B u i l d i n g T h e W i r e l e s s F u t u r e ?
Cellular Telecommunications & Internet Association
1250 Connecticut Avenue, NW Suite 800 Washington, DC 20036 202.785.0081 phone 202.785.0721 fax www.wow-com.com
February 27, 2002
Mr. William F. Caton
Federal Communications Commission
445 12th Street, S.W.
12th Street Lobby, TW-A325
Washington, DC 20554
Re: Ex Parte Presentation
WT Docket No. 01-184; CC Docket No. 99-200
Dear Mr. Caton:
The Cellular Telecommunications & Internet Association (?CTIA") would like to
submit this letter for the record in the above-captioned proceeding. We apologize that
that this letter was inadvertently not filed in the above-captioned dockets.
Pursuant to Section 1.1206 of the Commission?s Rules, this letter is being filed
with your office. If you have any questions concerning this submission, please contact
February 13, 2002
Honorable Michael K. Powell
Federal Communications Commission
445 Twelfth Street, S.W.
Washington, DC 20554
Re: Wireless Local Number Portability Mandate
CC Docket No. 99-200; WT Docket No. 01-184
Dear Mr. Chairman:
The current debate over extending the number portability mandate from local exchange
carriers (for whom it was required by law) to competitive wireless carriers (where it specifically
was not required by Congress) accepts without challenge that there is a positive cost-benefit
result. CTIA disputes that approach, and seeks to assist the Commission in making its required
cost-benefit analysis as rapidly as possible by providing the following information, incorporating
by reference the submissions you have received from various wireless carriers.
Wireline experience: There is scant evidence that wireline consumers have received
benefits to justify the $3 billion they were forced to spend for local exchange carrier number
When the Commission established the rules for wireline number portability back in 1998,
the then-Chairman cautioned the Commission would ?revisit today?s decision if it appears that
consumers will end up paying for number portability before they have a competitive choice in
local phone service.? Unfortunately, four years later it is clear that wireline number portability
has amounted to little more than a costly experiment that has failed to foster competition as
Congress and the Commission had intended.
The collapse of competitive local exchange carriers over the last four years, during which
time 225 carriers have gone bankrupt or been absorbed by others, has made it clear that number
portability ? by itself ? is not sufficient to insure a competitive market.
The Consumer Federation of America?s Gene Kimmelman put it well in 1999, "number
portability is just the quintessential example of what's gone wrong [with telecommunications
deregulation].? ?You're paying for the benefits of choice -- the problem is, you pay, but there's
no one there to give you the benefits, to give you the choice. It makes no sense.?
Wireless reality: Fortunately there is choice in the wildly competitive wireless
marketplace ? without number portability. The Commission stated in the most recent CMRS
Competition Report that the CMRS industry ?continued to experience increased competition and
innovation as evidenced by lower prices for consumers and increased diversity of service
The various filings made by wireless carriers with the FCC have demonstrated that the
incremental costs of providing number portability to wireless subscribers will greatly exceed the
costs of wireline portability implementation because of the much greater complexity required to
separate the wireless subscriber?s MIN from the MDN, and the need to deploy a new inter-carrier
communications system to accommodate wireless customers? expectations and the industry?s
diverse distribution channels.
CTIA urges the Commission to consider the cost/benefit analysis associated with wireless
number portability to determine whether it is truly warranted. Wireline number portability has
fulfilled the fears expressed by the then-Chairman when it was enacted; its costs to consumers
far outweigh its consumer benefits. There is no evidence to suggest that the higher costs
associated with wireless number portability will not also fall short of the required cost-benefit
Wireless number portability is estimated to cost wireless carriers almost $1 billion in its
first year and a half-a-billion dollars every year thereafter. Each dollar spent on number
portability will have an impact on consumers. Post mandating wireless number portability the
choice will be clear: either increase consumer costs through fees or pricing, or reduce the amount
of capital carriers can invest to continue expanding their coverage and service quality (or both).
In deciding this issue the Commission will determine if the wireless industry should
spend this money to reduce blocked and dropped calls as customers are asking, or if the money
will be spent on something that will be of value only to a few in the industry the Commission has
called the ?most competitive market in the telecommunications industry.?
Finally, CTIA and its member companies respectfully request the Commission to make
its decision as rapidly as possible. Wireless carriers are having an extremely difficult time
making critical resource allocation decisions affecting pooling implementation in the absence of
clear direction from the Commission on the outcome of the pending petition for forbearance.
This uncertainty is not good for carriers or consumers, and we urge the Commission to resolve
this matter as quickly as possible.
Very truly yours,
Thomas E. Wheeler
cc: Hon. Kathleen Q. Abernathy
Hon. Michael J. Copps
Hon. Kevin J. Martin