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These competing telephone companies include   interexchange carriers (IXCs), such as AT&T, MCI, and Sprint; cable operators, such as Time   Warner and Cablevision Lightpath; competitive access providers (CAPs), such as MFS and   Teleport; and wireless carriers, such as current cellular licensees and future PCS service  Y-providers.f &6  zP- ЍSee, e.g., Sprint Strategy for Local Service Challenge Rests on Cable Alliance, Communications Daily, at  zPU-  Z23 (November18, 1994); AT&T Applies for Local Service Authority in Two States, Telecommunications Reports,   yat 3536 (May8, 1995). The term "PCS" is used here as it is defined in Section24.5 of the Commission's rules,  zP-and is distinct from the way it is used with respect to 500 number services. See n. PCS57  infra.f  Yv-  A` ` 6. In conjunction with our consideration of the administration of the North  Y`-  American Numbering Plan (NANP), we have solicited comment on number portability. Z`$ zP5- ЍSee Administration of the North American Numbering Plan, Notice of Inquiry, CCDocket No.92237, 7   FCC Rcd 6837, 6842, 41 (1992); Notice of Proposed Rulemaking, 9 FCC Rcd 2068, 2075, 4142 (1994);  xP-Report and Order, FCC95283 (adopted July13, 1995).Ė In that   proceeding, we recognized the importance of number portability with respect to competition.   ;We deferred consideration of number portability to a future proceeding, however, because the   technical feasibility, implementation costs, and overall benefits of number portability required  Y -  <further study.  F zP- ЍAdministration of the North American Numbering Plan, Notice of Proposed Rulemaking, CC Docket No.92237, 9 FCC Rcd at 2075, 42. We now initiate that further study and examine these, and other important, issues relating to number portability.  Y -  ` ` 7. In this Notice, we tentatively conclude that the portability of telephone   numbers benefits consumers of telecommunications services and would contribute to the   development of competition among alternative providers of local telephone and other   telecommunications services. We recognize, however, that at this time we lack sufficient   information on the costs (monetary and nonmonetary) of making telephone numbers portable   ;either between service providers, services, or locations. Furthermore, we tentatively conclude   that the Commission should assume a leadership role in developing a national number portability   policy, and we seek comment to determine the specific nature of this role. We seek comment   on whether the Commission should promulgate rules to ensure the development of number   portability, and if so, what rules the Commission should promulgate. Finally, we tentatively   conclude that service provider portability of 900 and 500 numbers is beneficial for customers" ,**"   .of those services. We seek comment on that conclusion and on the costs of making such portability available and other related implementation issues.  Y-! II. BACKGROUND ׃  Xw-` ` A. The Telephone Numbering Plan   YI-  @ ` ` 8. II  INROU Telephone numbers in the United States consist of ten digits, as required by  Y3-  the NANP. 3 xP - ЍThe NANP now is applicable to 18 countries: Anguilla; Antigua and Barbuda; Commonwealth of the   Bahamas; Barbados; Bermuda; British Virgin Islands; Canada; Cayman Islands; Dominican Republic; Grenada;   Jamaica; Montserrat; Saint Kitts and Nevis; Saint Lucia; Saint Vincent and the Grenadines; Trinidad and Tobago; Turks and Caicos; and the United States (including Puerto Rico and the U.S. Virgin Islands). The first three digits of an NANP telephone number are referred to as the area   icode or Numbering Plan Area (NPA) code. If an NPA code represents a geographic region,   such as 202 for the District of Columbia, the telephone number is referred to as a geographic   telephone number. In contrast, certain NPA codes, for example, 800, 900, and 500, identify   certain services (not geographic regions), and are referred to as nongeographic telephone   Jnumbers. The second three digits, referred to as the central office code or NXX code, identify    the service provider switch that serves a specific customer location. NXX codes will be assigned   in the future by the new NANP administrator to carriers requiring telephone numbers, such as  Y{-  LECs, cellular carriers, paging companies, CAPs, and smaller local telephone companies. { zP- ЍSee Administration of the North American Numbering Plan, Report and Order, FCC95283 (adopted   July13, 1995). Currently, a local administrator (usually the dominant LEC within a particular area) is responsible   not only for assigning individual central office codes, but also for entering new assignments into the Local Exchange   Routing Guide (LERG). The LERG contains the information necessary for routing messages, common channel signalling system (SS7) call set up, operator access routing, and data for rating calls. The last four digits, or the line number, are associated with a specific customer.  Y6-  A` ` 9. Because most telephone numbers within the NANP are associated with a   particular switch operated by a particular service provider, they are inherently non-portable.   The NXX code designates the switch within the NPA code to which a call should be routed.   ,The line number designates the specific location within the area served by the switch at which   Ythe call should be terminated. Therefore, a telephone number cannot be transferred outside the   wservice area of a particular switch or between switches operated by different service providers.   In other words, customers that decide to change service providers or move outside the service area of their current central offices typically cannot retain their telephone numbers.  Yh-  0` `  10. 500In contrast, telephone numbers with certain NPA codes are portable between   geographic locations because the IXCs are able to "map", or translate, the dialed,   non-geographic number into a geographic number. Thus, 800800, 900, and 500 numbers, for   xexample, are geographically portable meaning that customers receiving calls through these   services can change the locations where calls to these numbers are delivered without changing the number. "b ,** "Ԍ Y-  ?` `  11.  NXX1   8002 In addition, 800 customers can now change service providers and retain their   same 800 numbers. Originally, the NXX code of 800 numbers identified the specific 800   service provider responsible for handling the routing and billing of a particular 800 call. Thus,   when customers wanted to change 800 service providers, they also had to change their 800   number. In 1993, pursuant to Commission mandate, the Bell Operating Companies and  Y-  ,independent telephone companies replaced this system with a database system for 800 access. zP- ЍSee 800 Access, Memorandum Opinion and Order on Reconsideration and Second Supplemental Notice of Proposed Rulemaking, CC Docket No.8610, 6 FCC Rcd5421 (1991); Order, 7 FCC Rcd 8616 (1992).   Under this system, the database contains the NXX code and line number for each 800 number   and identifies the IXC that the customer has selected to carry its calls. The LECs identify the   appropriate service provider for each 800 call by transmitting a query to the database via their   SS7 networks. Because the database system permits LECs to use the entire 800 number, rather   than just the NXX code, to identify the preselected IXC, 800 service customers may change 800   service providers while retaining the same NXX code and line number. In addition, a customer   xmay use multiple 800 service providers to handle calls placed to a single NXX code and line   xnumber. Indeed, 800 customers can even choose different IXCs to handle calls placed to the same 800 number, based on the origin of the call or the time of day.  Y-  ]` `  12. NXX  500_2 While customers of 500 and 900 services can change the termination location   for their calls, they cannot retain the same NXX code and line number if they wish to change   service providers. Instead, LECs use the NXX codes of 500 and 900 numbers to route calls to  YM-the appropriate IXCs, as they did originally with 800 numbers.mM" zP -Ѝ500 Access Order, 9 FCC Rcd at 7873, 3.m  X-b ` ` B. Types of Number Portability   Y-  ` `  13. IIB There are three basic types of number portability: service provider  Y-  hportability, service portability, and location portability.  xP)-  ЍINCINCThe Industry Numbering Committee (INC) workshop on number portability currently is working to develop  zP-  formal definitions for these three types of number portability. See Local Number Portability, Draft Report of the   Industry Numbering Committee's Number Portability Workshop, PORT66 R2, at 78 (draft of June28, 1995).  zP-  See also A Blueprint for Action: The Transition to Local Competition, MCI Telecommunications Corporation, Tab3,   at1 (March 1995). The INC is a standing committee of the Industry Carriers Compatibility Forum (ICCF), which   in turn exists under the auspices of the Carrier Liaison Committee (CLC) of the Alliance for Telecommunications   Industry Solutions (ATIS). ATIS sponsors a number of industry committees and forums, such as CLC, ICCF and   INC. The CLC seeks to resolve, through consensus procedures, equal access and network interconnection issues arising on a communications industrywide basis. Service provider portability refers to   the ability of end users to retain the same telephone numbers (that is, the same NPA and b NXX  Y-  Lcodes and the same line numbers) when changing from one service provider to another.'  xP&- ЍLegislation currently pending in Congress would impose an obligation to provide number portability.   S.652 would require LECs possessing market power in the provision of telephone exchange services or exchange   =access services to provide telecommunications number portability. S.652 defines " telecommunications number  zP')-  Nportability" as the ability of users of telecommunications services to retain, at the same location, existing   telecommunications numbers without impairment of quality, reliability, or convenience when switching from one"),***" telecommunications carrier to another." [emphasis added] S.652, 104th Cong., 1st Sess., 8(b) (1995).  ?H.R.1555 does not define "number portability", but states that the obligations pursuant to Section 201 of   the Communications Act include, among other things, "[t]he duty to provide, to the extent technically feasible and   economically reasonable, number portability in accordance with requirements prescribed by the Commission." H.R. 1555, 104th Cong., 1st Sess. 101 (1995).' "@,**}"   Service portability refers to the ability of end users to retain the same telephone numbers as they   change from one service to another (for example, from POTS to ISDN). Location portability   refers to the ability of end users to retain the same telephone numbers when moving from one   location to another, either within the area served by the same central office or between areas served by different central offices.  X_-` ` C. Current Status of Number Portability   Y1-  O` `  14.  EFFORTS1 IIC Efforts are under way in several states to explore various issues associated   with number portability.  