North American Numbering Council
Numbering Oversight Working Group
November 28, 2012
Honorable Betty Ann Kane
NANC Chairman
1333 H Street, N.W., West Tower 7th Floor
Washington, DC  20005
RE: NOWG Proposal for a Consolidated Numbering Administrator Contract - for NANC 
Distribution
Dear Madam Chair,
During recent NANC meetings, the Numbering Oversight Working Group (NOWG) obtained the 
NANC’s approval to conduct an evaluation of the benefits and risks of consolidating the 
contracts of the North American Numbering Plan Administrator (NANPA) and the Pooling 
Administrator (PA).  The NOWG proposed this idea to the NANC because our role as the 
oversight committee for the NANPA and the PA puts the NOWG in a unique position to observe 
redundancies that we believed could possibly be eliminated by combining the two contracts into 
one.  Our interest in conducting this exercise was not due to any dissatisfaction with the 
performance of the current administrators, but was motivated by the desire to explore efficiencies 
that may be gained by one unified contract.
Additionally, as shown below, the FCC’s Numbering Resource Optimization Order (CC Docket 
No. 99-200) which established Pooling Administration in 2000, recognized that there may be a 
benefit to looking at this issue in the future.
In FCC 00-104, paragraph 152, the FCC stated:
152. We acknowledge that it may be desirable in the future to link the thousands-block 
number pooling administration and central office code administration duties to take 
advantage of any synergies that may exist between these functions.
The NOWG held several sessions to discuss consolidation of the NANPA and PA administrator 
contracts.  The NOWG’s activity focused on identifying potential Service Provider and 
Regulator operational efficiencies and impacts in consolidating the contracts.  We also looked at 
the idea of combining the numbering guidelines, and discussed the benefits and risks associated 
with having a single user interface for the numbering systems (PAS/NAS).  Since we did not 
have access to cost data that would need to be provided by current and potential vendors bidding
for the Numbering Administrator contract, the NOWG worked under the assumption that over a 
contract period, the industry would realize a cost savings based on a single contract versus the 
two separate contracts.
The details of the NOWG’s operational analysis are contained in the attached document.  As a 
result of our analysis, the NOWG reached consensus on the following recommendation:
The NOWG recommends that the FCC consider consolidating the NANPA and PA 
Administrator contracts.  For the FCC’s consideration, the NOWG provides the 
attached input which documents some of the benefits and risks of a contract 
consolidation.
The NOWG requests that the NANC endorse the above recommendation for submission to the 
FCC.
Please feel free to contact any one of the NOWG co-chairs if you have any questions or require 
additional information.
Thank you,
Ms. Laura Dalton Ms. Natalie McNamer
Verizon Communications T-Mobile USA
914-741-7018 630-290-0021
mailto:laura.r.dalton@verizon.com natalie.mcnamer@t-
mobile.commailto:
Ms. Karen Riepenkroger
Sprint Nextel
913-253-5373
karen.s.riepenkroger@sprint.com
Numbering Oversight Working Group (NOWG):
Evaluation of Benefits and Risks of Consolidation of the NANPA and PA 
Administrator Contracts
Benefits:
? One Administrator to oversee the supply and distribution of the numbering resources 
of the North American Numbering Plan (NANP)
? Unify contracts to attain synergies in having a single contract, single bid process, 
and a single vendor
o No need for separate change orders when PA and NANPA systems are both 
affected, thus producing a single timeline for changes
o Conservation of resources in the industry (potential vendors) by having to 
respond to one RFP rather than two
o Larger scope of the combined contract may be more attractive to potential 
vendors than two separate contracts, potentially incenting more vendors to 
compete for the contract
? Operational efficiencies (reduced redundancy of certain functions)
o Reduction of processing days from 14 to 7 when opening new codes and 
modifying and disconnecting existing codes in pooling areas by allowing 
parallel processing of both PA and NANPA functions
o Single user interface would eliminate the need for pooling pass through 
requests between NAS and PAS, and separate passwords for each system
o One system to submit NRUFs and PA forecasts
o Single website for service providers and regulators to obtain reports and other 
information about numbering resources without duplication of information
o Training for new SP employees on one system for number administration
o Efficiencies for carriers and regulators in having one Numbering Administrator 
as a single point of contact for numbering questions and issue resolution
? Combine rules for the NANPA and the PA 
o The FCC may want to revisit the CFR sections that apply to both the NANPA 
and PA to determine if those need to be combined
? Simplified ongoing guideline updates due to unified INC guidelines (Consolidated 
COCAG and TBPAG)
Risks:
? Unknown changes to the structure of the vendor(s) organization and potential 
resulting impacts on Regulators and Service Providers
? Need for development of a single user interface (combining NAS/PAS into one 
system)
o upfront costs of developing a single NAS/PAS system 
o training of vendor staff to support single system
o combining the NANPA and PA websites into one website
o changes to SP internal back office systems that interface with PAS/NAS and 
retraining of SP staff
o some SP’s do not participate in pooling and do not access PAS today, so to 
combine the two systems may confuse those SP staffs
? Required FCC contracting changes
? Industry resources necessary to consolidate INC guidelines (COCAG and TBPAG) 
to coincide with the contract consolidation
Definitions of Acronyms:
NANP – North American Numbering Plan
PA - Pooling Administration
NANPA – North American Numbering Plan Administration
RFP – Request for Proposal
NAS – NANP Administration System
PAS – Pooling Administration System
NRUF - Numbering Resource Utilization/Forecast
SP – Service Provider
CFR – Code of Federal Regulations
INC – ATIS Industry Numbering Committee
COCAG – Central Office Code (NXX) Assignment Guidelines
TBPAG – Thousands-Block Number (NXX-X) Pooling Administration Guidelines
FCC – Federal Communications Commission