exv10w99



 





Exhibit 10.99




	 	 	 
	 
	 	Federal Communications Commission
	
	 	Washington, D.C. 20554






July 10, 2007




NeuStar, Inc.

46000 Center Oak Plaza,

Sterling, Virginia 20166



Attn.: Amy Putnam





			
	Re:	 	Notification of Intent to Exercise Option & Notification of Exercising of Option

Contract No. CON01000016




Dear Ms. Putnam:



In accordance with FAR Clause 52.217-9, Option to Extend the Term of the Contract, the purpose of
this letter is notify you of the Government’s intent to exercise Option Period 4e. Concurrently,
the contract is hereby unilaterally modified to exercise the Option Period. A copy of the executed
modification is enclosed.



If you have any questions regarding this matter, please contact me, on 202-418-0932 or at
anthony.wimbush@fcc.gov.




	 	 	 
	 
	 	Sincerely,

	 
	 	
	 
	 	Anthony S. Wimbush
	 
	 	Contracting Officer




















 








AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT



1. CONTRACT ID CODE PAGE OF PAGES 1 I 1



2. AMENDMENT/MODIFICAITON NO. 0031



3. EFFECTIVE DATE 07/10/07



4. REQUISITION/PURCHASE REQ. NO.



5. PROJECT NO. (If applicable)



6. ISSUED BY CODE



FCC/ Contracts and Purchasing Center
445, 12th Street., SW
Washington, DC 20554



7. ADMINISTERED BY (If other than Item 6) CODE



8. NAME AND ADDRESS OF CONTRACTOR (No., street, county, State and ZIP Code)



Neustar, Inc.
4600 Center Oak Plaza
Sterling, VA 20166



þ     9A. AMENDMENT OF SOLICITATION NO.



9B. DATED (SEE ITEM 11)



10A. MODIFICATION OF CONTRACT/ORDER NO. CON01000016



10B. DATED (SEE ITEM 11) 06/15/01



CODE FACILITY CODE



11. THIS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICITATIONS



o The above numbered solicitation is amended as set forth in
Item 14. The hour and date specified for receipt of Offers o is extended, o is not extended.



Offers must acknowledge receipt of this amendment prior to the hour and date specified in the solicitation or as amended, by one of
the following methods:



(a) By completing items 8 and 15, and returning copies of the amendment; (b) By acknowledging receipt of this
amendment on each copy of the offer submitted;
or (c) By separate letter or telegram which includes a reference to the solicitation and amendment numbers. FAILURE OF YOUR
ACKNOWLEDGMENT TO BE RECEIVED AT THE PLACE DESIGNATED FOR THE RECEIPT OF OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN REJECTION OF YOUR OFFER. If by virtue
of this amendment your desire to change an offer already submitted, such change may be made by telegram or letter, provided each telegram or letter
makes reference to the solicitation and this amendment, and is received prior to the opening hour and date specified.



12. ACCOUNTING AND APPROPRIATION DATA (If required)



No Funding Information



13. THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS.
IT MODIFIES THE CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14.



CHECK ONE



A. THIS CHANGE ORDER IS ISSUED PURSUANT TO: (Specify authority) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT ORDER
NO. IN ITEM 10A.



B. THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changes in paying office,
appropriation date, etc.) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103(b).



þ     C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF: FAR 52.217-9, Option to Extend the Term of the Contract



þ     D. OTHER (Specify type of modification and authority) FAR 1.6, Authority of the Contracting Officer



E. IMPORTANT: Contractor þ is not, o is required to sign this document and return ___ copies to the issuing office.



14. DESCRIPTION OF AMENDMENT/MODIFICATION (Organized by UCF section headings, including solicitation/contract subject matter where
feasible.)
The purpose of this unilaterally executed modification is to exercise Option Period 4d. The period of performance is hereby extended
from July 15, 2007 through August 14, 2007. Funding in the amount of $292,669.38 is funded via NANPA and will be paid by FCC Billing & Collection Agent,
Welch & Co.