TRIALS1 In Illinois, Ameritech issued a request for proposals (RFP) to permit   its customers to change providers of local telephone services without changing their telephone   Jnumbers. Ameritech's RFP sought to implement service provider portability by April1, 1996,    with service and location portability available either concurrently or within two years thereafter.   JNone of the proposals submitted in response to its RFP, however, addressed all of Ameritech's  Y -  requirements.  @ xP- |ЍAmeritech received responses to its RFP from: AG Communications Systems; Anderson Consulting   (partnered with Northern Telecom); AT&T Network Systems; Bellcore; Digital Equipment Corporation; DSC   Communications Corporation; Ericsson; IBM Integrated Systems; Hewlett Packard; Lockheed; Siemens StrombergCarlson; Stratus Computer (partnered with U.S. Intelco); and Tandem Computers. As a result, Ameritech plans to make the responses to its RFP available to the   YIllinois number portability task force and will attempt to develop a consensus proposal through  Yz-that task force.Zz(  xPS- ЍThe Illinois Commerce Commission has adopted the recommendation of its staff to establish a number   portability task force. The task force was charged with investigating the development and implementation of longer zP-term database solutions. Illinois Order at 110.  YL-  O` ` 15. In New York, ten companies, working with the New York Public Service  Y6-  Commission, have jointly issued an RFP to initiate a number portability trial.X6J  zP1!- @ЍSee NYPSC Number Portability Order. The ten companies issuing the RFP were: AT&T; Cellular   One/Genesee Telephone Company; LOCATE; MCI; MFS Intelenet; NYNEX; Rochester Telephone; Sprint   Communications Company; Teleport Communications Group; and Time Warner Communications. Subject to the   approval of the New York Public Service Commission, the trial is scheduled to begin on or about February1, 1996, and continue thereafter for approximately six months.X This RFP sought   proposals from manufacturers and providers of network database architectures that would permit   customers in the Rochester and Manhattan areas to retain their telephone numbers when",**"  Y-  changing service providers.  xPy- ЍSix bidders, Stratus Computer (partnered with U.S. Intelco), MCI Metro (partnered with DSC   Communications, Northern Telecom, Tandem Computers, and Siemens StrombergCarlson), Bell Atlantic, DSC   Communications Corporation, Northern Telecom, and Independent Telecommunications Network (ITN), responded to this RFP. On June16, 1995, the ten companies announced their selection  Y-  of Stratus Computer's bid for the Rochester area and MCI Metro's bid for the Manhattan area. xPJ- Ѝ Communications Daily at 7 (June20, 1995). Based on the recommendation of its technical staff, the   yPublic Service Commission of Maryland has commenced an inquiry into whether it should sponsor or encourage  zP-  a number portability trial in Maryland. See Letter to all parties in Case No.8587 from DanielP. Gahagan,  zP -  Executive Secretary, Public Service Commission of Maryland (dated April25, 1995); Maryland Report at 11.   xIndustry participants in California, with monitoring from the California Public Utilities Commission, are conducting meetings to examine the technical aspects of number portability.  Y-  ` ` 16.  SEATTLE1  In Seattle, Washington, a group of telecommunications service providers is  Y-  Kjointly testing a database method developed by Stratus Computer, U.S.Intelco, and others.,  xPk- 0ЍThe participants include: U.S. Intelco; Electric Lightwave Inc.; USWest; Stratus Computer; Teleport Communications Group; GTEINS; and ITN.   This method provides both location and service provider number portability. The objective of   this technical trial is to identify the technical, operational, and administrative issues that arise when a telephone number is disassociated from its traditional geographic location.  Y -  %` ` 17.  TRIALS2 In addition, the Industry Numbering Committee is addressing the   implementation and deployment of a database method that would make geographic telephone  Y -  -numbers portable. The proposals discussed in paragraphs PROPOSAL136 PROPOSAL239 infra have been presented formally to the INC workshop.  Y-L) III. DISCUSSION ׃  Yg-  ` ` 18. III In initiating this proceeding, we seek to obtain comment and information   concerning number portability. First, we consider issues relating to number portability for geographic numbers. We then consider service provider portability of 900 and 500 numbers.  X -` ` A. Portability for Geographic Telephone Numbers   Y-  l` ` 19.  IIIA  We tentatively conclude that the portability of geographic telephone numbers   Kbenefits consumers by providing them greater personal mobility and flexibility in the use of   telecommunications services and by contributing to the development of competition among   Lalternative providers of local telephone and other telecommunications services. We seek   ,comment on this tentative conclusion and on the public interest benefits of number portability.   Furthermore, we tentatively conclude that the Commission should assume a leadership role in   developing a national number portability policy due to its impact on interstate   telecommunications. We seek comment on this tentative conclusion and on the specific nature   of this role. We recognize, however, that we have insufficient information on the costs"' ,**-"   J(monetary and nonmonetary) of making geographic telephone numbers portable either between   service providers, services, or locations. Therefore, we seek comment on: (1)the feasibility,   limitations, and costs of longerterm number portability solutions; (2)the feasibility, limitations,   and costs of interim number portability measures; and (3)issues associated with a transition to   ,a permanent number portability environment. In developing a record on these issues, we hope to draw upon industry and state efforts in this area.  X_-` ` 1. Importance of Number Portability   Y1-  ` ` 20.  IIIA1  In this subsection, we consider the public interest benefits of number   portability for geographic numbers. First, we discuss the benefits that service provider number   portability would bring with respect to both wireline and wireless services. We also discuss the importance to consumers of service portability and location portability.  Y -  m` ` 21. Service Provider Number Portability. In light of our tentative conclusions   that the portability of geographic numbers benefits consumers and would contribute to the   development of competition among alternative providers of local telephone services, we identify   in the following paragraphs, and seek comment on, specific issues concerning the competitive impact of number portability.  Y6-  ` ` 22. The competitive importance of service provider number portability depends   primarily on the value that customers assign to their current telephone numbers. As we noted  Y -  in the 800 Access proceeding, service provider number portability promotes competition and   efficiency by allowing customers to respond to service and price changes without changing their  Y-  <telephone numbers.R\ zPV- _Ѝ800 Access, Report and Order, CC Docket No.8610, 4 FCC Rcd at 282526, 11, 13. See also  zP -  .Competition in the Interstate Interexchange Marketplace, CC Docket No.90-132, 6 FCC Rcd 5880, 5904, 138 (1991).R When end users attach a significant value to retaining their telephone   numbers while changing service providers, a lack of number portability likely would deter entry  Y-  Mby competitive providers of local services.| xPL- ЍIn supporting its proposed order to Judge Harold Greene regarding Ameritech's request to offer interLATA   iservice, the Department of Justice stated that "number portability was an important issue that needed to be addressed   <if local competition were to play the role envisioned by Ameritech's [Customers First] Plan." Memorandum of the   United States in Support of its Motion for a Modification of the Decree to permit a Limited Trial of Interexchange  zPl -  Service by Ameritech, United States v. Western Electric Co. et al., Civil Action No.820192 (HHG), at 11 (filed   May1, 1995). The New York Public Service Commission also has found that number portability will be essential  zP!-to the transition to a competitive local exchange market. See NYPSC Number Portability Order at3. For example, MCI has stated, based on a   .nationwide Gallup survey, that 4050% of residential customers and 7080% of business   v customers who otherwise were willing to consider changing their local telephone company would  Yj-  be unlikely to consider such a change if they also had to change their telephone numbers.j0  zPK&- ЍSee A Blue Print for Action: The Transition to Local Exchange Competition, MCI Telecommunications  zP'-  Corporation, Tab3, at 2 (March 1995). See also Local Number Portability National Study, Executive Summary,  zP'-  !prepared by The Gallup Organization for MCI Telecommunications Corporation, Figures 1 and3 (MCI  zP(-  Study)(finding that, while 70% of the business customers interviewed believed it somewhat or very likely that they   would change service providers for a 20% discount, only 24% of those business customers believed it somewhat"s),**)"   or very likely that they would change service providers for a 20% discount if that change also required them to  zPX-  change their telephone numbers); The Importance to Customers of Retaining Current Telephone Numbers When  zP"-  jSwitching Telecommunications Companies, Contribution of MFS Intelenet, Inc. to the INC Number Portability   Workshop, PORT64 (April6, 1995)(based on telephone interviews with 1,332 MFS Intelenet business customers,   finding that 33% and 48% of the interviewees believe it not very likely and not at all likely, respectively, that they would change their business telephone numbers for comparable or better services and prices). "j D,**N"   Business customers, in particular, may be reluctant to incur the administrative, marketing, and   goodwill costs of changing telephone numbers. These disincentives to changing service   providers may be mitigated, however, if a significant number of customers change their  Y-  Ztelephone numbers for other reasons.zD xP - ЍFor instance, Illinois Bell, in oral argument before the Illinois Commerce Commission concerning   Ameritech's Customers First Plan, stated that 25% of its customers change their telephone numbers annually for   various, noncompetitive reasons, such as the wish to avoid harassing telephone calls and the need to relocate outside   .the service area of one's current central office. Oral Testimony of Illinois Bell Telephone Company before the  zP -  Illinois Commerce Commission (March8, 1995). Cf. MCI Study, at4,6 (finding, based on a sampling of 2,050   business customers and 2,008 residential customers, that 3% of the business customers, and 13% of the residential customers, changed their telephone numbers during the past year). Both residential and business customers change their   numbers for a variety of reasons; for example, customers move to areas served by different  Y-  central offices.  