1. CONTRACT ID CODE PAGE OF PAGESAMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT A 1 3 2. AMENDMENT/MODIFICATION NO. 3. EFFECTIVE DATE 4. REQUISITION/PURCHASE REQ. NO. 5. PROJECT NO. (If applicable) 0015 11/15/2005 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) (x) 9A. AMENDMENT OF SOLICITATION NO. Neustar, Inc. 9B. DATED (SEE ITEM 11) 46000 Center Oak Plaza 10A. MODIFICATION OF CONTRACT/ORDER NO. Sterling, VA 20166 (X) CON01000016 (X) 10B. DATED (SEE ITEM 13) CODE FACILITY CODE 11. THIS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICITATIONS

Exhibit 10.3.4

1. CONTRACT ID CODE

PAGE OF PAGES

AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT

A

1

3

2.

AMENDMENT/MODIFICATION NO.

3. EFFECTIVE DATE

4.

REQUISITION/PURCHASE REQ. NO.

5.

PROJECT NO. (If applicable)

0015

11/15/2005

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)

(x)

9A.     AMENDMENT OF SOLICITATION NO.

Neustar, Inc.

9B.     DATED (SEE ITEM 11)

46000 Center Oak Plaza

10A.   MODIFICATION OF CONTRACT/ORDER NO.

Sterling, VA 20166

(X)

CON01000016

(X)

10B.   DATED (SEE ITEM 13)

CODE

FACILITY CODE

11.

THIS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICITATIONS

[  ]The above numbered solicitation is amended as set forth in Item 14. The hour and date specified for receipt of Offers [  ] is extended, [  ] 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 ACKNOWLEDGEMENT 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 Change
							13.		THIS ITEM APPLIES ONLY TO MODIFICATIONS OF CONTRACTS/ORDERS,
									IT MODIFIES THE CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14.
					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).
					C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF: Mutual Agreement of the Parties
					D. OTHER (Specify type of modification and authority)
E.		IMPORTANT: Contractor [X] is not, [  ] is required to sign this document and return 3 copies to the issuing office.

14.

DESCRIPTION of AMENDMENT/MODIFICATION (Organized by UCF section headings, including solicitation/contract subject matter where feasible.)

THE ABOVE NUMBERED CONTRACT IS HEREBY MODIFIED TO:

1) TO ACCEPT ALL CHANGE ORDER #37 AT A COST OF $1,358.00. COPY OF CHANGE ORDER IS ATTACHED.

ALL OTHER TERMS AND CONDITIONS REMAIN THE SAME.

15A.

NAME AND TITLE OF SIGNER (Type or print)

16A.

NAME AND TITLE OF CONTRACTING OFFICER (Type or print) Dennis O. Dorsey

15B.

CONTRACTOR/OFFEROR

15C.

DATE SIGNED

16B.

UNITED STATES OF AMERICA

16C. DATE SIGNED

BY

12/5/05

(Signature of person authorized to sign)

(Signature of Contracting Officer)

NSN 7540-01-152-8070

30-105

STANDARD FORM 30 (Rev. 10-83)

PREVIOUS EDITION UNUSABLE

Prescribed by GSA

FAR (48 CFR) 53.243

LINE ITEM

Document Number

Title

Page

SUMMARY

CON01000016/0017

Pooling Administrator   –  Neustar

2 of 3

Line Item

Delivery Date

Unit of

Number

Description

(Start date to End date)

Quantity

Issue

Unit Price

Total Cost

No Changed Line Item Fields

Previous Total:

Modification Total:

Grand Total:

National Pooling Administration

Change order Proposal #37

(INC Issue #458 – “Reduce Aging Period For
Returned/Reclaimed Blocks”)

December 7, 2004

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

Nat’l PAS — Change Order #37 (INC Issue 458)		December 7, 2004

TABLE OF CONTENTS

1 Introduction			3
2 Industry Numbering Committee’s Proposed Change			4
3 The Proposal			5
4 Assumptions and Risks			5
5 Cost			5
6 Conclusion			5

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		-ii

Nat’l PAS — Change Order #37 (INC Issue 458)		December 7, 2004

1 Introduction

1.1 Purpose and Scope

In accordance with NeuStar’s National Pooling Administration contract ¹ 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 Attachment B, Section C of the Thousands-Block Pooling Contractor Technical Requirements, dated November 30, 2000, Sections 2.5 through 2.5.4, which read as follows:

2.5 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. The contractor is additionally subject to the provisions of the changes clause in Section I.

2.5.1 Process

Accordingly, after a contractor is selected, the FCC, the NANC and/or the INC may establish NANP numbering resource plans, administrative directives, assignment guidelines (including modifications to existing assignment guidelines), and procedures that may have an effect on the functions performed by the contractor.

2.5.2 Changes

The contractor shall review changes when numbering resource plans, administrative directives, assignment guidelines, and procedures are initiated or modified to determine if there is any impact on the functions that they must perform.

2.5.3 Notifications

The contractor shall then, within a period of not more than 30 calendar days from said event (e.g., the date INC places an issue into Final Closure), provide the Contracting Officer, state PUCs, and the NANC with written notice regarding these changes and summarize the potential impact of the changes upon service and cost, if any.

2.5.4 Roles

The NANC shall review the notice and provide a recommendation to the FCC regarding the effect of the contractor’s notice and supporting documentation.

The contractor shall comply with state regulatory decisions, rules and orders with respect to pooling, as applicable, as long as they are not in conflict with FCC decisions, orders, and rules and are within state jurisdiction.

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		-3

Nat’l PAS — Change Order #37 (INC Issue 458)		December 7, 2004

This document provides the information required by the contract, such as identifying the new requirements of the expanded scope of work, offering our proposed solution, and addressing its cost, risks, and assumptions as a result of the Industry Numbering Committee’s (INC) disposition of Issue 458 on November 12, 2004.

2 Industry Numbering Committee’s Proposed Change

According to Section 9.2.4 of the Thousands-Block Number (NXX-X) Pooling Administration Guidelines, the aging period for returned or reclaimed thousands-blocks, is 90 days. After this 90-day aging period, blocks are made available for reassignment. On November 12, 2004, INC placed Issue 458 into Final Closure. As a result of INC Issue 458, the aging period in the guidelines is being reduced from 90 days to 45 days. Therefore, PAS will need to be modified to compensate for this reduction in the aging period.

INC Issue 458 Reduce Aging Period for Returned/Reclaimed Blocks

Quoted below are the INC official issue statement and final resolution, which can also be found on the ATIS website (http://www.atis.org):

A) Issue Statement

At INC 77, the INC received a request from the NANC’s Numbering Oversight Working Group (NOWG) to provide input to the NOWG’s upcoming review of the Pooling Administrator (PA) Technical Requirements. In CS-098, dated August 24, 2004, the INC provided four suggestions to the NOWG, including a suggestion to “Age returned blocks only 45 days instead of 90 days.” Verizon Wireless took an action item to bring in a new issue and contribution to INC so that the associated guidelines changes could be made.

