AT&T, Verizon Push Manual Contingency LNPA Rollback Plan; Cloud Group Concerned
Parties gave the FCC conflicting signals on a contingency rollback plan in the local number portability administrator (LNPA) transition from Neustar to iconectiv. AT&T and Verizon said system testing was going well and they support a North American Portability Management plan for manually rolling back functions to Neustar if iconectiv's new systems suffer "catastrophic failure," which both carriers called unlikely. Verizon said further discussions on a solution are ongoing. But the Cloud Communications Alliance (CCA) voiced concerns, and Neustar, in a strange twist, entered into the record a correction and retraction from PwC, NAPM's transition oversight manager (TOM), after NAPM apparently refused to do so. The FCC and NAPM didn't comment Friday.
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AT&T urged completion of the LNPA transition "without delay," saying industry has engaged in "thorough testing for more than six months" to prepare for using iconectiv's new Number Portability Administration Center (NPAC). "Given the amount of testing that has been performed, the chances of [a catastrophic event are] exceptionally low," said AT&T's filing Friday in docket 09-109. "Although a roll-back is unlikely to occur, AT&T has successfully tested its ability to move our connectivity from the new NPAC back to the Neustar NPAC in both production and test environments." The rollback plan developed by the TOM and endorsed by NAPM is a "workable" approach," the telco said.
Verizon has "experienced positive results in all areas of testing so far," including of iconectiv's LNP solution. Most test scenarios "are either complete or near the end of validation and, from Verizon's perspective, have no outstanding test failure cases," said its filing posted Friday. NAPM "is best positioned to address the status" of contingency rollback talks, but "active discussions" are underway "on developing a reasonable solution that, critically, does not impact the transition timing." An initial regional cutover from Neustar's systems to iconectiv's is scheduled for April 8, with May 25 the "final acceptance date" for the LNPA transition.
Neustar responded by email Friday: “The only thing more dangerous in a technology transition than not having a contingency rollback is pretending that you have one when you don’t.”
CCA said the "lack of a workable, tested contingency rollback plan creates an unacceptable risk," noting stakeholders were unable to agree on a solution despite a recent call from Chairman Ajit Pai (see 1802200051 and 1802020070). The group said the manual plan isn't viable, and it cited Neustar's concerns. Because it's a manual plan, "it does not accommodate the limited resources of smaller providers," a CCA filing Thursday said. "To the extent that smaller carriers are unable to adequately manually reenter information or incur expenses necessary under the manual plan, the NPAC will be corrupted for all carriers. It is unfortunate that the primary parties have been unable to reach agreement on an automated tested plan and the CCA respectfully calls on the FCC to once again make every effort quickly to facilitate an agreement." Absent an accord, CCA urged the agency to delay implementation until "a proper rollback plan, including testing, is in place."
PwC asked NAPM to file a correction and retraction regarding a Jan. 29 NAPM filing from PwC that accused Neustar of resisting a rollback plan (see 1801290046). When NAPM didn't make the filing, PwC authorized the LNPA incumbent to do so, said Neustar's letter (with PwC letters attached) posted Thursday. The PwC statement said: "None of the statements in the January 29, 2018 filing by the TOM should be read to state or imply an opinion that any party to the transition, including Neustar, NAPM LLC, or iconectiv, has acted in bad faith. To the extent that any statement by the TOM could be considered to allege that any party has acted in bad faith, the TOM hereby retracts such statement(s)."
Neustar said it's pleased by the retraction and emailed it "has been supportive of, and advocating for, a workable rollback solution for more than a year. Now that Neustar believes that such a solution is not feasible in time for the cutover date, Neustar is simply informing various stakeholders about the significant risks that exist."