1、 ATIS-0300069 REPORT ON UNASSIGNED NUMBER PORTING (UNP) Reissued with the resolution of Issue 177 or 2) to allow a service provider to establish a presence within a rate area (footprint). Both of these applications rely on the use of numbering resources from another SP and presume that the request c
2、an be met with less than a full NXX or, in a pooled area, less than a thousands-block. UNP is being proposed as an alternative method of obtaining numbering resources even if full NXXs or thousands-blocks are available from the NANPA or the PA respectively. 3.0 BACKGROUND Below is a brief summary of
3、 the past industry work on UNP and FCC references to unassigned number porting in FCC Orders. 1This concept does not change how carriers become LNP capable or how numbers are used within rate area boundaries. 3.1 A CHRONOLOGY OF INDUSTRY WORK ON UNP 3.1.1 North American Numbering Council LNPA Techni
4、cal NPAs in jeopardy; and, especially relevant, NPAs that have exhausted. 6.1.3.2 Competitively Neutral Access To Numbering Resources Competitive local exchange carriers are likely to be both those seeking resources for a footprint in a rate area as well as those with an initial fill rate among thei
5、r number resources which is lower than that of historical carriers. This means that there is every reason to expect that UNP transactions, especially for footprint requests, will often occur between newer market entrants. Transactions between a customers current carrier and that customers previous c
6、arrier for additional number resources which bear a relationship to those that have already been assigned are a logical and necessary extension of Local Number Portability (LNP) which made it possible to change carriers without changing numbers. In such a scenario, if current carriers cannot have ac
7、cess to numbers requested by the customer, assuming those numbers are available, then LNP has not achieved its public policy goal. In addition, customers may seek to trial service with a carrier other than their current service provider, but contingent upon the trial being offered with numbers withi
8、n their current range. UNP has the potential to transform carriers from resource owners wielding a weapon in the marketplace into custodians of a public resource. 6.1.3.3 UNP Satisfies Customer Needs As suggested in the paragraph preceding, UNP plays an important role in enabling carriers to satisfy
9、 customer needs for specific numbers. As a specific policy, customer specific requests may be made for any number or set of numbers which a customer could be assigned if the customer were being served by the service provider in whose inventory the resources are held. Although third in this list, sat
10、isfying customer needs is the only path to a competitive telecommunications environment. UNP is premised on the notion that a consumers choice of service providers should not be based on carriers having differing access to numbering resources because telephone numbers are a public commodity. If cust
11、omers must shop among carriers based on the carriers varying access to numbering resources, LNP has failed, and the effort and expense incurred to achieve a more level competitive playing field was wasted. 6.1.3.4 UNP Technology Is Here The technology to deploy UNP exists already as do the administr
12、ative systems to handle number transfers between carriers. Both were developed and deployed for Local Number Portability. UNP simply involves porting a local number not presently assigned to a customer. Although critics suggest that UNP will increase the volumes associated with LNP systems, supporte
13、rs point out that UNP simply makes good use of costly technology the industry has deployed. While the technology and administrative systems are already in place, effective use of UNP will almost certainly require a regulatory mandate to end the privatization of numbering resources. Thoughtful regula
14、tory management will be important in getting UNP off on the right foot. 6.1.4 Conclusion Public policy directed at optimizing the utilization of numbering resources is incomplete without the availability of Unassigned Number Porting. UNP provides a means of sharing numbering resources required below
15、 the thousands-block level without abandoning the concept of inventories to provide timely customer satisfaction. It completes the process begun by Local Number Portability of removing access to numbering resources as a barrier to competition. It meets customers specific needs. Its potential as a nu
16、mber conservation tool promises to defer substantially the need to expand the NANP. The need to implement UNP quickly is urgent, in view of recent estimates of NANP exhaust. Consequently, those who support UNP urge adoption of a limited administrative apparatus in order to speed implementation as we
17、ll as contain the already punitive expense of opening the local market (e.g. LNP). The service providers who support Section 6.1 and recommend prompt deployment of UNP include AT and (2) constitutes an unnecessary expense to both carriers and end users. With inter-carrier ordering and porting proces
