National Pooling Administration Contract #FCC13C nd Revised Change Order Proposal #3B

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National Pooling Administration Contract #FCC13C0007 2 nd Revised Change Order Proposal #3B (Development and Support of the PAS NPAC API) March 8, 2017 Neustar, Inc. 21575 Ridgetop Circle Sterling VA, 20166

Table of Contents 1 Background... 3 2 Functional Changes... 4 EXTERNALLY AVAILABLE API... 5 GUI ACCESS... 6 PAS DATABASE UPDATES FOR MIGRATION WINDOW... 7 3 Documentation and Training... 7 NPAC USER GUIDE... 7 NPAC USER GUI TRAINING... 7 4 Testing and Testing Support... 7 API CERTIFICATION TEST CASES & TESTING... 8 FUNCTIONAL TESTING... 8 4.2.1 Acceptance Testing... 8 4.2.2 Operational Readiness Testing... 8 CONNECTIVITY & DRY RUN TESTING... 9 5 Production... 9 ENHANCED API DEPLOYED TO PAS PRODUCTION... 9 REGIONAL MIGRATION ACTIVITIES AND SUPPORT... 9 6 Assumptions... 9 7 Timeline and Costs... 10 Neustar, Inc. 2017 - ii -

1 Background In accordance with the terms of Neustar s National Pooling Administration contract, 1 Neustar as the National Pooling Administrator (PA) hereby submits this change order proposal to the FCC for approval. On March 7, 2016, the PA submitted to the FCC and the Numbering Oversight Working Group (NOWG) 2 a change order proposal (Change Order #3) to enable the new Local Number Portability Administrator (LNPA), iconectiv, to access work items assigned by the Pooling Administration System (PAS) through an application programming interface (API) similar to the API used by Neustar in its LNPA capacity. That change order proposal responded to an email request from the North American Portability Management (NAPM) LLC, and addressed development of the API, modifications to PAS to accommodate interaction with two vendors during transition, and the testing and subsequent support Neustar deemed critical to ensure a seamless transition of LNPA responsibilities from Neustar to iconectiv. The Transition Oversight Manager (TOM) subsequently requested that Neustar divide Change Order proposal #3 into multiple parts to accelerate delivering the API specification document. On June 22, 2016, in response to the TOM s request, Neustar submitted Change Order proposal #3A, which addressed the review and delivery of specifications for the API. Those specifications, which tell iconectiv how to access the PAS during and after the LNPA transition, are a pre requisite to enhancing the security, flexibility, and expanded data transmission requirements needed to accommodate multiple vendor access to the PAS. The FCC approved Change Order #3A, and Neustar delivered the API spec on September 30, 2016. On October 19, 2016, Neustar submitted Change Order proposal 3B, which addressed: (1) development of the PAS API interface to allow iconectiv secure access to PAS over the Internet, (2) enhancement of the PAS GUI to enable both NPAC vendors to access PAS during the transition by region, (3) integrated performance testing, regional cutover testing, and/ or regional fallback testing with iconectiv, and (4) support through the NPAC regional migrations. On November 4, the NOWG reported to the FCC as follows: 1 FCC Contract for Pooling Administration Services, Contract No. FCC13C0007, dated July 12, 2013 (the Pooling Contract). 2 The NOWG is the FCC s designee for oversight over the numbering administrators operating under FCC contracts, including the PA. Neustar, Inc. 2017-3 -

The NOWG cannot recommend approval of the Change Order as written. However, the NOWG recognizes that the lack of approval of this Change Order may impact the NPAC transition timeline. Thus, because the NOWG is not privy to the detailed costs, the NOWG recommends that the FCC work with the PA to significantly reduce the costs associated with Change Order #3B. In an effort to reduce those costs, Neustar reviewed its approach to the transition, and reexamined its security concerns with respect to the PAS GUI. The revised Change Order proposal #3B addressed: (1) development of the PAS API interface to allow iconectiv secure access to PAS over the Internet, (2) integrated performance testing, (3) regional cutover development and testing, (4) GUI training, and (5) support through the NPAC regional migrations. The omission of the enhancements to the PAS GUI will allow more access to proprietary information on the part of both vendors, but decreased the development costs associated with the change order proposal. The FCC and the TOM requested further modifications, addressed in this document, which offers an initial webex to introduce iconectiv to the GUI, and delivery of two iterations of the API. We respectfully request that the FCC review and approve this change order proposal. 2 Functional Changes To provide the necessary connectivity and access to iconectiv, Neustar will need to enhance the API consistent with the Change Order #3A deliverable, to provide more security, flexibility, and resiliency for greater processing ability. In addition, certain changes will be made to the PAS database related to the actual cutover migration windows. The development, testing, and implementation timeline for releasing these deliverables to production is as follows: Neustar, Inc. 2017-4 -