Occasionally an SP may need to exchange a block with the industry inventory pool, and while there may not be other blocks immediately available for assignment, there may be blocks being “aged” by the PA that were recently returned or reclaimed. Allowing those returned or reclaimed blocks to be made available for assignment more quickly may assist SPs when they need to exchange a block, and may assist the PA in avoiding opening a new code to meet SP demand. The current TBPAG requires that recently returned or reclaimed blocks be aged for 90 days, but 45 days should be sufficient to allow the LERG Assignee time to modify its translations to provide vacant number treatment for the block by the LERG effective date of the disconnect.

B) Following Resolution from INC

The following text changes were made to the TBPAG, section 9.2.4:

9.2.4 The PA must also notify and coordinate with the LERG Assignee in advance of the thousands-block return Effective Date to allow sufficient

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		-4

Nat’l PAS — Change Order #37 (INC Issue 458)		December 7, 2004

time for the LERG Assignee to update switch translations in order to provide blank number treatment for the returned thousands-block(s). The PA will make the thousands-block available for reassignment after 45 calendar days.

3 The Proposal

NeuStar’s National Pooling Administrator has reviewed INC Issue 458 from both the operational and technical perspectives. The proposal set forth below will conform to the changes in the INC guidelines and meet the requirements of the industry in a cost-effective and efficient manner.

Solution

Presently the aging period for returned/reclaimed thousands-blocks according to Section 9.2.4 of the Thousands-Block Number (NXX-X) Pooling Administration Guidelines is 90 days. After this 90-day aging period, blocks are made available for re-assignment. The resolution of INC Issue 458 reduced the aging period from 90 days to 45 days. Therefore, PAS will need to be modified to similarly reduce the aging period for returned or reclaimed thousands-blocks from 90 days to 45 days from the effective date of the return or reclamation.

4 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.

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

5 Cost

As with any change order proposal, we also considered the associated costs that would potentially be incurred in implementing the proposed solution. These costs include the resources required to complete the milestones on a timeline for implementing the processes and system delineated in this change order. The timeline includes preparation, proper documentation updates, development, testing, monitoring, and execution.

The cost to implement our proposed solution would be $1,358.00.

6 Conclusion

In conclusion, the Pooling Administrator offers this viable solution to conform the PAS to INC Issue 458, and in accordance with contract terms, requests that the FCC review and approve this change order.

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		-5

AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT			1. CONTRACT ID CODE			PAGE OF PAGES
			A			1          3

2. AMENDMENT/MODIFICATION NO.			3. EFFECTIVE DATE			4. REQUISITION/PURCHASE REQ. NO.			5. PROJECT NO. (If applicable)
0016			05/19/2006

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.								9B. DATED (SEE ITEM 11)
46000 Center Oak Plaza					(X)			10A. MODIFICATION OF CONTRACT/ORDER NO.          CON01000016
Sterling, VA 20166					(X)			10B. DATED (SEE ITEM 13)
CODE		FACILITY CODE
11. THIS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICITATIONS

[   ] The above numbered solicitation is amended as set forth in Item 14. The hour and date specified for receipt of Offers [   ] is extended, [   ] 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 ACKNOWLEDGEMENT 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 APPLIES ONLY TO MODIFICATIONS OF CONTRACTS/ORDERS,
IT MODIFIES THE CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14.
					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).
					C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF: Mutual Agreement of the Parties
X					D. OTHER (Specify type of modification and authority) FAR 1.6 “Authority of the Contracting Officer”
E.		IMPORTANT: Contractor [X] is not, [   ] 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 above numbered contract is hereby modified to approve Change Order #41 @ no cost and Change order #43 @ a cost of $600.
		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)
				Wilma Mooney
15B. CONTRACTOR/OFFEROR		15C. DATE SIGNED		16B. UNITED STATES OF AMERICA		16C. DATE SIGNED
				BY /s/ Wilma S Moody		06/19/2006
(Signature of person authorized to sign)				(Signature of Contracting Officer)

NSN 7540-01-152-8070		STANDARD FORM 30 (Rev. 10-83)
PREVIOUS EDITION UNUSABLE		Prescribed by GSA
		FAR (48 CFR) 53.243

National Pooling Administration

Change Order Proposal #41

(LNPA WG PIM 24 and

CO/NXX Issue #364 — “Modification to Procedures for Code

Holder/LERG Assignee Exit”)

May 4, 2005

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

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		May 4, 2005

Table of Contents

				Page
1		Introduction			3
2		Industry Proposed Changes			4
3		The Proposal			10
4		Risks and Assumptions			12
5		Cost Assumptions and Summary			13
6		Conclusion			13
Appendix A					14

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		- ii

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		May 4, 2005

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 Attachment B, Section C of the Thousands-Block Pooling Contractor Technical Requirements, dated November 30, 2000, Sections 2.5 through 2.5.4, which read as follows:

2.5 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. The contractor is additionally subject to the provisions of the changes clause in Section I.

2.5.1 Process

Accordingly, after a contractor is selected, the FCC, the NANC and/or the INC may establish NANP numbering resource plans, administrative directives, assignment guidelines (including modifications to existing assignment guidelines), and procedures that may have an effect on the functions performed by the contractor.

2.5.2 Changes

The contractor shall review changes when numbering resource plans, administrative directives, assignment guidelines, and procedures are initiated or modified to determine if there is any impact on the functions that they must perform.

2.5.3 Notifications

The contractor shall then, within a period of not more than 30 calendar days from said event (e.g., the date INC places an issue into Final Closure), provide the Contracting Officer, state PUCs, and the NANC with written notice regarding these changes and summarize the potential impact of the changes upon service and cost, if any.

2.5.4 Roles

The NANC shall review the notice and provide a recommendation to the FCC regarding the effect of the contractor’s notice and supporting documentation.

The contractor shall comply with state regulatory decisions, rules and orders with respect to pooling, as applicable, as long as they are not in conflict with FCC decisions, orders, and rules and are within state jurisdiction.

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		- 3

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		May 4, 2005

This document covers the required subject matters such as explaining the industry’s requirements, proposed solution, cost, risk, and assumptions.

2 Industry Proposed Changes

Change Order History

On July 2, 2003, the Pooling Administrator (PA) submitted Change Order #23 as a result of the industry resolution of Local Number Portable Administration Working Group (LNPA WG) Project Issue Management (PIM) 24. PIM 24 proposed allowing the PA to obtain NPAC reports, which would enable the PA to check for contamination levels on donated thousands-blocks and ensure that an NPA-NXX is properly opened in the NPAC. In Change Order #23, the PA requested FCC approval of the purchase of reports from the NPAC to assess the contamination level of donated blocks.

On July 29, 2003, the Industry Numbering Committee (INC) placed CO/NXX Issue 364 into Final Closure. CO/NXX Issue 364 relates to the transfer of pooled codes from carriers that are proactively shutting down a network or service. The industry recognized that, as with donations, the PA must be able to verify whether and to what degree there is contamination of the affected blocks. INC determined that the changes it had made to the INC Thousands-Block Pooling Administration Guidelines in addressing Issue 364 would not be posted as revision to the guidelines until the FCC approved the related change order.

