1. A Primer on Local Number Portability A Primer on Local Number Portability An Unsponsored Presentation at the Ministerial Workshop on a Regional Approach to Number Portability Organized by the Caribbean Telecommunications Union Radisson Grenada Beach Resort January 16, 2014 Rob Frieden, Pioneers Chair and Professor of Telecommunications and Law Penn State University rmf5@psu.edu Web site : http://www.personal.psu.edu/faculty/r/m/rmf5/http://www.personal.psu.edu/faculty/r/m/rmf5/ Blog site: http://telefrieden.blogspot.com/http://telefrieden.blogspot.com/

2. A Working Definition of Local Number Portability Local Number Portability provides subscribers of telephone services the opportunity to change service providers while keeping their existing telephone number. This process reduces inconvenience in changing carriers and thereby increases the incentive to comparison shop. Local Number Portability provides subscribers of telephone services the opportunity to change service providers while keeping their existing telephone number. This process reduces inconvenience in changing carriers and thereby increases the incentive to comparison shop. The U.S. Telecommunications Act of 1996 defines LNP as “the ability of users of telecommunications services to retain, at the same location, existing telecommunications numbers without impairment of quality, reliability, or convenience when switching from one telecommunications carrier to another.” 47 U.S.C. § 153(30); 47 C.F.R.§52.21(k). The U.S. Telecommunications Act of 1996 defines LNP as “the ability of users of telecommunications services to retain, at the same location, existing telecommunications numbers without impairment of quality, reliability, or convenience when switching from one telecommunications carrier to another.” 47 U.S.C. § 153(30); 47 C.F.R.§52.21(k). Telephone numbers identify subscribers meaning that carriers can transfer responsibility for the switching, routing and delivery of traffic. This transfer process is commonly referred to as porting. The porting process typically occurs within a specified local calling area where two or more carriers compete. Telephone numbers identify subscribers meaning that carriers can transfer responsibility for the switching, routing and delivery of traffic. This transfer process is commonly referred to as porting. The porting process typically occurs within a specified local calling area where two or more carriers compete. Unlike the telephone numbering system, the Internet Protocol addressing system typically associates a physical location for switches, routers and servers. The telephone numbering system simply identifies end users making it possible to change which carrier manages traffic to and from a specific telephone number and subscriber. Unlike the telephone numbering system, the Internet Protocol addressing system typically associates a physical location for switches, routers and servers. The telephone numbering system simply identifies end users making it possible to change which carrier manages traffic to and from a specific telephone number and subscriber. 2

3. LNP Types LNP requires the creation of Location Routing Numbers (“LRNs”) for all traffic in lieu of nxx-xxxx telephone numbers that no longer are carrier, switch and location specific. The LRN creation, registration and look up function requires networking and data base interrogation. Fixed Number Portability—subscribers of a wireline network can change carriers with the “exporting carrier” porting the former- subscriber’s telephone number to the “importing carrier.” Mobile Number Portability –LNP provided by wireless carriers. Cross Number Portability– LNP between and among both wireline and wireless carriers. This category also can include porting numbers between traditional wireline/wireless carriers on one hand and Voice over the Internet Protocol (“VoIP”) providers on the other hand. 3

4. The Porting Process LNP involves sophisticated creation and interrogation of data bases containing information about which telephone number is associated with which carrier. Unlike call forwarding, the process requires coordination between exporting and importing carriers. Using telephone electronic switching technology of the last 30+ years, subscribers can Using telephone electronic switching technology of the last 30+ years, subscribers can temporarily change the receiving number by using the keypad of a telephone. LNP requires the reprogramming of carrier switches to change the carrier with responsibility for routing inbound and outbound calls associated with a specific telephone number. 4 source: Government of Bermuda, Ministry Of Energy, Telecommunications and E-Commerce, The Department of Telecommunications.

5. Source: North American Numbering Council 5

6. source: U.S. Federal Communications Commission 6

7. Source: Neustar 7

8. LNP Flow Charting 8 The LNP process may require regulatory authorities to create various flow charts that specify the step-by-step process for handling the porting process.