18、s preserved as proposed in this approach, existing systems and porting processes are deemed sufficient. Thus, UNP can be implemented through a one-on-one relationship between carriers, much the same as Resale, Unbundled Network Element utilization, Network Interconnection for mutual traffic exchange
19、, and Local Number Portability are being conducted. A third party administrator is not needed for either the Footprint or Customer Specific UNP-type request. Administration can be accomplished between carriers just as LNP administration is accomplished today. While some might argue that this form of
20、 UNP places carriers back into the role of number administration because one SP is relying upon another for footprint numbering 2The approach in this section is consistent with the WorldCom and WorldCom/Cox portions of the NANC UNP Business Rules developed by the UNP Ad-Hoc committee (contribution L
21、NPA-342). resources, this proposal recognizes that the FCC did not place limits on UNP in its NRO Order (CC Docket, 99-200, Order 00-104) because of this concern. Instead, the FCC expressed interest in the UNP processes. Because this approach relies upon carrier interaction to supply an arguably sma
22、ll supply of numbers, and not to satisfy all forms of resource requests (i.e., all needs for all SPs), this approach does not derive the need for demonstrating need of resource as similarly required for NXX code or thousands block requests. Therefore, the requesting carriers UNP request based upon t
23、heir certification of need, for either a footprint need, or to meet a specific customer request, offers the potential for making more efficient use of numbers that might otherwise remain unused in another carriers inventory. Such an advantage, that overcomes the otherwise required need for an NXX co
24、de or thousands block request, can be seen as a benefit. A third party administrator is also argued in this approach as not being required because audits can be relied upon if there is a need to ensure compliance. Audit tests, if deemed necessary by regulators, can be designed and used to ensure car
25、rier compliance with processes once they are established and uniformly accepted or mandated. Disputes between carriers can be resolved using existing means; problem escalation processes, existing dispute resolution procedures, or by state regulators. In addition, limiting the total number of telepho
26、ne numbers per request as proposed herein, is a self governing mechanism that in of itself promotes smaller volumes of requests, creates simplicity and negates the significant costs associated with a third party administrator. Moreover, certain parties have demonstrated the feasibility of this appro
27、ach by conducting and reporting to industry concerning the success of a trial to prove the concept indeed functions as asserted. Functional Description The following is a high level description of the UNP process without an administrator. 1. Upon determination for the need of a footprint in a rate a
28、rea for which the carrier is certified but has no resources and the current need for resources is small, or the carrier receives a request by one of its customers for numbers that the carrier does not have but are available from another carrier, the carrier with the need for numbers submits a UNP re
29、quest LSR; 2. The donor carrier receives the request and responds concerning the availability of the numbers; 3. LNP porting now proceeds as normal; 4. When confirmed available, the requesting carrier submits a “create” message to the NPAC; 5. Optionally, the donor carrier confirms the pending creat
30、e subscription version in the NPAC; 6. On the due date, the requesting carrier “activates” the telephone number; 7. Testing is performed to ensure that the numbers have been effectively ported. 7.1.2 Types of UNP Requests UNP requests may be made by a carrier to establish a footprint in a rate area
31、or to meet a specific customer request. Footprint requests are made to establish carrier presence in a rate area and are limited to one request per rate area. Subsequent or greater needs than the volume allowed for UNP requests, should be met by obtaining blocks or codes. Examples of footprint reque
32、sts are: Any Number/Range of Numbers within rate area Any Number/Range of Numbers within specific NPA and rate area Customer specific requests may be made for any number or set of numbers a customer could be assigned if served by the carrier in whose inventory the resources are held. Customer specif
33、ic requests have the following attributes: 10-digit number(s) Any Number/Range of Numbers within NPA-NXX Any Number/Range of Numbers within specific NPA and rate area Customer-specific requests may have the purpose of the end-user seeking to grow the quantity of numbers from those numbers previously
