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Mr. Brian Cohee Executive Secretary to the Indiana Utility Regulatory Commission Telecommunications Division
302 West Washington Street
Suite E­306
Indianapolis, Indiana 46204

Dear Mr. Cohee;

On July 1. 1996 the Indiana Utility Regulatory Commission (Commission) issued an order in the matter of Cause Number 39983 entitled 'Interim Order on Bundled Resale and Other issues' (Interim Order). in pantograph K of the interim Order on pages 44 and 45, the Commission established a task force on number portability. The Commission directed the number portability task force to review and consider technological issues related to long term number portability and the associated cost of each technology. Cost recovery and allocation issues were not to be addressed in this task force process. All interested parties were invited to participate in these industry discussions.

The Indiana number portability task force was assigned the responsibility to present a final report and recommendation to the Commission on any and all issues generally described above on or before November 8, 1996. The task force was unable to complete its work by the November 8, 1996 date and therefore requested and received an enlargement of time until January 8, 1997.

The task force met on four or occasions; July 11, August 16, October 8, and December 10, 1996. Additionally, several teleconferences were held between the months of October 1996 through January 1997. The attached "Indiana Number Portability Task Force Report." is the final report and recommendation prepared by participants of the number portability task force, as requested by the Commission in its interim Order.

Judith D. Evans
Co-Chairperson Number Portability Task Force

Attachment: Indiana Number Portability Task Force Report ­ Cause No. 39983


CAUSE NO. 39983

JANUARY 8, 1997

I. Background

In Cause No. 39983 Interim Order on Bundled Resale and Other Issues, approved July 1, 1996, the Commission ordered that a task force be established to review and consider technological issues related to long term number portability and the associated cost of each technology. Specifically, the order stated:

(K). Number Portability. On June 7, 1996, the presiding officers issued a docket entry in this Cause establishing, among other things, a second hearing in this matter and calling for comments from the respective parties on matters related to long term number portability. Those comments were due and received on June 14, 1996. The June 7, 1996 docket entry and the respective comments received June 14, 1996 appear more fully in the following words and figures, to wit:


The Commission having considered the comments and recommendations of June 14, 1996 now finds that a task force should be established, to be made up of member/representatives from each of the interested parties in this Cause and facilitated by two Commission staff members. The Commission further finds that this task force should review and consider the "Stipulation and Settlement Agreement" attached to AT&T's June 14, 1996 filing. This "Stipulation and Settlement Agreement" is purportedly the document filed with and approved by the Illinois Commerce Commission in Docket No. 96-0089 relating to Illinois' disposition of the number portability issue. The task force is specifically directed, but not limited to a review and consideration of technological issues related to long term number portability and the associated cost of each technology. Cost recovery and allocation issues will not be addressed in this task force process.

This number portability task force shall immediately be formed and organized by two Commission staff members designated by the presiding officers. The first organizational meeting, which will be monitored and facilitated by these two staff members shall be set for July 11, 1996 in the Commission Offices, Room E306, Indiana Government Center South, beginning at 9:30 a.m., local time. All parties desiring to participate and have input for Commission consideration should send a technical representative who is knowledgeable in this area and authorized by the particular party to discuss, present, decide and make recommendations to the Commission for ultimate action on certain number portability issues. The parties are advised that this may be their only opportunity to present and/or make their respective position(s) and recommendations(s) known and therefore should plan and participate accordingly. The task force shall have the limited authority to meet how and when it chooses but a final report and recommendation should be presented to the Commission on any and all issues generally described above on or before November 8, 1996. Disputes, confusion, or any other matter requiring Commission action or intervention, to allow the task force to accomplish this stated objective, should be formally presented to the Commission as soon as the matter arises.

The task force was unable to complete its work by the November 8, 1996 date and therefore requested and received an enlargement of time until January 8, 1997.

II. Indiana Task Force

A. Meetings/Participants

To meet the goals set forth by the Commission, the task force met several times. Meetings were conducted on July 11, August 16, October 7, and December 10. In addition, conference calls were held on November 8, November 14, and November 22. The meetings and conference calls were attended by numerous industry participants representing the Indiana Incumbent Local Exchange Carriers, New Competitive Local Exchange Carriers, Interexchange Carriers, Cellular Carriers, and Cable TV Providers. A complete list of participants is provided in Appendix B.