On August 26, 2003, the PA withdrew Change Order #23 and replaced it with Change Order #24, which we believed addressed the issues in both PIM 24 and INC CO/NXX Issue 364, allowing us to compare contaminated block information in the NPAC, with the information in the PAS, on an ongoing basis. Our intent was to avoid service-impacting assignment of blocks that had been contaminated after donation, or between assignment and return, or that were contaminated above the 10% limit.

The NOWG conducted its review of Change Order #24, but did not accept any of the three solutions proposed by the PA. Instead, the NOWG recommended to the FCC in a response dated September 19, 2003:

     The NOWG recommends that the PA select an NPA from each NPAC Region and perform an audit of embedded inventory using the proposed NPAC report to ascertain the type and frequency of error within the PAS embedded base. These results will be shared with the NOWG to assist in determining if there is value in proceeding with a one-time scrub of the entire PAS embedded base.

In response, the PA requested that the FCC hold Change Order 24 in abeyance, and submitted Change Order #26, asking to conduct a one-time trial of the process described in Change Order #24. The PA conducted the trial and presented its findings to the FCC and the LNPA WG. In addition, the PA recommended to the FCC that the PA should conduct this type of database comparison for all NPAs on an annual basis. Also, the PA recommended that it obtain NPAC reports for returned blocks and donated blocks on a weekly basis, at a minimum, as a way to provide ongoing protection for end users.

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		- 4

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		May 4, 2005

In response to the PA’s Change Order #26 report, on August 26, 2004 the NOWG recommended to the FCC as follows:

•

The PA [shall] provide an updated proposal with cost details for Change Order #24 to the FCC, for review by the NOWG, prior to the FCC authorizing a one-time scrub of PAS by the PA.

•

Concurrent with this one-time scrub, the PA [shall] prepare and propose to the INC that a self-certification statement be added to the Appendix 2 donation form. This proposed certification would require the SP to certify that (1) the information being provided has met certain designated stipulations and (2) the donating SP has properly marked/checked the appropriate items on the form prior to its submission, whether it be either an electronic or manual submission.

•

Concurrent with this one-time scrub, the PA [shall] work with INC to review the TBPAG directions for donating SPs in an effort to ensure the verbiage and responsibilities are thorough and clear for both SPs and the PA.

•

During the one-time scrub, the PA [shall] seek the appropriate support and assistance from the FCC and/or state commissions in enforcing SP participation in the one-time reconciliation process in situations where the PA is unable to obtain sufficient cooperation from individual service providers, e.g., answer PA inquiries in a timely manner in order for the PA to complete the one-time scrub.

•

Quarterly, the PA should distribute via their email exploder a “tip “ describing SP obligations when donating blocks to a pool and to remind SPs to follow the INC guidelines as they relate to the underlying causes of mismatches between PAS and the NPAC. Also, the PA should include any one-time scrub related information that it believes will help SPs understand where their efforts are substandard and therefore contribute(s) to this mismatch in the past and/or in the present.

•

Finally, the NOWG recommends that one year after the first full reconciliation has been completed by the PA, the NOWG and PA should then seek input from the industry as to any increase or decrease in the frequency in which SPs encounter erroneous block contamination. If the instances have increased, further action may be warranted, however, the NOWG does not recommend any further/additional activities other than those related to the “one-time scrub of the entire PAS database for unassigned/available blocks in the pool inventory” at this time.

On January 10, 2005, the FCC directed the PA to withdraw Change Order #24 and resubmit a new change order to conform to the NOWG’s recommendations. Subsequent to the FCC’s direction, the INC and the LNPA WG met with the NOWG, and agreed to re-examine the issues. In the meantime, however, the NOWG has now advised the PA by email that:

The NOWG has discussed and has come to consensus that the ‘one time scrub’ associated with change order 24 needs to be in the works as soon as possible. This is the shorter term solution that we all have discussed many times. We understand that the INC and the LNPA WG are discussing the longer term approach in terms of how to enforce this going

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		- 5

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		May 4, 2005

forward but we feel the shorter term solution should be submitted as a change order as soon as possible.

This Change Order #41 constitutes a resubmission of the request for a one time scrub associated with Change Order #24, as requested by the NOWG.

Industry Issues Leading to the Change Orders

LNPA WG PIM 24

The issue identified in PIM 24 relates to service providers who cannot use blocks that have been assigned to them either because the NPA-NXX has not been activated in the Number Portability Administration Center (NPAC), the thousands-block contamination level is greater than 10%, or the code holder failed to complete its intra-service provider ports prior to donating the blocks. To address these problems, the PA and AT&T Wireless submitted a joint PIM at the March 2003 LNPA WG meeting, which was accepted as PIM 24. PIM 24 proposed allowing the PA to obtain NPAC reports, which would enable the PA to check for contamination on a donated thousands-block and ensure the NPA-NXX is opened in the NPAC.

PIM 24, which the PA and AT&T Wireless submitted to the LNPA WG, is reproduced below:

1. Problem/Issue Statement: (Brief statement outlining the problem/issue.)

Blocks that are being assigned to Service Providers are either contaminated when they are donated as a non-contaminated block or the blocks have been contaminated over 10%. This is causing customers to be out of service or blocks being exchanged for a less contaminated or non-contaminated block.

In addition when the PA has assigned a block, at times the block is being rejected in the NPAC for not having the NXX as opened in the NPAC as portable.

2. Problem/Issue Description: (Provide detailed description of problem/issue.)

A. Examples & Impacts of Problem/Issue:

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		- 6

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		May 4, 2005

When a SP donates a block they mark the block as either contaminated or not contaminated. They do not indicate how many TN’s are contaminated. SP’s are suppose to do a Intra SP port on their contaminated TN’s prior to donating a block so that the block can be ported to the new SP and they can begin using the block on the effective date. The new SP should query the NPAC prior to assigning any TNs to determine which TN’s are contaminated and exclude those from their inventory assignment.

In one situation what is happening is that a block is assigned, the new SP goes to put those numbers in service, the old SP has not done their Intra SP ports causing their customers to be out of service. To resolve this, the 1000 block has to be deported, so that the old SP can Intra SP port their numbers then the 1000 block is reported to the new SP.

In another situation a block has been assigned either uncontaminated or contaminated and it is discovered the block has over 10% contamination. In this case the block has to be deported and a new block has to be assigned to the SP.

When a block is assigned and the NXX is not opened for porting in the NPAC, the block is rejected. The SP of the code then has to go into the NPAC and add their code as portable so that the block can be then ported. Even though this may take a matter of minutes to add, getting a hold of the correct person at a company to do this may take some time.

B. Frequency of Occurrence:

Ongoing

C. NPAC Regions Impacted:

Canada___Mid Atlantic___Midwest___Northeast___Southeast___Southwest

Western___West Coast___ALL X

D. Rationale why existing process is deficient:

It is up to the SP’s to do their INTRA SP ports and make sure they take the 1000 block out of their inventories when donating the block. This is not always happening.