9. LNP QOS and Cost LNP helps “level the competitive playing field” between incumbent carriers and market entrants. Incumbent carriers cannot deny the technical ability to achieve LNP, but they may object to the cost. If mandated to implement LNP, incumbents may use the regulatory process and litigation to generate and uncertainty. Additionally they may overstate the cost, try to implement costly and unneeded procedures and techniques, or handicap the competitiveness of market entrants by making it unnecessarily difficult to provide the same QOS. LNP helps “level the competitive playing field” between incumbent carriers and market entrants. Incumbent carriers cannot deny the technical ability to achieve LNP, but they may object to the cost. If mandated to implement LNP, incumbents may use the regulatory process and litigation to generate and uncertainty. Additionally they may overstate the cost, try to implement costly and unneeded procedures and techniques, or handicap the competitiveness of market entrants by making it unnecessarily difficult to provide the same QOS. LNP mandating legislation and regulation should specify that all carriers: LNP mandating legislation and regulation should specify that all carriers: participate and support existing network services, features and capabilities; efficiently use numbering resources; refrain from imposing higher than necessary costs on importing carriers; and not cause degradation in service quality, or network reliability. 9

10. Costs and Benefits in Regional Cooperation Data base registration and interrogation constitutes a significant portion of the total cost in LNP. Data base registration and interrogation constitutes a significant portion of the total cost in LNP. Note that Internet routing and switching builds in a similar “whois” function; ISPs cooperate in the installation of specialized servers containing routing registration information; see http://www.irr.net/docs/overview.html; Note that Internet routing and switching builds in a similar “whois” function; ISPs cooperate in the installation of specialized servers containing routing registration information; see http://www.irr.net/docs/overview.html;http://www.irr.net/docs/overview.html The Internet Routing Registry (IRR) is a distributed routing database development effort. Data from the Internet Routing Registry can be used by anyone worldwide to help debug, configure, and engineer Internet routing and addressing. The IRR provides a mechanism for validating the contents of BGP announcement messages or mapping an origin AS number to a list of networks. The Internet Routing Registry (IRR) is a distributed routing database development effort. Data from the Internet Routing Registry can be used by anyone worldwide to help debug, configure, and engineer Internet routing and addressing. The IRR provides a mechanism for validating the contents of BGP announcement messages or mapping an origin AS number to a list of networks. Caribbean telecommunications carriers can achieve scale economies and cost savings by cooperating in the creation of a regional LNP registry. Caribbean telecommunications carriers can achieve scale economies and cost savings by cooperating in the creation of a regional LNP registry. It appears that cost transporting registry information and interrogating the data base constitutes less than the cost incurred by individual carriers in each Caribbean nation to install, maintain and operate single LNP registries. It appears that cost transporting registry information and interrogating the data base constitutes less than the cost incurred by individual carriers in each Caribbean nation to install, maintain and operate single LNP registries. Wireless carrier roaming cost can provide a “back of the envelop” estimate of LNP costs Wireless carrier roaming cost can provide a “back of the envelop” estimate of LNP costs 10

11. Lessons from LNP Implementation in Other Nations Clear regulatory mandates, policy, and directives are essential for stakeholders to embrace LNP; Clear regulatory mandates, policy, and directives are essential for stakeholders to embrace LNP; Help carriers recognize that LNP can reduce, or will not vastly increase customer acquisition cost and subscriber churn; Help carriers recognize that LNP can reduce, or will not vastly increase customer acquisition cost and subscriber churn; Facilitate stakeholder participation in the development of regulations and LNP implementation; Facilitate stakeholder participation in the development of regulations and LNP implementation; Specify a fair and competitively neutral cost recovery mechanism; Specify a fair and competitively neutral cost recovery mechanism; Maintain regulatory oversight and dispute resolution; Maintain regulatory oversight and dispute resolution; Consider ways to promote scale and reduce costs by cooperating in the creation of a single regional LNP registry; and Consider ways to promote scale and reduce costs by cooperating in the creation of a single regional LNP registry; and Ensure LNP evolution to accommodate new types of voice and messaging services, such as VoIP. Ensure LNP evolution to accommodate new types of voice and messaging services, such as VoIP. 11