LNPA Transition Parties at Stalemate Over Contingency Rollback Plan as FCC Deadline Passes
Stakeholders in the local number portability administrator transition remain deadlocked over a contingency plan to roll back LNPA functions to incumbent Neustar if the systems of incoming administrator Telcordia (iconectiv) initially fail, parties told the FCC. Telcordia, which backs a North American Portability Management "industry-led" manual rollback plan, said "discussions are at an impasse" and unlikely to be resolved under an existing timetable. Neustar, which prefers an automated approach, said it and NAPM weren't able to agree on the testing of a manual rollback to meet a scheduled April 8 initial regional system handoff. The FCC and NAPM didn't comment. Chairman Ajit Pai demanded parties reach agreement by last Friday (see 1802020070).
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Iconectiv, Neustar, NAPM and its transition oversight manager held talks last week to see if there were "mutually-agreeable tests" to "further validate an industry-led rollback process" within the current schedule, as suggested by Pai staff, said a Telcordia letter Tuesday in docket 09-109. "Neustar has not yet agreed to reactivate its NPAC [Number Portability Administration Center] database in an affected region if rollback would be necessary, and the parties have not been able to converge on a testing plan that does not subject the service providers to unduly burdensome testing and that would hold to the current schedule."
The manual plan "is fundamentally very straightforward," Telcordia said. "For Neustar, it requires them to reactivate their NPAC database for the affected region(s) (which, in the case of the Southeast Region cutover on April 8, will be while they are operating NPAC databases for six other regions), allow service providers to reconnect to their NPAC, and process the ports submitted. ... For service providers, they must keep a log of their post-cutover ports that were sent to iconectiv (which iconectiv will supplement by providing its own log to each service provider), take account of certain exceptions, prioritize those ports for resubmission, and resubmit them to the Neustar NPAC."
To try to bridge differences, iconectiv offered to support additional voluntary testing to allow service providers to simulate a cutover and rollback process by transmitting ports, and comparing the results to verify consistency, said Telcordia. It called the prospects of a "catastrophic failure" and contingency rollback "vanishingly small," and detailed steps to reduce risks of data corruption during system migration, hardware failure and software failure.
The manual rollback is the only contingency plan that can be executed under the current cutover schedule and final acceptance date of May 25, Telcordia said: "There is no intermediate automated database-to-database solution that can be developed and tested consistent with the current cutover schedule. ... [T]he discussions are at an impasse. Further discussions are unlikely to yield a timely result consistent with the current cutover schedule and final acceptance date. ... Even if there were unlimited time available for testing, the additional testing requested by Neustar beyond what iconectiv has offered would impose unreasonable burdens on service providers and/or be unworkable."
Neustar essentially confirmed the deadlock. "Because implementation of a manual contingency rollback by April 8, 2018, would necessarily shortcut testing and therefore be inherently unreliable and contrary to industry best practices, Neustar and the NAPM were unable to progress on a manual contingency rollback," said a cover letter to three other filings, two redacted: a rollback analysis and a negotiation summary (all here). "Neustar’s primary concern with respect to any rollback approach remains its utility to restore NPAC data integrity quickly and reliably. This will in turn support the resumption of services with minimum consumer and service provider disruption. ... [A]n automated approach is the only viable solution to rollback that can be implemented and validated to facilitate the Commission’s objective of a seamless cutover."
Neustar included a sworn declaration from an information-technology expert supporting the company's approach. "Lack of an agreed upon rollback solution is a fatal flaw," said Cheryl Smith, principal of Smith & Associates and former Bell Atlantic vice president with LNPA experience. "A project this size with a six-week cutover scheduled (April 8--May 20, 2018) with no rollback plan goes against every generally-accepted Industry practice. Industry standards state that there should be a tested, redundant system ready to handle things if the rollout has a problem. This will minimize disruption." An "untested manual rollback solution provides none of the benefits inherent in a typical contingency rollback plan," Smith added. "A tested rollback solution is a must have, and an automated rollback is a preferable solution to minimize disruption."
Large carriers back the manual rollback plan, but others share Neustar's concerns (see 1802070003 and 1802130025).