xP-ЍWe note, however, that this turnover could be reduced through location portability. Moreover, changes in area codes, such as area code splits or overlays, create  Yv-a certain level of number churn.zv xP=- ЍArea code splits and overlays are two methods for dealing with area code exhaust. With a split, the   Lgeographic area assigned to an existing area code is split (usually in two) so that a portion of that area retains the   kprevious area code and the other portion is assigned a new area code. A recent example of an area code split   -occurred in Oregon, where the Oregon Public Utilities Commission adopted a plan to split the 503 area code in two.  zP]-  -See Communications Daily, at8 (May 4, 1995). With an overlay, a new area code is assigned to a geographic area   .that overlaps the geographic area(s) of one or more preexisting area codes. The first overlay was established in 1992 in New York City, where the 917 area code overlays the 212 and 718 area codes.  YH-  |` ` 23. We ask commenting parties to provide studies, data, and other information   on the relative importance of service provider number portability to the decisions of end users   when considering whether to take service from competing providers. We are particularly   interested in assessing the importance of this feature relative to other potential deterrents to   competitive entry into the provision of local services. Commenting parties also are invited to   provide studies, data, and other information on the extent to which situations, such as number   ;churn, and other factors enable competing providers of local telephone services to compete for   customers without service provider number portability. Further, we seek specific information   on whether different customer groups vary with respect to the value they assign to service provider number portability.  YL-  ` ` 24. We currently are examining issues concerning CMRS providers'  Y6-  Kinterconnection with the public switched network and with each other.Z6X zP?(-  ЍSee, e.g., Equal Access and Interconnection Obligations Pertaining to Commercial Mobile Radio Services,   Notice of Proposed Rulemaking and Notice of Inquiry, CC Docket No. 9454, 9 FCC Rcd 5408, 542627, 3639   <(1994)(tentatively concluding that requiring cellular providers to offer IXCs equal access: (1)increases consumers'"),**)"   .choice between longdistance service providers and promotes price competition; and (2)permits IXCs to develop  zPX-new and innovative services offerings); Second CMRS Interconnection NPRM. To the extent that"6 ",**"   ;wireless service providers offer services in competition with local telephone companies, a lack   of service provider portability may significantly hamper their ability to compete efficiently to   serve existing customers of the incumbent wireline service providers. Parties are asked to   provide comment, studies, data, and other information on: (1)the competitive significance of   service provider number portability for the development of competition between wireline and   wireless service providers; and (2)the current, and estimated future, demand of wireless   <customers for portable wireless telephone numbers when they change their service provider  Y_-either to another wireless service provider or to a wireline provider._" zP2 - @ЍIn the CMRS Interconnection proceeding, Pacific Bell (a cellular reseller and a future, Part24 PCS   kprovider) urged that wireless carriers should have the ability to transfer large blocks of consecutive telephone   .numbers with the associated customers from one service provider to another. Pacific Bell sought this ability for   two reasons. First, it argued that this would allow it to transfer its cellular customers to the facilitiesbased carrier   that offers the best underlying services and prices. In addition, Pacific Bell would be able to transfer existing   cellular customers to its Part24 PCS systems when those systems become operational. We sought comment on  zP-  these issues of "number transferability" in the CMRS Interconnection proceeding, and noted that we have not  zP-  !determined whether to address these issues in this or in the CMRS Interconnection proceeding. CMRS  zPx-Interconnection Second NPRM, at 94, n.192.  Y1-  0` ` 25. Service Portability. The need for service portability arises when a particular   xservice is available only through a particular switch. For example, if LECs deploy ISDN by   ;installing new ISDN switches within the existing service areas of switches that provide POTS,   customers that wish to receive ISDN services must change their telephone numbers. The same   Jfactors that inhibit customers from changing numbers in order to change service providers may   also deter customers from taking new services. We seek comment on the demand for service   -portability, and the extent to which a lack of service portability inhibits the growth of new   Jservices, such as ISDN. We seek comment, studies, data, and other information on the relative   <importance of service portability to the decisions of end users when considering whether to   switch from one service to another. We also seek comment on what federal policy objectives   hwould be served by encouraging (or possibly mandating) implementation of service portability, and steps the Commission could take to encourage service portability.  Y-  ` ` 26.  Location Portability. Today, telephone subscribers must change their   telephone numbers when they move outside the area served by their current central office.   Location portability would enable subscribers to keep their telephone numbers when they move   to a new neighborhood, a nearby community, across the state, or even, potentially, across the  Y-  country. As described in paragraphSEATTLE38 below, the technical trial in Seattle, Washington is   exploring the feasibility of providing location portability for wireline telephone numbers that now   Yare associated with a particular geographic location. We seek comment on the extent to which   ;there is demand for location portability and the geographic area in which portability is desired   iby consumers. What federal policy objectives would be served by encouraging (or possibly   ,mandating) implementation of location portability, and how could such objectives be attained? "  ,**"Ԍ Y-  3` ` 27. The advent of 500 number services may lead to the first widespread   wdeployment of a service permitting customers to be reached through a single telephone number,   zregardless of their location. Such services are available because 500 numbers are non  geographic telephone numbers and must be "mapped" into geographic telephone numbers for  Y-  purposes of routing calls.}  zP-ЍSee  50010 ,  500_212  supra.} We seek comment on the potential impact that implementation of   location portability for wireline telephone numbers may have on the development of the 500  Yw-  personal communications services market.!wZ xP - nЍThe geographic mobility offered through 500 number services differs from the location portability contemplated by the Seattle trial in that customers first must change their telephone numbers to 500 numbers. Conversely, we seek comment on the crosselastic   effects of the availability of personal mobility services offered through 500 and wireless services   ;on demand for location portability of wireline telephone numbers. Finally, we seek comment,   studies, data, or other information on the extent to which end users are requesting 800 numbers to obtain location portability.  X -` ` 2. The Commission's Role   Y -  o` ` 28. Currently, it appears unlikely that market forces alone will drive the   wdevelopment and deployment of a number portability solution. To date, the technical trials and   itask forces currently examining number portability have been initiated under the mandate or   guidance of state commissions. We seek comment on whether there should be a regulatory   mandate requiring the availability of number portability measures for geographic telephone   jnumbers. Assuming market forces will push the development and deployment of number   Yportability, we seek comment on whether they are sufficient to promote a nationwide, uniform development of number portability absent such a regulatory mandate.  Y-   ` ` 29.  IIIA2  We tentatively conclude that we have a significant interest in promoting the   nationwide availability of number portability due to its likely impact upon interstate   telecommunications. In the United States, the same set of telephone numbers is used to route   intrastate, interstate, and international telephone calls to individual telecommunications  Y-  customers."~ zP- ЍSee Proposed 708 Relief Plan and 630 Numbering Plan Area Code by Ameritech Illinois, Declaratory  zP-  Ruling and Order, IAD File No.94102, 10 FCC Rcd 4596, 460102, 12 (1995), pet. for clarification pending  zP -  -(Proposed 708 Relief Plan)(stating that preemption of state actions concerning the NANP may be necessary to avoid   thwarting federal regulatory goals because it is technologically impossible to have separate NPAs for interstate and   intrastate telephone calls). For example, a local caller, an interstate caller, and an international caller all dial the   isame NXX code and line number to reach the telecommunications customer located in Maryland at (301) 2341111; the only difference is that some of these callers must add an NPA code or a country code to the dialed number. This system of numbering promotes an efficient and fair telecommunications   ,system. We tentatively conclude that it is within our jurisdiction to ensure that the portability  Yh-  + of telephone numbers within the numbering system is handled efficiently and fairly.#$h  zP'- ЍSee 47 U.S.C. 151 (requiring the Commission to make available to all people of the United States "a  zP'-  rapid, efficient, nationwide, and worldwide wire and radio communications service"). See also 47 U.S.C.202   (requiring that the charges, practices, classifications, regulations, facilities, and services of common carriers not be unreasonably discriminatory). Moreover,"h #,**]"   both the subscriber line connecting an individual telephone service subscriber to the LEC's   Jcentral office and the radio transmission to and from a subscriber's wireless telephone are used   -by the subscriber to originate and terminate both toll and local telephone calls. As a result,   ymeasures such as number portability that promote competition between providers of local  Y-telephone services also promote competition between providers of interstate access services.$ zP- ЍSee Expanded Interconnection with Local Telephone Company Facilities, Memorandum Opinion and Order, 9 FCC Rcd 5154, 515859, 89 (1994).  Yv-  ` ` 30. We also tentatively conclude that there is a federal interest in this area   because deployment of different number portability solutions across the country would have a   significant impact on the provision of interstate telecommunications services. A uniform,   national method for providing number portability is likely to be less costly and more efficient   xfor interstate carriers. As we recently stated, we have a significant interest in a nationwide,   uniform system of numbering because such a system is essential to the efficient delivery of  Y -interstate and international telecommunications services.% " zP-ЍSee Proposed 708 Relief Plan, 10 FCC Rcd at 4602, 13. See also 47 U.S.C. 151.  Y -  0` ` 31. Finally, we tentatively conclude that we have a federal interest in fostering   the development of number portability due to our interest in efficient use of the numbering  Y-  Lresource.