At the meeting on July 11, 1996 Judy Evans of AT&T and Terry Appenzeller of Ameritech were elected co-chair persons of the task force.

B. Mission Statement

The task force agreed on the following mission statement:

The task force shall have the limited authority to meet how and when it chooses with a final report and recommendation to be presented to the Commission on technological issues related to long term number portability and the associated cost of each technology on or before November 8, 1996.

III. Technical Solution

A. Location Routing Number (LRN) Selected

As directed by the Commission, the task force reviewed and considered the "Stipulation and Settlement Agreement" which was attached to AT&T's June 14, 1996 filing. The Indiana task force agreed that using the Illinois model was the most logical and efficient way to implement long term number portability (LTNP) in Indiana. The Location Routing Number (LRN) call model was adopted unanimously as the long-term call processing model for the implementation of LTNP in Indiana. LRN is the architecture of choice by the industry and many states, including Illinois. It meets the following minimum performance criteria established by the FCC in their Number Portability Order (CC Docket 95-116) issued on July 2, 1996:

  1. Supports existing services, features, capabilities
  2. Efficiently uses number resources
  3. Does not require end users to change telephone numbers
  4. Does not require the use of other networks to route calls to the proper termination point
  5. Does not result in the unreasonable degradation in service, quality, or network reliability when implemented
  6. Does not result in any degradation when customers switch carriers
  7. No carrier has a proprietary interest
  8. Able to accommodate location and service portability
  9. No significant impact to areas outside of ported area

Utilizing LRN, a carrier seeking to route a call to a ported number queries or "dips" an external routing database, obtains a ten-digit location routing number for the ported number, and uses that location routing number to route the call to the end office switch which serves the called party. The carrier dipping the database may be the originating carrier, the terminating carrier, or the carrier prior to the terminating carrier (N-1 carrier). Under the LRN method, a unique location routing number is assigned to each switch. For example, a local service provider receiving a 7-digit local call, such as 887-1234 would examine the dialed number to determine if the NPA NXX is a portable code. If so, the 7 digit dialed number would be prefixed with the NPA and a 10-digit query (e.g., 679-887-1234) would be launched to the routing database. The routing database then would return the LRN (e.g., 679-267-0000) associated with the dialed number which the local service provider uses to route the call to the appropriate switch. The local service provider then would formulate an SS7 call set up message with a generic address parameter, along with the forward call indicator set to indicate that the query has been performed, and route the call to the local service provider's tandem for forwarding. LRN is a "single-number" solution because only one number is used to identify the customer in the serving switch. Each switch has one network address-the location routing number.

B. Five Indiana MSAs Impacted

The FCC's order directed the implementation of long term number portability in the Country's 100 largest Metropolitan Statistical Areas (MSAs). Included in the 100 MSAs listed are Indianapolis, Gary, Fort Wayne, Louisville, Kentucky, and Cincinnati, Ohio. The FCC order requires long term number portability to be operational in these MSAs during times specified starting in January, 1998 and lasting through December, 1998.

Date Range MSA
1/98 - 3/98 Cincinnati, OH
4/98 - 6/98 Indianapolis, IN
7/98 - 9/98

7/98 - 9/98

Gary, IN

Louisville, KY

10/98 - 12/98 Fort Wayne, IN

C. Specific Indiana Offices Selected

In order for the incumbent LECs (ILECs) to perform the necessary network upgrades for exchanges where bona fide requests for long term number portability have been received, it was imperative that competitive carriers identify those exchanges where they intend to utilize number portability. To do this, each ILEC operating in these areas provided a list of its exchanges serving the five Indiana MSAs. Agreement was reached that the lists would include all offices with switches physically located in the MSA boundary. These lists (which included the offices, MSA, Exchange English Name, CLLI, and NPA NXX) were sent to carriers who the IURC had identified as having petitioned the Commission to become a competitive LEC or ones who have expressed an interest in petitioning to become a competitive LEC providing local telephone service to the public in Indiana. (The distribution list was derived from the service list utilized in Cause No. 39983.) Although the task force has agreed to follow the Illinois task force and select only those exchanges (instead of all offices) within a MSA that a competitor plans to compete, this is contingent upon approval from the FCC in its order on reconsideration.

