Re: [WISPA] FW: FCC Adopts Order to Combat Rural Call Completion
So not only are the rural telcos getting tens of thousands of dollars per line, but they can't properly complete a call? - Mike Hammett Intelligent Computing Solutions http://www.ics-il.com - Original Message - From: Douglas A. Hass d...@franczek.com To: WISPA General List (wireless@wispa.org) wireless@wispa.org Sent: Monday, October 28, 2013 2:39:10 PM Subject: [WISPA] FW: FCC Adopts Order to Combat Rural Call Completion NTCA—The Rural Broadband Association Advocacy Interesting order today by the FCC…Links in the press release below. Douglas A. Hass Associate 312.786.6502 d...@franczek.com Franczek Radelet P.C. 300 South Wacker Drive Suite 3400 Chicago , IL 60606 312.986.0300 - Main 312.986.9192 - Fax http://franczek.com Franczek Radelet is committed to sustainability - please consider the environment before printing this email. Circular 230 Disclosure: Under requirements imposed by the Internal Revenue Service, we inform you that, unless specifically stated otherwise, any federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purposes of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or tax-related matter herein. For more information about Franczek Radelet P.C., please visit franczek.com. The information contained in this e-mail message or any attachment may be confidential and/or privileged, and is intended only for the use of the named recipient. If you are not the named recipient of this message, you are hereby notified that any dissemination, distribution, or copying of this message or any attachment thereto, is strictly prohibited. If you have received this message in error, please contact the sender and delete all copies. From: NTCA–The Rural Broadband Association [mailto:communicati...@ntca.org] Sent: Monday, October 28, 2013 2:32 PM To: Hass, Douglas A. Subject: FCC Adopts Order to Combat Rural Call Completion FCC Adopts Order to Combat Rural Call Completion October 28, 2013 Earlier today, the FCC adopted by unanimous vote a report and order and further notice of proposed rulemaking (FNPRM) to address problems associated with completion of long-distance calls to rural areas. Although NTCA–The Rural Broadband Association is still reviewing the order and FNPRM, it appears that both actions represent positive developments for rural consumers and their loved ones who have suffered the frustration or fear of a call not completing, lost business or endured public safety concerns because of circumstances beyond their control. The passage of the order and FNPRM also mark an important milestone in NTCA’s nearly three-year campaign to find a solution to this problem. That campaign has included numerous meetings with FCC staff, several Capitol Hill briefings, call completion test projects conducted with our rural allies and a successful effort by Sen. Tim Johnson (D–S.D.) to seek swift action via a letter to the commission that won the support of more than 30 senators earlier this year. In a statement accompanying the order issued today, Commissioner Ajit Pai credited NTCA and three other organizations for collaborating with the commission to seek a solution to the problem. Acting FCC Chairwoman Mignon Clyburn and Commissioner Jessica Rosenworcel also expressed support for the action. In particular, today’s action: • Requires that providers with more than 100,000 lines that make the initial choice as to how to route a call collect and retain data for six months and file quarterly reports. • Prohibits the practice of false audible ringing (a type of signaling that leads the calling party to believe the phone is ringing at the called party’s premises when it is not). • Allows providers taking advantage of the safe harbor, which incorporates an industry best practice to limit the number of intermediate long-distance providers to two, to receive reduced data retention and reporting obligations. • Gives providers the option of requesting individual waivers to have their retention and reporting obligations further reduced by adopting practices to ensure calls to rural areas are completed. NTCA Chief Executive Officer Shirley Bloomfield released the following statement in response to the FCC’s actions: “NTCA first brought the troubling occurrence of rural call failures and other call completion issues to the FCC’s attention nearly three years ago. We are grateful to Chairwoman Clyburn for making resolution of this epidemic a priority during her tenure, to Commissioners Pai and Rosenworcel for pressing for common-sense and effective solutions, and to the agency’s staff for their hard work in seeking answers to
Re: [WISPA] FW: FCC Adopts Order to Combat Rural Call Completion
On 10/28/2013 3:55 PM, Mike Hammett wrote: So not only are the rural telcos getting tens of thousands of dollars per line, but they can't properly complete a call? The problem is/was that they are perfectly capable of completing calls that reach them, but instead of sending calls to them directly via LD providers, calls were being handed off, by the originating carriers, to VoIP long distance providers who handed them off to other VoIP long distance providers... and the call often didn't go through, or went through with inadequate call quality. Some funny games have been played with arbitrage, trying to get around high rural-carrier switched access rates. The PSTN and Internet legal/business models are quite different, albeit complementary. In the Internet model, interconnection is all voluntary, and you can relay the packet through as many intermediaries as it takes, and it's all best efforts or blocked. It's not common carriage. The PSTN model, in contrast, is mandatory interconnection and delivery of calls at regulated intercarrier rates. (These are higher for small rural carriers than for large or urban carriers.) Rural call completion became a problem when people with Internet experience tried to game the PSTN to lower the cost per minute. -- Fred R. Goldstein k1io fred at interisle.net Interisle Consulting Group +1 617 795 2701 ___ Wireless mailing list Wireless@wispa.org http://lists.wispa.org/mailman/listinfo/wireless