CO Approved Design & Documentation Development Neustar Regression Testing Deployments Development Cycle complete Infrastructure & Software architecture 20 days Initial code drop by end of July API / Migration coding 150 days 20 days Deliver Final version in CTE to iconectiv by 11/24/2017 Deliver API to PAS prod TBD Neustar will deliver a GUI only Customer Test Environment (CTE) for iconectiv in conjunction with the GUI training, no later than May 26, 2017. Neustar will deliver API functionality in multiple iterations as described in Section 2.1. Neustar will perform all the necessary testing to confirm that functional, security, and stability requirements are thoroughly addressed and documented. The timeline is based on the assumption that this Change Order is approved by March 13, 2017. There would be a day for day slip in the timeline if the proposal is approved after that date. Externally Available API Neustar will implement new code to allow the PAS API to be accessed over the Internet, restricted to the NPAC vendor s IP address ranges, using HTTPS. Thereafter, the PAS API load balancer will be provisioned to accept traffic from the approved IP ranges. The API will be delivered in two phases: (1) an initial noncertified release will include the WSDL changes, security enhancements, and access to one region s data, to be available in the CTE no later than July 31, 2017; and (2) the final API release, which will include improved exception handling, improved attribute validation, SOAP message logging and nonsequential processing, will be delivered no later than November 24, 2017. As development, testing, and collaboration between IC and Neustar proceed, there may be additional point releases prior to the final, certified API release scheduled for November 24, 2017. Any support efforts required from the initial July 31 API release through the end of development on November 24 will be capped at 15 hours per week. Neustar will enhance the API as follows: Neustar, Inc. 2017-5 -

The new API will permit parallel processing, which will replace the current sequential processing pattern. Parallel processing will be necessary during transition for efficient and flexible processing of data being transmitted between the PAS and the two NPACs. Multiple NPAC regions will be able to access PAS over the API concurrently, although only one connection per region will be permitted at a time. The enhanced API will be configured to limit the NPAC requests and data update work items to a size that will not interfere with the PAS performance, to assure the continued stability of the PAS. The API servers will be architected to provide High Availability (HA) in production. The enhanced API will also support additional exception handling and data validation to accommodate external access, and enhanced error responses for failure scenarios. GUI Access During migration, Neustar will disable the screens for the NPAC User Manager functions and develop processes so that the Pooling Administration support team will act as the NPAC Manager for the limited purpose of managing NPAC user profiles. As Neustar has operated, the NPAC Manager User is an employee of the NPAC who is authorized to use the system to view Part 3, Part 1B, and Part 5 information and process Part 1B and Part 5 work items. The NPAC Manager User is able to update NPAC User profiles and assign/reassign states to the NPAC Users that he or she manages. In addition, any work item that cannot be assigned to a particular NPAC User due to a disabled user account, is escalated to the NPAC Manager User for that user. The NPAC Manager User account is created by the Login Administrator at the direction of the PA Sr. Director or the Regional Director, PASC. GUI functionality will change in the following ways during the entire migration window: Neustar will temporarily remove the management screens for the NPAC manager, disabling the ability to manage the regions and users during the transition phase, and reinstating it after transition. Work item assignments and updates will be assigned to the appropriate vendor. All reports for all regions, including the Ported TN reports, will be sent to both vendors. During transition, the Neustar Pooling Administration support team will perform the required NPAC user management tasks based on requests from the respective NPAC vendors. Neustar will develop scripts to support any user management requests for NPAC during the transition. Neustar will also develop code and procedures necessary to transfer work items from the Neustar NPAC to iconectiv during the regional migration maintenance window itself. Neustar, Inc. 2017-6 -

