to route a query to the home location register for the subscriber's service provider,” Farnsworth says, “and will use the profile information retrieved to populate a temporary entry in the roaming provider's visiting location registry [VLR]. The concern about compatibility comes if and when the roaming provider's VLR does not properly allow for separate MIN and MDN values. If a carrier had such a VLR, only through testing could it determine the resulting behavior. But there is a possibility that inbound calls that initially are routed to the subscriber's home switch will be properly routed to the roaming provider's network, but that they may not be able to make the connection to the handset once in the non-portable roaming provider's network.”

“Some of the smaller rural carriers have to make changes to their networks,” says Tom Bullotta, senior manager at Acumen Solutions. “They have to upgrade their switch software and the information contained in their number management databases. If some of the rural carriers don’t make those changes because they’re too expensive, or they don’t know they have to do that, the entire national roaming system could have gaps.”

Porting May Interrupt Service, 911 Effectiveness

The FCC wants wireline-to-wireline porting within four business days of the request; the wireless industry hopes to deliver wireless-to-wireless porting for each number within 2 1/2 hours. Unless the FCC establishes a porting interval limit for wireline-to-wireless porting, customers run the risk of being without service for days. More importantly, 911 operators may not be able to call back cell subscribers during emergencies if the number porting isn’t complete. Emergency dispatchers at police and fire departments require call back capability so they can give callers further instructions during an emergency. Delays could prevent the operator from reaching the cell user. The CTIA says this and the other 911/LNP issues have been raised by the industry three times in as many years without resolution. To address the potential public safety issue, an NPAC working group came up with several alternatives to prevent interruption to 911 call-back capability.

Farnsworth says wireline carriers aren’t hiding their disinterest in shortening gaps in service. “The timeframes cited are real, and wireline providers appear to have no interest in trying to meet wireless industry timelines.

“Wireline providers are sending trucks out to premises locations to disconnect service from the local demarcation point, and such activities generally take some number of days to schedule,” he says. “It is possible for a wireless provider to provision service on the cell phone with a temporary telephone number from local inventory, then update the record with the wireline number when the porting process has [been] completed. Alternatively, a carrier could require potential subscribers who are porting in wireline numbers to apply in advance for the port and pick up the activated handset after the port has been completed. While this second alternative delays revenue and may be less customer-friendly, it does mitigate the risk of 911 complications with callback numbers.”

One way to prevent loss of 911 call-back capability entails letting the new service provider activate the port at the NPAC service management system as soon as the 10-digit trigger has been applied by the old service provider. However, carriers have to agree to provide “mixed” service until disconnect can be accomplished.

Confusion Surrounds Testing Rules

Number portability will require testing among large and small carriers and the NPAC before it can be introduced, but the CTIA complains that testing parameters are still unclear.

Some testing platforms, however, have been in place for a while, Farnsworth says. Testing not only includes automated messages between wireline and wireless carriers, but also between the carriers and the NPAC, which ensures that identifying information for each ported number is current and sent to carrier databases. “The [NPAC’s] Wireless Number Portability Operations Testing Subcommittee has gone to great lengths to establish a test plan and to coordinate testing, both among wireless carriers and among wireless and wireline carriers,” he says. There are two critical interactions that must occur between carriers during the porting process: exchange of order information and broadcast of the network routing parameters.

“Both of these interactions must be tested to assure proper operation, and both operations follow established standards,” he says. “For the exchange of order information when porting with a wireline provider, unless special arrangements have been made between carriers to alter the existing procedure, wireless carriers will convert the information they generally exchange with other wireless carriers (in the form of a wireless port request) into a wireline-style request (local service request). At that point, the interface matches the normal wireline format and should be acceptable to the wireline carrier.”

Porting a number originally owned by a wireline carrier to a wireless subscriber raises issues of number ownership. When the wireless call is terminated on a wireline network, the terminating carrier needs to know instantly who owns that phone number for billing purposes. But if it was originally a wireline number, how does the terminating carrier know which wireless carrier is using it? How does that network routing information stay fresh every time it gets ported to another wireless carrier?

