*Pages 1--37 from  C:\Pdf2Text\Ready4Text_in\pdf\42419.pdf*
 North  American  Numbering  Council  c/  o  Columbia  Institute  for  Tele-  Information 
 Columbia  Business  School  1A  Uris  Hall 
 3022  Broadway  New  York,  NY  10027-  6902 

 May  3.2004 
 RECEIVED 

 Mr.  William  Maher  Chief,  Wireline  Competition  Bureau 
 Federal  Communications  Commission  445  Twelfth  Strtct,  S.  W. 
 Washington.  D.  C.  20554 

 Re:  Intermodal  Porting  Intervals 
 Dear  Mr.  Maher: 
 On  November  10,2003,  the  FCC  asked  the  North  American  Numbering  Council  (NANC)  to  consider  the  implications  of  reducing  the  interval  of  time  required  to  port 
 telephone  numbers  between  wireline  and  wireless  service  providers  (  in1exmodal  porting).  NANC  quickly  formed  an  Issues  Management  Group  (IMG)  to  prepare  a 
 response  to  the  Commissions  request.  The  IMG,  under  the  leadership  of  NANC  Vice  Chair  Hoke  b  o  x  ,  devoted  considerable  time,  talent  and  other  resources  over  the  last  four 
 months  (an  estimated  2,000  work  hours)  to  the  production  of  a  comprehensive  Report  &  Recommendation. 

 Attached  is  the  Report  &  Recommendation  on  Intennodal  Porting  Intervals  which  was  adopted  by  NANC  during  a  duly  noticed  telephone  conference  call  meeting  earlier  today. 
 The  report  makes  some  specific  recommendations  for  a  porting  procedure  which  would  shorten  the  porting  times  and  it  also  identifies  a  number  of  additional  issues  which  need 
 to  be  addressed  by  the  industry  and  regulatory  bodies. 
1
 If  you  have  any  specific  questions  about  the  substance  of  the  Report  &  Recommendation,  I  would  suggest  that  you  contact  Mr.  Knox  at  (913)  315-  9060. 
 Sincerely,  .A 
 I 

 Robert  C.  Atkinson  Chairman 

 Attachment 
 cc:  NANC  Members  (wlout  attachment)  Carol  Mattey  -  FCC 
 Eric  Einhom  -  FCC  Cheryl  Callahan  -  FCC 
 Sanford  Williams  -  FCC  Deborah  Blue  -  FCC 

 2 
 I  1 
2
 NANC  Report  &  Recommendation  on  Intermodal  Porting  Intervals 
 May  3,2004 
 Prepared  for  the  NANC  by  the 
 Intermodal  Porting  Interval  Issue  Management  Group 

 I  I 
3
 NANC  Report  on  the  Intermodal  Porting  Interval  May  3,2004 
 1. 
 2. 
 3. 

 4. 

 5. 
 6. 
 7. 

 8. 

 9. 

 BACKGROUND  ..........................  ,  ....................  ....  .............................................................  ...  4 
 MAC  PORTING  PROCESS  ............................................................................  ..  ................  5  Control  of  Activation  Date  Ultimately  Rests  with  the  NNSP  ................................................  6 

 WIRELINE  PORTING  INTERVAL  ...............................................................  ..  ...........  -...  6  6  LSWort  Response  Process  ................................................................................................... 
 8  Wireline  Porting  Process  ...................................  .............................  .  .......................  .  ..............  . 
 WIRELESS  PORTING  INTERVAL  ..................  .  ....................................  .  ...................  ....  11 

 Ten-  Digit  Trigger  ...................................................................................................................  7 

 Port  Request  and  Response  Process  ......................................................................................  11 
 ASSUMPTIONS  .................................................................................................  .  ..............  12 
 DISCUSSION  QUESTIONS  ....................................................................  .  ........  ...  .......  ......  12  A.  What  were  the  reasons  the  four  business  day  interval  was  initially 
 12  introduced?  ....  .  .  .  ..  .  .  .  .  .  ..  .  .  ..  .  .  .  .  ..  .  ..  .  ..  .  .  .  .  ...  .  .  ..  ....  .  .  .  ..  ,  ..  ..  .  .  .  ..  .  ...  .  ..  .  ..  ...........  ..  .  .  ....  .  .................... 
 B.  What  might  apply  to  the  intermodal  port?.............................................................  14  C.  Should  the  1MG  examine  the  costs,  benefits,  and  methodologies  involved  h 

 reducing  the  fourday  interval  and  define  a  reasonable  transition  period?  ........  14 
 PROPOSALS  ....................................................................................................................  ..  15  Proposal  C1-  (Port  request  and  port  response  within  1  hour)  (port  response 
 is  either  Port  Response  or  Port  Denjal  within  one  hour)  ......................................................  15  Proposal  C2  -  (Mechanized  port  request,  reduced  Port  Response  interval  Activation 
 16  interval  remains  3  days)  ....................................................................................................... 
 Proposal  AI  -  (2  Day  Port  Activation  After  Port  Response)  (New  W  A  C  timers  16  for  simple  internodal  ports)  ..................  ......................................................  -  .......................  . 

 Proposal  A2  -  (2  Day  Port  Activation  -  Shortened  Existing  Timers)  ................................  17  Proposal  A3  (Adapted  from  WirelesdWireline  Integration  Reports)  ..................................  18 

 21  IMG  ANALYSIS  ...................................  .............  .  .....  ........................................................  21  Proposal  Analysis 
 ...........................................................................  .  .................  ....................  Work  Steps  Required  Implementing  a  Shorter  Internodal  Porting  Interval  ........................  22 

 22  NPAC  Changes  ................................................................  ..  ..............  .  ..........  ...  .....  ................- 
 91  1  Impacts  -  Internodal  Porting  Interval  Change  ..............................................................  23 
 Carrier  Operational  Support  Systems  Impactskhanges  .......................................................  23  Cost  Recovery  ......................................................................................................................  24 

 Rural  Telephone  Company  Impacts  .....................................................................................  25 

 Page  2  of  35 
 1  1  , 
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 NANC  Report  on  the  Intermodal  Porting  Interval  May  3.  2004 
 TABLE  OF  CONTENTS  (Cont'd) 
 10  .  ADDITIONAL  CONSIDERATIONS  ..............................................................................  25  NANC  Flows  ........................................................................................................................  25 

 Further  Analysis  25  Existing  Intermodal  Issues  Not  Yet  Analyzed  vis-  a-  vis  Proposals  By 
 LNPA-  WG  .............  25 

 Inadvertent  Ports  ..................................................................................................................  25 

 SP  Operational  Systems  Issues  Warranting  Further  Analysis  To  Verify  Feasibility  ...........  27  State  Regulatory  Issues  That  Need  to  Be  Addressed  to  Ensure  Parity/  Compliance  ............  28 
 Need  for  Simple  Intermodal  Data  ........................................................................................  28 

 ................................................................................................................... 

 One  Local  Service  Ordering  Guideline  (LSOG)  Version  for  Porting  ..................................  27 
 11  . 
 12  . 
 13  . 
 14  . 

 FINDINGS  AND  CONCLUSION  ....................................................................................  29 
 RECOT+  fMJINDATIONS  .........................................................  .........................................  30 
 GLOSSARY  .........................  ..  .....................................................................  -  ......................  32 
 NANC  INTERMODAL  PORTING  INTERVAL  IMG  PARTICIPANTS  ...................  34 

 Page  3  of  35 
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 NANC  Report  on  the  Intermodal  Porting  Interval  May  3,2004  ' 
 1.  EXECWIVESUMMARY 
 The  Federal  Communications  Commission  (FCC),  on  November  10,2003,  asked  the  North  American  Numbering  Council  (NANC)  to  provide  input  on  reducing  the  porting  interval 
 for  intermodal  porting.  The  FCC  asked  the  NANC  to  also  include  corresponding  updates  to  the  NANC  LNP  process  flows  and  provide  any  recommendations  on  an  appropriate 
 transition  period.  The  NANC  should  also  provide  its  recommendations  promptly  as  the  FCC  intends  to  review  the  record  and  address  the  porting  interval. 

 In  evaluating  six  proposal  combinations,  the  IMG  agreed  that  two  procedures  hold  particular  promise.  Orders  received  in  a  mechanized  manner  should  be  responded  to  in  five 
 hours  or  less  (proposal  C2).  Ten  Digit  Triggers  should  be  set  a  full  day  before  12:  Ol  AM  of  the  confirmed  due  date  (proposal  A3).  This  combination  offers  the  shortest  "maximum 
 porting  interval"  (53  hours)  and  greatest  time  reduction  in  hours  (43)  for  the  "Low"  estimated  cost  impact.  The  NANC's  Issue  Management  Group  (IMG)  Proposal  Analysis 
 indicates  that  there  are  no  cost  impacts  on  batch  processes,  complex  changs  to  SP  programming,  changes  to  existing  NPAC  timers,  or  NPAC  software  changes.  Thus,  this 
 proposal  combination  could  offer  the  most  economical  opportunity  for  the  industry  to  substantially  reduce  the  porting  interval  for  consumers. 

 In  summary,  the  LMG  considers  the  CUM  proposal  the  most  promising  and  recommends  that  the  NANC  forward  this  document  to  the  FCC  and  ask  that  the  appropriate  industry  and 
 regulatory  bodies  be  given  additional  time  necessary  to  prepare  a  complete  analysis  of  this  alternative.  Section  10  titled  "Further  Considerations"  identifies  issues  not  addrcssed  by  the 
 IMG.  Although  some  of  these  issues  are  being  addressed  by  the  LNPA-  WG,  Section  10  identifies  additional  issues  that  may  impact  the  implementation  of  proposal  CZA3  and 
 therefore  further  analysis  by  Service  Providers  and  Regulators  is  warranted  before  a  decision  is  made  to  implement  CUA3.  The  IMG  would  like  to  note  that  this  report  has  not 
 been  evaluated  by  the  NANC's  LNPA-  WG  and  that  the  IMG  did  not  attempt  to  determine  if  the  CWA3  proposal  achieves  the  customer  benefits  desired  by  the  FCC. 

 Based  upon  known  information  at  this  time,  the  IMG  estimates  that  the  indusw  would  need  approximately  24  months  to  implement  the  C2  proposal  after  an  FCC  mandate  is 
 issued.  In  addition,  to  the  extent  that  LNP-  capable  switches  are  already  provisioned  with  the  10-  digit  uigger,  proposal  A3  could  be  implemented  more  quickly. 

 2.  BACKGROUND 
 In  CC  Docket  95-  1  16,  FCC  03-  284  released  November  10,2003  the  FCC  asked  for  "comment  on  whether  we  should  reduce  the  current  wireline  four  businessda  porting 
 interval  for  intermodal  porting.  If  so,  what  porting  interval  should  we  adopt"? 
 The  FCC  also  asked  for  comment  on  "whether  adjustments  to  the  NPAC  processes.  including  interfaces  and  porting  triggers,  would  be  required.  In  addition,  we  seck  comment 

 Y 

 CC  Docket  95-  1  16,  FCC  03-  284  released  November  10.2003  49  I 
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 8  , 
 NANC  Report  on  the  Intermodal  Porting  Interval  May  3,2004 

 on  the  risks.  if  any,  associated  with  reducing  the  porting  interval  for  intermodal  porting.  W  e  seek  comment  on  an  appropriate  transition  period  in  the  event  a  shorter  porting  interval  is 
 adopted,  during  which  time  carriers  can  modify  and  test  their  systems  and  pro~  edures.~ 
 The  FCC  asked  the  North  American  Numbering  Council  (NANC)  to  provide  input  on  reducing  the  porting  interval  for  intermodal  porting.  The  NANC  should  also  include 
 corresponding  updates  to  the  NANC  LNP  process  flows  and  provide  any  recommendations  on  an  appropriate  transition  peri~  d.~ 

 The  FCC  indicated  that  [  rleducing  the  porting  interval  could  benefit  consumers  by  making  it  quicker  for  consumers  to  port  their  numbers.  To  that  end,  wireless  caniers  intend  to 
 complete  intermodal  wireless  ports  within  two  and  one-  half  hours.  There,  however.  may  be  technical  or  practical  impediments  to  requiring  wireline  carriers  to  achieve  shorter 
 porting  intervals  for  intermodal  porting.   
 On  December  22,2003,  the  NANC  met  via  conference  call  and  formed  the  Internodal  Porting  Interval  Issues  Management  Group  (IMG)  to  address  the  above  issues  for  the  FCC. 

