Countdown to wireless number portability: Wireless service providers will face significant implementation challenges in complying with the FCC's fast-approaching deadlines

Survey after survey of telecom customers suggests that those customers would be more likely to consider changing service providers if they could retain their telephone numbers.

This capability, commonly known as number portability, is believed to be a fundamental building block of robust competition in the local exchange market. In fact, nationwide deployment of number portability was the tenet on which the Federal Communications Commission crafted its First Report and Order on Telephone Number Portability. The mandate requires wireline and wireless service providers to offer nationwide number portability before June 30, 1999 (see sidebar).

As the deadline for number portability approaches, wireless and wireline providers alike are discovering how difficult the seemingly simple FCC requirement will be to implement.

Complying with the order is a challenge because it involves extensive design, process development, and network and systems reconfiguration, as well as a great deal of employee ramp-up, testing and training (Figure 1). Fortunately for the wireless segment, the wireline segment's start date to meet this deadline is much earlier. Wireless providers can learn from wireline service providers' network and operational experience about what this massive undertaking entails.

At the least, wireless service providers can expect to make significant network and system infrastructure upgrades, develop and manage sophisticated business agreements between vendors and carriers, and forge complex interconnection agreements among carriers. They likely will also need to design and execute precise and coordinated service-order process among multiple carriers

Wireless service providers are advised not to delay, thinking the deadline is still a long way off. Number portability is not simply a technical challenge specific to one functional area. Rather, wireline service providers are discovering that it is an extensive cross-enterprise challenge.

What portability means

The FCC defines number portability in three parts.

Service provider portability. The only form of number portability required by the FCC at this time, service provider portability is the ability of end users to keep the same telephone numbers as they change from one service provider to another. Changing wireline and wireless service providers qualifies as a change in service provider and is therefore within the scope of service provider portability.

Location portability Location portability is the ability of telecom services users to retain existing numbers without impairment of quality, reliability or convenience when moving from one physical location to another.

Service portability Service portability means that users retain existing telecom numbers without impairment of quality, reliability or convenience when switching from one telecom service to another service provided by the same service provider, such as switching from basic telephone service to ISDN.

The driving force behind the required network upgrades is a new Advanced Intelligent Network routing solution that makes number portability possible. The solution, a location routing number, is a 10-digit call routing number that is uniquely assigned to a mobile switch.

Every time a customer changes service providers, or ports, the directory number he or she retains is assigned to a new location routing number at the new carrier's switch.

A third-party regional database, called the number portability administration center, maintains day-to-day location routing number information. The administration center downloads ported number information, such as the location routing number, on a real-time basis to all service providers in a region (Figure 2).

Both wireless and wireline service providers are faced with the challenge of administering their own porting information. This can be done by investing in, developing and managing an on-premises local service management system or by outsourcing this function to a third party.

The local service management system can be developed as a stand-alone operating system, or it can be functionally integrated into an existing operating system.

As the primary interface to the number portability administration center, the local service management system serves two functions.

On the service-order side of a porting transaction, it uploads the number portability administration center with porting information from a porting service order. On the number administration side, it receives real-time call-routing information from the number portability administration center, which must be worked into the network to successfully complete calls.

Accomplishing this requires investing in switching and signaling upgrades. For those wireless service providers that have not deployed SS7 capabilities, the cost and scope of this development may be significant. Service providers must track costs early in the development program and must manage vendors aggressively.

Detailed cost tracking. Although a ruling has not yet been made, the FCC has indicated that it may consider reimbursing carriers for the investments made to implement number portability. To prepare for cost recovery filings, wireline carriers are keeping careful records on number portability investments. Regardless of whether they will be able to recover these costs, wireless carriers should track number portability costs because such tracking also supports future pricing.

Cost tracking begins with clear documentation of the program scope, wherein regulatory, business and technical teams determine which initiatives are funded within the number portability program. Budgeting and tracking mechanisms should track related cost information in sufficient detail to support recovery claims without placing undue burdens on working teams.

Additionally, new or ongoing initiatives might further affect the same network or operating system elements that are affected by number portability. Service providers must carefully document costs for these joint efforts, including all assumptions that influence the costs assigned to each initiative. It is easier to plan the cost allocation than to determine it retroactively. Service providers considering cost recovery filings also should look at internal audits at program start-up and then periodically through the life of the program.

Managing vendors aggressively. Implementing the number portability mandate requires network and system hardware and software provided by third-party vendors. These technologies affect the heart of a service provider's network architecture and operations support systems.

