(or, This is How Number Portability Really Works)
Update: Case closed (details below).
In some of my academic writing I deal in legal anthropology. That area of scholarship makes a lot of noise about the big differences between laws as they are written in the book and laws as they are lived in the field. In the spirit of evolving, unfinished field notes, this blog post is a description of what happened last month when I tried to become a Comcast customer. It is about telecommunications regulation. Sort of.
In short, I am in what some bloggers have called Comcast Hell and I invite anyone else in there to join me in commiseration.
For some time now you’ve been able to buy basic telephone service from a cable company in the US. It’s called “cable telephony” or Digital Voice. It is a version of VoIP where the cable company (in my case, Comcast), uses PacketCable extensions or something similar to allow packetized voice over their cable network with quality-of-service guarantees. I decided to try it out. I don’t expect anyone to read the attached log of what happened; it reads like cement. It is here because I had to write it, not because I expect anyone to want to read it. The lessons are:
Comcast is dysfunctional.
Number portability is remarkably difficult (contrary to the writing about it).
Carriers may be actively discouraging number porting.
The regulatory consumer complaint system is dysfunctional.
Feel free to add more lessons in the comments. Here is the log. I am still trying to become a Comcast customer so this log is unfinished.
Updates after the original post date:
3/23: Added Mar 23.
3/26: Added more to Mar 23. Added Mar 25, 26.
3/28: Added final entry, Mar 28.
Becoming a Comcast Customer
In the form of an event log.
Feb 21
I order new Comcast Digital Voice and Internet service using the Web form (to receive the Web discount). I request to keep (port) my AT&T wireline phone number. Everything looks OK, but at the end of a long series of forms I am asked to have an online chat with customer service because of a problem with my order. The rep tells me that he isn’t sure what the problem was, it just doesn’t go through sometimes. It looks OK now, he types. I am directed to fill out a third-party online number portability request form (these were instituted to prevent carriers from switching customers away from other companies without telling them). I do so.
I requested an installation appointment on Thursday (Feb 24; three days away) but the rep says this might not allow enough time for my number port to come through from AT&T. So instead am re-scheduled for March 4 – over two weeks away! Finally, the chat person tells me that the problem with my order looks like it was that my number is “on hold” from AT&T and can’t be ported until AT&T releases it. They could be holding it for an unpaid bill, he types. He tells me to call AT&T in the morning (they don’t have 24-hour customer service) and deal with the hold, then call 1-800-XFINITY to reinstate the order at that time.
Feb 22
I call AT&T and they deny having a hold on the number. They even say there is no such thing as a hold like the one I describe, and that it would not be legal. They try to get me to stay with AT&T. I decline, since U-Verse skipped my house and only serves the rich suburbs in my town. 50 Mbps or bust!
Feb 22
I call 1-800-XFINITY as instructed and after the phone menu I am told by a nice guy with a distinctive Chicago accent that there is no record of my request for number portability. Furthermore, he can’t touch my order because it was placed online and he has no authority to do so. He could start over and re-enter the order but this would eliminate my online ordering discount. I explain that the online people actually asked me to call him, and I try to explain about the AT&T “hold” but he just seems confused by this, and says that he has never heard of anything like that. He is sorry, but he tells me I have to get back in touch with the online people via the chat function on the Web site.
Feb 22
As directed, I use the chat function on the Comcast Web site to speak to a representative. The rep can find my order, but says again there is no record of me requesting number portability. The rep says it is no problem and that she can make the number portability request now. I am directed to fill out a third-party online number portability request form (for the second time). I do so. I keep my Mar 4 appointment intact.
Mar 4
The installer arrives and tells me that there is no record of a number portability request for my order. He asks if I want to go ahead with the installation – it will mean turning off my phone service from AT&T.
I ask, “What will happen when people call my home phone number?” He is not sure.
This doesn’t sound like a good idea, so I decline. He urges me to call 1-800-XFINITY to get this straightened out. He explains that he has no power to do anything with the order other than to install it as written. He briefly considers installing only my Internet service but then says that since I ordered it on the Web he cannot change it. He tells me that number portability takes 5 business days.
