FCC Record, Volume 15, No. 3, Pages 1205 to 1858, Supplement Page: 1,264
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F Com ic at i i , , i ll, i II CommIssio I D 9 9-,64
Thousands-block pooling requires carriers to alter significantly the manner in which they account
for their inventory of telephone numbers, including changing their Operations Support Systems
(OSSs) and retraining their staffs.64 In addition, we also urge the New Hampshire Commission
not to require carriers to engage in processes related to thousands-block pooling which might
divert critical resources away from preparations related to the Year 2000 rollover.65
33. We further require that the New Hampshire Commission determine the method to
recover the costs of the pooling trial.66 The New Hampshire Commission must also determine
how carrier-specific costs directly related to pooling administration should be recovered.67 The
Commission has tentatively concluded that thousands-block number pooling is a numbering
administration function, and that section 251 (e)(2) authorizes the Commission to provide the
distribution and recovery mechanisms for the interstate and intrastate costs of number pooling.68
We conclude that, inasmuch as we are hereby delegating numbering administration authority to
the New Hampshire Commission, the New Hampshire Commission must abide by the same
statute applicable to the Commission, and, therefore, ensure that costs of number pooling are
recovered in a competitively neutral manner.9 We note that the Telephone Number Portability
proceeding found that section 251 (e)(2) requires all carriers to bear the costs of number
portability on a competitively neutral basis, and, thus, established a cost recovery mechanism
that assesses even carriers that cannot or have not implemented LNP to date.70 The New
Hampshire Commission may consider the recently released Telephone Number Portability Order
for guidance regarding the criteria with which a cost recovery mechanism must comply in order
to be considered competitively neutral:
64 See Letter from Todd D. Daubert, Counsel for Winstar, to Magalie R. Salas, Secretary, FCC, dated July 28, 1999.
65 See National Association of Regulatory Utility Commissioners (NARUC), "Resolution Urging State
Commissions to Consider Honoring Utility Requests to Defer Deadlines Because of Y2K Considerations," adopted
July 23, 1999. See also Memorandum from Jacob J. Lew, Director, Chief Information Officers Council, to the heads
of executive departments and agencies, dated May 14, 1999 (requesting that federal agencies refrain from
establishing requirements that would have an adverse effect on the Year 2000 readiness of regulated entities).
66 The Numbering Resource Optimization Notice tentatively concluded that thousands-block number pooling
administration involved three categories of costs: (1) shared industry costs, which include the cost to fund the pooling
administrator, (2) carrier-specific costs directly related to thousands-block pooling implementation, including, for
example, costs directly related to updating carriers' LSMS to support pooling; and (3) carrier-specific costs not
directly relating to thousands-block pooling implementation. Numbering Resource Optimization Notice at 203-09.
67 See id at 197.
68 Id at 193.
69 47 U.S.C. 251(e)(2).
70 Telephone Number Portability, Third Report and Order, 13 FCC Rcd 11701, 11759 (1998). The Commission
also found that it was equitable for all telecommunications carriers, even those without end-user revenues and those
not directly involved in number portability, to contribute towards LNP costs because they will all benefit from
number portability's role in increasing local competition and ameliorating number exhaust concerns by making
number pooling possible. Id.
-Federal Communications Co mis ion
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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/m1/77/: accessed September 20, 2018), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.