FCC Record, Volume 15, No. 3, Pages 1205 to 1858, Supplement Page: 1,261
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tentatively concluded that thousands-block pooling is an important numbering resource
optimization strategy, essential to extending the life of the NANP.49 In granting the Illinois
Commission the authority to engage in a mandatory thousands-block pooling trial in the
Pennsylvania Numbering Order, the Commission recognized that state number pooling trials
could aid in developing national pooling implementation, architecture, and administrative
25. The implementation of thousands-block pooling requires local number portability
(LNP) capability. Because New Hampshire does not contain one of the top 100 Metropolitan
Statistical Areas (MSAs),50 carriers operating in that state are not required to implement LNP
until they receive a customer request for this service.5 The New Hampshire Commission,
however, informs us that Bell Atlantic, which is New Hampshire's largest incumbent local
exchange carrier and provides service to 94% of the access lines in that state, is LNP capable.52
Moreover, the New Hampshire Commission informs us that all eighteen competitive local
exchange carriers currently certified to provide non-dedicated, facilities-based service in New
Hampshire were required to be LNP capable as of October 31, 1999. In light of the fact that
LNP has been deployed by a substantial number of wireline carriers, we conclude that
thousands-block pooling is technically feasible in New Hampshire.
26. In prior orders, the Commission has granted several state public utility
commissions the authority to initiate thousands-block pooling trials.53 In so doing, the
Commission considered support.for the proposal as well as concerns regarding the burdens that
thousands-block pooling trials might impose.4 The Commission noted that, in spite of the
potential for strain on the network occasioned by multiple pooling trials, the relatively small
volume of ported numbers and the importance of providing relief to states experiencing severe
49 Numbering Resource Optimization Notice at f 138.
50 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 Rcd 8352, 8394-95,
51 See 47 C.F.R. 52.23(c). 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 Rcd 8352, 8394-95,1 81 (1996).
52 Letter from Paul S. Keller, New Hampshire Commission, to Magalie R. Salas, Secretary, FCC, dated November
10, 1999. The New Hampshire Commission also states that the remaining 13 ILECs are independent telephone
companies which filed for, and were subsequently granted, relief from the requirement that all carriers in the state be
LNP capable by October 31, 1999. Id
53 See, eg., California Delegation Order at I 11-22; Florida Delegation Order at H 10-21; Maine Delegation
Order at IfI 26-36; Massachusetts Delegation Order at ft 11-22; New York Delegation Order at 10-21.
4 See, e.g., California Delegation Order at 12; Florida Delegation Order at 1 1; Maine Delegation Order at
28; Massachusetts Delegation Order at 1 12; New York Delegation Order at 11.
-Fegeral Comrmunications C mmi *o
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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/m1/74/: accessed September 24, 2018), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.