The Wireline Competition Bureau has issued a Public Notice seeking comment on a Petition for Declaratory Ruling filed by Far Homes, Inc. d/b/a Tin Can. Tin Can asks the Commission to declare that its restricted, whitelisted PSTN access service is not “interconnected VoIP” for purposes of the VoIP-related provisions of Title II; in the alternative, Tin Can requests a targeted waiver. Tin Can also commits to meeting 911/E911 obligations for its whitelisted offering.
Why this matters
Although styled as a narrow ruling, Tin Can’s ask could become a template for similarly situated providers to seek reduced federal and state obligations—with potential knock-on effects for USF contribution exposure and the scope of state PUC authority (e.g., CPUC) over I-VoIP-like services. The Commission’s framing, limiting principles (if any), and conditions will determine whether this stays narrow—or becomes a door through which a truck can be driven.
The irony isn’t subtle
Tin Can argues that existing FCC rules are onerous, complex, and burdensome and asks to be exempted. The FCC is engaging on that request now. Meanwhile, when the established cloud communications industry has raised the same “excessive and complex patchwork” concern about divergent state PUC regulation of I-VoIP—and asked the FCC to reaffirm Vonage preemption—the agency has not acted with similar urgency. In short, the Commission appears ready to consider an exemption that could further thin the USF contribution base and create another pathway around regulation, yet it has not moved to provide equal clarity by reaffirming preemption and curbing state overreach. (That contrast should be front-and-center in industry comments.)
Issues to brief in comments
- Classification & scope: Precisely what service attributes remove Tin Can from the I-VoIP definition, and how are those attributes cabined to avoid broad precedent?
- Conditions/guardrails: If any relief issues, what reporting, sunset, or use-case limits prevent spillover to unrelated models?
- USF & competitive neutrality: Would re-classification/waiver shift contribution burdens onto non-exempt rivals; how should the FCC address base erosion?
- State interplay: If Tin Can is not I-VoIP (or gets relief), what are the implications for state PUC jurisdiction (e.g., CPUC) and for Vonage preemption clarity?
Key dates & filing mechanics
- Comments: October 16, 2025
- Reply Comments: October 31, 2025
- File via ECFS in WC Docket No. 25-288 (permit-but-disclose proceeding).
Call to action
Providers whose offerings resemble Tin Can’s—or whose competitive position could be affected by a carve-out—should strongly consider filing to (1) cabin any relief to truly narrow, verifiable facts, and (2) press the FCC to pair any action here with long-overdue clarity reaffirming Vonage preemption to halt expanding state-level regulation of I-VoIP.
For questions or to coordinate participation, contact Jonathan S. Marashlian at jsm@commlawgroup.com.