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NANC Suggests New FCC Nationwide Number Portability Inquiry, Toll-Free Number Changes

Nationwide number portability "is probably the most technically fraught" topic recently referred to the North American Numbering Council, said Chairman Travis Kavulla, in a letter accompanying a NANC report (here). NANC recommended the FCC issue a second NNP notice of inquiry or establish a new advisory body. "Industry is divided on aspects of NNP, and in my opinion this is a topic which requires a clearer regulatory lead," Kavulla said. NNP would let consumers keep phone numbers when switching carriers or moving, outside a local market. Also released late Thursday, another NANC report had recommendations on toll-free number assignment rule changes. The council approved the reports May 29 (see 1805290023).

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A working group reviewing four NNP models "found one to be antiquated," and "was unable to make any conclusive recommendation" on the other three, said Kavulla, Montana Public Service Commission vice chairman, noting the report detailed pros and cons. "Regrettably, the working group was not able to conclude an especially detailed look at the costs of implementing NNP through the various approaches. There are clearly costs that would be incurred by any implementation of NNP, and the report specifies what these might be, without engaging in a calculation of them. Certain NNP models appear nearly inexorably linked to the larger trend of IP interconnection."

"There existed strong, differing opinions" at NANC's May 29 meeting, leading to changes to a draft report, Kavulla said. He said the report suggests considering "adopting partial NNP, with a recognition that as technology replacement proceeds, it will eventually become easier to accomplish the goal of full NNP." The report concludes further inquiry could provide a clearer view of which NNP pathway "may present a clear benefit net of its cost," he said. NANC stands ready to collaborate, but a new referral "would be most productive if it was precisely scoped around certain follow-on work the report suggests," he said.

The report said a new inquiry should focus on possible "regulatory reforms," cost issues, and different approaches, including hybrid solutions and partial NNP. It recommended the FCC's new Office of Economics and Analytics do a detailed cost-benefit analysis on ways to achieve NNP. "Some legacy fixed line switches may be unable to port NNP subscribers," it said. "Service providers interested in serving ported-in NNP subscribers will likely need to operate VoIP or mobile switching equipment or make commercial arrangements with a third party."

Kavulla said the toll-free number report recommends administrative rule changes to "facilitate the efficient transition to a market-based approach for the initial assignment of numbers that are presumed to be 'high value,' such as the 17,000 toll free numbers that have been set-aside in the recently opened 833 [area code]." It notes "potential complications," he said.

"With respect to prohibitions on the hoarding and brokering of toll-free numbers, the report recommends limited revisions" to a brokering rule, the state commissioner said. "These changes would allow for the transfer of a toll-free number or numbers in three specific instances, in lieu of the development of a full-scale, lawful secondary market. ... There is no need for a regulatory set-aside of toll-free numbers for government or non-profit use."