 3.  WAC  PORTING  PROCESS 
 The  Number  Portability  Administration  Center  (NPAC)  porting  process  is  the  same  for  wireless  and  wireline,  except  that  the  wireless  Initial  Concurrence  Window  f  l  l  timer)  and 
 Final  Concurrence  Window  (  2  timer)  are  1  business  hour  instead  of  9  business  hours. 
 Also,  the  NPAC  SMS  business  hours  are  different  and  occur  7  days  a  week  rather  than  just  Monday  through  Friday  as  is  the  case  for  the  wireline  timers.  The  Conflict  Resolution  (6 
 business  hours)  and  Initial  Cancellation  (9  business  hours)  and  Final  Cancellation  (9  business  hours)  timers  are  the  same  but  likewise  run  in  different  time  periods  and  days. 

 lbid.  150  Ibid.  951 
   Ibid.  149  There  is  one  other  small  difference:  For  the  wireline  family  of  timers,  there  is  a  p  i  n  t  relative  to  the  due  date  beyond  which  a  pending  SV  (Subscription  Version)  cannot  be  placed  into  conflict.  There  is  no  conespnding 

 limitation  for  the  wireless  family  of  timers. 
 (1.)  If  both  SPs  have  sent  their  create  messages  to  NPAC.  and  the  old  SP  create  message  had  its  concmm  flag  set  to  true  then  the  WAC  timers  become  moot;  they  would  have  no  impact  on  the  activation  so  it 
 wouldnt  matter  that  they  were  wireless  timers. 
 6 

 (2.)  While  the  two  families  of  NPAC  timers  often  are  referred  to  as  the  wireline  and  the  wireless  timers,  the  timers  used  for  a  carrier  are  based  on  an  SPs  WAC  profile.  i.  e.,  what  the  SP  tells  WAC  it  wants 
 determines  which  set  of  timers  is  used;  it  is  not  based  on  what  type  of  carrier  is  involved.  In  facI,  some  rural  wireless  carriers  have  elected  h  e  wireline  timers  for  Ihei  port-  out  and  port-  in  timers. 

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 NANC  Report  on  the  Intermodal  Porting  Intend  May  3,2004 
 3.  WAC  PORTING  PROCESS  (Contd) 
 Control  of  Activation  Date  Ultimately  Rests  with  the  NNSP 
 The  due  datdtime  entry  must  be  the  same  on  the  old  SP  create  and  the  new  SP  create.  When  the  WAC  is  satisfied  that  a  match  exists,  the  T  1  m  timer  sequence  stops  (if  the 
 timers  have  not  already  expired). 
 Once  the  NPAC  has  verified  this  match,  either  SP  can  modify  its  entry  in  the  due  datdtime  field  without  concern  about  continuing  to  match  the  other  SPs  due  datdtime  entry.  The 
 NPAC  does  not  require  either  SPs  due  datdtime  change  to  be  agreed  to  by  the  other  SP. 
 Later,  when  the  new  SP  activates  the  pending  Subscription  Version  (SV),  the  WAC  uses  the  due  datdtime  shown  on  the  new  SPs  create  message  to  determine  whether  it  is  too 
 soon  to  permit  the  activation  to  occur. 
 If  the  new  SP  alone  has  sent  a  Create  message  to  the  NPAC,  the  due  date  value  still  could  be  modified  with  no  action  required  of  the  old  SP.  However,  the  T1  and  T2  timers  still 
 must  run  their  course  before  activation  could  occur.  since  there  is  no  Create  message  from  the  old  SP  to  indicate  its  concurrence  with  the  port. 

 4.  WIRELINE  PORTING  INTERVAL 
 The  current  industry  agreed  porting  interval  for  wireline  service  is  four  (4)  days  for  simple  ports.  T  h  i  s  includes  a  maximum  of  one  (1)  day  for  the  exchange  of  the  Local  Service 
 Request  (LSR)  and  the  Firm  Order  Confirmation  (Port  Response)  between  the  old  service  provider  and  the  new  service  provider,  and  three  (3)  days  to  accomplish  the  port  of  the 
 telephone  number  from  the  old  service  provider  to  the  new  service.  provider. 
 LsRlport  Response  Process 
 When  a  customer  decides  to  port  their  number  the  new  service  provider  collects  information  from  the  customer  that  is  necessary  for  porting.  The  informdon  gathered  is 
 used  by  the  new  service  provider  to  prepare  a  LSR  that  is  sent  to  the  old  service  providm.  The  LSR  is  an  industry  standard  form  developed  by  the.  Ordering  &  Billing  Forum 

 The  maximum  one  (1)  day  LSRlPort  Response  process  requires  that  the  new  service  provider  and  the  old  service  provider  exchange  information  and  agree  on  a  due  date  to  port 
 the  customer.  Typically,  the  new  service  provider  will  send,  via  FAX  or  elcctroically,  a  LSR  to  the  old  service  provider  with  the  customer  information,  details  on  the  port  and  the 
 requested  due  date.  The  old  service  provider  has  24  hours  to  verify  the  information  on  the  LSR  and  to  respond  to  the  new  service.  provider  with  a  Port  Response  which  will  contain  an 
 agreed  upon  due  date  and  confirm  that  the  information  on  the  LSR  is  correct.  Factors  such  as  the  quantity  of  telephone  numbers  being  ported,  type  of  service  impacted,  use  of  the 
 Unbundled  Network  Elements  (UNE)  or  the  involvement  of  resellers  will  help  determine  the  actual  due  date  of  the  port. 

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 NANC  Report  on  the  Intermodal  Porting  Interval  May  3,2004 
 4.  WIFtELINE  PORTING  INTERVAL  (Cont'd) 
 LSRmort  Response  Process  (Cont'd) 
 If  the  LSR  information  is  not  correct,  the  old  service  provider  will  clarify  the  request  and  steps  will  be  taken  to  resolve  the  problem. 

 The  exchange  of  the  LSR  and  the  Port  Response  between  the  old  and  new  service  providers  indicates  agreement  that  the  number  can  be  ported,  and  it  indicates  the  date  on  which  the 
 port  is  expected  to  occur. 
 Ten-  Digit  Trigger 
 The  unconditional  ten-  digit  trigger  (TDT)  is  a  central  office  software-  switching  feature  optionally  assigned  to  a  number  on  a  donor  switch  during  the  transition  period  when  the 
 number  is  physically  moved  from  donor  switch  to  recipient  switch?  The  feature  forces  the  switch  to  search  the  L"  database  on  every  call  to  determine  if  the  database  has  been 
 updated  with  new  LhT  routing  instructions. 
 The  setting  of  the  TDT  causes  the  switch  to  query  the  appropriate  LNP  network  database  for  calls  to  the  applicable  TN,  and  eliminate  some  of  the  close  co-  ordination  needed 
 between  the  Old  Network  Service  Provider  (ONSP)  and  New  Network  Service  Provider  (NNSP)  during  the  completion  of  the  porting  process  by  eliminating  the  need  for  the  donor 
 switch  disconnect  to  take  place  simultaneously  with  WAC  activation. 

 The  unconditional  TDT  forces  a  query  to  the  provider's  LNP  database  on  calls  originating  from  the  ONSP  switch  and  allows  the  TN  to  be  resident  in  both  the  ONSP  and  NNSP 
 switches  during  the  porting  interval  while  ensuring  that  calls  complete  properly.  8 
 In  essence,  the  Ten  Digit  Trigger  forces  the  donor  switch  (the  switch  out  of  which  the  code  is  to  be  ported)  to  query  the  database  for  possible  porting  before  completing  the  call. 
 Without  the  Trigger  the  donor  switch  would  find  the  number  to  be  working  in  its  own  tables,  and  the  donor  switch  would  not  perfom  the  query.  This  trigger  is  typically  set  in 
 the  ONSP  switch  no  later  than  the  day  bcfore  the  due  date  of  the  port. 

 The  10  Digit  Trigger  shall  be  operational  no  later  than  1159PM  in  Lhe  donor  switch  (ONSP)  the  day  prior  to  the  anucipaced  pon-  out  date.  1 
 '  NNSP  may  a~  so  use  TDT  in  pe-  provisioning  based  on  the  process  flows. 

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 NANC  Report  on  the  Intermodal  Porting  Interval  ,.  May  3,2004 
 4.  WIRELINE  PORTING  INTERVAL  (Contd) 
 Wireline  Porting  Process 
 A  minimum  three  (3)  day  porting  interval  is  the  agreed  upon  interval  for  wireline  carriers  to  perform  system  updates  and  the  physical  work  required  to  complete  a  simple  port  once  the 
 LSRlPort  Response  process  is  complete.  Factors  such  as  the  quantity  of  numbers  being  ported,  type  of  service  impacted,  use  of  the  Unbundled  Network  Elements  (UNE),  loop 
 facilities  or  the  involvement  of  resellers  may  result  in  the  porting  process  to  be  longer  than  three  days. 

 After  the  new  SP  receives  the  Port  Response,  the  new  SP  sends  a  create  message  to  the  WAC.  The  message  indicates  the  telephone  number  being  ported,  the  new  call  routing 
 information  for  this  number,  the  agreed  upon  due  date,  and  the  NPAC  SPID  of  the  old  SP  and  new  SP?  If  there  is  no  corresponding  create  message  at  WAC  from  the  old  SP,  the 
 NPAC  notifies  the  old  SP  that  a  port  is  pending.  The  WAC  starts  its  T1  timer.  Note  that  the  old  SP  create  message  is  optional  in  this  process. 

 The  T1  timer  runs  for  9  WAC  business  hours,  that  is.  between  the  hours  of  7  a.  m.  and  7  p.  m.  Central  time,  Monday  through  Friday.  If  the  old  SP  has  not  sent  its  create  message  by 
 the  time  T1  expires  and  T2  begins,  then  another  notification  is  sent  to  the  old  SP.  For  the  case  where  it  is  the  old  SP  who  has  sent  its  create  message  to  the  NPAC  first,  the  new  SP 
 may  elect  to  receive  these  same  notifications. 
 Regardless  of  which  SP  sends  its  create  message  first,  once  the  NPAC  receives  a  matching  create  message  from  both  SPs,  the  timers  become  moot.  (A  matching  create  message 
 means  that  the  telephone  number,  due  date,  and  the  old  and  new  SPs  NPAC  Service  Providers  IDS  (SPlDs)  are  the  same  in  both  create  messages.)  Until  both  the  TI  and  Tz 
 timers  expire,  or  are  mooted  by  receipt  of  both  SPs  create  messages,  the  new  SP  cannot  activate  the  pending  port.  If  either  the  T2  timer  expires  or  the  old  SP  concurs  before  the 
 due  date,  the  new  SP  still  must  wait  to  activate  the  port  until  the  due  date  is  reached.  The  due  date  can  be  changed  by  the  new  SP,  incidentally,  provided  both  SPs  have  sent  their 
 create  messages  to  NPAC. 

 Due  date  is  a  timestamp  field  with  the  format  MMDDYYYYHHMMSS.  All  digits  are  q  u  a  .  lndushy  agreement  is  that  the  seconds  portion  is  always  00.  For  a  wireless  Crsate.  MM  is  the  agned  upon  lime.  For 
 a  wireline  Create,  typically.  the  MM  is  populated  with  oo00.  but  this  is  not  necesssrily  r~  quirrd. 