Except as provided herein, all terms and conditions of the document referenced in Item 9A or 10A, as heretofore changed, remains
unchanged and in full force and effect.



15A. NAME AND TITLE OF SIGNER (Type or print)                    16A. NAME AND TITLE OF CONTRACTING OFFICER (Type or print)



UNILATERAL MODIFICATION                     Anthony S. Wimbush



15B. CONTRACTOR/OFFEROR                      15C. DATE SIGNED 16C. UNITED STATES OF AMERICA 16C. DATE SIGNED



(Signature of person authorized to sign) (Signature of Contracting Officer) 07/10/2007



NSN 7 540- 01 -152-8070
Previous edition unusable



STANDARD FORM 30 (REV. 10-83)
Prescribed by GSA FAR (48 CFR) 53.243










 









 









AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT 1. CONTRACT ID CODE A Page 1 of 3



2. AMENDMENT/MODIFICATION NO. 3. EFFECTIVE 4. REQUISITION/PURCHASE REQ. NO. 5.
PROJECT NO. (If applicable) 0032 DATE 08/10/2007



6. ISSUED BY CODE 00001 7. ADMINISTERED BY (If other than Item 6) CODE



FCC Contracts and Purchasing Center
445 12th St., SW,
Washington, DC 20554



8. NAME AND ADDRESS OF CONTRACTOR (No., street, county, State and Zip Code)



9A. AMENDMENT OF SOLICITATION NO.
Neustar, Inc.
46000 Center Oak Plaza
Sterling, VA 20166



9B. DATED (SEE ITEM 11)



þ 10A. MODIFICATION OF CONTRACT/ORDER NO. CON01000016



þ 10B. DATED (SEE ITEM 13)



CODE            FACILITY CODE



11. THIS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICITATIONS



o The above numbered solicitation is amended as set forth in Item 14. The hour
and date specified for receipt of Offers o is extended, o is not extended.



Offers must acknowledge receipt of this amendment prior to the hour and date
specified in the solicitation or as amended, by one of the following methods:



(a) By completing Items 8 and 15, and returning copies of the amendment; (b) By
acknowledging receipt of this amendment on each copy of the offer submitted: or
(c) By separate letter or telegram which includes a reference to the
solicitation and amendment numbers. FAILURE OF YOUR ACKNOWLEDGMENT TO BE
RECEIVED AT THE PLACE DESIGNATED FOR THE RECEIPT OF OFFERS PRIOR TO THE HOUR AND
DATE SPECIFIED MAY RESULT IN REJECTION OF YOUR OFFER. If by virtue of this
amendment you desire to change an offer already submitted, such change may be
made by telegram or letter, provided each telegram or letter makes reference to
the solicitation and this amendment, and is received prior to the opening hour
and date specified.



12. ACCOUNTING AND APPROPRIATION DATA (If required) No Funding Information



13. THIS ITEM ONLY APPLIES TO MODIFICATION OF CONTRACTS/ORDERS. IT MODIFIES THE
CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14.



CHECK ONE



o      A. THIS CHANGE ORDER IS ISSUED PURSUANT TO: (Specify authority) THE CHANGES SET
FORTH IN ITEM 14 ARE MADE IN THE CONTRACT ORDER NO. IN ITEM 10A.



o      B. THE ABOVE NUMBERED CONTRACT/ORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE
CHANGES (such as changes in paying office, appropriation date, etc.) SET FORTH
IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103(b).



o     C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF:



þ     D. OTHER (Specify type of modification and authority)
FAR 43.103 (a) 3, “MUTUAL AGREEMENT”



E. IMPORTANT: Contractor o is not, þ is required to sign this document and return 1 copies to the issuing office.



14. DESCRIPTION OF AMENDMENT/MODIFICATION (Organized by UCF section headings,
including solicitation/contract subject matter where feasible.) The purpose of
this modification is to accept and incorporate Change Order Proposal (COP)
Number 48 into the contract. COP # 48 is accepted at a cost of $87,460.00. A
copy of the respective COP is attached. Funding will be via NANPA and will be
paid by FCC Billing & Collection Agent, Welch & Co.



