3. No transition plan. As the initial timeline recognized, transitioning a system that coordinated the efforts of more than 2,000 individual telecommunications customers (including large carriers like Verizon) to complete hundreds of millions of transactions annually is a complex process that should take at least two years. With Neustar’s contract expiring in 2015, where is the transition plan? According to Standish, the transition will cost between $300 and $600 million. Who will bear those costs? Will new expenses be passed to consumers? These questions should not remain unanswered so late in the game.
4. No plan for the IP transition. The FCC has recently begun an effort to transition old telephone networks to modern, Internet Protocol networks. These changes will greatly benefit consumers, but they will require significant planning and investment from telecommunications companies and the LNPA. The selection requirements devote only one sentence to the need to support the IP transition. Where are the detailed requirements that will be used to evaluate whether the LNPA can support what will be a long and arduous transition to an all IP world?
5. No representation of consumers, public safety organizations, or smaller companies. Although the selection process has been dominated by large companies, the LNPA also serves public safety organizations, many smaller operators, and, ultimately, the American consumer. While large carriers have their own resources to fall back on, how are the detailed needs of these other interested parties — who rely on the LNPA’s technical and operational expertise — being represented?
The FCC has decided the selection process should be a closed rather than a transparent, process. From the outside looking in, the selection process appears to have been driven by lawyers and policy makers. Where is the objective technology-driven process needed to ensure success for the millions of consumers who rely on number portability?
After the public catastrophe that was healthcare.gov, Americans should expect more attention to getting the technical details right. When will they ever learn?
Dr. Stagg Newman is a former Chief Technologist at FCC and a principal in Pisgah Communications Consulting.