“I think that there are a number of problems,” says Cathy McMahon, executive director of WNP product management at Telcordia. “It’s a complex process.”

For the broadcast of network routing information, the NPAC Regional Service Management System (RSMS) mediates between carriers and broadcasts the final parameters to all network providers in the region. “This process has been in place since 1997 and will not change with wireless portability,” Farnsworth says.

Establishing an NPAC Interface

To prepare for portability, carriers have to establish and test an interface to handle automated messages to and from the NPAC. Telcordia, Convergys, Neustar, VeriSign and other vendors offer NPAC interface testing in a service-bureau environment for carriers that can’t afford to make the software changes or dedicate staff to the work. “The NPAC functionality is necessary to create intercarrier reports between trading partners,” says Maggie Lee, senior technical solutions manager for VeriSign.

It takes a robust and fast platform to handle the information necessary to track porting events around the country simultaneously. Each ported number and assignment data is embedded in automated messages between carriers and the NPAC. The data includes directory number, service provider ID, location routing number and possibly global title translation information for additional services for the additional LIDB and class services, Lee says.

“A whole series of things has to happen between carriers for porting numbers,” Acumen’s Bullotta says. “For every ported number, the carrier needs to determine eligibility to see if the number can be ported. If it can, the wireless carrier has to generate a porting request to the wireline carrier. During the intercarrier communications, the wireless carrier has to validate that the customer owns the wireline number.”

Smaller carriers without the automated equipment face a tougher time because they may have to rely on faxes to confirm billing name and address, number ownership and services connected to the number, McMahon says.

Others contract with third parties, such as clearinghouses or service bureaus. No matter who handles this part of the process, Bullotta says, they will probably experience “fall out” when names don’t match the number assignment or the number is no longer active. “The porting transaction creates an error alert and it’s delayed and indicates that resolution is needed, so the original carrier has to go back and verify the customer information,” he says.

The number assignment information, such as billing name and address and services the subscriber wants, is then mated with the ported number. “Content is integrated with the Service Order and Administration System (SOA) that talks directly to NPAC about provisioning for ported in and the ported out number,” Lee says. “That is where the carrier sends up the information as a series of messages to SOA and NPAC to activate the number ported in and out of one provider to another. To move a number in the network, it has to be activated in NPAC down to the actual network side, in the carrier’s number portability database.”

Lee says carriers can either maintain their own number portability databases or rely on service bureaus to obtain that information. They can also offload the access to the database through the ILEC’s number portability database, which takes trust. “They have some options on the network routing side of it,” she says.

Once the systems are up and running, they should be able to handle the high traffic in ported numbers information. “It’s something that’s very dynamic,” Lee says. “The transactions are happening all the time. Once the system is running as designed, it should be able to handle 25 phone number porting events per second, across all the nation’s seven telecom regions.”

NPAC also had to accommodate the unique business culture of wireless carriers. For instance, wireline carriers take new phone orders during normal work hours. Wireless carriers, on the other hand, run kiosks in shopping malls and turn on cell phones for customers on the spot, whether on a weekday evening or a Sunday afternoon. To accommodate after hours wireless sign-ups, technicians had to make the NPAC system available beyond traditional business hours by adding timers that tracked the time it took to activate service.

A lot of mistakes can occur at those kiosks, McMahon says. “There’s a mismatch of data,” she says. The customer walks up to the kiosk, and says ‘I want to transfer to a new carrier.’ The wireless salesperson starts the transfer and the old carrier says he’s not their customer, or the customer hasn’t paid their bill. The wireless industry is going to have to simplify a number of their fields … to have a fairly neutral account number that’s easier to validate and less prone to interpretation.”