Contractor’s Release: In consideration of the modification agreed to here in as
complete equitable adjustment for NeuStar Inc. interim P-ANI Administrator
proposal dated August 17,2007, NeuStar Inc. hereby releases the Government from any
and all liability under this contract for further equitable adjustments attribuable
to such facts or circumstances giving rise to the interim P-ANI
Administrator proposal for adjustment.



Digitally signed by Amy L. Putnam



16A. NAME AND TITLE OF CONTRACTING OFFICER (Type or print) Anthony Wimbush



15B. CONTRACTOR/OFFEROR 15C. DATE SIGNED 16B. United States of America 16C. DATE SIGNED



(Signature of person authorized to sign) (Signature of Contracting Officer) 8-21-07



NSN7540-01-152-8070



PREVIOUS EDITION



UNUS/BLE



STANDARD FORM 30 (REV. 10-83)
Prescribed by GSA FAR (48 CFR) 53.243












 












 






Line Item Summary



Document Number CON01000016/0032



Title Pooling Administrator - Neustar



Page 2 of 3



Line Item Number                    Description          Delivery Date (Start Date to End date)     



Quantity Unit of Issue     Unit Price     Total Cost




Questions may be addressed to Tony Wimbush @anthony.wimbush@fcc.gov.


No Changed Line Item Fields



Previous Total:
Modification Total:
Grand Total:










 










 







Address Detail



Title



Pooling Administrator — Neustar



Document Number



CON01000016/0032



Page



3 of 3



Shipping Addresses



Cede            Detail



0001 Org: FCC Warehouse
Addr: 9300 E. Hampton Drive



Capital Heights MD 20743
Attn: No Contacts Identified
Phone :( )  — ext.
Fax: ( )  — ext.



Invoice Addresses



Code          Detail



0001          Org: FCC /Accounts Processing Branch

Addr: Financial Operations Division

445 12th St., SW





Washington DC 20554
Attn: No Contacts Identified
Phone: ( )  —  ext.
Fax: ( )  —  ext.






 



 












 






			
	Change Order Proposal #48 re: IRNA
	 	Revised August 17, 2007












Interim p-ANI Administrator




Change Order Proposal #48




 In Response to




Federal Communications Commission (FCC)




Letter postmarked September 11, 2006




Revised August 17, 2007






					
	 	 	 	 	 
	 
	© NeuStar, Inc. 2007
	 	NeuStar Proprietary and Confidential
	 	i


















 








			
	Change Order Proposal #48 re: IRNA
	 	Revised August 17, 2007















Table of Contents




	 	 	 	 	 
	1.0 Introduction
	 	 	3	 
	1.1 Purpose and Scope
	 	 	3	 
	1.2 Contractual Compliance
	 	 	3	 
	2.0 Background
	 	 	4	 
	3.0 NeuStar’s Proposed Solution
	 	 	6	 
	4.0 Staff and Administration
	 	 	8	 
	5.0 Assumptions and Risks
	 	 	9	 
	5.1 Assumptions
	 	 	9	 
	5.2 Risks
	 	 	9	 
	6.0 Cost
	 	 	10	 
	7.0 Conclusion
	 	 	11	 







					
	 	 	 	 	 
	 
	© NeuStar, Inc. 2007
	 	NeuStar Proprietary and Confidential
	 	ii















 








			
	PAS — Change Order Proposal #48 re: IRNA
	 	Revised August 17, 2007








1.0 Introduction




1.1 Purpose and Scope



This change order proposal is the third in a series, and was prepared in response to a request
from the contracting officer, to update the revised Change Order #48, dated June 29, 2007. The
original change order proposal was developed in response to the letter from Mr. Thomas Navin,
Chief, FCC Wireline Competition Bureau, and the subsequent National Pooling Administrator
Contract Modification #21 received from the Contracting Officer on October 4, 2006. These
documents directed the Pooling Administrator to assume the functions of the Interim e9-1-l
Routing Number Administrator (IRNA), as that term is defined in the pANI Interim Assignment
Guidelines for ESQK prepared by the North American Number Council (NANC) p-ANI Issues
Management Group (p-ANI IMG), as revised December 5, 2005.



