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PleadingHeader for numbered pleading paperPP@n   $] X X` hp x (#%'0*,.8135@8:8HH"&H>XHH8HB8>HH^HH>"".2",2,2,"222N2222"&22H22,006"6."""""""""""2H,H,H,H,H,XAB,>,>,>,>,""""H2H2H2H2H2H2H2H2H2H2H,H2H1H2H2H282H,H,H,B,B,B6B,H?>,>,>,>,H2H2H2H6H2H6H2""2"""2F866H2>>(>">">H2;H2H2H2H2XHB"B"B"8&8&8&86>*>>.H2H2H2H2H2H2^HH6>,>,>,H2>"H28&>"H2?22!!/FFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFN$<<$.2",2222`2 LL2 LL2L"",,2d""\4  pG;26ZڐZ'<?xxx,x6X@`7X@`y.X80,ɒX\  P6G;Pa7jC:,ynXj\  P6G;XPb7nC:,W*f9 xr G;X2KhKK\I"i~'^"(22TN"""28"2222222222888,\HBBH>8HH"&H>XHH8HB8>HH^HH>"".2",2,2,"222N2222"&22H22,006"6."""""""""2"2H,H,H,H,H,XAB,>,>,>,>,""""H2H2H2H2H2H2H2H2H2H2H,H2H1H2H2H282H,H,H,B,B,B6B,H?>,>,>,>,H2H2H2H6H2H6H2""2"""2F866H2>>(>">">H2;H2H2H2H2XHB"B"B"8&8&8&86>*>>.H2H2H2H2H2H2^HH6>,>,>,H2>"H28&>"H2?22!!WFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFFxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxN$<<$.2",2222`2 LL2 LL2L"",,2d"" yO1',ЍGTEC Petition at 1, 45.S " 6>,**c"Ԍ X,   The Testing and TurnUp ProcessĐm  X,30. The following is a brief summary of the testing and deploying LNP process as  X,described by Lockheed Martin in its capacity as an NPAC services supplier.^? {O4,ЍSee Lockheed Martin Letter. ^ There is a single NPAC/SMS for each of the regions served. The NPAC is connected to specific systems with participating carriers over a standardized interface. The systems involved are the Local Service Management System (LSMS) and Service Order Administration (SOA) system. The LSMS/SOA systems in a carrier are typically part of an Operation[s] Support System (OSS) network, which provides support services for network elements such as switches and  X1,LNP Service Control Points (SCPs).N@1Z {O< ,ЍId. at 23. N  X ,31. Testing the NPAC by the Administrator Lockheed, as the NPAC administrator indicates that its NPAC system is thoroughly tested for each new release of the NANC's specified "Interoperable Interface Specification" (IIS). Once Lockheed is satisfied with its internal testing of a new release, that release is then subjected to external "regression" testing by the carriers and by Lockheed to ensure that errors have not been introduced in the new releases. Regression testing, which attempts to forecast future events by analyzing past events, may identify problem areas in the implementation of LNP, thereby allowing the carrier to minimize the probability that technical problems will affect the reliability of the network. Once regional NPAC turnup testing is completed in a region, Lockheed designates the NPAC live or operational for that region. In a live NPAC, the LNP database for that region is subject to NPAC LNP business processes and standard methods and practices, so that when the system is activated, commercial porting may begin.  X,32. Carrier Certification Before porting takes place, each participating carrier must be certified. Certification means that each carrier's system has been thoroughly tested and verified so that end to end interoperation of LNP may take place. The extensions of the prescribed implementation dates established by the Commission are being sought by the petitioners because each carrier is required to test and receive certification on the Lockheed NPAC instead of the Perot system. According to Lockheed, LNP certification testing is accomplished in three distinct phases.  X ,X(a) Interoperability testing First, the carrier's individual components are tested and verified in isolation. This is commonly referred to as "Interoperability Testing" and is essentially a testing of interoperability of the Lockheed and carrier's platforms. Here each carrier or system developer tests its SOA and LSMS software for compatibly with the NPAC interface. The current Lockheed IIS is currently at release level 1.8 whereas when Perot discontinued its activities it was still testing release 1.1. Once a carrier's or developer's LSMS/SOA product has been certified, it does not need to be retested as it is deployed in the network, unless the carrier's or developer's software is revised as a new release. In that case it must be recertified. Lockheed indicates that it takes an average of eight weeks to complete this phase of testing.