PAS Database Updates for Migration Window Neustar will develop and test scripts that update each region s data with the new NPAC vendor s user credentials as each NPAC region is cut over, and will develop scripts and code for transferring the work items to the appropriate vendor during regional cutovers. 3 Documentation and Training NPAC User Guide Neustar will develop an NPAC User Guide to assist iconectiv in understanding how to access necessary screens through the GUI to achieve desired outcomes. This user guide will be comparable to those presently available for service provider and regulator access to PAS. The NPAC User Guide will be delivered to iconectiv no later than April 28, 2017. NPAC User GUI Training No later than March 31, 2017, Neustar PA will provide a webex training session to iconectiv personnel to acquaint them with how to manually access PAS through the GUI. No later than May 26, 2017, Neustar PA will provide training to iconectiv personnel on how the PAS GUI is configured and the actions that iconectiv NPAC personnel would need to perform. The training will be conducted virtually. The number of sessions is yet to be determined. 4 Testing and Testing Support Post Final API release The information and timeline that the TOM provided to Neustar advise that Neustar PA is responsible for the following types of testing with iconectiv: API certification testing, Functional testing, o Acceptance testing, o Operational readiness testing, Final connectivity testing, and Dry run testing. The testing portion of the timeline begins upon delivery of the CTE and concludes with the final regional migration, with the understanding that the version of the API to be delivered July 31 will not have been subjected to the rigorous testing that will accompany the November delivery. Neustar, Inc. 2017-7 -

API Certification Test Cases & Testing The CTE that mirrors production architecture will be made available in three phases: (1) The GUI only CTE will be made available when GUI training is conducted. (2) The initial API functionality will be delivered in July 2017. (3) The final API release in November will be the version that is subject to API Certification testing. API certification testing is not yet scheduled; it will be based on the execution plan provided by iconectiv and the TOM. Neustar will provide the API certification test cases on or before June 02, 2017. The test cases will cover: Block creates / modifies / transfers / deletes, Work items, forms, and reports, and Work items and forms with post migration effective dates. Neustar is responsible for setting up the test data, and will support test planning with iconectiv, provide dedicated support for and during the execution of the test cases, and assist with root cause analysis for any failed test cases. Neustar will support any additional testing cycles iconectiv requests during the API certification test period. Functional Testing Functional testing will validate the interface interactions and allow iconectiv to confirm its workflow processes. Acceptance testing and operational readiness testing are included in this testing phase. Either the TOM or iconectiv will provide the test cases. 4.2.1 Acceptance Testing The test cases provided by the TOM or iconectiv will validate functional operation of iconectiv NPAC and the PAS API. Neustar will set up the test data, work with iconectiv on test planning, and provide dedicated support during the execution of the test cases, including analysis of test results and any root cause analysis required for failed test scenarios. 4.2.2 Operational Readiness Testing The TOM or iconectiv and will provide test cases to validate iconectiv s pooling Methods & Procedures. Situational test cases written by iconectiv or the TOM will be included in these test cases. Neustar, Inc. 2017-8 -

Neustar will set up test data and provide support for the execution of those test cases, analysis of the test results and provide assistance in determining any failed scenarios. Connectivity and Dry Run Testing Connectivity testing prior to commencing any regional migration will allow iconectiv to validate that its production networks can reach the PAS production API end points. To facilitate dry run regional cutover testing, Neustar will update the CTE with production like data and perform the steps required for a regional cutover. 5 Production Enhanced API deployed to PAS production Neustar will deploy the new API to production for use with the existing, incumbent NPAC; this will take place prior to the date required for the NPAC transition and use by iconectiv. The date for production deployment will be published, as the project schedule is refined. Regional Migration activities and support Further discussion and agreement are needed regarding the activities surrounding regional migrations, including the order of migration, the duration of the migration window, and potential rollback. For each of the regional migrations the following activities will take place: Once migration of the region to iconectiv is complete, Neustar PAS will update that region s records with iconectiv NPAC user data. This will be done during the regional migration window. Neustar and iconectiv will validate that the appropriate regional data is being successfully accessed, transferred, and retrieved across the API and GUI interfaces. 6 Assumptions 1. The current pooling contract end date is July 14, 2017. In the event that Neustar ceases to be the pooling administrator at any time during the performance of this CO, the FCC agrees to compensate Neustar for expenses incurred under this CO. 2. Any changes to the actual migration dates (currently scheduled to complete in May 2018) will require Neustar PA to re evaluate the timeline and costs provided in this document. Any substantial impacts will be addressed in a subsequent change order proposal. Neustar, Inc. 2017-9 -

