Telcordia Hits Claims of LNP Alliance, New America's Open Technology Institute

Smaller telcos and VoIP providers' recurring LNPA costs will "drop significantly," said a Telcordia filing posted Thursday, responding to various filings by the two groups in docket 09-109. It said service bureaus serving small providers also will have lower recurring costs. "For many and potentially for all small telephone companies, small wireless carriers, and service bureaus, these reductions in recurring costs will offset any potential one-time NPAC transition costs," the company said. It said that under the new MSA, "a provider’s share of allocated region-wide charges" -- which is paid by all telecom and interconnected VoIP providers in a region -- "is dramatically lower than the costs currently charged by Neustar."

Telcordia denied the current testing schedule created significant risks for small providers. "No one has an interest in putting in place a new Number Portability Administration Center that does not work, and the proposed contract provides for testing that will focus on all users of the NPAC; small carriers will be provided needed support and will be included during this phase," the company said. "Service bureaus will also be part of that testing, and testing will cover both automated interactions with the NPAC as well as interactions through the web-based Graphical User Interface ('GUI'). Smaller providers should not be spooked."

The proposed MSA mandates "no change in the LNP workflows and information exchange under the existing requirements adopted through the LNPA Working Group and the North American Numbering Council," Telcordia said. "All the industry porting data and process flows remain the same." It said the LNPA transition won't cause any delay in number-porting times.

"Once the MSA is approved and executed such that timelines can be finalized, Telcordia anticipates that it, the [North American Portability Management], and the Transition Oversight Manager will be able to reach out more affirmatively to smaller providers," it said. "At this point, it is critical that the Commission act to approve the MSA, so that the transition can move forward."

LNP Alliance's counsel said the filing didn't address many of the groups' concerns. For instance, the groups believe "the LNPA transition doesn’t address the IP transition and will delay the IP transition," Eckert Seamans attorney James Falvey told us. He also noted concerns about process transparency and the composition and dues structure of NAPM, which negotiated the MSA with Telcordia. He said the groups have proposed changes to the MSA they believe would be constructive. The Telcordia letter "is all about cost and operational issues," he said. "The biggest cost reduction for smaller carriers is going to be the IP transition." Cost reduction from the LNPA transition is smaller, and if it delays the IP transition, it will postpone IP transition savings, he added.

Telcordia said the OTI program "purports to be acting 'as a non-profit policy institute,'" but the group's director, Michael Calabrese, submitted a Neustar-funded report in the proceeding March 9, 2015, "raising serious questions about the Program's independence."

Calabrese emailed, "It's odd that Ericsson’s subsidiary would mention our paper" from over a year ago, "which focused on LNPA selection issues and national number porting that are completely irrelevant to the concerns small carriers and consumers have raised about the MSA and transition process going on today." He added, "OTI and Public Knowledge also filed joint reply comments with the Competitive Carriers Association last year, advocating the same points about transparency and input from consumers and small carriers that we’ve reiterated more recently with LNP Alliance."