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A A B C W V U R N J E ? 8 4 / + ( $ !                   { x v# s& q* p. o2 o7 o? oF qK tQ xU ~X Z [ Z X U R M G @ 9 4 / * & !& ' ( ) * - / 2 6 9 = ? A D D F F F E D A ? = : 7 4 0 - + ) ( ' &  @ T@  =   S   & s ?    ? {s   Z@ A C F J O U \ c c   N F ? 9 4 0 . + * @  X- X   ( X-w  #XP\  P6QynXP#Federal Communications Commission`u(#FCC 9774 ă  yxdddy (+2 Before the w Federal Communications Commission  X-Washington, D.C. 20554 ă  X-Ԋ#Xj\  P6G;ynXP#  Xv-In the Matter of hh@h) x` ` hh@h)  XH-Telephone Number Portabilityhh@h)ppCC Docket No. 95116  X1-x` ` hh@h)ppRM8535 x` `  hh@h)  X -  FIRST MEMORANDUM OPINION AND  ORDER ON RECONSIDERATION  X -T P  Xy- xAdopted: March 6, 1997@hppReleased:  March 11, 1997 (#(#X By the Commission: `(#"Paragraph  X- Table of Contents ă`U (#+Number  X-    XxPI. INTRODUCTION p>"(#L 1 XxPII. BACKGROUND p>"(#L 2  Xe-XxX` ` xA.` ` First Report & Order ` p>"(#L 2  XN-XxX` ` xB.` ` Number Portability Methods ` p>"(#L 5  X7-XxX` ` xC.` ` Current State Efforts ` p>"(#L 8 XxPIII. DISCUSSION p!(#F 11  X-XxX` ` xA.` ` Issues Relating to LongTerm Number Portability Methods ` p!(#F 11  X-XxX` ` X ` ` 1. Performance Criteria p!(#F 11  X -XxX` ` X X a.Background p!(#F 11  X!-XxX` ` X X b.Pleadings p!(#F 14  X"-XxX` ` X X c.Discussion p"(#I 19  X#-XxX` ` X XXhh(1)hhService Degradation hp"(#I 21  Xh$-XxX` ` X XXhh(2)hhNetwork Reliability hp"(#I 25  XQ%-XxX` ` X XXhh(3)hhIntranetwork Use of QOR hp"(#I 30  X:&-XxX` ` X ` ` 2. Public Interest Considerations p"(#I 31  X#'-XxX` ` X X a.Overview p"(#I 31  X (-XxX` ` X X b.Purported Cost Savings Associated with QOR p"(#I 33  X(-XxX` ` X X c.Impact of QOR on the Implementation Schedule p"(#I 44"(,))ZZ'"Ԍ X-XxX` ` X X d.Impact on the States p"(#I 46  X-XxX` ` X X e.Conclusion p"(#I 47  X-XxX` ` xB.` ` Implementation Schedule for Wireline Carriers ` p"(#I 48  X-XxX` ` X ` ` 1. Background p"(#I 48  X-XxX` ` X ` ` 2. Deployment Only in Requested Switches p"(#I 50  X-XxX` ` X ` ` 3. Extension of Implementation Schedule p"(#I 72  Xv-XxX` ` X ` ` 4. Acceleration of Implementation Schedule p!(#C 100  X_-XxX` ` X ` ` 5. Exemptions for Rural and/or Smaller LECs p!(#C 108  XH-XxX` ` X ` ` 6. Implementation Requirements for Intermediate (N1) Carriers p!(#C 124  X1-XxX` ` xC.` ` Implementation Schedule for Wireless Carriers ` p!(#C 127  X -XxX` ` xD.` ` Deferral of Implementation Until Resolution of Cost Recovery Issues ` p!(#C 143 XxPIV. ORDERING CLAUSES p!(#C 149  X -XxPAPPENDIXA List of Parties(#  X-APPENDIXB Final Rules  Xy-APPENDIXC Description of Number Portability Methods  Xb-APPENDIXD Supplemental Final Regulatory Flexibility Analysis  XK-APPENDIXE Implementation Schedule  X- I. INTRODUCTION   X-x1.` ` On June 27, 1996, the Commission adopted the First Report and Order and  X-Further Notice of Proposed Rulemaking (First Report & Order) yO:-ԍxTelephone Number Portability, First Report and Order and Further Notice of Proposed Rulemaking, 11 FCC Rcd 8352 (1996). in this docket implementing the requirement under Section 251(b) of the Communications Act of 1934, as amended (the Act), that all local exchange carriers (LECs) offer, "to the extent technically feasible, number  X|-portability in accordance with requirements prescribed by the Commission."|  yOM-ԍx47 U.S.C. 251(b)(2). This requirement was added by the Telecommunications Act of 1996, Pub. L. No. 104104, 110 Stat. 56 (1996). By this action, we resolve certain petitions for reconsideration or clarification of our number portability rules  XN-adopted in the First Report & Order. Twentytwo parties filed petitions for reconsideration or clarification, nineteen parties filed oppositions or comments on the petitions, and sixteen  X -parties filed reply comments.t x yOI$-ԍxA list of petitioners and commenting parties appears at Appendix A.t While the petitions raise a broad range of issues, we address  X -three primary issues in this First Memorandum Opinion and Order on Reconsideration (First  X-Reconsideration Order). We will address the remaining issues in one or more subsequent reconsideration orders in this docket. First, we conclude that Query on Release (QOR) is not",-(-(ZZ" an acceptable longterm number portability method. Second, we extend the completion deadlines in the implementation schedule for wireline carriers by three months for PhaseI and by 45 days for PhaseII, clarify the requirements imposed thereunder, and address issues raised by rural LECs and certain other parties. Finally, we affirm and clarify our implementation schedule for wireless carriers.  Xv- II. BACKGROUND   XH-x A.` ` First Report & Order   X -x2.` ` Pursuant to the statutory requirement of Section 251(b), the First Report &  X -Order requires all LECs to implement a longterm number portability method in the 100 largest Metropolitan Statistical Areas (MSAs) according to a phased deployment schedule that  X -commences October1, 1997, and concludes December 31, 1998.ex  yON-  ԍxIn the First Report & Order, we identified two methods of providing service provider portability: those  ximethods that use databases (such as the Location Routing Number (LRN) method) and those that do not (such as  yO- x<Remote Call Forwarding (RCF) and Flexible Direct Inward Dialing (DID)). First Report & Order, 11 FCC Rcd at  xx8359, 8361. We refer to the database methods as those appropriate for "longterm" service provider portability  xbecause they do not suffer from the same limitations as nondatabase methods such as RCF and DID, which are  yO6- xcommonly referred to as "interim" or "currently available" measures. See First Report & Order, 11 FCC Rcd at 836162.e Thereafter, in areas outside the 100 largest MSAs, each LEC must make longterm number portability available within six  X -months after a specific request by another telecommunications carrier. The First Report &  X-Order also requires all cellular, broadband personal communications services (PCS), and covered Specialized Mobile Radio (SMR) providers to be able to deliver calls from their networks to ported numbers by December 31, 1998, and requires cellular, broadband PCS, and covered SMR providers to offer number portability throughout their networks and have the capability to support roaming nationwide by June 30, 1999.  X-x3.` ` Rather than choosing a particular technology for the provision of number portability, the Commission established performance criteria that any longterm number portability method selected by a LEC must meet. The Commission noted, however, that one  X-of the criteria it adopted effectively precludes carriers from implementing QOR. The First  X-Report & Order further concludes that longterm number portability should be provided through a system of regional databases that will be managed by one or more independent administrators selected by the North American Numbering Council (NANC).  XN-x4.` ` The First Report & Order also requires wireline LECs, pending their deployment of a longterm number portability method, to provide currently available number portability measures upon request by another telecommunications carrier. Consistent with  X -Section 251(e)(2) of the Communications Act, the First Report & Order sets forth principles that ensure that the costs of currently available measures are borne by all telecommunications carriers on a competitively neutral basis, and permits states to utilize various cost recovery",-(-(ZZ" mechanisms, so long as they are consistent with these statutory requirements and our  X-principles. The Commission also concurrently adopted a Further Notice of Proposed  X-Rulemaking (Further Notice) seeking comment on cost recovery for longterm number portability.  X-x B.` ` Number Portability Methods   X_-x5.` ` Because most telephone numbers within the North American Numbering Plan (NANP) are associated with a particular switch operated by a particular service provider, they currently cannot be transferred outside the service area of a particular switch or between switches operated by different service providers without technical changes to the switch or  X -network.   yO| -  zԍxUnder the North American Numbering Plan (NANP), telephone numbers consist of ten digits in the form  xxNPANXXXXXX, where N may be any number from 2 to9 and X may be any number from 0 to9. Numbering  xwplan areas (or NPAs) are known commonly as area codes. The second three digits of a telephone number are known  xas the NXX code. Typically, the NXX code identifies the central office switch to which the telephone number had  yO- xbeen assigned or central office code (CO). Administration of the North American Numbering Plan, Report and  yOd-Order, 11 FCC Rcd 2588, 259394 (1995) (Numbering Plan Order).  Industry participants have developed several methods for providing service provider portability that would be suitable for longterm use by carriers. These methods for providing longterm number portability employ databases containing the customer routing information necessary to route telephone calls to the proper terminating locations. All of these methods depend on Intelligent Network (IN) or Advanced Intelligent Network (AIN)  X-capabilities.x@ yO-  ԍxSee generally Intelligent Networks, Notice of Proposed Rulemaking, 8 FCC Rcd 6813 (1993). IN refers  xto a general call processing architecture in which a centralized database performs some aspect of call setup.  xDatabases supporting IN services are built to support a specific call processing application. AIN describes a specific  xLmodel of IN developed by Bellcore in which the database is a general purpose platform capable of supporting  xJmultiple call processing services. All of the longterm number portability methods utilize a signalling network (such  xas signalling system 7 or SS7) capable of routing database queries and responses and forwarding routing instructions. Proposed Final Draft on Number Portability, Industry Numbering Committee (INC Report) at 7.  Xb-x6.` ` While various methods for providing longterm number portability have been developed, two methods have emerged as the primary ones advocated by parties in this  X4-proceeding: Location Routing Number (LRN) and Query on Release (QOR).p4  yOe -ԍxFor a more detailed description of LRN and QOR, see Appendix C.p Under LRN, a unique 10digit number, or location routing number, is assigned to each central office switch. Carriers routing telephone calls to customers that have transferred their telephone numbers from one carrier to another perform a database query to obtain the location routing number  X-that corresponds to the dialed telephone number. yO%-  kԍxFor intraLATA calls, the originating carrier normally would perform the database query. For interLATA calls, the interexchange carrier normally would perform the query. The database query is performed for all"h,-(-(ZZr"  X-calls to switches from which at least one number has been ported.@ X yOy-   ԍxWe use the term "ported" in this context to mean the transfer of a telephone number from one carrier's  xswitch to another carrier's switch, which enables a customer to retain his or her number when transferring from one carrier to another. @ The carrier then routes the call to the new carrier based on the location routing number.  X-x7.` ` QOR, also known as Look Ahead, is a triggering mechanism that operates in conjunction with the LRN addressing scheme. Under QOR, the signalling used to set up a telephone call is routed to the end office switch to which the dialed telephone number was originally assigned (known as the donor switch or the release switch) according to the NPANXX of the dialed number. If the dialed number has been transferred to another carrier's switch, the release switch sends a release message back, and the previous switch in the call  X1-path queries the database to obtain the routing information. 1 yO -  ԍxFor intraLATA calls, the previous switch in the call path would be the originating switch. For interLATA calls, the previous switch in the call path would be an interexchange carrier's. The call is then completed to the new carrier's switch.  X -x C.` ` Current State Efforts   X -x8.` ` Prior to the adoption of our First Report & Order, a number of state commissions had selected LRN as the method for implementing number portability in areas within their states' boundaries. These states include Colorado, Georgia, Illinois, Maryland,  Xy-New York, and Ohio.! y@ yOj-  ԍxFirst Report & Order, 11 FCC Rcd at 836263. The task force in Florida had also selected LRN for  yO2-implementing number portability prior to adoption of the First Report & Order. Id. at 8362.! On August 2, 1996, the California Public Utilities Commission (CA PUC) issued an order mandating the use of LRN as the longterm number portability method  XK-to be implemented in California.2 XK yO-  ԍxCalifornia Public Utilities Commission, Re Local Exchange Service, Rulemaking Proceeding 9504043,  xInterim Order 9504044, Decision 9608028, slip op. at 1415 (Aug.2, 1996) (CA PUC Local Exchange Service Decision).2 No states have selected QOR as the preferred method for longterm number portability.  X-x9.` ` Since adoption of the First Report & Order, planning and implementation of longterm number portability has progressed significantly. A number of state commissions have spent the past eight months developing statespecific plans for implementing LRN and resolving technical issues associated with the deployment of LRN. For example, the Illinois Commerce Commission Number Portability Workshop (ICC Workshop) remains in the forefront with respect to implementation of number portability. It has developed a detailed LRN test plan and has resolved numerous operational issues relating to switching, signalling,"| ,-(-(ZZ"  X-and SCP requirements.  yOy-  ԍxSee Illinois Local Number Portability Steering Committee, Minutes of Dec.16, 1996, Meeting, CC Docket No. 95116, filed Jan.10, 1997 (IL LNP Steering Committee December16, 1996 Minutes). In addition, the Maryland Public Service Commission has determined a ranking and timeline for deployment of LRN in every switch in Maryland; established a comprehensive operations plan for LRN implementation; resolved issues relating to interfaces, ordering, provisioning, repair and maintenance processes as well as operator  X-services; and studied switch and SCP requirements.   yOu-  ԍxStaff of the Public Service Commission of Maryland, Commission's Investigation into Long Term Solutions  yO= - xwto Number Portability in Maryland: Third Quarterly Report of the Maryland Local Number Portability Consortium,  xCase No.8704, at 1418, CC Docket No. 95116, filed Nov.22, 1996 (rel. Oct. 1996) (MD LNP Consortium October1996 Report). Number portability task forces in Indiana, Michigan, and Ohio have also developed switchspecific implementation plans for  Xv-those states.v yO/-  ԍxSee, e.g., Indiana Number Portability Task Force, Cause No. 39983, Oct.7, 1996, CC Docket No. 95116,  x;filed Jan.10, 1997 (IN LNP Task Force October7, 1996 Minutes); Michigan Local Number Portability Workshop,  xNovember21, 1996 Meeting Minutes and December17, 1996 Agenda, CC Docket No. 95116, filed Jan.10, 1997  yO- x(Michigan LNP Workshop November21, 1996 Minutes); Sprint Ex Parte Letter at 45, from Warren D. Hannah,  yOO- xto William F. Caton, FCC, CC Docket 95116, filed Dec.19, 1996 (Sprint December19, 1996 Ex Parte Filing) (minutes of Nov.13, 1996 meeting of Ohio Local Number Portability Workshop).  XH-x 10.` ` The industry, under the auspices of the NANC, has been working on the design of the number portability regional database system. The NANC, a Federal Advisory  X -Committee established under the provisions of the Federal Advisory Committee ActJ  yOK-ԍx5 U.S.C., App. 2 (1988).J to  X -advise the Commission on numbering issues, held its first meeting on October1, 1996.EX  yO-  ԍxFCC Establishes North American Numbering Council Advisory Committee, Announces Members, and Sets  yO- xKInitial Meeting Date, Public Notice, CC Docket No. 92237, DA 961495 (rel. Sept.5, 1996) (Establishment of NANC Public Notice).E The NANC's Local Number Portability Administration (LNPA) Selection Working Group and its task forces have been meeting regularly to assist the NANC in recommending to the Commission resolution of issues related to the selection and duties of an entity or entities to serve as the local number portability administrator(s), the database architecture plan, and the  X-technical and operational requirements for the number portability database system.@0 yOq!-  ԍxThe North American Numbering Council Chairman Announces Organizational Structure and Seeks Working  yO9"- xJGroup and Task Force Participants, Public Notice, CC Docket No. 92237, DA 961664 (rel. Oct.4, 1996) (NANC  xAnnounces Organizational Structure Public Notice); Local Number Portability Administration Selection Working  xGroup Status Report: North American Numbering Council Meeting of February26, 1997, at 1, CC Docket No. 95 yO$- x116, filed Mar.4, 1997 (LNPA Selection Working Group February26, 1997 Status Report); see also Local Number  xPortability Administration Selection Working Group Status Report: North American Numbering Council Meeting  x>of December2, 1996, at 7, CC Docket No. 95116, filed Dec.4, 1997 (LNPA Selection Working Group December2, 1996 Status Report). The"8,-(-(ZZ" NANC has committed to making its recommendation to the Commission on LNPA issues by  X-May1, 1997.~ yOb-ԍxNANC Timeline at 1, CC Docket No. 95116, filed Dec.9, 1996 (NANC Timeline).~ Under NANC oversight, carriers in Illinois, Georgia, California, Maryland, Colorado, New York, and Texas have formed a Limited Liability Corporation (LLC) and issued a Request for Proposal (RFP) for each state to construct and maintain a number  X-portability database.X yO-  zԍxNorth American Numbering Council, State NPAC/SMS Status at 15, CC Docket No. 95116, filed Jan.8, 1997 (NANC January8, 1997 State NPAC/SMS Status). Each LLC has contacted neighboring states seeking to expand these  X-state databases into regional databases covering the RBOC service areas.c yO -ԍxNANC January8, 1997 State NPAC/SMS Status at 15.c The LNPA Selection Working Group projects that all seven regional databases will be ready for testing on dates ranging from April18, 1997, to July1, 1997, and will be ready to support number portability deployment on or before October1, 1997, in accordance with the deployment  X1-schedule set forth in the First Report & Order.1@ yO"-   ԍxLNPA Selection Working Group February26, 1997 Status Report at 1. See also NANC January8, 1997 State NPAC/SMS Status at 15; LNPA Selection Working Group December2, 1996 Status Report at 7.  X - III. DISCUSSION   X - /J:\POLICY\NUM_PORT\RECON1\ORDER\QOR.ORD/ x A.` ` Issues Relating to LongTerm Number Portability Methods (#`  X -x` ` 1. Performance Criteria   Xy-x ` `  a.Background   XK-x 11.` ` The Act requires all LECs "to provide, to the extent technically feasible,  X4-number portability in accordance with requirements prescribed by the Commission."J4 yO}-ԍx47 U.S.C.  251(b)(2).J The Act states that "[t]he term number portability' means 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  X-telecommunications carrier to another."Q(  yO!-ԍx47 U.S.C. at  153(30).Q We interpreted these statutory provisions to mean that the Commission should develop a national number portability policy and prescribe the requirements that all local exchange carriers, both incumbents and others, must meet to satisfy  X-their statutory obligations.`  yO%-ԍxFirst Report & Order, 11 FCC Rcd at 8370.` "|H ,-(-(ZZ"Ԍ X-x 12.` ` In the First Report & Order, we concluded that establishing performance criteria that a LEC's number portability architecture must meet would better serve the public  X-interest than choosing a particular technology or specific architecture.O yOK-ԍxId. at 8377.O We thus adopted the following nine minimum criteria, which require that any longterm number portability method must: (1) support existing network services, features, and capabilities; (2) efficiently use numbering resources; (3) not require end users to change their telecommunications numbers; (4) not require telecommunications carriers to rely on databases, other network facilities, or services provided by other telecommunications carriers in order to route calls to the proper termination point; (5) not result in unreasonable degradation in service quality or network reliability when implemented; (6) not result in any degradation of service quality or network reliability when customers switch carriers; (7) not result in a carrier having a proprietary interest in any longterm method; (8) be able to accommodate location and service portability in the future; and (9) have no significant adverse impact outside the areas where number  X -portability is deployed.I X yO-ԍxId. at 8378.I We concluded that a number of these criteria implement the statutory requirement that customers switching their carrier be able to retain their numbers  X -"without impairment of quality, reliability, or convenience."L  yO@-ԍxId. at 837883.L  Xy-x 13. In addition, we concluded that criterion four precludes carriers from using such  Xb-number portability methods as QOR.Ibx yO-ԍxId. at 8381.I When discussing criterion four, we stated that carriers may experience several undesirable effects if they are forced to rely on the networks of their competitors in order to route calls. For example, the use of number portability methods that first route the call through the original service provider's network in order to determine whether the call is to a ported number, and then perform a query only if the call is to be ported, would treat ported numbers differently than nonported numbers, resulting in ported  X-calls taking longer to complete than unported calls.I yO-ԍxId. at 8380.I This differential in efficiency would disadvantage the carrier to whom the call was ported and impair that carrier's ability to  X-compete effectively against the original service provider.: yO!-ԍxId.:  X|- x` `  b.Pleadings   XN-x 14.` ` Most petitioners focus primarily on our conclusion in the First Report & Order that incumbent LECs are prohibited from using QOR as a longterm number portability"7( ,-(-(ZZ"  X-method.  yOy-ԍxBell Atlantic Petition at 78; BellSouth Petition at 21; Pacific Petition at 1011; USTA Petition at 4. They argue that QOR does not violate the performance criteria the Commission established, and that QOR has many public interest benefits that will make it more efficient,  X-easier, and less costly to deploy than other number portability methods.4! X yO-  ԍxSee, e.g., Bell Atlantic Petition at 12; BellSouth Petition at 21 n.21; Pacific Petition at 1; SBC Petition at  yO- x12; USTA Petition at 3; U S West Petition at 1213; see also Bell Atlantic et al. Ex Parte Letter, from Raymond  yOk- xSmith, Bell Atlantic, et. al, to William Caton, FCC, CC Docket No. 95116, filed Nov. 26, 1996 (Bell Atlantic et  yO3-al. November 26, 1996 Ex Parte Filing).4 They assert that, at a minimum, we should allow a carrier to use QOR within its own network in order to route  X-calls made by its own customers to NXXs assigned to that carrier.S"X@ yO -  ԍxBell Atlantic Petition at 78; BellSouth Petition at 2122; NYNEX Petition at 36; Pacific Petition at 34;  yO] - xSBC Petition at 13; USTA Petition at 6; US West Petition at 12 n.16. See also Cincinnati Bell Comments at 1; GTE Opposition at 3.S Furthermore, they claim that a LEC's "intranetwork" use of QOR would not impact other carriers, nor would it present  Xv-network interoperability issues.X#v`  yO-  ԍxBell Atlantic Petition at 3, 8, 10; BellSouth Petition at 22 n.23; NYNEX Reply at 5; Pacific Petition at 3;  yOO- xLUSTA Petition at 2, 56. See also GTE Reply at 3. Some petitioners suggest that opponents of QOR fail to  xhunderstand how QOR works, pointing out that QOR does not require competing LECs to rely on the incumbent LEC  yO- xto process calls originated by the customers of the competing LEC. USTA Petition at 45; see also GTE Opposition at 5.X Some petitioners also argue that we should allow the use of  X_-QOR between networks if the carriers mutually agree to do so.$_ yO -ԍxBellSouth Petition at 2122; Pacific Petition at 3; USTA Petition at 6. See also TCG Reply at 3.  X1-x15.` ` With respect to the performance criteria, petitioners assert that QOR does not  X -violate performance criterion four (i.e., it does not "require dependency on another carrier's  X -network") any more than other number portability methods, such as LRN.%  yOT-ԍxBell Atlantic Petition at 910; BellSouth Petition at 21; Pacific Petition at 4 n.2, 11; USTA Petition at 4. For example, Pacific and USTA argue that there is no rational basis for the Commission to conclude that a number portability method that requires an SS7 message to be sent to a switch to which the NXX code of the called number has been assigned (the "essence" of QOR) causes "undue reliance" on the networks of other carriers, while a number portability method that requires an SS7 message to be sent to the incumbent's Service Control Point (SCP) (the "essence" of  Xy-LRN) does not involve such undue reliance.&xy0 yOZ"-   ԍxPacific Reply at 6; USTA Reply at 2. An SCP is a database in the public switched network that contains  xYinformation and call processing instructions needed to process and complete a telephone call. An originating switch  x<accesses an SCP to obtain such information. Typically, the information contained in an SCP is obtained from a  xService Management System (SMS). An SMS is a database or computer system not part of the public switched  xnetwork that, among other things: (1) interconnects to an SCP and sends to that SCP the information and call  xprocessing instructions needed for a network switch to process and complete a telephone call; and (2) provides  xwtelecommunications carriers with the capability of entering and storing data regarding the processing and completing" '%,-(-(U'" of a telephone call. Because every number portability method"y X&,-(-(ZZ" requires some dependence on another carrier's network facilities, several petitioners suggest that we eliminate criterion four as one of the performance criteria that a longterm number  X-portability method must meet.t'X yO-ԍxBellSouth Petition at 1921; SBC Petition at 2; USTA Petition at 4.t  X-x16.` ` Petitioners also argue that QOR does not result in any degradation of service quality or network reliability when customers switch carriers (performance criterion six). These parties contend that claims that use of QOR will cause significant additional delays in the routing of calls to ported numbers are unfounded. They allege that any additional delay attributable to the use of QOR is insignificant and imperceptible, as compared to the delay  X1-associated with LRN.b(` 1 yO -  \ԍxRecord estimates of the additional postdial delay stemming from the use of QOR to route calls to ported  xnumbers, as compared to the use of LRN to route calls to ported numbers, range from 0.4 to 0.5 seconds. Pacific  xPetition at 5, 6 (0.4 seconds); USTA Petition at 7 (0.5 seconds); US West Petition at 14 n.19 (less than 0.5 seconds).  yO"- xSee also ALTS Response at 4 (actual delay will depend on number of offices involved in completing QOR inquiry).  xxThe additional delay associated with QOR is comprised of the setup time for the originating switch to determine  xand signal the terminating switch; for the terminating switch to determine that the number called no longer resides  xZin that switch, create the return message, and signal the originating switch; and for the originating switch to take  yOB- xxdown the reserved call path. AT&T Ex Parte Presentation at 8, CC Docket No. 95116, filed October 29, 1996  yO - x(AT&T October 29, 1996 Ex Parte Filing). The LRN query must still be performed either by the original  xterminating switch, the originating switch, or the intermediate (N1) carrier. The call must go through additional  xsteps, reserve additional trunks, and possibly encounter even more delay if it must go through tandems linking the  yOb-originating and terminating switches. Id. at 4.bPDD US West urges the Commission to conduct a survey to determine  X -whether callers would perceive differences in call setup time between LRN and QOR.L)  yO-ԍxUS West Petition at 1215.L In addition, NYNEX asserts that QOR would impose postdial delay on a much smaller set of calls than LRN, because LRN without QOR increases postdial delay for all interswitch calls,  X -whether ported or not.B*  yO&-ԍxNYNEX Reply at 4.B USTA, on the other hand, argues that the standard should not be whether network routing for ported and nonported numbers is identical, but whether service  X -quality is discriminatory.h+ 0 yO -ԍxUSTA Petition at 8; see also GTE Opposition at 4.h  Xy-x17.` ` With respect to network reliability, proponents of QOR assert that QOR is less likely to threaten the reliability of the network than LRN, because QOR requires far fewer  XK-database queries than LRN.,K yO%-  ԍxBellSouth Petition at 2324; GTE Petition at 10; NYNEX Petition at 56; Pacific Petition at 9; USTA Petition at 1011. These parties contend that QOR imposes less of a burden on"K ,,-(-(ZZI"  X-the SS7 network and, therefore, poses a lower risk of a network outage.6-  yOy-  .ԍxSee, e.g., BellSouth Petition at 24; Bell Atlantic Petition at 3, 5; Pacific Petition at 78, 9; Pacific Ex Parte  yOA- x;Presentation at 3, CC Docket No. 95116, filed October 24, 1996 (Pacific Oct. 24, 1996, Ex Parte Filing); see also  yO - xBell Atlantic/Pacific joint Ex Parte Presentation at 4, CC Docket No. 95116, filed Jan. 10, 1997 (Bell  yO-Atlantic/Pacific January 10, 1997, Ex Parte Filing).6 In a latefiled ex  X-parte presentation, SBC submitted a network reliability study conducted by Bellcore that purportedly demonstrates that there is a 0.036 percent (0.00036) probability of a "catastrophic outage" if LRN is implemented under what they characterize as a "normal" schedule, and no probability of such a catastrophic network outage if QOR is implemented under a "normal"  X-schedule and less than one percent of the numbers are ported.. yO -  =ԍxSBC Ex Parte Letter at att. at 5, from Link Brown, to William F. Caton, FCC, CC Docket No. 95116, filed  yO - xFeb. 19, 1997 (SBC February 19, 1997 Ex Parte Filing). The Bellcore study defines "catastrophic outage" as losing  xall intraLATA, interoffice service for most or all of Houston. The Bellcore study further states that the "normal"  xYintroduction of a network capability involves "the definition of the capability, identification of all affected network  x<components, preparation and testing of new software and hardware as needed, development of operations plans,  xinstallation and testing of new hardware and software, integration testing and soak of new hardware, software, and  yO- xYprocedures within a carrier's network, and intercompany testing and soak." Id. at n.3. Pacific Bell and Bell Atlantic  yOf- xalso reiterated their concerns about network reliability if QOR is not permitted. See Pacific Bell, Bell Atlantic, and  yO.- xSBC Ex Parte Letter at 1, from Ross Ireland, to William Caton, FCC, CC Docket No. 95116, filed Feb. 24, 1997  yO-(Pacific, et al., February 24, 1997 Ex Parte Filing). MCI and AT&T vigorously dispute the purported findings of the Bellcore study, arguing, among other things, that the figures for "catastrophic outage" assume that all number portability databases in Houston fail simultaneously, which they argue is a highly improbable scenario, given that SBC has never  X1-experienced a single dual SCP failure, much less a dual failure of all SCPs.S/ 1H  yO*-  \ԍxMCI Ex Parte Letter at 2, from Donna Roberts, to William F. Caton, FCC, CC Docket No. 95116, filed  yO- xFeb. 26, 1997 (MCI February 26, 1997 Ex Parte Filing); see also AT&T Ex Parte Letter at 1, from R. Gerard  yO- xKSalemme, to William F. Caton, FCC, CC Docket No. 95116, filed Feb. 26, 1997 (AT&T February 26, 1997 Ex  yO-Parte Filing). For further discussion of the Bellcore study, see infra note ANTI-BELLCORE248.S MCI also notes that, according to the Bellcore study, probabilities for FCC reportable outages with LRN and  X -QOR are virtually identical under the same scheduling scenarios.0 0 yO-ԍxMCI February 26, 1997 Ex Parte Filing at 2; see infra note REPORTABLE235 (defining "FCC reportable outage"). In response, Bellcore argues that the types of failures contemplated by the Bellcore study are not "too improbable to be of concern" as AT&T claims, because a combination of events and errors has resulted in  X -various switch failures and outages in the past.w1X  yO/!-  [ԍxBellcore Ex Parte Letter at 12, from Michael Knapp, to William Caton, FCC, CC Docket No. 95116, filed  yO!- xhMar. 5, 1997 (Bellcore March 5, 1997 Ex Parte Filing) (citing outages in the networks of AT&T, Bell Atlantic, and Pacific Bell as examples of prior network failures).w Thus, Bellcore asserts that, even though a complete failure has not occurred, there is certainly a reasonable probability that such an  X-event could occur in the future.:2 yO!&-ԍxId.: In fact, Bellcore claims that such partial and complete failures have been relatively rare in the United States, because the industry has been diligent"y p2,-(-(ZZ" in anticipating failures, guarding against them, and adopting designs and procedures that  X-minimize their effects when they occur.:3 yOb-ԍxId.:  X-x18. ` ` Parties opposing these petitions argue that QOR violates both criterion four and  X-criterion six.4X yO-  ԍxSee, e.g., AT&T Opposition at 1415; MCI Opposition at 8; Time Warner Comments at 45; TRA Comments at 1112. They argue that QOR requires greater dependence on an incumbent LEC's  X-network than other number portability methods, such as LRN.5 yO -ԍxAT&T Opposition at 1415; MCI Opposition at 78; Time Warner Comments at 45.  