& zP-ЍProposed 708 Relief Plan, 10 FCC Rcd at 4602, 13. See also 47 U.S.C. 151. As discussed in more detail below,D'F zP-ЍId.D the longerterm and interim methods for   xproviding number portability have an impact on the availability and exhaustion of telephone   numbers. In some cases, longerterm solutions may even have the beneficial effect of slowing   ;the exhaustion of area codes and NXX codes, thereby avoiding the disruptions that accompany   measures to alleviate the exhaustion of telephone numbers and fostering a more uniform numbering plan.  Y-  ` ` 32. We recognize that state regulators also have legitimate interests in the   development of number portability, and that they are conducting tests and deploying number    portability measures. We encourage these tests because they will provide empirical evidence and   other relevant information. We note, however, that state requirements governing number  Y-  portability should not thwart or impede national policies,( zP"- ЍSee Louisiana Public Service Comm'n v. FCC, 476 U.S. 355 (1986); Public Service Comm'n of Maryland  zP"-v. FCC, 909 F.2d 1510 (D.C. Cir. 1990). such as nondiscrimination and   ;competitive neutrality. We seek comment on areas where state and federal policies on number   portability are likely to diverge or become inconsistent, and on the additional costs associated   with having different number portability approaches on a statebystate basis or on a regional   basis. Parties should address the need to develop a uniform solution to the provision of number   portability, and whether the deployment of different number portability methods across the country is in the public interest. " 4 (,** "Ԍ Y-  ` `  33. In the event we conclude that number portability should be implemented on   ;a nationwide basis, what specific actions can and should the Commission take to expedite such   implementation? For instance, should the Commission direct implementation of number   portability by a date certain and direct an industry group to develop a detailed implementation   plan? Alternatively, should the Commission adopt rules specifying how number portability shall   Jbe implemented? If we mandate implementation of specific number portability measures, upon   + whom should this obligation fall, and what is a realistic time frame in which that mandate should become effective?  Y2-  }` ` !34. Finally, we seek comment on the appropriate role of the Commission in   establishing technical and performance standards for number portability. Typically, we look to  Y -  industry bodies to develop standards in the first instance.)  zP~ - ЍSee Intelligent Networks, Notice of Proposed Rulemaking, CC Docket No.91346, 8 FCC Rcd 6813, 6820, 5556, n.64 (1993). Should we leave the establishment   of number portability standards to industry organizations and standardssetting bodies, and   simply monitor the activities of these groups? Or, should we direct industry bodies to resolve   certain issues (technical or otherwise)? If so, which issues should be designated for resolution   by these groups, and to which organizations should they be directed? Is it reasonable for the   KCommission to establish deadlines for the resolution by industry of issues involving number   ;portability? If so, parties should provide recommended time frames. Alternatively, should we   wtake a more active role in the development of such number portability standards? For example,   should we develop, and mandate compliance with, particular number portability standards, or should we establish nonbinding standards or guidelines?  X-` ` 3. LongerTerm Number Portability Solutions   Y-  !` ` "35.  IIIA3  In this subsection, we seek comment on what longerterm number portability   /solution is in the public interest. For purposes of this subsection, we intend "number   portability" to encompass service provider, service, and location portability because a method   Jfor providing location portability likely will also enable customers to change service providers   Zand services without changing their telephone numbers. First, we seek comment on various   number portability proposals that have been offered by different industry participants. We   consider more generally various issues associated with deploying a database method for   providing number portability, including call processing scenarios, the geographic area within   ;which numbers should be portable, the database architecture, administration of the database(s),   and the estimated cost and appropriate methods of cost recovery. We ask commenting parties   xto draw upon relevant information obtained through the various ongoing number portability trials.  Y!-  ` ` #36. Current Proposals. PROPOSAL1In response to the New York RFP, MCIMetro   K(partnered with DSC Communications, Northern Telecom, Tandem Computers, and Siemens   StrombergCarlson) has proposed a database method that would enable end users within a   particular geographic region (most likely a state) to retain their NXX code and line number if"l$"),**%"  Y-  they change their local service provider.5*( zPy- ЍMCI Local Number Portability (LNP) Trial Proposal, filed in response to New York State Number  zPC-  >Portability Trial Request for Proposal (RFP No.9501)(May5, 1995). See also Industry Group Proposes First  zP -  'True' Number Portability Plan, Communications Daily, at2 (May10, 1995); MCI, Manufacturers Unveil Number  zP-Portability 'Solution,' Telecommunications Reports, at1112 (May15, 1995).5 Under MCI Metro's proposal, a carrier routing a call   into an area where number portability has been deployed would know from the NXX code of   the dialed number that the telephone number may have been transferred to another local service   provider. The carrier would query a database serving that area, which would return to the   hcarrier a threedigit "carrier portability code" corresponding to the service provider serving the  Y-  wdialed number.+ xP - ЍCarrier portability codes would identify competing providers of local telephone services within each NPA. The same codes could be used to represent the same company or a different company in other NPAs. The carrier then would route the call according to the carrier portability code   wand the dialed NXX code. For example, an IXC delivering a call to the 301NPA would query   the database serving the 301 area code. In return, that database would transmit back to the IXC   the carrier portability code identifying the local service provider responsible for handling the  Y1-  Zcall, and the IXC would route the call to that carrier., 1 xP- {ЍRouting telephone calls based on carrier portability codes likely will require, among other things, that the   ysoftware be modified in each network switch located in the NPA within which this system is deployed. It would   similarly require modification to the LERG on the same NPAbasis so that the LERG contains routing data based on carrier portability codes. Similarly, carriers providing service   within the area would query the same database to identify the local service provider responsible   for handling specific local calls. MCI Metro's proposal essentially uses two NPA codes, and  Y -  itherefore precludes use of the second NPA code for other purposes.-  xP- ЍThis is so because MCI Metro's method would replace the dialed NPA code with a threedigit carrier portability code, which effectively removes that code from the pool of available NPA codes. Furthermore, it is not   ,clear how operator services, such as busy line verification, collect calls, calling card calls, and   wthirdparty billing, would be handled under this proposal. Finally, MCI's proposal would only permit location portability within the area served by the number portability database.  Yy-  ` ` $37. AT&T has proposed to the INC workshop a similar database method for  Yc-  providing service provider portability on a regional basis..\cP  zPd- ЍSee Ameritech's Local Number Portability Request for Proposal Number 6803-01-95, Section2, p.4. See  zP. -  also Communications Daily, at7 (May12, 1995); MCI, Manufacturers Unveil Number Portability 'Solution,'  xP -Telecommunications Reports, at1112 (May15, 1995).ė AT&T's method differs from MCI's   primarily in that the database would not substitute a new code for the NPA, but rather would   simply determine how to route a call based on the dialed NPANXXXXXX. Moreover, MCI's   ,method supports both advanced intelligent network (AIN) and intelligent network capabilities, while AT&T's method only supports AIN capabilities.  Y-  _` ` %38.  SEATTLE  The Seattle trial is testing a method developed by Stratus Computer and   U.SIntelco namely, a mapping scheme that uncouples the end user's telephone number from   its geographic location. To minimize the impact of this mapping scheme on the network, this   ,scheme uses two sets of 10digit numbers to associate customers' telephone numbers with their"t.,**"   ;geographic location. The first set of numbers, referred to as customer name addresses (CNAs),   represents the number a party would dial to contact a specific customer. The second set of   hnumbers, referred to as network node addresses (NNAs), are internal mapping numbers that the   network uses to identify the geographic location of customers. Thus, the dialed telephone   number of a particular customer no longer would associate that customer with a particular geographic location.  Y_-  ` ` &39. PROPOSAL2Finally, in the context of the INC number portability workshop, GTE has   proposed to implement number portability by requiring customers to change, on a onetime   basis, their telephone number to, for example, a 700 number. The 700 services essentially would operate the same way that 500 services operate.  Y -  ^` ` '40. We seek comment on the advantages and disadvantages of the MCI Metro,   AT&T, Seattle, and GTE proposals. We ask whether any of these proposals provide a workable   model for national implementation of number portability for geographic numbers and whether there are other workable proposals.  Y{-  ` ` (41. We tentatively conclude that a number portability environment should support   operator services and enhanced 911 services. Such services are in the public interest because   hthey are critical to the public safety and are important features of the public switched network. We seek comment on the extent to which the various proposals support these services.  Y -  ` ` )42. We  EXHAUST also tentatively conclude that any number portability proposal should   hefficiently use telephone numbers. One of the underlying causes of area code exhaustion is the   exhaustion of central office codes. The exhaustion of an area code occurs once all the central   Joffice codes within that area code have been assigned to individual carriers, whether or not all  Y-  ythe line numbers within each central office code have been assigned. Number portability   ,measures that permit the transfer of line numbers between central office codes may make more   efficient use of line numbers, and thereby slow the exhaustion of area codes. We seek comment on the impact that each of these proposals would have on the numbering resource.  Y;-  ` ` *43. Call Processing Scenarios. In any database solution, it is necessary to   determine which carrier involved in processing a call should be responsible for querying the   database and at what point in the routing of a telephone call should that database dip be   performed. At least three different call processing scenarios exist for routing telephone calls in   a number portability environment: (1)the terminating "access" provider (TAP) scenario; (2)the originating service provider (OSP) scenario; and (3)the N1 ("N minus 1") scenario.  