It is up to the SP to add their NXX to the NPAC as a portable NXX prior to donating blocks. They indicate so on their donation form. However, this has not been the case in many situations.

E. Identify action taken in other committees / forums:

Issue raised at INC on two different occasions, they felt the guidelines already addressed the issue by leaving the responsibility to the SP to do the necessary work when they donated the blocks.

F. Any other descriptive items:

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		- 7

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		May 4, 2005

3. Suggested Resolution:

The following actions are proposed to resolve this issue:

Provide the PA access to the NPAC to check for contamination prior to the assignment of a thousands block.

Provide the PA access to the NPAC to check if the code is opened as portable.

The LNPA WG submitted PIM 24 to the North American Portability Management Limited Liability Corporation (LLC) for approval. The LLC approved permitting the PA to obtain NPAC reports.

The PA subsequently gave the following report requirements to the NPAC:

The report generated from the NPAC should include the NPA-NXX-X, how many intra-SP ports are associated with it, how many total active and pending SVs there are, plus the company name associated with the active and pending SVs in an excel format by region. If an NPA-NXX is not found in the NPAC as portable, it should still come back to the PA with a note that the NPA-NXX does not exist in the NPAC.

CO/NXX Issue 364

The issue identified in INC CO/NXX Issue 364 relates to service providers who must transfer pooled codes to other carriers, because they are proactively shutting down a network or service. As with donations, the PA must be able to verify whether and to what degree there is contamination of the affected blocks.

Quoted below are both the INC official issue statement and its final resolution, which can also be found under INC working documents on the ATIS website (http://www.atis.org) for CO/NXX Issue 364 “Modification to Procedures for Code Holder/LERG Assignee Exit:”

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		- 8

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		May 4, 2005

A. ISSUE STATEMENT

INC’s newly defined and issued procedures for CO Code transfer process are not sufficient in aiding carriers that are proactively shutting down a network or service. The existing procedures were mostly developed from the perspective of a carrier going out of business in an unexpected manner(bankruptcy). The INC CO Code transfer guidelines are not sufficient in aiding carriers that are proactively shutting down a network or service. There are many independent activities evolving many internal organizations as well as the NANPA and other carriers.

The main problem is a complex timing issue, this because it involves the donating carrier, NANPA, NPAC, and the receiving carrier. In addition all other carriers must update their networks and OSSs to ensure that customers receive calls originating from their networks.

Donating Carrier issues:

•

Timing of Customer notification, disconnect timing

•

Timing of Network and trunk engineering disconnect timing

•

Timing of Support system disconnect

•

Timing of Co Code transfer/disconnect timing

•

Determine when the last day a user can port on CO Codes that already have port(s).

•

Determine when the last day a user can port on CO Code that does NOT already have port(s).

NANPA Issues:

•

The NANPA does not have immediate access to NPAC records to determine if there are ported customers associated with the CO-NXX that are being returned by a carrier. The North American Portability Management (NAPM), LLC currently does not allow the NANPA access to the NPAC. The NANPA has to request reports from the NPAC to determine if a CO Code has numbers that have been ported. This requires up to an additional week before a potential carrier can be contacted to takeover CO Code ownership.

•

The NANPA is required to adhere to existing INC guidelines and FCC Orders that may prevent a timely and non-service impacting transfer of CO Codes that require a new CO Code holder.

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		- 9

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		May 4, 2005

Examples:

	•		Due to neutrality and non-disclosure requirements the NANPA can not identify a carrier that agreed to become the CO Code holder to the donating carrier until it is published in the LERG (up to 30 days).
	•		The NANPA denies a disconnect request on a CO Code that has ported number, however the AOCN can enter the LERG effective disconnect date as long as the interval from the request to the LERG effective date is greater than or equal to the required 66 day CO Code interval.
	•		NANPA approves CO Code disconnects request that currently do not have ported customers, but have a high probability that a customer will port before the LERG disconnect date.

Receiving Carrier Issues:

•

Ensure that ported- in customer(s) do not have degraded or no service due to the transfer of the CO Code.

Attached: NANPA’s Proposed Process for Disconnecting or Finding New LERG Assignees for NXXs Assigned to a Service Provider Seeking to Disconnect Service

B. ISSUE RESOLUTION

INC created the attached new COCAG Appendix C to replace the existing Appendix C. The new Appendix C also replaces the interim NANPA process document titled “Procedures for Returning Non-Pooled Codes with Active or Pending Ported Telephone Numbers (TNs)” dated April 25, 2002. This new Appendix C becomes effective when posted to the ATIS web site.

In addition, INC also created the attached new TBPAG Appendix 7 (attached as Appendix A) replace the existing Appendix 7. However, this new Appendix 7 will NOT be posted on the ATIS web site because INC anticipates that the PA will be generating a Change Order for FCC approval. Posting of the document will be held in abeyance until any potential Change Order has been approved by the FCC and implemented by the PA.

This resolves the issue.

3 The Proposal

NeuStar’s National Pooling Administrator reviewed the NOWG’s recommendation dated August 26, 2004 from both the operational and technical perspectives. We believe that our proposed

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		- 10

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		May 4, 2005

solution based on NOWG recommendations as set forth below will address the NOWG’s recommendation in a cost-effective and efficient manner.

To conform to the NOWG recommendation, we propose to perform the following actions:

•		Conduct a one-time scrub of the PAS database using NPAC data. We will receive seven (7) NPAC reports, one for each NPAC region. This data will be compared to what is in PAS and SPs will be contacted to correct the data.
•		During the scrub we will seek appropriate support and assistance from the FCC and/or state commissions to enforce SP participation, if needed.
•		Concurrent with the one-time scrub, we will prepare and propose to the INC that a self-certification statement be added to the Appendix 2 donation form (which may result in a additional change order to modify PAS)
•		Concurrent with this one-time scrub, we will work with INC to review the TBPAG directions for donating SPs in an effort to ensure the verbiage and responsibilities are thorough and clear for both SPs and the PA.
•		Quarterly, we will distribute via our email distribution a “tip” describing SP obligations when donating blocks to a pool and to remind SPs to follow the INC guidelines as they relate to the underlying causes of mismatches between PAS and the NPAC. Also, we will include any one-time scrub related information that we believe will help SPs understand where their efforts are substandard and therefore contribute to the mismatch in the past and/or in the present.
•		One year after the reconciliation has been completed, the NOWG and the PA will seek input from the industry as to any increase or decrease in the frequency in which SPs are encountering erroneous block contamination.

It is our opinion that this proposal clearly does not meet the requirements of the industry as delineated in LNPA WG PIM 24 and CO/NXX #364, and set forth in TBPAG Appendix 7 (attached hereto as Appendix A). However, it does address the NOWG’s short-term concern, as expressed in its e-mail to the PA.