For example, opponents of QOR claim that QOR requires more signalling and routing steps than LRN before the call is delivered to a customer that has ported a number. They also assert that QOR relies to a  XH-greater extent on an incumbent LEC's facilities, because QOR uses both the signalling and trunking networks to reserve a call path to the incumbent LEC's terminating switch to which  X -the NXX code of the called party was originally assigned.6 @ yO -ԍxSee AT&T October 29, 1996 Ex Parte Filing at 10; MCI October 28, 1996 Ex Parte Filing at 3. Opponents of QOR further assert that the use of QOR affects service quality and network reliability. They contend that: (1) QOR results in service degradation by causing an incremental increase in the postdial delay  X -for calls ported to a new carrier;~7  yOV-  ԍxOpponents of QOR assert that the proper comparison for postdial delay is not the postdial delay of QOR  xversus LRN as the proponents of QOR claim, but rather the postdial delay using QOR for calls to ported numbers  yO- xjversus calls to nonported numbers. See, e.g., MCI Opposition at 9. MCI further asserts that postdial delay  yO- xassociated with QOR could be 1.7 seconds or more. MCI Opposition at 910; see also ALTS Response at 4; AT&T Opposition at 10; Sprint Opposition at 23.~ (2) QOR impairs network reliability because additional  X -network routing increases the potential for dropped calls and call blocking for ported calls,8  yO-  kԍxMCI Ex Parte Presentation at 2, CC Docket No. 95116, filed Oct. 28, 1996 (MCI October 28, 1996 Ex  yO-Parte Filing). and that (3) QOR is therefore not "competitively neutral," even when it is used only "within a  X-carrier's network" or between consenting carriers..9 yO-  ԍxAT&T Opposition at 11; MCI Ex Parte Presentation at 2, CC Docket No. 95116, filed Oct. 16, 1996 (MCI  yO-October 16, 1996 Ex Parte Filing); MCI October 28, 1996 Ex Parte Filing at 2; Sprint Opposition at 2..  Xb- x` `  c.Discussion   X4-x19.CRIT 4 ELIMINATED` ` Criterion Four. Based on our analysis of the record in this proceeding, we now conclude that criterion four should be removed from our list of minimum performance criteria required for number portability, because all interconnected carriers are likely to rely upon each other's networks to some extent to process and route calls in a market in which a long" 09,-(-(ZZ "ԫ X-term number portability method has been deployed.: yOy-ԍxSee, e.g., BellSouth Petition at 1921; SBC Petition at 2; USTA Petition at 4. For example, under both LRN and QOR, the competitive LEC may be dependent upon facilities provided by the original service provider for the proper routing of all ported calls, because the original service provider is the entity that launches a query to the number portability database to obtain the location routing number for the dialed number. Furthermore, we find no basis in the record for drawing a principled distinction between permissible and impermissible levels of reliance on the original service provider's network. For these reasons, we find that criterion four which requires that any number portability method may not "require telecommunications carriers to rely on databases, other network facilities, or services provided by other telecommunications carriers in order to route calls to the proper termination point" is, from a practical perspective,  X -unworkable. Moreover, many of our concerns about reliance on a competitor's network (e.g., the possibility of service degradation and call blocking) are addressed by criterion six. Thus, criterion four does not appear to be necessary in order to implement the statutory definition of number portability. In light of our decision to eliminate criterion four, we conclude that  X -AirTouch's requested clarification of criterion four is moot.; X yO-  ԍxSee AirTouch Petition at 910 (seeking clarification that criterion four does not prohibit a carrier from unilaterally relying upon another carrier for the routing and transport of its traffic).  X-x20.` ` Criterion Six. With respect to criterion six, we affirm our conclusion in the  Xy-First Report & Order that any longterm number portability method must not result in any degradation of service quality or network reliability when customers switch carriers. We further conclude, based on the record in this proceeding, that criterion six prohibits the use of QOR as a longterm number portability method. We agree with the commenters, primarily potential new providers of local exchange services (also referred to as "competitive LECs"), that: (1) QOR results in degradation of service by imposing postdial delay only on calls ported to new carriers; (2) if network reliability problems were to arise as a result of QOR, those problems would disproportionately affect customers who port their numbers; and (3) QOR should not be permitted on an intranetwork basis, because it is not "competitively  X-neutral."< yO -  ԍxAT&T Opposition at 11; MCI October 16, 1996 Ex Parte Filing at 2; MCI October 28, 1996 Ex Parte Filing at 2; Sprint Opposition at 2. We discuss each of these conclusions in more detail below.  X|-x` `  (1)hhService Degradation   XN-x21.` ` After considering petitioners' arguments and concerns, we affirm our  X7-conclusion in the First Report & Order that, in accordance with criterion six, a longterm number portability method may not cause customers to experience "a greater dialing delay or  X -call set up time" as compared to when the customer was with the original carrier.a=  yO&-ԍxFirst Report & Order, 11 FCC Rcd at 8382. a Criterion"  =,-(-(ZZ[" six implements the statutory requirement that consumers be able to retain their numbers "without impairment of quality, reliability, or convenience when switching from one  X-telecommunications carrier to another."g> yOK-ԍxId. (citing 47 U.S.C.  153(30)).g  X-x22.` ` At the outset, we agree with AT&T and Time Warner that the time it takes to receive a call is an important factor for many subscribers, particularly businesses that receive  Xv-and respond to a large number of calls on a daily basis.)?XvX yO -  \ԍxAT&T Opposition at 11; Time Warner Comments at 5. According to AT&T, these customers would be  xdissuaded from choosing competitive LEC services if that would entail increased call setup time. AT&T Opposition at 11.) If the party making a call to a business experiences additional delay because that business has switched carriers, that delay may negatively impact how the business is perceived, which, in turn, could dissuade the business from switching carriers in the first place. Therefore, we clarify that performance  X -criterion six requires that calls to customers who change carriers (not just calls from customers who change carriers) must not take longer to complete merely because the customer  X -has switched local service providers.@  x yO-  ԍxParties arguing in favor of QOR contend that postdial delay associated with QOR would affect only the  xYparty originating the call, and not the terminating party that has ported its number. Bell Atlantic Petition at 58, 9  xn.13; BellSouth Petition at 22 and n.25; GTE Reply at 23; NYNEX Petition at 6; Pacific Petition at 56; USTA Petition at 7; US West Petition at 1315. In order to implement the statutory requirement that consumers should be able to change carriers and retain their original phone number without impairment of quality, reliability, or convenience, we conclude that any postdial delay imposed by a number portability method should be roughly equivalent for all consumers,  X-whether they are calling to or from a ported or a nonported number.jAX`  yO-  ԍxAs petitioners point out, various technical factors not related to number portability can contribute to postdial  yOi- xdelay, such as whether the call is an interswitch or an intraswitch call. See, e.g., Bell Atlantic Petition at 5; Pacific Petition at 5.j  Xb-x23.` ` We further conclude that consumers that switch telecommunications carriers and retain their numbers would experience "impairment of quality" if QOR were used, because the postdial delay imposed by QOR is not equivalent for all consumers. Under QOR, calls that are placed to ported numbers must undergo a series of signalling and routing steps that result in longer postdial delay than occurs for calls that are placed to nonported  X-numbers.B  yO #-  {ԍxTime Warner Ex Parte Presentation at 2, CC Docket No. 95116, filed Dec. 10, 1996 (Time Warner  yO#-December 10, 1996 Ex Parte Filing). (The additional steps in the call flow required by QOR are illustrated in Appendix C.) No party disputes that QOR causes additional postdial delay. There is disagreement, however, over the appropriate baseline for comparison. Proponents of QOR erroneously focus on the postdial delay of alternative number portability technologies, comparing the"B,-(-(ZZp" incremental postdial delay associated with a call to a ported number using LRN with that of  X-a call to a ported number using QOR.\C yOb-ԍxSee supra note  PDD40 .\ That is not the statutory standard. We agree with AT&T and MCI that the proper comparison for incremental postdial delay is the difference in delay between calls placed to ported numbers and calls placed to nonported numbers, because that is the delay that occurs "when switching from one telecommunications carrier to  X-another."wDX yO-ԍxAT&T October 29, 1996 Ex Parte Filing at 8; MCI Opposition at 9.w According to the most conservative estimates, calls to ported numbers from a network that uses QOR would experience an additional postdial delay of approximately 1.3  X_-seconds as compared to calls placed to nonported numbers./E_ yO -  ԍxSee, e.g., Pacific Reply at 6 (a ported call utilizing QOR will have postdial delay of approximately 1.3  yO -seconds); but see MCI Opposition at 910 (postdial delay associated with QOR is 1.7 seconds or more). / Because we find that postdial delay of 1.3 seconds is significant, we conclude that QOR violates the statutory definition of number portability and criterion six. By contrast, under LRN, there is no differential between ported and nonported calls; for all calls, it takes the same amount of time to query the database for appropriate routing instructions. LRN therefore does not impair service quality when a customer changes carriers. Accordingly, we conclude that LRN is consistent with the statutory definition of number portability and performance criterion six.  X -x24.` ` We also reject petitioners' argument that some degree of added postdial delay  X-should be acceptable, provided that it is not "perceptible" to the public.F@ yO-  ԍxAT&T and Sprint dispute the claim that the postdial delay is imperceptible to customers, arguing there is no record evidence to support this claim. AT&T Opposition at 12; Sprint Opposition at 4. First, we agree with AT&T that the studies submitted by petitioners fail to demonstrate that 1.3 seconds of post Xb-dial delay is imperceptible to the public.G b yO-  ԍxSee, e.g., AT&T Ex Parte Letter at 2, from Frank Simone to Melinda Littell, FCC, CC Docket No. 95116,  yOs- xfiled Nov. 21, 1996, (AT&T November 21, 1996 Ex Parte Filing) (noting that the experiment described in the  xMacDonald & Archambault Study did not establish a level of postdial delay below which the delay was  ximperceptible; rather, the experiment tested impatience levels among the participants when exposed to differences  xZin postdial delay.) The MacDonald & Archambault Study's authors specifically note that a customer's threshold  xfor postdial delay may change over time, and customers may demand shorter average postdial delay than was found  yO[- xtolerable when the study was conducted. See MacDonald & Archambault Study at 4.1; see also AT&T November  yO# - x21, 1996 Ex Parte Filing at 2. The Cotton & Kuonglau Study is inconclusive, because the authors recommend  yO - xadditional studies to resolve differences between the three call models used in the experiment. See Bell Atlantic  yO!- xxPetition at 6 & n.6 (citing MacDonald & Archambault, Using Customer Expectations in Planning the Intelligent  yO{"- xNetwork, Proceedings of the 14th International Teletraffic Congress (ITC) 95104 (1994) (MacDonald &  yOC#- xArchambault Study) and Cotton & Kuonglau, Effects of Initial and Subsequent AIN Call Setup Delays on Grade  yO $- x of Service Expectations, Technical Memorandum TMNWT016605, July 1990) (Cotton & Kuonglau Study); Pacific Petition at 5 & n.5 (citing MacDonald & Archambault Study). Second, we agree with those parties that contend that, even if the additional postdial delay were imperceptible to the caller, QOR could adversely affect competitors, because the incumbent LEC could truthfully advertise the fact"4PG,-(-(ZZ*" that calls to customers that remain on the incumbent LEC's network are completed more  X-quickly than calls to customers that switch to a competitor's network.jH yOb-  ԍxMCI Opposition at 10; Sprint Opposition at 5; Time Warner Comments at 5; ALTS Response at 4; but see  xBell Atlantic Reply at 23, n.4 (asserting that carriers using QOR probably would not advertise the fact that they have  yO- xiintentionally introduced delay into their own service); USTA Reply at 6. Accord Pacific Reply at 78 (customer  xwould more readily understand an advertisement that competitive LECs' customers' calls will complete faster than the incumbent's customers).j MCI points out that this could create a marketplace perception that competitive LECs are operating inferior  X-networks, which could harm competition.I x yO -  >ԍxMCI Opposition at 10 (asserting that incumbent LECs are likely to seize upon postdial delay as a factor  x to differentiate their services from those of a competitor, and citing as evidence the advertising claims of AT&T prior  xto the deployment of the 800 number database that its 800 service was operationally superior based on, among other things, its faster call completion). In response, six incumbent LECs have voluntarily committed not to mention the call setup time differences between LRN and QOR in their  X-advertising materials.4J`  yO-  ԍxSee Ex Parte Letter from Bell Atlantic, BellSouth, GTE, NYNEX, Pacific, and SBC, to William Caton,  yOf-FCC, CC Docket No. 95116, filed Feb. 10, 1997 (Bell Atlantic et al. February 10, 1997 Ex Parte Filing).4 As AT&T and MCI point out, however, the incumbent LECs' voluntary commitment is limited to "advertising materials," and therefore does not preclude them from mentioning call set up in all other aspects of their marketing, such as direct sales and telemarketing, news releases, studies commenced to compare competitors' service  X1-performance, and editorials.KX1  yO-  ԍxSee Ex Parte Letter from MCI to William Caton, FCC, CC Docket No. 95116, filed February 19, 1997  yOb- xY(MCI February 19, 1997 Ex Parte Filing); AT&T Ex Parte Letter, to William Caton, FCC, CC Docket No. 95116,  yO*-filed Feb. 18, 1997 (AT&T February 18, 1997 Ex Parte Filing). Furthermore, because only six incumbent LECs signed the letter, we have no basis on which to conclude that all incumbent LECs will refrain from using the differences in call setup time to influence marketplace perceptions and inhibit competition. Thus, we decline to designate a threshold below which added postdial delay is permissible. Moreover, given our concerns about these marketplace perceptions, we find US West's suggestion that the Commission survey consumers to ascertain whether they can  X -perceive the postdial delay associated with QOR to be unnecessary.L  yO0-  ԍxUS West Petition at 1215; see also NEXTLINK Opposition at 5 (urging the Commission to reject US West's request to delay implementation in order to survey consumers about postdial delay caused by QOR).   Xy-x` `  (2)hhNetwork Reliability  Xb-   XK-x25.NTWK RELIAB` ` QOR. As discussed above, criterion six requires that no longterm number portability method may result in "any degradation of service quality or network reliability  X-when customers switch carriers."`M0 yO%-ԍxFirst Report & Order, 11 FCC Rcd at 8378.` We agree with the opponents of QOR that technical concerns raised by QOR are more likely to impact ported numbers adversely than nonported"M,-(-(ZZ "  X-numbers.aN yOy-ԍxMCI October 28, 1996 Ex Parte Filing at 3.a For example, QOR requires fewer SS7 links to the number portability database than LRN because of the lower number of queries to support. There is a risk, therefore, that an SS7 network engineered to accommodate a lower traffic level would not be able to handle an unexpected sharp increase in the number of calls to ported numbers. Such increases could occur in response to advertising or promotions by competitive LECs with ported numbers.  X-Difficulties in querying the database may result in call blockage (i.e., lost or incomplete calls) and increased postdial delay, but only on calls to ported numbers. We also note that the apparent advantage of QOR in requiring fewer queries to the database is offset by the fact that it will require at least two additional signalling messages for each call to a ported number  X1-before routing instructions are obtained.O1X yO: -  zԍxSee MCI Opposition at 12, 14; Time Warner Comments at 3; see also National Communications System,  yO -Local Number Portability: AIN and NS/EP Implications at 9.2 (July 1996). This additional load on the signalling network  X -creates the potential for reliability problems for ported calls.aP  yO{-ԍxMCI November 6, 1996 Ex Parte Filing at 2.a We conclude that network reliability concerns posed by QOR violate criterion six and the statutory definition of number portability because, if any network problems arise as a result of QOR, they would disproportionately affect consumers who port their numbers.  X -x26.` ` LRN. As a related matter, proponents of QOR assert that deployment of LRN is more likely to result in network failure than if carriers are permitted to use the QOR  Xy-enhancement to LRN.hQXy@ yOj-  ԍxSee, e.g., Bell Atlantic/Pacific January10, 1997 Ex Parte Filing at 4; BellSouth Petition at 2324; GTE  yO2- xPetition at 10; NYNEX Petition at 56; Pacific Petition at 9; USTA Petition at 1011; SBC February 19, 1997 Ex  yO-Parte Filing.h Although the proponents of QOR do not frame their arguments in  Xb-terms of the performance criteria we adopted in the First Report & Order, the thrust of their argument appears to fall within the scope of criterion five, which requires that no number portability method should result in "unreasonable degradation in service quality or network  X-reliability when implemented."`R`  yO.-ԍxFirst Report & Order, 11 FCC Rcd at 8378.`  X-x27.` ` Based on the record before us, we conclude that petitioners have not  X-demonstrated that LRN fails to meet criterion five.S  yOy"-ԍxSee generally MCI February 26, 1997 Ex Parte Filing; AT&T February 26, 1997 Ex Parte Filing. Although the initial deployment of any new technology may pose some risk to the network, we are not persuaded that deployment of LRN will result in unreasonable degradation of network reliability when deployed under the  X-revised schedule adopted in this First Reconsideration Order. Indeed, petitioners' concerns about LRN's impact on network reliability are mitigated by a number of factors. First, as we noted previously, LRN has been examined extensively by a number of state commissions and"e S,-(-(ZZ1" industry workshops, and had been selected for deployment by at least six states prior to the  X-adoption of the First Report & Order.T yOb-ԍxFirst Report & Order, 11 FCC Rcd at 836263; see also Section II.C. Second, we provided in the First Report & Order for a field test of LRN in the Chicago MSA (Chicago trial), which should help to protect against  X-network reliability problems.cUX yO-ԍxFirst Report & Order, 11 FCC Rcd at 839394.c If technical problems with LRN arise with respect to the  X-Chicago trial, we can take appropriate action at that time.V  yO= -  /ԍx In addition, one of the Commission's advisory committees, the Network Reliability and Interoperability  xMCouncil, has identified number portability as an issue on which it will be developing recommendations for  xwconsideration by the Commission and the industry. We expect to receive those recommendations in July 1997. For further information on the Council, see http://www.fcc.gov/oet/nric. Third, as discussed in more detail in Section III.B.3 below, we are extending the implementation schedule for Phase I to allow carriers additional time to test number portability in a live environment, and to take appropriate steps to safeguard network reliability. Indeed, the Bellcore study submitted by SBC supports our conclusion that additional time for testing, integration, and soaking (limited use of the software in a live environment for a length of time sufficient to find initial defects)  X -will help to reduce the probability of network failure.jW  yO-ԍxSBC February 19, 1997 Ex Parte Filing at att. at 1.j Fourth, as we clarify below, the Commission's implementation schedule does not require a flashcut implementation on October 1, 1997, for those MSAs in the first phase of the deployment schedule. Rather, number portability may be implemented gradually throughout the initial phase, provided that implementation in the designated markets is completed by the end of that phase.  X-x28.` ` Moreover, petitioners' fears about LRN's impact on the SS7 network are not grounds for abandoning LRN. Because of the predeployment procedures we adopt in this order, carriers will know in advance the specific switches in each MSA that require local  XK-number portability capabilities.KXK`  yO\-ԍxSee Section III.B.2.K Furthermore, the task of forecasting signalling load requirements should be easier with LRN than QOR, because queries are required for all interoffice intraLATA calls. As a result, carriers should be able to use historic traffic flows to help predict how many of these calls are typically destined to switches where local number portability has been deployed. In contrast, for QOR, signalling loads are dependent upon the percentage of numbers actually ported, which is a figure more difficult to predict in advance.  X-x29.` ` In sum, we conclude that claims that LRN will threaten network reliability are speculative and are mitigated by the added time we have provided for carriers to implement number portability during Phase I and Phase II. We expect the industry to continue to anticipate failures, guard against them, and minimize their effects when they occur, which, as Bellcore points out, has helped to make such failures rare events in the United States in the"N X,-(-(ZZ"  X-past.cY yOy-ԍxBellcore March 5, 1997 Ex Parte Filing at 2.c Thus, given all of the safeguards and mitigating factors discussed above, we are persuaded that deployment of LRN will not result in "unreasonable degradation of network reliability."  X-x` `  (3)hhIntranetwork Use of QOR  Xv-x30.` ` Incumbent LECs ask us to permit them to use QOR on all calls that originate on their network and are placed to numbers that originally were assigned to one of their end  XH-offices (i.e., calls "within their own network" or "intranetwork calls").IZHX yOQ -ԍxPacific Petition at 34.I We conclude that their request is misleading insofar as it implies that only calls to and from their own customers would be affected. In fact, calls that are placed to numbers that have been ported would require a query to the number portability database after the originating switch is notified by the terminating switch in the incumbent LEC's service area that the called number has been ported. We agree with MCI that, as customers subscribe to alternative carriers, the only calls that will remain "within" the incumbent LEC's network will be calls from one of  X -the incumbent LEC's customers to another.q[  yOB-ԍxMCI Opposition at 7; see also Time Warner Comments at 23.q As discussed above, however, the call to the ported number would experience increased postdial delay because of the additional signalling and routing preparations required by QOR. Such disparity in treatment between ported and nonported numbers violates criterion six and the statutory definition of number portability.  X6-vx 2.` ` Public Interest Considerations   X-x` ` a. Overview   X-x31.` ` Petitioners further assert that, regardless of our performance criteria, incumbent vLECs should not be prohibited from using QOR as a number portability method, because deployment of QOR serves the public interest. First, they claim that QOR will result in  X-significant cost savings.\x yO-  ԍxBell Atlantic Petition at 5; BellSouth Petition at 23; GTE Petition at 10; NYNEX Petition at 45; Pacific Petition at 79; SBC Petition at 12; USTA Petition at 910; US West Petition at 13 n.18.  Second, they claim that permitting incumbent LECs to use QOR  X~-will make it easier for them to meet the Commission's implementation schedule.]~ yO"-ԍxBell Atlantic Petition at 10 n.14; NYNEX Petition at 6; Pacific Petition at 910.  XP-x32.` ` As an initial matter, we disagree with the petitioners' premise that LECs should be permitted to implement QOR regardless of the performance criteria, if the Commission determines that QOR serves the public interest. As stated above, we conclude that QOR""` ],-(-(ZZ" violates criterion six, which is required by the statute. Thus, we are not at liberty to apply a public interest analysis that could result in an abrogation of the statutory mandate. Nevertheless, because the parties raised public interest concerns, we address them here in order to establish that our decision to prohibit QOR is not contrary to the public interest.  X-x` ` b. Purported Cost Savings Associated with QOR  X_-x 33.` ` Background. In the First Report & Order, we concluded that there was little evidence on the record to support the claim that deployment of QOR would result in  X1-significant cost savings.`^1 yO -ԍxFirst Report & Order, 11 FCC Rcd at 8381.` We found, based on the record, that the competitive benefits of ensuring that calls are not routed through the original carrier's network outweighed any cost  X -savings that QOR might bring in the immediate future._X X yO -  ԍxId. at 8382. We noted that parties had argued that QOR could treat ported and nonported numbers  xwdifferently, increase postdial delay and the potential for call blocking, result in inefficient routing, create significant  yO-network interoperability issues, and delay deployment of a longterm number portability method. Id. at 8381. Although Pacific submitted summary figures purporting to indicate that it would save approximately $14.2 million per year if it implemented QOR (assuming that 20 percent of subscribers ported their numbers), we concluded that these purported savings, which represent less than twotenths of a percent of Pacific's total annual operating revenues, appeared insignificant in relation to the potential  X-economic and noneconomic costs to competitors if QOR is used.`x yO-  ԍxId. at 8381. We note that the cost estimates submitted by Pacific have varied significantly over the course  yO-of this proceeding. See infra noteESTIMATES VARY122. There was also record evidence that using QOR would only be costeffective at low levels of ported numbers,  Xb-depending on the switch type.aXb yO-  NԍxFirst Report & Order, 11 FCC Rcd at 8381. AT&T asserted that, using Lucent switches, QOR is cost  xYeffective only if less than 12 percent of subscribers port their numbers, and, using Siemens switches, is cost effective  yOs-only if less than 23 percent of subscribers port their numbers. Id. In addition, we expressed concern that, because carriers using QOR may be required to send QOR signalling to another carrier's switch to determine whether a customer has ported his number, this would require the second carrier to have the  X-ability to recognize and respond to the QOR message, thereby increasing its costs.b  yO-ԍxFirst Report & Order, 11 FCC Rcd at 838182; see also 47 C.F.R. 52.3(a)(4).  X- x!34.` ` Pleadings. Petitioners again contend they should be allowed to use QOR  X-because they would achieve significant cost savings.c  yO $-  ԍxBell Atlantic Petition at 5; BellSouth Petition at 23; GTE Petition at 10; NYNEX Petition at 45; Pacific  xPetition at 79; SBC Petition at 12; US West Petition at 13 n.18; USTA Petition at 910. The data in the petitions  xifor reconsideration contained only summary figures, although various carriers provided more detail in their reply  yOa&- xcomments and through the ex parte process. Some data was submitted on a confidential basis. For specific figures,  {O)'-see infra  FIGURES40. These parties claim that QOR would"2c,-(-(ZZ" result in a reduction in the number of database queries, which, in turn, would reduce the costs that must be incurred to complete the infrastructure upgrades necessary to implement QOR  X-compared to those necessary to utilize LRN.qd yOK-ԍxBell Atlantic Reply at 8; GTE Opposition at 67; TCG Reply at 2.q Specifically, petitioners allege that QOR would require a carrier to install fewer additional SCP pairs and SS7 signalling links, and to  X-upgrade fewer STPs, than would be the case for LRN.eX yO-  \ԍxSee, e.g., BellSouth Ex Parte Letter at 2, from Cynthia Cox, to William Caton, FCC, CC Docket No. 95 yOu-116, filed Oct.21, 1996 (BellSouth October 21, 1996 Ex Parte Filing). Petitioners also allege that QOR would place less additional load on switch processors, and would thereby delay the need to  Xv-upgrade those switch processors.fv yO -  ԍxSee, e.g., NYNEX Ex Parte Letter at 34, from Alan Cort, to William Caton, FCC, CC Docket No. 95116,  yO -filed Oct.21, 1996 (NYNEX October21, 1996 Ex Parte Filing)  XH-x"35.` ` Petitioners further argue that QOR would allow carriers to expand the capacity of their SS7 signalling networks more gradually to handle an increased number of queries, as numbers are ported to other carriers. They allege that LRN, in contrast, will require carriers to engineer their networks to accommodate queries on every call from a given NXX once one  X -telephone number has been ported from that NXX.xg  yO-ԍxSee, e.g., BellSouth October 21, 1996 Ex Parte Filing at 2.x According to these parties, this will require their networks to be grossly "overengineered" when number portability is initially deployed. Several petitioners note that carriers using QOR would be able to decide on a switchbyswitch basis when it is more cost effective to disable the QOR triggering mechanism and use LRN alone.  Xb-x#36.` ` In response, both AT&T and MCI claim that the LECs have overestimated the costs of LRN and underestimated the costs of QOR, thereby grossly exaggerating the relative  X4-cost savings associated with QOR.vh4 yO}-ԍxFor specific figures, see infra  FIGURES40.v Their principal objections to the carriers cost studies  X-are that they: (1) overstate the number of SCP pairs needed to deploy LRN;i(  yO-  ԍxMCI October 28, 1996 Ex Parte Filing at 2; MCI Ex Parte Presentation at 2, 45, CC Docket No. 95116,  yO-filed Nov. 6, 1996 (MCI November 6, 1996 Ex Parte Filing). (2) exaggerate the impact of LRN on switch processor capacity and fail to account for the impact of QOR on  X-switch processor capacity;;j  yO #-ԍxId. ; (3) overstate the number of queries from nonparticipating carriers, which results in overstated cost estimates, and fail to account for offsetting  X-revenues;k yO&-  ԍxAT&T October 29, 1996 Ex Parte Filing at 5; MCI October 28, 1996 Ex Parte Filing at 2; MCI November  yOJ'-6, 1996 Ex Parte Filing at 3, 5. (4) fail to estimate the cost of unnecessary call setup under QOR;7lh yO-  ԍxAT&T Ex Parte Presentation at 2, CC Docket No. 95116, filed Nov. 19,1996 (AT&T November 19, 1996  yOX-Ex Parte Filing); AT&T October 29, 1996 Ex Parte Filing at 5; MCI November 7, 1996 Ex Parte Filing at 25.7 (5) fail to" l,-(-(ZZ" account for the additional cost of provisioning QOR in all intermediate and terminating  X-switches, including modifications to Operator Support Systems (OSS);bm  yO-ԍxAT&T October 29, 1996 Ex Parte Filing at 6.b and (6) exaggerate  X-the speed of number portability deployment outside of the top 100 MSAs.an yO3-ԍxMCI October 28, 1996 Ex Parte Filing at 2.a In addition, MCI points out that GTE, SBC, NYNEX, and Bell Atlantic failed to specify the assumptions underlying their cost studies, and Pacific submitted its cost study on a confidential basis,  X-making it difficult to undertake a detailed analysis of those cost studies.ao@ yO~ -ԍxMCI November 7, 1996 Ex Parte Filing at 1.a  X_-x$37.COST EFFECTIVENESS` ` Furthermore, there is a dispute in the record over the point at which it becomes  XH-more cost effective to use LRN rather than QOR. As we noted in the First Report & Order, AT&T contends that it is more cost effective to deploy LRN in Lucent switches when 12 percent of the customers served by such a switch have ported their numbers, and to deploy LRN in Siemens switches when 23 percent of the customers served by such a switch have  X -ported their numbers.ap  yOm-ԍxFirst Report & Order, 11 FCC Rcd at 8381. a In this phase of the proceeding, BellSouth asserts that the crossover  X -point occurs when 68 percent of its customers have ported their numbers.Fq `  yO-ԍxBellSouth Reply at 6.F NYNEX contends that the appropriate transition is a function of its SCP costs, its signalling costs, and its switch costs, and suggests that "this point may occur when 50 percent of numbers have  X-ported."dr  yO1-ԍxNYNEX October 21, 1996 Ex Parte Filing at 11.d In contrast, several interexchange carriers have argued that the crossover point for  Xy-Pacific occurs when 20percent of numbers have ported.s y  yO-  jԍxAT&T October 29, 1996 Ex Parte Filing at 7; MCI Ex Parte Letter at exhibit 2 at 12, from Donna Roberts,  yOr- xto William Caton, FCC, CC Docket No. 95116, filed Oct.25, 1996 (MCI October 25, 1996 Ex Parte Filing)  x(arguing jointly with AT&T before the California PUC that, after adjustments, Pacific's savings at 20 percent porting would be $1 million, rather than the $71 million claimed).  XK-x%38.