Groups Clash on Direct Numbering Access Proposals

Industry and consumer groups disagreed in comments posted Thursday in docket 20-67 on whether certain certification and disclosure requirements would hinder efforts to strengthen the FCC's direct numbering access authorization process. Commissioners sought comment in a Further NPRM adopted during the agency's September meeting proposing to impose new rules on interconnected VoIP providers seeking direct access (see 2309210055).

Verizon applauded the proceeding, calling the proposed rules "an appropriate and necessary means to protect consumers by ensuring that parties with access to numbering resources are appropriately qualified and accountable." The carrier backed requiring interconnected VoIP providers applying for direct access to provide additional certifications and compliance documents. "Any provider in the position of providing service and distributing numbers to end users should be able to meet these baseline qualifications," Verizon said, adding the FCC should ensure it doesn't "create unnecessary paperwork and recordkeeping regimes" when structuring how it verifies a direct access applicant's qualifications.

Expand the proposed requirements to include VoIP providers with preexisting authorization and revive the agency's audit program, said Electronic Privacy Information Center and Consumer Action in joint comments. The groups urged the FCC to "prohibit use of rotating [telephone numbers] in outbound calls, hold the direct access authorized VoIP providers liable for downstream misuse of their numbering resources, and revoke authorization where appropriate."

Numeracle also backed expanding disclosure requirements to existing interconnected VoIP direct access authorization holders. "Aligning the requirements across existing and future authorization holders is necessary to ensure competitive neutrality and for enforcement practicality," the company said. It would also "create a uniform understanding of the information reviewed by the commission prior to approval," Numeracle said.

The Cloud Communications Alliance raised several concerns. Requiring that providers collect detailed ownership disclosures from their wholesale numbering customers "may hinder access to telephone numbers" and "violate competitive and technology neutrality principles," CCA said. The group also reiterated its concern about requiring that VoIP providers update the FCC when there is "any change" in ownership information. "Access to telephone numbers is the lifeblood of voice (and texting) communications," CCA said, adding that the proposed information collection and disclosures "may well chill the market for number access." Telnyx also had "significant" concerns about requiring that indirect access recipients share certain information with their voice service providers. "How these new requirements will materially improve the fight against fraudulent activities remains unclear," Telnyx said, adding that VoIP providers are "already deeply engaged in robust anti-fraud measures."

The proposals "would impose significant burdens without addressing the root of the problem," said USTelecom, suggesting the FCC instead "look to its robocall mitigation tools to address bad actors gaining access to numbers." The group said any certification required from indirect access recipients should be narrower by requiring that direct access holders "require their customers to cooperate with number traces." It also backed mirroring existing robocall mitigation requirements. "Adopting streamlined, efficient requirements modeled on existing approaches will go far to address this problem without imposing undue burdens on providers," USTelecom said.