On October 31, 2012, Bandwidth.com, Level 3, and COMPTEL (the “CLEC Coalition” or “Coalition”) filed a letter with the Commission in response to an ex parte filing made by Vonage on October 22, 2012 concerning Vonage’s Petition for Limited Waiver of Section 52.15(g)(2)(i) to obtain direct access to numbering resources.

In anticipation of intercarrier compensation reform and the transition to IP networks, Vonage’s ex parte letter and petition sought direct access to numbering resources in order to prepare for the expected shift in the marketplace for wholesale services, arguing that the carriers opposing this request, including the CLEC Coalition, are merely doing so to delay the evolution of Vonage’s network and that the CLEC Coalition should, instead, embrace this opportunity to compete for services. Vonage alleges that the waiver would (1) serve the public interest in facilitating IP to IP interconnection, (2) improve service quality, (3) allow Vonage to provide new services, and (4) reduce costs for VoIP customers, all without substantially impairing the CLEC Coalition.

The CLEC Coalition, however, argues otherwise. In its letter, the CLEC Coalition argues that Vonage’s argument—that such a waiver would only have a limited impact on the revenues of the carriers with whom Vonage purchases its services from (e.g., the CLEC Coalition)—is a fallacy. The Coalition maintains that it would be discriminatory to provide Vonage, a non-carrier, with direct access to telephone numbering resources, a carrier privilege, without first requiring Vonage to comply with carrier obligations. Furthermore, the Coalition alleges that granting Vonage access to numbering resources through a waiver process as opposed to through a rulemaking proceeding would not only prejudice the ultimate outcome, but it would stifle sufficient deliberations and create unpredictability on how to handle future requests. The Coalition concluded its letter by encouraging the Commission to address these issues in new or existing rulemaking proceedings.