WASHINGTON-The rural wireless carriers Tuesday said recent implementation guidelines for wireless local number portability developed by the Cellular Telecommunications & Internet Association will put them at a competitive disadvantage.
“The large nationwide commercial mobile radio service carriers have developed certain guidelines for their implementation of WLNP. These large-carrier guidelines are not appropriate or workable for rural carriers, and their imposition on rural carriers could result in discriminatory and anti-competitive results inconsistent with the Federal Communications Commission’s rationale for imposing WLNP,” said Gregory Whitaker, an attorney with the law firm of Bennet & Bennet.
The differences between the rural carriers and the nationwide and regional carriers are not new. While CTIA has called on the FCC to allow for WLNP outside rate centers, the rural carriers have said this is not fair. A rate center is a geographic location around a switching center used by state regulators to set local rates. In other words, if a person moves from one side of a city to another, that person must change his telephone number. Large wireless carriers generally do not use rate centers, but smaller rural wireless carriers might because they may only be located in one rate center.
“Asking rural wireless providers to port numbers out of their local area into a neighboring area is geographic porting not local porting-this is not what the FCC has mandated,” said Michael Kurtis, an attorney and radio-frequency engineer with Kurtis & Associates.
Some of the members of the Rural Wireless Working Group, which submitted its new guidelines to the FCC this week, represent wireline carriers.
“Our members need to be in a position to exchange traffic on a local basis with carriers to whom we port numbers. Otherwise, landline callers will incur toll charges that they do not expect to incur,” said Marie Guillory, general counsel for the National Telecommunications Cooperative Association.
“Real-world local number portability solutions have to deal with the rate-center issue and local interconnection obligations. This cannot be looked at in a vacuum,” said Jeffrey Smith, policy analyst with the Organization for the Promotion and Advancement of Small Telecommunications Companies.
