WASHINGTON-The Cellular Telecommunications Industry Association filed comments with the Federal Communications Commission opposing the Public Service Commission of Wisconsin’s petition seeking a greater role in number conservation and area code relief.
Specifically, the PSCW requested authority to enforce current standards for number allocation or to set and enforce new standards; to order efficient number-use practices within NXX codes; to order the return of unused and reserved NXX codes; to order number utilization and forecast reporting and to audit such reporting; to investigate and order unassigned number porting; to investigate and order additional rationing measures; and to implement mandatory thousand block pooling.
“By requesting additional authority to implement various number conservation methods in Wisconsin, the PSCW joins other state-specific requests to recast the balance the commission struck in the Pennsylvania Numbering Order,” said CTIA in its comments. That order retained federal authority over numbering administration but allowed state commissions to engage in area code relief.
CTIA also expressed concern about the PSCW’s request to have the authority to locally implement conservation measures, which require wireless carriers to deploy local number portability.
“CTIA does not oppose voluntary thousand block number pooling trials,” said CTIA. “CTIA does, however, strongly oppose mandatory pooling arrangements like those proposed by the PSCW that require wireless LNP capability and thereby impose new obligations on all [commercial mobile radio service] providers nationwide, or else deny Wisconsin wireless customers the ability to roam.
“Conservation measures which require all carriers to have LNP capability necessarily disadvantage and discriminate against the wireless industry, which has implementation issues that are different from wireline carriers.”
CTIA said it strongly believes conservation measures should be developed on a national level.
“The alternative to the adoption of nationwide numbering conservation solutions is a `patchwork’ of individualized, local measures that would subject carriers to inconsistent state numbering-administration regimes and impermissibly compromise the commission’s exclusive jurisdiction over the North American Numbering Plan for the United States,” said CTIA.