Y"-  m` ` +44. The TAP scenario would place the burden of doing the database query on   the terminating access provider. With a local telephone call, the call would be routed to the   service provider assigned to the NXX code of the dialed telephone number, just as it is   + currently. When that service provider receives the call, it would query the database to determine   how the call should be routed. If the number has been transferred to another carrier, the service   provider would route the call to the other carrier; otherwise, it would complete the call. An   ZinterLATA call also would be initially routed by the IXC to the assignee of the dialed NXX   code, and that carrier would determine if the call needed to be routed to another carrier or to   Yits customer. Because the incumbent LECs are the assignees of the majority of NXX codes, the").,** +"   burden of performing the database queries under the TAP scenario would fall almost entirely on   these LECs. Finally, because all terminating interstate calls would pass over the incumbent   YLEC's network, the LEC -- not the competing local service provider -- would recover interstate  Y-access charges from IXCs for terminating traffic under our existing access charge regime./ zP4- \ЍSee generally Rochester Telephone Corporation Petition for Waivers to Implement Its Open Market Plan, Order, FCC 9596 (released March7, 1995).  Y-  ` ` ,45. The OSP scenario would require the originating service provider to perform   the database query and pass the information necessary to complete the routing of the call to   jsubsequent carriers. Every originating service provider would have to have access to the   information necessary to route all calls to areas where number portability has been deployed.  Y2-  This scenario, therefore, requires a flashcut implementation of a number portability database  Y -(or databases) across the country.W0X " xP - NЍFor example, once number portability was deployed in New York City, an originating service provider in   Billings, Montana would be responsible under the OSP scenario for determining the service provider in New York City to which a call should be routed.W  Y -  ` ` -46. Under the N-1 scenario, the carrier immediately prior to the terminating   Lservice provider performs the database query. When a call is placed to a local telephone   number, the originating service provider becomes the N-1 carrier. The originating service   provider would recognize the NPANXX codes of the dialed number as a local number, perform   the database query to determine the service provider that should receive the call, and route the   call accordingly. If the call is an interLATA call, the originating service provider routes the call   Yto the IXC selected by the calling party. The IXC is the N-1 carrier, and performs the database   query to determine which service provider should receive the call. This scenario avoids the need   to flashcut to a nationwide database scheme and having to route every call through the original   assignee of the telephone number. The N1 solution, however, may lead to inefficient routing   ,of calls. For example, if a customer moved from one NPA code to another and retained his or   her telephone number, calls originating in the second NPA would still be passed to the   appropriate IXC even though the number possibly is now located within the originating service provider's local service area.  Y-  ` ` .47. We seek comment on which of these three scenarios, or any alternative,   hwould best serve the public interest. We request that commenters discuss the different burdens   that each scenario would place on the relevant carriers involved, any methods that would reduce   the number of database queries, the burden such scenarios would place on current SS7 networks   and nextgeneration system signaling networks, and the network modifications such scenarios   xwould require. We also request that commenters address the impact that any call processing   xscenario would have on transmission quality, call setup time, and any other relevant service   quality considerations. We seek comment on how various call processing scenarios would   <operate under the proposals offered by MCI Metro, AT&T, GTE, or any alternative, and on   =whether certain proposals are limited to specific call processing scenarios. We also seek   comment on which carrier, or carriers, perform the database query in the Seattle trial, and what has been learned from that experience. "#B0,**$"Ԍ Y-  ` ` /48. Geographic Scope. One of the central issues in either a service provider or   location portability environment is the geographic region within which numbers should be   Kportable. We seek comment on whether telephone numbers should be portable within local   hcalling areas, throughout a particular area code, statewide, regionally, nationwide, or on some   hother basis. What are the advantages and disadvantages of each of these alternatives, and what   are the implications of each for carriers and their customers? For example, what changes would   the different alternatives require for carrier billing systems? To what extent do varying   approaches differently impact different types of carriers, such as LECs, new wireline carriers, and wireless carriers?  Y -  ` ` 049. What is the geographic scope of the number portability trial in Seattle, and   -what geographic scope is contemplated in the proposals offered by MCI Metro, AT&T, and   GTE? We seek comment on whether these proposals could be used to provide number portability on a nationwide basis without significant network modifications.  Y -  |` ` 150. Architecture. We seek comment on what database architecture would best   serve the public interest. To what extent is the database used to provide 800 number portability   a useful model? Is it technically feasible to deploy a single database to implement number   Yportability on a nationwide basis, or should a database solution be designed to use a number of   distributed (that is, regional) databases? If the latter, in what geographic areas should such   =databases operate, and what are the advantages, disadvantages, and relative costs of each approach?  Y-  m` ` 251. We also seek comment on the method for administering and modifying the   data contained in the database(s). Is it better to update and modify such data from a single,   <central location, or should that process be initiated by different sources? If a decentralized   system for updating the data is preferred, what processes will be required to ensure that the data   in different databases is updated consistently and without discrepancies? We also seek comment   on the types of information the database(s) will need to contain and who should be permitted access to such data.  Y;-  ` ` 352. Administration of the Database. Various administrative issues will need to   be resolved before a database solution can be implemented. First, we seek comment on who   wshould own the database(s) used to provide a longerterm number portability solution. Further,   we seek comment on how such a database (or databases) should be maintained and funded. We   seek comment on the criteria that should be used to evaluate potential administrators of a number   portability database system and who should select the administrator. Finally, we seek comment   on the scope of responsibilities that should be placed on the administrator or administrators of such a database or databases.  Ym$-  ` ` 453. Costs and Cost Recovery Issues. In order to weigh the public interest   benefits of deploying a longerterm number portability solution against the current interim   measures, we must consider the costs associated with designing, building, and deploying such   a longerterm solution. The use of a database to provide number portability will require a   significant investment in network infrastructure. Several LECs have already begun to deploy"(0,**@)"  Y-  databases and intelligent network capabilities to provide new services to their customers.;1$ zPy-  ЍSee generally Rolling Out New AIN Services, Telephony, Daniel D. Briere, 24 (July11, 1994); AIN Finally  zPC-  jHits the Ground Running, Telephony, Daniel D. Briere, 28 (May30, 1994). See also Bell Atlantic's Response   to the New York State Number Portability Trial Request for Proposal No.9501, p.2 (proposing to use Bell Atlantic's integrated service control point in Newark, New Jersey as the database for the New York trial).; In   many cases, the provision of number portability through a database system may be able to utilize    the intelligent network capabilities already being deployed by LECs. We request comment, data,   ,studies and other information on the estimated costs to design, build, and deploy a longerterm   database solution. We also seek comment on how these costs should be allocated between   federal and state jurisdictions. Commenting parties should, to the extent possible, estimate both   the total cost of infrastructure necessary to deploy number portability and the longterm   incremental cost of deploying number portability, exclusive of other costs such as network   equipment and hardware and software upgrades that would be incurred without implementation of number portability.  Y -  2` ` 554. We also seek comment on how and from whom the costs of designing,   ,building, deploying, and operating a database system should be recovered. If we mandate that   LECs implement number portability, should they be allowed to treat these as exogenous costs,   iand thereby increase their rates? Parties should comment on whether the costs of a database   system should be shared between all carriers using the system. Alternatively, should competing   providers of local telephone services and their customers bear the costs of such a database system?  XL-` ` 4. Interim Number Portability Measures   Y-  ?` ` 655.  IIIA4  To evaluate whether a transition to a longerterm number portability solution  Y-  is in the public interest, we must understand what measures are currently available for providing   number portability. In this subsection, we discuss the available interim measures, their limitations, and their costs.  Y-  ` ` 756. Currently, LECs offer their business and residential customers services that  Y-  redirect calls in the telephone network. These services include remote call forwarding (RCF),   flexible direct inward dialing (DID), and a few derivations of these two services. These services   can be adapted to provide customers with service provider number portability. For example,   NYNEX currently is offering RCF and flexible DID to MFS and Cablevision Lightpath, two   competitive exchange providers certified by the New York Public Service Commission, as an  Y#-interim type of number portability.2# zP#- ЍSee Cablevision Lightpath, Inc., Case No.92C0680, July8, 1993 (1993 WL 564541 (N.Y.P.S.C.)); MFS  zPR$-  jIntelenet of New York, Inc., Case No.92C0803, March17, 1993 (1993 WL 278869 (N.Y.P.S.C.)). NYNEX   offers these services pursuant to individual agreements with the competing service providers. NYNEX offers RCF   yto MFS and Cablevision Lightpath at $4.00 per line per month for ported business numbers, and at $2.00 per line per month for ported residential telephone numbers. " h 2,**"Ԍ Y-  B 6g  6g ` ` 857. Remote Call Forwarding. If a customer transfers his or her existing   telephone number from CarrierA to CarrierB, any call to that customer currently must be   routed to the central office switch operated by CarrierA that is designated by the NXX code of  Y-   6g  6g the customers telephone number.g3 zP5-ЍSee  INROU8  supra.g Through RCF, CarrierAs switch would route that call to   ;CarrierB translating the dialed number into a number with an NXX corresponding to a switch   operated by CarrierB. CarrierB then would complete the routing of the call to its customer. The change in terminating carriers would be transparent to the calling party.  