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WIRELESS ARGUES PORTING NOT THE BEST METHOD TO CONSERVE NUMBERS

WASHINGTON-The wireless industry last month urged the Federal Communications Commission
to look at options other than local number portability to conserve telephone numbers.

The ever-increasing exhaust
of numbers has caused many in industry and government to look for ways to conserve numbers without having to
create additional area codes. The option most bandied about is number pooling, where carriers would be assigned
leftover numbers from existing NXX codes.

An NXX code is commonly referred to as a telephone exchange and is
the first three digits of a seven-digit telephone number. NXX codes each contain 10,000 telephone numbers. An NXX
code is opened for every carrier wishing to serve a particular wireline rate center, and with the proliferation of second
lines, fax machines and wireless devices, NXXs run out fast, creating the need for a new area code and a new set of
NXXs.

Often not all of the 10,000 numbers in an NXX are used, so the telecommunications industry has suggested
pooling leftover numbers and assigning numbers in thousand-block pools instead of an entire NXX code. Pooling
requires local number portability to be in place because pooled numbers would be ported to the newly assigned carrier.
All of this would happen at the network level and would be invisible to the consumer.

The wireless industry-led by
the Cellular Telecommunications Industry Association-long has claimed local number portability is not cost effective
for the wireless industry. Indeed, CTIA urged the FCC in 1997 not to enforce number portability rules. A decision on
this request is due by the end of March.

FCC documents showed the wireless industry is generally very good at
number usage because it is not bound by rate centers. Wireless carriers usually sign interconnection agreements with
incumbent local exchange carriers that allow them to offer expanded local calling areas (ELCA) to their subscribers.
Using this method, a wireless carrier finds it is only necessary to receive one NXX code for each area code in an ELCA
it wishes to serve. For example, a carrier serving an ELCA covering three states would only need three NXX codes at
any one time.

CTIA cited the usage of ELCAs as a reason why number portability-dependent conservation methods
will not work. “The absence of ‘stranded’ numbers-numbers tied to a particular rate center but for which there is
no consumer demand-means that pooling numbers and doling them out in varying increments offers no efficiency gains
in wireless carriers’ utilization of numbering resources,” CTIA said.

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