Everybody from consumers, to emergency response, law enforcement and national security agencies, to state regulators, to carriers themselves rely on a routing database established as a result of the Telecom Act of 1996. This database, called the Number Portability Administration Center (NPAC), is a critical part of our national infrastructure.
It gives consumers more flexibility and enables competition by enabling sub-scribers to switch telecommunications providers without having to change phone numbers – a capability referred to as local number portability. The NPAC is also essential to the stability and reliability of 911 services, and is used by law enforce-ment in their investigations.
A poorly planned transition of the data and technology in the NPAC could result in the service failing, consumers not being able to keep their phone numbers when they change service providers, and service providers not able to compete on a level playing field.
Neustar has been entrusted with the administration of the NPAC since it went live 17 years ago, and has several times during that period been reaffirmed as the best candidate for the job. But recently, a consortium of the nation’s largest and most powerful telephone companies has put forth a recommendation that Telcordia, a subsidiary of Swedish telecom equipment giant Ericsson, take over the job.
The FCC (News - Alert) is now considering that proposal, and various responses to it. While topics like carrier consolidation and net neutrality continue to garner telecom headlines, Neustar says the future of the NPAC is no less important.
“The NPAC is far more than just a number portability system. It’s the only real-time routing system that connects every single service provider in the U.S.,” says Steve Edwards (News - Alert), Neustar’s Senior Vice President of Data Solutions.
That’s why, over the last several months, competitive local exchange carriers, the DEA, the FBI, and Neustar, among others, have reminded the FCC of the critical nature of the NPAC and the importance of keeping it affordable, available, and reliable – and that any decision made by the FCC needs to take into account the interests of all affected parties – not just those of the largest carriers.
Some of the specific concerns with the NPAC selection process and potential transition have to do with neutrality, transparency, cost, transition, and timeline.
According to Neustar and others, Ericsson (News - Alert) is not qualified to operate the NPAC, in part because of its close ties with tier 1 service providers. For example, Ericsson manages Sprint’s network through a contract with that carrier. Ericsson, as a manufacturer of wireless telecommunications equipment, also has strong ties to the wireless industry generally.
That raises questions as to whether Ericsson will treat all providers – wireless, wireline, and VoIP – equally as required by law and regulation.
Additional concern stems from what Neustar and some others see as a lack of transparency in the proposal and review process. According to Edwards, the proposal deadline for Ericsson was improperly extended an additional 22 days, without explanation. In addition, the process initially indicated there would be multiple rounds of bidding, but that process was cut short.. Neustar also questions whether the FCC advisory group evaluating NPAC administrator proposals kept required records of meetings or allowing for broad participation of all relevant constituencies.
There are also some significant cost concerns about a potential NPAC administrator transition.
According to Edwards, eighty percent of the carriers using NPAC get access to it for less than $1,000 a month but the cost of to those carriers to pay for the massive transition that would need to take place if there is a change in the NPAC administrator outweigh the benefit of any potential savings from a lower priced vendor.
Additionally, in the past, Ericsson has expressed interest in moving key functionality essential to enabling network transformation out of the NPAC and into a separate database, which could mean that carriers would have to pay two separate database fees.
Former COMPTEL President Jerry James (News - Alert), who now leads a CLEC group called The LNP Alliance, commented: “We want to be assured that such services will continue to be available and at no additional cost from the next LNPA under the new contract. Similarly, we are concerned that larger carriers may be better able to withstand a costly or disruptive transition to a new vendor.”
TRANSITION & TIMELINE
There’s also a fair amount of uncertainty regarding important details related to cost, security, and timing should there be an NPAC transition.
No one knows for sure just how much such a change would cost and who would shoulder that burden, although D.C.-based economic consulting firm Economists Inc. estimates first year NPAC transition costs for carriers alone would be around $719 million.
There are also security concerns about handing NPAC administration over to Ericsson, which Edwards says runs smaller number portability databases in India, Pakistan, and elsewhere. The issue, raised by national security experts in filings to the FCC, is that engineers in those countries would potentially have access to the same code as that used in the U.S.
And although the large telcos that submitted the Ericsson proposal suggest a transition would take 33 months, says Edwards, exactly what would be required during the transition and when that period would begin remain unclear. Neustar’s contract expires in June 2015. This is clearly a critical issue for the FCC to get right and avoid the potential fall out if this is not handled correctly.
Edited by Maurice Nagle