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 P6QP$2I=.X &I\  P6Q&P.%2N=.X&N4  pQ&&P,%XJ,\  P6QJP'I(!X,(\  P6Q,P({,C8*X3VC*f9 xQX)0J=.X3L&J*f9 xQ&X.y.G8*X<G4  pQ777777777>>>0eOIIOD>OO%*ODaOO>OI>DOOgOOD%%37%07070%777V7777%*77O77055;%;%%%%%%%%7%7O0O0O0O0O0aHI0D0D0D0D0%%%%O7O7O7O7O7O7O7O7O7O7O0O7O6O7O7O7>23 S- X   )d S- #&I\  P6Q &P#Federal Communications Commission`~(#DA 981763 ă  yx}dddy )x` `  hh@Q3 Before the Federal Communications Commission  S-& Washington, D.C. 20554 ă #&I\  P6Q &P#  S-In the Matter of hh@) x` `  hh@)  S-Telephone Number Portabilityhh@)hCC Docket No. 95116 x` `  hh@)  S5-Petition for Extension of Implementation @)  S-Deadlines of the Cellular Telecommunications@)hDA 972579  S-Industry Association  hh@)  S6 -  MEMORANDUM OPINION AND ORDER TP  S -X` hp x (#%'0*,.8135@8:is based in part on the delays in finalizing the standards necessary for full implementation of number  xportability. Because standards must be in place before software development, network testing, and  ximplementation can occur, delays in finalizing the standards cause delays in meeting the June 30, 1999  xdeadline. Although final standards have not yet been adopted that would permit carriers to implement  x>wireless number portability, including seamless roaming, the standardssetting process appears to be  xnearing completion. CMRS carriers employ wireless technologies including advanced mobile phone  xservice (AMPS), code division multiple access (CDMA) and time division multiple access (TDMA), and  S- xGlobal System for Mobile Communications (GSM).b 9 {O-  ԍx See Letter from Michael Altschul, CTIA, to Steven E. Weingarten, Chief, Commercial Wireless Division,  xJWireless Telecommunications Bureau, Federal Communications Commission, at 23, dated Aug. 25, 1998. Wireless  xnumber portability standards are being developed in Telecommunications Industry Association (TIA) standards  xxcommittees. AMPS, CDMA, and TDMA are the most common wireless technologies in the United States. GSM  {O-is the standard digital cellular phone service found in 85 countries around the world. Id.ĝ The wireless industry has been working on the  xxdevelopment of IS41 standards for AMPS, CDMA, and TDMA technologies through the TR45.2 Ad Hoc  Si - xCommittee for Wireless Number Portability (TR45.2 Committee).Fi 9 {O-ԍxId. at 2.F TR45.2 has developed its standards  S6 - xproposal and distributed a letter ballot to all TIA members.6 9 {O~-  ԍxId. TIA members may respond to comments received in the balloting process in three ways: (1) approved;  {OH- x(2) approved with comments; and (3) submit back to the committee with extensive comments.  Id. According to  x=CTIA, if the standards committee receives extensive comments, "additional time must be spent resolving all  xassociated issues before sending the standard back to the industry for reballoting. As a matter of practice, it is not  {O-uncommon for extensive commenting, and reballoting when facing a difficult technical challenge."  Id. One of the primary considerations in the  x.balloting process is whether to adopt standards for implementation of IS41 number portability through  S - xjthe separation of the Mobile Identification Number (MIN) and the Mobile Directory Number (MDN).x ^9 yO"-  mԍxLetter from Michael Altschul, CTIA to Magalie Roman Salas, Secretary, Federal Communications  yO#- xjCommission, dated July 17, 1998. When a subscriber is roaming, the MIN is used by the carrier in the visited  xmarket to identify the roamer. The MIN permits the visiting carrier to identify the roamer's home market and to  xcommunicate with the roamer's carrier for validation and to prevent fraud. For CDMA, and TDMA based carriers,  x<the MDN and the MIN are the same number and are associated with a particular carrier. In a number portability  xenvironment, however, every MIN will remain integrated in the phone as a tendigit nondialable number and will  xbe associated with a carrier, but the MDN will move with the ported user (every ported subscriber will require a new"~',l(l('"  {O- xiMIN from the new carrier, which will require reprogramming the subscriber's wireless unit).  