Several CLECs are concerned about the “potential impact...

(http://bit.ly/1fPTdkN) that they had sent to North American Portability Management in November. “We now understand from the NAPM that it will not be responding to our correspondence during the selection process,” the CLECs said, urging the commission to properly consider their concerns. According to the attached letter to NAPM (http://bit.ly/1iDcplv), previously unpublished, the CLECs had three main concerns. First the potential “regional multi-vendor approach” could “create economic and operational hurdles” if every carrier needs to deal with a different LNPA services vendor in each region, the CLECs said. This could cause some carriers to “rethink operating in multiple LNPA regions,” they said. “We believe that your assessment of the bids must take into account the increased costs for smaller carriers.” Second, the cost of any transition would hurt smaller carriers, which “simply do not have the wherewithal to undertake a costly and complex transition to a new LNPA provider, particularly if our transition costs are not offset by considerably lower LNPA charges to our companies,” the CLECs said. Third, the impact on consumers and businesses needs to be given adequate weight in evaluation of the proposals, the CLECs said. “If a change in LNPA is made, there is substantial risk that the transition will not be smooth,” with “failures along the way” as carriers try to modify their systems in such a short period, they said. “LNP is our lifeblood; it’s how we get customers. If what were one-day ports slip to become one-week ports or one-month ports under a new LNPA, it will have a devastating impact on small carriers and our ability to compete for business.” Large companies can weather such rough patches far more easily than can smaller companies, the CLECs said. “Please ensure that the potential for disruption of a smooth functioning LNPA process, and the impact of such disruption on small carriers and their customers, is thoroughly considered and evaluated as you examine the various proposals.” An “uninformed” LNPA selection could have “devastating consequences” for smaller carriers, the CLECs said. Neustar and Telcordia have both asked the FCC to step in and “restore transparency” to the bidding process (CD Feb 7 p9).