exv10w3w1






Exhibit 10.3.1










 









 













National Pooling Administration




Contract #CON07000005




Change Order Proposal #4




(INC
Issue #591 — Change Timeline of Part 1 / Part 3 Processing for NANPA)





September 17, 2008





			
	 	 	 
	NeuStar, Inc.
	 	46000 Center Oak Plaza
	 
	 	Sterling VA, 20166






 









 






Table of Contents



	 	 	 	 	 
	1 Introduction
	 	 	3	 
	2 Industry Numbering Committee (INC) Issue
	 	 	4	 
	3 Industry Numbering Committee (INC) Resolution
	 	 	4	 
	4 The Proposed Solution
	 	 	7	 
	5 Assumptions and Risks
	 	 	8	 
	6 Cost
	 	 	8	 
	7 Conclusion
	 	 	8	 






			
	 	 	 
	 
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1 Introduction




1.1 Purpose and Scope



In accordance with NeuStar’s National Pooling Administration contract1 and our constant
effort to provide the best support and value to both the FCC and the telecommunications industry,
NeuStar, as the National Pooling Administrator (PA), hereby submits this change order proposal to
the Federal Communications Commission (FCC) for approval. This change order complies with the
contractual requirements set forth in Clause C.1 of the CONTRACT FOR POOLING ADMINISTRATION
SERVICES FOR THE FEDERAL COMMUNICATIONS COMMISSION, effective August 15, 2007, which reads as
follows at Section 2.5.4:





2.5.4 Modifications of Guidelines





The PA shall participate in the development and modification of guidelines and procedures,
which may or may not affect the performance of the PA functions. These changes may come
from regulatory directives and/or industry-initiated modifications to guidelines. In
addition, new guidelines may be developed as appropriate to comply with regulatory
directives. The PA shall implement any changes determined to be consistent with regulatory
directives.




The PA shall:




	 	•	 	Provide, in real time, technical guidance to ensure processes and
procedures are
effective in meeting the goals of the change.
	 
	 	•	 	Provide issues and contributions, and be prepared to discuss at INC
meetings how
the proposed change promotes numbering policy and/or benefits the
NANP and
how the change will affect the PA’s duties, obligations and accountability.
	 
	 	•	 	Assess and share in real time (i.e., during discussion) the cost
implications and
administrative impact of the change upon the PA’s duties and
responsibilities in
sufficient detail as needed by the INC.






When the INC places any changes to its guidelines in final closure, the PA shall submit an
assessment regarding the impact of scope of work, time and costs to the INC, the NANC and
the FCC within 15 calendar days. The PA shall post changes in procedures on its web site
prior to the change taking effect.




Specifically, the PA shall:




	 	•	 	Notify all interested parties when guidelines have changed.
	 
	 	•	 	Interpret guideline changes and impact upon processes.
	 
	 	•	 	Identify implementation date or effective date.
	 
	 	•	 	Provide notification of new forms or tools that may be required.

	 
	 	•	 	Identify a Single Point of Contact (SPOC) within the PA to answer questions.






The NANC shall be consulted at the FCC’s discretion regarding the suggested implementation
date to determine the likely impact on service provider processes and





 




			
	1	 	FCC Contract Number CON07000005





			
	 	 	 
	 
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systems (i.e., whether it would be unduly burdensome or would unfairly disadvantage any
service provider or group of service providers per the PA’s obligations and NANP
administrative principles). The PA shall also seek input on implementation dates from
service providers that log in to PAS and vendors that interface with PAS.


Because the proposed changes affect the PAS/NAS interface, the PA is submitting this change order
proposal in coordination with the companion change order being submitted by NANPA. The
requirements of the NANPA contract direct an earlier submission than the PA contract (no more than
30 days after guidelines changes are placed into Initial Closure, rather than Final Closure, as
quoted above).




