But day-to-day management of the North American Numbering Plan — and responsibility for doling out numbers to carriers — rests with the North American Numbering Plan Administrator and the National Pooling Administrator. Carriers with enough customers have traditionally had to obtain FCC or state licenses, or an FCC waiver, before they have been allowed to delegate their own numbers.
But many "small nomadic" VoIP providers haven't obtained licenses from either states or the FCC, but instead directly petitioned the FCC for a waiver, NARUC said in its request. NARUC's request for rulemaking is a result of those petitions, it said.
The request also maintains that unlicensed carriers need to be subjected to some sort of regulation, which is why NARUC has asked the FCC to step in.
Vermont Public Service Board Commissioner John Burke, who chairs the NARUC telecommunications committee whose resolution resulted in the petition, told The Hill that the reason clearer regulations are needed isn't to deal with any sort of malfeasance; there aren't any companies that stand out as "bad actors" in the numbering process, which means that, ultimately, the push for FCC regulation is to ensure adequate transparency to conserve the number supply.
But he said that when "nomadic" or "over-the-top" VoIP carriers like Vonage, MagicJack and their smaller brethren (as opposed to fixed VoIP carriers like Comcast) "piggyback" onto the number allocations of larger companies, they don't participate in record-keeping systems. This keeps authorities from being able to know important things such as which "rate centers" the carriers are operating in, and how many numbers from a given bundle have actually been allocated.
Different states have different-sized bundles based on population, so while Washington, D.C., might allocate bundles of 10,000, Vermont would likely allocate a bundle one-tenth that size. This means a VoIP carrier with a small customer base in D.C. could theoretically control a bundle of 10,000 numbers but only use 1,500 of them. Without uniform regulations to ensure transparency, not even the larger company that had originally been assigned the bundle would have a way of knowing so many numbers were being left over.
The situation could be a consequence of NARUC's desire to be technology-neutral by not denying VoIP providers access to numbers, Burke said, which makes it unfortunate that VoIP has so undermined conservation efforts.
Mistakes in number conservation can have real-world consequences, Burke said. A small business that is forced to adopt a new area code as a result of a number shortage can lose a significant amount of money to updating printed material such as stationary and business cards, he noted. Keeping better track of numbers could keep situations like that from occurring.
"Conservation of numbers may seem pedestrian," he admitted, "but it's probably the single biggest concern that any of us [at NARUC] probably have."
—This post was updated at 4:16 p.m.