The FCC has requested comment on a Petition for Declaratory Ruling filed by Verizon that asks the FCC to clarify that the cost of certain tasks that use the Number Portability Administration Center (“NPAC”) database but are unrelated to number portability or pooling should be borne directly by the cost-causing providers, rather than shared by all telecommunications carriers.  While Verizon’s Petition is confidential and under protective order, the Public Notice indicates that Verizon claims in the Petition that many of its competitors are using the database to reorganize their network configurations, to migrate customers to newer or more efficient technologies, or to enable customers to keep their old phone number when moving to a new address within the same rate center.  Verizon stated that these uses escalate costs and do not further the original purposes of the database, and thus should be borne directly by the cost-causing provider.

Comments and Reply Comments are due on July 15, 2011 and August 15, 2011, respectively.  Parties wishing to file comments can obtain a copy of Verizon’s Petition by signing the protective order issued by the Commission.

Clients with questions regarding this Advisory should contact the attorney assigned to their account.