` ` Discussion. At the outset, it is important to clarify the nature of the asserted "cost savings" associated with QOR. As most carriers recognize, LRN is the more economical way to provide long term number portability once ported numbers for a given switch reach a certain level, although the point at which it becomes more costeffective to use  X-LRN rather than QOR remains in dispute.gth yO'-ԍxSee supra  COST EFFECTIVENESS37 . g From an economic perspective, the question is"t,-(-(ZZ " whether the present discounted value of the cost of initially deploying LRN is less than the  X-present discounted value of the cost of deploying QOR initially and LRN at some later date.pu`  yOb-  MԍxThe present discounted value is a calculation that converts a dollar amount expended (or received) in the  xfuture into its equivalent dollar amount today. A dollar today is worth more than a dollar tomorrow, because a dollar  xtoday can be invested today to earn interest, which yields more than a dollar tomorrow. The present discounted value  x-of a dollar amount expended (or received) by a firm n years in the future is computed as P/(1 + r)**n where P is  yO- x,the dollar amount, and r is the firm's opportunity cost of capital. See, e.g., Thomas E. Copeland & J. Fred Weston,  yOJ- xFinancial Theory and Corporate Policy 26 (1980); Kenneth E. Train, Optimal Regulation: The Economic Theory of  yO- xNatural Monopoly 171 (1991). In the past, the Commission has used the "present discounted value" as an analytical  yO- xtool for ascertaining economic viability in reviewing Section 214 applications. See, e.g., Applications of New  xEngland Telephone and Telegraph for Authority Pursuant to Section 214 of the Communications Act of 1934, as  xamended, and Section 63.01 of the Commission's Rules, to Construct, Operate, and Maintain Facilities to Provide  yO2 - xVideo DialTone Service to Communities in Rhode Island and Massachusetts, Order and Authorization, File Nos. WPC6982, 6983, 10 FCC Rcd 5346, 5377 n.165 (1995).p Proponents of QOR contend that the use of the QOR enhancement to LRN would result in real cost savings, not just a shortterm deferral of expenses, because the number of ported calls in some areas will never reach the level where it is more cost effective to disable QOR  X-and complete the buildout necessary to support LRN.tv  yO.-ԍxSee, e.g., NYNEX October 21, 1996 Ex Parte Filing at 8.t We conclude, however, that the statutory scheme that Congress has put in place should, over time, result in vigorous facilitiesbased competition in most areas, and therefore LRN will be the most economical longterm  XH-solution.wXH  yOy-  ԍxWe have already accounted for the possibility that vigorous facilitiesbased competition might not occur in  xevery end office, by not requiring incumbent LECs to deploy longterm number portability in those switches unless  yO -requested to do so by a competitor. See Section III.B.2.  Thus, deploying QOR would most likely result in shortterm cost savings, not overall cost savings. In fact, at least one incumbent LEC, Ameritech, has already decided that it is beneficial to deploy LRN from the outset, rather than converting from QOR to LRN at  X -some later date.<x  yOT-  yԍxSee, e.g., Further Comments of Ameritech (filed March 29, 1996) at 10 (arguing that the Commission should  yO- xKprescribe the LRN architecture as the template for long term number portability); see also Ex Parte Letter from  xiAmeritech, AT&T, Central Telephone Co. of Illinois, MCI, MFS, Teleport, Time Warner, and Sprint ("the ICC  xworkshop"), to Regina Keeney, FCC, CC Docket 95116, filed May 8, 1996 (stating that support for LRN has by  xno means been confined to Illinois, or to Ameritech among the RBOCs, and that similar industry groups across the country have conducted extensive reviews of available alternatives and likewise voted LRN as the best solution).< Even if facilitiesbased competition does not develop in the immediate future, however, we conclude that the harm that QOR imposes on competitors (as discussed in Section III.A.1 above) outweighs the benefit of allowing incumbent LECs to defer the cost of implementing a superior longterm number portability solution. " x,-(-(ZZ "Ԍ X-x&39.` ` Moreover, we are not convinced that the incumbent LEC's estimates of the  X-shortterm savings associated with QOR are reliable.y`  yOb-  ԍx In reaching this conclusion, we have considered carefully all of the cost information that the carriers  xsubmitted, even though a number of the petitioners did not submit such data in a timely fashion. Section 1.429(b)  xof our rules requires parties to set forth facts on which they rely in their petitions for reconsideration. 47 C.F.R.   x;1.429(b). Pacific provided only summary figures in its petition regarding the purported cost savings associated with  xQOR, with underlying data filed on a proprietary basis, while Bell Atlantic provided cost data supporting its claim  xxof savings in its reply comments. Pacific Petition at 89; Bell Atlantic Reply Comments at att. A. A number of  yO- xother LECs submitted cost data in ex parte filings after the pleading cycle closed on the petitions for reconsideration.  yO- xSee SBC Ex Parte Letter at 23, from Michael W. Bennett, to William Caton, FCC, CC Docket No. 95116, filed  yO - xOct. 21, 1996 (SBC October 21, 1996 Ex Parte Filing); NYNEX October 21, 1996 Ex Parte Filing at 3; GTE Ex  yOj - xiParte Letter at 2, from F.G. Maxson, to William Caton, FCC, CC Docket No. 95116, filed Oct. 21, 1996 (GTE  yO2 - x,October 21, 1996 Ex Parte Filing). Nevertheless, we have considered the latefiled information, because we believe  yO -it serves the public interest. See 47 C.F.R.  1.429(b)(3). We are particularly concerned by the fact that the cost savings estimates submitted by incumbent LECs have varied significantly over the course of this proceeding. In some cases, estimates from the same carrier have changed by 100 percent or more. Further, the changed estimates have not moved in the same direction; some carriers' estimates of the cost savings increased drastically and other carriers'  Xv-estimates decreased equally drastically.z@v  yO-  {ԍESTIMATES VARYxCompare Pacific Bell Ex Parte Letter at 7, from Alan F. Ciamporcero, to William F. Caton, FCC, CC  yO- xDocket No. 95116, filed June 6, 1996 (Pacific June 6, 1996 Ex Parte Filing) (estimating $71 million in cost savings  yO- xassociated with QOR over fiveyear period) with Pacific Petition at 89 (estimating $130 million in cost savings over  yOo- xfiveyear period); also compare Bell Atlantic Ex Parte Letter at 3, from Edward D. Young, III, to Hon. Reed E.  yO7- xwHundt, FCC, CC Docket 95116, filed May 10, 1996 (Bell Atlantic May 10, 1996 Ex Parte Filing) (estimating $180  yO- xmillion in cost savings for QOR) with Bell Atlantic Reply at 8 & Att. A (estimating $67.8 million in cost savings  yO- xfor QOR); also compare BellSouth Petition at 23 (estimating $50 million in cost savings for QOR) with BellSouth Reply at 5 (estimating $101.5 million in cost savings for QOR). While we recognize that carriers have worked over time to refine their projections, the wide variation in the estimates submitted by individual carriers at different points in this proceeding raises questions about the reliability of these  X1-estimates.{X1 yO-  ԍxContrary to the claims of AT&T, we do not believe that the variability of cost estimates across carriers in  xand of itself undermines the credibility of those estimates, because the technical requirements of different networks  yOj-could vary significantly. See AT&T October 29, 1996 Ex Parte Filing at 2. Furthermore, the fact that some carriers have not explained the basis for the assumptions underlying their estimates precludes us from conducting an independent evaluation of the reasonableness and reliability of their projected cost savings and, consequently, limits the weight we can reasonably assign to those estimates.  X -x'40.` `  FIGURES In addition, MCI alleges that the cost savings that would be realized by permitting the deployment of QOR are far less than the estimated $54 million to $136.3  X-million in annual savings alleged by individual incumbent LECs.b|XX yOY%-  ԍxThe LECs collectively estimate they would save between $624 and $649 million if permitted to use QOR.  x<MCI has provided figures indicating that the LECs collectively would save only $50 million, but that figure only  yO&- xincludes estimated savings for four out of the seven carriers. As noted infra in note MCI FIGURES125, MCI was unable to estimate"&{,-(-( '"  xJcost savings for three carriers due to insufficient information in the record. For three of the carriers for which MCI  xwas able to provide estimates, however, these estimates ranged from 20% to 23% of the corresponding LEC figure. For the fourth carrier, MCI argued that QOR actually would cost more than LRN.b The following chart"|,-(-(ZZj" shows the difference between estimated savings submitted by the petitioners and estimated savings calculated by MCI: T ddx !ddx T  c  f "{CarrierL" Estimated Savings as  Reported by the R Carrier (Millions)H"cEstimated Savings ^gas Reported by MCI  X5-t(Millions)@} 5ު yO -  ԍMCI FIGURESxMCI November 7, 1996 Ex Parte Filing at 26; MCI Letter at exhibit 2 at 12, from Donna Roberts, to  yO - xWilliam Caton, FCC, CC Docket No. 95116, filed Oct. 25, 1996 (MCI October 25, 1996 Ex Parte Filing). MCI  xstated that it was unable to determine true costsavings based on the information presented by BellSouth, NYNEX, and U S West, because these carriers failed to specify adequately the assumptions underlying their calculations.@c q  f  Bell Atlantich# X-.$68?~X. yO'-  LԍxBell Atlantic Reply at 8 & Att. A. This figure assumes that 10 percent of Bell Atlantic customers port their  xnumbers. Bell Atlantic asserts that it would realize approximately $56 million in savings if 25 percent of numbers were ported.?#$15q q  BellSouth h# X-)D$102 . yO-ԍxBellSouth Reply at 5. This figure assumes that 10 percent of BellSouth's customers port their numbers. #N/Aq q  GTEq h# X -(D$136d . yO-ԍxGTE October 21, 1996 Ex Parte Filing, at 2. dq #$28q q   NYNEX h# X -.$54 . yO-  ԍxNYNEX October 21, 1996 Ex Parte Filing at 3. NYNEX figures represent alleged cost savings over a fouryear (not fiveyear) period. #N/Aq q q  PacificS h# Xj -(D$130qXj h. yO-  ԍxPacific Petition at 89; Pacific Ex Parte Letter, from Alan Ciamporcero, to William Caton, FCC, CC Docket  yOK- xwNo. 95116, filed October 29, 1996 (Pacific October 29, 1996 Ex Parte Filing). The figures assume that 30 percent of Pacific's customers port their numbers. qS #ԩ$12q q   SBCh# X -0$84yX . yO#-  MԍxSBC October 21, 1996 Ex Parte Filing at 23. This figure represents estimated savings over a threeyear  x(not fiveyear) period, assuming that 10 percent of SBC's customers port their numbers. SBC asserts it would save $62.4 million at 20% porting, and $57.4 million at 30 percent porting.y#$19q   S    U S Weste# XL-8$50$75L* yO-  kԍxU S West Petition at 13 n.18 (suggests in conclusory terms that costs savings of QOR appear to be in the  yOX- x1015 percent range, and U S West could save $50 to $75 million, or more if permitted to use QOR). See also US  yO - xWest Ex Parte Presentation at 3, CC Docket No. 95116, filed Aug. 5, 1996 (US West August 5, 1996 Ex Parte  xFiling) (asserts $40$45 million in capital costs and $13$15 million in annual expenses if allowed to utilize QOR  xin its first 10 MSAs on the Commission's deployment schedule; no assumptions regarding the level of porting were provided). e#N/A"L@,-(-(ZZ-"  ݙ  X-x(41.` ` MCI's calculation of the asserted cost savings associated with QOR challenges a key assumption underlying the incumbent LECs' estimates. Specifically, MCI claims that  X-the LECs substantially underestimate the number of transactions (i.e., queries) per second (tps) that an SCP pair can perform and, consequently, their estimate of the number of SCP pairs  X-that must be deployed to provide LRN is overstated.@  yO~ -  ^ԍxIncumbent LECs assert that, when number portability is initially deployed, SCP pairs will perform  xapproximately 400 tps, and in the future will have a capacity of approximately 1000 tps. On the other hand, MCI  xYclaims that technology is available for SCPs to operate immediately at 800 tps, and eventually reach approximately  yO- xj2000 tps. Compare Bell Atlantic Reply at att. A.4 and SBC October 21, 1996 Ex Parte Filing at 4 with MCI  yO- xNovember 7, 1996 Ex Parte Filing at 2. According to MCI, the LEC cost studies may have exaggerated by  yOf- x-40percent to 50percent the number of SCPs needed for LRN. MCI November7, 1996 Ex Parte Filing at 2, 5.  xWe also note that U S West lowered its estimate of how much LRN will cost, in part because it is ordering the next  yO- xgeneration SCPs that operate at a higher rate. See US West Ex Parte Letter, from Robert Jackson, to William  yO-Caton, FCC, CC Docket 95116, filed Jan.17, 1997 (U S West January17, 1997 Ex Parte Filing). AT&T also alleges that the incumbent LECs' savings estimates do not take into account offsetting increases in additional switching  X_-facilities costs that would be required for QOR.z_  yO -  =ԍxAT&T estimates that, if 20% of customers port their numbers to a new service provider, the economic cost  yO- xof unnecessary call set ups under QOR would be close to $1 billion. AT&T October 29, 1996 Ex Parte Filing. Bell  yO- xAtlantic and Pacific both dispute AT&Ts analysis. Bell Atlantic Ex Parte Presentation at 3, CC Docket No. 95116,  yOx- xfiled Nov. 6, 1996 (Bell Atlantic November 6, 1996 Ex Parte Filing); Pacific November 8, 1996 Ex Parte Filing at 2.z MCI and AT&T further contend that the incumbent LECs' estimates of the relative costs of deploying LRN and QOR must be adjusted downward to account for revenues that they will receive to perform database queries at the request of rural and other LECs that do not have the capability to perform such queries  X -themselves.:    yOt-  ԍxBoth AT&T and MCI note that, although not required to do so, they plan on performing their own queries.  xFurthermore, in the event that they do not perform their own queries, they expect to pay a reasonable amount to the  yO - x: carrier providing this service. See AT&T Ex Parte Presentation at 1, CC Docket 95116, filed Nov. 12, 1996 (AT&T  yO -November 12, 1996 Ex Parte Filing); MCI November 6, 1996 Ex Parte Filing at 1.: Although incumbent LECs would obtain such revenues with both the LRN and  X -QOR methodologies,v   yOE#-ԍxSee, e.g., Pacific November 8, 1996 Ex Parte Filing at 6.v the revenue stream is likely to be significantly greater with LRN because the number of database queries is likely to be much greater. Indeed, Pacific, a proponent of QOR, acknowledges that its estimate of the cost savings associated with QOR"8,-(-(ZZ -" would be reduced by as much as $18 million if such revenues were included in the  X-estimate.}  yOy-ԍxSee Bell Atlantic/Pacific January10, 1997 Ex Parte Filing at 6.} In view of the significant changes in the estimates of the cost savings associated with QOR submitted by individual incumbent LECs over the past months, a lack of data explaining many of the assumptions underlying their estimates, and the questions raised by MCI and AT&T with respect to specific aspects of the estimates, we find, on balance, that the incumbent LECs have not substantiated their claim that deployment of QOR will produce significant cost savings.  XH-x)42.` ` Moreover, a recent submission by Illuminet, a provider of SS7, database, and other services to independent LECs and other entities, casts doubt on the reasonableness of one of the most basic assumptions underlying the incumbent LECs' estimates of the relative  X -costs of QOR and LRN. o  yO# -  jԍxIlluminet Ex Parte Presentation at 4, 911, CC Docket No. 95116, filed Feb.6, 1997 (Illuminet February6,  yO -1997 Ex Parte Filing). Incumbent LEC estimates assume that the LEC number portability  X -architecture will be deployed through a network of SCPs,$    yOd-  ԍxUsing an SCPbased architecture, call routing information from the regional number portability database is  xtransferred to a carrier's SCP. A number portability query is launched from a switch and is routed through an STP  yO- xito the SCP. The SCP processes the number portability query (i.e., associates the dialed number with the location routing number) and sends the location routing number back, through the STP, to the switch. $ and that a major cost driver of  X -LRN is the number of SCPs needed to handle increased traffic volumes.X   yO5-  ԍxSee, e.g., Pacific Telesis Ex Parte Filing at 2, from Nancy C. Woolf to William Caton, FCC, CC Docket  yO- xZ95116, filed Feb. 3, 1997 (Pacific February 3, 1997 Ex Parte Filing) (stating that one of the big drivers of LRN  yO-costs is the number of ISCPs needed to handle the volumes).Ĝ On the other hand, Illuminet advocates using an STPbased architecture, in which call routing information from the regional database is transferred to a carrier's STP instead of an SCP, and the SCP is  X-not involved in processing the number portability query.  yO-   ԍxThe query is launched from a switch to the STP, and the STP processes the query and sends the location  yO-routing number back to the switch. Illuminet February6, 1997 Ex Parte Filing at 4, 911. Illuminet asserts that STPs are designed specifically to do tendigit translations such as LRN query processing and can process number portability queries at a much faster rate than SCPs. In contrast, SCPs are designed to support multiple call processing applications and process significantly fewer  X4-queries per second.X4'  yO !-  ԍxIlluminet claims that STPs can process 1000 to 10,000 number portability queries per second, while  yO!-currently most SCPs typically process only 400 to 1000 queries per second. Id. at 910.  Carriers using an STPbased architecture, therefore, would need to purchase and install a relatively smaller number of STPs instead of the larger number of SCPs alleged by the LECs, and would not need to purchase and install additional SS7 links between"G,-(-(ZZ -"  X-the SCPs and STPs.@  yOy-  Mԍx Id. at 910. Illuminet claims, for instance, that servicing 20,000 tps would require eleven highcapacity  yOA- xSCPs that are capable of operating at 2000 tps, but only one STP pair. Id. at 10. Illuminet further claims that, even  xYwhen using an SCP that can service 1000 tps, the SCP functionality would cost 54% more with the LECs' SCPbased  yO- xapproach than with Illuminet's STPbased approach. Id. at 9.@ Thus, according to Illuminet, use of an STPbased architecture would  X-reduce dramatically the cost of LRN.;x  yO-ԍxId. ; In response, Pacific acknowledges that a combined STPSCP approach may reduce some costs, but that expenses related to upgrading switch  X-processors, links, and existing STPs will still be substantial.  yOt -  ԍxPacific Telesis Ex Parte Letter at 1, from Nancy Woolf, to Regina Keeney, FCC, CC Docket 95116, filed  yO< -Feb. 13, 1997 (Pacific February 13, 1997 Ex Parte Filing).  Although we acknowledge that carriers deploying LRN will incur costs other than those associated with SCPs, we agree with Illuminet that an STPbased approach should reduce the relative cost differential between LRN and QOR.  XH-x*43.` ` In addition, as we discuss more fully in Section III.B.2 below, we are modifying our implementation schedule to require LECs to deploy number portability only in those switches requested by a competitive LEC within a given MSA on the implementation schedule, rather than in every switch in that MSA. As a result, fewer switches should require upgrading in each phase of the deployment schedule, with a corresponding reduction in the cost of implementation for all carriers. Moreover, if number portability capabilities are not deployed in all switches, then there will be fewer switches generating database queries, and thus fewer SCPs and signalling links will be needed than the LECs have estimated. Sprint, for instance, has estimated that it would save approximately 25 percent of its number portability budget of $60 million for 1997 if it were not required to deploy number portability  Xb-in the smaller exchanges within the MSAs on its deployment schedule.E b`  yOs-  LԍxSprint Ex Parte Presentation at 8, CC Docket No. 95116, filed Dec. 4, 1996 (Sprint December 4, 1996, Ex  yO;- xParte Filing); see also U S West Ex Parte Letter at att. at 5, from Robert Jackson, to William Caton, FCC, CC  yO- xDocket No. 95116, filed Dec. 4, 1996 (U S West December 4, 1996 Ex Parte Filing) (suggests costs of implementing number portability would be lower if rural offices were not included in the deployment schedule).E While it is impossible at this time to quantify the precise magnitude of this effect nationwide because we do not know in how many switches competitive LECs will request number portability, this modification to our number portability requirements should lessen somewhat whatever actual cost differences may exist between LRN and QOR.  X-x` ` c. Impact of QOR on the Implementation Schedule   X-x+44.` ` Pleadings. Bell Atlantic and Pacific claim that allowing the use of QOR would make it easier for carriers to meet the Commission's implementation schedule, because they would not need to deploy as many databases and as extensive a signalling infrastructure as"|H ,-(-(ZZ-"  X-would be needed under LRN.  yOy-  ԍxBell Atlantic Petition at 10 n.14; NYNEX Petition at 6; Pacific Petition at 910. See also Cincinnati Bell Comments at 2. MCI disputes the claim that QOR would help carriers meet the implementation schedule. MCI argues that QOR has never been fully examined and  X-specified by the industry in any state task force.I   yO-ԍxMCI Opposition at 1516.I MCI further argues that the proponents of QOR have not established that it would be technically infeasible to deploy LRN fully under  X-the existing implementation schedule.A  yO -ԍxId. at 14.A AT&T claims that, even after QOR software  X-becomes available,i@@  yO~ -  {ԍxSiemens and Nortel have committed to making QOR software available in early to mid1997, whereas  xLucent which is the manufacturer of over half of the switches nationwide has committed to making QOR  yO- xsoftware available for its 5ESS and 1A ESS switches by December 1997, and its 4ESS switches by April 1998. See  yO- xNortel Ex Parte Letter, from Raymond Strassburger, to William Caton, FCC, CC Docket No. 95116, filed Jan. 27,  yO- x1997 (Nortel January 27, 1997 Ex Parte Filing); Siemens StrombergCarlson Ex Parte Letter at 1, from Terry  yOf- x;Jennings, to William F. Caton, FCC, CC Docket No. 95116, filed May20, 1996 (Siemens May20, 1996 Ex Parte  yO.- xFiling); Lucent Technologies Ex Parte Letter at 1, from Mary McManus, to Carol Mattey, FCC, CC Docket No. 95 yO-116, filed Dec. 19, 1996 (Lucent December19, 1996 Ex Parte Filing).i additional time would be necessary to complete the installation, testing,  Xv-and training necessary actually to implement QOR.vH  yOo-  ԍxAT&T Ex Parte Letter at 23, from R. Gerard Salemme, to Regina Keeney, FCC, CC Docket No. 95116,  yO7-filed Dec.23, 1996 (AT&T December23, 1996 Ex Parte Filing).  XH-x,45.` ` Discussion. We are not persuaded by Bell Atlantic and Pacific that number  X1-portability would be deployed more rapidly if incumbent LECs are permitted to use QOR.1  yO-  ԍxBell Atlantic Petition at 10 n.14; NYNEX Petition at 6; Pacific Petition at 910. See also Cincinnati Bell Comments at 2.  X -We find speculative petitioners' arguments that problems will arise in LRN implementation, and that the Commission therefore should allow the use of QOR. We agree with AT&T that no party has demonstrated that schedules for completing installation, testing, training, and other tasks necessary to implement QOR could be developed and coordinated with the  X -schedules for completing tasks necessary to implement LRN.k   yOg -ԍxAT&T December23, 1996 Ex Parte Filing at 23.k Furthermore, no party has alleged that a field trial of QOR could be performed earlier than or even contemporaneously with the Chicago trial for LRN. To the contrary, as discussed in the next subsection, we have reason to believe that allowing the use of QOR would delay the Chicago trial and the implementation schedule.  XK-"K,-(-(ZZ-"Ԍ X-x` ` d. Impact on the States  X-  X-x-46.` ` As discussed in SectionII.C above, seven state commissions have specifically ordered implementation of LRN. These and a number of other states have invested considerable time, effort, and resources in developing LRN implementation plans and  X-technical standards.   yO-  ԍxSee, e.g., First Report & Order, 11 FCC Rcd at 836263; CA PUC Local Exchange Service Decision at 14;  xJIL LNP Steering Committee December16, 1996 Minutes; MD LNP Consortium October1996 Report at 1418; IN  xLNP Task Force October7, 1996 Minutes; Michigan LNP Workshop November21, 1996 Minutes; Sprint  yO^ -December19, 1996 Ex Parte Filing at 25. Illinois is proceeding with the field trial of LRN in the Chicago  Xv-MSA.ov  yO -ԍxSee IL LNP Steering Committee December16, 1996 Minutes.o Illinois, Georgia, California, Maryland, Colorado, New York, and Texas have undertaken significant efforts to form LLCs to develop and issue RFPs to construct and maintain a number portability database, to plan for expanding these state databases into regional databases, and to prepare in each state for database testing, in order to be ready to  X -support number portability deployment in accordance with the schedule set forth in the First  X -Report & Order. @  yO-  >ԍxSee LNPA Selection Working Group February 26, 1997 Status Report at 1; NANC January8, 1997 State  yO-NPAC/SMS Status at 15. These states have been in the forefront of opening markets to local competition, and we applaud and support their ongoing commitment to take actions necessary to make local number portability a reality in their jurisdictions. If we were to reverse our earlier finding that QOR is not acceptable as a longterm number portability method, these  X -state activities could be greatly disrupted. Much of the testing and development of technical standards already done for implementation of LRN would have to be redone in order to accommodate a scenario in which both QOR and LRN may be in use in a given state. Moreover, the states that have been leaders in number portability implementation would likely be forced to reopen their state number portability proceedings to reconsider QOR, which  X4-could delay implementation for months while those proceedings are pending.gX4  yO}-  ԍxFor example, the California Public Utilities Commission's order mandating LRN specifically provides that,  yOE- xhif the Commission modifies its findings on QOR, then the California PUC must reconsider its decision. See CA PUC Local Exchange Service Decision at n.14.g  X-x ` ` e. Conclusion   X-x.47.` ` Congress recognized that there are costs associated with the implementation of  X-local number portability.  yO*$-  >ԍxIndeed, Congress created a specific provision in the 1996Act addressing the costs of establishing number  yO$-administration and number portability. See 47 U.S.C.  251(e)(2). Although carriers may realize some shortterm cost savings if permitted to use QOR instead of LRN, the exact amount of savings from utilizing QOR is unclear. Even if the cost savings figures submitted by the LECs were correct, we believe that",-(-(ZZQ-" the benefits to consumers of such savings do not outweigh the harm that QOR would impose on competitive LECs, the cost of disrupting state efforts to implement LRN, or any delay in implementation that might result from such disruption. Thus, we conclude that permitting carriers to deploy QOR as a longterm number portability method does not serve the public interest. /J:\POLICY\NUM_PORT\RECON1\ORDER\QOR.ORD/ x  X_- /J:\POLICY\NUM_PORT\RECON1\ORDER\SCH.ORD/ XxB.X` ` Implementation Schedule for Wireline Carriers (#`  X1-x ` ` 1. Background (#`  X -x/48.` ` In the First Report & Order, the Commission required local exchange carriers operating in the 100 largest MSAs to offer longterm service provider portability, according to a phased deployment schedule commencing on October 1, 1997, and concluding on December  X -31, 1998.  yO7-  kԍxThe Commission required deployment in one specified MSA in each of the seven BOC regions by the end  xof fourth quarter 1997 ("PhaseI"), 16 additional specified MSAs by the end of first quarter 1998 ("PhaseII"), 22  xadditional specified MSAs by the end of second quarter 1998 ("PhaseIII"), 25 additional specified MSAs by the end  xhof third quarter 1998 ("PhaseIV"), and 30 additional specified MSAs by the end of fourth quarter 1998 ("PhaseV").  yOW-First Report & Order, 11 FCC Rcd at 8393, app. F. The Commission noted that, in establishing the deployment schedule, it relied upon representations of switch vendors regarding the dates by which the necessary switching  X-software will be generally available for deployment.Cx  yO-ԍxId. at 8393.C In particular, vendors estimated that they could begin to make software for at least one longterm number portability method  Xb-generally available for deployment by carriers around mid1997.:b  yO-ԍxId.: In addition, a carrier may file a specific request for number portability beginning January 1, 1999, for areas outside the 100 largest MSAs, and each LEC must make longterm number portability available in that  X-MSA within six months after the specific request.C  yOf-ԍxId. at 8394.C The Commission also directed the carriers that are members of the Illinois Commerce Commission Local Number Portability Workshop (ICC Workshop) to conduct in the Chicago MSA, concluding no later than August 31, 1997, a field test of LRN or another technically feasible longterm number portability  X-method that comports with our performance criteria.F(  yO"-ԍxId. at 839394.F The Commission noted that Section 251(f)(2) of the Act permits a LEC with fewer than two percent of the country's total installed subscriber lines to petition a state commission for suspension or modification of the  X|-interconnection requirements of Sections 251(b) and (c).C|  yO&-ԍxId. at 8396.C"|H ,-(-(ZZ-"Ԍ X-ԙx049. ` ` The Commission delegated to the Chief, Common Carrier Bureau, the authority  X-to monitor the progress of LECs implementing number portability, and to direct carriers to  X-take any actions necessary to ensure compliance with its deployment schedule.C  yOK-ԍxId. at 8393.C The Commission also delegated to the Chief, Common Carrier Bureau, the authority to waive or stay any of the dates in the implementation schedule, for a period not to exceed nine months  X-(i.e., no later than September 30, 1999, for the MSAs in PhaseV of the deployment  Xv-schedule), as is necessary to ensure the efficient development of number portability.CvX  yO -ԍxId. at 8397.C In the  X_-event a carrier is unable to meet our deadlines for implementing a longterm number portability method, it may file with the Commission, at least 60 days in advance of the implementation deadline, a petition to extend the time by which implementation of longterm  X -number portability in its network will be completed.:   yO-ԍxId.: The Commission emphasized, however, that carriers are expected to meet the prescribed deadlines, and a carrier seeking  X -relief must present extraordinary circumstances beyond its control in order to obtain an  X -extension of time.: x  yO-ԍxId.: The Commission required a carrier seeking such relief to demonstrate through substantial, credible evidence the basis for its contention that it is unable to comply  X -with our deployment schedule.   yO`-  ԍxId. Requests for extensions of time must set forth: (1) the facts that demonstrate why the carrier is unable  xwto meet our deployment schedule; (2) a detailed explanation of the activities that the carrier has undertaken to meet  xthe implementation schedule prior to requesting an extension of time; (3) an identification of the particular switches  yO- xfor which the extension is requested; (4) the time within which the carrier will complete deployment (e.g., software  xLand hardware upgrades) in the affected switches; and (5) a proposed schedule with milestones for meeting the  yOH-deployment date. Id.  Xy-XxX` ` 2.X Deployment Only in Requested Switches (#  XK-x150.` ` Pleadings. Ameritech urges the Commission to limit initial deployment of  X4-number portability in an MSA to exchanges where bona fide demand exists.t4  yOe -ԍxAmeritech Reply at 1; see also Bell Atlantic Reply at 9 n.26.t Ameritech argues that excluding exchanges in rural and less densely populated suburban areas of an  X-MSA, where competition is not likely to develop immediately, will significantly reduce costs and the demand on carriers' limited technical personnel and resources, and simplify  X-deployment and testing.F  yO%-ԍxAmeritech Reply at 2.F " ,-(-(ZZ-"Ԍ X-x251.AMERITECH I ` ` Ameritech suggests delegating to state commissions the task of supervising the selection of exchanges where demand exists, and cites as a model the procedure used by the  X-ICC Workshop in the Chicago MSA, prior to the release of the First Report & Order, under which each competing LEC submitted to the ICC staff a list of the exchanges in which the  X-LEC sought number portability as a part of the initial deployment.KX  yO-  ԍxId. at 3, 5. Ameritech states that the ICC's plan has been presented to the state number portability  xworkshops in Michigan, Indiana, and Ohio, which have generally based their deployment plans on that of the ICC.  yO-Id.K The sole criterion for designation of an exchange was that the carrier anticipated needing immediately the capability  Xv-to port numbers from that exchange.@v  yO -ԍxId. at 3.@ The ICC staff then aggregated the lists and released  X_-one consolidated list to serve as the master deployment plan for the Chicago MSA.;_x  yO -ԍxId. ; According to Ameritech, this procedure excluded from deployment 103 out of 206 exchanges in the Chicago MSA, which serve primarily rural and less densely populated suburban areas and include many areas served by small independent telephone companies and by switches  X -with older technology.B   yO-ԍxId. at 23.B  X -x352.AMERITECH II ` ` According to Ameritech, the incumbent LECs then categorized the unrequested exchanges according to the type of switch serving that exchange, and planned to convert each  X -exchange upon a bona fide request according to the following time frames: (1) remote  X-switches supported by a host switch equipped for portability ("Equipped Remote Switches") within 30 days; (2) switches that require software but not hardware changes to provide portability ("Hardware Capable Switches") within 60 days; (3) switches that require hardware changes to provide portability ("Capable Switches Requiring Hardware") within 180 days; and (4) switches not capable of portability that must be replaced ("NonCapable Switches") (no  X-agreement was reached on a time frame).B  yOf-ԍxId. at 34.B Ameritech explains that, because unconverted offices would be identified prior to the initial deployment in the MSA, new LECs could request additional offices at any time, and thus notify the incumbent LECs to begin planning  X-for conversion of those offices as soon as possible after the initial deployment in the MSA.B(  yO!