[arin-ppml] Legacy Space authority

Robert Bonomi bonomi at mail.r-bonomi.com
Mon May 5 17:30:34 EDT 2008

> Date: Mon, 5 May 2008 15:20:50 -0500
> From: "Kevin Kargel" <kkargel at polartel.com>
> To: <ppml at arin.net>
> Subject: Re: [arin-ppml] Legacy Space authority
> >> Ah, but the telephone issue has already been decided, and telco's are
> >> required to let you keep your number and area code..
> >FALSE TO FACT.  _Read_ the document you cite.  I quote:
> >   "If you are moving from one geographic area to another, however, you
> may 
> >    not be able to take your number with you.
> Yes, this is true.  If you move from one area code to another at least
> within the same geographic area you will be able to take the number.

I say again, "FALSE TO FACT". 

  a) that 7-digit number may already be in use in the destination NPA.

  b) the porting rules require *LOCAL* number portability only.  that's why
     it is called "Local Number Portability", aka LNP.

  c) "local" is defined as "within the same rate center", which, by definition
     means it is restricted to a single area-code.  The concept of "rate-
     centers" was developed -before- 'overlay' area-codes existed, and there
     is a built-in assumption of a hierarchical structure, where a rate center
     is part of a single area-code only.  This can result in two rate centers,
     in different area codes, being 'zero miles' apart.

> Also, the statement you included says "you may not be able to", which
> infers "you may be able to"..  What it says to my reading is that if it
> is technically possible to port the number then you will be able to port
> the number.

What you read, and how it is interpreted in the real world, by the people
who do it, is different.  :)

If the 'new' carrier does not have a physical point of presence in the
same rate center at the C.O. of the 'old' carrier that the number is 
currently served out of, the number is *NOT* transferable to that company.
Don't take my word for it, ask the FCC.   <grin>

In theory, it may be "possible" in some circumstances, but the laws and
FCC regulations do -not- require it.  Since it is not 'required', it is,
in virtually all instances 'administratively denied'.  When a thing is _not_
required, you have no recourse if the other party "chooses not to" do it.

> People are moving from state to state and taking their cel numbers with
> them.  This is even happening across a span of more than one state.

No, they are _NOT_.  They are 'roaming' within the cellular network. The 
physical address for the service (where the call is handed off to the PSTN)
remains unchanged.  If a person with a (208) area cell-phone moves to 
Washington, D.C., and keeps their old number, when they're at 8th and I, 
and somebody calls them from 4th and K, it is billed as a long distance call
_to_Idaho_.  In fact, the call is _routed_ to Idaho over the PSTN, and then 
back-hauled to where the cell customer is over the wireless carrier's private
bandwidth.  (there _may_ be 'special case' handling if the calling party is
a cellular caller with service from the same provider as the called party uses.
Repeat, "may" be, not necessarily 'is'.)

Also, a "billing address" is unconnected to the 'service address'. For larger
businesses, it is not at all uncommon for the billing to go to 'headquarters',
many states away from the regional office.  this discontinuity between the
billing address and the point of connection to the PSTN is irrelevant to
phone network routing.

> I don't know what the definition of "geographical area" is, but I assume
> it has something to do with the reach ond interoperability of the telco
> switching networks.

You assume wrongly.  :)

>                      Perhaps a more technically educated telco tech can
> fill in the gaps for us.

You didn't listen to the telco guru.  I've been a telephony manager.  I've
done number porting.  I've fought the battles when the carriers screwed it
up. <wry grin>

It all has to do with how distance-based billing (originally long-distance) 
charges are calculated.  

Telco's have POP (switching facilities, known as a "Central Office", or C.O.)
in _lots_ of places.  What was regarded as 'too many' places to calculate
distances between every pair of C.O.s in the nation, to establish a mileage
charge for calls between those two C.O.'s.  Hence C.O.'s within some degree
of physical proximity were grouped into a single 'rate center'. And distances
were computed _only_ between pairs of "rate centers".  This also had the
advantage of being able to be done _once_, and the results "cast in stone".
When a new C.O. was brought on line, it was assigned (for billing purposes)
to the _already-existing_ rate-center that covered the area it served.

You can "port" a phone number only within the rate-center where the number
is billed.  And then only within the same NPA ("area code" to the average
person).  The latter restriction prohibits multiple people holding the same 
7-digit string in different NPAs from moving into a single vicinity and
fighting about who has to give up 'their' number.

> This doesn't change that if even one person moves from one telco to
> another (whether or not he moves physically) and he has the capability
> to demand to keep his number  - without regard to the wishes of his
> telco - then the number in question is being treated as property with
> value.

Sorry, you're wrong.  _If_ it is property, it is -not- the customer's property.
If it were customer property, he would not have to pay rent to continue to 
retain the rights to he number.  He would have to pay to _use_ the number, 
but not to simply retain it (not in active use).  And 'control' over that
number would not _revert_ to the telephone company that was the last one to
supply that customer with service for it.

The party that manages telephone number block assignments in the U.S does
it as a contractor for the FCC, with the costs of those contracted services
are paid for by assessments levied on telephone service providers in a manner
specified in FCC rules.

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