Mar 4
As directed, I use the chat function on the Comcast Web site to speak to a representative. They tell me that there is no record of me requesting number portability. But after digging a while, the rep finds a note in the work order that says “the services are set to be installed on the said date and you will be assigned a temporary native Comcast number until the porting request could be completed.” (Direct quote from the chat transcript.)
As we are already at eleven days, I ask how long it is supposed to take to complete a porting request but the rep is coy and says “ideally the porting process should be quick…rest assured we will do our best to resolve this as quickly as possible.” Does she know I am so upset I’ll probably blog about this? Cagey.
Just to be on the safe side, the rep puts in another request for a number port. I am directed to fill out a third-party online number portability request form, which I do. (That makes the third time.) My installation appointment is re-scheduled for Mar 10. Another six days. I complain to her about the delay – there are appointments available sooner – but the rep says that is the soonest she will schedule it to ensure the number portability goes through.
Mar 4
Okay I’m clearly getting a runaround. Where to turn? After some Web searching, I file complaint 0528-2011 with the Illinois Commerce Commission, which seems to be the right place to file complaints about this, since it says they regulate telephone service.
I find out from the Federal Communications Commission FAQ page that number portability is supposed to take one business day. Stunning!
Mar 4
@ComcastCares the Comcast twitter guy responds to my ranting on twitter where I used the #comcast hashtag. Sort of a milestone.
Mar 5
A person identifying herself as calling from the AT&T “Office of the President” (unlikely) calls me on the phone about my complaint. She says there is no record of a number portability request being made by Comcast so she is not sure what AT&T can do to resolve this. I thank her for her help. She suggests I should stay with AT&T instead.
I ask her if this is typical Comcast behavior and she diplomatically says that AT&T has rules preventing her from telling me any of her opinions about Comcast.
Mar 5
Why did AT&T call me when I complained about Comcast? I call the Illinois Commerce Commission, concerned that they sent my complaint to the wrong company. Maybe so many people complain about AT&T that they aren’t used to sending them anywhere else. Old habits die hard.
The very helpful and nice man on the phone tells me that by law the Commission does not have any authority over Comcast as a telephone provider. He says that the Commission staff person probably sent the complaint to AT&T because that is the only company they can regulate, and because porting a number by definition involves two companies, whoever fielded the complaint was probably trying to help by sending it to AT&T instead of throwing it away. I ask him, “Who I should complain to, then?” He recommends the FCC. But he doesn’t sound that optimistic about it.
Mar 5
I file complaint 11-C002860-17-1 with the Consumer Inquiries and Complaints Division of the Consumer and Governmental Affairs Bureau of the Federal Communications Commission.
Mar 9
I receive the strangest letter from the FCC. It basically says “we are reviewing your complaint,” but it is mostly incomprehensible.
It is three pages long, and fully half of it is the FCC NOTICE REQUIRED BY THE PAPERWORK REDUCTION ACT AND THE PRIVACY ACT (caps in original). It contains such gems as “A record from this system of records may be disclosed to GSA and NARA for the purpose of records management inspections conducted under authority of 44 USC 2904 and 2906.” Okay then.
Strangely, instead of letterhead the cover sheet contains a crudely distorted and pixilated low-resolution scan of the FCC’s logo. The whole document looks amateurish – as though a teen with insufficient resources were impersonating the government, or parodying them. It does not inspire confidence.
Mar 10
I receive a phone call from Comcast reminding me of my installation appointment later that day. I ask the person on the phone if she has access to my work order. She does, so I ask her to confirm for me that the number port went through.
It did not. She says that the AT&T number doesn’t appear on the paperwork anywhere, and there is no notation about portability where it should appear. It doesn’t look like you requested number portability, she says.
Very frustrated at this point, I ask to speak to her supervisor. She tells me “I don’t have a supervisor.” I say, “You’re seriously telling me you don’t have a supervisor?” She says, “I don’t have one who can help you with this kind of thing.” She says I need to call 1-800-XFINITY, or talk to the technician who is on the way to my house. I decide to wait for the tech.
Mar 10
The technician arrives and tells me there is no record of my request for number portability. Again he tells me this is something he can’t fix, and suggests I call 1-800-XFINITY. I explain that I’ve been through all of this before. He is a nice guy and we talk about it for a while.