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 NANC  Report  on  the  Intermodal  Porting  Interval  May  3,2004 
 4.  WIRELINE  PORTING  INTERVAL  (Contd) 
 Wireline  Porting  Process  (Contd) 
 I  the  old  SP  sends  a  create  message  to  WAC,  it  must  include  an  explicit  indication  of  concurrence  or  objection  to  the  port.  If  the  old  SPs  create  message  indicates  objection  -- 
 the  concurrence  flag  is  set  to  false  -  then  the  pending  port  is  placed  into  a  conflict  state.  When  this  occurs,  the  NPAC  starts  a  conflict  resolution  window  timer  during  which  only 
 the  old  SP  can  remove  the  pending  port  from  conflict.  After  the  conflict  resolution  window  timer  expires,  either  SP  can  remove  the  pending  port  from  conflict.  The 
 conflict  resolution  window  timer  runs  only  between  7  a.  m.  and  7  p.  m.  Central  time,  Monday  through  Friday.  Conflict  can  be  invoked  after  the  create  is  sent.  Conflict  can  be 
 invoked  repeatedly,  but  the  conflict  concurrence  window  occurs  only  the  first  time  a  conflict  is  invoked. 

 Upon  receipt  of  the  activate  message,  the  MAC  determines  that  the  pending  port  is  not  in  conflict  and  that  the  T1-  T2  timers  are  not  still  in  play,  and  then  broadcasts  the  ported  TN 
 information  to  all  LSMSs  in  the  region.  Some  old  SPs  proceed  with  their  disconnect  work  based  on  the  ports  agreed  upon  due  date,  either  on  that  date  or  a  day  later.  Other  SPs 
 begin  their  disconnect  processes  when  the  NPAC  broadcast  for  the  number  is  observed. 
 While  the  above  text  describes  the  provisioning  process,  both  service  providers  must  also  start  the  internal  processes  that  will  address  the  port  within  their  infrastructure.  For 
 example,  the  new  service  provider  must  provision  the  service  in  the  serving  switch  and  make  arrangements  for  a  serving  facility  while  the  old  service  provider  must  issue  the 
 service  orders  to  disconnect  service  to  this  customer  at  the  due  time  on  the  due  date.  The  old  and  new  service  providers  provisioning,  routing,  billing.  maintenance.  and 
 administrative  systems  must  be  updated  to  accomplish  the  transfer  of  the  telephone  number.  Typically,  the  old  and  new  service  providers  complete  b  S  S  and  central  office 
 updates  within  one  day  after  the  port, 
 Key  points  about  the  wireline-  porting  interval  are: 
 The  existing  or  current  flows  allow  a  period  of  two  business  days  for  the  concurrence  of  the  old  service  provider 

 The  time  to  return  the  Port  Response  may  be  less  than  24  hours  when  fully  mechanized  (non-  fax)  and  no  errors  exist  on  the  LSR. 
 Regardless  of  the  port  intervals,  if  activation  of  the  port  is  done  prior  to  the  completion  of  the  TN  disconnect  by  the  old  service  provider,  a  mixed  service 
 condition  exists  until  the  disconnect  is  completed. 

 lo  The  LNFA  WG,  through  the  Problem  Identification  Management  (PIM)  Rocess  is  working  on  PIM  22  which 
 seeks  to  eliminate  the  rimer  functionality  and  pos@  one  a  pori  placed  into  conflict  under  cause  code  50  (LSR  Not  Received)  or  51  (FOC  Nor  Issued)  until  the  conflict  is  resolved. 

 Mixed  scrvice  is  the  period  of  time  during  which  both  the  old  and  new  scMcc  providers  have  the  number  activated.  I 

 Page  9  of  35 
11
 NANC  Report  on  the  Intermodal  Porting  Interval  May  3,2004 
 4.  WIRELINE  PORTING  INTERVAL  (Contd) 
 Wireline  Porting  Process  (Contd) 
 A  pending  port  can  be  canceled  at  the  customers  request  or  because  a  conflict  between  the  SPs  cannot  be  resolved.  From  the  NPACs  standpoint,  a  port  is  cancelled  when  either  the 
 pending  port  has  not  been  activated  30  days  after  its  due  date  or  has  been  in  conflict  for  30  days,  or  when  the  new  SP  sends  NPAC  a  cancellation  request.  When  both  SPs  send  a 
 cancellation  request,  the  pending  port  is  cancelled  immediately.  If  only  the  new  SP  sends  a  cancellation  request,  a  pair  of  cancel  request  acknowledgement  timers  must  run,  each  for 
 nine  hours.  Like  other  timers  described  before  in  this  family  of  long  or  wireline  timers,  these  cancel  request  acknowledgement  timers  operate  only  during  the  7  a.  m.  to  7 
 p.  m.  Central  time,  Monday  through  Friday  NPAC  SMS  business  hours. 
 Following  is  a  pictorial  view  of  the  process  for  simple  port  confirmation  and  activation: 

 Simple  Port  Confirmation  and  Activation 
 Current  wireline  LNP  intervals 

 Hour  0  Hour  0-  24  Due  DUE  DlU  Dam  -3  Date  -2  Daw-  1  12:  Olm 
 or  Later 

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12
 NANC  Report  on  the  Intermodal  Porting  Interval  May  3,2004 
 5.  WIRELESS  PORTING  INTERVAL 
 The  wireless  porting  interval  is  based  upon  the  expectation  of  wireless  customers  to  go  to  a  wireless  point  of  sale  and  leave  with  functional  service  and  handsetherminal.  The  wireless 
 industrys  customer  acquisition  and  provisioning  systems  are  all  geared  to  meet  this  expectation.  Thus,  to  satisfy  the  wireless  business  model,  the  wireless  industry  agreed  to  30 
 minutes  for  a  port  request  (wireless  intercarrier  communication  process  (ICP)  equivalent  of  the  wireline  LSRlPort  Response),  and  two  hour  NPAC  activation  process  (1  hour  Initial 
 and  Final  Concurrence  Window  timers),  for  a  total  of  a  2-  1/  2  hour  wireless  porting  interval  for  a  simple  port  request. 

 Port  Request  and  Response  Process  When  the  customer  requests  service  and  to  port  their  telephone  number  to  a  New  Service 
 Provider  (NSP),  the  NSP  will  verify  the  customers  identity,  obtain  and  certify  their  authorization  to  port  the  number.  This  includes  obtaining  their  Social  Security,  current  Old 
 Service  Provide  (OSP)  account,  andlor  their  tax  identification  (based  upon  zip  code)  numbefls).  The  New  Network  Service  Provider  (NNSP)  also  confms  that  the  number  is 
 eligible  for  porting  (i.  e.  that  the  NXX  is  portable  and  in  the  local  serving  area). 
 Once  this  certification  is  complete,  the  NNSP  enters  the  required  port  request  data  into  their  system,  and  the  port  request  is  edited,  formatted,  and  sent  to  the  Old  Network  Service 
 Provider  (ONSP)  via  an  interface.  the  New  Interface  Communication  Process  (NICP),  usually  either  a  clearinghouse  or  the  NNSPs  Service  Order  Administration  (SOA)  system. 
 The  NICP  stores  and  transmits  the  port  request  to  the  ONSPs  Old  Interface  Communication  Process  (010)  and  issues  a  transmit-  received  acknowledgement.  If  there 
 is  no  acknowledgement  response,  NNSP  resolution  is  invoked.  If  a  transmit  acknowledgement  is  received,  the  timers  begin  tracking  time. 

 The  OICP  then  edits  and  stores  the  port  request.  If  the  request  cannot  be  validated  within  30  minutes  a  Delay  response  is  sent.  Given  that  the  customer/  eccount  has  alrcady  been 
 certified,  to  reduce  fallout,  the  major  wireless  carriers  agreed  to  validate  on  three  numerical  fields  (telephone  number,  social  security  number  or  account  number  or  tax  identification 
 number,  and  five-  digit  zip  code),  plus  pin  or  pass  code  if  protection  has  been  requested  by  the  customer,  The  ONSP  validates  the  port  request  and  issues  a  port  response,  either  a 
 confirm  if  the  validation  data  matches  or  a  deny  with  reason  code  if  the  validation  data  does  not  match.  The  ONSP  sends  the  response  via  the  OICP  to  the  NICP  and  requests  a 
 transmit  acknowledgement.  The  NICP  stores  the  response  and  sends  an  achowledgemcnt.  If  no  transmit  acknowledgement  is  received,  resolution  is  required  with  the  3. 
 the  NNSP  receives  the  confirm  response.  the  NNSP  has  completed  tbe  ICP  prooess  and  continues  the  porting  process  at  the  NPAC. 

 Page  11  of  35 
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 NANC  Report  on  the  Intermodal  Porting  Interval  May  3.2004 
 6.  ASSUMPTIONS 
 The  IMG  will  not  presume  that  the  previously  developed  wireline  porting  interval  of  four  days  can  be  reduced,  but  will  instead  review  the  processes  and  evaluate  proposals  to  &  if 
 the  interval  can  be  reduced. 
 Only  SIMPLE  (see  glossary)  ports  will  be  defined  and  discussed  in  this  IMG  report  Complex  ports  (see  glossary)  are  not  included.  Complex  ports  are  ports  that  generally 
 require  more  time  for  coordination  due  to  factors  such  as  number  of  lines,  multiple  geographic  locations,  multiple  time  zones,  involvement  of  multiple  service  providers,  or 
 other  similar  factors.  Simple  ports  generally  involve  fewer  complicating  factors,  e.  g.  single-  line  account  port. 

 Internodal  porting  is  defined  as  wireline  to  wireless  and  wireless  to  wireline  porting.  This  report  does  not  address  wireless  to  wireless  and  wireline  to  wireline  porting  intervals. 
 Options  to  shorten  the  porting  intervals  require  pons  be  error-  free. 
 Shortening  the  internodal  porting  interval  would  require  use  of  an  automated  process  for  the  port  request  and  port  response.  '2  Shorter  intervals  would  not  be  s  u  m  4  where  a  low- 
 tech  interface  is  used.  Low-  tech  interfaces  include  fax  and  email. 
 7.  DISCUSSION  QUESTIONS 
 A.  What  were  the  reasons  the  four  business  day  interval  was  initially  intrad~  ced?  '~ 
 For  ports  from  wireline  providers  to  wireless,  wireless  Service  Providers  desire  reduced 
 industry?  The  current  porting  intervals  for  wireline  include  a  maximum  of  one  (1)  business  day  for  the  LSR/  Port  Response  process  and  three  (3)  business  days  for  the 
 porting  process.  Wireline  ports  may  be  accomplished  in  less  time  when  conditions  are  optimal,  however,  the  timeframes  were  established  to  support  the  complex 
 systems  and  work  processes  of  all  the  wireline  Service  Providers.  A  variety  of  systems  are  used  during  the  porting  process  including,  but  not  limited  to  the 
 following: 

 rting  intervals  from  those  currently  used  by  the  wireline  segment  of  the 

 LSRlport  Response  Systems  -Processing  of  inter-  Service  Provider 
 commimicarion  documents 

 l2  Port  request  nfen  to  the  Local  Service  Request  (LSR)  or  Wireless  POn  Request  (WPR).  Port  response  d  e  n  10 
 the  Fm  Order  Confirmation  (Port  Response)  or  Wireless  Port  Request  Response  (WPRR). 

 Wireline  business  days  are  Monday-  Friday,  7  a.  m.  to  7  p.  m.  CST. 
 Wireless  Wueline  Integration  Subcommittee  2.6  Report. 

 l  3 
 " 

 Page  12  of  35 
14
 *. 
 NANC  Report  on  the  Intermodal  Porting  Interval  May  3,2004 

 7.  DISCUSSION  QUESTIONS  (Contd) 
 A.,  (Contd) 
 Service  Order  Systems  -  Initiate  the  service  orders  for  Service  Provider  provisioning  and  10  begin  the  porting  process 

 Inventory  Systems  -  Manage  the  distribution  and  assignment  of  equipment  and  telephone  numbers 
 Work  Force  Assignment  Systems  -  Schedule  assignments  to  accomplish  any  facilities  work 
 Billing  Systems  -  Update  recordr  required  to  ensure  accurate  billing 
 Maintenance  Systems  -  Update  records  required  to  enable  quality  trouble  resolution 

 Switch  Administration  Systems  -  Maintain  switch  translations  and  activate  optional  ten-  digit  triggers 
 E91  1  Systems  -  Update  records  to  ensure  accurate  customer  data 
 The  above  systems  were  individually  designed  and  developed  by  each  wireline  Service  Provider.  Many  of  these  systems  operate  in  batch  environments  that  require 

 at  least  an  overnight  timeframe  to  process  updates.  Porting  intervals  were  negotiated  during  19%  and  1997  by  the  wireline  industry  segment  to  allow  for  differences  in 
 processing  parameters  of  these  various  carriers  systems. 
 The  one  (1)  day  LSRlPort  Response  process  and  the  three  (3)  day  porting  interval  were  negotiated  by  the  wireline  carriers  in  order  to  peffom  all  of  the  system  updates 
 and  any  physical  work  required  to  accomplish  the  port.  For  example,  the  batch  service  order  process  used  by  many  wireline  carriers  results  in  the  need  for  the  one 
 (1)  day  LSRlport  Response  process.  During  the  threc  (3)  day  porting  timeframe.  a  batch  process  is  used  by  many  Service  Providers  to  complete  the  translations  work 
 needed  to  activate  the  ten-  digit  trigger  in  order  to  enable  routing  calls  to  ported  customers,  and  subsequently,  to  disconnect  the  porting  customer. 

