Groups Seek Strong Action on Numbering Access Authorizations

A coalition of consumer advocates said the FCC's proposals "do not go far enough" in addressing numbering access. The commission should "take unambiguous action to address the problems caused by service providers who rent telephone numbers to robocallers on a temporary basis," the coalition said. Signing were the National Consumer Law Center, Consumer Action, Consumer Federation of America, Electronic Privacy Information Center, National Association of Consumer Advocates, National Consumers League and U.S. Public Interest Research Group. There is "no legitimate need for the temporary rental of outward dialing numbers," the coalition said, noting the docket had no comments justifying the practice.

Direct the North American Numbering Plan Administration (NANPA) to deny applications for direct access if an applicant's authorization would present a "material security concern" rather than suspend pending and future requests, said ATIS. Doing so "would be less complicated for NANPA to implement from an operational perspective" and "eliminates the need to track suspended applications," it added. ATIS also backed requiring all applicants to provide a list of states where they initially plan to request resources. It would give states and NANPA "more awareness of new entrants and how those new entrants' numbering requests may impact demand," it said.

"Numbers cycling through aging are typically associated with customer disconnects, but a high volume of numbers in aging may also suggest that some providers are renting or rotating numbers to bad actors," said the Maine Public Utilities Commission. The PUC backed adopting a requirement that existing direct access authorization holders comply with any new rules. State commissions should also "be encouraged to request an audit of a service provider when appropriate to help stop bad behavior," the PUC said. It added that state offices are "a regulatory outpost of the commission" with "the capability and incentive to enforce numbering rules and laws."

The Voice on the Net Coalition raised concerns about the proposal. It's "replete with unnecessary proposed rules," VON said, noting the "most egregious" requires direct access authorization holders that sell telephone numbers to a voice service provider to obtain the same documentation from the provider as though it applied for numbering resources itself. The FCC "fails to recognize that direct access and indirect access recipients are competing for customers," the group said. Moreover, indirect access recipients "may look askance at providing what may be perceived as business sensitive confidential information."

The proposal is "unnecessary and administratively burdensome," said NetNumber. Instead, it encouraged the FCC to utilize its robocall mitigation database to ensure interconnected VoIP providers with direct access have a "sufficient robocall mitigation plan on file" to obtain direct access. CTIA urged the agency continue its auditing and enforcement efforts to assist interconnected VoIP direct access authorization holders in vetting indirect access recipients before selling or leasing numbers to them. "Removing facially deficient filings from the RMD is the first line of defense to ensure that the bad actors cannot originate illegal and unwanted robocalls on the domestic telephony network," CTIA said.