(#"Q% @,**~#"Ԍ X,ԙX(b) TurnUp Testing The second phase of certification is termed "turnup testing." In this phase a carrier connects its platform to a Lockheed NPAC testbed to verify the carrier's ability to interact correctly with the NPAC production platform while attempting to perform all the functions that the carrier will need to perform during live NPAC operation. Lockheed advises that the NPAC production platform for the three prior Perot regions will be deployed by approximately April 16, 1998. Lockheed Martin states that the turnup schedule for the Southeast region has not been finalized pending one carriers development schedule to complete a necessary update of their  XH,system software.KAH {O ,ЍId. at 8. K Each carrier will perform between 40 and 200 test cases against the test bed, depending on the carrier's experience and whether the platform previously had been subjected to this testing phase. Once a carrier completes the test cases, the carrier must test its ability to interoperate with at least two other previously certified carriers in what is called service provider to service provider or SP to SP testing. Finally a carrier being certified must connect its system to the regional NPAC production platform. (# XTurnup testing involves both establishing normal connectivity and establishing disaster or "failover" connectivity with Lockheed's backup NPAC production facility. Lockheed notes that the turnup testing is performed in two circumstances: once when a new region is being first tested with one incumbent and two other carriers (NPAC live), and once for each carrier that enters a live NPAC region. It states that it expects to complete turnup testing for the West Coast and Western regions by May 11, 1998. The average time a carrier requires to complete turnup testing is about a month.(#  X,X(c) Field Trial/Network Testing The field trial/network testing phase takes place after the NPAC is designated live. The primary purpose of this phase of testing is to provide one or more carriers in a region with a final opportunity to test completely endtoend LNP number porting to include all necessary downstream and other network element provisioning necessary to prove that the number has been fully ported  Xe,and tested.DBeZ {Op,ЍId.D Lockheed expresses the view that carriers typically wish to conduct this testing phase prior to beginning live porting of actual customers in an NPAC region, or in a new MSA within that region. Lockheed Martin notes that this phase is defined, organized, and conducted by the carriers with minimal assistance from Lockheed Martin test engineers and may take approximately 48 working weeks to complete for  X,the first MSA activated in a region.C" yO$,ЍLockheed Martin cautions that it is only tangentially involved in the network testing, as the NPAC services it delivers are otherwise live at this point. It states that in its experience, the actual amount of testing  {O&,varies substantially by carrier, MSA, and region and notes that a number of factors influence testing time. Id. at 89.(# " C,**w"Ԍ X, IV. DISCUSSION Ń  X, 33. Pursuant to section 1.3 of the Commission's rules, the Commission may grant a waiver of a provision of its rules upon a showing of "good cause." 47 C.F.R.  1.3. As construed by the U.S. Court of Appeals for the District of Columbia Circuit, section 1.3 allows the Commission to grant a waiver if special circumstances warrant a deviation from the  Xv,general rule and such a deviation will serve the public interest.D^v {O,  ԍNortheast Cellular Telephone Co., L.P. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990) (citing WAIT Radio  {O, w v. FCC, 418 F.2d 1153, 1159 (D.C. Cir. 1969), cert. denied, 409 U.S. 1027 (1972)); Industrial Broadcasting, Co.  {O ,v. FCC, 437 F.2d 680, 683 (D.C. Cir. 1970).   