October 15, 1997

A. Richard Metzger, Jr.

Acting Chief, Common Carrier Bureau

Federal Communications Commission

Washington, D.C. 20554

Re: Chicago Field Test, LNP and possible 9-1-1 problem

CC Docket No. 95-116

Dear Mr. Metzger:

I am requesting that the FCC officially adopt and mandate the NENA (National Emergency Number Association) voluntary database standard for LNP so that tens of thousands of LNP customers do not temporarily disappear from 9-1-1 databases for one to three days at a time in some states.

On May 23, 1997, Ms. Regina Keeney, CCB Chief, wrote a letter, re: "FCC Guidance to the Illinois Portability Task Force," which was sent to the task force, c/o Brent Struthers, Illinois Commerce Commission.

In that letter, she offered six areas of guidance, including #5) "The Field Test report should address tests of the ported subscriberís service. As applicable, various components of the telecommunications infrastructure (e.g....enhanced 911...) should be tested."

While the Field Test report should show the successful testing of enhanced 9-1-1, it will not show that part of the reason was the decision by Ameritech, AT&T, MCI, Sprint, TCG/Teleport, and Worldcom/MFS to comply with the voluntary database standards officially approved by the NENA Executive Board, in June of 1997, specifically to minimize the impact of LNP on 9-1-1 ALI (address location) databases.

My concern is to be sure that the appropriate people at the FCC are aware that at least one state outside the Midwest Region may not comply with the voluntary standards when LNP becomes operational.

This would mean that if a state with 10 million wireline phones had an estimated churn rate (customers changing service providers) of 10 per cent due to LNP, one million ALI database records would disappear from 9-1-1 ALI databases in that state for from one to three days during the year of that 10 per cent churn rate. The reasons for the disappearance would be the advent of LNP and the major 9-1-1 service provider(s) in that state refusing to cooperate with a voluntary NENA standard.

This potential major disservice to unsuspecting customers could be totally prevented by action of the FCC mandating the new NENA database standard (attached).



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October 15, 1997

The NENA committee that developed this standard included 9-1-1 representatives from most major service providers in the United States and Canada, including TCG, U.S. West, NYNEX, Bell Sygma, Pacific Bell, ALLTEL, Lucent Technologies, Ameritech, ICG, Time Warner Communications, GTE, Bell Atlantic, MCI Metro, Southwestern Bell, Sprint, Bell South, ICI, Bell Canada, and Winstar Telecommunications. Also represented was SCC, a major 9-1-1 database provider throughout the country.

Currently, when a customer changes service providers and does not move, the customerís 9-1-1 ALI record is deleted with information supplied by the current service provider and then a new 9-1-1 ALI record is added from data supplied by the new service provider. This delete/add process can take one to three days during which there is no address information available to a public safety answering point (PSAP) if the customer has an emergency and dials 9-1-1, depending on the area of the country, the service providers involved and the 9-1-1 database provider.

Following the new NENA 9-1-1 database standard specifically for LNP, a customerís 91-1- address (ALI) record and other associated data would not be deleted when the customer was changing service providers and keeping the same phone number. All 9-1-1 ALI records in any area where LNP was available, would be populated with a company ID (a 3 to 5 digit alpha-numeric code, representing the facilities-based service provider of the customer).

The donor service provider would send through an "unlock," which would delete that company ID only, and the recipient service provider would next send through a "migrate" record, which would re-populate the ALI record with the appropriate information concerning the customer, and the company-ID of the customerís new service provider.

At no time during the LNP process would the customer be without all the features of enhanced 9-1-1, particularly of the immensely-important feature of address information being immediately available to the PSAP.

It is expected that LNP will greatly enhance the competitive nature of the local phone market, so that a much greater percentage of customers will start changing from one service provider to another.

My understanding of one of the major reasons that the FCC chose the LRN (location routing number) method as the national mandated method for LNP over QOR (query on release) is that with QOR, call set up time would increase just over one second, and so the incumbent service provider could use this to convince customers not to change service providers.





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October 15, 1997

If the national NENA standard is not similarly mandated by the FCC on a national basis and an incumbent service provider (very often, this company is also the 9-1-1 service and database provider) chose not to follow the standard, the same incumbent service provider could tell customers that if they chose to change service providers, their 9-1-1 service would not be as good.

I believe having inferior 9-1-1 service would be a stronger selling point as a reason not to change providers, than having one second added to call set up of a regular phone call.

Thank you for any immediate consideration of this matter that may be offered.

Just for information, my background in this area is that since November, 1996, representing the Illinois chapter of NENA, particularly those members in the Chicago and St. Louis MSAs, I have been attending and offering input to the various groups within the Illinois Number Portability Task Force, including the steering committee, the operations subcommittee, the test team committee, and the 9-1-1 subcommittee (I do believe that the Midwest Region is the only region with an officially-recognized 9-1-1 subcommittee as part of its LNP implementation committee structure).

I also have served on the NENA LNP database study group that developed the special database standards to be sure the public did not receive any less 9-1-1 service during the LNP process (proving that a very large committee made up of service provider and switch vendor employees, who are dedicated to 9-1-1, can reach a major decision for the public good in a minimum amount of time).

With 20 years of employment in the public safety communications field, I have been a supervisor for about 19 years at a police/fire communications center that has had enhanced 9-1-1 for almost 7 years.

While I do have some other concerns about LNP and 9-1-1, I will address them at another time and/or through other venues, as I believe that the mandating of a national 9-1-1 database standard in an LNP environment is of critical importance.

Again, thank you very much for your prompt consideration.



Rick Jones

Loves Park 9-1-1 supervisor

cc: Illinois Number Portability Task Force and ICC c/o Brent Struthers

Barb Thornburg, NENA Data Technical Committee Chair

Norm Forshee, President, Illinois chapter, NENA

Contact information

Rick Jones

Loves Park 9-1-1 supervisor

Loves Park Police Department

540 Loves Park Drive

Loves Park, IL 61111

office # (815) 654-5015

fax # (815) 633-0555

E-mail: rockford9@aol.com