FCC Record, Volume 15, No. 3, Pages 1205 to 1858, Supplement Page: 1,248
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have a disparate effect on the ability of competing service providers to earn normal
returns on their investments.""
Consistent with our treatment of cost recovery in the Telephone Number Portability proceeding,
we believe that even those carriers that cannot participate in pooling at this time will benefit from
the more efficient use of numbering resources that pooling will facilitate. We also encourage the
Department to consider the "road map" provided by the Numbering Resource Optimization
Notice regarding cost recovery for thousands-block number pooling.45
21. In order to minimize possible disruption and expense and maximize the value of
the information that can be obtained from a number pooling trial, we believe that such a trial
should be limited in nature. As an initial matter, we limit the authority we grant to the
Department to a trial that generally covers one Metropolitan Statistical Area (MSA).46 We
believe that such a limitation strikes the appropriate balance between the Department's desire to
move quickly to implement measures that will enhance number utilization efficiency, and
possibly prolong the lives of certain area codes in Connecticut and our obligation to ensure that
such pooling trials are implemented and conducted in a manner that does not disrupt network
operations or reliability. We believe these goals ultimately benefit consumers in Connecticut by
allowing the Department to move forward with a pooling trial quickly in whatever area it
determines it is most necessary, while providing some assurance that the network changes
required for the trials are implemented in a manner that does not disrupt the normal functioning
of the network in Connecticut and nationwide.
22. After having implemented a thousands-block number pooling trial in one MSA,
the Department may wish to expand to another MSA.47 Should it wish to do so, we direct the
Department to allow sufficient transition time for carriers to undertake any necessary steps, such
as modifying databases and upgrading switch software, to prepare for an expansion of thousandsblock
pooling to other MSAs. 4 In other words, start dates for thousands-block pooling trials in
44 Telephone Number Portability, Fourth Memorandum Opinion and Order on Reconsideration, CC Docket No.
95-116, RM 8535, FCC 99-151, at 1 32 (rel. July 16, 1999) (citing Telephone Number Portability, CC Docket
No. 95-116, First Report and Order and Further Notice of Proposed Rulemaking, 11 FCC Rcd 8352, 8420-21
45 Numbering Resource Optimization Notice at [ 193-210.
46 MSAs are geographic areas designated by the Bureau of Census for purposes of collecting and analyzing
data. The boundaries of MSAs are defined using statistics that are widely recognized as indications of
metropolitan character. See Policy and Rules Concerning Rates for Dominant Carriers, Memorandum Opinion
and Order, CC Docket No. 87-313, FCC 97-168 (rel. May 30, 1997) at 17 n.26. When implementing LNP, the
Commission established a phased implementation schedule based on MSAs. Telephone Number Portability,
First Report and Order and Further Notice of Proposed Rulemaking, CC Docket No. 95-116, RM 8535, 11 FCC
Red 8352, 8394-95, 1 81 (1996)
47 A thousands-block pooling trial is implemented when LNP-capabe carriers are contributing and receiving
numbers in blocks of 1,000 from the pool. Furthermore, for a pooling trial to have been implemented, a pooling
administrator must be chosen and responding to requests from carriers for numbering resources.
48 See Letter from Todd D. Daubert, Counsel for Winstar, to Magalie R. Salas, Secretary, FCC, dated July 28,
1999 (detailing concerns with expanding the thousands-block pooling trial in Illinois to other NPAs, and noting
_ ___ __
Fed~eral Communications Co mision
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United States. Federal Communications Commission. FCC Record, Volume 15, No. 3, Pages 1205 to 1858, Supplement, book, 2000; Washington D.C.. (digital.library.unt.edu/ark:/67531/metadc2992/m1/61/: accessed June 23, 2018), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.