XH,Implementation Waiver Petitions based on the Change of NPAC   X ,!34. The parties agree generally that the failure of Perot Systems to provide a stable platform is the principal reason for any delays in meeting the Commission's March 31, 1998  X ,Phase I implementation deadline. In the January 28 Waiver Extension Order, the Chief of the Bureau's Network Services Division noted that the LLCs in the Southeast, Western and West Coast regions were still evaluating the impact of the failure and negotiating to resolve issues  X ,associated with the expected delayed deployment.E  {OH,ЍSee January 28 Waiver Extension Order at 13, citing NANC January 21 Letter.xx That order granted affected carriers a thirty day limited extension of time to file petitions for extension of the Phase I deadline on the basis that there was too much uncertainty to expect carriers in the affected regions to  Xd,evaluate fully the situation._Fd {O,ЍSee Id. at 13. _ On February 20, 1998, the Chairman of the NANC notified the Bureau Chief that the NANC members unanimously supported the decision of the LLCs to terminate their contracts with Perot Systems and to enter into contracts with Lockheed Martin to serve as the LNPA as essential in successfully implementing LNP in Southeast, Western,  X,and West Coast regions.QG yO,ԍNANC February 20, 1998 Letter. Q  X,"35. We find that special circumstances were created as a result of the decision of the LLCs for the Southeast, Western, and West Coast regions to terminate their contracts with Perot Systems and enter into contracts with Lockheed Martin to serve as the LNPA. We find that this circumstance warrants a deviation from the general rule which requires that Phase I be implemented by March 31, 1998, and that extending the deadline for Phase I, as provided  Xg,herein, will serve the public interest.DHg {O$,ԍSee Id.D  X9,#36. Some commenters argue that the testing sequences, time estimates, or intervals carriers cite are too lengthy or unnecessary. MCI argues, for example, that there is no reason for US WEST to delay testing after May 11, 1998, because implementation should be a"  4 H,**"  X,continuation of previous testing.FI yOy,ԍMCI Comments at 910.F MCI further argues that GTE's graduated implementation  X,is not warranted, because there have been no testing problems that cause outages.AJX {O,ԍId. at 13.A WorldCom argues that after Pacific's June 10, 1998 network testing is complete, porting  X,should begin over all switches, not phasedin.HK yOV,ԍWorldCom Comments at 7.H GTE asserts that sixty days for Phase I implementation is prudent, because failure in one part of the network may result in numerous  X,defaults to other locations, concerns that will be reduced in subsequent Phases.GLz yO ,ԍGTE Reply at 25, n.3.G Sprint argues that it is wrong to assume that because NPAC interacts correctly with one switch in  X_,one MSA, it will respond the same with every switch.CM_  yO,ԍSprint Reply at 2.C  X1,$37. In general, we decline to secondguess carrier's assessments of their additional time requirements. We believe that the time requested by the carriers will allow for rigorous intracompany and interindustry testing, which is needed to ensure efficient and problemfree implementation. Most of the carriers, WorldCom, AT&T, NEXTLINK, Sprint, US WEST, Pacific, MediaOne, and GTE request extensions of the Phase I implementation deadline, ranging from June 15, 1998 through July 31, 1998. Teleport has not specified a date. Subject to the requirements and conditions discussed herein, we find that the timing appears to be reasonable and conclude that the requirements of section 52.23(e) of the Commission's  Xy,rules are satisfied.SNy yO,Ѝ47 C.F.R.  52.23(e).S Accordingly, we grant the petitions for extensions of the Phase I deadline of March 31, 1998 for implementing LNP in the Western and West Coast regions, for WorldCom, AT&T, NEXTLINK, Sprint, US WEST, Pacific, GTE, and MediaOne as follows: World Com until June 15, 1998; AT&T until June 26, 1998; NEXTLINK until July 1, 1998; Sprint until July 13, 1998; US WEST until July 17, 1998; Pacific until July 19, 1998; GTE, until July 31, 1998; MediaOne (until July 19, 1998 in Pacific's territory and until July 31, 1998 in GTE's territory); and Teleport until July 19, 1998. If, for any reason, however, Lockheed Martin is delayed and does not provide a "live" NPAC on May 11, 1998, these carriers shall implement permanent LNP in the Western and West Coast regions as soon as practicable within sixty days after the NPAC is made available, but in any event no later than July 31, 1998.  