 The  current  intervals  perfom  the  additional  function  of  providing  a  necessary  interval  for  validation.  These  intervals  serve  as  a  process  brake  when  questions  arise 
 concerning  a  specific  port,  for  instance,  when  steps  are  performed  out  of  n  o  d  sequence.  A  new  service  provider,  issues  a  create  message  to  NPAC  before  sending 
 an  order  to  the  old  service  provider  and  receiving  a  Port  Response.  The  old  Service  provider  must  scramble  to  send  its  message  to  WAC  before  expiration  of  the  T1 
 timer.  Failure  to  do  so  represents  additional  work  steps  to  research  a  WAC  message  querying  for  an  order,  that  may  very  well  be  in  process,  but  delayed  by  late  service 
 order  issuance. 

 Page  13  of  35 
 , 
15
 NANC  Report  on  the  Intermodal  Porting  Interval  May  3.2004 
 7.  DISCUSSION  QUESTIONS  (Contd) 
 A.  (Contd) 
 When  a  new  service  provider,  as  another  example,  issues  a  create  message  to  NPAC  without  ever  issuing  an  order  to  the  old  service  provider,  the  old  service  provider  fmt 
 finds  out  about  the  order  from  the  *AC.  The  old  service  provider  may  invoke  a  conflict  timer,  but  the  total  number  of  business  hours  available  to  handle  the  port 
 before  it  becomes  active  is  the  sum  of  the  T2  timer  and  the  conflict  timer,  currently  15  hours.  Any  adjustment  of  these  timers  creates  less  time  to  communicate  with  the 
 new  service  provider.  research  the  problem,  check  the  account,  and  resolve  the  problem  in  a  way  consistent  with  end  user  wishes. 

 A  final  error  that  the  3  day  interval  forms  a  safeguard  against  occurs  when  the  new  service  provider  issues  porting  requests  for  telephone  numbers  which  may  include  a 
 number  not  shown  on  the  account  record.  In  short,  in  any  circumstance  where  the  requested  porting  activity  does  not  agree  with  messages  sent  to  the  NPAC  and  the 
 LSR  received  by  the  losing  carrier.  The  intervals  are  designed  to  allow  enough  time  for  the  carriers  to  work  out  these  differences  before  a  port  occurs  that  could 
 potentially  put  an  end  user  out  of  service. 
 What  might  apply  to  the  intermodal  port? 
 Carriers  may  need  to  modify  their  Operational  Support  Systems  (OSS),  Service  Order  Entry  Systems  (SOE),  Service  Order  Administration  (SOA),  Local  Service 
 Management  System  (LSMS)  to  use  the  shorter  intermodal  porting  interval. 
 The  NPAC  currently  has  two  separate  timers  depending  on  the  t  y  p  of  port,  wireless  to  wireless.  or  wireline  to  wireline  and  intermodal.  The  introduction  of  a  third  timer 
 for  use  in  limited  circumstances  (simple  ports)  within  the  context  of  an  intermodal  port  would  necessitate  development  work  within  the  WAC  as  well  as  carrier  system 
 interfacing  with  the  NPAC. 
 Should  the  IMG  examine  the  costs,  benefits,  and  methodologies  involved  h  reducing  the  four-  day  interval  and  defme  a  reasonable  transition  period? 

 Based  on  the  technical  detail  required  to  implement  a  shorter  internodal  porting  interval,  a  transition  period  commensurate  with  the  system  design  changes.  should  be 
 allowed  after  the  FCC  mandates  the  new  porting  interval.  This  time  period  would  allow  carriers  time  to  design,  budget,  and  implement  the  new  porting  interval  within 
 their  respective  networks  and  associated  systems.  Additional  time  would  also  allow  modification  to  the  WAC  based  on  the  outcome  of  this  analysis  and  any  subsequent 
 FCC  orders. 

 B. 
 C. 

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 NANC  Report  on  the  Intermodal  Porting  Interval  May  3,2004 
 8.  PROPOSALS 
 Proposals  are  identified  below  as  a  Confirmation  (  C)  interval  or  an  Activation  (  A)  interval.  The  confirmation  interval  includes  port  q  u  e  s  t  and  port  response.  The  activation 
 interval  is  the  time  after  port  response  until  the  port  is  activated  in  the  respective  industry  networks. 

 Each  proposal  offered  may  have  implications  related  to  state  jurisdiction  over  issues  such  as  performance  measurements  that  need  to  be  considered  in  the  analysis  of  each  proposal. 
 For  example,  performance  measurements  are  not  uniform  across  all  states. 
 ProDosal  C1-  (Port  reauest  and  wtl  reswnw  within  1  hour)  (wrt  reswnse  is  eithel:  Port  Reswnse  or  wrt  denial  within  one  hour) 

 An  automated  interface  standard  for  passing  port  requests  and  port  responses  would  be  needed  with  this  interface  being  established  as  a  public  domain  interface.  All  service 
 providers  that  plan  to  use  the  shorter  porting  interval  would  be  required  to  use  proposed  public  domain  interface  for  passing  port  requests  and  port  responses. 

 A  reduction  in  the  intermodal  porting  interval  could  be  feasible  if  all  carriers  used  the  same  validation  criteria  as  the  major  wireless  carriers.  These  validation  criteria  are  the  ported 
 number,  social  security  number  or  account  number  or  tax  identification  number,  five-  digit  zip  code,  and  pin  or  pass  code  if  applicable.  This  validation,  together  with  the  certification 
 of  the  customer  identity  via  the  service  activation  process.  authorization  to  port  the  number,  and  the  use  of  a  standard  automated  interface,  would  simplify  the  port  request  process  and 
 significantly  reduce  the  amount  of  data  exchange  necessary. 
 For  example,  carrjers  could  exchange  the  following  standardized  data  fields: 
 NNSP  (New  Network  Service  Provider  Service  Profile.  Company  Code  SPD) 
 ONSP  (Old  Network  Service  Provider  Service  Profile.  Company  code  SPD) 
 REQ  NO  (Request  Number,  order  tracking) 
 NPDI  (Number  Portability  Direction  Indicator,  to  set  WAC  timers) 
 DDT  (Due  Date  and  Time  ...  this  should  be  set  by  the  intermodal  porting  interval) 
 IMP  CON  (Implementation  contact  information  for  resolutions)  TEL  NO  (Telephone  number  of  implementation  contact) 

 Plus  the  validation  criteria: 
 Ported  #  (porting  telephone  number) 
 SSN/  ACCT  (Social  Security  Number  or  Account  Number  or  Tax  Identification  Number) 

 ZIP  CODE  (five  digit  zip  code) 
 PSWD/  PlN  (optional  pin  or  password  if  protection  was  requested  by  the  customer) 

 Page  15  of  35 
 1  I 
17
 NANC  Report  on  the  Intermodal  Porting  Interval  May  3,2004 
 8.  PROPOSALS  (Cont'd) 
 with  the  reduced  validation  criteria  and  fields,  a  standard  format  and  associated  interface  requirement  are  easily  defined  for  simple  ports.  Consequently,  port  confirmations  and 
 responses  could  be  executed  within  a  short  time  frame  of  60  minutes.  Moreover.  there  would  be  fewer  errors  and  a  significantly  reduced  fall  out  percentage  that  could  reduce  the 
 processing  costs  associated  with  simple  intermodal  port  requests. 
 Once  the  port  request  confirmationlPort  Response  is  received,  the  Inter-  canier  Communication  Process  (ICP)  is  complete.  Subsequently,  both  the  New  Network  Service 
 Provider  (NNSP)  and  the  Old  Network  Service  Provider  (ONSP)  can  initiate  the  WAC  port  activation  process  by  submitting  a  Subscription  Version  Create. 

 P  r  o  w  a  l  C2  -  (Mechanized  DOII  reauest.  reduced  Port  Resmnse  Interval  Actlvatlon  interval  remains  3  davs) 
 A  new  service  provider  may  reduce  the  Firm  Order  Confirmation  (Port  Response)  interval  by  establishing  a  mechanized  interface.  To  the  extent  that  the  mechanized  interface 
 obviates  the  need  for  the  order  to  be  retyped  manually  on  the  receiving  end,  the  Port  Response  interval  may  be  reduced  not  to  exceed  5  hours  from  receipt  of  an  error-  free  order. 

 T  h  i  s  five  hour  interval  will  be  established  miprocally.  when  a  canier  who  is  offering  a  5  hour  Port  Response  wishes  also  to  use  a  mechanized  interface  to  avail  itself  of  a  5  hour  Port 
 Response  for  ports  in  the  opposite  direction. 
 Prowsal  A1  -  (2  Day  Port  Activation  Afler  Port  Reswnse)  (New  NPAC  timers  for  simDle  intermodal  DO-) 

 Establish  a  two-  day  interval  for  Simple  Ports  (as  defined  in  Glossary).  A  threeday  interval  continues  to  apply  to  non-  intermodal  simple  ports.  This  option  necessitates  a  check  of 
 order  activity  against  account  record  to  insure  that  only  one  line  is  on  the  account,  before  an  interval  shorter  than  the  three-  day  wireline  standard  is  confirmed  with  a  Port  Response. 
 This  option  may  require  a  third  set  of  timers  to  be  developed,  ones  specifically  set  to  reach  a  two  day  port  interval. 

 To'make  this  interval  reliable,  the  factors  listed  at  the  end  of  Proposal  A2  may  apply  for  Proposal  A1  as  well,  depending  on  its  design.  Though  the  factors  are  described  below. 
 they  can  be  listed  as  follows: 
 1.  Changes  in  or  elimination  of  performance  measure  remedies  in  the  area  of  LNP  ports.  With  industry  agreement  and  state  commission  cooperation  in  relaxing  or 
 removing  the  Performance  Measurements  associated  with  percent  of  orders  that  are  completed  before  expiration  of  timers,  it  would  be  possible  to  shoot  for  a  shorter  goal. 

 Page  16  of  35 
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 NANC  Report  on  the  Intermodal  Porting  Interval  May  3,2004 
 8.  PROPOSALS  (Cont'd) 
 2.  '  Improved  order  accuracy.  With  further  ordering  experience  on  the  part  of  wireless  providers  and  their  service  bureaus.  as  orders  are  processed  more  efficiently,  quicker 
 due  dates  can  be  offered  to  end  users. 
 3.  Reciprocal  Commitment.  With  reciprocity  and  parity  in  shorter  intervals  (where  not  only  ILECs,  but  all  communications  companies  are  under  equal  obligation  to  achieve 
 quicker  provisioning),  the  industry  can  move  together  for  the  benefit  of  our  mutual  customers. 

 Adherence  to  NANC  defined  flows.  With  Industry  agreement  that  orders  will  not  be  sent  to  the  WAC  until  after  Port  Response  has  been  received,  the  T1  timer  may  be 
 reduced,  without  generating  duplicate  work  for  old  service  providers. 
 4. 

