Re: Direct Access to Numbering NPRM, Order and NOI
While I am personally unaware of anyone who makes calls from a rotary phone at
least on a regular basis, I know that there are thousands still in use. I retain fond
memories of over-stretched cords, the constant moving and plugging in of that
cumbersome device from room to room, and even the frustration I felt from the sound of
a busy signal.
In actual years, that really wasn’t so long ago, but as technology continues to
rapidly evolve we must maintain a meaningful process of crafting rules that will dictate
how the next voice, video, and data systems will be governed. I feel that this NPRM and
order is yet another step in our understanding of how we will govern this space in the
years to come. With a keen and steady eye toward promoting innovation, investment, and
competition in the marketplace, I support this item.
This NPRM contains meaningful and probing questions designed to answer in
part just how much benefit may be achieved by allowing direct access to numbering. And
I expect that we will proceed with caution in considering any regime change that would
permit allotments from the North American Numbering Plan Administration and the
Pooling Administrator. As the item states, improved number conservation, the removal
of barriers for innovative offerings, and the elimination of inefficiencies regarding the
need for VoIP providers to obtain numbers through partners are all worthwhile objectives
that the FCC should strive to actualize in a sensible and timely manner.
When it comes to the request for a waiver, which would allow Vonage to conduct
a trial and directly obtain numbers from numbering pools rather than through the current
partnering regime with traditional carriers, I am supportive because I feel that granting
this request will provide an opportunity for us to better understand how a VoIP carrier
would function if freed from a legacy regulatory framework. This particular waiver
involves a small sample of numbers that Vonage will use during its trial – 145,000, where
Vonage serves about 2.4 million subscribers today. This course will allow us to craft best
practices that may be used in allowing VoIP carriers access to numbering pools – which
may be an outcome of the IP transition – while not exhausting number sets in existing
As a former state regulator, I know how tied communities are to their area codes,
and I trust that this waiver will not result in any state having to split a community
between two codes. I am also happy to report that this waiver will conclude with a public
comment period allowing parties the opportunity for constructive engagement that will
inform the FCC’s next steps. Regulators and customers will have the chance to share
their experiences with Vonage during the waiver process as well, and those comments
and the reports Vonage are required to submit will help inform the Commission as we
decide on how best to structure the upcoming IP transition rulemaking.
Further, integrating TeleCommunication Systems’ services with the pseudo-Automatic
Numbering Identification will enhance 911 call centers’ ability to determine where a
VoIP call originates.
The combined effect of these waivers is, admittedly, quite small, but we must
keep the larger picture in front mind when considering them. The IP transition is
happening, and we must do everything we can to ensure it as smooth as possible, for both
industry and the public at large.
Knowing the differences between VoIP and traditional carriers’ use of number
pools – how long each holds a number and how long before that number can be recycled
by another customer or carrier – as well as how this waiver has impacted state regulators
and their customers, will make the much bigger step, IP transition, that much easier.
One of the toughest challenges of a communications’ regulator is making sure that
the well-intentioned rules we put in place today, will not stifle the technological
opportunities of tomorrow. The granting of limited waivers is yet another tool in our
nimble rulemaking arsenal that should be embraced whenever possible to keep our nation
on the cutting edge of innovation.
I look forward to the comments to our NPRM, as well as the results of the
trial. Both will assist the Commission in moving forward in a prudent and well-reasoned
fashion, and once again, I thank the bureau for its diligent work. I want to offer much
gratitude to Lisa Gelb, Bill Dever, Ann Stevens, Marilyn Jones, Julie Veach and the
others for their tremendous work.
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