Rural Operators Submit Mobile Number Portability Plans

In order to provide more unified support for rural carrier interests, the "Rural Wireless Working Group", a consortium of rural telecommunications advocacy organizations, says that it has developed new guidelines for wireless local number portability (WLNP) in rural areas, and filed those guidelines with the US's telecoms regulator, the Federal Communications Commission (FCC).

Comprised of key players in the rural wireless industry, the Rural Wireless Working Group (RWWG) was formed to better serve the interests of rural wireless telecommunications companies and support them with their regulatory and legislative needs. The group includes the National Telecommunications Cooperative Association ("NTCA"), the Organization for the Promotion and Advancement of Small Telecommunications Companies ("OPASTCO"), the Rural Telecommunications Group ("RTG"), and the law firms of Bennet & Bennet, PLLC, Blooston, Mordkofsky, Dickens, Duffy & Prendergast and Kurtis & Associates.

RWWG says that it could not support the standards developed by CTIA, which the group feels were designed primarily for large nationwide carriers, and do not take into account the specific operating conditions under which rural carriers conduct their business.

"The large nationwide CMRS 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 Commission's rationale for imposing WLNP," stated Gregory Whiteaker, a principal with the law firm of Bennet & Bennet.

Jack Nuttall, Wireless Product Manager for ENMR/Plateau (serving New Mexico & Texas) and a member of RTG and NTCA, agrees to the need for rural guidelines because, "they take into consideration standard business practices in rural America where customer service operations are not available 24/7/365."

The Cellular Telecommunications & Internet Association has issued industry standards for carriers to use as guidelines in implementing WLNP on their networks. The RWWG feels that these standards are discriminatory when applied to rural wireless operators who serve much smaller geographic areas, and will put them at a marked disadvantage to their large nationwide counterparts. At issue are the requirements for porting numbers between service providers, and whether they must port numbers across rate centers which ultimately determines which calls are local and which calls are "toll". The current standards have the potential to confuse rural consumers about the cost of service and will provide nationwide carriers with an unfair and anticompetitive edge over small rural operators.

"One way porting obligations are not competitively sustainable," remarked Michael K. Kurtis, an attorney and RF engineer with Kurtis & Associates. "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."

"NTCA has rural LEC and wireless members that are affected by the standards developed by the nationwide CMRS carriers," stated Marie Guillory, NTCA's General Counsel. "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," she added. Jeffrey Smith, a Policy Analyst with OPASTCO, agrees, "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."

Posted to the site on 27th August 2003