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Federal Internet Law & Policy
An Educational Project
VoIP: Numbers Dont be a FOOL; The Law is Not DIY


Number Portability

"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

Laws and Regulations

Access to Number Resource

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

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). 

Spoofing

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North American Numbering Council

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

FCC

State

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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