Contracts should be constructed carefully to provide periodic progress and quality checks, address goals and prescribe corrective actions if goals are missed. Subject matter experts from project teams addressing the portability initiative should actively participate in specifying these contracts as well as in periodic reviews and quality checkpoints.

Given the size and scope of the aggressive implementation schedule, early access to vendors' design documents and functional specifications can provide valuable insight into the quality of the final product. For most service providers, the product quality and delivery schedules of third-party vendors are the primary program elements outside of their control.

According to the FCC, the only valid reasons for a waiver are for "causes beyond the control of the carrier." For this reason, contract language should obligate vendors to accompany carriers to the FCC in the event that the timing or quality of their product causes the implementation date to slip.

Organizational impact

Much of the activity required for porting actually takes place before a customer submits a service order. The process begins with a series of database updates and signaling/switching translations for all service providers in a portable area.

In addition, the old, or donor, service providers and the new, or recipient, service providers work closely to plan and coordinate the physical rewiring to execute the porting transaction.

Aside from this external coordination, a smooth customer port requires the integration of systems, processes and training across all business support functions such as order entry, customer care, billing and network management. The ability to hire and train qualified staff will be tested rapidly.

It is more cost-effective if a service provider can automate as much of the process as possible. However, full automation may not be achievable in time for the FCC deadlines. Wireless service providers may need to resort to manual methods until a system solution becomes available.

Think simulation, not just test. Remember that failures in communications or processes--whether within or among service providers--are painfully visible to customers. Number portability dramatically increases the risk of both types of failures because by design, it requires increased interaction at both levels.

Business simulation can be a tremendous enhancement to the traditional testing programs. While traditional testing focuses on meeting functional requirements, business simulation focuses on the entire end-to-end service delivery process--the customer's perspective.

Business simulation helps a service provider establish the quality and reliability of its number portability solution. Early and extensive planning is a key success factor in simulation testing.

In addition to rigorous development of transaction scenarios and supporting scripts, plan for customer-facing employees, such as service representatives, to serve as customers during intercarrier simulation. They'll be well-positioned to capture the customer's perspective of the overall transaction and service quality.

Employees of affected organizations should be intimately involved in intracarrier simulation. Here they can ensure that processes work in a production environment.

Testing priorities should focus first on customer-facing transactions and high-volume internal processes, then on internal operational service and support processes (Figure 3).

Enforce program management disciplines. Because number portability affects a cross-section of the network, program management is a vital determinant of a successful implementation.

A service provider's organizational approach should allow for executive guidance and policy making that are consistent with regulatory assessments and company strategy. A dedicated implementation team composed of senior-level managers can shoulder day-to-day responsibility for the success of the program.

Applying a cross-functional team approach at several levels is essential to resolving common number portability issues such as resource shortages in technical and managerial ranks. It is also necessary to develop a milestone-based schedule to keep the program on track.

As high-risk issues emerge, contingency plans should be developed and incorporated into what-if schedule scenarios. Doing so provides management with an early warning system on the effect of slipped milestones.

Number portability raises hundreds of closely related issues. Issue management tools can provide record-keeping on issue definitions, priorities, impacts and resolutions. These tools become increasingly important as the program accelerates. Periodic readiness reviews also play an important part in successful programs. By measuring readiness for turning up the new capability, these reviews offer a different perspective than the program schedule.

Number portability is a relatively new technology that requires wireline and wireless service providers to expend a significant amount of money, time and human resources.

Still several months away from the first FCC implementation deadline, wireline service providers have had to overcome tremendous implementation challenges to get where they are today. Wireless service providers should expect the same headaches.

Nonetheless, wireless service providers can save a great deal of time and resources by starting as early as possible and by crafting an approach to number portability that leverages the best practices from current wireline implementation efforts.

In its First Report and Order on Telephone Number Portability, the Federal Communications Commission required all cellular, broadband personal communication services and covered specialized mobile radio providers to develop and implement the capability to deliver calls from their networks to ported numbers anywhere in the United States by Dec. 31, 1998.

By June 30, 1999, wireless service providers must offer service provider portability, including the ability to support roaming throughout their networks. In its First Memorandum Opinion and Order on Reconsideration (CC Docket No. 95-116, released March 6, 1997), the FCC further clarified that wireless service providers need only deploy service provider portability in the largest 100 metropolitan statistical areas in which they have received a specific request by Sept. 30, 1998.

Local exchange carriers are mandated to support service provider portability as early as March 31, 1998 in the largest 100 metropolitan statistical areas.