 |
|
|
Number conservation is something that the telecommunications industry has to get more disciplined with, just like we all should eat less and exercise more. But, when someone offers us a pill that is supposedly a shortcut to our goal of a fitter, firmer body, we simply cannot resist. Well, the FCC has a row of number conservation pills in front of it, and they all look tempting, but when you pick up the information sheets, and read about the side effects of each one, it is easy to decide that each one is too costly, not effective enough or simply too difficult to manage. Ultimately, we have to give up on the easy fixes and choose the old fashioned, common sense approach. Unfortunately, that is easy for the wireless industry, but tough for LECs, the FCC and State regulators. The common sense approach to number conservation is Rate Center Consolidation.
When a call is billed using distance sensitive billing, the location of the originating and terminating rate centers (usually telephone switch locations) are used to determine the distance for rating purposes as well as the names of the locations. Using the rate center locations instead of the actual locations of the phones makes a small difference in the calculated distance, but little if any difference in the cost of a call, and avoids the need for the phone company to know the precise location of every phone line. The rate center is determined from the first 6 digits of a North American 10-digit phone number, meaning that the smallest block of numbers that can be assigned to a rate center is 10,000. In the good old (bad old?) days, there was only one phone company, but today, there can be many wireless and wireline competitors, and if they all use the rate center paradigm, they could each chew up 10,000 numbers per rate center.
The use of 10,000 numbers for each competitor in each rate center would not be a problem if a rate center covered hundreds of thousands or millions of people, but unfortunately, they often do not. While the largest in the U.S.A. is Atlanta, with about 3 million people within its boundaries, one of the smallest rate centers is Midland, South Dakota, with under 300 people. Atlanta is unusual in having a single rate center. Most other towns and cities in the U.S. have several.
It is obviously very inefficient to assign numbers in blocks of 10,000 to each competitor in areas where rate centers are small. If several small rate centers are merged together (rate center consolidation), the fill level of number blocks can rise dramatically, even with many competitors in place. Furthermore, if each carrier can decide on their own boundaries, they can be customized to meet a number of objectives, including number conservation.
Wireless carriers generally pay only lip services to the rate center concept. One reason is because they use larger local calling areas as a competitive advantage. Further, for mobile originated calls, billing cannot be determined from the first six digits of the originating mobile’s phone number, but on the actual location of the mobile at the time of the call. The ‘rate center’ of the switch or base station handling the call is generally used to define that location for billing purposes.
Mobile terminated calls do use the rate center concept, because wireline systems are generally responsible for billing these calls. Consequently, because mobile phone numbers are allocated from a common pool throughout the local calling area, a call from a home in a suburb to a mobile phone in the same vicinity, may be rated as a toll call to downtown, if that is where the home wireless switch is located. This has often been hidden from callers to wireless phones by the wireless carrier agreeing to absorb these charges. However, a recent move by Pacific Bell in California will end these arrangements. This may have a negative effect on number conservation in wireless carrier operations, because customers may demand mobile phone numbers that do not incur these charges, moving wireless carriers grudgingly towards the rate center concept.
Another reason why wireless carriers may be forced to bow towards rate centers is to make number pooling work. Number pooling is technically very similar to number portability, using the same infrastructure, but aims to achieve number conservation by sharing blocks of 10,000 numbers between carriers, while maintaining the current rate center boundaries. This would be much more expensive than rate center consolidation, less consumer friendly, much harder to manage and much more error prone. And, it will only work between carriers that respect the same rate center boundaries, which would burden wireless carriers with enormous costs and transition difficulties. Yet, this is one of the most talked-about number conservation approaches. Why would something so ludicrous be receiving so much favorable attention in high places?
The battle between number pooling and rate center consolidation is, from all appearances, Goliath versus David, all over again. Number pooling comes along with a high-tech armory – databases, rules, regulations and procedures – while rate center consolidation does not involve anything new – no new databases, no new inter-carrier coordination, nothing more than a reorganization of data that is already defined in the telecommunication industry’s routing bible, the LERG (Local Exchange and Routing Guide). So, unless it is the aim of the FCC and other authorities to make the life of carriers more difficult, why does number pooling appear to have the upper hand at present? The answer appears to be mainly politics and power.
If rate centers are consolidated, there will be losers: the incumbent local exchange carriers, and state regulators. For consumers, the impact will mostly be positive, and for wireless carriers, there will be little impact, but in the long run it will be positive.
Local exchange carriers will lose because of the loss of intra-LATA toll revenue, which is often distance-billed (unlike inter-LATA long distance, which is generally billed at a fixed rate, regardless of the distance the call traverses), and may cost more than wide-area (inter-LATA) toll calls. State regulators will lose control over rate center boundaries if the FCC decides to impose rate center consolidation as a number conservation measure. Along with loss of control will come a loss of tax revenue from reduced toll revenue. The fear of a power struggle with state regulators is probably one of the reasons why the FCC is avoiding rate center consolidation.
Consumers will generally benefit from rate center consolidation through extended local calling areas, which will reduce the cost of wireline telephone services. However, there may be some confusion regarding billing. Since the name of the location that a call is made to is based on the rate center, calls to a suburban town may be printed on bills as if they were to the city with which the rate center has been consolidated. However, since this will likely make no difference to the cost of a call, consumers will probably accept this change after a period of some confusion. Or, perhaps bills are so confusing already that nobody will notice.
It would appear that wireless carriers are in a neutral position if rate center consolidation is the chosen number conservation approach, but they actually may gain significantly. If rate center consolidation does conserve numbers, the need for area code changes will be dramatically reduced. And, if number pooling is abandoned, the justification for the number portability infrastructure for number conservation will be gone, leading to the possibility that the wireless industry may get permanent forbearance on number portability for competitive purposes.
If engineers ruled the world, rate center consolidation would be implemented tomorrow. For better or for worse, this is not the case. However, hopefully, common sense will prevail, and the FCC will muster the courage to try to persuade (or force) state regulators to seriously act to rationalize rate center boundaries.
© – Copyright