-ԍxId. at 45.B Therefore, claims Ameritech, additional conversion could, in most cases, occur within 3060  X-days after the initial deployment in the MSA.@  yO%-ԍxId. at 5.@ "!H ,-(-(ZZ-"Ԍ X-x453.` ` BellSouth also seeks clarification that portability need not be deployed in every  X-switch within an MSA.N  yOb-ԍxBellSouth Petition at 11, 14.N BellSouth reports that industry participants in the Georgia number portability workshop conducted an exercise similar to that of the ICC Workshop prior to  X-release of the First Report & Order, in which the competing carriers selected 21 offices in the  X-Atlanta MSA for initial implementation in late 1997.X  yO-  ԍxId. at 14; BellSouth Ex Parte Presentation at 4, CC Docket No. 95116, filed Nov.1, 1996 (BellSouth  yOu-November1, 1996 Ex Parte Filing). Number portability task forces in Indiana, Michigan, and Ohio, following the work of the ICC Workshop, have also established procedures under which each competing LEC must submit a list of the exchanges in which it  X_-desires number portability as a part of the initial deployment.MX_  yO -  ԍxSee, e.g., IN LNP Task Force October7, 1996 Minutes; Michigan LNP Workshop November21, 1996  yO - xMinutes; Sprint December19, 1996 Ex Parte Filing at 45 (minutes of Nov.13, 1996 meeting of Ohio Local Number Portability Workshop).M In Maryland, each carrier  XH-submitted to the Maryland commission staff a ranking of the fifty end offices in the Baltimore and Washington, DC LATAs for which it most desired portability, and the five end offices in  X -the Salisbury and Hagerstown LATAs for which it most desired portability.e   yO-ԍxMD LNP Consortium October1996 Report at 15, app. 6.e The Maryland commission staff then prepared a consolidated ranking that became the implementation roll X -out schedule for Maryland.: `  yO-ԍxId.: There were 25 end offices in the Baltimore and Washington,  X -DC LATAs (out of 92 total end offices), and seven end offices in the Salisbury and Hagerstown LATAs (out of 13 total end offices), that no carrier included in its list of end  X -offices for which it requested number portability.E  yOH-ԍxId. at app. 6.E  Xy-x554.` ` USTA proposes that competing carriers be required to specify, in a request to a  Xb-LEC, those switches for which they wish the ability to port numbers.Hb  yO-ԍxUSTA Petition at 1516.H USTA argues further that, if a carrier does not receive a request for portability in an end office by April1, 1997, then the carrier should be able to obtain from the Commission a waiver of the deployment  X-schedule until the LEC receives a request.  yO"-  >ԍxId. at 16. See also Pacific Comments at 4. USTA asserts that its proposed waiver procedure would allow  xdeployment in response to market forces and varying levels of competition; foster efficient network planning,  xresource allocation, and increased cooperation among LECs; reduce costs and demands on vendors; and reduce  ximplementation burdens, especially for small and rural LECs. USTA Petition at 1418. USTA argues that such a  x<waiver will not undermine the procompetitive nature of the Act, as competition has already begun in the larger  yO&- xmarkets. Id. at 15. In addition, USTA warns that failure to modify the deployment schedule will create an undue"&,-(-('"  xadministrative burden because every rural provider will likely file for an individual waiver. USTA Comments at 2. Upon receiving such a request, the LEC would"" ,-(-(ZZG-" have nine months, or a period of time specified by the Chief of the Common Carrier Bureau,  X-to deploy portability.E   yO-ԍxUSTA Petition at 16.E USTA also proposes that state commissions and/or state number portability workshops be empowered generally to alter the timing of deployment for particular  X-switches within their state boundaries.C  yO -ԍxUSTA Comments 56.C USTA and several other rural LEC representatives argue that, without a procedure to limit deployment to switches for which a competitor has expressed interest, many rural and small LECs will have to upgrade their networks at significant expense even though no competitors plan to enter their markets and use number  X_-portability._@  yOP-  ԍxUSTA Petition at 1718; JSI Petition at 9; NECA Petition at 3; NTCA/OPASTCO Petition at 34; NTCA/OPASTCO Reply at 14.  X1-x655. ` ` GTE urges us to establish a "limited waiver" process for exempting smaller offices in the 100 largest MSAs from the deployment deadlines where competitive entry in that area will not be immediate, and implementation would require significant network  X -upgrades.    yO5-  ԍxGTE Petition at 9; GTE Opposition at 1415. See also GTE Ex Parte Presentation at 36, CC Docket No.  yO-95116, filed Feb.19, 1997 (GTE February19, 1997 Ex Parte Filing).  A LEC wishing to take advantage of GTE's proposed procedure would first determine whether any prospective entrant "expresses an immediate interest in entry" in the relevant area, and whether those prospective entrants, or the state commission, have any objection to waiving the schedule for that area. If the prospective entrants and state commission do not object, then the LEC would present the Commission with a petition for  Xy-waiver "with the expectation that it will be granted."HXy  yO-  ԍxGTE Petition at 9; GTE Opposition at 15; GTE Reply at 6. GTE claims that competition would not be  xLimpeded because LECs would commit to coordinating with prospective entrants before filing for waiver for a particular office. GTE Opposition at 15.H Afterward, the LEC would not have to implement portability until six months after a request from a competing carrier, assuming  XK-the switch already has SS7 and AIN capabilities.K  yO !-  LԍxGTE Petition at 9; GTE Opposition at 15. But see MCI Reply at 56 & n.12 (arguing that carriers will have already incurred most costs of upgrades, and thus do not need six months to deploy portability software). According to GTE, its proposal would enable LECs to devote their resources to upgrading offices in the more densely populated and competitive areas, and would recognize that portability requires expensive upgrades in many  X-smaller offices.Vh  yO&-ԍxGTE Opposition at 15; GTE Reply at 6.V "#,-(-(ZZ -"Ԍ X-x756. ` ` NEXTLINK presents a "swapping" proposal, under which an incumbent LEC seeking a waiver for a switch within the 100 largest MSAs instead would deploy switches  X-outside the 100 largest MSAs which a competitor requests.e  yOK-ԍxNEXTLINK Petition at 78 n.4; NEXTLINK Reply at 23.e NEXTLINK cautions, however, that we should rely on state commissions to determine the extent of competition in markets in their states, but not, as suggested by USTA, to determine whether waivers should be  X-granted.X  yO-  LԍxNEXTLINK Reply at 3. NEXTLINK maintains that uniform nationwide standards are necessary to prevent  yO^ -incumbents from persuading states to adopt inconsistent standards for market entry. Id.  X_-x857. ` ` AT&T does not oppose proposals to limit deployment of number portability to  XH-those switches for which a carrier requests deployment.qXH  yO -  ԍxIn fact, AT&T suggested earlier in this proceeding that initial deployment in an MSA need only consist of  xx20 to 25 switches (20 for the incumbent LEC and at least one for each alternative carrier) in each MSA. AT&T Further Comments at 8 & n.14, CC Docket No. 95116, filed Mar.29, 1996.q Sprint supports Ameritech's  X1-proposal, which does not entail LECs requesting waivers for unrequested offices.1  yO-  ԍxSprint Ex Parte Presentation, CC Docket No. 95116, filed Dec.4, 1996 (Sprint December4, 1996 Ex Parte Filing). Sprint predicts that as many as 127 out of a total of 360 of its central offices will not face immediate facilitiesbased competition and will be relieved from initial deployment under a procedure whereby carriers identify the switches for which they desire portability, at an estimated savings of over $15 million in 1997 alone (approximately 25percent of Sprint's  X -total number portability budget).C (  yO-ԍxId. at 7, 9.C Sprint emphasizes that we should determine a specific  X -time frame within which the carrier must deploy portability once a bona fide request for  X-portability is received, absent some other extenuating (and fully documented) circumstances.JX  yO-  /ԍxSprint Opposition at 13. Time Warner argues similarly that any waivers should consist only of setting a  yO- xwspecific extension or subjecting the particular office to the bona fide request requirements. Time Warner Comments at 8 n.14.J Sprint asserts that the state public utilities commissions in Florida, Ohio, Indiana, and Illinois,  Xb-have established procedures by which carriers request deployment in specific exchanges.eb  yO -ԍxSprint December19, 1996 Ex Parte Filing at 2.e Time Warner supports allowing carriers to apply for waivers of the deployment schedule for the 100 largest MSAs for end offices serving areas that competitors do not plan to enter  X-initially.%Xh  yO6%-  ԍxTime Warner Comments at 7. Time Warner further asserts that it may be appropriate to authorize states  xto oversee industry meetings to determine which end offices within a particular MSA will face competition, so that  xYa state could then support the waiver petitions of any carriers that it has determined will not face competitive entry"&,-(-(&"  yO-at the time of the deployment deadlines. Id.%"$X,-(-(ZZG-"Ԍ X-ԙx958.` ` MCI, in contrast, opposes relaxing the mandate of MSAwide deployment. According to MCI, forcing competitive LECs to defend the need for MSAwide portability and to justify deployment in each end office would create an environment of uncertainty for  X-competitive LECs.@X  yO-ԍxMCI Reply at 5.@ MCI claims that, if competitive LECs must request deployment each time a new customer requesting service is located in an end office that was not deployed according to the original deployment schedule, any incentive and ability to market their  Xv-services widely will be impaired.@v  yO -ԍxId. at 6.@ According to MCI, once portability is introduced in an area, the incremental cost and resources needed to add additional end offices are relatively  XH-minor because most costs, i.e., SCP hardware and signalling links, OSS modifications, and  X1-shared regional database costs, will have already been incurred.B1x  yOZ-ԍxId. at 56.B  X -x:59.WHY ONLY ON REQUEST` ` Discussion. We agree with the majority of the parties commenting on this issue that it is reasonable to focus initial efforts in implementing number portability in areas where competing carriers plan to enter. This approach will permit LECs to target their resources where number portability is needed and avoid expenditures in areas within an MSA  X -in which competitors are not currently interested.   yO`-  kԍxSee, e.g., BellSouth Petition at 14; USTA Petition at 1618; Ameritech Reply at 15; GTE Opposition at 15; JSI Petition at 9; NTCA/OPASTCO Petition at 34. We further agree that such a procedure will foster efficient deployment, network planning, and testing, reduce costs, and lessen  Xy-demands on software vendors.ey`  yO-ԍxSee USTA Petition at 17; Ameritech Reply at 2.e Moreover, we believe that limiting deployment to switches in which a competitor expresses interest in number portability will address the concerns of  XK-smaller and rural LECs with end offices within the 100 largest MSAs that they may have to  X4-upgrade their networks at significant expense even if no competitors desire portability.4  yO-  ԍxSee USTA Petition at 1718; JSI Petition at 9; NECA Petition at 3; NTCA/OPASTCO Petition at 34;  yO- xNTCA/OPASTCO Reply at 14. See also Ameritech Reply at 2; GTE Opposition at 1415; Time Warner Comments  xat 7. In addition, limiting deployment to switches in which a competitor expresses interest in number portability is  xlikely to lessen the burden on many rural or smaller LECs that are otherwise likely to file a waiver, and the burden  yO!-on the Commission to review those petitions. See USTA Comments at 3. Limiting deployment to switches in which a competitor expresses interest in deployment will be consistent to a large extent with procedures suggested by Ameritech and BellSouth and"%,-(-(ZZ -"  X-already considered by several state commissions,  yOy-  kԍxSee Ameritech Reply at 15 (Illinois); BellSouth November1, 1996 Ex Parte Filing at 4 (Georgia); Sprint  yOA-December19, 1996 Ex Parte Filing (Florida, Illinois, Indiana, Ohio). as well as our past practice in  X-implementing conversion to equal access for independent telephone companies.   yO-  LԍxA procedure under which independent telephone companies (ITCs) must convert specific end offices in their  x-networks to equal access has been in place for a decade. Under that procedure, "[e]nd offices equipped with SPC  x[stored program controlled] switches must be converted to offer exchange access services that are equal in type and  xquality to that offered to AT&T, within three years of the receipt of a reasonable request for equal access services  yO- xfrom any OCC [other common carrier]." MTS and WATS Market Structure Phase III, Report and Order, 100 FCC 2d 860, 875 (1985).  X-x;60.DEPLOY UPON REQUEST` ` We therefore conclude that LECs need only provide number portability within the 100 largest MSAs in switches for which another carrier has made a specific request for  X-the provision of portability.tX  yO-  ԍxSee Ameritech Reply at 12; BellSouth Petition at 11, 1415; USTA Petition at 1618. In contrast, for  xJswitches in which portability has been requested, a LEC must still file a petition for waiver of a deployment deadline if the LEC claims it is unable to meet our deployment schedule.t We leave it to the industry and to state commissions to determine the most efficient procedure for identifying those switches in which carriers have expressed interest and which will be deployed with number portability according to the original deployment schedule for the 100 largest MSAs. We find, however, that any procedure to identify and request switches for deployment of number portability must comply with certain minimum criteria to ensure that minimal burden is imposed upon carriers requesting deployment in particular switches, and that carriers that receive requests for deployment in their switches have adequate time to fulfill the requests. As explained below, we require that: (1) any wireline carrier that is certified, or has applied for certification, to provide local exchange service in the relevant state, or any licensed CMRS provider, must be allowed to make a request for deployment; (2) requests for deployment must be submitted at least nine months before the deadline in the Commission's deployment schedule for that MSA; (3) carriers must make available lists of their switches for which deployment has and has not been requested; and (4) additional switches must be deployed upon request within the time frames described below.  X-x<61.` ` First, any wireline carrier that is certified (or has applied for certification) to  X-provide local exchange service in a state, or any licensed CMRS provider, must be given a reasonable opportunity to make a specific request for deployment of number portability in any  X-particular switch located in the MSAs in that state designated in the First Report & Order. According to the Act, any carrier that desires number portability from a LEC must be able to  X-obtain portability, in accordance with the requirements established by the Commission.J  yO%-ԍx47 U.S.C.  251(b)(2).J A  X-state commission, however, may review whether the requests made by a carrier are unreasonable, given the state commission's knowledge of that carrier's plans to enter the state. "|&H ,-(-(ZZ-" Based on the limited information available to us at this time, the states that are reviewing seemingly unreasonable requests appear to be acting in good faith to accommodate carriers'  X-interests in number portability capabilities.  yOK-  ԍxSee, e.g., Sprint December19, 1996 Ex Parte Filing at 45 (minutes of Ohio Local Number Portability Workshop). If we receive evidence in the future that states are unreasonably limiting deployment, then we can revisit this issue at that time.  X-x=62.` ` Second, a carrier must make its specific requests for deployment of number portability in particular switches at least nine months before the deadline for completion of  X_-implementation of number portability in that MSA.V_   yO0 -ԍxSee, e.g., USTA Petition at 16.V We conclude that this deadline will enable a LEC to plan ahead for the deployment of number portability in multiple switches in a given MSA. We encourage carriers to make such requests earlier than the ninemonth deadline to give the LEC that operates the switch in which portability is requested more time to implement number portability capabilities. In addition, carriers may agree among themselves, or state commissions may require carriers, to comply with a deadline for submitting requests that is more than nine months prior to the implementation deadline.  X -x>63.` ` We encourage carriers, before requests for deployment are submitted, to seek to reach a consensus on the particular switches that initially will be deployed with number portability. We note, moreover, that the state commission may decide, or carriers affected in  Xb-the state may agree, that it would be preferable for the state commission to aggregate the  XK-requests to produce a master list of requested switches.K  yO-  ԍxSee Ameritech Reply at 3, 5 (suggesting that each new entrant submit a list of switches to the state commission of the exchanges it desires to have converted). In addition, we conclude that carriers may negotiate private agreements specifying that a carrier will not request that certain switches be deployed according to the Commission's schedule if the LEC from which deployment is requested agrees to deploy other number portabilitycapable switches, either  X-inside or outside the 100 largest MSAs, at an earlier date than the deadlines in the  X-Commission's schedule.   yO-  ԍxFor example, NEXTLINK suggests waiving the scheduled deployment deadlines for switches in the 100  xlargest MSAs for which no competitor expresses interest in deployment, and allowing carriers instead to deploy  xJswitches outside the 100 largest MSAs in which a competitor expresses interest, according to the deadlines for those unrequested switches within the 100 largest MSAs. NEXTLINK Petition at 78 n.4; NEXTLINK Reply at 3.  X-x?64.` ` Third, after carriers have submitted their requests, a carrier must make readily available upon request to any interested parties a list of its switches for which number portability has been requested and a list of its switches for which number portability has not been requested. We find that simplifying the task of identifying the switches in each MSA in which number portability is initially scheduled to be deployed is consistent with our policy of"N' ,-(-(ZZ-" facilitating the deployment of number portability in areas where new competitors plan to enter.  X-x@65.ADD SWITCHES 1` ` Fourth, carriers must be able to request at any time that number portability be deployed in additional switches. LECs must provide portability in these additional switches upon request, after the deployment deadline mandated by the Commission's schedule for that MSA, within the time frames that we adopt here, unless requesting carriers specify a later date. Although carriers may make specific requests for deployment in additional switches in a particular MSA at any time, the time frames set forth below will commence after the deadline for deployment in that particular MSA in our implementation schedule. We agree with Sprint and Time Warner that specific time frames within which number portability must be deployed in all switches that were not initially requested are necessary to ensure that competitive LECs can be certain that portability will be available in areas in which they plan to compete and can  X -formulate their business plans accordingly.   yON-  ԍxSee Sprint Opposition at 13 (urging us to determine a specific time frame within which number portability  yO- xmust be deployed in initially unrequested switches, once requested); cf. Time Warner Comments at 8 n.14 (arguing  xthat any exemptions for switches not facing competition should only be for a specific period of time or simply  yO-subject to a bona fide request). Absent this certainty, competing carriers would have an incentive to request more switches during the initial request process, including those serving markets which they do not plan to enter in the near future, in order to ensure deployment of portability in any switch in which they might ever want portability. We find, therefore, that establishing specific time frames for deployment in all additional switches will benefit competitive LECs by ensuring that portability will be available to them at a designated future time, and will benefit incumbent LECs by reducing their initial deployment burdens.  X-xA66.ADD SWITCHES 2` ` We find that the time frames developed by the carriers participating in the ICC Workshop generally successfully balance the needs of competitive LECs for certainty of  X-deployment and the burdens faced by incumbent LECs in deploying number portability in  X-additional switches that require different levels of upgrades.  yO9-  ԍxWe recognize that the ICC has not yet decided whether to adopt the time frames developed by the ICC Workshop. Ameritech Reply at 4. We therefore adopt, with slight modification, the time frames developed by the ICC Workshop for the conversion of additional exchanges: (1) Equipped Remote Switches within 30 days; (2) Hardware Capable Switches within 60 days; (3) Capable Switches Requiring Hardware within 180 days; and (4)  X|-NonCapable Switches within 180 days.|  yO5"-ԍxSee supra  AMERITECH II52 for definitions of terms; see also Ameritech Reply at 34. For example, if carriers request deployment in a certain number of switches in the Pittsburgh, PA MSA nine months before that MSA's  XN-PhaseIII deadline of June30, 1998 (i.e., they make requests by September30, 1998), and a carrier requests on April1, 1998, deployment in an additional Equipped Remote Switch in Pittsburgh, then the additional switch must be equipped with number portability capability on  X -or before July30, 1998 (i.e., 30 days after June30, 1998). We note that the ICC Workshop" (,-(-(ZZ[-" developed the time frames for the first three switch categories, but did not reach agreement on  X-a time frame for converting a NonCapable Switch.@  yOb-ԍxId. at 4.@ Since we find, as discussed above, that specific time frames for deployment of all additional switches are necessary, we find that it is reasonable to allow no more time for deployment of any switches within the 100 largest MSAs than is allowed for deployment of switches outside the 100 largest MSAs. Deployment in additional switches will be less burdensome for carriers with networks within the 100  Xv-largest MSAs that have already made networkwide upgrades, e.g., SCP hardware and OSS modifications, to support number portability in the initially requested switches.  X1-xB67.` ` Carriers seeking relief from these deadlines may file a petition for waiver under  X -the procedures set forth in the First Report & Order.j X  yO# -ԍxSee First Report & Order, 11 FCC Rcd at 8397.j We note that the deadlines for switches in categories (1) and (2) are shorter than switches in categories (3) and (4) because the former require less extensive upgrades. We realize that the shorter deadlines for switches in categories (1) and (2) do not allow time for carriers to file a petition for waiver under the  X -procedure established in the First Report & Order on the grounds of extraordinary circumstances that prevent it from complying with the Commission's deployment requirements. We therefore will suspend the deadlines for switches in categories (1) and (2)  Xy-during the period that the Commission is considering a carrier's petition for waiver. y  yO-  ԍxFor example, if a LEC receives a request for deployment in an additional switch that is an Equipped Remote  xSwitch, and five days later the LEC files a petition for waiver, then the LEC need not deploy number portability in  x<the switch until 25 days after the Commission denies its petition, or until the date specified in the Commission's grant of the petition.  XK-xC68.` ` We agree with MCI that, after portability has been introduced in an MSA, the  X4-incremental cost and resources needed to add additional end offices are relatively minor  X-because most costs, e.g., SCP hardware and signalling links, OSS modifications, and shared  X-regional database costs, will have already been incurred.B  yO-ԍxMCI Reply at 56.B Number portability, consequently, can be deployed more quickly in the switches for which number portability is requested after the initial deployment of number portability. We therefore decline to adopt suggestions by  X-USTA and GTE to allow a longer time after receipt of a request for deployment of number  X-portability capability in switches not in the initial deployment.q`  yO"-  ԍxSee USTA Petition at 16 (suggesting that carriers have nine months after receipt of a request to deploy  xhadditional switches); GTE Petition at 9 (proposing that a LEC not be required to implement portability in additional  xjswitches until six months after receipt of a request, and even then only if the switch already has SS7 and AIN  yO%- xcapabilities). Cf. MCI Reply at 6 n.12 (asserting there is no reason why it should take even six months to deploy software in additional switches).q "),-(-(ZZQ-"Ԍ X-xD69. ` ` We emphasize that a carrier operating a nonportabilitycapable switch must still properly route calls originated by customers served by that switch to ported numbers. When the switch operated by the carrier designated to perform the number portability database query is nonportabilitycapable, that carrier could either send it to a portabilitycapable switch operated by that carrier to do the database query, or enter into an arrangement with another carrier to do the query.  X_-xE70.` ` We conclude that permitting carriers to specify those switches within the 100 largest MSAs in which they desire portability is more workable than the procedures proposed by some petitioners that would require incumbent LECs to file waiver requests for specific  X -switches for which the incumbent LECs believe that no competitor is interested.  yO -ԍxSee USTA Petition at 16; GTE Opposition at 1415; Pacific Comments at 4; Sprint Opposition at 11. A waiver procedure would create a period of uncertainty for both the incumbent LEC and the  X -competitive LEC as to whether portability would actually be deployed in that switch.J X  yO-ԍxSee MCI Reply at 5.J Moreover, a waiver procedure would burden the incumbent LEC with preparing and filing the petition for waiver, require that we review the petition, and potentially burden the state commission with determining whether there is actual competitive interest in the switch. In addition, these proposals by petitioners appear to assume generally that no competitive LEC would oppose the waiver petition; if this is not the case, then a waiver procedure would burden competing carriers with challenging the waiver. A waiver procedure would also burden both competing carriers and consumers by hampering competitive entry into the market while waiting for a determination by the Commission or a state commission.  X-xF71.MARKET ASSURANCE ` ` We believe that the criteria set forth above adequately address MCI's concern that requesting carriers would bear an unnecessary burden of justifying deployment in each  X-end office and endure uncertainty as to deployment.L  yOq-ԍxSee id. at 56.L The only burden on requesting carriers is to identify and request their preferred switches. In addition, carriers have a time frame for deployment of the initially unrequested switches within the 100 largest MSAs. Competitive LECs can thus market their services as widely as they desire with assurance that number portability will be available in the areas where, and at the times when, they desire to compete. As an additional safeguard against anticompetitive abuses of the procedures to identify and request those switches for which a carrier desires deployment of number portability, we delegate authority to the Chief, Common Carrier Bureau, to take action to address any problems that arise over any specific procedures.  X-XxX` ` 3.X Extension of Implementation Schedule (#  X -xG72.` ` Pleadings. Several BOCs and GTE argue that the current schedule for implementation by wireline carriers allows too little time for implementing a technology that"!*x,-(-(ZZ -"  X-requires such extensive networkwide modifications._  yOy-  ԍxBellSouth Petition at 1015; NYNEX Petition at 712; GTE Petition at 38; SBC Petition at 11; US West  xPetition at 13 (Commission's performance criteria require that the technology not degrade service quality or network  yO - xreliability (quoting First Report & Order, 11 FCC Rcd at 8378, 8382)). See also Pacific Comments at 34  x,(concurring with network reliability concerns and the need to allow flexibility in the schedule for testing); US West Reply at 2._ These petitioners argue that the present schedule could jeopardize network reliability because it does not allow sufficient time to complete numerous tasks, many of which, they allege, are beyond their control, including:  X-(1) review and incorporation of the results from the Chicago trial,sXx  yO -  ԍxUS West Petition at 6 (stating that carriers serving seven of the most populous MSAs must start installing  xportability and supporting live traffic the day after reports for the Chicago trial are due); NYNEX Petition at 12; GTE Opposition at 12; US West Reply at 24; BellSouth Reply at 4.s and resolution of critical  X-carrierspecific operational issues that the Chicago trial will not address;  yO -  ԍxUS West Petition at 611 (listing as examples: network engineering; network load/stress; software system  xstability and reliability; impact on backup systems; and modifications of systems such as ordering, capacity  yO}- xxprovisioning, maintenance, repair, and billing). See also GTE Petition at 45 (claiming that the Chicago test will  xnot include several switch types and will only involve one specific network configuration); GTE Opposition at 13;  xPacific Comments at 3 (claiming that the Chicago trial will not adequately test many systems, as Ameritech is  xhperforming many of the activities involved in that trial on a manual basis); NYNEX Reply at 8 n.28. USTA further  xclaims that unspecified small and midsize carriers will be introducing SS7 and/or AIN capabilities into their  xnetworks for the first time, and that these carriers' networks are especially different from those networks being tested in the Chicago trial. USTA Reply at 910. (2) development  X-and testing of number portabilityspecific and "generic" software upgrades;h  yO-  ԍxGTE claims that testing of switch software could take 36 months, and, moreover, additional time is needed  xto install the software for longterm number portability in all switches and remove transitional number portability  x,methods. GTE Petition at 45. BellSouth claims that many switches' generic software cannot handle the necessary  xupgrades. BellSouth Petition at 11. NYNEX claims that switch vendors cannot meet their current workloads, and  xthat the time estimated for software upgrades does not reflect the fact that most upgrades will take place on weekends  yO- xin order to minimize system disruptions. NYNEX Petition at 89. See also BellSouth Petition at 12; NYNEX  xPetition at 78 (urging that we not hold carriers responsible for switch vendors' failure to deliver software in time  xfor carriers to meet the deployment schedule); NYNEX Opposition at 23; CBT Comments at 23; Pacific Comments at 4; GTE Opposition at 11.  (3) development and testing of infrastructure modifications and additions to support number portability  X_-capabilities;_8  yOH -  ԍxUS West Petition at 11; see also BellSouth Petition at 13 (claiming our schedule does not account for  x\availability of switch vendor functionality, SMS and SCP functionality, and billing systems and associated  xprocedures, despite the fact that these factors were reported to the Georgia Public Service Commission as essential  x<to LRN implementation); NYNEX Petition at 9 (stating that switch vendors' representations did not discuss the infrastructure that needs to be added, such as signalling links, STPs, databases, and operator services). (4) modification of operational support systems (OSS);_  yO$-  ԍxCBT Comments at 23; Pacific Comments at 4; GTE Petition at 6; BellSouth Petition at 13; NYNEX Petition at 9. (5) modification of vendor software if state commissions dictate inconsistent rate centers for identifying and"H+@,-(-(ZZ-"  X-billing calls;\  yOy-ԍxGTE Petition at 7; GTE Opposition at 1112.\ and (6) establishment of regional databases and associated technical standards  X-by the NANC.X  yO-  ԍxUS West Petition at 11; see NYNEX Petition at 11; NYNEX Opposition at 23; GTE Petition at 7; GTE Opposition at 1114; BellSouth Petition at 16. On February19, 1997, SBC submitted a study it commissioned from  X-Bellcore that purportedly demonstrates that the deployment schedule set forth in the First  X-Report & Order for PhaseI would threaten network reliability in Houston.x  yO -  ԍREPORTABLExSBC February19, 1997 Ex Parte Filing at att. at 12. The Bellcore study asserts that what it characterizes  yO - xas the Commission's "accelerated" (i.e., threemonth) implementation schedule for PhaseI will increase the  xYprobability of a "catastrophic outage" by a factor of nine, to 0.435percent, and increase the probability of an "FCC  yOt - xireportable outage" by a factor of 4.5, to 65.9percent. Id. The Bellcore study defines a "catastrophic outage" as  x,"losing all intraLATA interoffice service for most or all of Houston" and an "FCC reportable outage" as "an outage  yO - xthat potentially affects 30,000 or more subscribers for 30 or more minutes." Id. at att. at 5. See also Bellcore  yO -March5, 1997 Ex Parte Filing.  