On September 15, the Federal Communications Commission (FCC) granted delegated authority to four states - California, Florida, New York and Massachusetts - for number optimization measures. In addition, several other states may be planning to petition the FCC for similar authority.

Because of Lockheed Martin CIS's ("CIS") current role as the interim Pool Administrator (PA) in number pooling trials in Illinois and New York state; the NANC's recommendation to the FCC that CIS serve as the national PA; and the agreement under development with the North American Numbering Council (NANC) establishing the terms by which CIS will be asked to provide services as the National Pool Administrator, CIS has been contacted by the states regarding its potential roles and responsibilities during a trial as the interim PA and posed with questions about use of number conservation measures in the particular state.

As a result of inquiries from states, service providers, and the media, NANPA and the NANC have cooperated to assemble summary responses to the following list of frequently asked questions regarding pool administration and number pooling.

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Background

Today, if a Service Provider (SP) requires additional numbering resources or needs numbers for the first time to establish service in a geographic area, called a Rate Area or Rate Center (smallest area used by most Service Providers to rate calls), it must apply to the NANPA and per industry guidelines, will receive numbers in blocks of 10,000 to serve the rate area, regardless of how many numbers are needed by the service provider.

For example, if a company was authorized to provide service and applied for resources to offer service in an area code, it would have been assigned a 10,000-number block for each of the rate areas within the NPA where it wanted to serve customers. For example, if there are 42 rate areas in an area code and if an authorized service provider wanted to offer service in all 42 rate areas, it would need to be assigned 42 blocks of 10,000 numbers each (one for each rate area) or 420,000 numbers. This would pertain even if the company has no initial customers or just a few initial customers in a rate area.

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1. What is Number Pooling?

Per the NANC's Numbering Resource Optimization Report to the FCC, "Thousands-Block pooling involves the allocation of blocks of sequential telephone numbers within the same NXX to different SPs and potentially to different switches, which serve customers within the same rate area. All ten thousand numbers within each NXX continue to be assigned to one rate area, but are allocated among multiple SPs at the Thousands-Block (NXX-X) level." Thousand Block Number Pooling or simply 1K Pooling is based on the local number portability (LNP) technology, which allows phone numbers to be ported between service providers (within rate centers). The industry, through the NANC, has developed industry requirements for both the administration and the LNP technology software necessary to assign and route calls to numbers assigned to service providers in blocks of 1,000-number increments. The industry requirements ensure uniformity in how numbers are assigned to Service Providers and routed through the network.

2. Is Number Pooling in Effect Anywhere?

Yes. At least two states have held industry meetings to finalize "trial" thousand-block number pooling technical arrangements. Competitive bids were used to solicit and select an interim Pooling Administrator. These trials have been in the 847 area code in Chicago and in New York's 212 area code and were implemented prior to the inception of uniform national pooling guidelines supported by the industry and the NANC. These initial trials are proceeding and have been expanded to the 630, 773 and 312 NPAs in the Chicago area, and 718 area code in New York. The 708 NPA will be opened for pooling in the Chicago area early in 2000 and negotiations with CIS for the interim administration of pooling is underway for the 516 area code in New York.

In addition, NANC has recommended to the FCC that number pooling be implemented on a uniform basis using national pooling administration/assignment guidelines developed by the Industry Numbering Committee (INC) as well as uniform software requirements developed by the NANC's Local Number Portability Administration Working Group (LNPA-WG). These uniform industry guidelines and technical standards provide the states and service providers a road map to the uniform implementation of number pooling and will ensure uniformity in how numbers are assigned to Service Providers and routed through the network. Refinements to the guidelines are expected to be completed by year-end.

3. How does Number Pooling Work?

Pooling may be implemented in rate areas (or rate centers) where the LNP infrastructure is in place. The LNP infrastructure provides the network capability to support the assignment of thousand blocks from a single NXX to be assigned between different switches and/or service providers. It is generally expected that in each area code where pooling is implemented, each of the rate areas in the NPA will have their own pool of thousand-blocks. The blocks in each pool will be drawn upon and assigned by the Pool Administrator to LNP capable service providers that are participating in number pooling. Note that service provider participation is initiated by a regulatory order unless there is a voluntary agreement to pool among the service providers providing service in the rate area in question. Once there is an order or a voluntary agreement in place, the steps required to establish a rate area pool are itemized in the national INC Thousand Block Pooling Administration Guidelines.

Once pooling begins, a service provider will apply for a thousand-block instead of an NXX. To do this, the service provider sends a request to the PA, who then assigns a thousand-block to that service provider. On the date that they requested the thousand-block to be effective, the numbers are ported to the SP for their assignment to customers.

4. Who is the Pooling Administrator?

Currently, Lockheed Martin CIS has been selected through competitive bid to serve as the interim Pooling Administrator in the Illinois and New York trials. After determining that number pooling is an extension of the Central Office Code Administration duties currently provided by CIS as the North American Numbering Plan Administrator (NANPA), the NANC recommended to the FCC that CIS also be the national pooling administrator. As a result, the NANC's Pooling Administration Issues Management Group (IMG) is currently finalizing terms and conditions for review and endorsement by the NANC and the FCC. The FCC is currently considering the NANC's recommendation that CIS be the national pool administrator and their decision will be made known in a future FCC Order.

