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Feb. 16 Response Deadline

Pai Demands LNPA Transition Parties Agree on 'Workable Contingency Rollback' Plan, Specifics

FCC Chairman Ajit Pai wants agreement on a "workable contingency rollback" in the local number portability administrator (LNPA) transition from Neustar to iconectiv. Despite efforts to achieve the switchover, "more must be done," and he called it "unacceptable" that parties hadn't agreed on a contingency plan to roll back to Neustar's system if iconectiv's new system fails. Regional transitions to iconectiv's system are to begin April 8.

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"It is imperative that the parties quickly reach agreement on a workable contingency rollback approach before regional cutovers are set to begin," Pai said in a Friday letter to Neustar, iconectiv, North American Portability Management (NAPM) and its transition oversight manager (TOM), PwC, in docket 09-109. "I expect all parties to carry out their transition and contractual responsibilities and obligations in good faith and to work cooperatively throughout the transition. Without such cooperation, the transition could be delayed to the detriment of the American public. This Commission cannot -- and will not -- allow this to occur."

Pai asked the parties to report to the FCC by Feb. 16 on "specific details" of an "agreement to ensure a seamless, timely transition." He didn't say what would happen if no agreement is reached by then.

Earlier, Neustar denied NAPM allegations the company is thwarting the LNPA transition, and said NAPM admitted it lacks a viable contingency plan as a planned April 8 Southeast region handoff nears. Replying to a Jan. 29 filing by NAPM and its TOM (see 1801290046), Neustar said it will address their "false" allegations "in the appropriate forum." But NAPM "concedes, for the first time, that the NAPM and TOM have not prepared a technically and operationally feasible contingency rollback solution if the transition to iconectiv fails," said a Neustar filing posted Friday in docket 09-109.

Neustar said a TOM summary says "it will use an industry-led manual rollback solution in the event of a 'catastrophic failure' because of 'technical, resource, schedule, and contractual constraints.'" Because NAPM and TOM "poorly managed" the transition, the FCC and industry "will assume the risk of an unproven, newly-coded LNPA database without the ability to roll back to a proven service provider," said Neustar, suggesting it "offered to support an automated solution with none of the deficiencies of the NAPM's proposed manual rollback for as little as $1.5 million."

The TOM "obfuscates the real threat that its manual contingency rollback poses: there will be no alternative database service to roll back to," said Neustar. The NAPM "negotiated a contract amendment with Neustar to discontinue service in each region once iconectiv begins its service,'" the incumbent said. "Even if a manual rollback could work, which Neustar doubts, there will be no working database to provide LNPA service once iconectiv turns on its service in a given region of the country. ... [I]f iconectiv's system fails and Neustar's system is no longer operational, the contingency plan will result in massive consumer disruption." NAPM didn't comment Friday.

NAPM's cited incremental progress in its January LNPA transition status report filed Wednesday. It said the transition remains "on track to meet the Final Acceptance Date of May 25," but faces various risks. NAPM said Neustar "has yet to agree to terms that would govern the resumption of" Number Portability Administration Center services by the incumbent if iconectiv's systems fail: "While an incident that would trigger such a rollback is unlikely, it is still prudent to establish protocols and test them."