Re: [WISPA] FW: FCC Adopts Order to Combat Rural Call Completion
So they just chose poor VoIP upstreams? - Mike Hammett Intelligent Computing Solutions http://www.ics-il.com - Original Message - From: Fred Goldstein fgoldst...@ionary.com To: wireless@wispa.org Sent: Monday, October 28, 2013 3:11:20 PM Subject: Re: [WISPA] FW: FCC Adopts Order to Combat Rural Call Completion On 10/28/2013 3:55 PM, Mike Hammett wrote: So not only are the rural telcos getting tens of thousands of dollars per line, but they can't properly complete a call? The problem is/was that they are perfectly capable of completing calls that reach them, but instead of sending calls to them directly via LD providers, calls were being handed off, by the originating carriers, to VoIP long distance providers who handed them off to other VoIP long distance providers... and the call often didn't go through, or went through with inadequate call quality. Some funny games have been played with arbitrage, trying to get around high rural-carrier switched access rates. The PSTN and Internet legal/business models are quite different, albeit complementary. In the Internet model, interconnection is all voluntary, and you can relay the packet through as many intermediaries as it takes, and it's all best efforts or blocked. It's not common carriage. The PSTN model, in contrast, is mandatory interconnection and delivery of calls at regulated intercarrier rates. (These are higher for small rural carriers than for large or urban carriers.) Rural call completion became a problem when people with Internet experience tried to game the PSTN to lower the cost per minute. -- Fred R. Goldstein k1io fred at interisle.net Interisle Consulting Group +1 617 795 2701 ___ Wireless mailing list Wireless@wispa.org http://lists.wispa.org/mailman/listinfo/wireless ___ Wireless mailing list Wireless@wispa.org http://lists.wispa.org/mailman/listinfo/wireless
Re: [WISPA] FW: FCC Adopts Order to Combat Rural Call Completion
On 10/28/2013 4:33 PM, Mike Hammett wrote: So they just chose poor VoIP upstreams? Poor quality ones, yes. Under current rules, being VoIP doesn't waive switched access rates. Until the FCC ruled in late 2011 that VoIP termination was subject to interstate access (even on intrastate calls, where access rates were allowed to be higher until this year), many VoIP providers assumed that they were exempt, and the Bells usually went along with it. But the rurals usually didn't, so there was no safe legal way to deliver calls cheaply to the rurals. But small VoIP providers tried anyway. And they charged less per minute than legit providers, so originating carriers chose them in their LCR tables. And if the call didn't go through at all, well, the call was unprofitable anyway. So this may have to some extent been a way to get around the rule of universal call completion. You make an effort to complete the call but do it badly enough so that it often fails... and if your customer really needs to call that location, they switch to another carrier. Which is fine since they're probably a negative-margin customer. Remember, FCC rules require that *retail* long distance rates be averaged (costs the same to call a rural as an urban carrier), but wholesale rates vary (reflecting different call termination charges). fgThe problem is/was that they are perfectly capable of completing calls that reach them, but instead of sending calls to them directly via LD providers, calls were being handed off, by the originating carriers, to VoIP long distance providers who handed them off to other VoIP long distance providers... and the call often didn't go through, or went through with inadequate call quality. Some funny games have been played with arbitrage, trying to get around high rural-carrier switched access rates. The PSTN and Internet legal/business models are quite different, albeit complementary. In the Internet model, interconnection is all voluntary, and you can relay the packet through as many intermediaries as it takes, and it's all best efforts or blocked. It's not common carriage. The PSTN model, in contrast, is mandatory interconnection and delivery of calls at regulated intercarrier rates. (These are higher for small rural carriers than for large or urban carriers.) Rural call completion became a problem when people with Internet experience tried to game the PSTN to lower the cost per minute. -- Fred R. Goldstein k1io fred at interisle.net Interisle Consulting Group +1 617 795 2701 ___ Wireless mailing list Wireless@wispa.org http://lists.wispa.org/mailman/listinfo/wireless ___ Wireless mailing list Wireless@wispa.org http://lists.wispa.org/mailman/listinfo/wireless -- Fred R. Goldstein k1io fred at interisle.net Interisle Consulting Group +1 617 795 2701 ___ Wireless mailing list Wireless@wispa.org http://lists.wispa.org/mailman/listinfo/wireless