5. Will CIS, as the NANPA, provide the Pooling Administration function for the states that receive authority from the FCC?

No. If selected to perform interim pooling administration functions for a state, CIS will not be performing this function as the NANPA, but as CIS until the FCC makes a decision as to whether CIS will be confirmed as the national pool administrator.

6. What happens to state rollout after the FCC issues an order for nationwide pooling?

Any decision by the FCC would supercede the individual state's delegated authority that they receive prior to a FCC decision. It was recommended by the NANC and it is expected that the FCC's Order will require all thousand block pooling trials to be transitioned to comply with the national thousand block pooling administration guidelines and technical standards. The FCC has stated publicly that the national pooling order is expected to be completed by the end of March 2000.

For those areas participating in a state pooling trial, CIS, if selected as the national Pool Administrator by the FCC, will "transition" these pools to the national pooling administration system that is currently under development. CIS has agreed to transition the areas pooled, with few exceptions, free of charge if the fee paid for pooling implementation during a state pooling trial matches that fee specified in the national pricing schedules. (However, if the state pooling implementation fee paid during the trial does not match this fee schedule, payment of the difference prior to the transition of the pooled area to the national rates may ensure there are no other transition charges.)

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1. How much does pooling cost?

The cost to the industry for the administration services of CIS as the national pool administrator is considered proprietary and is not available publicly. However, the rates for the initial trials in IL and NY were identified through individual competitive bids, and negotiated with the respective Local Number Portability (LNP) Limited Liability Corporations (LLC's). Going forward, CIS has agreed to perform pooling administration services in any state trial at national pooling rates.

Beyond "pooling administration," there are other work efforts and costs. These include but are not limited to the following:

• NPAC modification (necessary to accommodate number pooling)
• CIS Number Portability Administration Center (NPAC) charges (to broadcast pooled-block routing data related to pooled blocks)
• NPAC User support services (for pooling)
• Service Provider network modifications (SP system impact varies and may include operational, maintenance and LNP (routing) infrastructure network elements).

2. How can a state tell Service Providers to begin pooling if they don't know what it will cost?

The cost for performing the pooling administration function is just one of the cost elements (and work efforts) required before pooling could be deployed. The North American Numbering Council (NANC) is negotiating with CIS on the national Pooling Administrator terms and conditions.

The regional LNP Limited Liability Corporation (LLC) is the body that manages the Number Portability Administration Center (NPAC) contracts and associated porting cost structure. The NPAC costs (separate from administration costs) established for LNP can be provided under non-disclosure from CIS, the NPAC vendor, to the participants.

Negotiations are currently underway between the joint LLC National Negotiations Team (NNT) and the NPAC vendor on the industry cost for NPAC transactions necessary to support pooling.

3. How are pooling costs allocated and recovered?

This has yet to be decided at either a national or a state level. However, the FCC will determine how costs will be allocated and recovered in those areas where pooling is implemented using the national uniform approach.

The FCC, when recently delegating authority to several states to begin interim pooling trials, requires the states to determine cost allocation and recovery of costs related to the implementation of (non national) pooling trials. It is anticipated that the FCC's Order will determine how national pooling costs will be allocated and recovered but only for those costs related to pooling activities employing national uniform industry processes and standards recommended by the industry and the NANC. Interim state pooling trial costs will be determined at the individual state level.

4. How can states move forward without cost allocation and recovery?

The states with delegated pooling authority are required under the current FCC granted waivers to determine cost allocation and recovery for pooling trials.

Orders to date delegating interim pooling authority did not specify if the states need to complete this task prior to ordering a pooling trial. States can however begin the process for pooling while addressing cost allocation and recovery.

5. How long should it take the industry to implement a number pooling trial?

Neither CIS nor the NANC are in a position to answer the question because each service provider must assess the modifications that are necessary to operational support systems and network infrastructure to support a number pooling trial.

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1. I have heard references made to differing software in the Number Portability Administration Center (NPAC) system. What software release is required to start pooling?

CIS can perform the pooling administration function with NPAC Release 1.4, 2.0, or 3.0. Currently Release 2.0 (which has Release 1.4 capability) is available throughout the U.S. However, as of November 1, 1999, only the Mid-West Regional LLC has paid the licensing fee and activated Release 1.4 to support the Illinois pooling trial. Other LLCs that want to use the Release 1.4 pooling functionality found in Release 2.0 would have to agree to turn on that feature in the NPAC. Some Service Providers will also need to undergo NPAC interface testing before Release 1.4 functionally can be used for pooling.

NPAC Release 3.0 also supports number pooling and contains the ability to assign a block of numbers to a service provider in one transaction process in the NPAC. This capability meets national industry standards identified by the NANC's LNPA WG (known as the national pooling NPAC release). Release 3.0 will be available to begin service provider testing on 6/30/99. This interface testing for Release 3.0 is expected to last 4 - 6 months. As of November 1, 1999, the Mid-Atlantic, Southwestern, Southeastern, Western and West Coast LLCs have ordered Release 3.0.