3. This change order does not include development or support for API changes that may be requested by iconectiv after review and testing. 4. iconectiv will perform end to end testing prior to go live, to assure that the migration will not cause any downtime to PAS. If any iconectiv action causes downtime to PAS, that time will not be counted against PAS SLAs. 5. This change order does not cover rollback testing. 6. The PA and the iconectiv NPAC will continue to exchange the existing manual and system to system data reports at no cost to either party. Any new reporting requirements not currently identified will be the subject of separate change order. 7. The iconectiv NPAC will provide the PA the same information in the same form that the current NPAC vendor provides today, such as updates to the Part 1B and Part 5 forms, and ported TN information. 8. Neustar Pooling will retain its SPID and capacity to access the NPAC as a user. 9. The PA will send one weekly disconnect report to each NPAC vendor. 10. Each state can be assigned to only one NPAC User id. 11. To comply with the request that costs be lowered, Neustar has deleted changes to the PAS that would have protected access to carrier data during transition by the entity not operating in a specific NPAC region. Thus both NPACs will have read only access to PAS all Part 1Bs, Part 3s, Part 5s, and NPAC related reports and forms for all regions during transition, but will be able to update only the work items for regions each is the administrator for at that time. Neustar, therefore, cannot assure the confidentiality of any information in those forms or reports during transition. To the extent that this situation compromises any neutrality or confidentiality requirements, the FCC s approval of this change order proposal waives such requirements to the extent of this visibility. 12. The email reports generated by PAS for the NPAC vendor contains data for all the regions. The same reports will now be sent to both vendors. Any email confirmation emails sent now by PAS to the NPAC vendor will be sent to both the vendors. 13. Both the Neustar and the iconectiv NPACs will process all assigned work items in a timely manner. Any corruption of PAS data experienced as a result of the transition will require an additional change order to perform the necessary clean up activities. 7 Timeline and Costs In developing this proposal, Neustar has considered the costs associated with its implementation of the proposed solution, including the Neustar resources required to complete discrete milestones on the timeline for implementation. The timeline includes Neustar s preparation, development, testing, proper documentation updates, monitoring, and execution of the solution. Neustar, Inc. 2017-10 -

Key Deliverables & Timelines: 03/13/2017 November 2017 Design and development 03/31/2017 GUI webex walkthrough 04/28/2017 NPAC User Guide 05/19/2017 GUI training conducted 05/19/2017 Deliver GUI CTE access for iconectiv 06/02/2017 Deliver API test cases for certification 07/31/2017 Deliver uncertified API CTE access 11/24/2017 Deliver final API CTE access 11/24/2017 12/27/2017(est.) PA support for certification testing 12/28/2017 02/19/2018(est.) PA support for functional testing 02/20/2018 06/29/2018(est.) PA support for pre migration and migration efforts 1. The cost for the following deliverables, as described in this document, will be: An enhanced API, an NPAC User Guide, API test cases, and iconectiv NPAC user training. 2. Neustar will provide no more than 15 hours per week of technical support related to the initial API release from July 31 through the end of development. That technical support will be. 3. The post final API delivery support phase includes supporting all iconectiv TBP testing and NPAC regional migrations through completion. Support will be provided from November 2017 through June 30, 2018. This post final API delivery support includes 80 hours per month of dedicated technical support, 1 resource to augment the Pooling Administrator for the duration of the transition, and any necessary support from the Application Support team, Project Managers, and management. Also included are the costs for running the CTE and licenses required for our infrastructure. The fixed monthly support fee is. In the event that more than 80 hours of technical support are required in a calendar month, the additional support will be. Neustar, Inc. 2017-11 -