Specifically, the INC has directed us as follows in Appendix 7:

From section 4.1 relating to Returned Thousands-Blocks Containing Ported Numbers.
When the Block Holder is not the LERG Assignee:

The PA shall request an ad hoc report from the NPAC to determine if there are any ported TNs or pending ports on the block(s) being returned. This information will assist the PA in re-allocating the block. If the block is 10% or less contaminated the PA will process the block return. This will effectively be a contaminated block donation to the pool inventory. If the contamination level is greater than 10%, the PA will follow the order below to select a new block holder:

From section 4.2 relating to Returned Thousands-Blocks Containing Ported Numbers.
When the Block Holder is also the LERG Assignee:

The PA shall request an ad hoc report from the NPAC to determine if there are any ported TNs or pending ports on the block(s) being returned. The PA will follow the order below to select a new LERG assignee:

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		- 11

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		May 4, 2005

From section 5.1 relating to Abandoned Thousands-Blocks Containing Ported Numbers.
When the Block Holder is not the LERG Assignee:

The PA shall request an ad hoc report from the NPAC to determine if there are any pending or completed TN ports. The PA will contact the appropriate regulatory authority and seek guidance concerning the return or reassignment of the abandoned block. If the block contamination level is 10% or less, the block is returned to the pool once written confirmation (email or fax) is received from the regulatory authority to reclaim the block. If the block contamination level is greater than 10%, the PA will follow the order below to select a new block holder unless otherwise directed by the regulatory authority:

From section 5.2 relating to Abandoned Thousands-Blocks Containing Ported Numbers.
When Block Holder is also the LERG Assignee:

The PA shall request the ad hoc report from the NPAC to determine if there are any pending or completed TN ports. This information will assist the PA in reallocating the NXX code/blocks. The PA will follow the order below to select a new LERG assignee unless otherwise directed by the appropriate regulatory authority:

The PA receives returned blocks literally on a daily basis. Under the NOWG proposal, the PA will not be able to determine, except on the day it examines a particular NPA, if there are any pending or completed ported TNs on any blocks that are voluntarily returned, so blocks that could be potentially over 10% contaminated will just be returned to the pool. The new assignee simply will not know whether it is getting a block that is less than 10% contaminated until it runs its own report with the NPAC. Essentially, the industry will have to continue proceeding in caveat emptor mode, and all the work that went into the crafting of Appendix 7 will have been for naught.

4

Risks and Assumptions

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

A.

Assumptions

The PA assumes that this is a short-term fix to assure the accuracy of the PAS database as of a specific date, the date the one-time scrub is completed. The PA does not assume that this solution addresses PIM 24 and INC Issue #364, and assumes those will have to be addressed at a later date.

B.

Risks

The proposed solution does not present any additional risks to our operations. It does not, however, decrease the risk to carriers of service-affecting outages on contaminated blocks that PIM 24 and Appendix 7 intended.

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		- 12

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		May 4, 2005

C.

Impact on Operations

This proposed solution has a one-time impact on our operations because it will take a significant amount of staff time to do the initial scrub of the data, send notifications to the service providers of any discrepancies, and receive responses from the industry.

5

Cost Assumptions and Summary

As with any change order proposal, NeuStar’s National Pooling Administrator considered the associated costs that can be incurred in implementing the proposed solution. These cost assumptions are based upon the NPAC’s standard charges.

The anticipated cost to implement this proposed solution is $6,209.00, which includes the price for the extensive staff hours that will be required to perform this task, along with the costs of the reports we must obtain from the NPAC. The PA staff members are already carrying heavy workloads, due to the steady rise in volumes, which have increased significantly over the past few months. We respectfully request that this Change Order be approved giving the PA authorization to charge straight overtime for the staff members involved in the project.

The alternative would be to hire a temporary employee for this project, but we have considered and rejected that option because it would not facilitate timely completion of the project, or keep costs down, for the following reasons:

•

it would add the time of posting the position, interviewing, and obtaining the appropriate security clearance for the person

•

training time would be needed

•

the person would not have the familiarity with carrier contacts that pooling staff members have

•

the person would not have the familiarity with the two databases involved, or the previously developed personal contacts at the NPAC, that existing pooling personnel have.

6

Conclusion

In conclusion, the NeuStar National Pooling Administrator has offered a viable solution that supports the NOWG’s August 26, 2004 recommendation in accordance with contract terms, and we ask that the FCC review and approve this change order proposal. However, we reiterate our concern that this proposed solution does not address the original solutions for INC Issue #364 and the LNPA WG PIM 24, as resolved in Appendix 7 to the TBPAG.

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		- 13

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		May 4, 2005

Appendix A

May 8, 2003		TBPAG Appendix 7

Procedures for Block Holder/LERG Assignee Exit

1.0

Purpose

This appendix describes the responsibilities of NANPA, service providers, and the PA in situations when a service provider (SP) is returning or abandoning NXX codes/blocks that contain ported telephone numbers and a new LERG assignee must be selected with minimal impact on ported customers. The specific circumstances addressed cover:

	•		Voluntary Return of Thousands Blocks Containing Ported Numbers
	•		Abandoned Thousands Blocks Containing Ported Numbers

2.0

Assumptions

2.1

Reasonable efforts should be taken to re-establish a LERG assignee in order to maintain default routing. Should the LERG assignee vacate their responsibilities, calls to the donor switch will not be processed.

2.2

The SP returning an NXX code will coordinate with NANPA to ensure that the code is not removed from the LERG as an active code until the Part 3 with the effective date of the disconnect is received. This is to prevent an adverse effect on ported-out customers.

2.3

A LERG assignee must be LNP capable, may put the code/block on any switch in the rate center, and should already be providing service in the rate center. This should eliminate any potential problems with facilities readiness.

2.4

It is desirable to avoid having to designate a new LERG assignee in the NPAC because all ported customers will experience a temporary interruption of incoming service during transition to the new assignee while the Service Provider Identification (SPID) is updated in the Number Portability Administration Center (NPAC). However, it is a regulatory requirement to allow continued porting of any number in the NXX, a process that requires correct SPID/number association at NPAC for NPAC’s message validation process.2

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		- 14

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		May 4, 2005

2.5

The PA shall work closely with regulatory authorities to obtain timely information about SPs abandoning service or filing bankruptcy. Such circumstances are under the direction of a regulatory authority or court.

2.5

A SP has the option to refuse a NXX code/block re-allocation. Refusal will not adversely impact any pending NXX code/block assignment request because it is unrelated to the reallocation.

2.7

These guidelines also apply in jeopardy/rationing situations.

2.8

It is the responsibility of each SP to provide an accurate E911 record for each of its customers to the E911 Service Provider. It is essential that the outgoing SP unlock its E911 records in the regional E911 database, and the new SP must transition the affected customers records to its own company ID in the E911 database.

2.9

It is the responsibility of the new LERG assignee and new block holder to notify Telcordia™ to update the AOCN responsibility in BIRRDS for the reallocated NXX code/block(s).

2.10

The SP returning the NXX code/block has the responsibility to assure that affected parties, especially any end-users, are notified consistent with state or regulatory requirements.