Xe,%38. BellSouth seeks an extension of Phase I until November 14, 1998. Allegiance and MediaOne seek the same extension as BellSouth, while ITC DeltaCom seeks an extension until sixty days after BellSouth.  X ,&39. Prior to the change of LNPA from Perot Systems to Lockheed Martin, all of BellSouth's territory was in the former Perot Systems region. BellSouth states that it requires"* N,**" substantial, additional time to implement LNP since it must upgrade from Perot System's NANC specification 1.1 to Lockheed Martin's software, which was designed to meet NANC specification 1.8. It argues that more time is required to complete testing, because unlike  X,some other carriers, it did not have a previous business relationship with Lockheed Martin.XO {O4,ԍSee BellSouth Comments at 4, 67.X It explains that its software was designed to interface with the NANC 1.1 specification required by Perot Systems. Other carriers, such as AT&T, WorldCom, US WEST, and GTE, had preestablished business relationships with Lockheed Martin in other regions of the country and consequently, already had tested and certified 1.8 programs to interface with Lockheed's NPAC. BellSouth argues that this distinguishes it from other carriers, since other carriers already are certified for NANC specification 1.8 and do not need to undergo the certification process set forth generally above.  X ,'40. Several commenters argue that BellSouth should have known of the need for upgrades since a November 1997 NANC meeting where it was discussed that Perot System's  X ,software was built only to specification 1.1.P Z {O,ЍSee MCI Comments at 45; WorldCom Comments at 45; AT&T Comments on DA 98449 at 79, and Exhibit I, to the 11/1314/97 NANC meeting minutes. AT&T further argues that BellSouth does not detail what the 1.11.8 upgrade actually requires. It asserts that the vast majority of changes for the upgrade involves documentation, not coding changes, and that there are only two coding changes "port to original" (cancel the order) and "NPA spits" (permitting area code updating). AT&T notes that these changes were specifically identified in the 11/1314/97 NANC minutes. AT&T Comments on DA 98449 at 1011. Arguing that the databases of Perot System and Lockheed Martin are different and not fungible, BellSouth explains that until the LLCs terminated the contractual relationship with Perot Systems and entered into one with Lockheed Martin, BellSouth was legally obligated to implement LNP in the Southeast region in  Xb,accordance with Perot Systems' specifications.OQb yO,ԍBellSouth Reply at 69, 1115.O AT&T argues that implementation means only being prepared to accept and fulfill orders, and download routing information from an  X4,NPAC/SMS to a local SMS._R4d  yOI,ЍAT&T Comments on DA 98449 at 1315._ US WEST disputes this, contending that the specifications of  X,Perot Systems and Lockheed Martin are not identical.ES  yO,ԍUS WEST Reply at 11.E  X,(41. Subject to the conditions discussed herein, we find that BellSouth has satisfied the  X,requirements of section 52.23(e) of the Commission's rules.ST  yO $,Ѝ47 C.F.R.  52.23(e).S We find that BellSouth has demonstrated unique circumstances that justify additional time to implement number portability, in part, because carriers, such as AT&T, WorldCom, US WEST, and GTE, have systems in other regions of the country, and thus have previous experience working with the Lockheed Martin's NPAC. Accordingly, we grant BellSouth a waiver of the Phase I implementation date to August 31, 1998 subject to the following conditions: BellSouth must file with the Bureau, two reports, by May 8, 1998 and June 8, 1998, on the progress it and"NT,**" Lockheed Martin have made and are making with respect to BellSouth's interface with the  X,Lockheed Martin NPAC, and its progress on updating BellSouth's