He tries to convince me to let him turn on service anyway with a different (new) Comcast number, but I insist that I want my old AT&T phone number. He says that if we set up the Comcast number the number portability people can switch numbers without another technician visit when the number port goes through.
I’m interested, but I ask him what will happen if we switch the lines at my house, then someone calls me on the old AT&T number before the number port goes through.
“For the caller, it will probably just ring and ring, but you’ll get no trace of it at your house.”
I suggest to him that he could install the new Comcast “temporary” number but not plug it into my internal house wiring. That would let me keep the old AT&T line as well as the new Comcast line (which would work only directly at the modem). He agrees. I now have two phone lines.
This costs me $2.29 for every day that I have two phone lines (figured as: $68.83/month for my AT&T Personal Choice (SM) Plan, Local Saver Pack, and Unlimited Nationwide Calling Select (SM) divided by 30 days).
I followed the instructions online and purchased a DOCSIS 3 modem from the Comcast approved modems list. The tech says I cannot use it because digital voice service requires an integrated telephony modem and none exist that can be purchased by consumers. So I have to pay the Comcast monthly rental fee and get the modem from them. That also means I’ll have to wrestle with Best Buy’s nasty returns policy and/or sell the modem I just bought on Craigslist. The technician says that number ports usually take 14 business days (!).
Mar 10
The same lady I spoke with earlier (or perhaps another one with a similar voice?) calls me back to ask about how satisfied I am with the technician visit that just happened. I try to explain my number port problem but she has a questionnaire she must go through first. Ok. The first question she asks is “Did you receive the welcome pack?” I didn’t receive anything except the cardboard box that the modem came in. It doesn’t seem like a welcome pack, but I can’t be sure, so I ask, “What is a welcome pack?” She says, “Please hold a moment,” and then I hear her voice, softer, as though she is holding her hand over the microphone. She calls out to her colleagues, “What is a welcome pack?” I hang up.
Mar 16
The Office of the President at AT&T calls again, again in the person of Kim. She now has my FCC complaint on my desk as well as my Illinois Commerce Commission complaint, she says to my voicemail. She had a thorough search conducted of AT&T records, she says, and as of this morning there is absolutely no indication of any number portability request ever being made by Comcast for my number. She wants to help, she tells me, but she isn’t sure what she can do. (The date for this entry may be off because I’m not sure when this voicemail was left.) But the Comcast tech told me that the number portability people would contact me, that I wouldn’t have to do anything else. Hmm….
Mar 22
I call 1-800-XFINITY and after the phone menu I try a different tack. I just say that I want a supervisor. No supervisor is available now but one can call me back.
The guy is really nice and he says why don’t I let him have a crack at fixing my problem while we wait? He says, “I’m really good with these.” So we go through the whole deal and he says (drumroll) that there is no record of me ever requesting number portability. I tell him this conversation always happens this way. I am trapped in an infinite loop. He says it will work this time. I am directed to fill out a third-party online number portability request—this time by voice. He messes up the phone transfer somehow so I get to hear the voice menu intended for him. I select the menu option “initiate a third-party number portability request for customer.” I am instructed to disconnect, but I stay on the line and I get the part for the customer (me). I complete the prompts.
The initial directions ask me to “speak in my own voice.” (?)
Mar 22
I get a voicemail from Prashanth that says that a technician visit to my house is required. Why would I need a technician to visit to change the phone number of a telephone service that is already connected? I don’t know why this would be the case, it contradicts the last thing they said but… ok. They automatically scheduled one that is during a time that I can’t do it. I follow their instructions to reschedule by calling their 1-800 number and entering a sequence of menu codes. The voice interface locates my appointment, but when I press the number for “re-schedule this appointment” I am inexplicably read a recording about how to reboot my set-top box to correct for on demand video problems such as error 32.
I think: “I must have pressed something wrong.” I re-do the entire phone tree only to be presented with the same message.
Mar 22
I call Kim again at the “Office of the President” at AT&T. Mostly because she is reachable by phone — unlike Comcast. She still says there is no record of Comcast requesting my number be ported anywhere. She says she’ll look into it again. In desperation, I ask her if she has any way to reach someone at Comcast by phone. Is there a counterpart at Comcast’s “Office of the President”? Perhaps Kim lunches with them when they visit Philadelphia? No.
