Industry Voices—Lowenstein’s View: The number portability database migrates in April: Is the industry ready?

Mark Lowenstein Industry Voices

With all the pre-MWC talk about 5G and IoT, I’m going to raise a topic that few of us have probably thought about in years: number portability. You might be yawning already. But it’s worth reading on.

In 1997, in response to a provision in the 1996 Telecom Act, number portability was introduced. Although we take this for granted today, allowing subscribers to keep their number when switching service providers ushered in a new era of competition in telecom and wireless. Neustar was awarded the contract to administer the database, called the Number Portability Administration Center (NPAC), which also performs the important function of making sure calls and texts are routed to the correct number, as well as assigning numbers to the operators (some 100,000 per day). When a number ports or a new number is assigned, it is propagated across all the databases (sort of like a DNS propagation when you change hosting providers).

That contract came up for review in 2010 and was awarded to iconectiv (formerly Telcordia, now 80% owned by Ericsson) in 2014. A final agreement was signed in August 2016, providing a relatively tight timeframe to implement what is a large systems project. Since then, the companies have been in this delicate dance of arranging for the creation of the new NPAC and the transfer of the data. The project is overseen by the Transition Oversight Manager, being run by PWC. The North American Portability Management is populated by operators and provides monthly reports to the FCC. The cutover is scheduled to begin on April 8, in the southeast region (the largest and most complex), followed by the six other regions over the next six weeks.

So, why am I writing about this? Three reasons. First, as one of the most significant IT projects in the telecom industry’s history, involving some 12 billion data elements (akin to two airlines putting their IT systems together when they merge), this is something that deserves our attention. The NPAC handles some 1.8 million transactions per day. If the transfer runs into problems, there could be substantial consumer disruption, in that new ports would not be completed and there might be some difficulty terminating calls/texts. This would undoubtedly result in a raft of calls to customer care and could result in a slowdown in new customer activations. A data failure during the NPAC transition could also affect priority service programs for public safety agencies. 

Second, several key actors in the process, including some operators, have contacted me (on background), expressing concern that the process is not on track to meet the April deadline. Some say that an inadequate amount of testing has been performed. A consultant with deep experience in mega IT projects testified to the FCC in August 2015, expressing concern at the compressed timeframe for a project of this magnitude and suggesting that a larger number of tests be conducted.

Third, there is no provision for a “rollback” to the existing NPAC if for some reason there are issues with the cutover. The current provision is for a “manual” rollback (think paper-based) if the new system fails. There’s been a call for an “automated” rollback and although agreed to be the preferred approach, the main parties have been unable to find common ground on this. Concerns over this lack of a rollback option, as well as some other issues related to the transition, have reached the desk of FCC Chairman Ajit Pai, who asked the principals to provide a status report to him by Feb. 16. As of the time of this writing, it is not clear what the outcome is. The time needed to develop and test an automated rollback process would probably cause a delay in the transition.

I’ve spoken with the main actors on this issue, and even attended a panel session on the topic at the NARUC meeting last Monday in Washington, D.C. It is a bit of a challenge to get a definitive view of the status. Iconectiv insists that they “are on track and prepared,” and are conducting the requisite amount of testing. Neustar—clearly unhappy at having lost the contract—is not nearly as confident. With a project of this magnitude, there are bound to be some failures. The company believes that the cutover should be delayed until a suitable rollback plan has been developed. I’ve gotten mixed signals from the operators (about 2000 of whom are impacted by this issue). Several operator working teams I spoke to are worried, although there haven’t been any alarm bells sounded at the executive level yet. At the NARUC meeting, Charter expressed concern, while an AT&T representative said that iconectiv appears to be “on track.” My sense is that smaller operators would be more impacted if there are issues with the cutover, since the larger operators could more easily throw some resources at plugging holes that might arise during the transition.

There is a larger issue to raise here, which is that the new NPAC is basically a replication of the old. This means we are relying on the legacy PSTN (when’s the last time you read that acronym?) and TDM routing, rather than moving to an IP-based system that would take into account new trends in software, cloud services, network virtualization, rich communications services (RCS), OTT, and the participation of Web folks such as Google and Facebook in telecom. A newer system would also be able to more effectively address issues such as spoofing and robocalling, and would be less reliant on the now-antiquated geographic orientation (LATA, anyone?) of how numbers are assigned.

To be fair, a replication of the existing system is what the FCC asked for. But the world has changed a lot since the original NPAC contract came up for review. If we were starting this process now, we’d be thinking quite differently about what an NPAC for the 2020s might look like. I’ll write in more detail about this in a future column.  

Mark Lowenstein, a leading industry analyst, consultant, and commentator, is managing director of Mobile Ecosystem. Click here to subscribe to his free Lens on Wireless monthly newsletter, or follow him on Twitter at @marklowenstein.