Inclusion of Direct Fees in Carriers'
Proportionate Sharing of Contract Costs

Parties' Positions

NeuStar's current practice is to collect certain administrative fees directly from pooling participants (i.e., Direct Fees). NeuStar seeks confirmation from the Commission that Direct Fees are not included in the carrier's proportionate allocation of costs based on each carrier's share of the assigned numbers. NeuStar believes carriers should continue the current practice of paying the Direct Fees in accordance with the current Interim Number Pooling Administration agreements.

WorldCom disagrees with NeuStar, and argues that the Direct Fees charged by NeuStar should be recovered as part of the pro rata allocation assigned to each carrier based upon its share of assigned numbers in the NPA. WorldCom further argues that, it is inefficient to implement a Direct-Fees process when all costs can be more efficiently collected using the recovery process adopted in the Decision. WorldCom further argues that, due to Incumbent Local Exchange Carriers' (ILECs) more abundant number inventories lessening their reliance on pooling, Direct Fees will burden CLECs with higher costs than their ILEC competitors and that such an outcome would be anticompetitive.