YI-  ^` ` 958. Use of RCF to provide service provider portability has several limitations,  Y3-  ;however. First, RCF INTERIMEXHplaces a significant strain on number plan administration and contributes   ;to area code exhaust. Because RCF involves a translation from the dialed telephone number to   a telephone number corresponding to the new service providers switch, this method requires   the use of two, tendigit telephone numbers. Exhaustion of telephone numbers has become a   significant problem in numerous metropolitan areas, and the use of RCF as a longterm solution  Y -  for number portability likely will exacerbate those problems.4& Z zP- ЍSee, e.g., Communications Daily, p.8 (March23, 1995); Illinois Commerce Commission Adopts Plan to  zP-  Split Area Codes in Chicago Suburbs, Communications Daily, pp.78 (March22, 1995); North American  zP_-  Numbering Plan Manager Sees Companies 'In Denial' on Changes, Communications Daily, p.6 (March24, 1995); Communications Daily, p.8 (May4, 1995). Second, RCF will not support   several custom local area signalling services (CLASS), such as caller ID, and may degrade   transmission quality, because RCF actually places a second call to a transparent telephone   number. Third, RCF is capable of handling only a limited number of calls to customers of the same competing service provider at any one time.  Y6-  ` ` :59. RCF also appears to preclude the development of efficient competing  Y -  networks. Under RCF, calls to customers that have retained their telephone numbers and moved  Y -  -to competing providers' networks must be routed initially to the customers' original service   providers. Thus, the incumbent LEC is always involved in the routing of calls to that customer,  Y-  even when the customer chose to switch providers.g5H zP-ЍSee  INROU8  supra.g Moreover, the incumbent LEC has little   incentive to provide efficient routing services to their competitors. Finally, because all   terminating interstate calls would pass over the incumbent LEC's network, the LEC -- not the   competing local service provider -- would recover interstate access charges from IXCs under our  Y-existing access charge regime.6 zP #- \ЍSee generally Rochester Telephone Corporation Petition for Waivers to Implement Its Open Market Plan, Order, FCC 9596 (released March7, 1995).  YQ-  ` ` ;60. Flexible Direct Inward Dialing. Flexible DID is similar to RCF in that the   Yoriginal service provider and the new service provider perform the same functions. Like RCF,   all calls to customers that have retained their telephone numbers while changing service   yproviders must be routed to the carrier's switch designated by the NXX of the customers" 4 6,**,"  Y-  htelephone number.g7 zPy-ЍSee  INROU8  supra.g Unlike RCF, however, the original service provider does not translate the   dialed number to a new number, but routes calls to that particular phone number over a   <dedicated facility to the new service providers switch. Flexible DID has many of the same   Jlimitations as RCF, such as the inability to support certain CLASS features (for example, caller   hID) and the possible degradation of transmission quality. While flexible DID is able to process   more simultaneous calls to a competing service provider than RCF, there remain significant limitations on how many such calls flexible DID can process at any one time.  YH-  @` ` <61. Other Interim Measures for Providing Number Portability. We are aware  Y2-  of at least three other interim number portability measures. All three measures are derivatives   .of RCF and flexible DID, require routing of all incoming calls to the terminating switch   identified by the NXX code of the dialed phone number, and involve the loss of CLASS   functionalities. They differ from the interim approaches discussed above in that they use LEC   htandem switches to aggregate calls to a particular competing service provider before those calls  Y -  are routed to that provider.$8 Z xP- NЍUnder enhanced remote call forwarding (ERCF), a call is routed to the LEC switch corresponding to the   NXX code of the dialed telephone number. The dialed number is then assigned an ERCF "translation" which   consists of the same number preceded by a 10XXX prefix. The XXX is the carrier ID code assigned to the   competitive exchange provider. This 12 to 15digit number (telephone number with 10XXX prefix) is sent to a   \tandem switch that recognizes the 5digit prefix, strips it out, and routes the call to the competitive exchange providers switch.  Route index/portability hub also requires the call to be routed to the LEC switch corresponding to the NXX   Lcode of the dialed number. The LEC switch inserts a 1XX prefix onto the front of the telephone number. This   j1XX code identifies the competitive service provider to which the call will be routed. This 10 to 13digit number   (telephone number with the 1XX prefix) is transmitted to the LEC tandem switch to which the competitive exchange   provider is connected. The tandem switch strips the 1XX prefix from the dialed number, and routes the call to the competitive exchange providers switch, from where the routing of the call is terminated.  zFinally, hub routing with AIN is similar to route index/portability hub, except that, rather than the receiving   LEC switch interpreting the routing information, the LEC switch interrogates a remote database that contains routing   information. Having obtained this routing information from the database, the LEC switch routes the call via a   Ztandem switch to the terminating competitive exchange providers switch. This method may require that the LEC's tandem switch be equipped with the ability to interrogate a database.$ Use of such tandem switches is often more efficient, because it   alleviates the need for direct connections between every LEC end office in a local exchange and the switch of each competitive exchange provider.  Yc-  {` ` =62. We seek comment on the costs, and offsetting benefits, of implementing these  YM-  interim measures. We recognize that RCF and flexible DID have significant limitations. Parties   hare asked to comment and elaborate on the limitations and disadvantages of RCF, flexible DID,   and their derivatives. Further, we ask commenting parties to discuss the availability of these   kinterim measures and their effectiveness as an interim substitute for a database number   Kportability solution. Finally, parties should consider whether these interim measures can be improved so that they are workable, longterm solutions, and if so, at what cost. "8,**"Ԍ Y-  ` ` >63. Cost Recovery for Interim Measures. Because RCF and flexible DID are   based on preexisting LEC services, the new local service providers, or their customers,   generally bear the costs of RCF and flexible DID. For example, under NYNEX's agreements   with MFS and Cablevision Lightpath, NYNEX charges the competing telephone companies a   monthly, per line fee. This arguably places responsibility for paying the costs of RCF and   flexible DID on the parties who directly benefit from the number portability that RCF and   flexible DID offer. We seek comment on this approach for recovering the costs of interim   ;number portability measures. We also seek comment on the amounts charged for these interim   measures, whether such rates have a significant competitive impact, and whether reductions in   such rates would make these measures more workable as longterm solutions. Finally, we ask parties to propose alternative ways to recover the costs of interim measures.  X -` ` 5. The Transition from Interim Portability Measures   Y -  P` ` ?64.  IIIA5  In this subsection, we consider issues relating to the transition from the   existing interim measures to longerterm number portability solutions. It is not clear at this   ypoint whether the industry will move to a longerterm solution that provides only service   provider number portability, or will evolve to a location portability environment. Commenting   parties should identify any transitional issues that are unique to either environment and the particular impacts that shortterm choices may have on longerterm possibilities.  Y-  ~` ` @65.  Transition to Service Provider Portability.  SERVPORT We seek comment on the   hestimated time frame to design, build, and deploy a system that would provide service provider   portability. Commenting parties should addressSERVPORT2 the modifications that would be necessary to   + implement a transition to service provider portability, including, but not limited to, modifications   to the carriers' networks, operating procedures (for example, billing and collection procedures),   and dialing plans. We seek comment on whether the ability to transfer wireless telephone   Ynumbers between different service providers (wireline and wireless) places the same burden on the LECs and other carriers as transferring wireline telephone numbers.  YQ-  ` ` A66. Transition to Location Portability. We also seek comment on the estimated   time frame to design, build, and deploy a system capable of providing location portability.   Commenting parties should addressSERVPORT2 the modifications that would be necessary to implement a   Ktransition to location portability, including, but not limited to, modifications to the carriers'   networks, operating procedures (for example, billing and collection procedures), and dialing plans.  Y!-  ]` ` B67. Transitioning to a location portability solution may raise additional issues not   relevant in an environment in which there is service provider portability. Today, dialing parties   Ygenerally can distinguish between a local and a toll call from the telephone number dialed, and   zhave a general sense of the charge that they likely will incur. In a location portability   environment, the association between telephone numbers and geographic locations will dissolve,   and dialing parties may not be able to determine from the telephone number they dial the charge   incurred by placing a telephone call. We seek comment on the impact that a transition to   wlocation portability would have on consumers, the network, service providers, and others. Are   there ways to provide dialing parties notification of the charge they will incur when they dial a   particular number? What effect will location portability have on operator services, directory")8,** +"   assistance, enhanced services, the way carriers determine rates for toll and interLATA calls, and   Jbilling systems? What impact would location portability have on the current administration of the numbering resource?  