FCC Record, Volume 15, No. 3, Pages 1205 to 1858, Supplement Page: 1,263
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Federal Communications Commission
be in the position of being unable to exercise their choice of carier because that carrier does not
have access to numbering resources. This criterion attempts to ensure that consumers continue
to retain a choice of telecommunications providers in the event that the pooling trial does not
stave off the need for area code relief.
31. Only those carriers that have implemented permanent LNP shall be subject to the
trial.61 At the present time, we do not grant the state commission the authority to require a carrier
to acquire LNP solely for the purpose of being able to participate in a thousands-block pooling
trial. Carriers are only required to implement LNP if requested by another carrier subject to the
requirements established by the Commission.62 Within areas that are subject to the pooling trial,
non-LNP capable carriers shall have the same access to numbering resources after pooling is
implemented that they had prior to the implementation of a pooling regime, i.e., non-LNP
capable carriers shall continue to be able to obtain full NXX codes. We recognize that
conditioning the New Hampshire Commission's authority to implement a mandatory thousandsblock
pooling trial on exemption of non-LNP capable carriers from participation in the trial will
create a disparity in the way different types of service providers obtain access to numbering
resources, in tension with the criteria set forth above.63 In order to ensure that consumers may
continue to obtain service from non-LNP capable carriers of their choosing, however, we fmd
that for the purposes of this interim delegation, it is necessary to safeguard these carriers' access
to numbering resources, while they lack the technical capability to participate in pooling. The
Numbering Resource Optimization Notice raises a number of issues relating to non-LNP capable
carriers' participation in pooling, and we believe these issues are best addressed in the larger
rulemaking context. In the meantime, we suggest to the New Hampshire Commission that it
urge the non-LNP capable carriers to use various other numbering resource optimization
strategies such as those discussed in the Numbering Resource Optimization Notice to improve
the efficiency of numbering resources assigned to such carriers.
32. We direct the New Hampshire Commission to ensure that an adequate transition
time is provided to carriers to implement pooling in their switches and administrative systems.
60 Se Petition by Citizens Utility Board to Implement a form of telephone number conservation known as number
pooling within the 312,773, 847,630, and 708 area codes and Petition by Illinois Bell Telephone Company for
Approval of an NPA Relief Plan for the 847 NPA, Docket Nos. 97-0192 and 97-0211 (Consol.), Order (May 11,
1998) (establishing an area code overlay as a back-up plan concurrently with ordering thousands-block pooling in the
847 NPA). Although the Illinois Commission had an NPA relief plan in place in the 847 NPA to relieve what it had
forecast to be imminent exhaust, through number conservation measures, including thousands-block pooling, it has
forestalled the need for area code relief. See Petition of the Illinois Commerce Commission for Expedited
Temporary Waiver of 47 C.F.R. 52.19(c)(3)(ii) at 2-3 (filed August 11, 1999).
61 Wireless carriers are not require to implement LNP until November 2002, or until the Commission releases an
order establishing requirements for wireless carriers' participation in number pooling in the Numbering Resource
Optimization docket See Cellular Telecommunications Industry Association's Petition for Forbearance From
Commercial Mobile Radio Services Number Portability Obligations and Telephone Number Portability,
Memorandum Opinion and Order, WT Docket No. 98-229 and CC Docket No. 95-116, 14 FCC Red. 3092,3116, 1
62 See 47 C.F.R. 52.23(b)c).
63 See supra 1 3.
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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/m1/76/: accessed September 21, 2018), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.