2 Industry Numbering Committee (INC) Issue



As a result of the automation of the interface of the Part 1 CO Code data from the PA to the NANPA,
industry representatives raised concerns regarding shortening the length of time for code
processing. Members of the INC brought in an issue to INC addressing the timeframe for code
processing. Also, a contribution was brought under this issue that added a checkbox to the Part 1A
form that the SP can select to request the earliest possible effective date. The INC issue
statement is reproduced below:





INC Issue Statement:




Section 5.22 and Appendix D II of the Central Office Code Administrative
Guidelines (COCAG) provides the timeline of 10 business days for the NANPA to
process a Part 1 request / issue a Part 3. In June 2008, the NANPA will be
implementing a change to NAS (Number Administrative System) that will add an
interface with PAS (Pooling Administration System) to allow an automated flow
of Part 1 forms for NPA/NXXs in a pooled rate center. With this change there
will be not be a need for manual entry by NANPA for Part 1s received from the
PA.




With the automated receipt of Part 1 data from the PA to the NANPA, INC
should reduce the number of days the NANPA has to process a Part 1 / issue a
Part 3 from 10 business days to 7 calendar days.



3 Industry Numbering Committee (INC) Resolution



On August 29, 2008, the INC placed Issue 591 — Change Timeline of Part 1 /Part 3 Processing for
NANPA into initial closure, with the following language.




Resolution from INC:



The following text changes (in track changes) were made to the noted
sections within the TBPAG:



			
	 	 	 
	 
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	 	7.4.4	 	The following steps provide the process flow and activation procedures
for the addition of central office codes in order to provide additional
thousands-blocks to the industry inventory pool to meet immediate or forecasted
demand.
	 
	 	 	 	Step 1 — The PA utilizes SPs’ forecasts to determine that
additional thousands-blocks are required to maintain a 6-month
supply for the industry inventory pool for a specific rate
center.
	 
	 	 	 	Step 2 — The PA may require new NXX Code(s) to replenish the
industry inventory pool to meet an SP’s request that is not able be filled
from thousands-blocks currently available in the industry inventory pool:
	 
	 	•	 	From a list of SPs that have a forecasted need (first for LRNs, then for
thousands-blocks), the PA will send an email seeking a LERG Assignee
a to open
a code to be used to replenish the pool.. The SP, responding to the PA’s
request, must complete the Central Office Code (NXX) Assignment Request — Part
1 form and return it to the PA within two business days. The Central Office
Code (NXX) Assignment Request — Part 1 form will include the selected LERG
Assignee and a proposed Code Effective Date that allows for the industry
minimum assignment/activation interval of 66 calendar days. The SP also is
responsible for submitting the Thousands-Block Application Form(s) — Part 1A
to the PA only for the thousands-block(s) the SP needs to retain. If the SP is
retaining multiple blocks and the routing information is different for those
blocks, then the SP shall submit a Part 1A modification in order to update the
Part 1B information for the effected block(s).
	 
	 	•	 	When an SP applies for more than one block in a pool that needs to be
replenished, the PA will notify the SP submitting the request of the need for
pool replenishment. The SP will be given the option and encouraged to take
part of the requested blocks from the industry inventory pool and the
remaining requested blocks from a new NXX for pool replenishment.
	 
	 	•	 	The LERG Assignee receives a thousands-block(s) from the NXX assigned
to ensure that responsibilities in 4.2.1 are maintained. However, once the
responsibilities of the SP outlined in 4.2.1 of the TBPAG are fulfilled and
the SP determines that the block is not needed, the SP does have the option of
returning the block to the PA. The PA will follow the order below to select a
LERG Assignee:
	 
	 	1)	 	An SP requiring an LRN: A unique LRN is required for each
LNP-capable switch/POI that serves subscriber lines, or otherwise terminates
traffic per LATA. LRNs are to be used for routing and not for rating/billing
calls. SP must provide the MTE worksheet (TBPAG Appendix 3) to the PA. The
LERG Assignee shall select the LRN from its assigned thousands-block(s)





			
	 	 	 
	 
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	 	2)	 	An SP volunteering to be the LERG Assignee who meets the MTE and
utilization threshold requirements.
	 