Y-  ` ` C68. Public Interest of a Transition to LongerTerm Solution. To determine what   would best serve the public interest, we seek comment comparing the relative costs and benefits   associated with the current interim solutions to the costs and benefits associated with alternative   ,longerterm solutions. In answering this question, parties are encouraged to focus on the costs   and benefits of the specific proposals currently being tested in Seattle and developed by MCI   YMetro, AT&T, and GTE. Is it in the public interest to require only that carriers make available   interim measures that accommodate number portability and not require the implementation of   a longerterm number portability solution? We also seek comment on the additional costs that   ;would be incurred, and the benefits that would be attained, by evolving to location portability from an intermediate step of service provider portability.  X - ` ` B. Portability for Nongeographic Telephone Numbers   Yz-  "` ` D69.  IIIB  We tentatively conclude that service provider portability for 900 and 500  Yd-  h(PCS N00) numbers is beneficial for customers of those services.9zd xP- ЍThe term "PCS" is used here generically as "a set of capabilities that allows some combination of personal   mobility, terminal mobility, and service profile management." PCS N00 number portability includes 500 number   portability. The INC uses this more general title of PCS N00 number portability to include other NPA codes,   because it recognizes that PCS services may use NPA codes other than, or in addition to, the 500 NPA code. The   xterm PCS"PCS" or "personal communications services" as used here with respect to 500 numbers and the INC workshop   -should not be interpreted as the term "personal communications services" is defined in Part24 of the Commission's  zP-rules. See 47 C.F.R. 24.5 (1994). Service provider  portability   wfor these services will allow customers to respond more readily to service and price differences   wamong service providers, thereby promoting competition and efficiency in the provision of 900   and PCS N00 services. We seek comment on this tentative conclusion and on the costs   (monetary and nonmonetary) of making such portability available. We seek to gather more   Yinformation to determine whether the public interest would be served by mandating portability   for 900 and PCS N00 services, and we consider other issues related to the implementation of such number portability.  Y-  $` ` E70. We note that the INC has addressed PCS N00 and the portability of   geographic numbers separately in two different workshops. We seek comment on whether   Ydeveloping and deploying a method for providing number portability for geographic telephone   numbers could, or should, include service provider number portability for nongeographic   htelephone numbers, such as 500 and 900 numbers. Is it technically possible, and cost effective,   to use the same database method, and possibly the same database, to provide service provider   wportability for geographic and servicespecific (nongeographic) telephone numbers? Similarly,   is it technically possible, and cost effective, to use the same database to provide service provider   portability for all types of nongeographic numbers, such as 800, 500, and 900 numbers, or is it preferable to use separate databases for each type of nongeographic number? "! 9,**""Ԍ X- 6g  6g ` ` 1. 900 Service Provider Portability   Y-  1` ` F71.  IIIB1  On October 18, 1994, the Teleservices Industry Association (Teleservices)   filed a petition for rulemaking seeking initiation of a rulemaking to make 900 numbers portable  Y-  J 6g  6g among service providers.*: zP- ЍSee Petition for Rulemaking by Teleservices Industry Association, RM No.8535 (filed October18,  zP-1994)(Petition). See also FCC Public Notice, ReportNo.2037, Mimeo No.50358 (October 25, 1994).* Currently, 900 number access is provided through NXX screening,  Y-  <as 800 access was provided originally.{;$ zPc -ЍSee  NXX111 ש NXX12  supra.{ Teleservices proposes that the Commission require   implementation of a tendigit database system that would enable information providers to switch   their 900 service providers without changing their 900 numbers. Ten parties filed comments in  YI-response to the Petition, and five parties filed reply comments.<I xP - {ЍA list of the parties filing comments and replies in response to Teleservices' Petition is attached hereto as AppendixC.  Y -  l` ` G72. Teleservices argues that the benefits of 900 portability far outweigh the costs.   It argues that the lack of number portability for 900 numbers has stifled competition among IXCs  Y -  in the paypercall marketplace.f=  xP-ЍPetition at 56; Teleservices Reply at 13.f Teleservices asserts that competition among IXCs in the   ymarket for 900 number transport is almost nonexistent, and that consumers would benefit   Jthrough lower prices and more services if 900 numbers were portable. Teleservices maintains   that implementation of a tendigit screening system would be relatively inexpensive because most  Y-  iof the necessary software and hardware is already in place and used to route 800 numbers.h> xP-ЍPetition at 1518; Teleservices Reply at 45.h   It also argues that the regulatory costs to implement a 900 database access system would be   minimal because the Commission, in adopting regulatory policies for 800 number portability,   has already resolved virtually all of the regulatory issues necessary to implement 900 number  Y6-portability.M?6.  xP-ЍPetition at 1819.M  Y-  "` ` H73. MCI and information service providers support initiation of a rulemaking  Y-  xto address 900 number portability.@  zPa"- ЍSee generally Comments of MCI, Interactive Services Association, Network Telephone Services, and The Weather Channel; MCI Reply. Sprint similarly supports initiation of a rulemaking and   urges the Commission to address all number portability issues in one rulemaking proceeding.   Sprint argues that number portability is a prerequisite to competition because it removes barriers  Y-  that make customers captive to carriers and limit consumer choice.A zPv'- !ЍSprint at 2. See also USTA Reply at 3 (arguing that issues pertaining to 500 and 900 numbers should be addressed simultaneously). In contrast, the LECs"rA,**"  Y-  generally question whether the benefits of 900 number portability outweigh the costs.KB xPy-ЍUSTA Reply at 2.K They  Y-  note that demand for 900 numbers has declined,zCX xP-ЍAmeritech at 1; BellSouth at 2; SW Bell at 2; NYNEX Reply at 2.z and they dispute Teleservices' assertion that  Y-  the costs of implementing 900 number portability would be minimal.D xPk-ЍAmeritech at 1; BellSouth at 3; Pacific Bell at 2-4; SWBell at 2; USWEST at 24; NYNEX Reply at2. They argue that the   hsystem used to route 800 calls was specifically designed to handle only 800 calls and cannot be  Y-  modified easily and inexpensively to route 900 calls.~Ex xP -ЍBellSouth at 3; Pacific Bell at 13; SWBell at 2; USWEST at 24.~ Further, several LECs suggest that the  Y-Commission should refer this issue to industry fora for resolution.\F xPF -ЍBellSouth at 2; NYNEX Reply at 3.\  Y_-  ` ` I74. We seek comment on various issues relating to portability of 900 numbers.   -We ask parties to address the extent to which 900 number portability will lower prices and   thereby stimulate demand for 900 number services. Parties are asked to provide comment,   studies, data, and other information on the estimated costs of designing, building, and deploying   a 900 database, and the estimated costs of operating such a database. Is it technically feasible   to upgrade the existing 800 database and associated software to accommodate 900 numbers, and   if so, at what cost? Is AIN a less costly way to implement 900 number portability? We also   Lseek comment on whether the Commission should direct an industry group to develop an   ,implementation plan for a 900 number portability database, and if so, to which industry group   should this task be referred. If the Commission decides to mandate implementation of service provider portability for 900 numbers, what is a realistic schedule for implementation?  XL-` ` 2. 500 Service Provider Portability   Y-  ` ` J75.  IIIB2  In June 1993, Bellcore, as administrator of the North American Numbering   ZPlan, informed the Common Carrier Bureau that, absent a directive to the contrary, Bellcore  Y-  hwould begin assigning the 500 NPA and the NXX codes within the 500 service.G xP:- ЍLetter from Ronald R. Conners, Director NANP Administration, Bellcore, to Kathleen B. Levitz, Acting Chief, Common Carrier Bureau, FCC, dated June23, 1993. In response,   Zthe Bureau requested a delay of such assignments and sought comment on the use of the 500  Y-  ;NPA.H  xPd#- ЍLetter from Kathleen B. Levitz, Acting Chief, Common Carrier Bureau, FCC, to Ronald R. Conners, Director NANP Administration, Bellcore, dated August5, 1993. In May 1994, the Bureau directed that assignment of 500 NXX codes begin, urged the   development of a plan to achieve 500 number portability, and stressed that such portability be  Y-achieved as expeditiously as possible.IH  xP'- kЍLetter from A. Richard Metzger, Jr., Acting Chief, Common Carrier Bureau, FCC, to Ronald R. Conners, Director NANP Administration, Bellcore, dated May3, 1994. "~I,**"Ԍ Y-  ` ` K76. Pursuant to the Bureau's directive, the INC established a workshop entitled   i"PCS N00 Number Portability" to develop an implementation and migration plan to provide   service provider portability for 500 and other PCS N00 services. On May17, 1995, the INC   [submitted a report to the Bureau that sets forth alternative database architectures for such  Y-  portability and an estimated implementation schedule.mJ\ xP- "ЍLetter from Denny Byrne and Robert Hirsch, CoChairs, INC, to Kathleen M.H. Wallman, Chief,  zP-  Common Carrier Bureau, FCC, dated May17, 1995 (attaching INC Report on PCS N00 Portability, INC 950512 zP-010(PCS N00 Portability Report)).m The INC concluded, however, that   implementation cannot proceed until there is regulatory guidance on: (1)who will be the   howner/operator of the service management systems administering the data contained in the PCS   wN00 database; (2)how will the owner/operator be selected; (3)how will the costs of providing   PCS N00 number portability be recovered; and (4)by what date should PCS N00 number  Y2-  portability be deployed.eK2 zP -ЍPCS N00 Portability Report at 2829.e The report recommends that the appropriate regulatory bodies identify   a specific industry group to do detailed planning for development and implementation of a  Y -nationwide PCS N00 database once the regulatory issues are resolved.LZ ~ xP3- ЍAccording to the INC, this industry group should: draft an RFP and handle the bidding process for a PCS   LN00 database; develop a detailed time-line for cutover to the database; and monitor the development, operation,  zP-and maintenance of the database. PCS N00 Portability Report at 3132.  Y -  ` ` L77. Presently, LECs provide 500 access by two methods: switchbased  Y -  Ytranslation or database capabilities.sM  zP-Ѝ500 Access Order, 9 FCC Rcd at 7873, 4.s We seek comment on the extent to which LECs are using   AIN capabilities or other database technology to provide 500 access, and on the impact that PCS   JN00 service provider portability would have on the LEC networks. We also seek comment on   Ywhether it is feasible (both technically and economically) to provide PCS N00 service provider portability in a switchedbased translation environment.  