Mar 22
Still finding Comcast impenetrable, I call the FCC at the number on my strange letter from them. There is a complicated phone menu system that does not include any option that describes what I want to do (speak with someone about my complaint), although it does include numbers to use if I am a member of the press (as a Huffington Post blogger, I should have picked that one), or if I wish to participate in an auction for electromagnetic spectrum.
The woman I finally reach, who is very nice, looks up my file. She tells me that they have received no official reply yet from Comcast or AT&T, but that these companies are required to respond to my complaint. I ask her how long it is supposed to take to do number portability. She asks me a few questions about it and then says “one business day.”
I explain my situation in great detail. She agrees that the Illinois Commerce Commission has no authority, and says that the regulations on number ports are very clear. The company must process your number port in one business day or they must contact you and tell you why they can not. I tell her that no one at Comcast will admit that they are supposed to do these things, and that their estimates of number port time actually range from 5 calendar days to 14 business days. I am now at 31 days. She seems very interested in this, although perhaps she is being polite.
She finally says very sternly, “Well if they can’t accomplish this port in one business day they will have to explain this situation in writing to the FCC.” By mid-April. Until then, I should just hang on. But I am welcome to call the FCC for updates anytime. I find this unsatisfying.
Mar 22
The Comcast supervisor never called me back.
Mar 23
A Comcast robot called me to confirm the appointment I didn’t make (see a few entries back). I pressed the buttons to speak to a representative, and the representative agreed with me that there was no reason for a service call. The rep didn’t know why the appointment had been made, and said she would need to transfer me to the phone department as she didn’t understand this situation.
After I was transferred and explained everything all over again to the phone department rep, she said, “hang on a moment while I look at your file.” Then after a long pause she commented softly to herself, “hey, this is all screwed up.” She asked me to hold on while she spoke to the porting department. For a very long time.
Then she came back on and said triumphantly, “we have the number.” But after a long period of silence and some typing noises she said, “I’m going to need to reach out to someone for some assistance with this.”
After another pause she said that the number would be activated on Friday. When I pressed her about the ongoing problems with the order, she blamed AT&T. “When we make a number port request if AT&T doesn’t release the number to us, it just lapses in our system, it goes away and needs to be made again. Probably AT&T didn’t release the number.”
I calmly explained that AT&T told me (repeatedly) that Comcast never requested the number and that I suspected Comcast had some sort of problem in its internal processes that caused these requests to disappear she said, “I’m sorry that you feel that way.” But she assured me everything would be fixed on Friday.
Mar 23
@ComcastBill on twitter asks me to send him my account information. I send it to we_can_help@comcast.com along with the log from this blog post. This produces a response in just 27 minutes, but it is “How can we help?”
I ask for my number portability to be completed. I also ask to speak to a supervisor again. I say, “connect me someone with some kind of authority to actually do things at Comcast…The bigger picture issue is that the experience described in the post indicates some systemic problems. It looks like your computer system is simply losing these requests. Someone at a higher level than your front line customer reps needs to look at this.”
But (as of Mar 26) I get no reply.
Mar 25
Yay, it’s deadline day. This is the day that the rep who said “we have the number” told me the number port would be executed. But… it isn’t. I guess I’ll give them until midnight.
Mar 26
Midnight. No luck.
Mar 26
I write back to Kim at “Digital Media Outreach” with this note:
Hi Kim, The number port did not happen on Friday, as I feared. I asked to speak to a supervisor or someone higher up at Comcast. You did not reply to my message. Please reply, Christian
I swear I should probably call 1-800-XFINITY but I’m not sure I have the strength.
Mar 26
My first Comcast bill came in the mail. I see I have to pay $7/month for modem rental, contrary to my earlier information. My installation charges are:
CDV Service Activation $10
HSI Promo Install $50
$25 Install for .com -$25
CDV Promo Install $40
$25 Install for .com -$15 [sic]
Looks like some typos? Anyway, looking at the numbers only that’s $100 of installation fees minus $40 in discounts. That means even if I had been able to order the same service from another provider (I can not), I would still be paying $60 just in switching costs (plus the modem rental). That’s competition.
