Neustar Wants Industry Comment on Its Petition to Fix ‘Flawed’ LNPA Selection Process
Neustar and Telcordia traded barbs before the FCC in filings Monday, with Telcordia asking the Wireline Bureau to dismiss a Neustar petition to “immediately rectify” the Local Number Portability Administration selection process, which Neustar had said was “flawed in its design and implementation” (CD Feb 13 p13). Neustar asked the full commission to force a public notice seeking comment on its petition, which the Wireline Bureau had not yet responded to. “Given the time sensitivity of this matter, Neustar believed a letter was appropriate,” a Neustar spokeswoman told us.
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Neustar’s request is “both procedurally defective and substantively meritless,” said Telcordia, doing business as iconectiv, in its opposition (http://bit.ly/1dvCfnG). Neustar’s petition isn’t a proper petition for declaratory ruling, but rather a belated attempt to get the commission to “vacate three years of decisions regarding the Local Number Portability Administrator,” said Telcordia, which has also expressed interest in the LNPA position. In the three years since the request for proposal process has been under way, Neustar “never petitioned for reconsideration or filed an application for review” of bureau decisions until now, Telcordia said. “It is now too late to do so -- and for good reason. The Commission cannot allow parties to sandbag three years of work by waiting until the end to raise issues with decisions made months or years earlier.”
Neustar’s new claim -- that the North American Portability Management’s “Future of the NPAC Subcommittee” was an inappropriate entity to draft the request for proposals and evaluate bids -- “contradicts its earlier claims that the FoNPAC was exactly the appropriate entity to conduct such work,” Telcordia said. “Neustar’s new arguments are particularly ironic because, when Telcordia proposed selection process changes during the FCC’s comment process, Neustar proclaimed that it did ‘not believe it was appropriate for a prospective vendor to suggest alterations in the selection process.'"
"Neustar is fighting to ensure that a massive mistake is not made by a flawed LNPA selection process,” a spokeswoman told us. “It is vital to have a process move forward that will enable consumers and the broadest set of telecommunications industry constituencies -- small and large -- to benefit from ascertaining the best technical selection at the most advantageous value.” Determining value should take into account hidden costs, risks to the system, and an apples-to-apples comparison of what services are provided, she said. “In attempting to dismiss Neustar’s arguments around the RFP process, Ericsson has only confirmed how important it is that the process be reformed.”
Neustar asked the full commission Monday to direct the Wireline Bureau to immediately issue a public notice seeking comment on Neustar’s Feb. 6 petition (http://bit.ly/1k7A15H). “It is difficult to see how the FCC and the NANC can fulfill their obligations” to consider the needs of all stakeholders when “key substantive requirements, including those needed to address critical public safety and national security issues” were “left out of or glossed over in the RFP,” Neustar said in its letter to Chairman Tom Wheeler and the other commissioners. Neustar also criticized an RFP that doesn’t support “evolving technology goals such as the IP transition.”
The RFP did contemplate the IP transition, said Telcordia’s filing. “The RFP required a bidder to be ‘flexible in order to support the transition of the Public Switched Telephone Network (PSTN) to an all-Internet Protocol (IP) network’ and to ‘work expeditiously with the industry to implement any required changes,'” Telcordia said, quoting the RFP. “Neustar’s claim that the RFP should have prescribed the NPAC’s role in an all-IP environment, or should have conducted a ‘bake-off’ among competing visions would have been inappropriate,” Telcordia said. “Whatever the outcome of those deliberations, the NPAC vendor must be prepared and committed to evolve the NPAC, if necessary, as the RFP requires. The Commission need not and should not restart the LNPA procurement to await those decisions."
Texaltel, an association of Texas CLECs, wrote to Wireline Bureau Chief Julie Veach and FCC acting General Counsel Jonathan Sallet to express its “concern” about LNPA selection, and the impact on its member companies (http://bit.ly/1dvRg96). Texaltel thanked Veach and Sallet for writing to NANC to clarify the LNPA selection process (CD Feb 12 p7), but said it wished the letter “had asked for greater transparency” or “opened a door for smaller providers” to “have a meaningful opportunity” to present their concerns. “Before any recommendation on selection is made to the FCC, we request that there be an opportunity for representatives of smaller providers to review and comment upon any analysis that was done regarding the impact of this selection process on smaller carriers and their customers,” Texaltel said.