See generally CTIA Petition, Declaration of Arthur L. Prest at  911. " ",l(l(,,L"  S- x The TR45.2 Committee plans to complete this process by the end of 1998."9 {O-  MԍxSee Letter from Barbara A. Baffer, Ericsson Inc. to Magalie R. Salas, Secretary, Federal Communications  yO- xCommission, dated Aug. 5, 1998. Motorola estimates that the MIN/MDN separation standards will not be completed  x-until November 1998, and that it will take twelve to eighteen months to develop a deployment schedule and to  xiincorporate these requirements into 1999 operations software. Letter from Mary E. Brooner, Motorola, Inc. to  {O-Magalie R. Salas, Secretary, Federal Communications Commission at 3, dated Aug. 7, 1998.  Similarly, wireless number  xportability standards are being developed for GSMbased carriers, through the T1P1/TR46 Committee  S- x(T1P1/TR46 Committee). 9 yO -  ԍx Letter from Michael Altschul, CTIA, to Steven E. Weingarten, Chief, Commercial Wireless Division, Wireless Telecommunications Bureau, Federal Communications Commission, at 23, dated Aug. 25, 1998.  The T1P1/TR46 Committee has scheduled balloting for the first quarter of  Sg-1999.:g. 9 {O5-ԍxId.:  S- ` _x9. ` ` If the TR45.2 Committee adopts standards for implementation for IS41 wireless number  S- xportability through the MIN/MDN separation,xz 9 yO.-  ԍxSome commenters on the WWITF Report recommend the adoption of a Location Routing Number approach  {O- x.in lieu of MIN/MDN separation. See Telephone Number Portability, CC Docket 95116, Comments of the  xTelecommunications Resellers Association on the May 18 Report of the WWTIF, NANC on Wireless Number  yO- xPortability at 1011. With the LRN approach, a unique tendigit number is assigned to each central office switch  xto identify the switch for call routing purposes. We express no opinion here as to whether the CMRS industry should  xwimplement wireless number portability through MIN/MDN separation, the LRN approach, or an alternative method.  yO- x a ninemonth extension will be necessary because,  xfollowing the adoption of separation standards, manufacturers will need additional time to develop and  xtest the necessary software products, produce the software, and deliver the software to carriers for roll out  xin the top 100 MSAs. Estimates from manufacturers of the amount of time it will take them to provide  xthe software to their CMRS customers for the MIN/MDN separation demonstrates the critical need for a  xninemonth extension. According to Ericsson, for example, it will take between twelve and eighteen  S - xmonths after standards are available to deliver software to their CMRS customers for deployment. 9 {O>-  MԍxSee Letter from Barbara A. Baffer, Ericsson Inc. to Magalie R. Salas, Secretary, Federal Communications  {O- xCommission, dated Aug. 5, 1998.  See also Letter from Mary E. Brooner, Motorola, Inc. to Magalie R. Salas,  {O- xSecretary, Federal Communications Commission at 3, dated Aug. 7, 1998. Motorola estimates it will take eighteen  xmonths from the completion of standards work to the first office application and one year from the time of the first  {Od -office application to nationwide roll out. Id. at 25. This  x/twelve to eighteen month period would include eight to twelve months for software development by  xmanufacturers, three to four months of functional testing by manufacturers, and one to two months of  S - xcustomer site testing. 