34、 ported, or to enable a service “trial” with another carrier using a number range requested by the end-user. Requesting SP Donor SP NPAC SMS 12 3, 4, 6 5 7.1.3 Quantities of UNP Requests Footprint requests are limited to 25 numbers on a one-time basis. Although Customer-specific requests in principl
35、e should only be limited in theory to the constraints applicable to quantities of numbers customers would be able to obtain from any potential donor and any appropriate demonstration of need, for the sake of simplicity these requests should be limited to 25 TNs until more experience with UNP is gain
36、ed. 7.1.4 Qualification for Submitting UNP Requests Requests for footprint resources must meet the FCCs criteria for resource assignment (certification and ability to serve). Carriers submitting UNP footprint requests shall certify to the donor that they are authorized to provide service and do not
37、have existing resources in the given rate area. The requesting carriers submission of a request also satisfies that they are able to port and place the numbers into use upon their receipt. A donor carrier may consult the LERG if they chose to determine if the requesting carrier has resources in the
38、rate area requested. Although it may be argued that a carrier might submit multiple footprint requests to multiple carriers at the same time, this method discourages that potential because of the low quantity of TNs per request. This limitation serves as a throttle for those carriers that might othe
39、rwise seek to gain advantage in the marketplace. The work effort involved to port the numbers in such small quantities motivates parties to abide by the process. Needs for larger quantities than 25 numbers would be motivated to request pooled thousands blocks or NXX codes. Carriers submitting UNP Cu
40、stomer-Specific requests shall only submit requests to meet their customer needs. Customer specific requests will not be used to build inventory or to allow numbers to be requested in anticipation of customer requests. Upon request, the identity of the requesting end-user will be provided by the req
41、uesting carrier when the UNP request is made. 7.1.5 Donor Identification Carriers submitting UNP requests pursuant to the footprint case where there is a single donor carrier in the rate area, or when the customer-specific request is for a specific number(s) or a specific NPA-NXX (i.e., single donor
42、) will identify LNP-capable resource holders in the LERG. The process for determining the donor carrier in multiple donor footprint or customer-specific scenarios shall be resolved by conducting an impartial round robin. The following guidelines could be used to implement this process to determine t
43、he UNP donor: (1) decisions by states regulators many of which are proactive in number optimization efforts; or (2) round robin list maintained by NANPA or Pooling Administrator for the rate area. Either of these entities would satisfy as the party to resolve the UNP request to a single donor. An in
44、formal list maintained by the requesting carrier of previous requests to carriers, starting by alphabetical order could also suffice. Finally, for the customer specific scenario, the end-user could be asked to select from the potential list of donor carriers when the request is for a number or range
45、 of numbers within a specific NPA and rate area. The round robin approach performed by the state regulator, the NANPA, or the pooling administrator negates any concern that might be raised about being the recipient of simultaneous requests to other donors. This proposal ensures that only one donor i
46、s identified per request. This assurance then, removes the uncertainty about the genuineness of the request that then places an obligation upon the donor to comply. 7.1.6 Processing UNP Requests Carriers shall submit UNP requests and respond by using existing Local Service Requests (LSR)/Firm Order
47、Confirmation (FOC) forms and porting processes.3Requesting carriers shall also, as necessary, provide documentation as described in Section 7.1.4 above to verify the request. A single LSR is issued for a footprint UNP request. For customer-specific UNP requests, two LSRs will be issued: a “reservati
48、on” LSR is sent to determine whether the number is available, and a porting LSR is then used to initiate the standard porting process. UNP-specific annotations in the Remarks section will specify the details of the request, whether a specific 10-digit number, a range of numbers within a specific NPA
49、-NXX, or any numbers within an NPA and rate area. The Remarks/Comment field should also contain the tracking number associated with a UNP reservation. Carriers shall respond to the LSR within 24 hours and, if numbers are available, adhere to the standard porting process and intervals. Donors should not refuse requests unless numbers requested are not available or the donor faces imminent exhaust of its inventory and growth resources are not available. All parties to UNP transactions shall maintain the documentation associated with all transfers for reference and potentia