2.11

It is the responsibility of the SP returning the NXX code/block to disconnect and remove all records related to the LRN and NXX code, including intra-SP ported TNs, from the NPAC database. If a NXX code/block is reassigned and there are still old records in NPAC, the new LERG assignee will encounter problems with the affected numbers from the reassigned NXX code/block, e.g., porting records on TNs not in service.

2.12

When an NXX code is re-allocated and there are no active or pending ported numbers in the NPAC, the NPAC, via receipt of the LNP NXX LERG Assignee Transfer Form, should ensure that any existing NXX records of the code are deleted from its database on the effective date of the reallocation.

2.13

In certain situations the decision to actually change the NPAC code ownership record (i.e., by deleting and subsequently re-creating records for all ported numbers in the returned NXX code and accepting the likely adverse customer service impact) may be acceptable. This decision should be based on the quantity and type of customers involved, and the agreement of the involved SPs that would have to coordinate the change.

The LNPA WG has developed requirements for the ability to mass update the SPID associated with an NXX code without taking ported customers out of service. This functionality has been assigned NANC Change Orders 217 and 323 which is expected to be available in Release 3.2.

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		- 15

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		May 4, 2005

2.14

If there are no active or pending ports on the returned NXX code pending disconnect, the NPAC will use the Part 3 disconnect information received via email from the NANPA in order to remove the capability to port numbers from the returned NXX code 15 business days prior to the effective date of the disconnect. This removal will cause any new port attempts against the returned NXX code to fail at the user interface, thus avoiding additional impediments to the code return process.

2.15

It is the responsibility of the new LERG assignee or block holder to notify NECA to update the NECA Tariff FCC No. 4 database with the new OCN for the reallocated NXX code/block(s). NECA currently requires a copy of the new Part 3 form.

3.0

Notification Procedures for Returned NXX Codes/Blocks

NANPA is required to post the effective dates of pending NXX code disconnects on the NANPA website in order for SPs to be aware of approved NXX code disconnects.

LERG assignees should notify the PA if they are no longer able to perform default routing functions (e.g., the SP is no longer providing service in the area served by that NXX code).

NANPA must inform the outgoing LERG assignee of their responsibility to update the appropriate routing databases upon receipt of the Part 3.

There are specific actions related to LNP processes to be taken by SPs, the PA, and NPAC during the NXX code reallocation process. An overall description, including a required form, can be found at: (http://www.nationalpooling.com/guidelines/index.htm).³

In addition, it is the responsibility of the SP returning the NXX code/block to remove any LRN record it has associated with the returned NXX code and all ported in TNs associated with that LRN, including intra-SP ports. In addition, if the NXX is being disconnected, the NXX should be disconnected in the NPAC as well. If a block is being reallocated, the SP returning the block should not attempt to disconnect the NXX in the NPAC; it should only remove its LRN and any ported in TNs associated with that LRN, including any intra-SP ports.

If there are no active or pending ports on the NXX code, a Part 3 disconnect should be issued by NANPA to the SP. The Part 3 disconnect information shall be entered into BIRRDS by the SP’s AOCN. The NXX code should be included in the Part 3 disconnect report posted on the NANPA web site.

If there are no active or pending ports on the returned NXX code pending disconnect, the NPAC will use the Part 3 disconnect information received via email from the NANPA in order to remove the capability to port numbers from the returned NXX code 15 business days prior to the

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		- 16

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		May 4, 2005

effective date of the disconnect. This removal will cause any new port attempts against the returned NXX code to fail at the user interface, thus avoiding additional impediments to the code return process.

If porting of TNs occurs on a returned NXX code after NANPA has issued a Part 3 disconnect but prior to the 15 business days before the effective date of the disconnect, NPAC should notify NANPA that a port has occurred. NPAC also will disregard the Part 3 disconnect information and not suspend porting at 15 business day timeframe.

4.0		Returned Thousands-Blocks Containing Ported Numbers
4.1		When Block Holder is not the LERG Assignee

In a pooled area where thousands-blocks are voluntarily returned and there are ported numbers or pending ports contained in those returned blocks, the SP will return the blocks to the PA and the ported customers are not affected.

The PA shall request an ad hoc report from the NPAC to determine if there are any ported TNs or pending ports on the block(s) being returned. This information will assist the PA in reallocating the block. If the block is 10% or less contaminated the PA will process the block return. This will effectively be a contaminated block donation to the pool inventory. If the contamination level is greater than 10%, the PA will follow the order below to select a new block holder:

a)

The PA will notify SPs with ported TNs, the LERG assignee, SPs with a forecasted need, and the outgoing block holder within the applicable rate center. SPs will have ten business days to respond. The PA will provide the date and hour the responses are due. The first SP to respond with a completed and correct Part 1A and LNP NXX LERG Assignee Transfer Form will become the new block holder. MTE and utilization requirements are waived for SPs with ported TNs.

b)

If no SPs respond within ten business days or all refuse the block holder functions, the PA will contact the appropriate regulatory authority and seek guidance concerning the return or reassignment of the contaminated block. Should a new block holder be designated, regulatory authorities may waive MTE and utilization requirements.

The PA will work with the new block holder to determine if a Part 4 submission is necessary.

4.2

When Block Holder is also the LERG Assignee

The PA shall request an ad hoc report from the NPAC to determine if there are any ported TNs or pending ports on the block(s) being returned. The PA will follow the order below to select a new LERG assignee:

a)

The PA will contact SPs with blocks assigned from the affected NXX, SPs with ported TNs and SPs with a forecasted need within the applicable rate center. SPs will have ten business days to respond. The PA will provide the date and hour the responses are due.

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		- 17

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		May 4, 2005

	?		The first SP with blocks assigned from the affected NXX to respond with a Part 1 and LNP NXX LERG Assignee Transfer Form will become the new LERG assignee. MTE and utilization requirements are waived.
	?		If no SPs with blocks assigned from the affected NXX respond or all refuse the LERG assignee functions, the first SP with ported TNs to respond with a Part 1 and LNP NXX LERG Assignee Transfer Form will become the new LERG assignee. MTE and utilization requirements are waived.
	?		If no SPs with ported TNs respond or all refuse the LERG assignee functions, the first SP with a forecasted need with a Part 1 and LNP NXX LERG Assignee Transfer Form that meets the MTE and utilization requirements will become the new LERG assignee.

NPAC, upon the receipt of the LNP NXX LERG Assignee Transfer Form, will remove the LRN and all ported in TNs of the LRN (including intra-SP ports) in its database associated with the reallocated code after the effective date.

The PA will automatically update the BCD record in BIRRDS with the new LERG assignee’s information upon receipt of the Part 3 from NANPA.

The new LERG assignee shall:

§

notify the PA via email which blocks assigned to the original LERG assignee are to be reallocated to the new LERG assignee because the contamination level is over 10%. This notification will take place within 90 calendar days of receiving the Part 3 confirmation.

§

notify the PA via email which blocks assigned to the original LERG assignee are to be donated by the new LERG assignee because the contamination level is 10% or less. This notification will take place within 90 calendar days of receiving the Part 3 confirmation.