SMS interface with its  X,internal systems, including its AIN SMS, Service Order Control System, Product and Services Information Management System, and its Customer Revenue Information Systems. The reports must set forth in detail progress it has made and steps taken, including a detailed work  X,plan for next steps.U {O,ЍSee BellSouth Letter at 4; AT&T Comments on DA 98449 at 78 and 1213. In addition, BellSouth must notify the Bureau Chief by letter, as soon as Lockheed Martin establishes an NPAC live date in the Southeast region. We believe that this approach strikes an appropriate balance between BellSouth's need for additional time based on its unique circumstances and the need to implement LNP without greater delay, other than that encountered as a result of the change from Perot Systems to Lockheed Martin.  X ,)42. Allegiance, AT&T, ITC DeltaCom, MediaOne, and WorldCom operate in the Southeast region. Allegiance, ITC DeltaCom, and MediaOne rely upon BellSouth to implement number portability and it is appropriate to grant them the same extension as BellSouth. We find that Allegiance, ITC DeltaCom, and MediaOne satisfy the requirements of section 52.23(e) of the Commission's rules and accordingly, grant them until August 31,  X,1998 to implement Phase I.SVZ yO,Ѝ47 C.F.R.  52.23(e).S As stated above, we grant the petitions of WorldCom for extension of the Phase I deadline in the Western and West Coast regions until June 15, 1998 and AT&T until June 26, 1998. Although WorldCom and AT&T have not requested comparable extensions to that given to BellSouth, we hold that all carriers operating in the Southeast region prior to August 31, 1998 must implement LNP as soon as practicable, but in any event, no later than August 31, 1998. Carriers, such as ITC DeltaCom, that may not yet be operational in the Southeast region prior to August 31, 1998, must implement LNP  X,consistent with the Commission's rules.`W {O,ЍSee 47 C.F.R.  52.23(b)(2).` All carriers in the Southeast region must notify the Bureau Chief by letter, as soon as Lockheed Martin establishes an NPAC live date for the Southeast region. In addition all carriers in the Southeast region must file with the Bureau by May 8, 1998, a report describing their architectural arrangements for number porting. We deny ITC DeltaCom's petition to extend its implementation of permanent number portability sixty days beyond BellSouth's implementation deadline because we reasonably expect it to implement LNP on the same schedule as BellSouth, or consistent with the Commission's rules.  X ,GTEC Implementation Waiver  X,*43. No party opposes the petition for extension of the implementation deadline filed by GTEC. We find that GTE has demonstrated that it has taken reasonable steps to modernize the switch once it came under its control and that it satisfies the requirements of  X!,section 52.23(e) of the Commission's rules.SX!| yO(,Ѝ47 C.F.R.  52.23(e).S Accordingly, we grant GTEC an extension of"! X,**/ " the Phase I implementation deadline to June 1, 1998 for its switch located on the campus of USC in the Los Angeles MSA.  X, +44. Some of the Petitioners also requested extensions of Phases II V.Y yO4,ЍBellSouth petition at 22; GTE petition at 910; Pacific petition at 21; and US WEST petition at 1112. We limit our discussion in this Order to delays in implementing Phase I and will address extensions of Phases II V in future orders.  X_,6[ V. ORDERING CLAUSES ă  4IT IS THEREFORE ORDERED, pursuant to sections 1.3 and 52.23(e) of the Commission's rules, 47 C.F.R.  1.3 and 52.23(e), and by authority delegated in sections 0.91 and 0.291 of the Commission's rules, 47 C.F.R.  0.91 and 0.291, that the Petitions for extensions of the Phase I for implementing local number portability, discussed in this Order ARE GRANTED, subject to the requirements and conditions provided herein. We DENY ITC DeltaCom's petition to extend implementation sixty days beyond BellSouth's implementation deadline. ` `  Ghh~FEDERAL COMMUNICATIONS COMMISSION ` `  Ghh~Geraldine A. Matise ` `  Ghh~Chief, Network Services Division ` `  Ghh~Common Carrier Bureau 4