SEPARATE STATEMENT OF 
ACTING CHAIRMAN MICHAEL J. COPPS, APPROVING
Re:  Local Number Portability Porting Interval and Validation Requirements, WC 
Docket No. 07-244, Telephone Number Portability, CC Docket No. 95-116, 
Report and Order (May 13, 2009)
It had its doubters and detractors early on, to be sure, but number portability has 
been, I do believe, a significant success. Technology has brought consumers so many 
ways to help us keep in touch, no matter where we are, and one of our important jobs at 
the FCC is to facilitate consumers being able to use these new products and services—
and use them in a timely fashion.
It appears to be the unanimous judgment of this Commission that a one-business 
day porting interval for simple wireline-to-wireline and intermodal ports best serves 
consumers and is nevertheless altogether do-able in the time-frame we provide today. I 
am pleased to support the item. 
In the 1996 Telecommunications Act, Congress imposed a number portability 
obligation on providers so consumers could retain their phone numbers when switching 
carriers. This was both consumer-friendly and competition-friendly. As a result, gone 
are the days when you were bound by your existing service provider, regardless of 
service quality or rates, simply because you had grown to know – and be known by –
your telephone number. Gone are the days when making that effort to change service 
providers would include sending cards or making calls to friends, family, colleagues, and 
clients – just to make sure others could continue to reach out and touch you. Instead, by 
easing consumers’ ability to change voice service carriers, we encourage providers to 
become more competitive if they want to keep their customers.
Of course, we learned that when switching voice providers, simply allowing 
consumers to retain their telephone numbers would not be enough to break down barriers 
to competition. Unlike changes in other types of services, such as video or broadband, 
when a number is being ported, the provider winning the customer must communicate 
with the provider losing the customer. This necessary interaction between competitors 
requires processing and time, both of which allow providers opportunities to make a 
change in voice providers unpalatable to just about any consumer. While the wireless 
industry has adopted a standard 2.5 hour porting interval for wireless-to-wireless ports 
voluntarily, thereby avoiding most opportunity for mischief, there has been no such 
industry-wide voluntary interval for wireline-to-wireline and intermodal ports. Thus, the 
Commission was compelled to implement a mandatory interval so that consumers of all 
voice services can realize the true benefits intended by local number portability.  
Twelve years ago, the Commission implemented a four-business day interval for 
wireline-to-wireline and intermodal simple ports. Since that time, we have considered 
shortening the interval for such ports, and have encouraged the industry to update its 
standard interval—all to no avail. So today, finally, we address the issue, something I 
proposed we do in the Commission’s 2007 Local Number Portability Notice of Proposed 
Rulemaking. At that time, I was optimistic about moving forward with the proceeding.
Well, it took too long, but I believe in this Order we do, albeit belatedly, what I then 
suggested.
While this item does shorten the porting interval significantly, I recognize that 
many providers will have to make real-world changes in their porting procedures to fulfill 
this requirement. So we herein direct the North American Numbering Council (NANC) 
to develop in 90 days new local number portability process flows that take into account 
the shortened porting interval. Then we give providers time to implement and comply.
Nine months—although it may seem to some a long time to implement a much needed 
change—strikes me as appropriate, given the significant reduction of the current interval 
and the difficulties of our current economy.
As much as we strive to put together the best item possible, no Order is perfect, 
and this one is no exception. We have a few loose ends still to tie-up—other standards 
surrounding porting processes and “non-simple” ports. In particular, as the Order stands 
now, the shortened interval still applies only to simple ports. Some of the non-simple 
ports look no different to consumers than simple ports, yet the shortened interval adopted 
in this Order will not apply. All consumers should be able to benefit from the shortened 
porting interval. We do, however, take these matters up in the Further Notice, and I look 
forward to addressing them in the relatively near future.
Thanks to our FCC team for their hard work over a long time here, and special 
thanks to my colleagues for pursuing a pro-consumer and achievable position on this 
item. I welcomed their pro-consumer input. And I look forward to witnessing and 
experiencing the many benefits that will, I am confident, flow from the Commission’s 
adoption of this item.