In accordance with the terms of the national pooling contract, the Pooling Administrator
submits this change order proposal to the FCC for approval.




1.2 Contractual Compliance



The National Pooling Administration function is a contractual relationship between NeuStar and
the Federal Communications Commission. Any function performed by the PA beyond its contractual
obligations and limitations must be approved by the FCC prior to commencement of that function.



This Change Order is consistent with the wording of Attachment B, Section C of the
Thousands-Block Pooling Contractor Technical Requirements, dated November 30, 2000, Sections
2.5 through 2.5.4, which reads as follows:





2.5.4 Changes in the Environment The FCC may issue rules, requirements, or policy
directives in the future, which may increase, decrease or otherwise modify the functions to
be performed by the contractor.





					
	 	 	 	 	 
	 
	© NeuStar, Inc. 2007
	 	NeuStar Proprietary and Confidential
	 	3




















 





			
	PAS — Change Order Proposal #48 re: IRNA
	 	Revised August 17, 2007
	 






2.0 Background



It is intrinsic to the technology that Voice over Internet Protocol (VoIP) users can be
nomadic, and this movement raises issues regarding the ability of VoIP users to access Public
Safety Answering Points (PSAPs) in an emergency situation. These issues can be evaluated in
light of similar PSAP access issues experienced by roaming wireless users. The wireless
industry has addressed these issues through the use of pseudo-ANIs1 (p-ANIs) to
establish access to the correct PSAP for a nomadic user with a foreign telephone number.



The term “pseudo-ANI” is defined in the Code of Federal Regulations at 47 CFR § 9.3 as:





A number, consisting of the same number of digits as ANI, that is not a North
American Numbering Plan telephone directory number and may be used in place of
an ANI to convey special meaning. The special meaning assigned to the
pseudo-ANI is determined by agreements, as necessary, between the system
originating the call, intermediate systems handling and routing the call, and
the destination system.



A similar methodology has been proposed to provide VoIP users’ access to PSAPs, using a type
of p-ANI called Emergency Service Query Keys (ESQKs).


On June 3, 2005 the FCC issued the First Report and Order, FCC Docket 05-196, requiring VoIP
providers to supply enhanced 9-1-1 (E9-1-1) service capabilities to their
customers.2 In Paragraph 1 of that Order, the FCC stated as follows:





we require providers of interconnected VoIP service to provide E911 services to
all of their customers as a standard feature of the service, rather than as an
optional enhancement. We further require them to provide E911 from wherever the
customer is using the service, whether at home or away from home.


On July 25, 2005 the Alliance for Telecommunications Industry Solutions (ATIS) Emergency
Service Interconnection Forum (ESIF) submitted to the industry and to the North American
Numbering Council (NANC) a document entitled: “Routing Number Authority (RNA) for p-ANIs Used
for Routing Emergency Calls — p-ANI Assignment Guidelines and Procedures”3 for
comment. On August 5, 2005 the NANC Future of Numbering Working Group established the E9-1-1
p-ANI Issue Management Group (IMG) to address the request by ESIF and to provide a
recommendation to the NANC.






 




			
	1	 	ANI is the acronym for automatic number identification, a service that provides the
telephone number of an incoming call. ANI is used for a variety of functions including helping to identify the
caller’s address to speed
response time to 911 calls.
	 
	2	 	FCC First Report and Order and Notice of Proposed Rulemaking in its proceeding
regarding the regulation of internet protocol (IP) enabled services (FCC 05-116).
	 