The testing is designed to iron out the wrinkles. “Sometimes numbers don’t get ported and all of the systems need some fixing,” Lee says. Tier 1 carriers are undergoing testing now, “but the smaller carriers have not yet fully stepped up to the plate; testing between themselves and larger carriers is not going on.”

Interconnection Agreements or SLAs?

What about wireline carriers that are demanding interconnection agreements before they let testing with wireless carriers occur? That could mean the involvement of public utility commissions in each state before testing begins.

Though wireless carriers have agreed to use simple SLAs, CTIA says ILECs won’t participate in wireline-to-wireless portability without formal interconnection agreements. “Requiring such agreements is a dodge to keep from having to port numbers to wireless phones, and the FCC has the power to shut down that dodge,” the CTIA says.

Indeed, BellSouth and SBC told the FCC that terms and conditions by which ILECs provide number portability “is an interconnection agreement that must be filed with the appropriate state commissions.” This represents a hellish nightmare for anyone hoping to get portability up by November—or trying to come up with a blockbuster reason to postpone it. There is little indication that wireline carriers would actually open such time-consuming and expensive deliberations nationwide. However, CTIA’s mentioning of it may serve to make a point rather than actually asking the FCC to rule on it. But the wireless carriers do have a point.

“The interconnection agreements are necessary to specify how local service request information is provided to the wireline carrier and how wireline-specific fields are populated to assure proper operation for the wireline carriers’ back-office systems that may be servicing the request,” Farnsworth says. “For example, a wireless carrier won't have a premise or service location address, while a wireline carrier will. While scheduled intercarrier testing is necessary, it requires cooperation and coordination.”

“Wireline carriers do not appear to accept requests in the Wireless Intercarrier Communication Interface Specification (WICIS) wireless port request format (WPR),” Farnsworth says. It is possible that a wireless carrier with exceptional negotiating skills could reach an agreement with a wireline carrier to accept the WICIS WPR format, but I doubt it.”

What happens if an uncooperative carrier slows the testing through stalling tactics? The other carrier can then create a “virtual” carrier partner for testing purposes. Evolving Systems, for instance, develops a test harness for wireless number portability that can surround a carrier’s systems and simulate a wireline carrier partner as well as the NPAC and the regional support management system. Such testing harnesses are designed to give carriers sufficient time to find snafus during the short intercarrier test period phase.

Long Distance Charges for Ported Calls

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.

Wireline carriers say that under the current rules they can charge long distance rates if the ported number moves to a wireless switch in another rate center. “The wireless carriers are going grudgingly with that idea,” Acumen’s Sheehan told Billing World and OSS Today in March. “If you port to a different rate center—the wireline carriers say, ‘every time you make a call, I’m going to charge you a toll.’ They’re just trying to protect some revenue.”

“We are not aware of a final ruling on the issue of rate center disparity between wireless and wireline carriers, but we expect that a wireless switch located in a different rate center than the dialed telephone number will not be subject to long-distance charges. This practice follows the treatment of a CLEC telephone number homed on a switch that is physically located in another rate center. In either case, the assumption is that the premise (CLEC/wireline service) or primary serving area (wireless) is within the local rate center.”

CTIA Still Sees Problems

Even as wireless carriers move toward implementation, CTIA still carps about all the problems carriers face. “The FCC’s failure to act thus far has placed the industry in a precarious situation with its won customers,” Wheeler scolded in the CTIA petition. The commission’s indecision “has fostered an unstable environment that calls into question the underlying purpose and enforceability of the LNP rule.”

“CTIA continues to believe that number portability is poor public policy, but given that it is currently required by FCC mandate, the … FCC [must] make a decision on operational realities.”

After a long and highly visible tour as wireless industry advocate, Wheeler is set to leave CTIA to pursue opportunities elsewhere. His pugnacious stance against wireless portability—a technology the American public clearly wants—indicates that should Wheeler roam into a rural area and lose his cell signal, the FCC might finally get some peace.