Commenters Offer Suggestions on VoIP Provider Direct Access to Numbers

Commenters were generally bullish on the FCC’s proposal to make direct access to numbers available generally to interconnected VoIP providers, in comments posted Monday. Several offered tweaks on how the rules could better accommodate VoIP providers. And some questioned whether it was wise to do so without “holistic” reform.

The agency should promptly permit interconnected VoIP providers to directly access numbers on a wider basis than just the trials, said Vonage, among those granted access during a six-month trial in an NPRM the agency approved at its April meeting (CD April 19 p1). The commission has “ample authority” to do this, as it has “plenary authority over numbering resources,” Vonage said (http://bit.ly/12ZtpNE). “It thus need not determine whether it has ancillary authority to extend numbering requirements to interconnected VoIP providers, nor must it devise specialized authorization procedures to enable direct access.” The rules should be competitively neutral, putting all providers with direct access on an “equal footing,” Vonage said. That would give all companies access to the same phone numbers as traditional providers and making them subject to the same number utilization requirements, said the VoIP provider.

If direct access to numbers is made generally available to interconnected VoIP providers, it should be subject to “reasonable conditions necessary to protect the public by preserving scarce numbering resources,” said HyperCube Telecom (http://bit.ly/12ZtkJQ). The commission should require VoIP providers to “fulfill their obligations” regarding utilization of numbering resources and intercarrier compensation, and should require VoIP providers to offer direct Internet Protocol-to-IP interconnection consistent with sections 251 and 252 of the Telecom Act, it said. To ensure network robustness, the commission should also require VoIP providers to “maintain a back-up routing of last resort with homing to a LEC tandem,” HyperCube said.

Comcast supports modernization of the FCC’s numbering rules “because it is likely to facilitate a smoother and faster transition to an all-IP world for voice services,” the cable company said (http://bit.ly/17z2APY). The commission need make “only minor modifications” to the current rules and industry practices, Comcast said. That would include allowing VoIP providers to submit “alternative documentation” to get numbers; requiring them to comply with current number utilization rules and guidelines; making clear that telecom carriers and interconnected VoIP providers are equally obligated to respond to each other’s porting requests; and ensuring VoIP providers comply with “standard industry traffic routing requirements” that currently apply to their numbering partners, said the operator.

Number administration and management into the future bring challenges that require a balance between “conservation and accommodation of inevitable industry and market changes,” CenturyLink said (http://bit.ly/12Zxh18). Direct VoIP access to numbers is “desirable,” but it’s important to note that the trials at issue are number-assignment trials, “not network re-design” trials, the telco said. ILECs’ existing networks and traffic exchange processes are “not poised for a major overhaul” in connection with this trial, it said. CenturyLink also pointed to the commission’s cost allocation rules, saying they “need immediate attention to restore equity and equilibrium to the matter of number administration.” The telco called for a rulemaking to address “more futuristic issues of telephone numbers as addressing devices and how that might drive a new cost allocation model."

Not everyone supported the expanded access to numbers. Although the FCC’s decision to treat VoIP providers as telecom carriers for purposes of granting direct access to numbers is “moving in the right direction,” the FCC’s proposal ultimately is just a “convoluted way to provide VoIP providers” with the “benefits of Title II classification” without actually classifying them as such, said the California Public Utilities Commission. This action interprets the Communications Act in a manner “inconsistent with the statute’s plain language,” said the CPUC. By treating VoIP providers like telecom services for the purposes of direct access to numbering, but not for other purposes, “the FCC’s action could easily lead to absurd results,” the state commission said.

Bandwidth.com argued that without “holistic” reform, granting non-carriers direct access to numbers will “create more problems than it will solve” (http://bit.ly/12ZxNMu). The commission is “trying to implement a discrete, but extremely thorny, concept that is fundamentally driven by a handful of non-carriers aiming to achieve a discriminatory leg up on the competition,” said the provider of VoIP phone systems. The commission should instead “focuses its resources” on “the holistic reform that is necessary to enable a rapid but smooth transition to a regulatory structure premised upon advancing the public interest through IP technologies in a nondiscriminatory fashion,” it said. “Numbering is inherently connected to a myriad of related regulatory and policy considerations and must not be approached as if it exists in a vacuum.”