FCC Issues Order Standardizing Number Porting Process
Kelley Drye Client Advisory
On May 20, 2010, the Federal Communications Commission (“FCC” or “Commission”) issued a Report and Order updating its local number portability (“LNP” or “porting”) rules. In the Order, the Commission standardizes the information to be exchanged between telephone service providers when a customer switches telephone service but desires to retain their existing telephone number. The Order also adopts new local number portability (“LNP”) provisioning flows in support of the porting process and mandates a one-business day porting interval for “simple ports” between service providers.[1]
In order to effectively implement the one-business day porting interval, the Commission mandated that 14 information fields be exchanged between carriers when a customer switches service providers. The FCC found that these fields provide the necessary information for service providers to effect a “simple port”[2] within the one-day interval and mandated that service providers utilize the specified fields. The required information fields are:
Ported Telephone Number: This field identifies the telephone number or consecutive range of telephone numbers residing in the same switch to be ported.
Account Number: Identifies the account number assigned by the current service provider.
Zip Code: This field identifies the zip code of the end user’s service address and is used to validate that the correct user’s number has been sent on the port request.
Company Code: Identifies the exchange carrier initiating the transaction.
New Network Service Provider: This field identifies the Number Portability Administration Center (“NPAC”) Service Provider Identifier (“SPI”) of the new provider.
Desired Due Date: Identifies the customer’s desired due date for the port
Purchase Order Number: This field identifies the customer’s unique purchase order or requisition number that authorizes issuance of the request or supplement.
Version: This field identifies the submitting service provider’s order version number and enables service providers to track orders internally and make changes or modifications. In combination with the Purchase Order Number field, this field is used by service providers to track the ongoing progress of the port request and to ensure the correct version of the order is being processed.
Number Portability Direction Indicator: This field lets the new service provider direct the correct administration of E-911 records.
Customer Carrier Name Abbreviation: This three-letter code identifies the company that submitted the Local Service Request (LSR) and the company to whom response messages must be returned.
Requisition Type & Status: This field specifies the type of order to be processed.
Activity: This field identifies the activity involved in the service request.
Telephone Number of the Initiator: This field provides the telephone number for the initiator of the port request.
Agency Authority Status: This field indicates that the customer is acting as an end user’s agent and has an authorization on file. The Commission set no standard form or format for the exchange of these information fields, but left open the possibility that the Commission will take up the issue of standardizing a form for these information exchanges at a later date.
As discussed, the Order also implements a one-business day porting interval for simple ports between service providers. However, service providers should note that the FCC did not apply the one-business day interval to transfers between wireless providers and left unchanged the four business day porting interval for non-simple wireline-to-wireline and non-simple intermodal ports. The Order defines a “business day” as the traditional Monday to Friday work week and the business day as the hours between 8 a.m. and 5 p.m. Under the Order, if an accurate and complete simple port LSR is received by the current service provider between 8 a.m. and 1 p.m. it must be made eligible for activation by midnight of the same day. Any LSRs received after 1 p.m. will be considered received on the next business day. Similarly, the Order sets a 4 business hour interval for responding to a LSR with either a Firm Order Confirmation or a reject, with any LSR received after 1 p.m. considered received at 8 a.m. the next business day. The deadline for implementing the one-business day porting interval is August 2, 2010, while “small providers” must comply by February 2, 2011.[3]
Finally, the Commission adopted binding LNP provisioning flows for the industry. The Order adopts a series of provisioning flows recommended by the North American Numbering Council (“NANC”) consisting of illustrative diagrams and narratives setting forth the specific processes to be used by service providers and administrators, including new flows for determining the type of ports and mandated processes for specific porting scenarios.[4] The mandated provisioning flows also sets the time interval for the current service provider to return a Customer Service Record (“CSR”) at 24 hours, unless otherwise negotiated. Note that these flows apply both simple and non-simple port processes.
Taken together, the Order attempts to streamline the number porting process by imposing greater standardization upon the industry. Telecommunications service providers should take steps to update their operational systems and processes in order to ensure compliance with the FCC’s Order. For further information on this Order and its implications, please contact your Kelley Drye attorney or any member of the Communications Practice Group. For more information on the Communications practice group, please click here.[1]Note that the one-business day porting interval does not apply to transfers between wireless providers.
[2]The Commission has defined a “simple port” as those ports that: (1) do not involved unbundled network elements, (2) involve an account only for a single line, (3) do not include complex switch translations, such as Centrex or ISDN, and (4) do not include a reseller.
[3]“Small providers” are defined by the 2009 LNP Order. The 2009 LNP Order defined “small providers” to mean either: (1) a provider with fewer than 2 percent of the nation’s subscriber lines installed in the aggregate nationwide (as defined in 47 U.S.C. s 251(f)(2)), or (2) a Tier III wireless carriers, as defined in the E911 Stay Order (“CMRS carriers with 500,000 subscribers or fewer”). See Local Number Portability Porting Interval and Validation Requirements; Telephone Number Portability, WC Docket No. 07-244, CC Docket No. 95-116, Report and Order and Further Notice of Proposed Rulemaking, 24 FCC Rcd 6084, Appendix C, para. 2 (2009).
[4]See http://www.nanc-chair.org/docs/mtg_docs/Oct09_LNPA_WG_FCC_09_41_Implementation_Plan_v5.doc (NANC Flows v.4.0 -10-16-2009.ppt and NANC_OPS_Flows_Narratives v4.0 (10-16- 009).doc); see also http://www.fcc.gov/wcb/cpd/Nanc/nanccorr.html.