	3	 	© 2005 by Alliance for Telecommunications Industry Solutions) created by the
Emergency Services Interconnection Forum (ESIF).





					
	 	 	 	 	 
	 
	© NeuStar, Inc. 2007
	 	NeuStar Proprietary and Confidential
	 	4






 









 





			
	PAS — Change Order Proposal #48 re: IRNA
	 	Revised August 17, 2007
	 





Working independently, the National Emergency Number Association and the NANC IMG came to the
conclusion that an Interim E9-1-1 Routing Number Authority should be appointed to enable VoIP
carriers to meet the FCC’s November 28 deadline, while a procurement or other process was
undertaken to choose a more permanent RNA. They recommended that the FCC appoint the national
pooling administrator to perform this interim function.



Working from the draft guidelines proposed by ESIF for the permanent RNA, the NANC IMG
developed interim guidelines for the IRNA to use in the issuance of Emergency Service Query
Keys (ESQKs)4 in those areas of the country where no other entity is assigning them.
These resources will be taken from the North American Numbering Plan (NANP), specifically from
the 211 and 511 NXXS (with the 211 NXX being utilized first) in each applicable NPA. This would
enable VoIP services providers to comply with the FCC First Report and Order and Notice of
Proposed Rulemaking regarding the regulation of internet protocol (IP) enabled services (FCC
05-116).



The IMG sent its final revised proposed P-ANI Interim Assignment Guidelines for ESQK (Interim
Guidelines) to the NANC for approval on September 14, 2005, where they were subsequently
revised. Those revised guidelines, dated December 5, 2005, are included in and referenced in
the Contract Modification #21.



The Interim Guidelines, as clarified by the FCC letter, will apply to the IRNA and any entities
that seek to obtain numbers from the IRNA until such time as guidelines for the permanent RNA
can be developed and published, and the FCC can appoint a permanent e9-l-l RNA.






 




			
	4	 	Like p-ANIs, for a 9-1-1 call, ESQKs allow the designated response center to provide
the caller’s location to the responders.





					
	 	 	 	 	 
	 
	© NeuStar, Inc. 2007
	 	NeuStar Proprietary and Confidential
	 	5






 









 





			
	PAS — Change Order Proposal #48 re: IRNA
	 	Revised August 17, 2007
	 






3.0 NeuStar’s Proposed Solution



In accordance with the terms of the letter from Mr. Navin and the Interim Guidelines, the
Pooling Administrator has developed and implemented the following solution.



In a manner similar to our existing pooling administration processes, the IRNA allocates ESQKs
in a fair and neutral manner consistent with all the requirements of the Guidelines, to all
eligible users, as that term is clarified in the letter from the FCC. ESQK assignments are
expected to be made within 5 business days of a complete and valid request. ESQKs will be
allocated as requested by eligible users; however, since this is an unregulated environment,
no verification will be made regarding the appropriateness and size of the allocation with the
corresponding PSAP. In accordance with the Interim Guidelines, the application form contains a
statement by which the applicant self-certifies that it has received the authority to apply
for the resources from the appropriate e9-1-1-governing authority to provide routing or data
retrieval for e9-1-1-traffic to the applicable PSAP.



NeuStar has established a website, www.esqk.com, which is separate from the pooling
website. The ESQK website is similar to our pooling website. It is the gateway to the ESQK
system where new users can register to obtain access as well as log in to the ESQK system. It
supplies access to a user-friendly guide to assist users in navigating the ESQK system,
industry-related documents, NeuStar’s conflict resolution process, industry-related website
links, and our customer support contact information. For our customer support, we created a
dedicated toll-free customer support line and email to support the needs of the industry.