§

work with the PA to determine if any Part 4 submissions are necessary.

Blocks that were previously donated by the original LERG assignee will remain in the pool.

It is recommended that the new LERG assignee retain at least one block to ensure that responsibilities in section 4.2.1 of the Thousands-Block Number (NXX-X) Pooling Administration Guidelines (TBPAG) are maintained. However, once the responsibilities of the SP outlined in section 4.2.1 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.

b)

If no SPs respond within ten business days or all refuse to become the new LERG assignee, the PA will proceed with the NXX return, notify those SPs with ported TNs and/or pooled blocks from the affected NXX. Further, the PA will request that NANPA notify the appropriate regulatory authorities that a NXX code is going to be disconnected and that some working customers will lose service. NANPA will follow the disconnect process as outlined in Sections 4.0.f through 4.0. h of COCAG Appendix C.

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		- 18

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		May 4, 2005

5.0

Abandoned Thousands-Blocks Containing Ported Numbers

The difference between an abandoned block and a returned block is that if abandoned, the PA is unable to reach the incumbent block holder to ask it to maintain default routing functions.

5.1

When Block Holder is not the LERG Assignee

In the case when the block holder is not the LERG assignee and blocks containing ported numbers or pending ports are abandoned, the ported customers are not affected. Typically, customer complaints are the catalyst for initiating the steps that follow. The PA shall request an ad hoc report from the NPAC to determine if there are any pending or completed TN ports. The PA will contact the appropriate regulatory authority and seek guidance concerning the return or reassignment of the abandoned block. If the block contamination level is 10% or less, the block is returned to the pool once written confirmation (email or fax) is received from the regulatory authority to reclaim the block. If the block contamination level is greater than 10%, the PA will follow the order below to select a new block holder unless otherwise directed by the regulatory authority:

	a)		The PA will notify SPs with ported TNs, the LERG assignee, SPs with a forecasted need, and the outgoing block holder within the applicable rate center. SPs will have ten business days to respond. The PA will provide the date and hour the responses are due. The first SP to respond with a completed and correct Part 1A and LNP NXX LERG Assignee Transfer Form will become the new block holder. MTE and utilization requirements are waived for SPs with ported TNs.
	b)		If no SPs respond within ten business days or all refuse the block holder functions, the PA will contact the appropriate regulatory authority and seek guidance concerning the return or reassignment of the contaminated block. Should a new block holder be designated, regulatory authorities may waive MTE and utilization requirements.

The PA will work with the new block holder to determine if a Part 4 submission is necessary.

5.2

When Block Holder is also the LERG Assignee

In the case when the block holder is the LERG assignee and blocks containing ported numbers or pending ports are abandoned, the PA may not have prior knowledge of the situation. Typically, customer complaints are the catalyst for initiating the steps that follow. The PA shall work closely with the appropriate regulatory authority to obtain timely information about SPs abandoning service or filing bankruptcy. Such circumstances are under the direction of a regulatory authority or court.

The PA shall request the ad hoc report from the NPAC to determine if there are any pending or completed TN ports. This information will assist the PA in re-allocating the NXX code/blocks. The PA will follow the order below to select a new LERG assignee unless otherwise directed by the appropriate regulatory authority:

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		- 19

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		May 4, 2005

a)

The PA will contact SPs with blocks assigned from the affected NXX, SPs with ported TNs, and SPs with a forecasted need within the applicable rate center. SPs will have ten business days to respond. The PA will provide the date and hour the responses are due.

	?		The first SP with blocks assigned from the affected NXX to respond with a Part 1 and LNP NXX LERG Assignee Transfer Form will become the new LERG assignee. MTE and utilization requirements are waived.
	?		If no SPs with blocks assigned from the affected NXX respond or all refuse the LERG assignee functions, the first SP with ported TNs to respond with a Part 1 and LNP NXX LERG Assignee Transfer Form will become the new LERG assignee. MTE and utilization requirements are waived.
	?		If no SPs with ported TNs respond or all refuse the LERG assignee functions, the first SP with a forecasted need with a Part 1 and LNP NXX LERG Assignee Transfer Form that meets the MTE and utilization requirements will become the new LERG assignee.

		NPAC, upon the receipt of the LNP NXX LERG Assignee Transfer Form, will remove the LRN and all ported in TNs of the LRN (including intra-SP ports) in its database associated with the reallocated code after the effective date.
		The PA will automatically update the BCD record in BIRRDS with the new LERG assignee’s information upon receipt of the Part 3 from NANPA.
		The new LERG assignee shall:

	§		notify the PA via email which blocks assigned to the original LERG assignee are to be reallocated to the new LERG assignee because the contamination level is over 10%. This notification will take place within 90 calendar days of receiving the Part 3 confirmation.
	§		notify the PA via email which blocks assigned to the original LERG assignee are to be donated by the new LERG assignee because the contamination level is 10% or less. This notification will take place within 90 calendar days of receiving the Part 3 confirmation.
	§		work with the PA to determine if any Part 4 submissions are necessary.

		Blocks that were previously donated by the original LERG assignee will remain in the pool.
		It is recommended that the new LERG assignee retain at least one block to ensure that responsibilities in section 4.2.1 of the TBPAG are maintained. However, once the responsibilities of the SP outlined in section 4.2.1 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.
b)		If no SPs respond within ten business days or all refuse to become the new LERG assignee, the PA will proceed with the NXX return, notify those SPs with ported TNs and/or pooled blocks from the affected NXX. Further NANPA will follow the disconnect process as outlined in Section 5.0.b of COCAG Appendix C.

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		- 20

National Pooling Administration

Change Order Proposal #43

(INC Issue #475 – “Update Appendix 1: Thousands-Block

Forecast Report Directions”)

August 12, 2005

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

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		August 12, 2005

Table of Contents

				Page
1		Introduction			3
2		Industry Numbering Committee’s Proposed Change			4
3		The Proposal			6
4		Assumptions and Risks			6
5		Cost			6
6		Conclusion

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		-ii -

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		August 12, 2005

I		Introduction
1.1		Purpose and Scope

In accordance with NeuStar’s National Pooling Administration contracts¹ 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 Attachment B, Section C of the Thousands-Block Pooling Contractor Technical Requirements, dated November 30, 2000, Sections 2.5 through 2.5.4, which read as follows:

		2.5 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. The contractor is additionally subject to the provisions of the changes clause in Section I.
		2.5.1 Process
		Accordingly, after a contractor is selected, the FCC, the NANC and/or the INC may establish NANP numbering resource plans, administrative directives, assignment guidelines (including modifications to existing assignment guidelines), and procedures that may have an effect on the functions performed by the contractor.
		2.5.2 Changes
		The contractor shall review changes when numbering resource plans, administrative directives, assignment guidelines, and procedures are initiated or modified to determine if there is any impact on the functions that they must perform.
		2.5.3 Notifications
		The contractor shall then, within a period of not more than 30 calendar days from said event (e.g., the date INC places an issue into Final Closure), provide the Contracting Officer, state PUCs, and the NANC with written notice regarding these changes and summarize the potential impact of the changes upon service and cost, if any.
		2.5.4 Roles
		The NANC shall review the notice and provide a recommendation to the FCC regarding the effect of the contractor’s notice and supporting documentation.
		The contractor shall comply with state regulatory decisions, rules and orders with respect to pooling, as applicable, as long as they are not in conflict with FCC decisions, orders, and rules and are within state jurisdiction.

