VoIP Providers Slam Direct Numbering FNPRM

VoIP providers said a Further NPRM on imposing more requirements for those seeking direct numbering resources would harm members of their industry compared with traditional carriers, This came in comments posted Friday in docket 13-97. Others said additional requirements are necessary to curb illegal robocalls and spoofing. The NPRM would require that VoIP certify compliance with anti-robocalling obligations (see 2108050038).

Placing additional limitations on VoIP providers' use of numbers “would be anti-competitive,” said Twilio. The FCC “must carefully craft its rules to avoid unfairly burdening interconnected VoIP providers as compared to their traditional carrier competitors,” Twilio said. The Voice on the Net Coalition agreed, saying limitations would “run afoul of the original intended purpose of providing direct access” and “likely be impossible to enforce or administer.” The FCC didn’t comment Monday.

Some commenters said additional certifications to obtain direct access to numbering resources may be duplicative given existing robocall mitigation requirements. USTelecom, which acts as the industry-led traceback consortium, said the FCC should “instead focus on potential gaps” in its existing robocall mitigation framework. Additional certification requirements “will only serve to increase confusion about which rules apply, to whom, and in what circumstances,” the group said.

The proposed rules would “unfairly restrict providers of VoIP service,” said ATIS. It would “impose burdens on interconnected VoIP providers not applied to other direct access recipients without any record that the new rules would prevent robocalls or enhance network security,” VON said.

It’s “facially anti-competitive and would be onerous to administer,” said RingCentral, Telnyx and Vonage. “Unduly burdening VoIP direct access will only serve to disincentivize it and cause more providers to obtain numbers on the secondary market instead of directly,” the providers said. Additional regulation “would ignore the potential for misuse of numbers obtained by LECs,” the providers said: “Pursue a competitively neutral solution that targets the problems themselves.”

Others backed the proposed rules and suggested more scrutiny of providers seeking direct numbering access. Establish “more robust review procedures” for granting access, said Bandwidth. Additional requirements are “necessary and appropriate” to reduce illegal spoofing and traffic pumping and the FCC “cannot expect the industry to entirely self-regulate against bad actors effectively.” More explicit guidance on what constitutes an illegal robocall is needed, said the Electronic Privacy Information Center and National Consumer Law Center, asking that “know your customer” requirements “only apply to commercial callers.”

Some CLECs and VoIP providers “identified what they perceive to be loopholes” to access stimulation rules, said AT&T. It asked that additional language be added to the definitions of “end user” and “end office” to “ensure that VoIP providers ... do not gain a competitive advantage over LECs.” AT&T said the FCC should “re-affirm that it will invoke its enforcement authority” because complaints can't be filed against VoIP providers due to their lack of common carrier status.