Attachment #5
October 28, 2009
The Honorable Betty Anne Kane
Chair, North American Numbering Council
Public Service Commission of the District of Columbia
1333 H Street, N.W., West Tower 7th Floor
Washington, DC  20005
RE: Cox Communications, Inc. and Comcast Corporation’s Minority 
Report to the Local Number Portability Administration-Working 
Group’s (LNPA-WG) Report to the North American Numbering 
Council  - Revised “Required” LSR Fields
Dear Chairperson Kane,
Comcast and Cox commend the NANC for directing the LNPA WG to further 
review its recommendation on standardizing the LSR fields necessary for 
completing simple ports. We also applaud the effort by the OBF to reduce the 
number of fields deemed mandatory. In less than a week, the OBF was able to 
eliminate seven fields, leaving 14 labeled “required.”  
That said, Comcast and Cox believe that, if NANC is to present to the FCC any 
recommendation on which LSR fields are required, the LNPA WG itself should 
fully evaluate the OBF’s submission.  Comcast and Cox continue to believe that 
additional reductions can be made, but in any case, the open participation and 
discussion available via the LNPA WG’s processes could result in a plan the 
FCC is more likely to find acceptable.  We reiterate our concern, expressed in 
our Minority Report of October 13, 2009, that extraneous fields create 
additional opportunities for delay or denial of customer port requests. This 
stands in stark contrast with the goals of the FCC’s Order prohibiting the use 
of more than four fields (FCC 07-188) to validate an LSR. 
Many parties have submitted filings on whether and how to standardize 
required LSR information in the Commission’s open proceeding (FCC 09-41, 
FNPRM). Comcast and Cox agree in principle with the need for such 
standardization. However, Comcast and Cox request that the LSR fields 
standardization proposal as presented to NANC not be included in the NANC 
recommendation to the FCC on implementing the one business day interval for 
simple ports.  We will note that the FCC did not direct NANC to comment on 
the issue of standardization. Consequently, the absence of any suggestions on 
LSR fields in the NANC report is appropriate. NANC fulfilled its duties 
completely.  Should the FCC decide that further work on standardizing LSR 
fields can and should be done by the industry, the standardization proposal 
would remain with LNPA-WG where all industry participants will benefit from 
additional comprehensive evaluation of the ATIS’s OBF proposal, and not just
paying members of the OBF. 
Sincerely,
/s/ Cindy Sheehan /s/ Jose Jimenez
Cindy Sheehan
Senior Director
National Customer Activation & Repair
Comcast Corporation
Jose M. Jimenez
Executive Director
Regulatory Affairs-Policy
Cox Communications, Inc.