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		-3 -

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		August 12, 2005

This document provides the information required by the contract, such as identifying the new requirements of the expanded scope of work, offering our proposed solution, and addressing its cost, risks, and assumptions as a result of the Industry Numbering Committee’s (INC) disposition of Issue 475.

2 Industry Numbering Committee’s Proposed Change

On July 15, 2005, INC placed Issue 475 into Final Closure. As a result of this resolution of INC Issue 475, the directions on the INC Appendix 1: Thousands-Block Forecast Report form were modified. Therefore, PAS will need to be updated to reflect the modified directions.

INC Issue 475 Update Appendix 1: Thousands-Block Forecast Report Directions

Quoted below are the INC official issue statement and final resolution, which can also be found on the ATIS website (http://www.atis.org):

A)

Issue Statement

		The directions on the Thousands-Block Number Pooling Administration Guidelines (TBPAG) Thousands-Block Forecast Report (Appendix 1), dated 6/3/02, states:
		“If any of the forecasted demand above includes the need for a new NXX due to a LRN, please indicate in the space provided below how many LRNs and specify the month that the new NXX will be placed in service.”
		This sentence needs to be amended to remove the step where the applicant would specify the month that the new NXX(s) will be placed in service since there is no field on the Appendix 1 to input that data into. The applicant only has a field to indicate how many new NXX(s) are needed due to a LRN.

B)

Following Resolution from INC

The following text changes were made to the Thousands-Block Number Pooling Administration Guidelines (TBPAG) Appendix 1:

[tbd]		Thousands-Block Forecast Report		Appendix 1
Company
Name
OCN
Contact
Contact TN
Fax#
E-mail
Date
Submitted

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		-4 -

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		August 12, 2005

				Month		Month		Month		Month		Month		Month		Month		Month		Month		Month		Month		Month
Rate Area		NPA(s)		1		2		3		4		5		6		7		8		9		10		11		12

		Directions:
		Please provide the forecasted number of thousands blocks in each Rate Area that your company expects to take from the pool each month for the next 12 months
		Only the total quantity of thousands blocks that are forecasted should be entered. Do not include in the forecast the thousands blocks or full NXXs that are already in your inventory. If full NXX(s) is/are forecasted, please reflect this in thousands blocks, e.g., a full NXX = 10 thousands blocks.
		If any of the forecasted demand above includes the need for a new NXX due to a LRN, please indicate in the space provided below, e.g. a new NXX due to a LRN = 1.

		Month		Month		Month		Month		Month		Month		Month		Month		Month		Month		Month		Month
NXX(s) Month		1		2		3		4		5		6		7		8		9		10		11		12

If further assistance is required, please contact the PA on ###-###-####.

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		-5 -

Nat’l PAS — Change Order #39 (LNPA WG PIM 24 and CO/NXX 364)		August 12, 2005

3 The Proposal

NeuStar’s National Pooling Administrator has reviewed INC Issue 475 from both the operational and technical perspectives. The proposal set forth below will conform to the changes in the INC guidelines and meet the requirements of the industry in a cost-effective and efficient manner.

Solution

Modify the existing text under the “Directions” section of the Thousands-Block Forecast Report screen in PAS to conform to the new directions as altered by INC Issue 475.

4 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.

There are no associated assumptions.

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

5 Cost

As with any change order proposal, we also considered the associated costs that would potentially be incurred in implementing the proposed solution. These costs include the resources required to complete the milestones on a timeline for implementing the processes and system delineated in this change order. The timeline includes preparation, proper documentation updates, development, testing, monitoring, and execution of the solution.

The cost to implement our proposed solution would be $605.00

6 Conclusion

In conclusion, the Pooling Administrator offers this viable solution to conform the PAS to INC Issue 475, and in accordance with contract terms, requests that the FCC review and approve this change order.

© NeuStar, Inc. 2005		NeuStar Proprietary and Confidential		-6 -

AMENDMENT OF SOLICITATION/MODIFICATION OF CONTRACT			1. CONTRACT ID CODE			PAGE OF PAGES
			A			1          |           3

2. AMENDMENT/MODIFICATION NO.			3. EFFECTIVE DATE			4. REQUISITION/PURCHASE REQ. NO.			5. PROJECT NO. (If applicable)
0017			05/24/2006

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.								9B. DATED (SEE ITEM 11)
46000 Center Oak Plaza					(X)			10A. MODIFICATION OF CONTRACT/ORDER NO. CON01000016
Sterling, VA 20166					(X)			10B. DATED (SEE ITEM 13)
CODE		FACILITY CODE
11. THIS ITEM ONLY APPLIES TO AMENDMENTS OF SOLICITATIONS

[    ] The above numbered solicitation is amended as set forth in Item 14. The hour and date specified for receipt of Offers [     ] is extended, [     ] 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 ACKNOWLEDGEMENT 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 APPLIES ONLY TO MODIFICATIONS OF CONTRACTS/ORDERS,
IT MODIFIES THE CONTRACT/ORDER NO. AS DESCRIBED IN ITEM 14.
					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).
					C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF: Mutual Agreement of the Parties
X					D. OTHER (Specify type of modification and authority) FAR 1.6 “Authority of the Contracting Officer”
E.		IMPORTANT: Contractor [X] is not, [     ] is required to sign this document and return 3     copies to the issuing office.
14.		DESCRIPTION OF AMENDMENT/MODIFICATION (Organized by UCF section headings, including solicitation/contract subject matter where feasible.)
		This modification revises the associated cost for Change order #41 to $6,209.00 in lieu of $0.

15A. NAME AND TITLE OF SIGNER (Type or print)				16A. NAME AND TITLE OF CONTRACTING OFFICER (Type or print)
				Wilma Mooney
15B. CONTRACTOR/OFFEROR		15C. DATE SIGNED		16B. UNITED STATES OF AMERICA		16C. DATE SIGNED
				BY		05/24/2006
(Signature of person authorized to sign)				(Signature of Contracting Officer)

NSN 7540-01-152-8070                                                                                   30-105		STANDARD FORM 30 (Rev. 10-83)
PREVIOUS EDITION UNUSABLE		Prescribed by GSA
		FAR (48 CFR) 53.243

LINE ITEM

Document Number

Title

Page

SUMMARY

CON01000016/0017

Pooling Administrator   –  Neustar

2 of 3

Line Item

Delivery Date

Unit of

Number

Description

(Start date to End date)

Quantity

Issue

Unit Price

Total Cost

No Changed Line Item Fields

Previous Total:

Modification Total:

Grand Total: