Federal Internet Law & Policy
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VoIP: Numbers Dont be a FOOL; The Law is Not DIY
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Number Portability Dkt 07-243

"Washington, D.C. - The right of consumers to keep the same, familiar phone number when switching to a new telephone company was expanded today by the Federal Communications Commission , in an Order that will further ensure consumers' opportunity to choose a telephone service provider based on quality, price and service.

"The FCC made clear that the obligation to provide local number portability extends to interconnected Voice over Internet Protocol providers and the telecommunications carriers that obtain numbers for them. This action was, in part, a response to numerous complaints by consumers about their inability to port numbers to or from interconnected VoIP providers. The FCC also initiated a Notice of Proposed Rulemaking seeking comment on additional VoIP numbering issues.

"The FCC also clarified in its Order that telephone companies may not obstruct or delay number porting by demanding excess information from the customer's new provider, and specifically concluded that LNP validation for a simple number port should be based on no more than four fields: (1) 10-digit telephone number; (2) customer account number; (3) 5-digit zip code; and (4) pass code, if applicable. In its Notice, the FCC also tentatively concluded that it should require the industry to complete simple ports in 48 hours.

Telephone Number Requirements for IP-Enabled Services Providers; Local Number Portability Porting Interval and Validation Requirements; IP-Enabled Services; Telephone Number Portability; Numbering Resource Optimization, WC Docket Nos. 07-243, 07-244, 04-36, CC Docket Nos. 95-116, 99-200, Report and Order, Declaratory Ruling, Order on Remand, and Notice of Proposed Rulemaking, 22 FCC Rcd 19531 (2007) (VoIP LNP Order), aff’d sub nom. National Telecomms. Cooperative Ass’n v. FCCLeaving CT (D.C. Cir. Apr. 28, 2009)

10/31/07 FCC Expands Local Number Portability to VoIP.
News Release: Word | Acrobat
Martin Statement: Word | Acrobat
Copps Statement: Word | Acrobat
Adelstein Statement: Word | Acrobat
Tate Statement: Word | Acrobat
McDowell Statement: Word | Acrobat

TELEPHONE NUMBER REQUIREMENTS FOR IP-ENABLED SERVICES PROVIDERS. The Commission took a series of steps designed to ensure that consumers benefit from local number portability (LNP). (Dkt No. 95-116, 04-36 , 07-243). Action by: the Commission. Adopted: 10/31/2007 by R&O. (FCC No. 07-188). WCB (Released November 8, 2007)  FCC-07-188A1.doc   FCC-07-188A2.doc   FCC-07-188A3.doc   FCC-07-188A4.doc   FCC-07-188A5.doc   FCC-07-188A6.doc   FCC-07-188A1.pdf   FCC-07-188A2.pdf   FCC-07-188A3.pdf   FCC-07-188A4.pdf   FCC-07-188A5.pdf   FCC-07-188A6.pdf   FCC-07-188A1.txt   FCC-07-188A2.txt   FCC-07-188A3.txt   FCC-07-188A4.txt   FCC-07-188A5.txt   FCC-07-188A6.txt

Fed Reg Vol 73 No 35 p 9463 (Feb. 21, 2008) Comments Due Mar 24 Replies Due Apr 21, 2008


Access to Number Resource Dkt 13-97

Docket 99-200

Petitions for Waivers

After the FCC's order granting SBC's numbering petition, the FCC received a number of additional petitions from VoIP service providers requesting similar waivers. Docket 99-200

  • Released: 05/04/2005. WIRELINE COMPETITION BUREAU SEEKS COMMENT ON QWEST COMMUNICATIONS CORPORATION PETITION FOR LIMITED WAIVER OF SECTION 52.15(G)(2)(I) OF THE COMMISSION'S RULES REGARDING ACCESS TO NUMBERING RESOURCES. (DA No. 05-1288). (Dkt No 99-200) Pleading Cycle Established. Comments Due: 06/04/2005. Reply Comments Due: 06/20/2005. WCB. Contact: Mika Savir at 0384, email: Mika.Savir, 0484, FCC 5/6/2005
  • Corecomm-Voyager, Inc. Petition for Limited Waiver Filed April 22, 2005 PDF
  • Vonage Petition for Limited Waiver Filed March 4, 2005 PDFpdf
  • Vonage Holdings Corporation (“Vonage”), respectfully requests that the Federal Communications Commission (“Commission”) grant it a limited waiver of Section 52.15(g)(2)(i) of the Commission’s rules, 47 C.F.R. § 52.15(g)(2)(i), to allow Vonage to obtain numbering resources directly from the North American Numbering Plan Administrator (“NANPA”) and/or the Pooling Administrator (“PA”) in a manner comparable to the waiver granted to SBC Internet Services, Inc. (“SBC-IS”).1 Vonage intends to use these numbering resources to deploy IPenabled services, including Voice over Internet Protocol (“VoIP”) services, on a commercial basis to residential and business customers.
  • "Between February 2005 and August 2006, the following entities filed petitions for waiver of section 52.15(g)(2)(ii):  Constant Touch Communications;CoreComm-Voyager, Inc.; Dialpad Communications, Inc.; Frontier Communications of America, Inc.; Net2Phone Inc.; Nuvio Corporation; Qwest Communications Corporation; UniPoint Enhanced Services d/b/a PointOne; RNK Inc.; VoEX, Inc.; Vonage Holdings Corporation; and WilTel Communications, LLC.  More recently the following entities have filed petitions for waiver of section 52.15(g)(2)(ii):  SmartEdgeNet, LLC; Millicorp, LLC; and, Inc."
  • Dialpad Petition for Limited Waiver Filed March 1, 2005 PD pdf
  • Administration of the North American Numbering Plan, CC Docket No. 99-200, Order, 20 FCC Rcd 2957 (2005)
  • SBC IP Communications, Inc. Petition for Limited Waiver of Section 52.15(g)(2)(i) of the Commission’s Rules Regarding Access to Numbering Resources, CC Docket No. 99-200, at 2­–3 (filed July 7, 2004)
  • CC Docket No. 99-200 SBC IP Petition for Waiver Comment due Aug 16, 2004 Reply due August 31
  • " In this order, we grant SBC Internet Services, Inc. (SBCIS) a waiver of section 52.15(g)(2)(i) of the Commission’s rules. Specifically, subject to the conditions set forth in this order, we grant SBCIS permission to obtain numbering resources directly from the North American Numbering Plan Administrator (NANPA) and/or the Pooling Administrator (PA) for use in deploying IP-enabled services, including Voice over Internet Protocol (VoIP) services, on a commercial basis to residential and business customers. We also request the North American Numbering Council (NANC) to review whether and how our numbering rules should be modified to allow IP-enabled service providers access to numbering resources in a manner consistent with our numbering optimization policies. The waiver will be in effect until the Commission adopts final numbering rules for IP-enabled services." -- ADMINISTRATION OF THE NORTH AMERICAN NUMBERING PLAN. Granted SBC Internet Services, Inc. a waiver of section 52.15(g)(2)(i) of the Commission's rules. (Dkt No. 99-200). Action by: the Commission. Adopted: 01/28/2005 by ORDER. (FCC No. 05-20). WCB, FCC 2/1/2005 POC: Sanford Williams, Telecommunications Access Policy Division, Wireline Competition Bureau at 7400, TTY 0484.
  • Public Notice
  • See Numbering Info
  • PSTN Transition :: Dkt 13-97