	 	3)	 	Participating SPs with a forecasted need that also meet the MTE
and
utilization threshold requirements will be selected on a rotational basis.
An
SP with a forecasted need cannot refuse to become a LERG Assignee,
except for technical limitations, or if any SP is a LERG Assignee for
greater than 50% of the pooled NXX Codes within that rate center.
	 
	 	 	 	Where the SP has requested a dedicated NXX Code to meet a specific customer
request, the SP is responsible for completing the Thousands-Block Months to
Exhaust and Utilization Certification Worksheet — TN Level (Appendix 3) and
submitting it to the PA.
	 
	 	 	 	Step 3 — The PA then will forward that Part 1 to the CO Code Administrator.
For pool replenishment only, the PA must provide to the CO Code
Administrator an aggregated Thousands-Block Pooling Months to Exhaust
Certification Worksheet — 1000 Block Level (TBPAG Appendix 4).
	 
	 	 	 	Step 4 — The CO Code Administrator will review the Central Office Code
(NXX) Assignment Request — Part 1 form and, within
14 7 calendar days,
notify the PA and the LERG Assignee of the NXX Code(s) assignment.
	 
	 	 	 	Step 5 — The CO Code Administrator will input LERG Assignee information into
the ACD record of BIRRDS, using Central Office Code (NXX) Assignment Request — Part 1 form data (NPA, NXX, OCN, and Effective Date.).
	 
	 	 	 	Step 6 — Within seven calendar days of receipt of the NXX Code assignment
from the CO Code Administrator, the PA will inform the LERG Assignee of the
NXX Code and thousands-block(s) assigned using the Thousands-Block
Application Forms, Part 3 — Pooling Administrator’s Response/Confirmation.
	 
	 	•	 	During this seven -day interval, the PA will input all ten
thousands-blocks
into PAS and assign the requested number of blocks per the SP’s Part 1A
form. All other blocks from this code will be listed as “pending
verification of activation in the PSTN” and be available for assignment
listed as “pending verification of activation in the PSTN” and be until the
PA receives confirmation from the LERG Assignee that the code has been
activated in the PSTN, loaded in the NPAC, and all other LERG Assignee
Responsibilities have been fulfilled.
	 
	 	•	 	As an option, and at the request of a block applicant, the PA may
assign a
block(s) from the code with a block effective date one business day after





			
	 	 	 
	 
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	 	 	 	the effective date of the code, if a block applicant selects the checkbox on
the Part 1A that indicates that the block applicant explicitly understands
that the underlying CO code may not yet be activated in the PSTN and loaded in
the NPAC on the block effective date. Regardless of whether this option is
utilized, it is still advisable for block recipients to make a test call and
ensure that default routing has been established by the LERG Assignee before
loading the assigned blocks into translations, and to verify that the NXX has
been loaded in the NPAC.
	 
	 	•	 	The PA will build the BCD record for thousands-block(s) being
assigned to the LERG Assignee. The information entered on the BCD record will
include OCN of the Block Holder, the thousands-block range, switch ID and
thousands-block Effective Date. The Effective Date for all thousands-block(s)
assigned to the LERG Assignee will be the same as the Effective Date of the
CO Code unless the SP requests a date further out.
	 
	 	 	 	Step 7 (concurrent with Step 6) — Within seven (7) calendar days of
notification by the CO Code Administrator, the LERG Assignee, or its
designee, will input Part 2 information from the Central Office Code
(NXX) Assignment Request into BIRRDS.
	 
	 	 	 	TBPAG Part 1A
	 
	 	1.3	 	Dates
	 
	 	 	 	Date of Application:
                    
Requested Block Effective
Date:                           
	 
	 	 	 	Request Expedited Treatment? (See Section 8.6) Yes
                    
No                      
	 
	 	o	 	By selecting this checkbox, I acknowledge that I am requesting the
earliest possible effective date the Administrator can grant. Please note that
this only applies to a reduction in the Administrator’s processing time,
however the request will still be processed in the order received.





