NAPM, Iconectiv Press Contingency Rollback Plan, Open to New Testing; Neustar Unmoved
North American Portability Management and iconectiv pushed their plan for a contingency rollback to incumbent local number portability administrator Neustar if a cutover to iconectiv's new systems results in a catastrophic failure. The "core elements of the standing contingency rollback plan either have been tested or are simply service providers (or their service bureaus) submitting porting transactions to Neustar in the same manner as they would have done had a cutover never occurred," said a NAPM/iconectiv filing posted Tuesday in FCC docket 09-109. They offered to discuss new testing with Neustar, which has objected to the plan, and urged the incumbent to participate in the contingency rollback.
Sign up for a free preview to unlock the rest of this article
Timely, relevant coverage of court proceedings and agency rulings involving tariffs, classification, valuation, origin and antidumping and countervailing duties. Each day, Trade Law Daily subscribers receive a daily headline email, in-depth PDF edition and access to all relevant documents via our trade law source document library and website.
“Neustar does not want to partake in creating a false sense of security around the rollback solution being proposed,” the company emailed us. The LNP Alliance of smaller carriers criticized the current process as tilted toward big carriers: "The original plan called for a longer test cycle and for an in-place tested rollback capability that now seems to be optional according to the larger carriers."
The chance a contingency rollback would be needed is "vanishingly small," NAPM and iconectiv said. If such failure occurs, they said, the potential burdens on carriers to resubmit porting requests to Neustar would be "very small." They noted an initial Southeast region cutover occurs Sunday, April 8, when there are few porting requests, and said the need for a rollback would be apparent within a few hours, or a day at most. Carriers facing the biggest potential burdens -- AT&T, Sprint, T-Mobile and Verizon -- "strongly" back maintaining the current transition schedule with the industry-led contingency rollback, said the filing (see 1803090031 and 1802070003). NAPM wouldn't oppose FCC clarification to allow any carrier not confident in its own resubmission ability to wait until 24 hours after the cutover. The FCC didn't comment.
Neustar's claim the rollback would be manual is "somewhat misleading," NAPM and iconectiv said. They said porting requests to Neustar could be resubmitted through existing processes and gateways, meaning for those using automated mechanisms, the resubmissions would be no different from the current resubmission process that parties use. They acknowledged there wouldn't be "database-to-database transfers between iconectiv and Neustar's" number-portability systems of completed porting transactions, but even if there were, the "standing contingency rollback plan would be a necessary component of any rollback plan." Neustar is "disputing the feasibility of a process that occurs today and that would be a necessary back-up component even under Neustar's preferred contingency rollback plan," they said.
NAPM and iconectiv criticized Neustar claims it can't participate in an "untested" solution. The "fundamental actions and components of the standing contingency rollback mechanism have been or will be tested prior to cutover, or are the same submission processes that providers are already using to submit ports," they said.
Though they believe "no further testing of contingency rollback is necessary," NAPM and iconectiv are willing to discuss further testing with Neustar and will make a proposal. They asked Neustar to take certain steps to participate in the current rollback plan.
The LNP Alliance has many concerns about the NAPM/iconectiv plan. "Industry standard for these type projects is to have a well-documented detail 'rollback' plan that is fully tested by all users before the cutover to ensure the original system is available and accessible by all users in the event the new system fails," it emailed. "This has not been done in the LNPA Transition project. Job #1 in a rollback is coordination of activities. There has been no transparency much less coordination by the largest carriers with smaller carriers of the alleged rollback testing that larger carriers assert they have conducted. A rollback test that assumes only the testing carrier’s recovery needs is no test at all. The new system should be pre-tested under normal and possibly escalating industry load conditions."
"The iconectiv system has been tested for 'certification' and limited 'round robin testing,'" the LNP Alliance said. "There are still issues to be resolved that were discovered in the round robin testing and which did not occur in the certification testing. In the round robin testing, users attempted and tested other functions of the iconectiv platform that work currently in the Neustar platform and have very recently discovered new problems which they are still in the process of correcting. These late-stage testing and corrections are as much an issue as the lack of an agreed-upon and fully tested rollback plan." The group said smaller providers and service bureaus have different requirements than large carriers, called "manual" operations "burdensome" for them, and said database corruption would be "unavoidable" without small carrier success in a rollback. Smaller carriers have been left out of the rollback testing and "instead are being asked to consider delaying their use" of porting systems, it said.