Renumbering and the '96 Telecom Act

[Larry Honig]

Hi. 

This may seem offtopic, but perhaps not. ARIN itself may need to become
involved in the medium term if and when telephone numbers and IP
addresses converge.

I was perusing the '96 Telecom Act (my usual lite bedtime reading) and I
came across the following:

"All LECs must immediately provide interim number portability measures
such as remote call forwarding ("RCF"), flexible direct inward dialing
("DID") or other comparable and technically feasible methods."

Now my question is: since ISPs and IX operators are not presently
defined as LECs under this Act, are they therefore exempt? If there is
some uncertainty about the durability of any exemption, shouldn't a
prudent Board of Directors (of an IX operator or ISP) be asking
questions now about their liability to conform with an expanded
interpretation of the Act should it occur? How would ARIN's authority
be  exercised when renumbering disputes occur?  

The full text of the portions of the Act pertaining to local number
provisioning can be found here:

http://www.technologylaw.com/techlaw/local_access.html#lnp