These carriers were asked to return the lists of offices where they desired long term number portability to an independent third party, Mr. Brad Behounek, by September 18, 1996. At the October 7, 1996 task force meeting it was determined that Mr. Behounek had received information from only one carrier, thus a new schedule was established. On or before October 21, 1996, the carriers were to submit their lists of requested offices, and by October 28, 1996, the lists were to be summarized by an independent third party and returned to the IURC. During the conference calls that were held in November it was determined that the lists were still not compiled and that some carriers had requested all offices. After the IURC staff discussed with these companies that only the exchanges where they wanted LTNP were to be selected, these companies were given until December 3, 1997 to send their revised lists to Mr. Behounek. He then compiled the master list and provided it to the IURC staff on December 9, 1996. The IURC staff distributed the list at the task force at the meeting on December 10, 1996. After the ILECs received their lists, they then complied the estimated costs to provide LTNP. A list of the offices where LTNP will be offered in accordance with the FCC schedule is included in Appendix C. Additional offices will be handled via a bona fide request as specified by the FCC order.

IV. Small ILEC Issues/Position

Implementation of long term number portability for facility based competition is an important and critical issue for the small Indiana ILECs. The Indiana task force primarily focused on moving ahead with number portability implementation. The task force did not give consideration to the small ILEC implementation problems, economic impact upon the small ILEC areas, nor the impact as measured by the rates paid by small ILEC subscribers. The Indiana task force focused its efforts on the Illinois workshop experience. It is important for the Commission to understand the significance of five facts:

  1. No small ILEC was involved in the number portability efforts in Illinois.
  2. Illinois is not a flat-rate local service state like Indiana, which impacts recovery of per-minute or per-message costs arising from the processing of calls ported to customers.
  3. The cost of deployment and operation of number portability including administrative and bill process charges is unknown.
  1. Small ILEC EAS routes will be affected.
  2. Every subscriber administrative function will be affected.

Complete details of the concerns and issues identified by the small ILECs are in Appendix A. Consideration must be given to the impact of long term number portability on the small ILECs before moving ahead. Appendix A indicates how this can be done very quickly and simply.

V. Costs

The estimated one-time cost to implement LTNP in the currently requested offices (per the list provided by the IURC on December 10, 1996 and listed in Appendix C) in Indiana is:

Incumbent LECs costs: $ 41.6 Million

Competitive LECs costs: $ 0.7 Million

(Note: three incumbent LECs and two competitive LECs reported costs which are included in the above estimates.)

To assure confidentiality of specific company information, these figures represent the total estimated one-time initial investment costs (through 1998) for incumbent LECs and new competitive LECs who submitted estimates to the IURC. It does not include any of the costs for the (approximate) 5% of the access lines served by the small LECs. LEC recurring costs and IXC costs (recurring or non-recurring) are not included.

The above mentioned LEC costs include the three types of costs that were defined by the FCC. Per the FCC order in CC Docket 95-116 issued on July 2, 1996, paragraph 208, the three types of costs involved in providing long-term service provider portability are: "(1) costs incurred by the industry as a whole, such as those incurred by the third-party administrator to build, operate, and maintain the databases needed to provide number portability; (2) carrier-specific costs directly related to providing number portability (e.g., the costs to purchase the switch software implementing number portability); and (3) carrier-specific costs not directly related to number portability (e.g., the costs of network upgrades necessary to implement a database method)."

Per the Commission order, no discussions were held regarding cost recovery and allocation issues. Competitive neutral cost recovery, specific to Indiana, will be discussed at a later time.

VI. LTNP Database for Indiana

Long Term Number Portability uses databases to route calls to portable numbers. Copies of the LTNP databases are resident in participating networks for efficiency, while the master database is maintained by a neutral third party. For every ported number, the master LTNP database stores the network address (LRN) for call routing, the SS7 addresses for routing non-call associated signaling to the actual destination, and the current local service provider. On July 2, 1996, the FCC issued an order in Docket 95-116 which endorsed a neutral third party administrator to be selected by NANC (North American Numbering Council) or allowed a state to develop its own database administration rather than participate in the regional database, while still meeting national technical requirements. NANC recommendations are due in April, 1997, with an expected endorsement of regional databases.

The Indiana task force has decided to follow the model developed in Illinois. This means Indiana will use the database which will be created for Illinois and can be made large enough to handle several other states. The database is owned and administered by Lockheed Martin. A Limited Liability Company, which will manage Lockheed Martin, has been established among participating Illinois carriers. The following discussion reflects the process used in Illinois, which is expected to be utilized in Indiana.