 Proms1  A2  -  (2  Dav  Port  Activation  -  Shortened  Existine  Timer@)  Another  methodology  for  reducing  the  provisioning  interval  (from  Port  Response  to 
 completion  of  order)  is  to  work  with  the  existing  process,  and  adjust  the  timers  for  all  standard  orders.  By  working  with  all  standard  orders,  a  great  deal  of  money  and  time  is 
 saved  in  not  developing  an  additional  process,  and  not  running  the  process  on  a  separate  basis  once  developed. 

 Proposal  A2  recognizes  that  the  current  process  is  based  on  a  period  of  time  that  NPAC  waits  for  both  orders  to  arrive  (9  hours),  the  time  to  advise  a  provider  that  its  order  is 
 missing  (another  9  hours)  and  the  time  for  the  old  service  provider  to  place  an  order  in  conflict  if  there  is  a  problem  (6  hours).  Based  on  the  following  conditions.  these  timers 
 may  be  reduced,  and  a  two  day  activation  interval  achieved  for  all  orders  currently  worked  in  three  days. 

 1.  Changes  in  or  elimination  of  perlormance  measure  remedies  in  the  area  of  Lh"  ports.  With  industry  agreement  and  state  commission  cooperation  in  relaxing  or 
 removing  the  Performance  Measurements  associated  with  percent  of  orders  that  arc  completed  before  expiration  of  timers,  it  would  be  possible  to  shoot  for  a  shorter  god. 

 Improved  order  accuracy.  With  further  ordering  experience  on  the  part  of  wireless  providers  and  their  service  bureaus,  as  orders  are  processed  more  efficiently,  quicker 
 due  dates  can  be  offered  to  end  users. 
 2. 

 3.  Reciprocal  Commitment.  With  reciprocity  and  parity  in  shorter  intervals  (where  not  only  ILECs,  but  all  communications  companies  are  under  equal  obligation  to  achieve 
 quicker  provisioning),  the  industry  can  move  together  for  the  benefit  of  our  mutual  customers. 

 Adherence  to  NANC  defined  flows.  With  Industry  agreement  that  orders  will  not  be  sent  to  the  NPAC  until  after  Port  Response  has  been  received,  the  T1  timer  may  be 
 reduced.  without  generating  duplicate  work  for  old  service  providers. 
 4. 

 Page  17  of  35 
19
 NANC  Report  on  the  Intermodal  Porting  Interval  May  3,2004  , 
 8.  PROPOSALS  (Contd) 
 5.  A  method  to  handle  data  portion  of  line  sharing.  The  FCC  has  ordered  that  when  a  port  out  is  requested  on  a  loop  where  the  High  Frequency  portion  is  being 
 used  by  a  data  carrier,  the  data  carrier  must  be  given  a  chance  to  place  orders  to  retain  use  of  the 

 High  Frequency  p0rti0n.  I~  The  time  offered  the  data  provider  to  research,  currently  is  three  days  for  some  LECs.  A  two  day  interval  for  porting  out  the  number  can  not 
 be  met  without  adjusting  Data  CLECs  expectation,  either  through  negotiation  or  regulatory  assistance. 

 The  reduction  in  T1  timer  will  become  difficult  if  new  service  providers    jump  the  gun  and  send  the  WAC  notice  early,  as  the  T1  timer  would  then  be  expiring  even  while  the  old 
 provider  is  still  receiving  the  order.  If  T1  expires  and  NPAC  sends  notifications  to  old  carriers  for  orders  that  old  carriers  are  processing  on  a  timely  manner,  duplicate  work  is 
 created  in  tracing  the  reports.  Proposal  A2  is  based  on  agreement  that  steps  will  be  handled  sequentially,  order  to  old  provider,  Port  Response  to  new  provider,  then  messages  to 
 NPAC. 
 Proposal  A2  includes  a  reduction  of  T1  timer  to  5  hours  (from  9),  and  reduction  of  due  dates  from  3  business  days  after  Port  Response  to  2  business  days  after  Port  Response. 

 Prowsal  A3  (AdaDted  from  wire~  esdw  ireline  Jnteeration  Rewrts) 
 This  approach  describes  how  an  ONSP  can  facilitate  the  NNSP  s  ability  to  activate  an  internodal  port  up  to  24  hours  prior  to  the  duedate  identified  on  the  Port  Response. 
 This  can  be  accomplished  if  the  ONSP  agrees  to  send  a  subscription  version  to  the  WAC  no  later  than  24  hours  prior  to  WAC  due-  date  and  sets  the  1Gdigit  trigger  on  the  number 
 in  the  donor  switch  no  later  than  1159  pm  on  due  date  minus  2. 

 ~ 
 In  he  FCCs  Line  Sharing  Order  FCC  99-  355  relead  1219/  1999,  the  FCC  said  in  Paragraph  72.  We  note  th.  l  in  the  event  that  the  customer  terminates  its  incumbent  LEC  provided  voice  scmcc.  for  whatever  -n.  the 

 competitive  data  Lu:  is  rquircd  IO  purchase  he  full  stand-  alone  loop  network  element  if  it  wishes  Io  continuc  providing  xDSL  service.  The  FCC  reiterated  its  finding  in  this  regard  in  iu  TRO  order.  Scc  TRO  K!  C  03-  36 
 released  8/  21~  2003.9269. 
 The  interval  described  by  this  proposal  does  not  alm  or  change  the  existing  Wireline  intervals.  buf  provides  an  option  to  use  an  intermodal  poning  interval  that  is  urnsparent  to  existing  indusey  ponjng  intervals. 

 Since  port-  outs  to  wireless  consumers  may  include  a  mixed  service  interval,  the  wireless  SP  is  responsible  for  implementing  verifiable  confirmation  by  the  consumer  regarding  the  91  1  and  billing  implications.  e&,  the 
 customer  will  k  billed  by  the  wireline  SP  up  to  the  day  and  time  the  wireline  service  is  disconnected  on  the  Pori  Response  duedak. 

 I5 
 l6 

 Page  18  of  35 
 I  I 
20
 NANC  Report  on  the  Intermodal  Porting  Interval  May  3,2004 
 8.  PROPOSALS  (Cont'd) 
 Prowsal  A3  (Adaoted  from  Wirelesflireline  Inteeration  Rewrts)  (Cont'd) 
 After  receiving  NPAC  notification  that  the  ONSP  has  sent  a  positive  create  message  to  the  NPAC  (assumes  the  ONSP  already  set  the  lodigit  trigger),  the  NNSP  is  now  aware  that 
 there  were  no  problems  with  the  port"  and  that  they  can  if  they  desire  initiate  the  transmission  of  a  modify  message  to  the  NPAC  to  change  the  WAC  due-  date.  This  act  by 
 the  NNSP  does  not  require  further  intervention  or  activity  on  the  part  of  the  ONSP  or  require  the  ONSP  to  change  the  Port  Response  duedate. 

 Note  that  this  opportunity  is  only  available  to  orders  tha\  jlow-  through  100%  since  otherwise,  the  need  to  perform  complex  system  changes  to  address  fall-  out  prior  to  the 
 Port  Response  duedate  is  beyond  the  scope  of  this  proposalm. 
 This  approach  may  work  as  follows: 
 1. 
 2. 
 The  NNSP  submits  an  LSR  which  is  processed  by  the  ONSP. 
 The  ONSP  issues  a  Port  Response  specifying  the  due-  date  within  standard  industry  intervals. 

 The  NNSP  acknowledges  receipt  of  the  Port  Response  and  if  the  NNSP  receives  Port  Response  jeopardy,  the  NNSP  needs  to  resubmit  the  LSR. 
 The  NNSP  sends  a  subscription  version  to  the  NPAC  corresponding  the  Port  Response  duedate  and  time. 
 The  ONSP  OSSs  begin  to  process  the  order  in  its  service  order  provisioning  systems"  and  sets  the  10-  digit  trigger  on  its  donor  switch  and  sends  the  subscri89on  version  to 
 the  NPAC  no  later  than  11:  59  pm  on  due  date  minus  2  (new  process). 

 3. 
 4. 
 5. 

 ~  '* 
 This  approach  is  for  'now-  through"  orders  only  and  orders  that  "fall-  out"  during  the  editinghcrification  stcps  performed  by  the  ONSP  within  its  OSSs  during  the  post-  Pm  Response  (activation)  intcrval  do  not  qualify. 

 An  analysis  of  complex  SP  systcm  changes  needed  to  provide  the  mcchanizcd  tools  and  the  impact  upon  human  resources  necessary  to  address  NNSO  queries  regarding  pons  that  do  not  "flow-  through"  1-  has  pt  U,  bc 
 performed  and  would  likely  change  the  IMG's  opinion  of  this  proposal  relative  IO  other  p  r  o  p  ~d  s  . 
 To  this  point.  queries  to  the  ONSP  by  the  NNSP  to  advance  the  duedatc  andor  ask  why  a  port  hos  not  yet  and/  or  was  not  available  for  porting  during  the  24  hours  prior  to  the  Porl  Response  duedate  arc  prohibited. 
 otherwise.  this  propossl  would  need  to  include  complex  SP  system  changes.  Also  see  footnole  4. 
 This  approach  is  for  'now-  through"  orders  only  and  orders  that  'Yall-  out"  during  the  editing/  verification  stcgs  performed  by  the  ONSP  within  its  OSSs  during  che  post-  Port  Response  (activation)  intmal  do  not  qualify. 

 This  proposal  only  applies  lo  O  K  ~K  that  "flow-  through"  which  include  a  single  residential  01  business  TN  POTS  line  that  passes  individual  ONSP  OSS  edits  and  verification  steps  during  the  activation  intmal. 

 I' 
 'I 
 21 

 Page  19  of  35 
21
 NANC  Report  on  the  Intermodal  Porting  Interval  May  3.2004 
 8.  PROPOSALS  (Contd) 
 Promal  A3  (Adapted  from  WirelesslWireline  Intemation  RewrtsL(  Contd) 
 6. 

 7. 

  
 The  NNSP  is  notified  by  WACz3  that  the  ONSP  has  sent  a  subscription  version  to  the  NPAC  for  the  TN. 
 No  earlier  than  24  hours  before  Port  Besponse  due-  date,  the  NNSP  sends  a  modify  to  NPAC  changing  the  NPAC  duedate  and  time  (new  process). 
 Upon  activation  by  the  NNSP,  the  mixed  service  interval  begins  and  the  customer  can  originate  calls  using  her  wireline  and  wireless  handset.  but  all  calls  will  be  rcceived 
 by  the  wireless  handset  only  (new  process). 
 On  the  Port  Response  due-  date,  the  wireline  service  is  disconnccted  and  ordinary  activities  practiced  today  using  the  existing  wireline  intervals  are  performed  by  the 
 ONSP  in  the  case  of  wireline  ONSP. 

 8. 
 9. 

