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Number Portability: Ensuring Convenience and Fostering Competition in Telecommunications

6. Number Pooling

In a competitive telecommunications environment, the current method of allocating NPA–NXXs in blocks of 10,000 is wasteful and inefficient. Studies have shown that numbering resource shortages are caused in large part by the telecom industry’s requirements to use one exchange code per rate center for each carrier. In a joint effort to determine a more efficient method of allocating these scarce resources, the industry devised and the FCC recently approved a national number pooling plan for network resource optimization. Number pooling is the ability to share an NPA–NXX among several facilities-based carriers within the same rate center with the intent of prolonging the life of an NPA by reducing the demand for new NXXs. When a “pooled” block of numbers is transferred from one service provider to another, critical information needs to be broadcast across the region to ensure effective data provisioning for call routing. To facilitate the broadcasting of “pooled” blocks and associated routing data, the location routing number method, the same platform used for LNP, is being used to implement national number pooling. This method of resource allocation allows NXXs within a given NPA to be shared among entities that offer service to subscribers within a defined geographic area (rate center). Specifically, it allows the assignment of numbers to competitive service providers in a 1000s block or down to the NPA–NXX-X level.

The concept of pooling, designed to address telephone number exhaust, is based on the fact that whole blocks of telephone numbers, held by some service providers, are not assigned or in service. Pooling would allow these currently unassigned blocks of numbers to be reassigned to other service providers in need of numbers, as they request and show need. Service providers can maintain a small supply of numbers for subsequent subscriber assignment. As that supply depletes, the service provider will request additional numbering resources from the industry inventory maintained by the pooling administrator. The Industry Numbering Council (INC) has established clear guidelines (INC 99-0127-023) to direct service providers, as well as the number administrator, in the allocation of these resources to promote fairness and standardization. NeuStar currently serves as the interim pooling administrator in most states where some pooling activity is in progress.

Number pooling can be a very effective number conservation tool. The number administrator currently must issue numbers in blocks of 10,000, an entire NXX code, even though the requesting party may need fewer numbers. Pooling allows the allocation of numbers between multiple industry participants in quantities much smaller then 10,000 (i.e., 1,000) blocks. Thousand-block number pooling is currently under way in several regions in the United States, including the Midwest, Northeast, and West Coast.

On December 29, 2000, the FCC released the text of the Second Report & Order and Further Notice of Proposed Rulemaking in its Number Resources Optimization proceeding. In a press release from CTIA, the following statement appears: “The most significant setback for CMRS carriers in today's Commission action is the requirement for CMRS carriers to comply with the Thousands Block Pooling mandate on November 24, 2002, the deadline for Wireless Number Portability.” No transition time between the two measures was granted. Wireless carriers should contemplate the significance of this ruling when reviewing their deployment options and choosing a methodology for NP.

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