X-xH73.` ` In their petitions and comments, some of the incumbent LECs recommend specific ways to relax the deployment schedule for wireline carriers. US West suggests extending the deadline for each phase by three months, claiming this would give carriers not participating in the Chicago trial the necessary time to study the results of the trial and  X1-conduct tests within their own networks.j1  yO-  ԍxUS West Petition at 23; US West Reply at 34. Specifically, US West advocates extending the schedule  xfor three months so that US West may perform a "first region application" test during the fourth quarter of 1997,  yOb- xafter the Chicago "first office application" trial is done in the third quarter of 1997. Id. at 34. SBC and Bell  x;Atlantic advocate more flexible guidelines, including extensions to the implementation schedule, to account for any  yO- xwimplementation problems. SBC Petition at 11; Bell Atlantic Reply at 10. See also Pacific, et al., February24, 1997  yO-Ex Parte Filing at 12) (advocating sixmonth extension for every market in Pacific's region).j BellSouth, CBT, and GTE recommend that the  X -deadlines for completing implementation of Phases I and II each be extended from 90 to 180  X -days.}x h  yO-  >ԍxBellSouth Petition at 11; GTE Opposition at 16; CBT Comments at 24. CBT claims such an extension  xwould recognize that small and midsize LECs located in the 100 largest MSAs cannot make software and OSS  xupgrades as quickly as the BOCs, and would allow the larger LECs to test and resolve the problems of this new  yOt- xtechnology, thereby reducing testing costs for small and midsize LECs. Id. at 34. See also SBC Ex Parte Letter,  xJat 12, from Link Brown, to William F. Caton, FCC, CC Docket No. 95116, filed Feb.10, 1997 (SBC February10,  yO - xZ1997 Ex Parte Filing) (proposing, based on Bellcore study, that deadlines for SBC's PhaseI and PhaseII markets be extended by three months).} Under this plan, new Phase I would extend from October 1997 through March 1998; new Phase II would extend from January 1998 through June 1998, and the remaining phases  X -would remain the same (e.g., Phase III would still extend from April 1998 through June  X -1998).T   yO%-ԍxSee BellSouth Petition at 11.T BellSouth claims that, because its plan would extend only the deadlines for  X -completing implementation of longterm number portability for PhasesI and II, LECs would still start implementation of all phases, and complete deployment in PhasesIII through V,",8,-(-(ZZ-"  X-according to our original schedule.F  yOy-ԍxBellSouth Reply at 4.F In addition, BellSouth seeks clarification that Phase I  X-implementation may begin at any time during PhaseI (i.e., from October 1997 through March  X-1998, under its proposed schedule).OX  yO-ԍxBellSouth Petition at 15 n.17.O GTE urges us to clarify that LECs will be entitled to a waiver of the deployment deadlines if they cannot meet the deployment schedule for reasons  X-"outside the control of the LECs."  yO= -  ԍxGTE Opposition at 1014; GTE Reply at 5; see also Bell Atlantic Reply at 9 (claiming that LECs must rely on others, especially switch vendors, to meet the schedule); NYNEX Opposition at 2. USTA proposes allowing each state commission and/or its workshop to evaluate evidence of local competition in areas within that state, and either accelerate or decelerate the deployment schedule in those areas, as long as the "overall  X_-burden" on carriers implementing number portability is not increased.X_@  yOP-  ԍxUSTA Comments at 46. USTA cautions, however, that states must not make changes to the deployment  xschedule that would harm a carrier's ability to deploy portability in another state, or undo state deployment plans  yO-to which carriers have already agreed (e.g., in Illinois). Id. at 6.  X1-xI74.` ` NYNEX urges us to expedite the Chicago trial, or, in the alternative, to select  X -other areas to hold field trials.l `  yO+-ԍxNYNEX Petition at 12. See also GTE Opposition at 13.l NYNEX also urges us to encourage states to be flexible in opting out of the regional database or choosing to construct joint databases, and to work with  X -less active neighboring states to establish regional databases.I  yO-ԍxNYNEX Petition at 1112.I NYNEX also suggests that, during Phase I of the schedule (fourth quarter of 1997), we allow LECs to deploy longterm number portability in smaller MSAs as test beds, instead of requiring deployment in the  X -largest MSAs.  yO-  \ԍxNYNEX claims that new capabilities in the public switched network are typically introduced and tested in  xa smaller market first before widespread deployment. NYNEX Opposition at 3 & n.10; NYNEX Reply at 78  x(asserting that Charleston, West Virginia was used as a test bed for introducing equal access signalling). NYNEX  xclaims that, under its proposal, the MSAs currently scheduled for deployment in Phase I would instead be deployed  xthree months later during Phase II, and the MSAs currently scheduled for deployment in Phase II would instead be  yO- xdeployed during Phase III, and so on, but deployment would still be completed by the end of 1998. Id. at 89.  xNYNEX also expresses additional concerns over introducing new technology into the network during the busy  xholiday season and notes that the Commission specifically delayed the introduction of 800 number portability until  yO"- xKafter the holiday season. NYNEX Petition at 10 n.25; NYNEX Reply at 8. See also SBC February19, 1997 Ex  yO"-Parte Filing at att. at 1.  Xy-xJ75.` ` The prospective entrants generally oppose any delay in the implementation schedule for wireline carriers. AT&T responds that the Commission's schedule is justified by specific showings in the record that an industry Service Management System (SMS) could be"K-,-(-(ZZ-" deployed, upgrades of carrier networks could be performed, and operational issues could be  X-addressed in time for completion of widespread deployment (i.e., in 84 MSAs) of longterm  X-number portability by the third quarter of 1998.E  yOK-  ԍxAT&T Opposition at 2021 & n.65; see also ACSI Reply at 89 (supporting AT&T's assertion that the  x<incumbent LECs will be able to meet the schedule and urging us not to extend the schedule or relax the standards  xfor obtaining a waiver of the schedule). TRA asserts that the schedule considers projected switch software  xavailability dates and installation rates and burdens on incumbent LECs, and provides for field testing. TRA LateFiled Comments at 6.E MCI argues that our schedule is reasonably based on the schedules that several states had already established which ordered  X-deployment to begin in the third or fourth quarter of 1997.Fx  yO -ԍxMCI Opposition at 16.F In ex parte filings, AT&T and MCI both argue that the latefiled Bellcore study does not provide an adequate basis for  Xv-extending the implementation schedule, and that the study is "fatally flawed."` v  yO/-  {ԍANTI-BELLCORExAT&T February26, 1997 Ex Parte Filing at 13; MCI February26, 1997 Ex Parte Filing at 13. For  xinstance, they point out that the Bellcore study describes a "highly improbable scenario" in which all four number  xportability SCPs (two mated pairs) in the Houston MSA would undergo simultaneous dual failures, yet the study  yO- xJacknowledges there has never been a dual failure of even one mated pair. AT&T February26, 1997 Ex Parte Filing  yOO- x,at 2; MCI February26, 1997 Ex Parte Filing at 3. AT&T alleges, moreover, that the Bellcore study makes various  xincorrect and internally inconsistent assumptions that, if the first mated SCP pair fails, then it is extremely likely that  yO- xsubsequent SCP pairs will also fail simultaneously. AT&T February26, 1997 Ex Parte Filing at 2. AT&T also  xasserts that the Bellcore study incorrectly assumes that the use of switchbased software fault factors increases the  yOo- xxlikelihood that components other than the switch will fail. Id. at 3. MCI claims that implementation of number  xportability will indeed follow the "normal" approach to service implementation, as every item listed by Bellcore as  xpart of a "normal" introduction process will be performed in the Chicago trial, as well as by regional regulatory  yO-bodies. MCI February26, 1997 Ex Parte Filing at 2.  XH-xK76.` ` MCI argues that the safeguards in the First Report & Order monitoring of implementation by the Chief of the Common Carrier Bureau, the Chicago trial, and the waiver procedure for extending the deployment deadlines if necessary will be adequate to avoid  X -alleged network reliability risks and technical problems. 0  yO-  MԍxId. at 1718. US West claims, however, that it would be dangerous to wait to issue a waiver until carriers are about to begin porting "live" traffic. US West Reply at 4. MCI also urges us to instruct the LECs that they will not receive a waiver of the schedule if they introduce new services or technologies that are incompatible with LRN, experience implementation problems as a result, and then claim more time is needed to modify LRN and resolve the problems caused by the  X -introduction of incompatible services or technologies.   yO"-  {ԍxMCI Reply at 78. MCI cites BellSouth's plan to roll out a new service that uses the AINO.2 software  yO#-platform, which it claims is incompatible with LRN. Id. at 8 n.18. AT&T, ICG, NEXTLINK, Sprint,  X-and TRA also argue that a procedure for relief already exists if carriers show that they cannot".,-(-(ZZ-"  X-meet the implementation schedule.  yOy-  ԍxAT&T Opposition at 21; ICG Comments at 6; NEXTLINK Opposition at 4; Sprint Opposition at 1314; TRA LateFiled Comments at 6, 10. Therefore, argues NEXTLINK, requests for delay of the implementation schedule are premature and fail to demonstrate the "extraordinary  X-circumstances" required by the First Report & Order.J   yO-ԍxNEXTLINK Opposition at 4.J ALTS argues that the incumbent LECs challenging the technical aspects of the schedule should instead first try to resolve their claims with the involved carriers and vendors, and then seek Commission intervention with  X-respect to any remaining issues.J  yO -ԍxALTS Opposition at 6 n.7.J Time Warner argues that, given the incumbent LECs' strong incentive to delay competition, we should closely scrutinize claims of infeasibility in casebycase waiver requests, and deny a waiver if another carrier facing similar technical  XH-challenges (e.g., upgrading similar generic software on similar switches) has met the  X1-deployment deadlines.r1@  yO"-ԍxTime Warner Comments at 89; see also MCI Opposition at 18.r  X -  X -xL77.` ` ICG claims BellSouth's request to extend the number portability implementation schedule for PhasesI and II is unjustified and would slow implementation in  X -the later phases as well.C   yOV-ԍxICG Comments at 5.C ICG suggests that if we do grant BellSouth's request, however,  X -then the implementation dates for Phases III, IV, and V should not be changed.D `  yO-ԍxId. at 6 n.2.D ICG and  X -NEXTLINK oppose US West's request that carriers not participating in the Chicago trial receive an extension of the implementation schedule, arguing that: the four month period between the completion of the Chicago trial and the completion of implementation in PhaseI is ample time for carriers to review the results of the Chicago trial, and carriers can schedule  XK-their own trials if they want more time;BK  yO-ԍxId. at 67.B LECs need not wait for the outcome of the Chicago trial before testing and modifying their own networks, as the trial's results will be  X-available as it progresses;p  yON!-ԍxNEXTLINK Opposition at 34; see also ICG Comments at 67.p and US West participates in state and industry fora where implementation and intercarrier OSS impacts of number portability have been extensively  X-analyzed.L  yO$-ԍxNEXTLINK Opposition at 34.L Similarly, MCI claims that the results of the Chicago trial will be applicable to all networks, because all carriers use switches from the same few vendors and have similar"/,-(-(ZZ&-"  X-network designs.K  yOy-ԍxMCI Opposition at 17 n.10.K Finally, MCI claims that USTA's proposal to allow states to alter the Commission's deployment schedule would let incumbent LECs influence the states to delay  X-the schedule and thus "cripple" deployment of longterm number portability in every MSA.@X  yO-ԍxMCI Reply at 5.@  X-xM78.NO QOR DELAY` ` Discussion. We grant, with some modifications, the requests by BellSouth and  X-other parties to extend the deadlines for completion of deployment of longterm number  Xv-portability for PhasesI and II, as set forth in AppendixE of this First Reconsideration  X_-Order._  yO -ԍxSee BellSouth Petition at 11; CBT Comments at 24; GTE Opposition at 16. On reconsideration, we extend the end date for PhaseI by three months. Thus, deployment in PhaseI will now take place from October1, 1997, through March31, 1998. We take this action because we are now persuaded that initial implementation of this new number portability technology is likely to require more time than subsequent deployment once the technology has been thoroughly tested and used in a live environment. For example, initial implementation of this new technology is likely to involve more extensive testing, and may require extra time to resolve any problems that may arise during the testing. It therefore is appropriate that PhaseI be longer than subsequent phases in the schedule to allow carriers to take appropriate steps to safeguard network reliability.  X-  Xy-xN79.` ` We also note that the participants in the Chicago trial have recently informed us that the completion date of the Chicago trial, previously scheduled for August31, 1997,  XK-has been postponed by approximately one month until September26, 1997.bXKx  yOt-  /ԍxMidwest Region Local Number Portability L.L.C. Ex Parte Letter at 12, from Roger P. Marshall, et al.,  yO<- xto Regina Keeney, FCC, CCDocket No.95116, filed Feb.27, 1997 (Midwest LNP L.L.C. February27, 1997 Ex  yO-Parte Filing).b While the Chicago trial participants have committed to providing the Commission with weekly updates on trial progress, the full report on the Chicago trial that participants had planned to file  X-September30, 1997, is now scheduled to be filed October17, 1997.@  yOO-ԍxId. at 2.@ Consistent with this notification by the Chicago trial participants, we hereby extend our deadline for carriers that are members of the ICC Workshop to conduct a field test of any technically feasible longterm database method for number portability in the Chicago, Illinois, MSA and to report the results of that trial. While we understand that participants in the Chicago trial are prepared to commence implementation in Chicago immediately upon conclusion of the trial and still  X|-expect to meet the original December31, 1997, deadline,: |(  yOU%-ԍxId.: we recognize that carriers operating in other MSAs may require additional time to interpret the results of the Chicago  XN-trial in light of their individual network configurations. Finally, we find some merit in CBT's"N0 ,-(-(ZZ-" argument that an extra 90 days for initial implementation may permit small and midsize LECs to reduce their testing costs by allowing time for larger LECs to test and resolve the  X-problems of new technology.O   yOK-ԍxSee CBT Comments at 34.O Given all the factors listed above, we conclude that a three-month extension of the time period for initial deployment in PhaseI markets appropriately safeguards network reliability, and therefore is warranted.  Xv-xO80.` ` We also extend the end date for PhaseII by 45 days. Thus, deployment in PhaseII will now take place from January1, 1998, through May15, 1998. We extend PhaseII to alleviate potential problems that may arise if deployment in markets in PhaseI and II must be completed on the same date. Requiring that implementation be completed in a  X -greater number of markets by a specific deadline may make that deadline more difficult to  X -meet (e.g., by straining vendor resources to perform software upgrades in any given period of  X -time).T  X  yO-ԍxSee ICG Comments at 5, 6 n.2.T For the same reason, we decline to extend PhaseII by 90 days as requested by BellSouth, as such an extension would establish the same deadline for completion of deployment for PhasesII and III. We conclude that the modest adjustment of the deadline for  X -PhaseII adopted in this First Reconsideration Order will more effectively stagger the deadlines for deployment in different markets than BellSouth's proposal.  Xb-xP81.` ` We clarify, per BellSouth's request, that implementation of number portability for a phase may begin at any time during that phase, provided that implementation in the  X4-designated markets is completed by the end of that phase.O 4  yO-ԍxBellSouth Petition at 15 n.17.O Contrary to the allegations of Pacific and other parties, number portability thus need not be introduced "on virtually the same day" in the seven of the largest MSAs, especially because it may now be phased into the  X-first markets more gradually over six months, instead of three. x  yO-ԍxSee, e.g., Pacific, et al., February24, 1997 Ex Parte Filing at 1.  X-xQ82.WAIVER FILING` ` We strongly advise carriers to begin implementation early in each phase, however, as they will not be able to obtain a waiver of the schedule if they cannot demonstrate, through substantial, credible evidence, at least sixty days before the completion deadline, the extraordinary circumstances beyond their control that leave them unable to comply with the schedule, including "a detailed explanation of the activities that the carrier has undertaken to meet the implementation schedule prior to requesting an extension of  X7-time."j7  yO$-ԍxSee First Report & Order, 11 FCC Rcd at 8397.j This is especially applicable to PhasesI and II, given that we now are granting carriers additional time during those phases specifically so that they can implement number portability more gradually. We will not look favorably upon a waiver request if the carrier" 1,-(-(ZZ-" has not taken significant action to implement portability, if the carrier does not place orders with switch manufacturers in a timely manner, or, for example, if the carrier requests a waiver for a PhaseII market because it only began preparing for implementation for a PhaseI market in the first quarter of 1998, and then claims that it has too many software upgrades to perform from January through May15, 1998. Carriers should be able to identify any specific technical problems that may necessitate an extension of the deployment deadline for Phase I during the four months between the scheduled end of the Chicago trial and the deadline for  X_-requesting an extension for Phase I, especially because carriers will be receiving initial feedback from testing in Chicago far in advance of the Chicago trial's conclusion. As noted above, the participants in the Chicago trial have committed to providing weekly progress reports as the trial progresses. Initial tests of LRN hardware and software on a subset of  X -switches in the Chicago MSA began in January 1997.p  yO| -ԍxComm. Daily, vol.17, no.15, Telephony Section, Jan.23, 1997.p Intranetwork and database testing in  X -Chicago is scheduled to take place for several months before the start of the Chicago trial  X -mandated by the Commission.q X  yO-ԍxMidwest LNP L.L.C. February27, 1997 Ex Parte Filing at 2.q  X -xR83.` ` Our decision to extend the deadlines for completing PhasesI and II of our deployment schedule reflects the fact that we consider network reliability to be of paramount  Xy-importance. Consistent with that commitment, in the First Report & Order we delegated authority to the Chief, Common Carrier Bureau, to monitor generally the progress of number portability implementation and take appropriate action, as well as establishing a procedure for individual LECs to obtain an extension of the deployment deadlines as necessary for their  X-specific markets.`  yO-ԍxFirst Report & Order, 11 FCC Rcd at 8393.` The Chief, Common Carrier Bureau, will monitor the weekly reports from the Chicago trial and any other pertinent developments. We find that further adjustment of the deployment schedule in response to these developments is more properly a matter for the Chief, Common Carrier Bureau, to handle as number portability technology is tested and carriers discover any actual, specific difficulties. If significant problems arise during the Chicago trial, or other significant implementation problems arise during PhaseI, the Chief,  X-Common Carrier Bureau, has the authority to adjust the schedule for the Chicago trial or the deadline for PhaseI implementation, as appropriate, to ensure network reliability.  XN-xS84.` ` Although the findings of the Bellcore study submitted by SBC were vigorously  X7-challenged by AT&T and MCI,a7x  yO`#-ԍxSee supra note ANTI-BELLCORE248.a it bears mention that extending the PhaseI completion date by three months is responsive to the recommendation in the Bellcore study that we should  X -allow additional "time for testing, integration, and soaking (limited use of the software in a" 2,-(-(ZZy-"  X-live environment for a length of time sufficient to find initial defects) of the software."j  yOy-ԍxSBC February19, 1997 Ex Parte Filing at att. at 1.j In fact, the Bellcore study specifically recommended that the Commission "[e]xtend the time  X-interval for introduction of [number portability] by 3 months."HX  yO-ԍxId. at att. at 2.H Our extension of PhaseI, in  X-combination with our conclusion that carriers need provide portability only in requested  X-switches,f  yO= -ԍxSee supra  DEPLOY UPON REQUEST60.f also allows carriers the flexibility to introduce portability more gradually,  X-beginning with a subset of switches within the MSA.jx  yO -ԍxSBC February19, 1997 Ex Parte Filing at att. at 3.j  X_-xT85.` ` We deny the petitions to extend the deployment deadlines for all markets or  XH-otherwise provide wireline carriers greater flexibility in the schedule to implement longterm  X1-number portability.1  yO-  ԍxSee, e.g., US West Petition at 23; SBC Petition at 11; Bell Atlantic Reply at 10; Pacific, et al.,  yO-February24, 1997 Ex Parte Filing at 6. Although we conclude that initial implementation of this new number portability technology may require additional time, we are not persuaded that implementation in subsequent phases, after the technology has already been tested and installed in the initial markets, need be delayed to the extent requested by some petitioners. We find on the basis of  X -the record in this proceeding that the implementation schedule as revised in this First  X -Reconsideration Order is reasonable, and that granting any further delay of the schedule at this time is premature and unnecessary, especially because there is still approximately one year before LECs must complete deployment for the earliest phase. Petitioners have only speculated that unpredictable events may, at some point in the future, generally delay implementation, and have not shown that a specific factor will render the later schedule  XK-impossible to meet for any particular reason, much less for any particular LEC.  X-xU86.` ` For example, despite NYNEX's vague claim that switch vendors cannot meet  X-current workloads,G`  yO-ԍxNYNEX Petition at 89.G no party has submitted any evidence refuting the specific vendor  X-representations cited in the First Report & Order that vendors will be able to begin providing  X-software for at least one longterm number portability method around mid1997.`  yOy"-ԍxFirst Report & Order, 11 FCC Rcd at 8393.` Indeed, GTE admits that it "has no reason to doubt that [the switch vendors Lucent, Northern Telecom, Siemens, and Ericsson] can meet their commitments" to "begin supplying LRN"3 ,-(-(ZZ-"  X-software in earlytomid 1997."D  yOy-ԍxGTE Petition at 4. D It is our understanding that the switch vendors Lucent and  X-Nortel are still on schedule to provide LRN software by mid1997.XX  yO-   ԍxComm. Daily, vol.17, no.15, Telephony Section, Jan.23, 1997 (Lucent has provided LRN software to  yO- xAmeritech for testing); Nortel Ex Parte Presentation at 5, CC Docket 95116, filed Jan.27, 1997 (Nortel January27,  yO-1997 Ex Parte Filing) (Nortel will make LRN software available in the third quarter of 1997).  X-xV87.` ` NYNEX also claims that the time estimated for software upgrades does not account for the fact that most upgrades will take place on weekends in order to minimize system disruptions, and generally alleges that "[t]here are probably not enough weekends" to  Xv-complete deployment according to the schedule.Gvx  yO -ԍxNYNEX Petition at 89.G NYNEX fails, however, to specify the additional time that, according to its estimate, would be necessary to complete the necessary upgrades. Similarly, GTE claims generally that more time is necessary to install the software for longterm number portability in all switches and remove transitional number portability  X -capabilities, but does not estimate the additional time it believes it would need.C   yO-ԍxGTE Petition at 5.C GTE also claims in general terms that the schedule does not accurately reflect the time needed to modify vendor software if state commissions dictate inconsistent rate centers, but does not explain to what extent the rate centers are inconsistent and thus need modified software, nor  X -does it show that a specific amount of additional time will be needed.B   yO-ԍxId. at 7. B  X-xW88.` ` Petitioners' arguments are even more speculative given that their implementation obligations are likely to be significantly lighter than they assume, because, as we discuss above, LECs are required to deploy number portability only in switches for which  XK-they receive requests for number portability capability.fK(  yO$-ԍxSee supra DEPLOY UPON REQUEST60.f Moreover, even if the problems  X4-identified by petitioners do in fact develop, in our First Report & Order we established a procedure for LECs to obtain an extension of the deployment deadlines as necessary, and delegated authority to the Chief, Common Carrier Bureau, to monitor the progress of number  X-portability implementation.`   yOX"-ԍxFirst Report & Order, 11 FCC Rcd at 8393.` "4H ,-(-(ZZ-"Ԍ X-xX89.STATE WORK ` ` In addition, contrary to petitioners' claims,!  yOy-  yԍxSee, e.g., BellSouth Petition at 1113; NYNEX Petition at 79; GTE Petition at 46; CBT Comments at 23; Pacific Comments at 4. the schedule set forth in the First  X-Report & Order did allow time for factors such as the need to modify OSS (e.g., ordering and billing systems) and the need to upgrade the number portabilityspecific and the generic  X-switch software. We noted in the First Report & Order that we based the schedule largely on  X-state commission deployment schedules.s"   yOu-ԍxSee First Report & Order, 11 FCC Rcd at 836265, 8392.s State commissions and workshops, organized under their auspices and composed of industry representatives, have been and still are working to resolve deployment issues and many of the associated issues that petitioners now claim  X_-warrant delay.9#@_  yO -  >ԍxFor example, the Maryland and Illinois state commissions throughout 1996 studied issues associated with  xJlongterm number portability such as operations, switch requirements, SCP requirements, technical strategies, billing  xand rating, operator services, and SMS database system requirements and testing. MD LNP Consortium  yO- xOctober1996 Report at 1519; Staff of the Public Service Commission of Maryland, Commission's Investigation  xinto Long Term Solutions to Number Portability in Maryland: Second Quarterly Report of the Maryland Local  yO- xNumber Portability Consortium, Case No.8704, at 612 (rel. Apr. 1996) (MD LNP Consortium April1996 Report);  yOp- x;AT&T Ex Parte Presentation at 13, CC Docket No. 95116, filed Feb.6, 1996 (AT&T February6, 1996 Ex Parte  yO8-Filing); see also First Report & Order, 11 FCC Rcd at 8364.9 While studying these issues in detail, those states that established  XH-deployment schedules prior to our First Report & Order nonetheless concluded that  X1-deployment could commence in certain MSAs in those states by mid1997.s$1  yO-ԍxSee First Report & Order, 11 FCC Rcd at 836265, 8392.s Moreover, since October, 1993, the industry, under the auspices of the Number Portability Workshop of the Industry Numbering Committee (INC), has been "assess[ing] the technical feasibility and implementation requirements, impacts, and attributes of number portability," including the  X -factors identified by petitioners.~%X H  yO-  ԍxIndustry Carriers Compatibility Forum (ICCF), INC Report on Number Portability, July11, 1996, at 7.  xyAmong the technical considerations that the INC has been studying are impact of implementation of number  yO^-portability on switches and operations systems. Id. at 3638.~ We conclude that state commissions were well aware of the concurrent need to resolve associated issues such as modification of OSS, and allowed time to resolve these associated issues when setting their longterm number portability  X-implementation schedules. While the First Report & Order did not expressly consider how much time is necessary to modify OSS and to upgrade software, the schedule the Commission adopted relies upon the prior work and expertise of the state commissions in establishing those state implementation schedules. At any rate, the extensions of PhasesI and II, as discussed above, should alleviate any potential concerns about the sufficiency of time for modifying OSS and upgrading switch software.  X-xY90.` ` We have concluded that a modest extension of the deployment schedule for PhaseI (and PhaseII) markets is warranted to allow more time for testing and modifications to be made when local number portability is first implemented. We do not believe, however,"5h%,-(-(ZZ-" that speculative and unspecified concerns about possible future technical concerns are sufficient to justify an acrosstheboard delay in implementing number portability in view of the adverse effects of delay on competition in local markets. The Commission found in the  X-First Report & Order that number portability is essential to effective facilitiesbased  X-competition in the provision of local exchange services.`&  yO-ԍxFirst Report & Order, 11 FCC Rcd at 8367.` Extending the schedule now for  X-deployment of longterm number portability, beyond the modifications adopted in this First  Xv-Reconsideration Order, based on unsubstantiated concerns will thus hamper the development  X_-of that competition.Z'_X  yOh -ԍxSee TRA LateFiled Comments at 78.Z Such an extension, moreover, would conflict with the 1996 Act's intent to open monopoly local telecommunications markets to competition as soon as  X1-possible.(1  yO -  /ԍxSee S. Conf. Rep. No. 230, 104th Cong., 2d Sess. 1 (1996); 141 Cong. Rec. S7880, S7984 (daily ed. June 7, 1995) (statements of Sens. Pressler and Hollings).  X -xZ91.` ` Moreover, we are not persuaded by the argument that we should delay the implementation schedule to account for problems that some other LECs may experience, due to differences in LEC networks that may prevent them from deploying number portability at  X -the same speed.+) @  yO-  ԍxSee GTE Opposition at 13; USTA Reply at 910; BellSouth Petition at 11. Regarding CBT's argument that  x-small and midsize LECs located in the 100 largest MSAs have more limited resources to upgrade their networks  xthan the BOCs, we note that the deployment schedule already eases the burden on those LECs by starting with the  ximore populous markets, in which the incumbent LEC is more likely to be a large carrier; in addition, small LECs'  x.concerns are further relieved by our conclusion, as set forth above, that portability need be deployed only in  yO-requested switches. See supra DEPLOY UPON REQUEST60; CBT Comments at 34.+ We believe that Congress, in requiring the provision of number portability "to the extent technically feasible," did not intend for LECs that are capable of providing number portability according to our deployment schedule to delay deployment on the grounds  Xy-that some other LECs may encounter technical obstacles in adapting their networks.`*Xy  yO-  NԍxSee 47 U.S.C.  251(b). See also Time Warner Comments at 89 (arguing against granting a waiver if  yO- xanother carrier facing similar technical challenges (e.g., upgrading similar generic software on similar switches) has met the deadlines).` We recognize, as Bell Atlantic points out, that the BOCs were permitted to develop and deploy  XK-equal access pursuant to a more relaxed schedule.T+K  yO!-ԍxSee Bell Atlantic Reply at 9.T The BOCs, however, did not have a statutory mandate to deploy equal access as soon as it was technically feasible to do so, and no party has shown that the schedule established by the Modification of Final Judgment (MFJ) for deployment of equal access could not have been accelerated.  X-x[92.` ` Furthermore, we find it unnecessary to act on GTE's request that we clarify that LECs may obtain a waiver if they cannot meet the schedule for reasons beyond their"6h+,-(-(ZZ-"  X-control. The waiver procedure established in the First Report & Order for extending deployment deadlines as necessary provides an effective vehicle for addressing any problems  X-in implementing number portability that LECs can document.,@  yOK-  ԍxIn particular, if problems necessitating delay do arise, the Chief of the Common Carrier Bureau may waive  x;or stay any of the dates in the implementation schedule, as the Chief determines is necessary to ensure the efficient  xwdevelopment of number portability, for a period not to exceed nine months. In the event a carrier is unable to meet  xour deadlines for implementing a longterm number portability method, it may file with us, at least 60 days in  xadvance of the deadline, a petition to extend the time by which implementation in its network will be completed.  