Vonage presses its case for direct access to numbering resources for VoIP services

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Vonage (NYSE: VG), the nation's largest Internet-based telephony company, reiterated to federal regulators last week why the company should be granted a waiver allowing direct access to numbering resources for IP-enabled services.

Strandberg

The Holmdel Township, N.J.-based communications-services provider, in a letter to the Federal Communications Commission, urged the FCC to grant the company's petition for a limited waiver of the Commission's Rules Regarding Access to Numbering Resources.

With a so-called Section 52.15(g)(2)(i) waiver, Vonage would be able to obtain numbering resources directly from the North American Numbering Plan Administrator (NANPA) for use in deploying IP-enabled telephony, including Voice over Internet Protocol (VoIP) services.

Granting its pending Petition for a Limited Waiver would, overall, advance the FCC's stated policy goals of "fostering innovation and speeding the delivery of advanced services to consumers," Vonage Holdings Corp.'s June 27 letter reads.

"With direct access to numbers, Vonage hopes to reduce the number of hand-offs involved in a Vonage call, thereby improving call quality, reducing delay, and eliminating opportunities for routing errors," Brita Strandberg, counsel to Vonage Holdings Corp., wrote to the commission.

She argued further that allowing the company direct access to NANP telephone numbers would eliminate a "significant barrier" to IP interconnection. Moreover, a rule waiver would ease the transition to bill-and-keep arrangements for intercarrier compensation.

For Vonage itself, the rule waiver would allow the company to deliver "new and innovative services" to customers and provide better service quality, at a reduced cost, wrote Strandberg, partner at Wiltshire & Grannis LLP.

Also, she noted, states would be able to better monitor and manage number use. For its part, though, the National Association of Regulatory Utility Commissioners (NARUC) 20-member board of directors, in February, adopted a resolution calling on the FCC to issue a Notice of Proposed Rulemaking to address the Vonage and other similar waiver requests.

Moreover, competitive local exchange carriers remain opposed to allowing any interconnected VoIP provider to obtain NANP numbers by waiver.

They warn "amplified regulatory confusion" and accelerated number exhaustion would result from a limited waiver of the Commission's Rules Regarding Access to Numbering Resources. codified at 47 C.F.R. § 52.15(g)(2)(i).

At a June 11 meeting with FCC Commissioner Jessica Rosenworcel's wireline legal adviser, counsel representing CLECs Level 3 Communications (Nasdaq: LVLT) and Bandwidth.com and the industry lobby COMPTEL, argued that a rule waiver would be "discriminatory" since it would generally afford "carrier rights to certain non-carriers that do not also shoulder carrier obligations."

In her five-page letter to the commission, Vonage attorney Strandberg dismissed the CLEC argument from counsel James Falvey that Vonage's requested relief is discriminatory.

"Granting a waiver that serves the public interest is not discriminatory for the simple reason that all parties in a similar position are free to request similar relief," Strandberg wrote, noting that in January 2005 the commission granted SBC Internet Services (SBCIS) a limited waiver for direct number access (Administration of the North American Numbering Plan, Order, 20 FCC Rcd. 2957).

"The Commission recognized as much when it invited petitions from providers like Vonage that sought the same relief the Commission granted to SBCIS," she continued. "Bandwidth's recent request for its own waiver merely confirms the appropriateness of Vonage's request." 

Telecom behemoths Verizon Communications (NYSE: VZ) and AT&T (NYSE: T) have said VoIP carriers should be allowed direct access to numbering resources so long as VoIP providers follow the same rules as other carriers when it comes to the FCC's broader numbering rules, including those related to number portability.

The petition before the FCC Common Carrier Bureau is Vonage Holdings Corp. Petition for Limited Waiver of Section 52.15(g)(2)(i) of the Commission's Rules Regarding Access to Numbering ResourcesCC Docket No. 99-200 (March 4, 2005).

For more:
 - read the Vonage ex parte notice
 - read the CLEC ex parte letter
 - see the NARUC resolution (.pdf)

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