CARRIERS SKETCH LNP CHALLENGES FOR FCC ON TESTING, COORDINATION

AT&T Wireless, Cingular Wireless, Sprint and Verizon Wireless filed replies with the Wireless Bureau late Tues. to a request by Bureau Chief John Muleta earlier this month for an update on LNP implementation efforts. Wireless carriers face a Nov. 24 deadline for implementing LNP in the top 100 markets, while wireline carriers already have that obligation. Muleta asked the companies for implementation updates in certain markets, including testing progress, customer service training and coordination efforts with other carriers. He also said he wanted to arrange site visits to examine implementation efforts with Enforcement Bureau Chief David Solomon. At a news briefing this week, Muleta said that while questions from the wireless industry seeking guidance on LNP implementation would be decided by the Commission before Nov. 24, the agency still expected carriers to meet the deadline (CD Sept 24 p4). One sore point for some companies on how LNP will work has involved intercarrier agreements. Large wireless carriers have argued service level agreements are appropriate, but LECs and some rural telcos contend interconnection agreements are needed. Meanwhile, FCC officials said they want the end-user experience as of Nov. 24 to be seamless for customers who wanted to take their number when switching carriers.

“While Sprint PCS is working toward, and expects to be, LNP ready on November 24, 2003, this does not mean that all customers will be able to port their numbers (whether to or from Sprint) on November 24, or that the process will be error-free from the beginning,” Sprint said. Porting is a bilateral transaction between 2 carriers that have to cooperate to transition a number, it said. “Sprint is receiving mixed cooperation from other carriers, leaving Sprint concerned at the prospects of its ability to port with many carriers on November 24.” The factors that will let LNP occur smoothly -- exchange of porting information between carriers, testing and consumer education -- require Commission action, the carrier said.

“Until the FCC resolves the disputes relating to rate centers and the form of agreement (interconnection vs. service level agreement), Verizon Wireless will have a difficult task in completing porting agreements and testing with wireline carriers,” it said.

Sprint stressed that certain basic information has to be exchanged between the carriers involved in a porting request, including contact names and service provider IDs. Sprint said it had provided this information, which it called trading partner profile, to nearly 600 carriers to which it sent bona fide requests (BFRs) for LNP. In asking them to share such data, Sprint said fewer than 6 of the 600 agreed to do so. It said some refused to recognize its requests or to discuss LNP unless Sprint first agreed to additional “prerequisites” to porting. In a separate letter, Verizon Wireless said many wireline carriers had rejected its valid BFRs or were pressing restrictions to porting that could create hurdles for LNP.

Sprint said prerequisites linked to LNP by other carriers have included: (1) An interconnection agreement, “even though LNP does not change existing interconnection arrangements.” (2) Requiring Sprint to obtain its own set of phone numbers in the rate center. (3) Requiring it to directly interconnect with the carrier in the rate center, even though this isn’t cost efficient because of the small amount of traffic exchanged. Sprint said “full progress” on LNP wasn’t likely until the FCC confirmed that carriers, upon request, had to provide all relevant trading profile information and could not link LNP availability to requirements not covered under FCC rules.

All the carriers expressed frustration at the progress of intercarrier testing. Verizon said it had made progress in training employees to implement LNP: “Verizon Wireless is facing greater difficulty, however, on the intercarrier front with testing and coordination, particularly with wireline carriers. Until the FCC resolves the disputes relating to rate centers and the form of agreement (interconnection vs. service level agreement), Verizon Wireless will have a difficult task in completing porting agreements and testing with wireline carriers.”

Cingular told the Wireless Bureau it had initiated contacts and negotiations for porting with major wireline carriers, including Alltel, BellSouth, Qwest, SBC, Sprint and Verizon. “To date, these negotiations are not complete,” it said. Cingular said it had started, but not yet completed, intercarrier testing, but planned to do so by Nov. 24.

AT&T Wireless (AWS) said it had made “extensive efforts” to coordinate with wireline carriers on porting, including negotiating or “attempting to negotiate” intercarrier agreements on the business arrangements and communications processes for LNP. The company said it also had been in talks on testing issues with such carriers. “However, AWS has been unable to negotiate successfully a single agreement with a wireline carrier.” The reasons have varied from carrier to carrier, it said. “It is abundantly clear to AWS that as a general matter, wireline carriers have no interest in negotiating to resolve issues in these agreements,” AT&T Wireless said. Two key obstacles AT&T Wireless said it faced in reaching LNP agreements with wireline carriers had been: (1) The latter’s insistence that porting be limiting to cases in which a subscriber still had a geographic link to the rate center. (2) The “constant shifting” of some LECs’ position as to what form an LNP pact should take. AT&T Wireless identified all the wireline carriers with which it had tried to negotiate LNP agreements, including AT&T, BellSouth, Comcast, Cox, Qwest, SBC, Sprint, Time Warner and Verizon. In the case of Verizon, it cited a “constant change in positions regarding [the] form of agreement to negotiate.”