Potential LNPA Vendors Argue Over Re-Do of Bids on Eve of Closed NANC Meeting

Telcordia, doing business as iconectiv, rebutted what it called five “myths” about number portability (http://bit.ly/1ixxTBa). Switching administrators wouldn’t be risky, Telcordia said, and porting times would not increase with a different administrator. “Switching from the incumbent to iconectiv will not mean porting will take seven days, as has been suggested,” it said. FCC rules require simple ports to be completed within one business day, with wireless industry standards that are even faster, it said.

"Starting over” with a new request for proposals (RFP), as Neustar has requested, “means a long delay in which the incumbent continues to get paid at inflated levels set through a no-bid contract amendment,” Telcordia said. Changing administrators wouldn’t slow the migration to all-IP communications networks, it said, and small carriers won’t be harmed. “Small carrier representatives supported the selection process” and “never voiced any disagreement with the contents of the RFP at any point in the process prior to its release,” Telcordia said. “Competitive bidding can’t work if the incumbent can’t lose or a decision never happens. It’s time for a change: change that will foster competition and innovation in number portability."

"Neustar’s competitor minimizes the serious issues involved in a transition to a new LNPA,” a Neustar spokeswoman said. Neustar released its own analysis Tuesday arguing any transition would take “a minimum of two years,” and likely longer. “Because of multiple delays, the process is now far behind schedule and two years of work must be completed within a nine-month time frame,” the spokeswoman said. “The industry could not conceivably be at full readiness and connected to a new LNPA prior to mid 2016,” said a paper written by Neustar Vice President-Numbering Services Bill Reidway (http://bit.ly/1ixA5IQ).

If Neustar were to approach the transition as a new vendor today, using its existing codebase and resources, it wouldn’t be able to take over management of the portability process in time for a July 2015 deadline, it said. That’s “assuming virtually no implementation, testing, or deployment obstacles,” working “in cooperation with an industry that has no resource or time constraints,” Reidway wrote. “Neustar is not asserting that an LNPA transition is not possible, nor that one should never be attempted. At a minimum, however, the consideration of such a transition should include a full evaluation of impacts on stakeholders, including the impacts of serious delay, outright failure, and the potential pressure to move quickly at the expensive of quality and stability."

A transition will require between 26 and 33 months, Reidway said: Transitioning to a new LNPA will require “complex coordination across thousands of carrier accounts, law enforcement and public safety agencies,” as well as regulators and other stakeholders. “With success resting on the efforts of multiple stakeholder groups, seamless management and sequencing of interdependent work streams needs to occur over a fixed and universally binding timeline,” he wrote. “Clear definition of roles and responsibilities across the stakeholders and adequate planning to underwrite this complex project do not currently exist to support this transition."

The closed-door NANC meeting makes Harold Feld “nervous,” said the Public Knowledge senior vice president in a post on his personal blog Tuesday (http://bit.ly/1ixEkEi). “The possibility that we may create a destabilizing tug of war around the maintenance of phone numbers during the IP Transition gives me serious tummy queasies.” Feld warned of a “possible meltdown of the phone system.” Feld said he’s not sure whether Telcordia or Neustar is right or wrong, and is “very sympathetic” to Telcordia as a challenger of the incumbent. “On the flip side, as an actual user of the phone system, I find myself really attracted to stability in the phone number system,” Feld said. “We have a request for proposals that was extremely vague on what we would need to actually support the IP Transition, so we have no way to really measure whether the parties submitting the bids are really up to what the job will be.” The FCC should “hold off” on picking a new LNPA “until it does the numbering testbed and figures out what the actual requirements” for the next LNPA will be, said Feld.

The Competitive Carriers Association and Frontier Communications are concerned about the LNPA selection process. Competition in the telecom market depends on consumer confidence in the ability to “seamlessly” move between carriers without changing phone numbers, CCA told the FCC in a letter Friday (http://bit.ly/1ixCsvg). “The LNPA selection process does not appear to have taken into account the interests of non-nationwide wireless carriers in matters such as vendor transition costs, support for Internet Protocol-based numbering systems, and several of the features and functions on which the business models of competitive wireless carriers depend.” The RFP made many substantive omissions that “threaten the reliability and functionality of telecommunications services” in the U.S., and the “insular LNPA selection process has exacerbated these concerns,” CCA said.

Frontier wrote the FCC Friday to urge commissioners to “ensure that the concerns of mid-size carriers like Frontier and thousands of smaller carriers are taken into careful consideration” (http://bit.ly/1ixCVh3). “Critical functions” provided by the NPAC today were “omitted from the scope of the RFP, including disaster recovery and emergency preparedness, ecosystem monitoring and management, and mass porting capabilities,” Frontier said. “These functions must be a part of any LNPA selection process at this time; retrofitting the system to include such functions at a later date would be unacceptable.”