Or, if dial-tone service is cut over promptly from the ILEC to the CLEC, but interim number portability is commonly cut over at a different point in time, incoming calls will go astray, and again competition and consumers will suffer. OSS measurements can capture these problems. They can assist ILECs in self-assessments, so that corrective actions can be taken before disputes arise. Alternatively, when disputes do arise, appropriate measurement data may make it easier to distinguish isolated incidents from recurrent problems. I affirmatively support the notion of proposing guidelines or model rules instead of binding FCC rules, and I am grateful to Commissioner Powell for his leadership in advocating this approach.
Guidelines express a spirit of partnership with the state commissions.
This proceeding will establish a detailed record upon which the states and the FCC can proceed in a cooperative fashion. OSS measurement guidelines should enable states to act rapidly, as now is the time when such measurements will prove to be most useful. Measurement guidelines will enable the state commissions and the FCC to use a common framework to monitor what are, typically, regional rather than single-state systems and databases. Guidelines will also provide state commissions with the flexibility to address state-specific circumstances and needs. It should be noted that we also have chosen at this time not to propose performance or technical standards.