Onvoy Spectrum, LLC has filed a petition with the FCC requesting a waiver of the Commission’s numbering rules so that it can deploy a a 911/E911 solution for non-voice/data only mobile devices that operate in WiFi mode, such as tablets and certain CMRS devices that are set to operate in WiFi-only mode. The waiver request follows successful testing of Onvoy’s 911/E911 solution developed for over-the-top (OTT) mobile services that are delivered over WiFi networks. Onvoy’s 911/E911 solution relies on the use of pseudo automatic numbering identification codes (p-ANI) administered by Neustar. According to Onvoy, Neustar has rejected Onvoy’s request for p-ANIs because the company does not have registered wireless towers in each of the counties in which it desires to obtain p-ANI resources. Neustar has used that fact to conclude that Onvoy cannot qualify for numbering resources because the company is not “capable of providing service” as required by Section 52.15(g)(2) of the FCC’s rules. Onvoy argues that while the tower requirement might make sense in the context of traditional mobile services, it is inapplicable to OTT mobile applications that rely on WiFi services made available by other providers. Onvoy argues that grant of its requested waiver will serve the public interest by expanding the availability of 911 services to a growing number of users that depend solely on WiFi networks for their communications.