yO3- xiFirst Report & Order, 11 FCC Rcd at 8397. See ALTS Opposition at 6 n.7 (arguing that incumbent LECs should  xtry to settle their claims with carriers and vendors and develop a record before challenging our schedule); Sprint Opposition at 1314. We note that carriers may file petitions for waiver of the deployment schedule more than 60 days in advance of an implementation deadline, and thus receive relief earlier, if they are able to present substantial,  X-credible evidence at that time establishing their inability to comply with our deadlines.-  yO-ԍxSee First Report & Order, 11 FCC Rcd at 8397; supra  WAIVER FILING82.  X_-x\93.` ` We reject USTA's proposal to give every state commission and/or workshop the authority to extend independently our deployment deadlines according to their assessments of the level of local competition in an area. As set forth above, we require carriers to identify the switches in which they desire number portability capability well before the deadline for  X -deployment in a particular MSA.f. `  yO-ԍxSee supra DEPLOY UPON REQUEST60.f We find that this requirement will enable LECs to deploy number portability in areas in which local competition is likely to develop at an early stage, while relieving LECs of the obligation to install the capability in areas that competitive LECs  X -have no initial interest in serving.f/  yO_-ԍxSee supra  WHY ONLY ON REQUEST59.f This requirement, in our view, addresses USTA's concerns by striking a reasonable balance between a LEC's interest in avoiding unnecessary switch upgrades, and a competitive LEC's interest in having assurances that number portability will be available in areas where it plans to compete to serve existing LEC customers.  X4-x]94.` ` We decline to expedite the Chicago trial, as requested by NYNEX.\04  yOe -ԍxNYNEX Petition at 12; GTE Opposition at 13.\ The First  X-Report & Order scheduled the completion date for the Chicago trial for as early as appeared reasonably possible at that time. Given the record before us now, we conclude that it would  X-not be possible to accelerate the commencement of that trial.s1  yO$-ԍxMidwest LNP L.L.C. February27, 1997 Ex Parte Filing at 12.s Moreover, we agree with the"71,-(-(ZZ-" Chicago trial participants that it would be inappropriate to shorten or delete any of the  X-planned testing.@2  yOb-ԍxId. at 2.@  X-x^95.` ` We also decline to order additional field tests, as requested by NYNEX.F3X  yO-ԍxNYNEX Petition at 12.F The requirement that there be a field trial in Chicago is only intended to ensure that at least one field trial is held to identify technical problems in advance of widespread deployment, which will provide all carriers, as well as the Commission, with information on implementation. All carriers will have an opportunity to monitor testing in Chicago and evaluate the results of the testing on an ongoing basis. We find, moreover, that LECs currently have access to additional information concerning the impact of number portability on their systems, because many LECs are, and have been for some time, analyzing extensively implementation and  X -intercarrier OSS impact of number portability under the auspices of state and industry fora.B4X   yO-  ԍxSee NEXTLINK Opposition at 34; MD LNP Consortium October1996 Report at 1519; MD LNP  yOd- xConsortium April1996 Report at 612; AT&T February6, 1996 Ex Parte Filing at 13; First Report & Order, 11 FCC Rcd at 8364.B  X -As we stated in the First Report & Order, we do not routinely schedule field trials in rulemaking proceedings; our requiring a field trial in the Chicago MSA is an exceptional step  X -that we adopted to safeguard against any risk to the public switched telephone network.`5   yOw-ԍxFirst Report & Order, 11 FCC Rcd at 8394.` The need for any further trials should be determined by the industry.  Xy-x_96.` ` To the extent that other networks differ in design or switch use or other relevant variables, we do not preclude the testing of either software or hardware in other areas or by other carriers, either contemporaneously with the Chicago trial or even before that trial  X4-begins.O64  yO}-ԍxSee ICG Comments at 67.O Indeed, we encourage carriers to test portability within their own networks as early  X-as possible.>7(  yO-  ԍxWe note that US West's argument on whether the deployment schedule accounts for sufficient time for  xwcarrierspecific testing is internally inconsistent. US West has made no showing that switch vendors will not release  xwnumber portability software in time for US West to do its own first office testing; rather, it has only alleged vaguely  xthat vendors "are generally reluctant to provide additional early software releases" because they prefer not to have  xmultiple carriers test, and find problems in, "the same earlyrelease software." US West Reply at att. at 9. If,  xhowever, the software that US West purchases is the same as that being tested in the Chicago trial, then US West  xshould be able to rely largely on the ongoing results of the Chicago trial. Since US West claims that the software  xto be tested in Chicago differs from the software it will use, there appears to be no reason for the software vendors  x<to refuse to release different software for first office testing so that US West may do testing in its own network  yO%-contemporaneously with the Chicago trial. Id. at 3.> For example, Bell Atlantic plans to do "first office application" testing in"87,-(-(ZZ -"  X-Gaithersburg, Maryland, from July15, 1997, to August30, 1997.8  yOy-  ԍxMD LNP Consortium October1996 Report at app.3 at att.3. A "first office application" is an initial test of new technology, performed in a limited area, to find and eliminate bugs before widespread deployment. The Gaithersburg test, therefore, will have been completed seven months before Bell Atlantic's March31, 1998, deadline to complete implementation in Philadelphia, the market in which it must deploy longterm number portability in PhaseI under our revised schedule. In any event, carriers should have the opportunity to perform their own testing, including on "live traffic," well before the date by which they must request any waiver of the PhaseI implementation requirements.  XH-x`97.` ` We also decline to adopt NYNEX's proposal to deploy portability in smaller  X1-MSAs instead of the largest ones during Phase I of the deployment schedule.l91   yO -ԍxSee NYNEX Opposition at 3 & n.10; NYNEX Reply at 79.l At this time, there is only speculation that starting with the most populous MSAs will result in technical problems. Indeed, carriers are further ahead in preparing for number portability in many of the larger MSAs than in the smaller ones; for example, several state commissions that had  X -addressed the issue of number portability before issuance of the First Report & Order had ordered that deployment begin in several major cities that are currently in Phases I or II of  X -our schedule. :   yO-  ԍxAfter a first office application in Gaithersburg, Baltimore and the Maryland portion of the Washington, DC  x<LATA are first on Maryland's deployment schedule. MD LNP Consortium October1996 Report at 3, app.3 at  xatt.3; MD LNP Consortium April1996 Report at 40. The Georgia workshop scheduled initial implementation in  yO`- xJAtlanta. BellSouth Ex Parte Presentation at 4, CC Docket No. 95116, filed Nov.1, 1996 (BellSouth November1,  yO(- x-1996 Ex Parte Filing). The Chicago LATA was scheduled for initial deployment in Illinois. Ameritech Further Comments at 8, CC Docket No. 95116, filed Mar.29, 1996.  Therefore, switching the deadlines of those larger MSAs with other, smaller MSAs now would, at a minimum, disrupt planning by competitive LECs and state commissions in those jurisdictions. Moreover, our threemonth extension of the end date of PhaseI, in combination with our conclusion that carriers need provide portability only in  XK-requested switches,f;K(  yO$-ԍxSee supra  DEPLOY UPON REQUEST60.f will serve much the same purpose as NYNEX's request by allowing carriers the flexibility to begin deployment in a subset of switches within each of the PhaseI MSAs and gradually increase coverage over the sixmonth period. In addition, we do not prohibit, but rather encourage, carriers to take whatever additional actions they believe are necessary to safeguard their networks, including testing deployment of portability in one of their smaller MSAs before or during Phase I of our deployment schedule. For example, Bell Atlantic is testing number portability in the smaller market of Gaithersburg, MD before Phase  X-I.k<  yO%-ԍxMD LNP Consortium October1996 Report at app.3 at att.3.k "9H <,-(-(ZZQ-"Ԍ X-xa98.` ` We also deny NYNEX's request that we explicitly encourage states to be flexible in opting out of the regional database or choosing to construct joint databases, or to  X-work with less active neighboring states to establish regional databases.I=  yOK-ԍxNYNEX Petition at 1112.I We find that the  X-First Report & Order allows sufficient flexibility for states to opt out of the regional  X-databases.>X  yO-  ԍxSee also BellSouth November1, 1996 Ex Parte Filing at 4 (Georgia and Florida are working together to develop a regional database). In addition, NYNEX's concern that the NANC would not resolve the database issues in time for carriers to meet the deployment schedule is now largely moot, given the recent activities of the NANC. The NANC has committed to making its final  X_-recommendations to the Commission on the database system by May1, 1997.D?_  yO -ԍxNANC Timeline at 1.D The NANC's working groups and task forces relating to number portability are already organized  X1-and holding regular meetings to resolve the database issues.@1@  yO"-  ԍxLNPA Selection Working Group February26, 1997 Status Report at 1; see also LNPA Selection Working Group December2, 1996 Status Report at 7. The Local Number Portability Administration Selection Working Group projects that all seven regional databases will be ready for testing on dates ranging from April18, 1997, to July1, 1997, and will be ready to support number portability deployment on or before October1, 1997, in accordance with the  X -deployment schedule set forth in the First Report & Order.}A   yO-ԍxId. See also NANC January8, 1997 State NPAC/SMS Status at 15.}  X -xb99.` ` Finally, we clarify that the first performance criterion, that any method "support existing network services, features, and capabilities," refers only to services existing at the  Xy-time of the First Report & Order. We caution LECs that problems in implementing their chosen number portability method due to modifications necessitated by the introduction of a  XK-new service or technology will not justify a delay of the deployment schedule.MBK(  yO$-ԍxSee MCI Reply at 78. M We decline, however, specifically to prohibit the introduction of any new service that is incompatible with  X-LRN, as the First Report & Order did not adopt LRN or mandate use of any specific long X-term number portability method.`C  yOo!-ԍxFirst Report & Order, 11 FCC Rcd at 8377.` "|:H C,-(-(ZZn-"Ԍ X- XxX` ` 4.X Acceleration of Implementation Schedule (#  X-xc100.` ` Pleadings. Several competitive LECs urge us to accelerate the deployment  X-schedule in smaller markets.D   yO4-  zԍxACSI Petition at 3, 712; KMC Petition at 23, 513. See also ICG Comments. ACSI adds that the 1996  xAct is predicated on promoting competition without reference to the size of the market. ACSI Petition at 11. KMC  xjargues that we could not have intended to foreclose number portability in smaller markets where "meaningful competition" exists. KMC Petition at 7. ACSI contends that the present schedule incorrectly assumes larger markets will experience competition first. ACSI claims that in fact many competitors  X-are focusing on MSAs beyond the largest 50.HE  yO -ԍxACSI Petition at 9, 11.H Consequently, accelerating the deployment of number portability in those smaller markets would promote competition in all markets and  X_-treat competitors more equally regardless of the size of market they are entering.:F_@  yOP-ԍxId.: ACSI proposes that the schedule for the 100 largest markets be accelerated so that all BOCs implement number portability "according to roughly the same schedule as a function of  X -population served."pGx   yO-  ԍxId. at 10 & n.18. See also ICG Comments at 4. ACSI submits a proposed schedule under which certain  xspecific MSAs in the 100 largest MSAs would be deployed earlier. ACSI Petition at att.A. ACSI also suggests  xthat the implementation date of the Fort Worth MSA be accelerated to coincide with that of Dallas so competing  yO- xcarriers can cover the entire DallasFort Worth area. Id. at 10 n.16. ICG expands on this idea to recommend that  yO- xall "consolidated MSAs," as determined by the Rand McNally Major Trading Area definitions (e.g., Cleveland and  xDayton, Ohio) be deployed at the earlier of the two relevant MSAs' implementation deadlines. ICG Comments at 34 & n.1.p ACSI also proposes requiring nonBOC incumbent LECs to deploy portability in their largest market in the fourth quarter of 1997, or, at the latest, the first  X -quarter of 1998.EH   yO-ԍxACSI Petition at 10.E In the alternative, ACSI urges us to allow carriers with "operational networks in the 100 largest MSAs and the authority to provide local exchange services" to request, beginning July1, 1997, the deployment of number portability on a specified date six  X -or more months in the future.dI   yO-ԍxId. at 12. See also ICG Comments at 4.d ACSI would place upon an incumbent LEC the burden of proving that it cannot provide number portability, and proposing an alternative date for  Xy-implementation no more than three months later than the date requested.JXy0  yOZ"-  MԍxACSI Petition at 12. ACSI adds that its proposal imposes no greater burden on any incumbent LEC than  xthe burden the two BOCs with the largest implementation burden, Bell Atlantic and Pacific, have under the  yO#-deployment schedule in the First Report & Order. Id. at 89. ALTS agrees that incumbent LECs should be required to implement portability in a region before the scheduled  XK-implementation date for that region, if the incumbent LEC is able to do so.iKKP  yOL'-ԍxALTS Opposition at 6; see also ACSI Petition at 3.i"K;K,-(-(ZZ-"Ԍ X-ԙxd101.` ` For markets outside the 100 largest MSAs, KMC contends that we should  X-require LECs to accept bona fide requests for deployment of portability, after January 31,  X-1997, and to require implementation of such requests within six months.CL  yOK-ԍxKMC Petition at 6.C Alternatively,  X-KMC urges us to require all LECs immediately to accept bona fide requests for markets outside the 100 largest MSAs, and to satisfy such requests within 24 months, unless the LEC  X-can prove technical infeasibility.AMX  yO-ԍxId. at 10.A Another option presented by KMC and ACSI is to permit carriers to submit requests for markets outside the 100 largest MSAs as early as July 1, 1998, so that implementation of these requests can begin immediately upon completion of  XH-deployment in the 100 largest MSAs.NxH  yO -  ԍxKMC Petition at 12; ACSI Petition at 10. See also ICG Comments at 45; MCI Reply at 6. ACSI adds  yO - x,that, in regions served by NYNEX, Southwestern Bell, and US West, bona fide requests for markets outside the 100  xlargest MSAs should be permitted beginning April 1, 1998, since, under ACSI's proposed changes to the initial  x deployment schedule, those carriers would complete implementation for the markets among the 100 largest they serve  x-by September 1998. ACSI Petition at 10 n.18. In addition, suggests ACSI, requests for markets outside the 100  xlargest MSAs served by a nonBOC incumbent LEC should be accepted six months before that LEC must complete  yO-implementation in the last scheduled MSA that it serves that is within the 100 largest MSAs. Id. NEXTLINK urges us to accept requests earlier than  X1-the First Report & Order allows for the provision of number portability for markets outside the 100 largest MSAs, consult with the relevant state commission regarding the extent of competition in that requested market, and grant the request if there is "sufficient evidence" of  X -competition.Ox (  yO-  /ԍxNEXTLINK Petition at 56. The determination of "sufficient evidence" of competition would consider  xwhether the requesting carrier has a central office switch in the relevant MSA with assigned NXXs, has  xxinterconnected with the LEC operating the requested switch, and will itself provide number portability within the  yO- xsame time period. NEXTLINK Ex Parte Presentation at 45, CC Docket No. 95116, filed Oct.18, 1996  yO- x(NEXTLINK October18, 1996 Ex Parte Filing). NEXTLINK specifically urges us to accept a request for  xaccelerated deployment of portability in the Spokane MSA, asserting that US West's obligations are disproportionately light compared with other BOCs. NEXTLINK Petition at 7 & n.4. NEXTLINK contends that accelerating the schedule will not be overly  X -burdensome because incumbent LECs may still seek a waiver.@P h  yO-ԍ NEXTLINK Reply at 23.@  X -xe102.` ` Several BOCs, GTE, USTA, and ALLTEL oppose accelerating the deployment  X-schedule for markets below the top 100 MSAs.Q  yO9"- x-ԍ NYNEX Opposition at 2; GTE Opposition at 1112; ALLTEL Opposition at 2. Specifically, BellSouth,  xGTE, NYNEX, and USTA argue that sufficient switch software may not be available to support an accelerated  xschedule. BellSouth Opposition at 6; NYNEX Opposition at 23; GTE Opposition at 1011; USTA Comments at  x4. Similarly, NYNEX suggests that any schedule modification should reflect the NANC's ability to accomplish its  yOY%-responsibilities. NYNEX Opposition at 23; see also GTE Opposition at 1314. BellSouth and GTE assert that accelerating deployment will impede the phased deployment and jeopardize carriers' ability to meet the"y<Q,-(-(ZZ-"  X-original schedule.R  yOy-ԍxBellSouth Opposition at 6; GTE Opposition at 1011; see also NYNEX Opposition at 2. GTE, USTA, Sprint, and Pacific argue that resources would be diverted from deployment in larger markets where competitors are more likely to be interested in  X-entering.SX  yO-ԍxGTE Opposition at 10; USTA Comments at 4; Sprint Opposition at 12; Pacific Comments at 2. BellSouth asserts that, if we add new central offices to the schedule, then we  X-should remove a corresponding number of central offices from the original schedule.MT  yOT-ԍxBellSouth Opposition at 67.M BellSouth also suggests that, if we add new central offices to the schedule, then failure to implement any of those additional MSAs according to deadlines on the original schedule  Xv-should not constitute a failure to meet a Section271 checklist requirement.@Uvx  yO -ԍxId. at 7.@ In response to ACSI's claim that the Commission's schedule discriminates against smaller markets, GTE asserts that the phased schedule takes into account the differing levels of local exchange competition in different areas, the burden on carriers serving multiple regions, and the fact  X -that more significant upgrades may be necessary for carriers operating in smaller areas.IV   yO-ԍxGTE Opposition at 1011.I  X -xf103.` ` USTA supports KMC's recommendation that LECs be able to submit requests for deployment in markets outside the 100 largest MSAs earlier than January 1, 1999, but proposes that such requests be fulfilled on a negotiated timetable subject to the decisions of each state commission, instead of by December 1998, or within 24 months, as suggested by  X-KMC.WX  yO-  ԍxUSTA Comments at 67. USTA proposes allowing each state commission and/or its workshop to evaluate  xevidence of local competition in areas within that state, and either accelerate or decelerate the schedule in those areas,  yOi-as long as the "overall burden" is not increased. Id. at 46. ALLTEL contends that accelerating the schedule will force carriers to file waivers  Xy-or seek suspensions of implementation.JXXy  yO-  ԍxALLTEL Opposition at 3. ALLTEL contends further that the present schedule does not prohibit competitors  xfrom using the Section 252 negotiation process to enter into number portability agreements prior to January 1999.  yOr-Id.J ALLTEL argues, moreover, that smaller providers should not be required to invest in number portability technologies until they have been  XK-proven reliable in larger markets.mYK  yO!-ԍxId. at 23. See also NTCA/OPASTCO Reply at 34.m  X-xg104.` ` Discussion. We deny the petitions for reconsideration that advocate: (1)  X-accelerating deadlines for certain MSAs;fZh  yO&-ԍxSee ACSI Petition at 912; ICG Comments at 34.f (2) allowing carriers with operational networks in the 100 largest MSAs and the authority to provide local exchange service to request"=Z,-(-(ZZE-" portability in any MSA in the 100 largest MSAs beginning July1, 1997, and requiring LECs  X-to fulfill such requests on a specified date six or more months in the future;|[  yOb-ԍxSee ACSI Petition at 912; ALTS Opposition at 6; ICG Comments at 34.| (3) adding  X-MSAs outside the largest 100 MSAs to the initial deployment schedule;T\X  yO-ԍxSee NEXTLINK Petition at 56.T or (4) combining  X-the deadlines of consolidated MSAs.o]  yOT-ԍxSee ICG Comments at 34 & n.1; ACSI Petition at 10 n.16.o The current schedule is based on the projected  X-availability of switch software,^x  yO -  ԍxSee First Report & Order, 11 FCC Rcd at 839395; see also BellSouth Opposition at 6; GTE Opposition at 1011; NYNEX Opposition at 23. and recognizes the burden on carriers serving multiple regions and the fact that more significant upgrades may be necessary for carriers operating in  Xv-smaller areas._v  yO-ԍxSee First Report & Order, 11 FCC Rcd at 839395; see also GTE Opposition at 1011. Petitioners have not made a showing that the necessary software, hardware, and other resources will be available earlier in areas originally scheduled for later deployment, or will be available in quantities sufficient to support deployment in additional areas, particularly in areas outside the 100 largest MSAs. If such hardware and software is not available for deployment early enough or in sufficient quantities to support deployment in additional areas, then accelerating deployment deadlines for smaller MSAs may divert these limited resources from deployment in other, larger MSAs, and thus delay deployment of  X -number portability where a greater population might benefit from competition.` `  yO-  ԍxSee BellSouth Opposition at 6; GTE Opposition at 10; USTA Comments at 4; Sprint Opposition at 12; Pacific Comments at 2.  X -xh105.` ` For the reasons stated above, we also reject ACSI's request to require deployment in PhaseI in certain additional markets in which the incumbent LECs are not BOCs. In addition, we continue to believe that nonBOC incumbent LECs, most of which have more limited resources than the BOCs, should have additional time to upgrade and test  XK-their networks.OaK  yO-ԍxSee CBT Comments at 34.O Moreover, we conclude above that LECs need deploy number portability in the 100 largest MSAs only in switches for which another carrier has made a specific request  X-for the provision of portability.fbH  yO"-ԍxSee supra  DEPLOY UPON REQUEST60.f Requiring that additional MSAs be deployed in PhaseI does not give sufficient notice to carriers or states to establish switchrequesting procedures in MSAs for which they had no previous notice that deployment was required in PhaseI. We also decline to adopt USTA's proposal that state commissions be free to accelerate the deployment schedule. While we are sympathetic to the desires of some states to advance deployment where actual competitive interest exists, we conclude that the schedule adopted in">b,-(-(ZZ-"  X-the First Report & Order, as modified in this First Reconsideration Order, represents a reasonable balancing of competing interests, and carriers need to have certainty that these are  X-the requirements with which they must comply. Our First Report & Order was silent on the issue of whether states could accelerate the deployment schedule. We therefore grandfather any state decisions to accelerate deployment for a particular market from one phase to an  X-earlier phase that were adopted prior to release of this First Reconsideration Order.  X_-xi106.` ` We do not prohibit LECs from agreeing to accelerate implementation, either for specific MSAs or specific switches within MSAs. We find, however, that acceleration of our schedule is more properly determined by private agreements among carriers. Competitive LECs are free to negotiate with incumbent LECs for deployment of number portability ahead  X -of our schedule.Rc  yO| -ԍxSee ALLTEL Opposition at 3.R Moreover, to the extent that carriers agree to "swap" the implementation deadlines for specific MSAs or switches within MSAs, they can jointly file specific waiver  X -petitions to do so.Xd X  yO-ԍxSee NEXTLINK Petition at 78 n.4.X  X -xj107.` ` We grant in part the petitions of ACSI, KMC, and NEXTLINK to allow requests for deployment of number portability in areas outside the 100 largest MSAs to be submitted earlier than January1, 1999. We therefore modify our rules to permit carriers to submit requests for deployment of number portability in areas outside the 100 largest MSAs at any time. We decline, however, to require that deployment be completed within six months of request for requests filed prior to January 1, 1999. This modification to our rules will benefit all parties, because receiving earlier notice to upgrade switches will likely ease a LEC's compliance burden and help to ensure that competing carriers will receive portability within the time requested. Finally, we clarify that, contrary to KMC and ACSI's view, our current schedule does not leave an implementation gap between December31, 1998, and July1, 1999, since implementation of requests for deployment of number portability in areas outside the 100 largest MSAs filed on or before January1, 1999, will occur during the first six months of 1999. KMC and ACSI's suggestion that we permit requests for markets outside the 100 largest MSAs beginning July1, 1998, and require fulfillment of those requests within six months, would actually require that those smaller markets be completed at the same time as the MSAs in the last phase of our deployment schedule, thus sharply increasing the burden  X7-on carriers during that phase.ce7  yO!-ԍxSee ACSI Petition at 10; KMC Petition at 12.c  X -XxX` ` 5.X Exemptions for Rural and/or Smaller LECs (#  X-xk108. FRFA 1 ` ` Pleadings. JSI, NECA, and NTCA/OPASTCO argue that requiring rural LECs to provide number portability where no competitor has requested it will burden rural LECs" ?xe,-(-(ZZ-"  X-significantly without benefitting the public by increasing competition.fX  yOy-  kԍxJSI Petition at 9 (asserting that the cost of implementation in areas in which there is no competition will  xZresult in higher rates for consumers); NECA Petition at 3; NTCA/OPASTCO Petition at 34; NTCA/OPASTCO  yO -Reply at 14. See also USTA Comments at 2; ALLTEL Opposition at 45; Sprint Opposition at 13. NECA and NTCA/OPASTCO state that requiring rural LECs to provide portability absent such a request contravenes our intent to let the pace of competitive entry into local markets determine the  X-need for number portability.`g  yOT-ԍxNECA Petition at 2; NTCA/OPASTCO Petition at 3.` NTCA/OPASTCO asserts that these small businesses do not  X-have the resources to test portability technologies.Khx  yO -ԍxNTCA/OPASTCO Reply at 45.K GTE argues that the same concerns that prompted us to forego an implementation schedule for areas outside the 100 largest MSAs,  Xv-i.e., lack of imminent competition and the need for significant network upgrades, apply to  X_-smaller offices within the 100 largest MSAs.Fi_  yO-ԍxGTE Petition at 910.F JSI, NECA, and NTCA/OPASTCO contend that the need for such an exemption is apparent in Congress' Joint Explanatory Statement which states, "Duties imposed under new Section 251(b) make sense only in the context of a  X -specific request from another telecommunications carrier ...."^jX   yOc-  ԍxJSI Petition at 35 (quoting S. Conf. Rep. No. 104230, 104th Cong., 2d Sess. 121 (1996));  yO+- xNTCA/OPASTCO Petition at 3 (same); NECA Petition at 34 (quoting H.R. Report 104458, Joint Explanatory Statement of the Committee of Conference at 121).^  X -xl109.` ` JSI and NTCA/OPASTCO suggest that we exempt rural LECs operating within the 100 largest MSAs from complying with the implementation deadlines until receipt of a  X -request for deployment.ak  yO'-ԍxJSI Petition at 78; NTCA/OPASTCO Petition at 2.a Several other parties agree with JSI and NTCA's suggestion, and would expand the exemption to include: (1) LECs with less than fivepercent of their  X-subscribers in an MSA, or LECs with only 10percent of their access lines within an MSA;xlXH  yO-  .ԍxUSTA Petition at 19. USTA argues that many LECs located within MSAs (1) do not provide service within  x;the MSA, (2) serve a small percentage of the MSA, or (3) have operations within the MSA which constitute a small  yO-percentage of the LEC's total operations. Id. at 18.x  Xy-(2) rural LECs with study areas that only partially overlap one of the 100 largest MSAs;]mXyh  yO!-  \ԍxNECA Petition at 23 (claiming that of the 115 rural LECs operating in the 100 largest MSAs, only four  xZare completely contained within a top 100 MSA, and the remaining 111 overlap a top 100 MSA by only a small fraction of their total customer base); JSI Petition at 8.] or  Xb-(3) any carrier with less than twopercent of the nation's access lines.Hnb  yO%-ԍxALLTEL Opposition at 5.H JSI further argues that we should not apply our deployment requirements to rural LECs until there is factual"K@n,-(-(ZZ-" evidence that number portability is technologically feasible, and will not disproportionately  X-burden rural LECs.o  yOb-  ԍxJSI Petition at 7. JSI argues that we have not justified expediting implementation for a rural LEC solely  yO*-because it is located within a top 100 MSA. Id. at 6. GTE suggests that, if no competitors express an interest in entering the market, and the state commission does not object, smaller LECs should be allowed to present a waiver to us that, if approved, would exempt them from portability requirements until six  X-months after a request is made.p   yOu-  ԍxGTE Petition at 9. See also GTE Opposition at 15. GTE asserts that permitting these waivers would free  yO= -LECs to devote resources to areas in which competition is more immediate. Id. CBT suggests that we exempt from the implementation schedule carriers granted a suspension or modification of the number portability requirements  Xv-under Section251(f)(2) until the state commission removes the suspension.Cqvx  yO -ԍxCBT Comments at 4.C  XH-xm110.` ` USTA urges us to exempt from the deployment schedule rural LECs that are  X1-exempt from interconnection requirements under Section251(f).~r1  yO-  ԍxUSTA Comments at 3. USTA suggests that, should a state commission end the interconnection exemption  xfor a particular rural provider, then the commission should determine that provider's deployment schedule. USTA  xargues that this is necessary to preserve state authority over the full range of interconnection issues affecting smaller  yOB- xand rural LECs. Id. at 3. See also Pacific Comments at 4 (claiming that implementation makes sense only in areas where interconnection has been requested).~ JSI goes further and argues that Section251(f)(1) prohibits the imposition of number portability requirements on rural LECs because rural LECs are automatically exempt from the interconnection  X -requirements of Section251(c).Es  yOU-ԍxJSI Petition at 34.E JSI states that this exemption from interconnection requirements permits us to impose number portability requirements upon rural LECs only to the extent it is technically feasible for rural LECs to provide portability without upgrading their networks to utilize databases, installing SS7 or AIN capabilities, or installing and  X-furnishing functions requiring new switching software.ftH  yO-ԍxId. at 3. See also NECA Petition at 34.f JSI adds that this exemption may be  Xy-terminated only by a state commission.Cuy  yO -ԍxJSI Petition at 4.C In addition, JSI argues, the Commission recognized  Xb-in the First Report & Order that carriers meeting the 251(f) criteria may be exempt from  XK-number portability requirements.wvXKh  yOd#-  zԍxId. at 5 (citing First Report & Order, 11 FCC Rcd at 8396). But see USTA Comments at 2 (claiming that  xzthe Section251(f)(1) exemption covers only Section 251(c) obligations, not Section 251(b) obligations); NTCA/OPASTCO Petition at 2 n.3 (same); ALLTEL Opposition at 4.w "4Av,-(-(ZZ-"Ԍ X-xn111.` ` NTCA/OPASTCO claims that the First Report & Order's Final Regulatory Flexibility Analysis does not address the impact of the rules on small incumbent LECs, and is  X-thus inconsistent with the Local Competition Order.Rw  yOK-ԍxNTCA/OPASTCO Petition at 4 & n.6.R NTCA/OPASTCO suggests that exempting rural LECs from number portability requirements absent a specific request would  X-fulfill our responsibility under the Regulatory Flexibility Act.@xX  yO-ԍxId. at 5.@  Xv-xo112.` ` Time Warner and MCI oppose any "blanket waiver" of number portability  X_-requirements for smaller and/or rural LECs.pyX_  yO -  yԍxTime Warner Comments at 7; MCI Opposition at 18. But see USTA Reply at 9 (protesting that recognizing  xthat failure to receive an interconnection request constitutes "extraordinary circumstances beyond the LEC's control" justifying a waiver does not constitute a "blanket waiver").p MCI argues that such waivers will "lessen the  XH-likelihood" that competition will ever reach areas served by smaller and rural providers.z H  yO-  ԍxMCI Opposition at 1819. MCI argues, moreover, that once a small office receives a bona fide request, it  xYshould be required to deploy portability within one or two months, not six months as proposed by GTE. MCI Reply  xat 6 n.12. According to MCI, the LEC will already have deployed portability within the MSA, and, therefore, can  yOY-deploy portability in a new office quickly. Id. MCI claims that a blanket waiver is unnecessary, because smaller and rural LECs can receive  X -waivers under the statutory provision or under the procedure described in the First Report &  X -Order.F{  yO-ԍxMCI Opposition at 18.F Time Warner argues that any blanket waiver, either for technical difficulties or for a carrier's smaller size, will be overly inclusive and result in unnecessary delay, and that carriers should have to file individually for waivers that demonstrate why they should be  X -exempt from the number portability deployment schedule.M|  yO-ԍxTime Warner Comments at 67.M  X-xp113.