The PA used its experience to develop a secure ESQK system that is backed up regularly and is
completely separate from the existing Pooling Administration System (PAS). The secure ESQK
system is available to maintain a complete and accurate record of all ESQK transactions,
current ESQK “assigned” and “available” status, and the user’s authorization status.
Registered users may access the secure database through a use-friendly web-based interface
located on the ESQK website. Any registered users that is considered an eligible user “that
is licensed or certified by the FCC or a state commission to operate as a telecommunications
carrier.” may submit requests for ESQKs as well as view the assigned and available ESQK
inventory. The ESQK system currently does not support requests from users to modify
information to existing ESQK assignments and requests to voluntary return ESQKs, however they
may submit those requests directly to the IRNA, which will retain such requests for the
permanent p-ANI Administrator.



Pursuant to Section 9.3 and 9.4 of the Interim Guidelines, the IRNA completed the following
tasks prior to the November 1, 2006 implementation.





9.3 Initial Implementation: Before it begins assigning ESQKs, the Interim 9-1-1 UNA must
ensure that the ESQKs it assigns are not presently in use. Because it is believed that
few ESQKs have been assigned from the 211 NXXs, the Interim 9-1-1 RNA will assign ESQKs
only from the 211 NXX unless extenuating circumstances exist. To avoid duplication, the
Interim 9-1-1 RNA will first perform the following steps in order until it can determine
what numbers are available to be assigned:




1. Ask existing mobile position center (“MPC”) and VPC vendors to provide a list of
all the entities that have been assigned pANIs in the 211 NXX, and the entity (and
contact information) that assigned the pANI.



					
	 	 	 	 	 
	 
	© NeuStar, Inc. 2007
	 	NeuStar Proprietary and Confidential
	 	6






 









 





			
	PAS — Change Order Proposal #48 re: IRNA
	 	Revised August 17, 2007
	 







2. Ask each wireless service provider to respectively identify the entity that provides pANIs to it.




3. Ask each E9-1-1 SSP to identify any pANl and entity that it has assigned a p-ANl to
from the 211 code. In addition, ask each E9-1-1 SSP to identify any other entities that
may perform pANl assignments within its territory (including independents).




9.4 Once it has compiled a list of entities that assign numbers, the Interim 9-1-1 RNA will
canvass those entities to determine what, if any, pANIs they have assigned from the 211 NXX.
The remaining available pANIs in the 211-NXX in all NPAs will constitute the available pool
from which the Interim 9-1-1 RNA will assign ESQKs.


These were time-consuming functions, the success of which was virtually totally dependant upon
receipt of information from industry. Individuals on the pooling administration staff began
working on these tasks promptly after the receipt of the initial appointment letter.




					
	 	 	 	 	 
	 
	© NeuStar, Inc. 2007
	 	NeuStar Proprietary and Confidential
	 	7






 









 





			
	PAS — Change Order Proposal #48 re: IRNA
	 	Revised August 17, 2007
	 






4.0 Staff and Administration



Florence Weber, Regional Director, IRNA, manages the IRNA responsibilities, administers ESQKs
in compliance with the both the Interim Guidelines and the terms of the letter from the
Wireline Bureau, and participates in industry meetings. From the inception of the IRNA to the
date of this change order proposal, the IRNA has received only six (6) registrations and one
(1) ESQK application. We are aware that some states have recently begun to certify VoIP
carriers as CLECs or have issued Orders allowing VoIP carriers to obtain numbering resources,
and we recognize that this could increase the volume of registrations and applications.
Nevertheless, we are confident that we can manage any such increase in registrations and
applications with only a single staff member whose primary responsibility is as the Interim
IRNA. Ms. Weber also performs various pooling functions when her attention is not directed at
the IRNA, and her time is recorded and billed according to which task she is performing.



In addition to the dedicated IRNA administrator, one additional person from the existing PA
staff has been trained to provide backup administration for the ESQK administrator, so that in
the event of illness or vacation, the functions can continue to be performed in a timely manner
as prescribed by the Guidelines. This person was available to assist the IRNA administrator in
the initial implementation period and will continue to be available as needed. Additionally,
with the knowledge and consent of the FCC, other members of the PA staff worked prior to the
implementation date to process and assess incoming data from existing administrators, to
establish processes and user guides, to determine the parameters of the IRNA’s responsibility,
to work with state commissions and existing administrators to develop processes to prevent
double assignments, to develop the various functionalities of the database, and to design and
implement the website.



