NARUC Draft Would Conserve Phone Numbers Through Audits

Mitigating practices that could speed the country toward phone number exhaustion is a priority item for state officials ahead of NARUC’s Feb. 25-28 meeting in Washington, commission officials told us. The state utility regulator association is planning a vote during the meeting on a proposed resolution from Telecom Committee Chair Tim Schram. It urges the FCC “to provide updated guidance on how states should bring forward cases of telephone number resource mismanagement or suspected robocalling using rented telephone numbers to the Commission using the audit process” from Section 52.15(k) of the Telecom Act.

“We’re continuing to look at ways to conserve numbers” and “get more accountability that the numbers are going for the right use,” Schram said during an interview Friday. Numbers are “a national resource,” the Republican from the Nebraska Public Service Commission said. While rules should be federal, having states police their area codes would be the most efficient way to keep carriers accountable, said Schram. The FCC should supply some parameters including what is allowed and prohibited uses of numbers, he added.

It's also to good-actor carriers' "benefit that the numbering pool is preserved as long as possible,” said Schram: The U.S. could switch to 12-digit dialing, but that would be a “tremendous cost for the industry.” NARUC’s draft resolution cites an FCC estimate that such a move would “have a societal cost of up to $270 billion.”

The U.S. is expected to run out of phone numbers by 2051, or possibly sooner, noted the draft. At the same time, it said, state commissions report telecom carriers failing to comply with numbering rules, including many that “fail to fulfill basic reporting requirements, over-inflate the forecasted need for telephone numbers, and use blocks of thousands of numbers inefficiently, contaminating them for future use by another carrier.” Some carriers “are knowingly facilitating illegal robocalling and circumventing FCC rules by renting finite telephone numbering resources to wholesale telecommunications customers who are often located outside of the United States,” said the draft: Robocallers use those local numbers for caller ID spoofing.

“State commissions, through their ongoing review of numbering resource requests from telecommunications carriers, are in a unique position to identify inefficient, unusual, or bad behavior from telecommunication carriers with direct access to numbering resources,” the draft resolution said. Meanwhile, the FCC hasn’t audited a telecom carrier “in at least a decade,” it said. “State commissions need more tools and resources available to them as the regulatory outpost of the FCC to enforce both state and federal numbering rules.”

Maine Public Utilities Commission staffers helped draft the resolution and plan on speaking during a NARUC Telecom Staff Subcommittee panel Sunday about steps the northeastern state has taken to conserve numbers, a Maine PUC spokesperson said. One staffer said in September that a proposal to consolidate rate centers could be a model for the entire U.S. (see 2309220060). Other recent Maine PUC efforts that slow number exhaustion include investigations into T-Mobile and Verizon Wireless numbering practices (see 2207130042).

“Many providers appear to be breaking a variety of FCC rules ranging from how they are forecasting the need for numbers to then using those numbers in a manner that is wasteful,” the Maine PUC spokesperson said. “Still other providers seem to be engaging in the facilitation of robocalling by ‘renting out’ telephone numbers to robocallers to avoid new anti-robocalling rules. States like Maine are seeking better guidance on how to enforce the rules that are in place and hope that the FCC can provide greater guidance on how existing, but under-used rules such as audits may be applied.”

"Numbers represent a trusted identity and are a vital communications resource," said Somos Chief Administrative Officer Ann Berkowitz. Somos is the North American numbering plan administrator. "We are encouraged by the increased dialogue around numbering resources and look forward to working closely with NARUC and the individual states on the critically important issues."

The Competitive Carriers Association “supports efforts to stop unwanted robocalling and improve the efficiency and longevity of the nations’ numbering resources,” said President Tim Donovan in a written statement. “In addition to supporting the recommendations in NARUC’s draft resolution, CCA encourages policymakers to consider how implementing nationwide number portability could disincentivize fraudulent use of numbers and delay the need for 12-digit dialing.” Other industry groups including USTelecom, CTIA and NTCA didn’t comment.