Mar 26
I call 1-800-XFINITY. This time, I just ask to speak to a supervisor right away, right after I get through the telephone menus. But the supervisor is talking to another customer. The rep keeps coming on the line and apologizing for the supervisor not being ready yet.
Since we’re still waiting for the supervisor, the rep verifies all of the information on the account and we go over the whole story again. Interestingly, he says that according to his information, my old wireline AT&T phone number *is* the Comcast number that I have now.
Let’s pause and appreciate the significance here. Something has actually happened at Comcast. For a month my problem was that Comcast never had any record of me requesting a number port. Now it appears I have a new problem — they now think that they’ve completed the number port.
My rep is so sure that I am the one confused that he asks me to hold. Then he calls my AT&T number without warning me . I answer (on the phone with him twice now) and say “My Comcast phone did not ring. This is not the phone connected to my cable modem.” He says guiltily, “just double-checking.”
I have a timer on my phone — I was connected to a supervisor, Ian, after 32 minutes. (We then spoke for 15 more minutes for a total call time of 47 minutes.)
While Ian was polite, his main move was to apologize profusely and in an extremely scripted way. He also kept repeating that the number port was probably on hold from AT&T, or that there was some delay by AT&T. He said that the number was “in their system” and that they were just waiting for AT&T.
He said that the port would be completed within three business days of the successful port request, which showed in his system as Mar 22. I pointed out that three business days had already elapsed.
Now the math started to get pretty weird. He said that three business days equals 72 hours but that these were “business hours” and not regular hours. Since we know that there are 8 business hours in a work day, that actually works out to 9 business days. So… maybe by April 1?
After a huge amount of me repeating the same details about my case over and over again, I had a breakthrough. Ian admitted–probably due to fatigue–that he was aware of the FCC’s “next-day” (24 hour) porting rule, and that he knew Comcast was breaking it. But he tried to explain why some numbers weren’t subject to the rule.
I told him that this number didn’t fit any of the exceptions to the rule. I had my Web browser open so I listed the exceptions. He then said that the estimate of three business days was not an industry standard estimate, it is the estimate that Comcast received from AT&T when my number port request was entered into the system on Mar 22. He said that they can’t do anything on the Comcast side because they are waiting for the phone line “configuration details” to be sent over from AT&T.
He says that they know all about “next-day ports” at Comcast but that AT&T doesn’t do them, in his experience, no matter what the details of the number are and no matter what the rules at the FCC say. He offered to check with the number portability office at Comcast to ensure they were doing all they could at their end, and call me back.
After the experiences chronicled above I was pretty sure everyone at Comcast was lying about everything. But except for the crazy math, this had some solid ring of truth to it. Partly because Ian didn’t sound like he was reading a script when he was saying it. He said he would call me back in 30 minutes after checking this out.
Mar 26
Well, he never called me back.
Mar 26
Got a phone call from Comcast Corporate Public Relations. At first I thought it was Ian or @ComcastBill… or really anyone at Comcast that I had repeatedly asked for a supervisor. I thought, “Finally! This is it! Comcast CORPORATE.” But no, this call is in regard to my FCC complaint, filed March 4. AT&T called me back on that the next day, but after three weeks it is great to hear from you also, Comcast.
So I am floored again: why is he calling? To personally apologize for my inconvenience. They are very big on scripted apologies at Comcast, as we all now know from this blog. He told me that he saw from my file that my problem had already been resolved but he just wanted to check in to apologize.
In fact, nothing had been resolved. We are clearly deeply into the second phase of the Comcast dysfunction. The first was “unable to remember, acknowledge, or act on the request for service.” Now we are in “falsely believe they are already providing the service.”
In fact, he was so sure that the problem had been resolved that he called me back 20 minutes after we got off the phone and said: are you really sure this phone number isn’t working?
No, my friend, the phone number is not working.
He said there was nothing that could be done about it on Saturday in any case. I gather at Comcast Saturdays are only open for apologies. But he said he would ensure that this was absolutely, positively sorted out on Monday.
Mar 28
I almost fell over when I picked up the phone today (Monday) and discovered the number port went through. My one-day number port (according to FCC rules) may have been 1 day in FCC-days, but it came in at 35 days in real life days. I know you’re tired of reading about this but I’m not tired of writing about it. There will be more written about this until my outrage dissipates completely.
(To be continued.)