4 The Proposed Solution




The National Pooling Administrator has reviewed the changes to the TBPAG to determine whether and
how they will impact either the pooling operations or the Pooling Administration System (PAS). As
a result of our assessment, we developed the following proposed solution to address the changes
that the INC guidelines require, in a cost-effective and efficient manner.



The amendments to the TBPAG relating to the CO Code processing time, will necessitate updates to
the effective date interval in PAS for both the GUI and FTP interfaces. The standard effective date
interval will change from 72 calendar days to 66 calendar days. PAS will now default to the new
standard effective date of 66 calendar days from the date of application for CO



			
	 	 	 
	 
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codes. The user will have the option to change the standard effective date if desired. PAS will
also validate that the requested effective date is no less than 66 calendar days if the applicant
does not choose expedited treatment.



In addition, a new checkbox will be added to the Part 1 and Part 1A screens in PAS to allow the SP
to request the earliest possible effective date for all New Code Requests, Code Modification
Requests, Code Disconnect Requests, New Block Requests, Block Modification Requests, and Block
Disconnect Requests. This capability will also be added to the FTP interface. This checkbox will
be added to the viewable Part 1 and Part 1A forms in PAS. Also this checkbox will be added to the
PA’s Part 3 processing screen in PAS to assist the PA in determining the earliest effective date
to establish for all New Block Requests, Block Modification Requests, and Block Disconnect
Requests.



User manuals will be updated as appropriate.



5 Assumptions and Risks




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



This change order affects only the system, and would have no impact on our day-to-day
operations.



The implementation of this change order will be coordinated with NANPA.



6 Cost




In developing this proposal, we considered the costs associated with implementing the proposed
solution, including the resources required to complete discrete milestones on a timeline for
implementation. The timeline includes preparation, development, testing, proper documentation
updates, monitoring, and execution of the solution.



The cost of modifying the system to implement the changes to the TBPAG will be $9504.00.



7 Conclusion




This change order proposal presents a viable solution that addresses the amendments to the TBPAG
and is consistent with the terms of our contract. We respectfully request that the FCC review and
approve this change order.



			
	 	 	 
	 
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National Pooling Administration




Contract #CON07000005




Change Order Proposal #3




(User-Proposed Enhancements to PAS)




September 8, 2008




			
	 	 	 
	NeuStar, Inc.
	 	46000 Center Oak Plaza
	 
	 	Sterling VA, 20166






 









 







Table of Contents




	 	 	 	 	 
	1 Introduction
	 	 	3	 
	2 Users’ Proposed Enhancements
	 	 	3	 
	3 The Proposed Solution
	 	 	4	 
	4 Assumptions and Risks
	 	 	5	 
	5 Cost
	 	 	5	 
	6 Conclusion
	 	 	5	 






			
	 	 	 
	 
	 	- ii -






 









 





1 Introduction




1.1 Purpose and Scope




In accordance with NeuStar’s National Pooling Administration contract1 and our constant
effort to provide the best support and value to both the FCC and the telecommunications industry,
NeuStar, as the National Pooling Administrator (PA), hereby submits this change order proposal to
the Federal Communications Commission (FCC) for approval. This change order complies with the
contractual requirements set forth in Clause C.1 of the CONTRACT FOR POOLING ADMINISTRATION
SERVICES FOR THE FEDERAL COMMUNICATIONS COMMISSION, effective August 15, 2007.