` ` Discussion. As set forth above, we grant the petitions to limit deployment of portability to those switches for which a competitor has expressed interest in deployment by concluding that LECs need only provide number portability within the 100 largest MSAs in switches for which another carrier has made a specific request for the provision of  X4-portability.f}4  yO!-ԍxSee supra  DEPLOY UPON REQUEST60.f We find that this modification to our rules should address the concerns of parties that urge us to waive number portability requirements for rural and/or smaller LECs  X-serving areas in the largest 100 MSAs until receipt of a request.~  yOW%-  ԍxSee JSI Petition at 7; NTCA/OPASTCO Petition at 3; NECA Petition at 2; GTE Petition at 9; NTCA/OPASTCO Reply at 12; ALLTEL Opposition at 45; USTA Petition at 1819. "B~,-(-(ZZ'-"Ԍ X-xq114.NO BLANKET WAIVER` ` We deny the petitions that request a blanket waiver of our number portability requirements for rural and/or smaller LECs that receive a request for deployment in one of their switches. We find that such a blanket waiver is unnecessary and may hamper the development of competition in areas served by smaller and rural LECs that competing carriers  X-want to enter.  yO-  ԍxSee MCI Opposition at 1819. Moreover, the Commission recognized in the First Report & Order that some  xsmaller LECs may face greater burdens in upgrading their networks to implement number portability. The phased  xwdeployment schedule also recognizes that carriers in areas outside the 100 largest MSAs are more likely to be smaller  x<or rural LECs, and thus requires that portability be deployed earlier in the more populous MSAs, and deployed in  yO= -smaller markets only upon receipt of a specific request. First Report & Order, 11 FCC Rcd at 839395. If, as petitioners allege, competition is not imminent in the areas covered by  X-rural/smaller LEC switches,x  yO -ԍxSee GTE Petition at 8; GTE Opposition at 15; JSI Petition at 9; NTCA/OPASTCO Reply at 24. then the rural or smaller LEC will not receive requests from competing carriers to implement portability, and thus will not need to expend its resources, until competition actually develops in its service area. In addition, by that time extensive noncarrierspecific testing will likely have been done, and carriers' testing costs will likely be  X1-smaller.K1  yO-ԍxNTCA/OPASTCO Reply at 45.K  X -xr115.2 AVENUES` ` Further, to the extent that portability is requested in a rural or smaller LEC's switch, and that LEC has difficulty complying with the request, it has two avenues for relief.  X -Pursuant to the First Report & Order, a LEC may apply for an extension of time on the basis of extraordinary circumstances beyond its control that prevent it from complying with the  X -Commission's deployment schedule.`   yO-ԍxFirst Report & Order, 11 FCC Rcd at 8397.` In addition, under Section251(f)(2), a LEC with fewer than two percent of the nation's subscriber lines installed in the aggregate nationwide (an "eligible LEC") may petition the appropriate state commission for suspension or  Xb-modification of the requirements of Section251(b).Gb(  yO;-  ԍx The state commission shall grant such petition to the extent that, and for as long as, the state commission  xdetermines that such suspension or modification: (A) is necessary to avoid a significant adverse economic impact  xhon end users, to avoid imposing an unduly economically burdensome requirement, or to avoid imposing a technically  xinfeasible requirement; and (B) is consistent with the public interest, convenience and necessity. 47 U.S.C. 251(f)(2).G The state commission is required to act  XK-on the petition within 180 days.:K  yO!-ԍxId.: We believe eligible LECs will have sufficient time to obtain any appropriate Section251(f)(2) relief as provided by the statute, especially since the"4Ch,-(-(ZZH-" state commission can suspend the application of our deployment deadlines to that LEC while  X-it is considering the LEC's petition for suspension or modification of our requirements.   yOb-  ԍxSection 251(f)(2) provides that "[t]he State commission shall act upon any petition filed under  x[Section251(f)(2)] within 180 days after receiving such petition. Pending such action, the State commission may  xsuspend enforcement of the requirement or requirements to which the petition applies with respect to the petitioning  yO-carrier or carriers." Id.  X-xs116.` ` If, however, a competitor is interested in number portability in a particular switch operated by a rural or smaller LEC, and the LEC cannot demonstrate extraordinary circumstances justifying an extension of our deployment requirements, and the state commission denies a Section251(f)(2) request for suspension or modification, we find no  X_-statutory basis for excusing such a LEC from its obligations to provide number portability.z_  yO -  ԍxIn addition, issuance of a blanket exemption in this proceeding would be inconsistent with the Local  yO - xCompetition Order, in which the Commission generally declined to adopt national rules regarding Section 251(f),  yOP- xor provide for different treatment of rural and smaller carriers. Implementation of the Local Competition Provisions  yO- xin the Telecommunications Act of 1996, First Report and Order, 11 FCC Rcd 15,499, 16,11819 (1996), motion for  yO- xstay of the FCC's rules pending judicial review denied, Implementation of the Local Competition Provisions in the  {O- xTelecommunications Act of 1996, Order, 11 FCC Rcd 11754 (1996), partial stay granted, Iowa Utilities Board v.  yOr-FCC, No. 96-3321, 1996 WL 589204 (8th Cir. 1996) (Local Competition Order). Rather, Congress established a specific procedure under which state commissions are empowered to make casebycase decisions on the application of number portability requirements to eligible LECs pursuant to Section251(f)(2), based on the particular facts and circumstances presented. Eligible LECs that have been granted suspension or modification of number portability requirements under Section 251(f)(2) are not bound by our implementation  X -schedule until the state commission removes the suspension.M  yOx-ԍxSee CBT Comments at 4.M  X -xt117.` ` The comments of some parties in this proceeding appear to reflect a  X-misapprehension of the scope of Section251(f).[X  yO-  yԍxSee JSI Petition at 3. But see NTCA/OPASTCO Petition at 2 n.3 (claiming that the Commission incorrectly  yO- xKasserted in the First Report & Order that Section 251(f)(1) per se exempted rural LECs from number portability requirements).[ Sections251(f)(1) and 251(f)(2) apply to different classes of carriers, and provide different types of relief. Section251(f)(1) applies only to rural LECs, and offers an exemption only from the requirements of Section251(c). In contrast, Section251(f)(2) applies to all LECs with less than two percent of the nation's subscriber lines. In addition, Section251(f)(2) establishes a procedure for requesting  X-suspension or modification of the requirements of Sections251(b) and 251(c). Number portability is an obligation imposed by Section251(b). Because Section251(f)(1) does not exempt rural LECs from the requirements of Section251(b), there is no exemption for rural"D,-(-(ZZ-"  X-LECs of their number portability obligations under Section251(f)(1).  yOy-  ԍxWe note, however, that Section 251(f)(1) does exempt rural carriers from the duty to negotiate in good faith over the terms and conditions of agreements to fulfill the duties of Section251(b), including number portability. The only statutory avenue for relief from the Section251(b) requirements specifically for eligible LECs is to request suspension or modification of the number portability requirements under the procedure established by Section251(f)(2).  X-xu118.` ` The plain text of the statute refutes JSI's argument that Section251(f)(1)  Xv-exempts rural LECs from number portability requirements.Ov   yOG -ԍxSee JSI Petition at 34.O JSI states that the Section251(f)(1) exemption from interconnection requirements permits us to impose number portability requirements upon rural LECs only to the extent it is technically feasible for rural LECs to provide portability without having to upgrade their networks to utilize databases, install SS7 or AIN capabilities, or install and furnish functions requiring new switching  X -software.EX   yOd-  ԍxId. at 3. USTA advocates, similarly, that any carrier that is exempt from the interconnection requirements  xunder 47 U.S.C. 251(f) should be automatically exempt from the implementation schedule. USTA Comments at 3; USTA Reply at 9.E JSI adds that this exemption may be terminated only by a state commission.C   yO-ԍxJSI Petition at 4.C  X -xv119.` ` Because Sections251(b) and 251(c) are separate statutory mandates, the requirements of Section251(b) apply to a rural LEC even if Section251(f)(1) exempts such LECs from a concurrent Section251(c) requirement. To interpret Section251(f)(1) otherwise would undercut Section251(b) and, in this case, would effectively preclude any provision of longterm number portability by rural LECs until termination of the Section251(f)(1) exemption by a state commission. We find such an interpretation to be contrary to Congress's mandate that all LECs provide number portability, and Congress's exclusion of the Section251(b) obligations, including the duty to provide number portability, from the Section251(f)(1) exemption for rural LECs.  X-xw120.` ` Moreover, under JSI's interpretation, the only carriers that would have to provide number portability would be incumbent LECs that are not exempt under Section251(f)(1). Nonincumbent LECs, as well as rural incumbent LECs that are exempt under Section251(f)(1), would not have to satisfy the requirements of Section251(b) and, consequently, would not have to provide number portability. This directly contradicts Section251(b)(2), which specifically requires "all local exchange carriers" to provide number  Xe-portability.Je`  yOv%-ԍx47 U.S.C.  251(b)(2).J Section251(c) sets forth "additional obligations" that apply only to incumbent LECs, whereas Section251(b) sets forth obligations that apply to all LECs. "7E ,-(-(ZZ-"Ԍ X-xx121.` ` Even if we were to agree with JSI's statutory interpretation that rural LECs that are exempt from the Section251(c) requirements are also exempt from any requirements of Sections251(b) and (c) that overlap, petitioners have not demonstrated that the Section251(b) and (c) obligations in fact overlap. To provide longterm number portability under Section251(b)(2), LECs obviously must install and use any necessary databases, SS7 or AIN capabilities, or switching software. Section251(c), in contrast, requires incumbent LECs to  Xv-provide unbundled access to network elements, including callrelated databases.Tv  yO-ԍxSee 47 U.S.C.  251(c)(3).T Number portability does not require any provision of unbundled access to these elements. Moreover, to provide number portability, carriers can interconnect either directly or indirectly as required  X1-under Section251(a)(1).1X  yO: -  ԍxSee 47 U.S.C.  251(a)(1). For example, a smaller rural carrier and a competing carrier might interconnect  xindirectly by both establishing direct connections with a third carrier and routing calls to each other through that third  x-carrier. The smaller rural carrier could then provide portability by performing its own database queries and then  xrouting the call to the competing carrier through that third carrier. Another option would be for the smaller rural LEC to contract with that third carrier to perform its queries and the necessary routing. Section251(c), in contrast, imposes an additional requirement on incumbent LECs to provide "equal" interconnection at "any technically feasible point within  X -the carrier's network,"T   yO-ԍxSee 47 U.S.C.  251(c)(2).T which a carrier does not need to provide number portability. Thus, Sections251(a) and (b), not Section251(c), require that carriers interconnect and install and  X -use necessary network elements to provide number portability.   yO-  ԍxRural LECs are not exempt from Section251(a) or (b) requirements under Section251(f)(1). See 47 U.S.C.  yO- 251(f)(1); Local Competition Order, 11 FCC Rcd at 15,991. We therefore deny JSI and USTA's request to "automatically exempt" rural LECs from our number portability requirements to the extent that they are exempt from the requirements of Section251(c) under  X-the provisions of Section251(f)(1).a  yO1-ԍxSee JSI Petition at 7; USTA Comments at 3.a  Xb-xy122. FRFA 2 ` ` We also deny the requests that we clarify that smaller and/or rural LECs serving areas that only partially overlap one of the 100 largest MSAs need not deploy number  X4-portability until receipt of a bona fide request.x4  yOe -ԍxSee NECA Petition at 23; JSI Petition at 8; USTA Petition at 19.x We believe that, when determining whether a suspension or modification is necessary to avoid imposing an unduly economically burdensome requirement, pursuant to Section251(f)(2), state commissions would likely  X-consider whether an eligible LEC's presence in the MSA is truly de minimus and whether such a LEC is entitled to a suspension or modification of the number portability requirements on this basis. "F,-(-(ZZ-"Ԍ X-xz123.` ` Finally, NTCA/OPASTCO erroneously claims that the First Report & Order violates the Regulatory Flexibility Act (RFA) because its Final Regulatory Flexibility Analysis (FRFA) does not address the impact of our rules on small incumbent LECs, and is, therefore,  X-inconsistent with the Local Competition Order.\  yO4-ԍxSee NTCA/OPASTCO Petition at 4 & n.6.\ As we stated in the First Report & Order's FRFA, small incumbent LECs do not qualify as small businesses because they are dominant  X-in their field of operation.`X  yO-ԍxFirst Report & Order, 11 FCC Rcd at 8487.` The Local Competition Order's FRFA likewise set forth the Commission's view that small incumbent LECs are not subject to regulatory flexibility analyses because they are not small businesses due to their dominance in their field of  XH-operation.eH  yO -ԍxLocal Competition Order, 11 FCC Rcd at 16,145.e The Commission in that proceeding specifically stated that it was including small incumbent LECs in its FRFA only because two parties had especially questioned that conclusion in that proceeding's Initial Regulatory Flexibility Analysis (IRFA), and it wanted  X -to "remove any possible issue of RFA compliance.": x  yO,-ԍxId.: In contrast, no party commented on  X -the IRFA in this proceeding.`   yO-ԍxFirst Report & Order, 11 FCC Rcd at 8486.` We attach, nevertheless, as AppendixD a Supplemental Final Regulatory Flexibility Analysis that further explains our analysis of our rules' impact upon rural and smaller carriers and our basis for selecting the particular options that we have selected. This analysis takes into account NTCA/OPASTCO's specific claim raised in its  X-petition for reconsideration, in order to "remove any possible issue of RFA compliance."o  yO-ԍxCf. Local Competition Order, 11 FCC Rcd at 16,145.o We also note that our establishment of a procedure whereby number portability would only be deployed in requested switches effectively grants the relief sought by NTCA/OPASTCO, the  XK-sole petitioner on this issue.^XK(  yO$-  ]ԍxNTCA/OPASTCO suggests that exempting rural LECs from number portability requirements absent a  xspecific request would fulfill our responsibility under the Regulatory Flexibility Act. NTCA/OPASTCO Petition at  yO-5.#x6X@`7X@#^  X-Xx X` ` 6.X Implementation Requirements for Intermediate (N1) Carriers (#  X-x{124.` ` Pleadings. Pacific urges us to require all intermediate (N1) carriers, including interexchange carriers, to implement the capability to query number portability databases in  X-order to route calls properly.H  yO%-  ԍxPacific Petition at 1213. "N1 carrier" refers to the carrier through which the call passes immediately before reaching the terminating service provider. Pacific expresses concern that, if an intermediate carrier has"G,-(-(ZZ-" not implemented portability, an interLATA call will be routed to the original terminating LEC, which must then query the database and reroute the call, in violation of performance  X-criterion four.   yOK-  >ԍxId. The fourth performance criterion mandates that any longterm number portability method must not  xrequire telecommunications carriers to rely on databases, other network facilities, or services provided by other  yO- xtelecommunications carriers in order to route calls to the proper termination point. First Report & Order, 11 FCC Rcd at 8378. Pacific urges us to clarify that the original terminating LEC will not be responsible for handling queries not performed by an intermediate carrier that lacks the  X-capability to query number portability databases.H  yO -ԍxPacific Petition at 13.H Pacific further asserts that requiring the  X-original terminating LEC to query all interLATA and intraLATA calls will increase its implementation costs, and limit the ability of those LECs to meet the implementation  X_-schedule.:_@  yOP-ԍxId.: NYNEX asserts that granting Pacific's request will reduce the stress on the  XH-terminating LEC's signalling infrastructure by reducing that LEC's database queries.GH  yO-ԍxNYNEX Opposition at 3.G NYNEX urges, in the alternative, that we confirm that terminating LECs may charge N1 carriers for performing the query, where the N1 carrier cannot or will not perform the query  X -itself.I `  yO-ԍxId. at 34 & n.13.I MCI claims that Pacific's request is unnecessary, since interexchange carriers already  X -plan to deploy number portability as soon as possible.  yO-  LԍxMCI Opposition at 19. MCI claims that it, AT&T, Sprint, and other interexchange carriers have frequently  x,announced their intentions to deploy portability in their networks as soon as it is available. MCI argues, moreover,  x<that interexchange carriers are strongly motivated to deploy number portability because it would enable them to  xescape paying their current high LEC access charge rates by routing calls to competitive LECs that will likely offer  yO-terminating access at charges more closely related to costs. Id.  X -x|125.` ` Discussion. We deny Pacific's request that we require all N1 carriers, including interexchange carriers, to meet the implementation schedule we established for  X-LECs.i  yO-ԍxSee Pacific Petition at 13; NYNEX Opposition at 3.i Such a requirement is not mandated by the 1996 Act, which subjects only LECs, not interexchange carriers engaged in the provision of interexchange service, to our number  Xb-portability requirements.b0  yOC#-ԍx47 U.S.C. 251(b)(2); see also First Report & Order, 11 FCC Rcd at 8453. Moreover, petitioners have not demonstrated a need for us to impose such requirements under our independent rulemaking authority under Sections1, 2,  X4-and 4(i) of the Communications Act of 1934, as amended.U4  yO&-ԍx47 U.S.C.  151, 152, 154(i).U In that regard, we are not"4HP,-(-(ZZ-" convinced that Pacific's hypothetical situation, whereby the N1 carrier would not perform any queries and the original terminating LEC would thus have to perform all the queries not performed by the originating LEC, will arise often. The industry already appears to favor using the N1 scenario, under which the N1 carrier performs the database query, as indicated in the majority of comments on call processing scenario issues received pursuant to the  X-original Notice of Proposed Rulemaking.`  yO-ԍxFirst Report & Order, 11 FCC Rcd at 8376.` The vast majority of interLATA calls are routed  Xv-through the major interexchange carriers,rvX  yO -  =ԍxPercentage of Total Toll Service Revenues for 1995: AT&T 45.8%; MCI 15.4%; Sprint 8.7%; LDDS 4.3%;  yOG - xall other carriers 12.2%; LECs 13.5%. Table 1.4 Statistics of Communications Common Carriers, Federal  xCommunications Commission, 1995/1996 ed. The preceding figures actually understate the interexchange carriers'  xwshare of interLATA traffic, because the percentages are based on total toll traffic, which includes (particularly in the case of the BOCs) a large measure of intraLATA toll.r and the two largest interexchange carriers, at least,  X_-claim they plan to deploy portability as soon as possible.X_  yO-  ԍxSee MCI Opposition at 19 (claiming that interexchange carriers have a powerful incentive to escape access  yO- xcharges); AT&T November 12, 1996 Ex Parte Filing at 1; MCI Ex Parte Presentation at 1, CC Docket No. 95116,  yO-filed Nov.6, 1996 (MCI November6, 1996 Ex Parte Filing). Therefore, most interLATA calls will be queried by the major interexchange carriers, not the incumbent LECs. Moreover, as  X1-we stated in the First Report & Order, we wish to allow carriers the flexibility to choose and negotiate among themselves which carrier shall perform the database query, according to what  X -best suits their individual networks and business plans.` (  yO-ԍxFirst Report & Order, 11 FCC Rcd at 8384.` Finally, we decline to address Pacific's argument that, if the terminating carrier is forced to perform queries, that would  X -violate our fourth performance criterion.R  yO>-ԍxSee Pacific Petition at 13.R Since we are eliminating our fourth performance  X -criterion,d H  yO-ԍxSee supra  CRIT 4 ELIMINATED19.d Pacific's argument is moot.  X-x}126.` ` We clarify, however, per NYNEX's request, that if an N1 carrier is designated to perform the query, and that N1 carrier requires the original terminating LEC to perform the query, then the LEC may charge the N1 carrier for performing the query, pursuant to guidelines the Commission will establish in the order addressing longterm number portability cost allocation and recovery. /J:\POLICY\NUM_PORT\RECON1\ORDER\SCH.ORD/ 4J:\POLICY\NUM_PORT\RECON1\ORDER\WIRELESS.ORD4 "I,-(-(ZZ-"Ԍ X-x` ` C.X Implementation Schedule for Wireless Carriers (#  X-x~127.` ` Background. In the First Report & Order, we required all cellular, broadband  X-PCS, and covered SMR carriers@  yO4-  \ԍxThe term "covered SMR" means either 800 MHz and 900 MHz SMR licensees that hold geographic area  xlicenses or incumbent wide area SMR licensees that offer realtime, twoway switched voice service that is  xlinterconnected with the public switched network, either on a standalone basis or packaged with other  xtelecommunications services. This term does not include local SMR licensees offering mainly dispatch services to  xspecialized customers in a noncellular system configuration, licensees offering only data, oneway, or stored voice  xJservices on an interconnected basis, or any SMR provider that is not interconnected to the public switched network.  x47 C.F.R. 52.1(c). We note that several parties have petitioned for reconsideration of the definition of "covered SMR." We will address this issue in a subsequent order. to have the capability of querying the appropriate number portability database systems in order to deliver calls from their networks to ported numbers  X-anywhere in the country by December 31, 1998.y  yO-ԍxFirst Report & Order, 11 FCC Rcd at 8439; 47 C.F.R. 52.11(b).y These wireless carriers may implement the upgrades necessary to accomplish the queries themselves, or they may make arrangements  X_-with other carriers to provide that capability.c_`  yOp-ԍxFirst Report & Order, 11 FCC Rcd at 843940.c In addition, wireless carriers subject to our rules are required to offer service provider portability throughout their networks, including the  X1-ability to support roaming, by June 30, 1999.\1  yO-ԍxId. at 8440; 47 C.F.R. 52.11(a).\ In the First Report & Order, we delegated authority to the Chief, Wireless Telecommunications Bureau, to waive or stay any of the dates in the implementation schedule for a period not to exceed nine months, and to establish  X -reporting requirements in order to monitor the progress of wireless carriers.  yO-ԍxFirst Report & Order, 11 FCC Rcd at 844041; 47 C.F.R. 52.11(c), (e). In the event a carrier subject to these requirements is unable to meet the Commission's deadlines for implementing a longterm number portability method, it must file a petition to extend the time by which implementation must be completed with the Commission at least 60 days in advance of the deadline, along with an explanation of the circumstances and the need for such an  Xy-extension.yy  yO:-ԍxFirst Report & Order, 11 FCC Rcd at 8441; 47 C.F.R. 52.11(d).y  XK-x128.` ` Pleadings. Several parties urge the Commission to modify the number  X4-portability implementation schedule set forth in the First Report & Order for CMRS providers. AirTouch and GTE reason that the wireless industry is behind the wireline industry in considering how to implement number portability and, moreover, faces special  X-technical challenges.  yO@&-ԍxAirTouch Petition at 1416; GTE Petition at 2123; see also CTIA Petition at 57; SBC Petition at 1213. These parties assert that wireless carriers need to resolve various technical issues before implementing number portability, including establishing the standard"J0,-(-(ZZ-"  X-for the intelligent wireless network, and redesigning network protocols and support systems.c  yOy-ԍxAirTouch Petition at 1516; GTE Petition at 2223.c GTE urges the Commission to allow enough time for wireless carriers to test thoroughly  X-number portability to ensure network integrity.GX  yO-ԍxGTE Petition at 2224.G  X-x129. ` ` AirTouch, CTIA, and SBC argue that the Commission should not limit to nine months the authority of the Chief, Wireless Telecommunications Bureau, to grant extensions  Xv-of the schedule set forth the First Report & Order.v  yO -  jԍxAirTouch Petition at 1314; CTIA Petition at 78; SBC Petition at 1314. See also RCA Reply at 23; RTG Comments at 35. CTIA argues that the ninemonth period within which the Chief, Wireless Telecommunications Bureau, may waive or stay the schedule is arbitrary because it is unsupported by the record, is not predicated on any analysis of industry's ability to comply with the schedule, and may not allow industry and the Wireless  X -Telecommunications Bureau enough time to determine CMRS carriers' ability to comply.y @  yO -ԍxCTIA Petition at 57. See also RCA Reply at 5; RTG Comments at 5.y  X -GTE urges the Commission to repeal the deadlines set forth in the First Report & Order  X -altogether and instead establish target dates.D   yOm-ԍxGTE Petition at 24.D  X -x130. ` ` BANM and CTIA claim that the schedule for CMRS providers is stricter than that for wireline service providers because CMRS providers must provide number portability  X-in areas outside the top 100 MSAs, even if it is not requested.`  yO-ԍxBANM Petition at 8; CTIA Petition at 2. See also RCA Reply at 23; RTG Comments at 34. CTIA urges the Commission to clarify whether, in addition to supporting nationwide roaming of CMRS customers with ported numbers, CMRS providers must implement full number portability in every market throughout the nation, or in only the largest 100 markets and any market where number  X4-portability is requested, by June 30, 1999.{4  yO-ԍxCTIA Petition at 3. See also RCA Reply at 23; RTG Comments at 35.{ If the Commission requires full number portability in all markets, CTIA argues, then the wireless schedule should be conformed to the wireline schedule so that CMRS providers need only provide full number portability in the largest 100 MSAs by December 31, 1998, and, thereafter, in smaller markets upon creation of  X-a regional database that includes both LEC and CMRS numbers.F  yO $-ԍxCTIA Petition at 35.F  X-x131. ` ` CTIA also reasons that, if a LEC does not provide number portability in an area, a regional database for that area may not exist, and the CMRS providers would have to"K,-(-(ZZ-"  X-establish their own individual databases.B  yOy-ԍxId. at 34.B BANM also points out that the regional databases that CMRS providers need to access may not all be in place, given the lack of any deadline  X-for establishment of the databases and the possibility of statewide databases.DX  yO-ԍxBANM Petition at 9.D In addition, argues BANM, because many CMRS providers' service areas are not defined by MSAs, they  X-often will not match the landline database regions.:  yO= -ԍxId.:  Xv-x132.` ` BANM urges the Commission to defer wireless number portability until  X_-wireline number portability is complete, and the record shows it is necessary.A_x  yO -ԍxId. at 10.A BANM claims that the 1996 Act's explicit exclusion of CMRS providers from the definition of a LEC, and standards set forth in earlier Commission orders, require the Commission to demonstrate a "clear cut need" before regulating CMRS providers, and that the Commission  X -did not do so.X   yO-  ԍxId. at 4 (citing Petition of the Connecticut Department of Public Utility Control to Retain Regulatory Control  yO- x<of the Rates of Wholesale Cellular Service Providers in the State of Connecticut, Report and Order, 10 FCC Rcd  yOL-7025, 7031 (1995) (CT DPUC Petition)). According to BANM, the record does not support the Commission's conclusion that CMRS number portability rules are competitively important or are justified on  X -other grounds.F (  yO-ԍxBANM Petition at 56.F If the Commission decides to maintain its rules, however, BANM argues, then no CMRS provider should have to provide number portability until June30, 1999, and then only (1) six months after receiving a request, and (2) after regional or statewide  X-databases are available.A  yO-ԍxId. at 10.A  Xb-x133.` ` MCI opposes what it characterizes as delay tactics by the CMRS providers and observes that their arguments are reminiscent of the arguments advanced by portability  X4-opponents in the 800 portability proceeding.F4H  yO-!-ԍxMCI Opposition at 20.F MCI argues that they do not provide a compelling reason for the Commission to retreat from its CMRS number portability  X-requirements.:  yO$-ԍxId.: MCI argues that the monitoring and reporting mechanism established during the implementation of 800 number portability worked well, and the similar mechanism established for CMRS number portability will provide an opportunity for the industry to"Lh,-(-(ZZ&-"  X-address implementation issues quickly.D  yOy-ԍxId. at 2021.D MCI opposes petitioners' requests for delay pending further study, establishing targets rather than deadlines, and granting authority to the Chief of the Wireless Telecommunications Bureau to defer indefinitely or suspend the portability  X-requirements.AX  yO-ԍxId. at 21.A TRA urges the Commission to resist efforts by CMRS providers to limit  X-number portability in wireless markets.D  yO= -ԍxTRA Comments at 14.D  Xv-x134. CMRS 1 ` ` Discussion. We decline at this time to alter the implementation schedule  X_-imposed by the First Report & Order for wireless carriers. We recognize that the wireless industry has lagged behind the wireline industry in developing a method for providing number portability, and that the wireless industry faces special technical challenges in doing so. Nonetheless, we find that the schedule for implementation of number portability by cellular, broadband PCS, and covered SMR providers is reasonable and takes into account the current stage of development for wireless number portability. We find that a period of nearly two years is sufficient for wireless carriers either to implement the upgrades necessary to perform the database queries themselves, or to make arrangements with other carriers to provide that capability. We also believe it is reasonable to expect wireless carriers to implement longterm service provider portability, including roaming, in their networks in a period of more than two years. We continue to believe the monitoring and reporting mechanism established in the  Xb-First Report & Order will ensure that wireless carriers will continue to work together to find solutions to technical problems associated with number portability, and to address quickly any  X4-implementation issues which may arise. As we provided in the First Report & Order, in the event a wireless carrier is unable to meet the Commission's deadlines for implementing a longterm number portability method, it may file a request for extension with the  X-Commission.`x  yO-ԍxFirst Report & Order, 11 FCC Rcd at 8441.` If it becomes apparent that the wireless industry is not progressing as quickly as necessary to meet the deadlines for providing querying capability and service provider portability, the Wireless Telecommunications Bureau Chief may waive or stay the  X-implementation dates for a period of up to nine months.F  yOc -ԍxId. at 844041.F We find that enough flexibility has been incorporated into the implementation schedule for wireless carriers, and that no modification is needed.  XN-x135. CMRS 2 ` ` We also decline to establish target dates in lieu of actual deadlines or to defer imposing number portability requirements on wireless carriers, as some petitioners have  X -suggested. As we stated in the First Report & Order, requiring cellular, broadband PCS, and covered SMR providers to provide number portability is in the public interest because these" M,-(-(ZZ-" entities are expected to compete in the local exchange market, and number portability will enhance competition among wireless service providers, as well as between wireless service  X-providers and wireline service providers.C  yOK-ԍxId. at 8433.C Service provider portability offered by wireless service providers will enable customers to switch carriers more readily and encourage the  X-successful entry of new service providers into wireless markets.FX  yO-ԍxId. at 843334.F Removing barriers, such as the requirement that customers must change phone numbers when changing providers, is likely to foster the development of new services and create incentives for carriers to lower prices and costs. In light of these positive competitive results that are likely to be produced, we continue to believe that number portability should be provided by wireless carriers with as little delay as possible. Setting specific deadlines, rather than amorphous "target dates," is consistent with this goal.  