Operations require ongoing contact with those entities other than the IRNA which continue to
assign ESQKs, to assure that double assignment does not occur. In addition, the IRNA
Administrator will continue to work closely with the Industry Numbering Committee on any
further amendments to the proposed permanent p-ANI guidelines. In the development of those
guidelines, the IRNA brought in multiple contributions and provided significant assistance to
the INC in cross-referencing the existing numbering guidelines, while participating in the INC
meetings.




					
	 	 	 	 	 
	 
	© NeuStar, Inc. 2007
	 	NeuStar Proprietary and Confidential
	 	8






 









 





			
	PAS — Change Order Proposal #48 re: IRNA
	 	Revised August 17, 2007
	 






5.0 Assumptions and Risks



Part of the PA’s assessment of this change order is to identify the associated assumptions and
consider the risks that can have an impact on our operations.




5.1 Assumptions



1. The IRNA function will exist only until the FCC appoints or chooses a permanent e9-l-l RNA.



2. The IRNA will assign non-dialable numbers exclusively out of the 211 and 511 NXXs (with 211 being used first).



3. The IRNA function will be limited to that set forth in the Interim Guidelines as they have
been clarified by the letter from the Wireline Competition Bureau. Conversely, the IRNA will
not function in a manner inconsistent with the letter. For example, the IRNA will not accept into
its system prior operations and transfers of information that would be inconsistent with the
letter
because it would require us to house and operate p-ANI administration for those not entitled to
the resources under the terms of the letter.



4. The IRNA will assign p-ANIs to eligible users only in the geographic locations in which
they are certified.



5. Other entities and states already administering p-ANIs will continue to perform that
function, and the operation of the IRNA will complement those existing operations until a
permanent solution is reached.



6. The IRNA will escalate to the FCC any questions or issues relating to applications for resources, and that escalation will toll the processing period.



7. The IRNA will not perform audits or reclamation.




5.2 Risks



The proposed solution does not present any additional risks to the internal operations of the
national pooling administrator.



Because it is a separate system, the system proposed here does not pose any risk to the Pooling
Administration System.




					
	 	 	 	 	 
	 
	© NeuStar, Inc. 2007
	 	NeuStar Proprietary and Confidential
	 	9






 









 





			
	PAS — Change Order Proposal #48 re: IRNA
	 	Revised August 17, 2007
	 






6.0 Cost



Because of the unusual circumstances of this change order proposal, we not only considered the
costs that would potentially be incurred in implementing the proposed solution, but also included
hours that pooling employees have already spent on this project.



Pooling employees were required to work overtime hours to comply with the FCC’s stated desire
that preparation for this project begin as quickly as possible, even before any change order
could be developed. We therefore advised the FCC that these charges would be included in the
cost as identified in the change order proposal.



Under the assumptions identified above, the maximum cost to implement our proposed solution until
August 14, 2007 is $87,460.00, which includes allowance for additional hours on any changes to the
proposed permanent guidelines, and any possible increase in activity due to state orders
certifying VoIP providers.



This figure includes costs incurred in set-up.




					
	 	 	 	 	 
	 
	© NeuStar, Inc. 2007
	 	NeuStar Proprietary and Confidential
	 	10






 









 





			
	PAS — Change Order Proposal #48 re: IRNA
	 	Revised August 17, 2007
	 






7.0 Conclusion



In conclusion, the national Pooling Administrator has offered a viable solution that addresses
the immediate necessity for an interim e9-l-l Administrator, and we ask that the FCC review
and approve this change order proposal.




					
	 	 	 	 	 
	 
	© NeuStar, Inc. 2007
	 	NeuStar Proprietary and Confidential
	 	11