The Number Portability Administration Center (NPAC) will maintain a database of ported customer information. This information will be used by all carriers in a geographic area. The information will be supplied by the local service providers through a standard interface. It will then be downloaded to carriers requesting the information through another standard interface. The information will be used to route and bill calls to and from customers that have decided to port their service. The overall management of the NPAC will be performed by a neutral third party, Lockheed Martin, the NPAC supplier. The basic processes which involve LTNP administration (when a ported number is involved) are installation, repair, and disconnect. The basic functions include: coordinating service order processing between porting service providers; propagation of database updates (downloads) upon service order completion; and housekeeping (user support calls, audits, reports, billing, mass changes, etc.)

A Limited Liability Company (LLC) provides a vehicle to hire and manage a neutral third party supplier of the NPAC. The LLC is formed to establish guidelines for the joint management of the NPAC. It contains provisions governing central issues in the process, such as how the members establish new features, funding levels of the participating members, rights and responsibilities of each member and the voting structure of its members. One of its main functions is to enter into and provide ongoing management of a contract with the selected supplier of the NPAC. The LLC will then act as the single point of contact to deal with the supplier on issues such as adherence to the LLC technical requirements and system performance.

The LLC has no responsibility for cost recovery, nor is it responsible for rendering bills and collecting funds for the NPAC. Other than a small initial capital contribution from each member to cover start-up costs, and small periodic assessments for administration expenses, there is no cash flow through the LLC. Start-up costs in Illinois are currently estimated to be $10,000 per member. A similar cost is expected in Indiana.

Each service provider separately contracts with the NPAC administrator for services. This includes those service providers which upload and download data, as well as those service providers which download only. The NPAC administrator will bill each service provider separately.

The LLC will not be involved in the arrangement between the NPAC administrator and the service provider. However, in order to ensure that all service providers are treated fairly by the NPAC administrator, the LLC will attempt to negotiate an agreement with the NPAC administrator so that any service provider purchasing services from the NPAC administrator will do so on uniform terms and conditions regardless of whether the service provider is a member of the LLC or not. Future membership in the LLC will be open to facilities-based certificated local exchange carriers which sign the LLC Agreement and which pay a proportionate share of the start up and operating costs of the LLC. A decision to participate in the LLC is an individual company choice.

VII. Implementation Sub-Committees

The use of regional sub-committees to address the many implementation issues associated with the implementation of LTNP has been agreed to by the Indiana task force. Several sub-committees, which are now regional, were formed in Illinois:



Coordination Create and manage a comprehensive LTNP plan.

Facilitate communications among LTNP subcommittees.

Legal Identify and resolve legal issues associated with the LLC.
Billing and Rating Identify rating and billing impacts of LRN.
SCP/STP Develop, document and put under change control the baseline SCP/STP requirements for LRN.
Switch Requirements Develop switch requirements for LRN.
Funding, Cost Recovery, Tariffs Cost identification and inter-carrier cost recovery methods.
Local Numbering Administration Support activities involving the drafting of the SMS RFP, selection of SMS vendor, and implementation of the SMS.
Operations Focus on inter-service provider processes & interfaces to enable excellent customer service.
Operator Services Develop requirements for the operator service switch in the LRN environment.

VIII. Future Plans

The task force has identified the following issues as we move forward implementing LTNP in Indiana.

  1. Merge the Indiana task force into the regional sub-committees for purposes of implementing LTNP in Indiana. (Underway)
  2. Finalize NPAC administration plans and evaluation of NANC recommendations regarding database implementation. (Database Administration Subcommittee)
  3. Decision of specific participants to join the LLC. (Specific companies)
  4. Develop Indiana specific LTNP deployment plans for each participating networks. (Operations Subcommittee)
  5. Develop Indiana specific test plans for each participating network. (Operations Subcommittee)
  6. Competitively neutral cost recovery. (Cost Recovery Subcommittee)
  7. Identify Cellular impacts and determine an implementation plan. (Cellular companies)
  8. Address small ILEC implementation issues. (Small ILECs)

The Indiana LTNP task force recommends that the IURC endorse the task force decision to work with the regional sub-committees for purposes of implementing LTNP in Indiana. The regional teams will address many issues which impact all states in the region, as well as working on specific plans for implementation in Indiana. As a result, the existing Indiana LTNP task force will only meet on an as needed basis in 1997.