 SPs  will  not  be  measured  or  penalized  if  a  TN  is  not  made  available  for  porting  within  the  24  h  o  w  prior  to  due  date  sincc  the  condition  for  this  proposal  is  that  otherwise  the  order  did  not  flow-  lhrough  lW%. 
 The  NNSP  would  not  change  the  duedatc  using  the  LSR  process  but  will  dincdy  contact  WAC  to  specify  the  intenodd  activation  due-  dnte  that  pppears  in  the  WAC  BE  the  new  duedate.  )1 

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 NANC  Report  on  the  Intermodal  Porting  Interval  May  3,2004 
 9.  IMG  ANALYSIS 

 Simple  Port  Confirmation  and  Actlvatlon 

 Page  21  of  35 
23
 NANC  Report  on  the  Intermodal  Porting  Interval  ,.  May  3,2004 
 9.  IMG  ANALYSIS  (Cont'd) 
 Work  Stem  Reauired  to  ImDlement  a  Shorter  Intermodel  Portine  Interva 

 NPAC  Changes 
 The  NPAC  today  does  not  determine  whether  or  not  a  transaction  involves  an  intermodal  port.  Instead,  the  selection  of  timers  to  apply  in  a  particular  porting  transaction  is  based  on 
 information  about  each  SP  contained  in  the  regional  WAC  Service  Management  System's  (SMS's)  User  Profile  data.  It  is  the  comparison  of  the  involved  carriers'  timer  profile 
 settings  that  determines  whether  a  porting  transaction  is  to  be  treated  as  intermodal,  i.  e.,  to  determine  whether  the  port  should  be  processed  using  the  long  timers.  (The  long  timers 
 and  certain  other  related  NPAC  process  intervals,  including  the  days  and  times  those  processes  operate,  are  sometimes  referred  to  as  the  "wireline"  timers;  these  me  invoked  as 
 the  default  process  values  in  what  apparently  are  internodal  porting  situations.) 
 The  NANC  IMG  proposal  adds  a  criterion  to  timer  selection  that  is  event-  specific.  That  is.  no  longer  will  it  be  sufficient  in  every  transaction  to  determine  whether  the  old  SPs  port- 
 out  timer  is  the  same  as,  or  is  different  from,  the  new  SFs  port-  in  timer,  (When  the  two  are  different,  there  is  presumption  of  an  intermodal  port  and  the  process  defaults  to  the  long 
 timer  values.)  Instead.  it  will  be  necessary  to  have  an  explicit  indication  provided  to  h  e  NPAC  SMS  that  a  particular  transaction  involves  M  intermodal  port  that  is  defined  as 
 "simple."  This  requires  a  design  change  for  both  the  NPAC  itself  and  for  User  systems  involved  in  "simple  intermodal"  ports.  The  NPAC  software  must  be  changed  to 
 accommodate  a  third  family  of  timers,  for  use  in  "simple  intermodal"  ports,  and  to  recognize  an  indication  by  the  old  SP  andor  new  SP  that  a  transaction  involves  a  "simple 
 intermodal"  port.  This  interface  change  likewise  would  require  a  change  to  the  carriers'  systems. 

 A  somewhat  different  approach  would  be  to  have  the  two  SP's  involved  in  a  port  indicate  which  of  the  three  timer-  families  they  wanted  applied  and  then  to  have  NPAC  default  to  the 
 longer  of  the  two.  Because  the  current  process  is  not  strictly  a  determination  of  inter-  modality,  an  expansion  of  the  User  Profile  data  also  might  be  requested.  to  add  M  explicit 
 indication  of  each  User's  carrier  t  y  p  .  This  new  indicator  then  would  be  used  to  identify  intennodal  porting  in  addition  to  the  interface  change  made  to  identify  which  transactions 
 involve  "simple  intermodal"  ports.  Or  the  User  Profile  data  might  be  left  as  i  s  and  instead  the  interface  change  broadened  to  include  an  indication  of  which  tw  of  intermodal  port  is 
 occumng.  A  more  detailed  discussion  of  the  impact  on  the  WAC  SMS  design  can  be  provided  once  a  complete  and  detailed  description  of  the  desired  NPAC  behavior  is 
 provided. 

 Page  22  of  35 
 I 
24
 ,. 
 NANC  Report  on  the  Internodal  Porting  Interval  May  3,2004 

 9.  IMG  ANALYSIS  (Cont'd) 
 911  Impacts  -  Intermadal  Porting  Interval  Change 

 Changes  in  the  porting  interval  itself  should  not  negatively  impact  9  11. 
 For  wireline  to  wireless  porting.  the  91  1  wireline  address  records  used  for  routing  and  address  display  at  the  public  safety  answering  point  (PSAP)  are  deleted  from  the  automatic 
 location  identification  (&  I)  database  after  wireline  phone  service  is  discontinuddisconnected.  These  processes  arc  cumntly  in  place  and  should  not  be 
 negatively  impacted  by  any  change  in  time  interval. 
 For  wireless  to  wireline  porting,  the  91  1  wireline  address  records  used  for  routing  and'  address  display  at  the  PSAP  are  insertedadded.  That  process  today  takes  place  after  the 
 wireline  phone  service  is  activated  (usually  within  a  business  day).  Shortening  the  porting  interval  itself  should  not  negatively  impact  that  process  which  will  still  take  place  after  the 
 wireline  phone  service  is  activated  (usually  within  a  business  day). 
 The  wireless  to  wireline  porting  process  may  also  require  the  opening  of  a  new  code  (NPA-  NXX)  in  91  1  databases  to  establish  default  routing  in  various  failure  conditions.  Some  91  1 
 service  providerdocal  exchange  carriers  (LECs)  have  already  opened  all  wireless  codes  in  their  areas  so  that  process  will  not  be  needed.  This  is  a  quick  process  and  should  be 
 accomplished  within  a  business  day  after  wireline  phone  service  is  activated. 
 A  91  1  callback  issue  exists  during  the  mixed  service  interval  of  porting,  when  there  are  two  phones  on  two  separate  networks,  with  both  capable  of  dialing  91  1.  This  issue  with  the 
 technicalities  of  which  phone  c  w  be  called  back,  dependent  upon  which  stage  of  podng  has  or  has  not  occurred,  is  fully  documented  in  Section  4  of  the  LNPA-  WG  3Rd  Report  on 
 Wireless-  Wireline  Integration,  filed  with  NANC  September  30.2000. 
 Since  this  mixed  service  callback  issue  occurs  between  the  time  the  new  phone  service  is  activated  and  the  old  phone  service  is  deactivateddisconnetd,  shortening  of  that  process 
 reduces  the  time  frame  of  potential,  negative  91  1  impact  (PSAP  inability  to  call  back  the  correct  phone  in  an  emergency  situation). 

 Carrier  Operational  Support  Systems  Impacdchanges 
 "Excerpt  Source:  WWISC  3rd  Report" 
 Many  of  the  SPs  that  are  participating  in  Local  Number  Portability  (WP)  employ  the  use  of  large  mainframe  computer  systems.  These  systems  are  the  core  processing  systems  that 
 run  their  business  operations  and  provide  service  to  their  customers.  Most  of  these  existing  systems  use  a  batch  processing  method,  which  means  collecting  data  during  the  normal 
 work  day  and  then  sorting,  processing  and  distributing  this  data  to  other  internal  and  external  systems  during  off  peak  hours. 

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 NANC  Report  on  the  Inleermodal  Porting  Interval  I  .  May  3,2004 
 9.  IMG  ANALYSIS  (Cont'd) 
 These  existing  systems  provide  functions  such  as.  Service  Order  Processing  from  order  creation  through  to  order  completion,  Customer  Billing.  Directory  Listing  updates, 

 Customer  Service  records  generation  and  maintenance,  91  1  updates,  Network  systems  updates  for  call  routingkompletion  and  Customer  feature  provisioning.  etc.  Because  these 
 systems  form  the  core  of  the  business  operation  and  BTC  interdependant  on  one  another.  a  change  to  one  system  may  have  a  cascading  effect  on  the  next  system.  It  is  estimated  a 
 reduction  in  the  porting  interval  could  impact  at  least  10  to  15  major  existing  systems  within  a  company. 

 Elimination  of  appropriate  batch  processing  would  facilitate  the  possibility  of  a  reduced  porting  interval.  However,  to  consider  a  change  from  batch  processing  to  real  time  data 
 processing  would  require  an  in-  depth  systems  analysis  of  all  business  processes  that  use  these  systems.  This  analysis  is  required  to  insure  that  other  business  processes  arc  not 
 broken  by  such  a  change.  A  normal  high  level  analysis  of  this  type  q  u  i  r  e  s  ,  in  addition  to  the  systems  analysis,  cost  development,  budget  preparation  and  approval, 
 softwarelhardware  development  and  implementation.  Accomplishment  of  these  activities  would  be  a  very  labor  intensive  and  time  consuming  effort  leading  to  increased  expense. 

 Another  aspect  of  system  change  is  the  effect  on  operations  personnel  and  staffing  levels.  Current  operations  often  minimize  the  staffing  level  during  off  peak  hours.  Changing  from 
 the  batch  processing  method  of  operation  could  extend  staffing  hours,  particularly  on  the  weekends.  Operational  changes  of  this  nature  could  require  24  hours.  7  days  a  week  (24x7) 
 operations,  making  system  development,  deployment  and  maintenance  more  expensive  and  difficult.  This  would  require  stfling  on  a  24x7  basis,  thus  increasing  expense  to  the 
 companies'  operation  and  thus  the  consumer. 
 For  example,  the  batch  service  order  process  used  by  many  wireline  carriers  results  in  the  need  for  the  one  (1)  day  LSRlPort  Response  process.  During  the  three  (3)  day  porting 
 timeframe,  a  batch  process  is  used  by  many  Service  Providers  to  complete  the  translations  work  needed  to  activate  the  tendigit  trigger  in  order  to  enable  routing  calls  to  ported 
 customers,  and  subsequently,  to  disconnect  the  porting  customer. 
 Cost  Recovery 
 NANC  is  concerned  with  industry  cost  but  does  not  deal  with  cost  recovery.  However,  under  the  current  FCC  rules  cost  recovery  is  allowed  for  L"  implementation  using  a  "but 
 for  LNP"  clause  to  identify  recoverable  costs.  Shortening  the  porting  interval  impacts  LECs  and  may  impact  CMRS  carriers  and  should  meet  the  "but  for  LNP"  rule.  This 
 shorter  porting  interval  was  neither  a  part  of  the  1997  LNP  process  flows  nor  a  part  of  industry  design.  Considering  the  potential  industry  costs,  and  given  the  fact  that  these  costs 
 potentially  meet  the  "but  for"  standard,  depending  upon  what  the  Commission  chooses  to 

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 NANC  Report  on  the  Intermodal  Porting  Interval  Mav  3.2004 
 9.  IMG  ANALYSIS  (Contd) 
 do,  explicit  cost  recovery  for  any  incremental  intermodal  porting  costs  for  LECs  is  au  issue  which  should  be  resolved  by  the  Commission  (or  other  appropriate  regulatory 
 authority)  rather  than  this  IMG  or  the  NANC.  Of  course,  non-  ILEC  service  providers  are  allowed  to  recover  their  respective  incremental  LNP  costs  in  any  legal  manner. 

 Rural  Telephone  Company  Impacts 
 In  order  to  support  a  shorter  porting  interval,  service  providers  will  necd  to  change  internal  operating  software,  business  practices  and  implement  mechanized  systems  and  automated 
 interfaces  with  other  carriers. 
 The  Commission  should  recodize  that  this  may  cause  economic  impacts  on  rural  telephone  companies  that  may  pot  be  justified  considering  the  size  of  the  customer  b  y 
 customer  density,  or  availabilit  of  alternate  service  providers  and  that  rural  telephone  companies  may  seek  a  waiver  lorn  LNP  and  or  shorter  porting  intervals  under  the  exibting 
 d  e  s  and  regulations. 
 10.  ADDITIONAL  CONSIDERATlONS 
 NANC  Flows 
 There  was  general  agreement  that  the  IMG  should  not  open  the  NANC  flows  while  writing  this  report.  To  engineer  these  t@  mical  flows  around  policy  issues  would  be  tough.  The 
 IMG  agreed  that  it  develop  a  bkeline  process,  then  have  the  LNPA  WG  update  the  flows  with  what  is  agreed  to  or  wait  for  the  FCC  to  rule  on  the  porting  interval  first  to  ensure  the 
 flows  will  be  adopted  with  the  proper  interval. 
 Inadvertent  Ports  There  is  some  concern  about  ibadvertent  ports  with  a  shorter  porting  interval.  Industry 
 participants  will  need  to  follow  the  established  emergency  restoration  procedures  for  thost  end  users  that  are  ported  by  dstake  (see  NPAC  website). 

 As  a  result  of  differences  between  the  wireless  and  wireline  intercher  communication  process,  several  intermodal  m  n  g  issues  have  been  identified  and  are  being  addressed  in 
 the  interest  of  reducing  fallouq  and  improving  the  consumers  porting  experience.  Below  are  six  issues  being  addresdiby  the  NANCs  LNPA-  WG.  In  addition  to  the  LNPA-  WG, 
 CTIA  and  USTA  have  establidhed  a  Task  Force  to  expedite  resolution  of  intermodal  porting  issues,  and  several  intkrmodal  issues  have  been  referred  to  the  OBF  for  resolution. 

