COMMISSIONER AJIT PAIRe:
Numbering Policies for Modern Communications, WC Docket No. 13-97; IP-Enabled Services,
WC Docket No. 04-36; Telephone Number Requirements for IP-Enabled Service Providers, WC
Docket No. 07-243; Telephone Number Portability, CC Docket No. 95-116; Developing a
Unified Intercarrier Compensation Regime, CC Docket No. 01-92; Connect America Fund; WC
Docket No. 10-90; Numbering Resource Optimization, CC Docket No. 99-200; Petition of
Vonage Holdings Corp. for Limited Waiver of Section 52.15(g)(2)(i) of the Commission’s Rules
Regarding Access to Numbering Resources; Petition of TeleCommunication Systems, Inc. and
HBF Group, Inc. for Waiver of Part 52 of the Commission’s Rules.
Telephone numbers are at the heart of voice communications in the United States. They are used
to connect one customer to another, to identify carriers on the public-switched telephone network (PSTN),
to enable texting and multimedia messaging, and to route emergency calls. And yet, no one ever seems
eager to talk about the Local Exchange Routing Guide or the Number Portability Administration Center
or the North American Numbering Plan, let alone how to integrate those last-generation systems with
next-generation technologies like the Session Initiation Protocol (for point-to-point Internet Protocol (IP)-
based calls) or ENUM (for mapping telephone numbers into the Internet space).1 In short, numbering
gets no respect.
But today, numbers rightfully take center stage. We need to address the subject now because
today’s numbering system is becoming an anachronism. It assumes the dominance of old-school carriers
interconnecting over time-division-multiplexed (TDM) circuits, using copper lines and the out-of-band
Signaling System No. 7. But that’s not how modern, IP-based networks operate.
This morning’s item comes none too late. It’s been nine years since then-Chairman Powell
recognized that IP-based communications were the future and opened up a proceeding on IP-Enabled
Services.2 Since then, interconnected voice over IP service providers have proliferated and consumers
have fled the PSTN. Meanwhile, the Commission has gained invaluable experience and perspectives. It
has managed a database to allow point-to-point IP-based communications via telephone numbers.3 It has
established a Technology Transitions Policy Task Force.4 And it has heard from its Technological
Advisory Council that the old TDM infrastructure should sunset in the next five years.5
It is time for the FCC to acknowledge that the IP Transition is upon us—that old copper-based
networks are fundamentally different from new IP-based networks, and that our legacy regulations slow
1 Fun fact: The “E” in ENUM stands for E.164, the technical standard for telephone numbers, not “electronic.” For
a useful and readable description of ENUM and précis on the integration of traditional and IP-based networks, see
http://www.cisco.com/web/about/ac123/ac147/archived_issues/ipj_5-2/enum.html. More intrepid readers can turn
to the International Telecommunications Union. See http://www.itu.int/osg/spu/enum/.
2 See IP-Enabled Services, WC Docket No. 04-36, Notice of Proposed Rulemaking, 19 FCC Rcd 4863 (2004).
3 See Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech
Disabilities; E911 Requirements for IP-Enabled Service Providers, CG Docket No. 03-123, CC Docket No. 98-67,
WC Docket No. 05-196, Second Report and Order and Order on Reconsideration, 24 FCC Rcd 791 (2008) (creating
the iTRS Numbering Database).
4 Press Release, FCC Chairman Julius Genachowski Announces Formation of ‘Technology Transitions Policy Task
Force’ (Dec. 10, 2012), available at http://go.usa.gov/TWFB; Statement of Commissioner Ajit Pai on the Formation
of Technology Transitions Policy Task Force (Dec. 10, 2012), available at http://go.usa.gov/TWFw.
5 Meeting of the Technological Advisory Council of the Federal Communications Commission (June 29, 2011),
available at http://go.usa.gov/TWFe.
down the transformation from old to new (not to mention investment and innovation). Last month, I
highlighted the importance of revising numbering for next-generation networks as one task we must
undertake to facilitate the IP Transition.6 Needless to say, then, I am pleased that the Notice we adopt
today takes a fresh look at many of our numbering rules, including those regarding number portability and
numbering cost allocation.
I am particularly grateful to my colleagues for incorporating many of my suggestions. These
related primarily to the upcoming trial that will allow interconnected VoIP providers to gain direct access
to numbers. Most importantly, the trial now will place participants on a six-month schedule with a
limited geographic scope, which will help us identify and hopefully resolve any unforeseen problems.
And the trial will require reporting from participants on what worked and what didn’t—for we can’t
benefit from the lessons learned unless we learn the lessons. Additionally, the Wireline Competition
Bureau will report back to us (and the public) on the results of the trial, thanks to a proposal by my
colleague, Commissioner Rosenworcel. All of these changes will ensure that the trial is a real
experiment, one that will help us eschew opinions in favor of facts.
Speaking of trials, I feel compelled to mention another critical one that’s necessary for a smooth,
successful IP Transition: an All-IP Pilot Program. Just like the VoIP numbering trial we embrace today,
an All-IP Pilot Program would allow providers to voluntarily test the waters of the IP Transition, in this
case by turning off their old TDM electronics in a discrete number of wire centers and migrating
consumers to an all-IP platform. Like today’s trial, it would be geographically limited. Like today’s trial,
we’ll need to include consumer protections to make sure that no consumer loses voice service. And like
today’s trial, we’ll need to rigorously evaluate the results of that pilot program, so that we know how to
make the IP Transition a success for all Americans. I hope we undertake the All-IP Pilot Program soon.
But enough words about that. Today is appropriately a day for numbers.7 I want to thank the
numbering team in the Wireline Competition Bureau for all their work on this item. I look forward to
reviewing the results of the trial and moving forward with a Report and Order in this proceeding early
6 Remarks of Commissioner Ajit Pai, “Two Paths to the Internet Protocol Transition,” Hudson Institute,
Washington, DC (Mar. 7, 2013), available at http://go.usa.gov/TWMj.
7 Cf. Norton Juster, The Phantom Tollbooth 176–77 (1961) (“[The Dodecahedron asked,] ‘Don’t you know anything
at all about numbers?’ ‘Well, I don’t think they’re very important,’ snapped Milo, too embarrassed to admit the
truth. ‘NOT IMPORTANT!’ roared the Dodecahedron, turning red with fury. ‘Could you have tea for two without
the two—or three blind mice without the three? Would there be four corners of the earth if there weren’t a four?
And how would you sail the seven seas without a seven? . . . Why, numbers are the most beautiful and valuable
things in the world. Just follow me and I’ll show you.’ He turned on his heel and stalked off into the cave.”).
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