2. What is the difference between NPAC Release 1.4 or 2.0 and software Release 3.0?

Release 3.0 provides all of the standard national number pooling functionality required by the NANC LNPA Working Group and industry technical standards bodies. Release 1.4 was a customized release designed for the Midwest LLC's use. The initial purpose of Release 1.4 was in support of a number pooling test in the Illinois trial. The critical difference between the two releases is the inclusion of Efficient Data Representation (EDR) in Release 3.0 which permits downloading and storage in an SP's database 1,000 numbers "as a single record" instead of 1,000 records. This capability, only available in Release 3.0, was developed to resolve LNP database capacity issues associated with widespread telephone number pooling deployment. For this reason, it is considered to be a critical requirement by many service providers.

CIS, as the NPAC provider, is prepared to support pooling under software Release 2.0 (which contains the Release 1.4 pooling functionality, but requires turn up authorization from other LLCs). Release 2.0 contains only a small percentage of the national telephone number pooling requirements. Due to carriers database capacity concerns, carriers see the need for NPAC records created using Release 1.4 to undergo an additional step of record migration (from Release 1.4) to the national uniform industry pooling Release 3.0. The customer and administrative impacts from this record migration are currently unknown.

3. Have issues been raised about service provider LNP database capacity?

Certain service providers have identified an LNP database limitation constraining the quantity of records that can be stored in their databases. Questions concerning service provider LNP database capacity should be directed to Service Providers.

As stated above, the "EDR" capability in Release 3.0 was developed to overcome service provider LNP database capacity constraints. Using NPA 847 as an example, there have been approximately 250,000 numbers ported due to pooling since the trial started in June of 1998. This equates to 250,000 records in each service provider's LNP databases. With NPAC Release 3.0, service providers that require or will use this capability could potentially reduce this quantity to few as 250 records - a reduction in storage needs by a factor of 1000.

4. Have other issues been raised?

Yes, some industry members have identified the need for modifications to national systems (Telcordia National Routing Database) and individual service provider's may require modifications to Operations Support Systems (e.g., telephone number assignment, billing, maintenance, provisioning) to accommodate the requirements of telephone number pooling.

Additionally, there are LNP database download issues, which may affect block allocation to Service Providers, and subsequently, activation of customer telephone number assignments. Requirements that describe the procedure to migrate records from Release 1.4 to Release 3.0 need to be developed.

Numerous Service Providers have indicated that their current OSSs rely on the association of an NPA-NXX with one specific Service Provider end office. These Service Providers may require significant OSS enhancements to support the administration, provisioning, billing, and maintenance of thousand blocks.

5. How did the Service Providers in Illinois and New York get around these obstacles?

Each Service Provider may have a different system and method of operating and they would have to individually answer this question. As for the LNP download concern, CIS, in conjunction with the industry, has modified the NPAC download schedule and put NPAC personnel on notice to monitor LNP downloads to reduce issues with data acceptance and ensure service providers' systems are online.

6. What date should be used as the most realistic date for National Pooling to begin?

The most realistic date to expect national pooling administration and pooling software to be implemented depend on when a national regulatory order is released and service provider testing is completed. If an order is released by March 2000, the pooling administration system will be ready within 7-9 months. NPAC software Release 3.0 will be released for testing by service providers in July 2000.

• Pooling Administration
  CIS has identified in the NANC national pooling terms and conditions that it will take nine months for the pooling administration system to be developed and implemented. CIS also asserts that this interval can be shortened to seven months if ordered. CIS is currently using interim methods to administer interim pooling trials, including those underway in Illinois and New York. This method can be expanded to include additional trials.
• NPAC Software Y2K Quiet Period (November 1999 to March 2000)
  The Number Portability Administration Center (NPAC) and most if not all, service providers will observe a Y2K quiet period until after February 29, 2000.
• Release 3.0 National Pooling with Efficient Data Representation (EDR) (October 2000)

  1. Release 3.0 has been authorized by five LLCs and is being considered by the other two LLCs.
  2. Release 3.0 with EDR will be ready for NPAC testing in June 2000.
  3. EDR will resolve service provider LNP capacity issues.
  4. Service provider/NPAC testing is scheduled for completion October 2000.

Service provider/NPAC testing is scheduled to begin completion in October 2000. The industry is currently reviewing this test plan.

Individual service provider implementation constraints vary and it is suggested interested parties review the NANC's Numbering Resource Optimization (NRO) Report to the FCC to get a full understanding of some of the work effort and resources necessary to implement thousand block number pooling.

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Additional information on this and other Numbering-related issues should be referred to the NANPA by calling John Manning at 202-533-2655 or at john.manning@NANPA.com.

The latest "Thousand Block NXX-X Pooling Administration Guidelines" (INC 99-0127-023) can be found at http://www.atis.org by clicking on "INC" and then on "INC Documents." Please note the most up to date version, which is currently being modified, can be found under "INC Working Documents". The INC is expected to reissue the revised Thousand Block Number Pooling Assignment Guidelines in December 1999.

Additional information and reports detailing the NPA 847, NPA 212 and other number pooling trials can be found at http://www.numberpool.com

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