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 NANC  Report  on  the  Intermodal  Portlng  Interval  May  3,2004 
 10.  ADDITIONAL  CONSIDERATIONS  (Contd) 
 The  IMG  did  not  evaluate  the  impact  each  of  the  proposals  may  have  upon  possible  resolutions  to  these  intermodal  issues  being  addressed  at  the  various  industry  committees.  It 
 is  recommended  that  these  committees  take  into  consideration  these  impacts  if  the  FCC  mandates  an  internodal  porting  interval. 

 Ports  Attempted  While  Port  Conflict  Still  Unresolved  Customers  are  taken  out  of  service  inadvertently  when  a  NNSP  continues  with  a  port 
 that  had  been  placed  into  Conflict  by  an  ONSP.  The  LNPA-  WG  is  developing  the  requirements  for  NANC  Change  Order  375. 
 (LNPA  PlM  (Problem  Ident@  ation  Manugement)  22V3  -  Verizon) 
 Intermodal  Port  Coflrmation  Port  Date  Not  Recognized  There  is  a  fundamental  difference  between  wireless  WICIS  and  wireline  LSOG. 
 Wireless  providers  have  developed  our  process  to  interpret  a  confirmed  response  to  mean  that  everything  in  the  LSR  Sent  is  confirmed.  When  a  wireline  provider  changes 
 a  field  and  still  confirms  the  port,  WSP  systems  fail  to  send  an  SV  create  and  activation  message  and  the  port  fails.  FOC  allows  for  a  due  date  and  time  change  on 
 confirmations,  but  is  not  allow  on  the  WPRR.  (WVPA  PlM  28  -  Sprint  PCS;  OBF  LSOP  Issue  2729/  lnterspecies  Task  Force  (lTF)) 

 Inconsistent  Intermodal  Porting  Processes  Cause  Service  Disruption  on  Due  Date  Customers  porting  from  a  wireline  carrier  a  r  ~  disconnected  in  the  donor  switch  b  e  f  a 
 the  wireless  carrier  activates  the  port.  Inter-  modal  porting  processes  were  not  clearly  defined  or  developed  by  the  industry  prior  to  wireless  local  number  portability 
 implementation.  (LRPA  PIM  29  -  Sprint  PCS) 

 Intermodal  Port  Date  Change  (Post  Confirmation)  Not  Rerognid  If  a  wireline  SPs  identifies  a  problem  with  a  port  and  is  not  able  to  meet  the  onginally 
 confirmed  desired  due  date  and  time.  then  wireline  service  providers  send  a  jeopardy  notice  to  the  wireless  SP  changing  the  original  DDT.  Wireless  carriers 
 currently  cannot  support  these  jeopardy  notices  this  creates  fall-  out  on  inter-  modal  ports.  The  customer  loses  service  when  the  disconnect  is  performed  by  the  ONSP  on 
 the  due  date  but  the  NNSP  has  failed  to  activate  the  port.  (LNPA  PlM  31  -  Syniverse/  TSI) 

 CSR  Not  Executable  For  Intermodal  Porting  From  Reseller  Typc  1  When  the  OSP  is  not  the  ONSP  but  a  reseller  and  the  number  porting  is  a  Typc  1 
 number  there  is  not  enough  information  provided  on  the  CSR  for  the  Wireless  SP  to  complete  the  LSR.  M&  Ps  for  interrogating  the  CSR  (for  example,  DSL,  RingMatt 
 and  Centrex)  prior  to  Wireless  sending  an  LSR,  including  the  step  of  informing  the  customer  that  they  need  to  prepare  for  changes  to  any  other  serviccs  provided  by  the 
 LEC  prior  to  the  NNSP  issuing  an  LSR  is  needed  so  CSRs  can  be  used  to  create  an  executable  LSR. 
 (LRPA  PIM  32V2  -  Syniverse/  Ts) 

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 NANC  Report  on  the  Intermodal  Porting  Interval  May  3,2004 
 10.  ADDITIONAL  CONSIDERATIONS  (Contd) 
 SP  Owrational  Svstems  Issues  Warranting  Further  Analvsis  To  Verih  Feasibilitr 
 Given  the  limited  time  for  which  detailed  analysis  could  be  done,  there  may  be  technical  issues  that  warrant  further  analysis. 

 A  service  order  cancellation  or  jeopardy  prior  to  due  date  will  not  undo  the  WAC  port  activation  needed  to  avoid  the  end  user  from  being  without  incoming  service. 
 Most  SP  systems  are  due  date  driven  and  although  cancellations  can  be  done  on  the  due  date,  they  can  not  be  undone  if  the  port  is  activated  prior  to  duedate.  Processes 
 that  allow  the  port  to  revert  back  to  prior  state  may  be  needed  to  minimize  customer  service  disruptions  if  ports  are  allowed  to  take  place  prior  to  due  date. 

 Processing  of  billing  changednotifications  happen  on  or  after  due  date  and  the  customer  educationlimpact  of  advancing  activation  has  yet  to  be  analyzed. 
 Wireline  disconnects  are  due-  date  driven  and  if  a  port  takes  place  prior  to  due  date  all  existing  pre-  due  date  system  processes  and  manual  activities  have  yet  to  be  fully 
 analyzed  to  ensure  they  can  be  performed  without  incident  in  the  post  due-  date  timeframe.  In  one  example,  a  major  LEC  has  difficulty  completing  disconnects  if  the 
 port  is  activated  in  advance  of  the  due  date. 
 Some  SP  systems  do  not  allow  personnel  to  distinguish  between  wireless  and  wireline  ports  nor  can  they  determine  if  a  service  order  has  flowed  through  and  is  eligible  for  a 
 shortened  interval  before  issuing  the  port  confirmation,  making  it  difFicult  to  administer  the  process  and  respond  to  customer  requests  andor  wireless  SP  inquiries 
 as  to  the  candidacy  of  porting  prior  to  due  date. 
 Service  Providers  should  consider  the  impacts  on  existing  porting  processes  and  back  office  processes  if  they  choose  to  activate  a  port  prior  to  the  due  date.  The  A3 
 Proposal  (Adapted  from  WirtlesslWireline  Integration  Reports)  allows  a  port  to  be  activated  24  hours  prior  to  the  due  date  if  there  is  no  problem  with  the  port  request. 
 Activating  early  requires  modification  of  the  due  date  on  the  SV  at  the  WAC.  Service  Providers  may  choose  to  automate  this  process.  Automating  the  modify  of 
 the  subscription  due  date  will  q  u  i  r  e  business  and  technical  requirements  to  be  identified,  system  development  and  testing  to  ensure  all  issues  are  addressed  SO  that 
 customers  wont  experience  delays  or  porting  errors. 
 Intermodal  ports  are  subject  to  fallout  and  those  that  require  manual  intervention  an?  only  required  to  be  available  for  activation  on  the  due  date,  however,  NNSPs  who  fail 
 to  see  a  port  available  for  activation  prior  to  the  due  date  may  call  the  JXC  to  ask  why.  Some  LECs  are  not  able  to  track  flow-  through  for  wireless  intermodal  porting 
 and  systems  and/  or  tools  may  need  to  be  identified  and  prepared  so  that  internodal  porting  activity  can  be  monitored. 

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 NANC  Report  on  the  Intermodal  Portlng  Interval 
 10.  ADDITIONAL  CONSIDERATIONS  (Contd) 
 State  Reeulatorv  Issues 
 Local  jurisdictions  (State  PUCs)  may  require  LECs  to  report  specific  porting  events  relative  to  state  andlor  industry  porting  standards  in  the  form  of  performance  metrics. 
 Changes  to  industry  standards  as  well  as  the  need  to  track  and  report  on  porting  activity  that  take  place  prior  to  the  due  date  may  require  State  PUCs  to  introduce  revisions  and 
 additions  to  the  current  metrics  reported  by  LECS. 
 The  benefit  to  customers  realized  by  shortening  the  porting  interval  was  not  measured  by  the  IMG.  There  was  a  conscious  decision  by  the  IMG  to  let  Regulatory  authorities 
 determine  if  (1)  the  interval  was  sufficiently  shortened  to  warrant  implementation  of  one  of  the  alternatives  and  (2)  the  quantity  of  anticipated  internodal  porting  activity 
 was  sufficient  to  warrant  implementation  given  that  (a)  some  Wireless  SPs  may  opt  not  to  invoke  the  shortened  porting  interval  and  @)  the  quantity  of  intermodal  ports 
 which  actually  flow  through  may  not  achieve  the  level  of  activity  regulators  believe  warrant  such  an  implementation. 

 Additional  time  and  system  modifications  to  SP  systems  may  be  required  if  regulators  determine  that  SPs  must  employ  the  shortened  porting  interval  for  all  flow-  through 
 candidates  to  ensure  customem  derive  the  optimal  benefit  from  the  shortened  porting  interval,  given  the  cost  of  implementation. 

 Additional  time  and  system  modifications  to  SP  systems  may  be  required  if  regulators  require  all  SPs  participate  1M)%  in  the  shortened  internodal  porting  interval  using 
 fully  automated  processing  of  ports  from  order  issuance  through  port  activation. 
 Need  for  Simple  Intermodal  Data 
 The  LMG  did  not  attempt  to  determine  the  quantity  of  simple  intermodal  ports--  ports  that  are  error  free,  require  no  network  changes  nor  coordination  with  the  porting-  out  carrier.  If 
 the  quantity  of  simple  intermodal  ports  is  small,  do  the  benefits  to  consumers  to  support  a  shorter  intermodal  porting  interval  justi@  the  costs?  The  IMG  did  not  evaluate  the  costs 
 benefit  analysis  to  consumers  for  a  shorter  porting  interval. 
 One  Local  Service  Ordering  Guideline  (LSOG)  Version  for  Porting 
 The  industry  may  consider  establishing  one  common  LSOG  version  (a  uniform  format  and  exchange  of  information)  and  a  single  mechanized  interface  that  could  yield  efficjencies  by 
 reducing  the  implementation  time  and  effort  required  to  deploy  a  mechanized  interface  when  compared  to  automating  the  various  intercarrier  communication  process.  formats  and 
 forms  in  use  by  trading  partners  today.  Currently,  each  LEC  may  choose  a  diffemt  version  based  on  their  business  needs  to  process  consumer  updates  including  porting.  The 
 standard  in  porting  is  to  use  the  Old  Service  Providers  (OSP)  forms.  To  automate  porting  requests,  a  service  provider  must  be  able  to  automatically  process  any  LSOG  version  (the 
 Local  Service  Ordering  &  Provisioning  (LSOP)  committee  is  currently  working  on  LSOG  version  10)  that  the  OSP  may  be  using. 

 Page  28  of  35 
30
 ..  NANC  Report  on  the  Intermodal  Porting  Interval 
 May  3,2004 
 10.  ADDITIONAL  CONSIDERATIONS  (Contd) 
 One  Local  Service  Ordering  Guideline  (LSOG)  Version  for  Porting  (Contd) 
 Service  Providers  that  serve  a  large  geographic  area  have  to  be  able  to  process  any  LSOG  version  that  other  service  providers  are  using  in  that  geographic  m.  A  service  provider 
 could  find  it  necessary  to  be  able  to  process  L-  SOG  version  1  through  10  and  more  as  new  LSOG  versions  are  approved  for  production,  and  this  would  be  very  expensive  to  automate 
 and  maintain. 
 11.  FINDINGS  AND  CONCLUSION 
 The  IMG  considered  two  confirmation  proposals  with  either  of  three  activation  proposds  in  reducing  the  intermodal  porting  interval  for  wireline  t  d  h  m  wireless  porting.  The 
 combination  of  proposals  equated  to  six  proposal  plans. 
 The  estimated  high  level  cost  of  the  C1  proposal  and  the  difference  of  only  four  hours  between  the  shorter  porting  interval  of  the  C1  and  C2  proposal  combinations  appears  to 
 eliminate  the  C1  combination  proposals  from  consideration  as  a  potential  solution.  The  C1  proposal  could  cost  the  industry  and  consumers  in  excess  of  $6OOM  to  $1B.  These  costs  do 
 not  consider  savings  due  to  a  reduction  in  manual  staff  processes  which  have  no!  been  calculated. 

