Discussion

We conclude that the payments NeuStar currently recovers through Direct Fees charged to specific carriers should be recovered from all carriers on a proportionate basis based upon each carrier's share of assigned numbers used in service in the NPA on the same basis as other number pooling costs. We agree with WorldCom that assessing separate Direct Fees on carriers will result in a disproportionate burden on CLECs in comparison to ILECs. The use of assigned numbers as a cost allocation basis results in a more competitively neutral means of recovering number pooling costs in accordance with the underlying intent of the Decision. Therefore, we shall clarify the Decision to explicitly require that the PA contract be conformed to the requirement that Direct Fees not be separately charged, but shall be recovered from all carriers on a pro rata basis using assigned numbers as the allocation basis.