9 yO]$-  0ԍxLetter from Barbara A. Baffer, Ericsson Inc. to Magalie R. Salas, Secretary, Federal Communications  yO%%-Commission, dated Aug. 5, 1998. Following the delivery of software, CMRS operators will need time to conduct  xextensive testing in the laboratory and in the field under varying conditions to ensure reliability, quality  xand integrity of the service. In addition, if a MIN/MDN separation standard is adopted for IS41 wireless  x-technologies, CMRS operators will be required to ensure that every switch in the top 100 MSAs is capable"j,l(l(,,,"  S- x-of recognizing the MIN and MDN as separate and distinct parameters.9 yOh-  {ԍx Letter from Michael Altschul, CTIA to Steven E. Weingarten, Chief, Commercial Wireless Division,  yO0-Wireless Telecommunications Bureau at 3, dated August 13, 1998. Moreover, in order to implement  x[number portability through a MIN/MDN separation, CMRS carriers must make extensive modifications  S- xand upgrades to billing, customer care, sales automation, maintenance, and repair and inventory systems.DZ 9 {OZ-  LԍxCTIA Petition, Declaration of Arthur L. Prest at  1113 Accord 360 Comments at 2; AT&T Wireless  xxComments, Declaration of Carol H. Peters at  510; PrimeCo Personal Communications Comments at 3; GTE Comments at 45.D  S4- ` x10.` ` The record indicates that it will be less difficult for GSMbased carriers to implement  xnumber portability by the June 30, 1999 deadline. In fact, one GSM carrier, Omnipoint Communications,  xInc. (Omnipoint) states that it intends to meet the Commission's current implementation schedule.  xLOmnipoint contends that the financial and technical obstacles cited by CTIA and others do not apply to  xall CMRS carriers, and Omnipoint's readiness to implement number portability heavily weighs in favor  S5- x]of proceeding under the Commission's existing implementation schedule.K5B9 yO-ԍxOmnipoint Comments at 25.K We are not convinced,  xhowever, that the ability of one class of CMRS providers to implement number portability justifies  S- x>retaining the existing schedule.9 yOA-  MԍxSBC, a GSMbased PCS provider, does not share Omnipoint's view that the June 30, 1999 deadline can be  x-met by GSM based CMRS providers. SBC Comments at 3. SBC contends that GSM markets are also affected by  {O- xithe work associated with the separation of the MIN/MDN as it relates to the roaming process. Id. According to  xxSBC, CMRS number portability requires a rework of the GSM 1900/AMPS dual mode specifications to assure that  xLseamless automatic roaming is available, and work is still needed to develop standards to support various PCS  {O+-features. Id. Even if some GSMbased carriers are ready, the majority of CMRS  xcarriers are not far enough along with the development of standards to support seamless nationwide  Si - xroaming.Ji N 9 yOW-ԍxSBC Reply Comments at 3. J We note that many CMRS carriers now use dualmode mobile phones, which allow their  xcustomers to roam in a system using a different technology. Thus, even if all GSM carriers were to  xsupport number portability, a GSM mobile unit roaming into an IS41 system, for example, would encounter difficulties if the IS41 system were not number portability enabled.  Sj- ` P x11.` ` MCI Communications, Inc. (MCI) and WorldCom, Inc. (WorldCom) argue that CTIA has  xnot adequately demonstrated that a ninemonth extension is justified, and that if the Bureau grants a nine xmonth extension, it will be followed by a very high number of requests by individual carriers for  S- xindividual extensions.[ 9 yOO!-ԍxMCI Comments at 4; WorldCom Comments at 7.[ We disagree. The record before us strongly substantiates the claims of CTIA and  S- xothers that a ninemonth stay of the June 30, 1999, deadline is warranted and serves the public interest.!n9 yO#-  zԍxFurther, we do not believe that we have to address the carrierspecific, fivepart test articulated in section  {Ot$- x52.31(d), as urged by MCI. See MCI Comments at 24. The Commission has drawn a distinction between the  xindustrywide relief that may be granted by the Bureau Chief under section 52.31(c) of the Commission's Rules and  xYthe carrierspecific relief that may be granted by the Commission under section 52.31(d) of the Commission's Rules.  {O&- xIn the Order on Reconsideration, the Commission stated that "in the event that a wireless carrier is unable to meet  xthe Commission's deadlines for implementing a longterm number portability method, it may file a request for"' ,l(l('"  xextension with the Commission. If it becomes apparent that the wireless industry is not progressing as quickly as  xnecessary to meet the deadlines for providing querying capability and service provider portability, the Wireless  x;Telecommunications Bureau Chief may waive or stay the implementation dates for a period of up to nine months."  {O- xOrder on Reconsideration, 12 FCC Rcd at 7312,  134; see also First Report and Order, 11 FCC Rcd at 844,  168  {O- x(setting out the fivepart, carrierspecific test that was codified under 47 C.F.R.  52.31(d)). Accord, AT&T Wireless Reply Comments at 2 & n.3; AirTouch Reply Comments at 3 n.4. "D!,l(l(,,"  xThe Commission's rigorous criteria under section 52.31(d) of its Rules will likely deter the filing of  S- xunsubstantiated and frivolous extension requests."` D9 yO-  /ԍxA carrier seeking [an extension of the Commission's number portability requirements] must demonstrate  xthrough substantial, credible evidence the basis for its contention that it is unable to comply with [the number portability deadlines]. Such requests must set forth: XxX` ` (1) The facts that demonstrate why the carrier is unable to meet our deployment schedule:(#`  ` aXxX` ` (2) A detailed explanation of the activities that the carrier has undertaken to meet the implementation schedule prior to requesting an extension of time;(#` XxX` ` (3) An identification of the particular switches for which the extension is requested;(#` x` ` (4) The time within which the carrier will complete deployments in the affected switches; and(#` XxX` ` (5) A proposed schedule with milestones for meeting the deployment date.(#` 47 C.F.R.  52.31(d)(1)(5).  To the contrary, we believe that by granting the nine xKmonth extension at this time, we will allow the industry to work cooperatively towards full implementation  Sg-of wireless number portability and decrease the need for individual carrier requests for deployment.#"gl9 {Os-  ԍxSee 47 C.F.R.  52.31(a)(1)(ii) ("For MSAs identified in the appendix to this part, carriers must submit  xhrequests [for deployment of number portability] by September 30, 1998 . . . ."). Under this rule, if we do not extend  xthe deadline for nine months, before September 30, 1998, CMRS carriers would receive requests for number portability before the final standards are adopted.   S- ` Dx12.` ` Some commenters have expressed concern that any delay in number portability  S- x.implementation may potentially harm related number administration policies, such as number pooling.$V9 {O-ԍxSee, e.g., MCI Comments at 910; WorldCom Comments at 67; ALTS Comments at 2.  x{We share these concerns about the effect of a delay in number portability on number conservation  xtechniques such as number pooling, which is technologically dependent on number portability, and we  S5- xacknowledge that the ninemonth extension will delay further CMRS carriers' ability to participate. We  xbelieve, however, that if CMRS providers are required to adhere to the existing number portability  xschedule with incomplete and untested standards, their billing systems would be unmanageable, and  x[seamless roaming would be difficult. We urge the CMRS industry to work both formally and informally  xwith the states and through industry fora, including NANC, to examine numbering conservation solutions that will preserve and increase numbering resources.  S - ` bx13. ` ` Some of the commenters have argued that neither CTIA nor its supporters have  xdemonstrated they will be able to implement wireless number portability within the ninemonth extension  Sj- xperiod, and that the Bureau instead should impose an interim implementation schedule with milestones.%Xj9 yO%-  ԍxMCI Comments at 1112 (the "CTIA petition and other attempts to delay number portability demonstrate  x[the need for the Commission to define specific interim wireless number portability milestones."); MCI Reply  xjComments at 56 ("The Commission should not be held hostage to the unbounded discretion of CTIA and its"'$,l(l('"  xmembers' failure to commit to a specific implementation schedule."); Omnipoint Reply Comments at 2 (remarking that CTIA has given no indication that nine months will be sufficient to implement wireless number portability). "j %,l(l(,,"  xWe are not persuaded by these arguments. As explained above, the record demonstrates that a ninemonth  xextension is necessary to ensure efficient development of wireless number portability. Furthermore, as  S- xjnoted above, the Forbearance Petition seeks forbearance from imposing number portability requirements  xon the wireless industry until the completion of the fiveyear buildout period for PCS carriers. In that  xproceeding, the Commission will determine whether an alternative implementation schedule is appropriate  xand, if so, the appropriate length of time to forbear from imposing the current wireless number portability schedule.  Si- ` x14.` ` In conclusion, by the action we take today, we delay for a period of nine months the  xfollowing dates in the implementation schedule for CMRS number portability: (1) carriers must submit  xrequests for deployment of number portability in the top 100 MSAs by June 30, 1999, instead of  xLSeptember 30, 1998; and (2) all cellular, broadband PCS, and covered SMR providers must offer number  xportability in the top 100 MSAs including the ability to support nationwide roaming, throughout their  xnetworks by March 31, 2000, instead of June 30, 1999. We take no action with respect to the requirement  xthat by December 31, 1998, all cellular, broadband PCS, and covered SMR providers must have the  xcapability to obtain routing information, either by querying the appropriate database themselves or by  xjmaking arrangements with other carriers that are capable of performing database queries, so that they can  xmdeliver from their networks to any party that has retained its number after switching from one telecommunications carrier to another.  S- III. ORDERING CLAUSES ă  S- ` Qx15. ` ` Accordingly, IT IS ORDERED that, pursuant to section 52.31(c) of the Commission's  xRules, 47 C.F.R.  52.31(c), the petition of the Cellular Telecommunications Industry Association for  xan Extension of the Implementation Deadlines for Number Portability is hereby GRANTED. We hereby  x[stay until March 31, 2000, the requirement that all cellular, broadband PCS, and covered SMR providers  xoffer number portability in the top 100 MSAs, including the ability to support nationwide roaming,  xthroughout their networks. We also stay until June 30, 1999, the requirement that carriers submit requests for deployment of number portability in the top 100 MSAs.  S- x` `  hh@FEDERAL COMMUNICATIONS COMMISSION x` `  hh@Daniel E. Phythyon x` `  hh@Chief, Wireless Telecommunications Bureau " %,l(l(,, "  S-XxP(# APPENDIX OF COMMENTERS ă  S-Comments/Opposition 360 Communications Company (360) Association for Local Telecommunications Services (ALTS) AirTouch Communications, Inc. (AirTouch) AT&T Wireless Services, Inc. (AT&T Wireless) American Mobile Telecommunications Association, Inc. (AMTA) BellSouth Corporation (BellSouth) GTE Service Corporation (GTE) Mobex Communications (Mobex) MCI Telecommunications Corporation (MCI) Omnipoint Communications, Inc. (Omnipoint) PrimeCo Personal Communications, L.P. (PrimeCo)  S -Rural Telecommunications Group (RTG)@@hh@(# Southern Company (Southern) Southwestern Bell Mobile Systems, Inc. and Pacific Bell Mobile Services (SBC) Sprint Spectrum L.P. d/b/a Sprint PCS (Sprint PCS) United States Cellular Corporation (USCC) Worldcom, Inc. (Worldcom Opposition)  S-Reply Comments 360 Communications Company (360) AT&T Wireless Services, Inc. (AT&T Wireless) AirTouch Communications, Inc. (AirTouch) Century Cellunet, Inc. (Century) Comcast Cellular Communications, Inc. (Comcast) Cellular Telecommunications Industry Association (CTIA) GTE Service Corporation (GTE) MCI Telecommunications Corporation (MCI) Motorola, Inc. (Motorola) Omnipoint Communications, Inc. (Omnipoint) Southwestern Bell Mobile Systems, Inc. and Pacific Bell Mobile Services (SBC) Sprint Spectrum L.P. d/b/a Sprint PCS (Sprint PCS)  S-  S;-