Y6-  |` ` M78. We ask parties to address the extent to which PCS N00 number portability   will lower prices, and thereby stimulate demand for PCS N00 number services. Parties are   asked to provide comment, studies, data, and other information on the estimated costs of   designing, building, and deploying a PCS N00 database, and the estimated costs of operating   such a database. We seek comment on whether it is technically feasible to upgrade the existing   K800 database and associated software to accommodate PCS N00 numbers, and if so, at what   cost. We seek comment on the advantages, disadvantages, and relative costs of the proposed  Y-architectures and call flow scenarios set forth in the PCS N00 Portability Report.  Yj-  N` ` N79. We tentatively conclude that the owner/operator of the service management   systems administering the PCS N00 database should be a neutral third party. We seek comment   on this tentative conclusion and on the other regulatory issues that the INC has presented to this   Commission. We further seek comment on whether we should direct an industry group to   proceed with the development of an implementation plan for PCS N00 service provider   portability. Assuming such a directive is in the public interest, we seek comment on what"2 M,** "   industry group (for example, ATIS or the Telecommunications Industry Association) should be   selected to develop the detailed implementation plan for the database. Finally, we ask parties  Y-  to comment on the estimated implementation schedule set forth in the PCS N00 Portability  Y-Report and to propose an alternative schedule, if appropriate.  Yz-$ IV. CONCLUSION ׃  YM-  ` ` O80. IV Number portability is an increasingly important issue that has direct impact   Zon the provision of interstate telecommunications services. By this Notice, we seek to draw   upon the industry and state efforts with respect to number portability as we develop a record on   the public interest benefits of number portability and how best to implement specific solutions to number portability problems.  Y -  V. PROCEDURAL MATTERS ׃ l  X- ` ` A. Ex Parte   YR-  ` ` P81. VA This is a non-restricted notice and comment rulemaking. Ex parte   presentations are permitted, except during the Sunshine period, provided they are disclosed as  Y&-provided in the Commission's rules.N& zP-ЍSee generally 47 C.F.R. 1.1202, 1.1203, and 1.1206(a).  X- ` ` B. Regulatory Flexibility Act   Y-  l` ` Q82. VB As required by Section 603 of the Regulatory Flexibility Act, 5 U.S.C.601  Y-  et seq. (1981), the Commission has prepared an Initial Regulatory Flexibility Analysis (IRFA)   of the expected impact on small entities resulting from the policies and proposals set forth in this   Notice. The IRFA is contained in AppendixA to this Notice. The Secretary shall cause a copy   of this Notice, including the IRFA, to be sent to the Chief Counsel for Advocacy of the Small Business Administration in accordance with Section 603(a) of the Regulatory Flexibility Act.  X,-` ` C. Notice and Comment Provision   Y-  O` ` R83. VC  IRFA Pursuant to applicable procedures set forth in Sections 1.415 and 1.419 of   the Commission's Rules, 47 C.F.R. 1.415 and 1.419, interested parties may file comments  Y -  on or before September12, 1995 and reply comments on or before October12, 1995. To file   wformally in this proceeding, parties must file an original and four copies of all comments, reply   comments, and supporting comments. Parties wanting each Commissioner to receive a personal   copy of their comments must file an original plus nine copies. Comments and reply comments   should be sent to the Office of the Secretary, Federal Communications Commission,   Washington, D.C. 20554. In addition, parties should file two copies of any such pleadings with   the Policy and Program Planning Division, Common Carrier Bureau, Room 544, 1919 M Street,   N.W., Washington, D.C. 20554. Parties should also file one copy of any documents filed in"0'ZN,**_("   this docket with the Commission's copy contractor, International Transcription Services, Inc.   (ITS, Inc.), 2100 M Street, N.W., Suite 140, Washington, D.C. 20037 (202/8573800).   Comments and reply comments will be available for public inspection during regular business hours in the FCC Reference Center, Room 239, 1919 M Street, N.W., Washington, D.C.  Yv-  VI. ORDERING CLAUSES ׃ l  YI-  O` ` S84. VI Accordingly, IT IS ORDERED that, pursuant to the authority contained in   wSections1, 4(i), 4(j), 201205, 218, and 332 of the Communications Act as amended, 47 U.S.C.   151, 154(i), 154(j), 201205, 218, and 332, a NOTICE OF PROPOSED RULEMAKING IS HEREBY ADOPTED.  Y -  Q` ` T85. IT IS FURTHER ORDERED that the Petition for Rulemaking of the Teleservices Industry Association IS GRANTED. ` `  hh,FEDERAL COMMUNICATIONS COMMISSION ` `  hh,William F. Caton ` `  hh,Acting Secretary " N,**"  Y-  @A-@> APPENDIXA ă  Y-  Initial Regulatory Flexibility Act Analysis ă  As required by Section 603 of the Regulatory Flexibility Act, 5 U.S.C.603, the   Commission has prepared an Initial Regulatory Flexibility Analysis (IRFA) of the expected   Limpact on small entities resulting from the policies and proposals set forth in this Notice. Written public comments are requested on the IRFA.  Y3-Reason for Action  This rulemaking proceeding was initiated to obtain comment on and information   concerning number portability because the Commission believes that the portability of telephone   numbers benefits consumers of telecommunications services and would contribute to the   development of competition among alternative providers of local telephone and other telecommunications services.  Y{-Objectives  In this Notice, the Commission tentatively concludes that the portability of telephone   numbers benefits consumers of telecommunications services and would contribute to the   development of competition among alternative providers of local telephone and other   telecommunications services. The Commission recognizes, however, that at this time it lacks   sufficient information on the costs (monetary and nonmonetary) of making telephone numbers   portable either between service providers, services, or locations. Furthermore, the Commission   tentatively concludes that it should assume a leadership role in developing a national number   portability policy, and seeks comment to determine the specific nature of this role. The   Commission seeks comment on whether it should promulgate rules to ensure the development   of number portability, and if so, what rules it should promulgate. Finally, it tentatively   concludes that service provider portability of 900 and 500 numbers is beneficial for customers   jof those services. The Commission seeks comment on that conclusion and on the costs of making such portability available and other related implementation issues.  Y -Legal Basis  The proposed action is authorized under Sections1, 4(i), 4(j), 201205, 218, and 332 of the Communications Act as amended, 47 U.S.C. 151, 154(i), 154(j), 201205, 218, and 332.  Y"-Reporting, Record-keeping, and Other Compliance Requirements  The proposals under consideration in this Notice do not propose new reporting or record-keeping requirements on carriers.  Y%'-Federal Rules Which Overlap, Duplicate or Conflict with These Proposals None. ")N,** +"Ԍ Y-Description, Potential Impact, and Number of Small Entities Involved  Small entities could be affected by the policies and proposals set forth in this Notice.   Number portability obligations have not been previously established with respect to any carrier.   It is uncertain whether such obligations are in the public interest and, if so, whether they should   apply to small entities. After evaluating the record established in response to this Notice, the   jCommission will examine the impact of all rule changes on small entities and set forth its findings in the Final Regulatory Flexibility Act Analysis.  Y1-Alternatives Minimizing the Impact on Small Entities with the Stated Objectives  yThe Notice solicits general comment on various obligations related to number portability.   YThe Commission will consider all significant alternatives presented in the record in response to the Notice.  Y -IRFA Comments  NWe request written public comment on the foregoing Initial Regulatory Flexibility   Analysis. Comments must have a separate and distinct heading designating them as responses  YK-to the IRFA and must be filed by the deadlines provided in paragraph  IRFA83  of this Notice."KN,**"  Y-  @A-B-@? APPENDIXB ă  Y-0 Glossary of Terms ă  Y- AIN ` `  Advanced intelligent network(#  Yy- ATIS ` `  Alliance for Telecommunications Industry Solutions(#  YL- CAP ` `  Competitive access provider(#  Y - CLASS ` `  Custom local area signalling service(#`  Y - CLC ` `  Carrier Liaison Committee(#  Y - CMRS ` `  Commercial mobile radio service(#  Y- CNA ` `  Customer node address(#`  Yk- DID ` `  Direct inward dialing(#  YU-  Y>- ERCF ` `  Enhanced remote call forwarding(#  Y- ICCF ` `  Industry Carriers Compatibility Forum(#  Y- INC ` `  Industry Numbering Committee(#  Y- IRFA ` `  Initial Regulatory Flexibility Analysis(#  Y- ISDN ` `  Integrated services digital network(#  Y]- LEC ` `  Local exchange carrier(#  Y0- LERG ` `  Local exchange routing guide(#  Y- b Line Number  The last four digits of a North American Numbering Plan telephone number.(#  Y!- LNP ` `  Local number portability(#  Y#- NANP ` `  North American Numbering Plan(#`  Ye%- NNA ` `  Network node address(#  Y8'- NPA ` `  Numbering plan area(#  Y )-  NPA code ` `  The first three digits of a North American Numbering Plan telephone" )N,**0*" number.(#  Y- r NXX code ` `  The three digits immediately following the NPA code of a North American Numbering Plan telephone number.(#  Y- OSP ` `  Originating service provider(#  Ya-  PCS ` `  Personal communications services. As used in this Notice, PCS can have  'two meanings. First, PCS, in a generic sense, refers to "a set of   capabilities that allows some combination of personal mobility, terminal  mobility, and service profile management." Second, PCS, as defined in   Section24.5 of the Commission's rules, refers to "radio communications   Cthat encompass mobile and ancillary fixed communication that provide  oservices to individuals and businesses and can be integrated with a variety of competing networks.(#  Y- POTS ` ` X Plain old telephone service(#  Yf- RCF ` `  Remote call forwarding(#  Y9- RFP ` `  Request for proposals(#  Y - SS7 ` `  Common channel signalling system(#  Y- TAP ` `  Terminating access provider(#  Y- IXC ` `  Interexchange carrier(# " N,**`"  Y-  @B-C-@> APPENDIX C  Parties Filing in Response to  X- Teleservices' Petition for Rulemaking à  Y-  Comments: ` ` (filed November23, 1994) Ameritech Companies (Ameritech) BellSouth Telecommunications (BellSouth) Interactive Services Association MCI Telecommunications Corporation (MCI) Network Telephone Services Pacific Bell Southwestern Bell Telephone Company (SWBell) Sprint Corporation (Sprint) U S WEST Communications The Weather Channel  Yd- Replies: ` ` (filed December12, 1994) MCI NYNEX Telephone Companies (NYNEX) Teleservices Industry Association (Teleservices) United States Telephone Association (USTA)