On July 22, 2015, the Federal Communications Commission (“FCC”) published a Notice in the Federal Register seeking Paperwork Reduction Act (“PRA”) comments on the information collection requirements adopted last month permitting Interconnected VoIP (“I-VoIP”) providers to obtain numbers directly from the Numbering Administrators, rather than through intermediaries.  PRA comments must be filed with the FCC no later than September 21^st.

The June 22^nd Order details the policies and procedures adopted by the FCC governing I-VoIP providers’ ability to obtain direct access to numbers.  First, an I-VoIP provider must obtain FCC authorization in order to demonstrate to the Numbering Administrators that the I-VoIP provider is authorized to provide such services.  Then, following the receipt of FCC authorization, the I-VoIP provider must give 30 days advance notice to the states from which it intends to request numbers.  Finally, after waiting 30 days, the I-VoIP provider may directly access numbers from the Numbering Administrators in accordance with their specific policies and procedures governing such acquisitions.

The FCC also set forth various conditions for ensuring the stability of the numbering system.  These new requirements include, among others, Numbering Resource Utilization and Forecasting (“NRUF”) reporting requirements for I-VoIP providers.

Finally, the Order permits VoIP Positioning Centers (“VPCs”) offering E911 services to obtain pseudo-Automatic Number Identification (“p-ANI”) codes in states where a VPC has been unable to obtain state certification.

We invite clients who are interested in filing PRA comments, or receiving a detailed summary of the Commission’s I-VoIP Numbering Order and the new rules governing I-VoIP provider’s direct access to numbers, to contact the attorney assigned to their account or Michael P. Donahue at mpd@commlawgroup.com.