    Numbering Testbed

    Numbering Research

    AT&T Petition to Launch a Proceeding Concerning the TDM-to-IP Transition; Connect America Fund; Structure and Practices of the Video Relay Service Program; Telecommunications Relay Services And Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities; Numbering Policies for Modern Communications, GN Docket Nos. 13-5, 12-353, WC Docket Nos. 10-90, 13-97, CG Docket Nos. 10-51, 03-123, Order, Report and Order and Further Notice of Proposed Rulemaking, Report and Order, Order and Further Notice of Proposed Rulemaking, Proposal for Ongoing Data Initiative, FCC 14-5, para 201 (rel. Jan. 31, 2014). 


  • Rules and Regulations Implementing the Truth in Caller ID Act of 2009, WC Docket No. 11-39, Report and Order, 26 FCC Rcd 9114 (2011)
  • Fed Reg Notice
  • FCC Caller ID and Spoofing
  • See also Cybertelecom :: DNS :: Truth in Domain Names Act
  • North American Numbering Council

  • NENA VoIP Agreement, NENA 3/18/2004
  • What's in a number? (telephony numbering exhaustion issue), CNET 1/27/03
  • Web Calling Roils the Telecom World, NYT 12/16/02
  • VOIP UNDER ATTACK (LECs claims that IPT leads to number exhaustion) Pulver 11/15/02
  • VoIP Numbering Issues prepared by Bell South, Qwest and Verizon
  • ATIS Industry Numbering Committee
  • North American Numbering Plan Administration
  • North American Numbering Council
  • North American Numbering Council Chair | Reports
  • Vonage Presentation Jan 22, 2003
  • 2/1/05 Administration of the North American Numbering Plan. Order: Word | Acrobat
    Abernathy Statement: Word | Acrobat
    Copps Statement: Word | Acrobat
    Adelstein Statement: Word | Acrobat

    Other Activity



    Order instituting investigation on the Commission's own motion to determine the extent to which the public utility telephone service known as Voice over Internet Protocol should be exempted from regulatory requirements, CA PUC February 11, 2004

    Impact of VoIP on Numbering Resources: Federal and state regulators have been successful in slowing the explosive growth of new area codes. Each new area code places additional costs on businesses, adds complexity to the lives of residential consumers, and is inconvenient for all telephone customers. Under Federal Communications Commission (FCC) leadership, California has developed an effective set of rules that ensure that telecommunications providers receive the number they need and makes telecommunications providers efficiently utilize the number they have. VoIP providers currently utilize telephone numbers, but under FCC rules, they do not currently have to comply with protocols under the NANP, thereby potentially undercutting the concerted effort of regulators and carriers subject to the plan to manage scarce numbering resources.
        In many ways, the issues presented by VoIP mirror those once presented by wireless providers. Wireless providers, like VoIP providers, offer nationwide service that is portable to the subscriber. Wireless providers, however, register with the California Public Utilities Commission, contribute to state (and federal) universal service programs, pay access charges for interconnection with the PSTN, are required to provide E911 service, and must comply with NANP protocols.

    U-14073 - Commission's Own Motion (investigation of VOIP) - (MI PUC 3/16/2004 ) HTML | PDF

    In order to formulate an informed, consistent regulatory policy, the Commission would like to obtain information about VOIP activity in Michigan . The Commission, therefore, requests comments on VOIP activity in Michigan on the following topics that may be affected by both state and federal law:
    . . .
    c. Information regarding the effect of VOIP on telephone numbering resources, including non-licensed VOIP providers' access to numbering resources through licensed telecommunication carriers and VOIP end users' ability to port their current landline or wireless telephone number to their VOIP equipment.





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