 Proposal  A1  requires  a  new  set  of  timers  for  the  WAC  and  changes  to  the  industries  OSSs  which  make  this  proposal  very  expensive.  Proposal  A3  achieves  the  same  time  saved  at  a 
 much  lower  cost  to  the  industry  and  consumers. 
 The  A2  proposal  was  evaluated  but  eliminated  after  discussions  related  to  the  impact  to  existing  processes  for  complex  orders.  The  IMG  agreed  that  this  proposal  did  not  allow 
 enough  time  to  consider  the  handling  of  complex  orders  and  Proposal  A2  is  not  recommended  at  this  time. 

 In  reviewing  the  C2  proposal  combinations,  the  C2  &  A3  combination  provides  the  shorter  porting  interval  and  the  most  economical  approach  to  an  intermodal  porting  interval  based 
 on  the  proposals  considered.  In  addition  to  the  items  in  the  Other  Considerations  section  of  this  report,  one  concern  of  this  proposal  combination  is  that  there  is  a  mixed  service 
 interval  for  91  1  that  NENA  believes  is  sustainable  and  yet  allows  a  shortening  of  the  intermodal  porting  interval.  An  additional  concern  is  the  period  of  time  the  consumer  will 
 have  two  lines  (cellular  and  landline)  and  will  be  billed  for  both.  This  problem  is  sustainable  as  well.  At  the  point  of  sale,  the  new  provider  should  advise  that  as  long  as  dial 
 tone  is  available  on  the  old  line,  it  is  available  for  use  and  will  incur  billing. 

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31
 NANC  Report  on  the  Internodal  PorUng  Interval  May  3,2004 
 12.  RECOMMENDATIONS 
 The  FCC  asked  that  the  NANC  provide  modified  LNP  process  flows  for  the  shorter  intermodal  porting  interval.  The  DAG  develop  multiple  proposals  for  shorting  the  porting 
 interval  and  recommends  that  the  LNPA  WG  update  the  LNP  process  flows  if  the  FCC  issues  an  order  on  its  conclusion  regarding  shortening  the  intermodal  porting  interval.  This 
 will  ensure  that  the  c  o  m  t  LNP  process  flows  are  adopted. 
 Of  the  six  proposal  combinations  evaluated,  proposal  combination  C2  and  A3  offers  the  shortest  "maximum  porting  interval"  (53  hours)  and  grcatest  reduction  Total  Time  Saved  in 
 Hours  (43)  for  the  "Low"  estimated  cost  impact.  The  IMG  Proposal  Analysis  indicates  that  there  are  no  cost  impacts  on  batch  processes.  complex  changes  to  SP  programming, 
 changes  to  existing  NPAC  timers,  or  WAC  software  changes.  Thus,  this  proposal  combination  could  offer  the  most  economical  opportunity  for  thc  industry  to  substantially 
 reduce  the  porting  interval  for  consumers. 
 In  order  to  support  the  C2  shorter  Confirmation  Interval.  SPs  would  be  required  to  u  r  a  mechanized  interface.  The  IMG  recommends  that  the  C2  and  A3  proposal  apply  only  to 
 simple  intermodal  port  requests  that  are  "error  free"  as  described  in  this  report.  Based  upon  known  information  at  this  time,  the  IMG  estimates  that  the  industry  would  need 
 approximately  24  months  to  implement  the  C2  proposal  after  an  FCC  mandate  is  isyed.  In  addition,  to  the  extent  that  LNPcapabk  switches  are  alrrady  provisioned  with  the  IO-  diat 
 trigger,  proposal  A3  could  be  implemented  more  quickly. 
 In  summary,  the  IMG  considers  the  CUA3  proposal  the  most  promising  and  recommends  that  the  NANC  forward  this  document  to  the  FCC  and  ask  that  the  appropriate  industry  a  d 
 regulatory  bodies  be  given  additional  time  necessary  to  prepare  a  complete  analysis  of  t  h  i  s  alternative.  Section  10  titled  "Further  Considerations"  identifies  issues  not  addressed  by  the 
 IMG.  Although  some  of  these  issues  are  being  addressed  by  the  LNPA-  WG,  Section  10  identifies  additional  issues  that  may  impact  the  implementation  of  proposd  CzIA3  and 
 therefore  further  analysis  by  Service  Providers  and  Regulators  is  warranted  before  a  decision  is  made  to  implement  CUA3.  The  IMG  would  like  to  note  that  this  xpfl  has  not 
 been  evaluated  by  the  NANCs  LNPA-  WG  and  that  the  IMG  did  not  attempt  to  determine  if  the  CWA3  proposal  achieves  the  customer  benefits  desired  by  the  FCC. 

 The  NANC  IMG  would  like  to  share  with  the  FCC  that  the  LMG  spent  an  estimated  900  work  hours  in  meeting  time  to  discuss  and  write  the  report  and  the  participants  along  with 
 their  respective  subject  matter  experts  spent  an  additional  1.100  hours  work  hours  in  providing  input  to  this  report.  The  total  work  hours  spent  on  the  repofi  arc  estimated  to  be 
 2,000  hours. 

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32
 NANC  Report  on  the  Intermodal  Porting  Interval  May  3,2004 
 12.  RECOMMENDATIONS  (Contd) 
 Early  Morning  Activation  Can  Reduce  the  Porting  Interval  Now  The  nominal  interval  of  96  hours  can  be  reduced  unilatedly  by  a  wireless  canier  (or  any 

 carrier)  which  activates  its  porting  record  shortly  after  midnight  on  the  due  date.  Assuming  ao  1159PM  10  Digit  Trigger  (IODT)  deployment  in  thc  donor  switch,  LNP  activation  in 
 the  early  morning  (e.  g.,  12:  05AM)  can  reduce  several  hours  from  the  total  interval.  The  mean  porting  time-  of-  day  is  mid-  to-  late  afternoon.  Using  5PM  as  an  average  port  tim,  17 
 hours  would  be  reduced  from  the  96  hour  interval,  an  18%  reduction.  This  practice  is  used  by  some  carriers  today.  This  recommendation  may  be  implemented  for  little  or  no  cost, 
 can  be  deployed  immediately  by  some  carriers,  and  provides  a  tangible  benefit  to  end  users. 

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 NANC  Report  on  the  Intermodal  Porting  Intend  May  3,2004 
 13.  GLOSSARY 
 OSS  -Operational  Support  System 
 Port  Response  -  Finn  Order  Confirmation 
 Complex  Ports  -  Complex  ports  currently  have  an  activation  interval  in  excess  of  throe  days,  and  may  be  negotiated  between  service  providers.  One  form  of  complexity  involves 

 the  first  number  of  an  A-  NXX  to  bc  pond.  This  first  number  currently  requks  a  five  day  activation  period. 

 LNP  -  h  a  l  Number  Portability. 
 LSR  -  Local  Service  RequestRort  Request. 
 NNSP  -  New  Network  Service  Provider. 
 NPAC  -Number  Portability  Administration  Center. 
 ONSP  -  Old  Network  Service  Provider. 
 Simpk  Port  -  Simple  ports  are  defined  as  those  ports  that:  do  ~o  t  involve  unbundled  network  elements,  involve  an  account  for  a  single  line  (porting  a  single  line  from  a  multi- 
 line  account  is  not  a  simple  port),  do  not  include  complex  switch  vanslations  (e.  g.,  Centrex  or  Plexar,  ISDN,  AIN  services,  remote  call  forwarding,  multiple  services  on  the  loop),  m  y 
 include  CLASS  features  such  as  Caller  ID,  and  do  not  include  a  reseller.  All  other  ports  are  considered  complex  ports. 
 (andor)  Simple  Port: 

 A  Simple  Port: 
 Does  not  include  any  Unbundled  Network  Elements  (UNE)  or  Imp  facifities. 
 Involves  an  account  for  a  single  line  only.  (Porting  a  single  line  from  a  multi-  line  account  is  not  a  simple  port.) 

 Does  not  include  complex  services,  such  as: 
 -  Centrex  or  Plexar 

 -  AINservices  -  Remote  call  forwarding 
 -  -  WirelineDID 

 -  ISDN 
 Multiple  services  on  the  loop  (DSL  etc.) 

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 .  NANC  Report  on  the  Intermodal  Porting  Interval 
 May  3,2004 
 13.  GLOSSARY  (Cont'd) 
 simple  Port:  0 

 -  CallerID  -  Automatic  call  back 
 -  Automatic  redial 

 May  include  CLASS  features  such  as: 

 -  Etc. 
 Does  not  include  a  reseller. 
 Does  not  include  numbers  associated  with  Wireless  Typc  1  interconnedon  arrangements. 

 SP  -  Service  Provider. 
 SV  (Subscription  Version)  -  the  term  for  the  NPACs  ported  number  record.  The  data  includes  the  telephone  number,  routing  information  specific  to  that  p  o  d  number  and 
 other  information  related  to  the  record  such  as  the  current  SP  1D.  The  SV  stored  at  "PAC  has  more  information  than  is  transmitted  when  broadcast  is  done  and  is  somewhat  larger 
 than  the  corresponding  SV  contained  in  a  user's  LNP  database. 

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 NANC  Report  on  the  Internodal  Porting  Interval  ,.  May  3,2004 
 14.  NANC  INTERMODAL  PORTING  INTERVAL  IMG  PARTICIPANTS 
 1  2 
 3  4 
 5  6 
 7  8 
 9  10 
 11  12 
 13  14 
 15  16 
 17  18 
 19  20 
 21  22 
 23  24 
 25  26 
 27  28 
 29  30 
 31  32 
 33  34 
 35  36 

 37  38 
 39  40 
 41  42 

 Matthew  Steve 
 Mikc  Bob 
 Craig  Natalie 
 Chris  Commissioner  Anne 
 Jim  Pamela 
 Mike  Commissioner  Tom 
 Rosemary  Dave 
 Tiki  Don 
 Julie  Ken 
 Suzanne  Rick 
 Paula  Christine 
 IMG  Chair  Hoke  Paul  F. 
 Mark  Dawn 
 Maggie  Jason 
 Anne  John  T. 
 Lori  Anna 

 Marie  Karen 
 Adam  C. 
 Michael  Beth 

 Susan  Dennis 
 Ed  Bill 

 Craig 

 Adams  Addicks 
 Altschul  Atkinson 
 Bartell  Billingsley 
 Bowe  Boyle 
 Castagna  Connell 
 Donzc  Dunleavy 
 Emmer  Gamer 
 Gaugler 
 Groenen  Havens 
 Howard  Jones 
 Jordan  Kelly 
 Knox  La  Gattuta 
 Lancaster  Lawrence 
 Lee  Lee 
 Mardick  McHugh 
 Messing  Miller 
 Mindell  Moore 
 Mulberry  Newman 

 OConnor  0'  Donne11 
 Ortega  Robins 
 SdaS 
 Shaughnessy 

 Gray 
 SBC  NeuStar 
 CTIA  NANC 
 Sprint  NASUCA 
 Nextel  NE  PSC 
 Verizon  NeuStw 
 BellSouth  NY  PSC 
 Nextel  Qwest 
 ALTS  NE  PSC 
 Verizon  Wireless  Sprint 
 Cox  Communications  "A 
 T-  Mobile  NY  PSC 
 Sprint  AT&  T 
 AT&  T  XO  Communications 
 Verisign  MCI 
 Sprint  OPASTCO 
 CTIA  T-  Mobile 
 SBC  Verizon  Wireless 
 MCI  Telcordia 

 Verizon  Cox  Communications 
 Nextel  Citizens  Communications 
 Verizon  Wireless  BellSouth 

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 NANC  Report  on  the  Intermodal  Porting  Interval  May  3,2004 
 43  44 
 45  46 
 47  48 
 49  50 
 51  52 
 53 

 Commissioner  Elliott  Thomas 
 Ron  Brent 
 Doug  Randy 
 Sue  Steve 
 Diana  Mark 
 Sanford 

 Smith  Soroka 
 Steen  Struthers 
 Sullivan  Thoesen 
 Tiffany  Trotman 
 vargas  Welch 
 Williams 

 Iowa  UB  USTA 
 BellSouth  NeuStar 
 Verizon  Iowa  UB 
 Sprint  Compte1 
 Verizon  SBC 
 FCC 

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