X -x136. CMRS 3 ` ` In response to requests by CTIA and BANM, we agree that some clarification of our requirements under the schedule is necessary. Contrary to the petitioners' claims, the schedule for CMRS providers is not stricter than the schedule for wireline service providers.  X -Some carriers apparently misunderstood our First Report & Order to require wireless providers to provide number portability in areas outside the largest 100 MSAs, even if number portability is not requested in those areas. We require cellular, broadband PCS, and covered SMR providers to have the capability to query the number portability databases nationwide, or arrange with other carriers to perform the queries, by December 31, 1998, in order to route calls from wireless customers to customers who have ported their numbers. We clarify that, by June 30, 1999, CMRS providers must (1) offer service provider portability in the 100 largest MSAs, and (2) be able to support nationwide roaming. Although we have not provided a specific phased deployment schedule for CMRS providers as we have for wireline carriers, we expect that CMRS providers will phase in implementation in selected switches over a number of months prior to the June30, 1999, deadline for deployment.  X-x137.` ` In addition, consistent with our modification to the wireline schedule deployment requirements, CMRS carriers need only deploy local number portability by this deadline in the 100 largest MSAs in which they have received a specific request at least nine  XN-months before the deadline (i.e., a request has been received by September30, 1998).; N  yO -  ԍxSee supra DEPLOY UPON REQUEST60. As explained above, for an MSA in the 100 largest MSAs, LECs need only provide number  yO!- xportability capability according to the implementation schedule, as modified in this First Order on Reconsideration,  xin those switches that provide service in that MSA for which carriers have, at least nine months before the  yO?#-deployment deadline, specifically requested deployment. Id.; As in the wireline context, any wireline carrier that is certified, or has applied for certification, to provide local exchange service in the relevant state, or any licensed CMRS provider, must be allowed to make a request for deployment; and cellular, broadband PCS, and covered SMR providers must make available lists of their switches for which deployment has and has not"N,-(-(ZZ<-"  X-been requested.f  yOy-ԍxSee supra DEPLOY UPON REQUEST60.f Additional switches within the 100 largest MSAs (i.e., those that are not requested initially) must be deployed upon request, after the June30, 1999, deadline for wireless carriers, within the same time frames that we adopt here for wireline carriers, unless  X-requesting carriers specify a later date.aX  yO-ԍxSee supra  ADD SWITCHES 165.a The time frames for deployment of additional wireless switches are as follows: (1) Equipped Remote Switches within 30 days; (2) Hardware Capable Switches within 60 days; (3) Capable Switches Requiring Hardware within  Xv-180 days; and (4) NonCapable Switches within 180 days.v  yO -ԍxSee supra  AMERITECH II52, ADD SWITCHES 266. As in the wireline context, carriers may submit requests for deployment of number portability in areas outside the 100 largest MSAs at any time. CMRS providers must provide number portability in those smaller areas within six months after receiving a request or within six months after June30, 1999, whichever is later. As a result, the schedule for wireless providers is comparable to the one for wireline carriers in terms of timing.  X -x138. CMRS 4 ` ` We add one further requirement for any procedures that limit deployment in such fashion to requested wireless switches. The existing state procedures for limiting deployment of number portability capabilities within one of the 100 largest MSAs to requested wireline switches generally appear to require carriers to specify which switches  Xy-located within the MSA the carrier wishes to be deployed.Yyx  yO-ԍxSee, e.g., Ameritech Reply at 35.Y We do not wish to disturb a number of state decisions concluding that it is preferable to limit the selection of wireline switches for deployment to switches located within the MSA rather than switches serving subscribers within the MSA. We recognize, however, that the wireless switches that provide service to areas within a particular MSA are more likely to be located outside the perimeter of that MSA than the wireline switches that provide service to areas within the MSA. We conclude, therefore, that, when limiting deployment within one of the 100 largest MSAs to particular requested wireless switches, carriers must be able to request deployment in any wireless switch that provides service to any area within that MSA, even if the wireless switch is located outside of the perimeter of that MSA, or outside any of the 100 largest MSAs.  X|-x139.` ` By June 30, 1999, we expect that regional or statewide local number portability databases containing both wireless and wireline numbers will be widely available; therefore, we do not anticipate a need to condition the requirement that number portability be required on request after June 30, 1999, upon the existence of regional or statewide databases. If there is a delay in the development of the databases, the Wireless Telecommunications Bureau  X -Chief has been delegated authority to waive or stay the deadline for CMRS providers.F   yO&-ԍxId. at 844041.F" O,-(-(ZZy-"Ԍ X-ԙx140.` ` In its petition for reconsideration, BANM questions the Commission's authority and its basis in the record for imposing number portability obligations upon CMRS  X-providers.F  yOK-ԍxBANM Petition at 37.F Specifically, BANM claims that we have previously held that our regulatory authority over CMRS providers is limited to instances in which there is a "clear cut need" for doing so, and that regulation of number portability is not clearly necessary in the CMRS  X-market.X  yO-ԍxFirst Report & Order, 11 FCC Rcd at 8432 (citing BANM Further Comments on Notice at 3 n.3). BANM advanced essentially the same argument previously in this proceeding, and its reconsideration petition raises no new issues. Accordingly, we affirm our prior rejection of  X_-this argument. As we stated in the First Report & Order, the CT DPUC Petition does not limit our authority to require CMRS providers to provide number portability to other CMRS or wireline carriers because that proceeding was restricted to the question of state authority to  X -regulate rates of CMRS providers.o   yO-ԍxPetition of CT DPUC, Order, 10 FCCRcd at 7025, 703233.o The CT DPUC Petition did not reach the question of the Commission's authority to impose number portability requirements on CMRS providers. We affirm our determination that we have authority to impose number portability obligations on CMRS providers based on our findings that this requirement will result in procompetitive effects, and furthers our CMRS regulatory policy of establishing moderate, symmetrical  X -regulation of all services. x  yO-  ԍxSee id. at 703334 (concluding that Omnibus Budget Reconciliation Act of 1993 validates the Commission's CMRS regulatory approach).  Xy-x141.` ` We recognize that the 1996 Act excludes CMRS providers from the definition of a LEC, thereby excluding them from the Section251(b) obligation to provide number portability, unless the Commission concludes that CMRS providers should be included in the  X4-definition of local exchange carrier.R4  yO-ԍxSee 47 U.S.C. 153(26).R In our Local Competition Order, we declined to find that CMRS providers should be treated as LECs for purposes of other LEC obligations under  X-Section 251.h`  yO-ԍxLocal Competition Order, 11 FCC Rcd at 15,99596.h As we explained in the First Report & Order, however, we possess independent authority under Sections 1, 2, 4(i), and 332 of the Communications Act of 1934, as amended, to require CMRS providers to provide number portability as we deem appropriate. These provisions of the Communications Act authorize us to ensure that the portability of telephone numbers within the United States is handled efficiently and fairly, as part of our obligation to ensure that "a rapid, efficient, Nationwide, and worldwide wire and  X|-radio communication service" is available.D|  yO&-ԍx47 U.S.C. 151.D Section 1 also establishes a significant federal interest in ensuring the efficient and uniform treatment of numbering, because such a system"eP ,-(-(ZZO-"  X-is essential to the efficient delivery of interstate and international telecommunications.  yOy-  ԍxSee Proposed 708 Relief Plan and 630 Numbering Plan Area Code by Ameritech Illinois, Declaratory Ruling and Order, 10 FCC Rcd 4596, 4602 (1995). In addition, Sections 2 and 332(c)(1) of the Act give the Commission authority to regulate commercial mobile service providers as common carriers, except for the provisions of Title II  X-that we specify are inapplicable.    yO-  ԍx47U.S.C.152, 332. Section 332 provides that "[a] person engaged in the provision of a service that is  x,a commercial mobile service shall, insofar as such person is so engaged, be treated as a common carrier for purposes  xof this Act, except for such provisions of title II as the Commission may specify by regulation as inapplicable to that service or person." 47U.S.C.332(c)(1)(A). We found in the First Report & Order that implementation of longterm service provider portability by CMRS carriers will have an impact on the efficient use and uniform administration of the numbering resource. Section4(i), moreover, grants the Commission authority to "perform any and all acts, make such rules and regulations, and issue such orders, not inconsistent with [the Communications  XH-Act of 1934, as amended], as may be necessary in the execution of its functions."GH  yO-ԍx47U.S.C.154(i).G We conclude that the public interest is served by requiring the provision of number portability by CMRS providers because number portability will promote competition between providers of local telephone services and thereby promote competition between providers of interstate  X -access services.   yO5-  \ԍxSee Notice, 10FCCRcd at 12362; Expanded Interconnection with Local Telephone Company Facilities, Memorandum Opinion and Order, 9FCCRcd5154, 515859 (1994).  X -x142.` ` BANM has not introduced any new evidence or arguments that cause us to  X -reconsider our conclusion in the First Report & Order that provision of number portability by CMRS carriers is important to competition. Previously in this proceeding, several PCS providers attested to the importance of number portability in fostering competition in the  Xb-CMRS industry.b  yO-  ԍxFirst Report & Order, 11 FCCRcd at 842627 (describing statements by Omnipoint, PCIA, and PCS Primeco supporting number portability for CMRS industry). The record in this proceeding contains convincing evidence that service provider portability would enhance competition between wireless service providers, as well as between wireless and wireline service providers, by removing the requirement that a customer must change numbers when changing service providers. We also reject BANM's argument that we failed to make a determination on the technical feasibility of wireless number  X-portability.PH  yO#-ԍxSee BANM Petition at 78.P The record in this proceeding supports our prior conclusion that cellular,"Q,-(-(ZZ-" broadband PCS, and covered SMR providers will be able to resolve any technical issues  X-necessary to implement number portability.  yOb-   ԍxFirst Report & Order, 11 FCCRcd at 8438 (citing pleadings of Competitive Carriers, Pacific, and PCIA, and INC Report). 4J:\POLICY\NUM_PORT\RECON1\ORDER\WIRELESS.ORD4  X- 3J:\POLICY\NUM_PORT\RECON1\ORDER\TAKINGS.ORD3 Xx D.X` ` Deferral of Implementation Until Resolution of Cost Recovery Issues (#`   Xv-x143.` ` Background. Section 251(e)(2) of the Act requires that the costs of establishing number portability "be borne by all telecommunications carriers on a competitively neutral  XH-basis as determined by the Commission."JH   yO -ԍx47 U.S.C.  251(e)(2).J In conjunction with the First Report & Order, we  X1-adopted a Further Notice of Proposed Rulemaking (Further Notice) that seeks comment on appropriate cost recovery mechanisms for longterm number portability. We have not yet  X -issued the Second Report & Order addressing these issues, although we intend to do so in the near future.  X -x144.` ` Pleadings. US West argues that, as a matter of law and policy, the Commission must put in place a mechanism for full cost recovery prior to requiring any  X-carrier to implement number portability.L  yO-ԍxUS West Petition at 1619.L According to US West, it is not enough for the Commission to establish a cost recovery mechanism before carriers actually commence the provision of longterm number portability, because carriers will begin incurring costs now to  XK-meet the implementation schedule.K@  yO<-  ԍxUS West Reply at 6; see also U S West January16, 1997 Ex Parte Filing at 8 (estimating that the cost of deploying number portability in its top ten MSAs will be approximately $310 million). US West asserts that carriers have a statutory and constitutional right to recover their "full" costs of number portability in a timely manner,  X-because the number portability requirement is a federal mandate.|  yOf-ԍxU S West January16, 1997 Ex Parte Filing at 16; US West Reply at 8.| Furthermore, U S West claims that deferring the establishment of cost recovery to a future proceeding will cause "distorting effects" on investment decisions, the use of number portability facilities, and the  X-relationships among providers and between providers and their customers.I(  yO!-ԍxUS West Petition at 17.I US West also asserts that deferring costrecovery issues is inconsistent with the Commission's own precedent, because the Commission recently made its E911 requirements for wireless carriers"R ,-(-(ZZ-"  X-contingent upon adoption of a cost recovery mechanism.N  yOy-ԍxUS West Reply at 67 & n.15.N JSI makes similar arguments with  X-respect to rural LECs.X  yO-  ԍxJSI Petition at 10 (arguing that it is unwise and unfair to mandate rural LEC implementation of longterm number portability before settling long term cost recovery issues).  X-x145.` ` Sprint argues that delaying the implementation of a longterm number portability solution until a cost recovery mechanism is in place is unwarranted because there is no basis for concluding that cost recovery issues will not be resolved before LECs must  Xv-deploy longterm number portability in Phase I markets.uv  yO -ԍxSprint Opposition at 1213; see also NEXTLINK Opposition at 6.u Moreover, claims Sprint, any cost recovery method adopted by the Commission may allow carriers to recover the reasonable  XH-costs of implementation that were already incurred.LH@  yO9-ԍxSprint Opposition at 1213.L ALTS points out that US West was subject to an equal access requirement long before the Equal Access and Network  X -Reconfiguration (EANR) access element was approved.J   yO-ԍxALTS Opposition at 6 n.7.J ALTS also argues that US West's constitutional claim is premature, because U S West cannot show that it will necessarily fail  X -to recover a constitutionally mandated amount.: `  yO-ԍxId.:  X -x146.` ` Discussion. We are not persuaded by the requests of U S West and JSI that LECs should be permitted to suspend ongoing preparations to meet the deployment schedule  X-until the Commission has acted on the issues raised in the Further Notice in this proceeding that involve the LECs' recovery of their costs of providing number portability. As stated  Xb-above, we plan to adopt a Second Report & Order in this proceeding in the near future implementing the statutory provision that expenses incurred as a result of number portability  X4-be "borne by all telecommunications carriers on a competitively neutral basis."J4  yO-ԍx47 U.S.C.  251(e)(2).J U S West appears to suggest that it necessarily will be barred from assessing charges in the future that are intended to recover costs that it incurs in connection with the implementation of longterm  X-number portability prior to our resolution of the cost recovery issues posed in the Further  X-Notice. That speculative assertion is unfounded. We anticipate that the Second Report &  X-Order will be adopted well before a LEC is required by the deployment schedule to commence the provision of longterm number portability to the public in the PhaseI markets. Moreover, we expect that LECs will maintain records of the costs that they incur in  X|-implementing the requirements of the First Report & Order in this proceeding. Those records  Xe-will enable the LECs to comply with the decisions we reach in the Second Report & Order"eS ,-(-(ZZO-" with respect to their recovery of longterm number portability costs. The Act does not mandate that we complete action on cost recovery issues prior to the LECs' commencement of the planning and other steps required to deploy longterm number portability consistent  X-with the schedule adopted in the First Report & Order. Indeed, permitting carriers to suspend their ongoing preparations to meet the deployment schedule for number portability until we have adopted specific cost recovery rules may be inconsistent with the statutory mandate that  Xv-carriers must provide number portability "to the extent technically feasible."Jv  yO-ԍx47 U.S.C.  251(b)(2).J  XH-x147.` ` The fact that we made the implementation of E911 contingent on the adoption of cost recovery mechanisms by state and local governments does not require us to defer  X -implementation of number portability until a federal cost recovery mechanism is adopted. X  yO# -  ԍxIn the E911 proceeding, the Commission made implementation of E911 service contingent upon the adoption  xof a cost recovery mechanism (in that case, by a state or local government), but declined to prescribe a particular  yO- xcost recovery methodology. Revision of the Commission's Rules to Ensure Compatibility with Enhanced 911  yO{- xhEmergency Calling Systems, Report and Order and Further Notice of Proposed Rulemaking, CC Docket No. 94-102,  yOC-at 8990 (rel. July 26, 1996) (E911 Order). In other instances, we have made cost recovery determinations after LECs had incurred costs in compliance with our orders and have permitted carriers to recover such previouslyincurred  X -costs as part of a costrecovery scheme.X   yO-  ԍxSee, e.g., Provision of Access for 800 Service, Second Report & Order, 8 FCC Rcd 907, 911 (1993) (stating  xthat LECs are allowed to treat as exogenous the reasonable costs they incurred specifically for the implementation and operation of the basic 800 data base service required by prior Commission orders).  X -x148.` ` We also conclude that US West has not described, much less documented, the specific "distorting effects" on investment decisions, the use of number portability facilities, and the relationships among providers and between providers and their customers that it claims will ensue from our brief deferral of longterm number portability cost recovery  XK-issues.SK(  yO$-ԍxSee US West Petition at 17.S We further agree with ALTS that U S West's constitutional claim is premature,JK  yO-ԍxALTS Opposition at 6 n.7.J because it is impossible for any party to establish that a cost recovery mechanism that has not  X-yet been adopted is unconstitutional.LXH  yO"-  ԍxSee, e.g., Illinois Bell Co. v. FCC, 911 F.2d 776 (D.C. Cir. 1990) (claim that Commission's rate base  xYpolicies were confiscatory is not ripe prior to a Commission determination regarding the rate of return to be applied to that rate base).L Finally, because the arguments advanced by JSI on behalf of rural carriers with respect to these cost recovery issues repeat the points asserted by  X-US West, we reach the same conclusions.Vh  yO'-ԍxSee, e.g., JSI Petition at 10. V 3J:\POLICY\NUM_PORT\RECON1\ORDER\TAKINGS.ORD3 "T,-(-(ZZ-"Ԍ X- ÙIV. ORDERING CLAUSES  X-x149.` ` Accordingly, IT IS ORDERED that, pursuant to the authority contained in Sections1, 4(i), 4(j), 201205, 218, 251, and 332 of the Communications Act as amended, 47 U.S.C. 151, 154(i), 154(j), 201205, 218, 251 and 332, Part 52 of the Commission's rules, 47 C.F.R. 52, is AMENDED as set forth in Appendix B hereto.  X_-x150.` ` IT IS FURTHER ORDERED that the Petitions for Reconsideration and/or Clarification ARE GRANTED to the extent indicated herein and otherwise ARE DENIED.  X -x151.` ` IT IS FURTHER ORDERED that the policies, rules, and requirements set forth  X -herein ARE ADOPTED, effective 30 days after publication of a summary of this First  X -Reconsideration Order in the Federal Register, except for collections of information subject to approval by the Office of Management and Budget (OMB), which are effective 150 days following publication in the Federal Register.  X-x152.` ` IT IS FURTHER ORDERED that the Motion to Accept LateFiled Comments of Telecommunications Resellers Association and the Motion to Accept LateFiled Reply Comments of US West ARE GRANTED. x` `  hhFEDERAL COMMUNICATIONS COMMISSION x` `  hhWilliam F. Caton x` `  hhActing Secretary "U,-(-(ZZ-"  X- V @A-@ 3J:\POLICY\NUM_PORT\RECON1\ORDER\PARTIES.LIS3   @A-A-@ APPENDIX A LIST OF PARTIES  X-Petitions for Reconsideration/Clarification, filed 8/26/96: AirTouch Communications, Inc. [AirTouch] American Communications Services, Inc. [ACSI] American Mobile Telecommunications, Inc. [AMTA] Bell Atlantic Bell Atlantic NYNEX Mobile, Inc. [BANM] BellSouth Corporation and BellSouth Telecommunications, Inc. [BellSouth] Cellular Telecommunications Industry Association [CTIA] Cincinnati Bell Telephone Company [CBT] GTE Service Corporation [GTE] John Staurulakis, Inc. [JSI] KMC Telecom, Inc. [KMC] MCI Telecommunications Corporation and MCIMetro [MCI] National Exchange Carrier Association, Inc. [NECA] National Telephone Cooperative Association and Organization for the XxPromotion and Advancement of Small Telecommunications Companies (# Xx[NTCA/OPASTCO](# Nextel Communications, Inc. [Nextel] NEXTLINK Communications LLC [NEXTLINK] NYNEX Telephone Companies [NYNEX] Pacific Telesis Group, Pacific Bell, Nevada Bell, Pacific Bell Mobile Services [Pacific] SBC Communications Inc. [SBC] United States Telephone Association [USTA] U S West, Inc. [US West]  Xe- Petitions for Reconsideration/Clarification, latefiled 8/30/96: Small Business in Telecommunications, Inc. [SBT]  X- Oppositions/Comments to Petitions for Reconsideration, filed 9/27/96: ALLTEL Telephone Services Corporation [ALLTEL] AT&T Corp. [AT&T] Association for Local Telecommunications Services [ALTS] Bell Atlantic BellSouth CTIA CBT GTE"#'V,-(-(ZZ(-"ԌIntelCom Group (USA), Inc. [ICG] MCI NEXTLINK NYNEX RAM Mobile Data USA Limited Partnership [RMD] Rural Telecommunications Group [RTG] Pacific Sprint Corporation [Sprint] Time Warner Communications Holdings, Inc. [Time Warner] USTA  X - Oppositions/Comments to Petitions for Reconsideration, latefiled 9/30/96: Telecommunications Resellers Association [TRA]  X- Replies, filed 10/7/96:  Xy- Ameritech NEXTLINK Teleport Communications Group [TCG] Rural Cellular Association [RCA] NTCA/OPASTCO  X- Replies, filed 10/10/96:  X- ACSI Bell Atlantic BellSouth CBT GTE MCI NYNEX Pacific SBC USTA U S West 3J:\POLICY\NUM_PORT\RECON1\ORDER\PARTIES.LIS3 ""W,-(-(ZZ$-"  X-  @A-B-@ 1J:\POLICY\NUM_PORT\RECON1\ORDER\RULES.ORD1 |APPENDIX B FINAL RULES AMENDMENTS TO THE CODE OF FEDERAL REGULATIONS   X- Part 52 of Title 47 of the Code of Federal Regulations is amended as follows:  X-  Xv-|PART 52 NUMBERING TP  XH-1.xSection 52.23 is amended by revising paragraphs (a)(4) through (a)(8), removing paragraph (a)(9), and revising paragraphs (b) and (g) to read as follows:  X -  52.23` ` X Deployment of longterm database methods for number portability  X -by LECs. (#  X -x(a)` ` * * * x` ` (4) Does not result in unreasonable degradation in service quality or network reliability when implemented; x` ` (5) Does not result in any degradation in service quality or network reliability when customers switch carriers; x` ` (6) Does not result in a carrier having a proprietary interest; x` ` (7) Is able to migrate to location and service portability; and x` ` (8) Has no significant adverse impact outside the areas where number portability is deployed. x` ` (b)(1) All LECs must provide a longterm database method for number portability in the 100 largest Metropolitan Statistical Areas (MSAs) by December 31, 1998, in accordance with the deployment schedule set forth in the Appendixto this part, in switches for which another carrier has made a specific request for the provision of number portability, subject to paragraph (b)(2) of this section. x` ` (b)(2) Any procedure to identify and request switches for deployment of number portability must comply with the following criteria: x` `  (i) Any wireline carrier that is certified (or has applied for certification) to provide local exchange service in a state, or any licensed CMRS provider, must be permitted to make a request for deployment of number portability in that state; x` `  (ii) Carriers must submit requests for deployment at least nine months before the deployment deadline for the MSA;"#'X,-(-(ZZ(-"Ԍx` `  (iii) A LEC must make available upon request to any interested parties a list of its switches for which number portability has been requested and a list of its switches for which number portability has not been requested; and x` `  (iv) After the deadline for deployment of number portability in an MSA in the 100 largest MSAs, according to the deployment schedule set forth in the Appendixto this part, a LEC must deploy number portability in that MSA in additional switches upon request within the following time frames: x` `  (A) For remote switches supported by a host switch equipped for portability ("Equipped Remote Switches"), within 30 days; x` `  (B) For switches that require software but not hardware changes to provide portability ("Hardware Capable Switches"), within 60 days; x` `  (C) For switches that require hardware changes to provide portability ("Capable Switches Requiring Hardware"), within 180 days; and x` `  (D) For switches not capable of portability that must be replaced ("NonCapable Switches"), within 180 days. l<* * * * *  X-x(g)` ` Carriers that are members of the Illinois Local Number Portability Workshop must conduct a field test of any technically feasible longterm database method for number portability in the Chicago, Illinois, area. The carriers participating in the test must jointly file with the Common Carrier Bureau a report of their findings within 30 days following completion of the test. The Chief, Common Carrier Bureau, shall monitor developments during the field test, and may adjust the field test completion deadline as necessary.  XN-2.xSection 52.31 is amended by revising paragraph (a) to read as follows:  X -  52.31` ` X Deployment of longterm database methods for number portability  X -by CMRS Providers. (# x(a) By June30, 1999, all cellular, broadband PCS, and covered SMR providers must provide a longterm database method for number portability, in the MSAs identified in the Appendix to this part in compliance with the performance criteria set forth in section 52.23(a), in switches for which another carrier has made a specific request for the provision of number portability, subject to paragraph (a)(1) of this section. x` ` (1) Any procedure to identify and request switches for deployment of number portability must comply with the following criteria: "#'Y,-(-(ZZ%-"Ԍx` `  (i) Any wireline carrier that is certified (or has applied for certification) to provide local exchange service in a state, or any licensed CMRS provider, must be permitted to make a request for deployment of number portability in that state; x` `  (ii) For the MSAs identified in the Appendixto this part, carriers must submit requests for deployment by September30, 1998; x` `  (iii) A cellular, broadband PCS, or covered SMR provider must make available upon request to any interested parties a list of its switches for which number portability has been requested and a list of its switches for which number portability has not been requested; x` `  (iv) After June30, 1999, a cellular, broadband PCS, or covered SMR provider must deploy additional switches serving the MSAs identified in the Appendix to this part upon request within the following time frames: x` `  (A) For remote switches supported by a host switch equipped for portability ("Equipped Remote Switches"), within 30 days; x` `  (B) For switches that require software but not hardware changes to provide portability ("Hardware Capable Switches"), within 60 days; x` `  (C) For switches that require hardware changes to provide portability ("Capable Switches Requiring Hardware"), within 180 days; and x` `  (D) For switches not capable of portability that must be replaced ("NonCapable Switches"), within 180 days. x` `  (v) Carriers must be able to request deployment in any wireless switch that serves any area within that MSA, even if the wireless switch is outside that MSA, or outside any of the MSAs identified in the Appendix to this part. x` ` (2) By June30, 1999, all cellular, broadband PCS, and covered SMR providers must be able to support roaming nationwide. l<* * * * *  X!-3.xThe Appendix to Part 52 is revised to read as follows:"!Z,-(-(ZZ -"  X-  APPENDIX to Part 52 Deployment Schedule  X-for LongTerm Database Methods for Local Number Portability ă XxImplementation must be completed by the carriers in the relevant MSAs during the periods specified below:  T !ddx Addx_[8 T       X` hp x (#%'0*,.8135@8:!Y yO-ԍx Local Competition Order, 11 FCC Rcd at 16,176.f By largely leaving this determination to the states, the  X -Local Competition Order stated, our decisions permit this factspecific inquiry to be administered in a manner that minimizes regulatory burdens and the economic impact on  X-small entities and small incumbent LECs.;?Y yO% -ԍx Id.; However, to minimize further regulatory burdens  X-and minimize the economic impact of our decision, in the Local Competition Order we adopted several rules that may facilitate the efficient resolution of such inquiries, provide  X-guidance, and minimize uncertainty.I@( Y yOp$-ԍx Id. at 16,17677.I In the Local Competition Order, we found that the rural LEC or smaller LEC must prove to the state commission that the financial harm shown to justify a suspension or modification would be greater than the harm that might typically be"il @,-(-(ZZO!"  X-expected as a result of competition.FAY yOy-ԍx Id. at 16,177.F Finally, we concluded that Section 251(f) adequately provides for varying treatment for smaller or rural LECs where such variances are justified. As a result, we stated, we expect that Section251(f) will significantly minimize regulatory  X-burdens and economic impacts from the rules adopted in the First Report & Order and this  X-First Reconsideration Order.;BXY yO-ԍx Id.;  Xv-XxX` ` 3.X Reporting Requirements by the Chief, Wireless  X_-Telecommunications Bureau, on Carriers' Progress  X1-x31.` ` Summary of Projected Reporting, Recordkeeping and Other Compliance  X -Requirements. In the First Report & Order, the Commission delegated authority to the Chief, Wireless Telecommunications Bureau, to require reports from cellular, PCS, and covered SMR providers in order to monitor the progress of these providers toward implementing longterm number portability. These reporting requirements were not defined in sufficient detail in  X -the First Report & Order to obtain approval from the Office of Management and Budget. Separate approval will be requested when the specific requirements are imposed by the Wireless Telecommunications Bureau.  Xf-x32.` ` Steps Taken to Minimize Significant Economic Impact on Small Entities and  XQ-Small Incumbent LECs, and Alternatives Considered. Although no party to this proceeding suggested that changes to these reporting requirements would affect small entities or small incumbent LECs, several parties requested that the Chief, Wireless Telecommunications  X-Bureau, be given greater authority to act to increase flexibility in the schedule.VCY yO-ԍxSee, e.g., RTG Comments at 45.V As explained  X-above in this First Reconsideration Order, we lighten the burden on smaller and rural wireless carriers by modifying our rules so that CMRS providers, like wireline providers, need only  X-provide portability in requested switches, both within and outside the 100 largest MSAs.DxY yO-ԍxSee First Reconsideration Order, supra  CMRS 3136שCMRS 4138.  X-We also decline at this time to alter further the implementation schedule imposed by the First  X-Report & Order for wireless carriers because we find that enough flexibility has been incorporated into the implementation schedule for wireless carriers, and that no modification  Xm-is needed.EmY yO&#-ԍxSee First Reconsideration Order, supra  CMRS 1134שCMRS 2135. "mE,-(-(ZZ!"Ԍ X-x E.` ` Report to Congress  X-x 33. The Commission shall send a copy of this Supplemental FRFA, along with this  X-First Reconsideration Order, in a report to Congress pursuant to the Small Business Regulatory Enforcement Fairness Act of 1996, 5 U.S.C.  801(a)(1)(A). A copy of this Supplemental FRFA will also be published in the Federal Register. 02J:\POLICY\NUM_PORT\RECON1\ORDER\FRFA.ORD0 "nE,-(-(ZZ!"  X-  @D-E-@ 4J:\POLICY\NUM_PORT\RECON1\ORDER\SCHEDULE.APP4     @E-E-@  X-$ APPENDIX E IMPLEMENTATION SCHEDULE ă XxImplementation must be completed by the carriers in the relevant MSAs during the periods specified below:  O addx\ 8 ddx_o8 O s  "   X` hp x (#%'0*,.8135@8: