Industry News


John Staurulakis Inc

JSI e-Lert
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New Number Porting Requirements for Carriers and
Interconnected VoIP Providers
This e-lert summarizes the following new porting requirements for carriers and interconnected VoIP providers:

(I) New Porting Obligations for Interconnected VoIP Providers and Their
Numbering Partners
(II) Small Wireline Carriers Must Begin Porting to Wireless Carriers (Intermodal
LNP)
(III) New Requirements for Validating Port Requests
(IV) Dates for Compliance

On November 8, 2007 the FCC released a Report and Order clarifying local number portability (LNP) obligations for all carriers and interconnected VoIP providers. The FCC's Order provides clarification in three key areas: (1) new porting obligations for VoIP providers and their numbering partners; (2) intermodal porting implementation for small carriers; and (3) new requirements for validating port requests.

JSI has summarized these three requirements, as well as upcoming dates for compliance, in this e-lert and will release the full details of these requirements in the next several weeks. In addition, JSI has scheduled a webinar on December 12 to provide more detailed intermodal porting implementation assistance for clients. The webinar details are discussed below.

I. New Porting Obligations for Carriers, VoIP Providers and Their Numbering Partners

The FCC's new porting requirements require the porting of numbers between VoIP providers and wireline and wireless carriers. Carriers will not be permitted to refuse to port when an end user is purchasing VoIP service. Similarly, VoIP providers can no longer refuse to port numbers back to the local exchange carrier that wins a customer back.

According to the FCC's rules and the North American Numbering Plan Administrator's (NANPA) standards, only carriers authorized to provide service in an area, and are capable of providing services in that area within sixty (60) days, may obtain numbering resources for that area. Therefore, most VoIP providers must work with a numbering partner, including local exchange carriers and wireless carriers, to port a number.

The FCC now requires wireline and wireless carriers to accommodate porting with VoIP services. Any ILEC must port out a telephone number to: (a) a VoIP provider that partners with a wireless carrier for numbering resources, where the partnering wireless carrier's coverage area overlaps with the geographic location of the porting-out wireline carrier's rate center; or (b) a VoIP provider that partners with a wireline carrier for numbering resources, where the partnering wireline carrier has facilities or numbering resources in the same rate center as the ILEC. Wireless carriers must port out a telephone number to: (a) a VoIP provider that partners with a wireless carrier; or (b) a VoIP provider that partners with a wireline carrier for numbering resources, where the partnering wireline carrier is within the number's originating rate center.

Any VoIP provider partnering with a wireline carrier must port out a telephone number to (a) a wireless carrier with a coverage area that overlaps with the geographic location of the porting-out numbering partner's rate center; (b) a wireline carrier that has facilities or numbering resources in the same rate center; or (c) another VoIP provider whose numbering partner meets the requirements of (a) or (b). A VoIP provider partnering with a covered CMRS provider for numbering resources must port out a telephone number to: (a) another wireless carrier; (b) a wireline carrier within the telephone number's originating rate center; or (c) another VoIP provider whose numbering partner meets the requirements of (a) or (b).

II. Small Wireline Carriers Must Begin Porting to Wireless Carriers (Intermodal LNP)

As of the effective date of the FCC's rules, any carrier qualifying as a "small entity" under the FCC's Regulatory Flexibility Analysis must begin intermodal porting. Specifically, small entities are required to provide wireline-to-wireless intermodal porting to a requesting wireless carrier. The wireless carrier's coverage area must overlap the geographic location in which the customer's wireline number is provisioned, and the porting-in carrier must maintain the number's original rate center destination following the port.

ILECs not already porting with wireless carriers need to be prepared to begin testing or commencing porting on the effective date of the order. As we send this e-lert, the effective date has not been established, but JSI anticipates that it will be set for the beginning of January. Once a firm date is established, JSI will send out an update. On the effective date, companies that have a request from a wireless carrier will need to:

• have an LNP-capable switch;
• be registered with the Number Portability Administration Center (NPAC) for porting;
• determine how the company will submit port requests to NPAC;
• have an arrangement with a database provider to query calls;
• understand the translations required for routing based on the location routing number; and
• set up a process to receive and implement port requests.
Once again, JSI will conduct a webinar on December 12 at 10 a.m. EST to review the basic LNP implementation steps and answer questions about intermodal porting requirements.

III. New Requirements for Validating Port Requests

Beginning February 6, 2008, any porting-out carrier verifying a port request for a simple port may not require more information than is a "minimal but reasonable amount" from the porting-in provider. The FCC has specified four fields of information that may be requested by a carrier to validate and complete a simple port: (1) 10-digit telephone number; (2) customer account number; (3) 5-digit zip code; and (4) pass-code (if applicable). Accordingly, carriers will need to modify their local service order forms to comply with this requirement. The national standards organizations (ordering and billing forum), North American Numbering Council (NANC), and JSI are working to update procedures. JSI is working to update its LNP Operations Manuals that many clients have used to communicate their procedures to wireless carriers and competitive local exchange carriers to incorporate the changes in the service order.

IV. Dates for Compliance

The new LNP obligations established in the FCC's Report and Order become effective 30 days after publication in the Federal Register, which JSI expects to occur any day, making the effective date early January 2008. However, the FCC's new validation requirements are effective for all carriers as of February 6, 2008, 90 days following the date of release of the FCC's order.

Please also look for this upcoming information and assistance from JSI:

• JSI will release the full details of these new requirements and their implications for clients in an upcoming e-lert.
• JSI will provide more detailed intermodal porting implementation assistance for clients in a webinar on December 12 at 10 a.m. EST.
• JSI plans to conduct a second webinar in early January to address the VoIP porting requirements and the new validation process.

If you have any general questions about the FCC's new porting requirements, please contact Bridget Alexander (balexander@jsitel.com), Karen Hoffman (khoffman@jsitel.com), Valerie Wimer (vwimer@jsitel.com), John Kuydendall (jkuydendall@jsitel.com), or Terri Parrilla (tparrilla@jsitel.com) in JSI's Maryland office, at 301-459-7590, or Lans Chase (lchase@jsitel.com) in JSI's Atlanta office at 770-569-2105.

NTCA Applauds Report Finding that Landline Still King: Pew Internet Survey says landline youth's most popular communication method

December 21, 2007, Arlington, Va. - The National Telecommunications Cooperative Association (NTCA) today hailed a recently released report by the Pew Internet & American Life Project that debunks the myth that communications landlines are going the way of the horse and buggy. The report found that the landline telephone is the number one method of communication for teens ages 12 to 17.

The study validates NTCA, Foundation for Rural Service (FRS), and other industry reports that indicate that there will always be an overarching need for landlines and their superior characteristics. In fact, the most recent survey of rural youth communications habits by NTCA and FRS found that, when given a choice, 70 % of respondents selected the landline as their method of communication at home.

"Despite dire predictions of the demise of landline telephone service, today's communications-oriented teens rely most heavily on landlines wired to the wall for their day to day social interactions," said NTCA Chief Executive Officer Michael E. Brunner. "To paraphrase Mark Twain, 'reports of landlines' death are greatly exaggerated.'"

The study suggests that rather than abandoning older technologies in favor of newer ones, today's educated and tech-savvy youth are adapting to their environments by utilizing technologies and approaches that are most applicable to the current need-in the same way rural communications providers have adapted their business plans to deliver consumers the services they demand.

"The study validates the experience that rural telcos have been committed to for many years: Continuing to offer and value the traditional landline while expanding their offerings to meet the changing needs of consumers-particularly the younger generation," Brunner said. "Rural telcos provide the security and dependability of landline service and the innovation of newer technologies, and their commitment to the new vision of telecommunications-including landlines, wireless and broadband-means they will continue to be relevant well in the future."

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