On September 26, 2025, Somos, Inc. filed a Petition for Rulemaking urging the FCC to overhaul its numbering administration and routing rules to reflect the realities of today's IP-based communications environment (for a copy of the Petition, please contact Jonathan S. Marashlian at jsm@commlawgroup.com).
Background
Telephone numbers remain the essential identifiers for U.S. communications traffic, yet the administration of numbering resources still relies on decades-old databases and processes designed for a legacy, circuit-switched environment. Current systems—including the North American Numbering Plan (NANP), the Local Number Portability Administration Center (NPAC), and the Local Exchange Routing Guide (LERG)—operate in silos, each overseen by different administrators and governed by outdated regulatory frameworks.
According to Somos, this fragmentation not only imposes significant costs on carriers, but also creates vulnerabilities increasingly exploited by cybercriminals. The rise of AI-driven robocalling and spoofing schemes highlights how legacy systems hinder effective call authentication and traceback.
The Petition
Somos asks the FCC to:
- Retire the LERG and replace it with a Commission-overseen IP routing guide, eliminating reliance on an unregulated, monopoly-administered database.
- Consolidate NANPA and LNPA functions into a single administrator under one government contract, creating a unified numbering and portability database.
- Update the FCC's numbering rules to reflect modern IP-based networks, phasing out geographic and switch-based assumptions that no longer apply.
The petition emphasizes that consolidation and modernization would:
- Reduce duplicative costs that carriers currently shoulder for multiple administrators;
- Simplify regulatory compliance and reduce administrative burdens;
- Enhance network security and improve the effectiveness of anti-robocall tools like STIR/SHAKEN; and
- Better prepare U.S. numbering systems for future innovations, including AI-powered services and emerging communications technologies.
Industry Implications
The SOMOS petition raises fundamental questions about the future governance of numbering resources. If the FCC initiates a rulemaking, providers should anticipate:
- Closer FCC oversight of critical numbering and routing functions currently administered by private entities;
- Potential cost reallocation, as consolidation of databases could change how carriers fund numbering administration;
- Operational changes in how carriers obtain numbers, port numbers, and route traffic, with an eventual shift away from legacy TDM-based systems; and
- A greater emphasis on security and accountability in numbering policy, aligned with the FCC's broader anti-robocall and AI oversight initiatives.
For competitive carriers, VoIP providers, CPaaS platforms, and any business dependent on efficient number administration, these reforms could streamline operations but also require investment in compliance and systems integration during the transition.
Momentum Toward an "All-IP" Transition
The SOMOS filing is not occurring in isolation. Industry observers note a growing momentum pushing the FCC toward policies that accelerate the retirement of TDM (time-division multiplexing) networks and transition to an "All-IP" environment. Despite decades of progress, many incumbent local exchange carriers (ILECs), including the nation's largest, still rely on TDM tandem switches to route calls. This legacy infrastructure creates inefficiencies, hinders innovation, and perpetuates vulnerabilities in numbering and routing systems.
Stakeholders like Bandwidth, supported by counsel at Cooley LLP, have been active in advocating for modernization measures, emphasizing the need for reforms that reduce dependence on outdated TDM-based tandem interconnection. Additionally, the Coalition for IP Transition, headed by Rob Jackson of Marashlian & Donahue, PLLC, The CommLaw Group, has been a leading voice in urging the FCC to adopt policies that expedite the migration to all-IP frameworks. The Coalition's filings in WC Docket No. 24-445 illustrate both the technical case and the competitive rationale for this transition.
Taken together, the SOMOS petition and these industry efforts suggest the FCC may be positioning itself for more aggressive action—potentially mandating or incentivizing accelerated retirement of TDM switching, while ensuring numbering, routing, and interconnection policies fully align with an IP-based future.
Conclusion
The SOMOS Petition underscores a pivotal moment for U.S. numbering policy. As networks rapidly transition to IP, the FCC faces mounting pressure to modernize outdated frameworks that no longer align with industry practices—or with consumer protection needs in an era of AI-enabled fraud.
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