Somos questions NANC extension request for RND
Somos, a registry management and data solutions company and the administrator of the Toll-Free Number database registry, submitted an ex parte filing with the FCC in response to the NANC NAOWG’s request for a 7-month extension on the technical requirements document and funding report for the Reassigned Numbers Database (RND). In their filing, Somos stated that the delay was unwarranted.
The Number Administration Oversight Working Group (NAOWG) of the North American Number Council (NANC) requested a delay on August 14, 2019. We reported their reasons in this blog post.
Somos disagreed. Here’s why.
1. Keeping to the original timeline is in the public interest
Each day the RND is delayed, the public remains vulnerable to disruptive intrusions, missed connections, and even legal liability.
2. The RND is not a particularly difficult database to set up
The database inputs are simple: a telephone number, and the disconnect date of the service. Queries are simple: has this number been disconnected since a particular date?
Somos created a similar database with its Toll-Free Number Administration service.
3. Technical Requirements Documents need not be very technical
Most requirements listed in the TRD are business oriented. NAOWG does not have to provide a system design in the TRD. Bidders can provide the necessary technical details for their proposed solutions. It’s common for the government to solicit solutions through the procurement process. And companies in the NAOWG, especially the larger service providers, can reach inward to their own resources to identify technical requirements.
4. The NANPA/PA and RNDA should be combined
Somos asserted that the decision to combine the NANPA/PA and the RND administrator roles is sensible and should not be reconsidered, for these reasons:
- Separating them would create unnecessary duplication
- These roles liaise with the same stakeholders
- Launching the RND and next NANPA/PA at the same time will create synergies
- The government need manage one procurement process, not two
- Combining these bids will attract more bidders