2 Users’ Proposed Enhancements




Users of the Pooling Administration System (PAS) sometimes suggest changes to either our
administrative process or to PAS. This change order consists of several requests from both service
provider users of PAS and NOWG members to enhance the functionalities of PAS. The following five
(5) items describe the enhancements that the users are requesting:




	 	1.	 	The current Part 1A report in PAS allows a user to view all Part 1 As for all block
request
types and full NXX requests only. With the addition of the PAS/NAS interface and the
ability to submit code modifications and code disconnects through PAS, it has been
requested that the Part 1A report be modified in PAS to also include code modifications
and code disconnect requests.
	 
	 	2.	 	The Block Report is on the public (i.e. non-password-protected) pooling website. The
block report identifies blocks that are currently assigned, retained, and available within
an
NPA and rate center. It has been requested that the block report now include an
additional column that indicates who the Code Holder is for an available block.
	 
	 	3.	 	Users have the capability to reset their respective passwords in PAS. When the
password is reset by the user, the Login Id and new password are displayed to the user in
a white font with a blue background, which a few users find hard to read. It has been
requested that the color of the font be changed.
	 
	 	4.	 	Service providers are allowed to maintain a six-month inventory of numbers in each
pooled rate center in which they operate. They are required to donate blocks in pooled
rate centers that are above and beyond their six month inventory that are 10% or less
contaminated. It has been requested that further automated validations (e.g., rate center
and OCN) be added at the time the user submits its donation to assure that the donation
will not be rejected later when the PA processes the donation.
	 
	 	5.	 	A service provider must submit a Part 4 on every assigned block within six months of
the
original Part 3 effective date. At this time, each Part 4 is submitted individually. It has







 




			
	1	 	FCC Contract Number CON07000005





	 	 	 
	 
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	 	 	 	been requested that PAS be enhanced to allow a user to submit multiple Part 4s at the same
time on one screen.





3 The Proposed Solution




The National Pooling Administrator has reviewed the users’ requests from both their operational and
technical perspectives. As a result of our assessment, we developed the following proposed
solutions to address the changes that the users recommended, in a cost-effective and efficient
manner.




	 	1.	 	The Part 1A report that currently exists in PAS will be modified to include code
modifications as well as code disconnects. The report will also be renamed from Part IA
Report to Part 1/1A Report.
	 
	 	2.	 	The block reports available on the public portion of the pooling website will be
modified
to include a new column called “Code Holder” for the Available Block Report and the
Available, Assigned, and Retained Block Report. Also, when service providers submit
requests for blocks, they can view the Blocks Available list which will also include this
new column.
	 
	 	3.	 	When a new password is generated in PAS, the Login ID and Password screen will be
modified to display the login id and password in a dark blue font.
	 
	 	4.	 	PAS will be modified to validate the rate center and OCN of the code from which the
donation is being made, at the time the donation is submitted by the user. If the rate
center and/or the OCN do not match, an error message will be generated to the user and
the user will have the option to either correct or cancel the donation.
	 
	 	5.	 	PAS will be modified to allow a user to enter multiple Part 4s in PAS during one
submission. The three new drop-down fields — State, NPA and OCN — will be added to
the Create Part 4 — Block Screen in PAS. Users may select a specific state, NPA, or
OCN, or choose the Select All option, which will be based on their user profile. After the
users make their selections, a new Part 4s Due List screen will appear with a list of blocks
for which a Part 4 is still due. The user may submit one or multiple Part 4s from that
screen.





The user manuals will be updated as appropriate and user training will be conducted on the
changes.



			
	 	 	 
	 
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4 Assumptions and Risks




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



This change order affects only the system, and would have no impact on our day-to-day
operations.



5 Cost




In developing this proposal, we considered the costs associated with implementing the proposed
solution, including the resources required to complete discrete milestones on a timeline for
implementation. The timeline includes preparation, development, testing, proper documentation
updates, monitoring, and execution of the solution.



The cost of modifying the system to implement the changes to the PAS will be $ 20,736.00.



6 Conclusion




This change order proposal presents viable solutions that address the suggestions made by users of
PAS and is consistent with the terms of our contract. We respectfully request that the FCC review
and approve this change order.



			
	 	 	 
	 
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