Washington Watch 10/25/2013
| October 25, 2013 | |
Contents
Open Meeting
FCC Issues Tentative Agenda for November 14 Open Meeting
Call Completion
NTCA, NECA Discuss Call Completion Data Requirements
NTCA Discusses Call Completion Data Collection, Retention Rules
Comcast Suggests Network Performance Metrics for Call Completion Order
USTelecom Discusses Approaches to Address Call Completion Issues
Indiana Commissioner Calls for Bold Enforcement Action on Rural Call Completion Problems
AT&T Discusses Call Completion Data Retention, Safe Harbors
Frontier Urges FCC to Consider Cost Burden of Proposed Call Completion Rules
Vonage Requests Time Be Granted in Call Completion Order to Change Network Call Tones
USF/ICC Transformation Order
Congressional Members Express Concern With QRA Caps
Adak Eagle, Windy City File Information in Connection With Requests for Review/ Reconsideration of USF Caps
NECA Files Average Schedule to Cost Company Conversion Dates
Intercarrier Compensation
Northern Valley Discusses AT&T Access Charge Dispute With FCC
Broadband
USDA Announces Awards for Broadband Projects in Unserved Rural Areas
Numbering
Vonage Files Third Report on VoIP Numbering Trial
Relay Services
Purple Communications Replies to Comments on its Clarification Request of IP CTS Rules
Open MeetingFCC Issues Tentative Agenda for November 14 Open Meeting The FCC issued the tentative agenda for its November 14, 2013 Open Meeting. The Wireline Competition Bureau, Wireless Telecommunications Bureau, and Office of Native Affairs and Policy will present an update on universal service reform implementation. The FCC will also hear an update on the multiple public-private initiatives seeking to boost broadband adoption and digital literacy. The FCC will also consider a Declaratory Ruling to clarify the agency’s policies and procedures in reviewing broadcast applications for transfer of control or requests for declaratory ruling; and will consider a Report and Order to improve the reliability and resiliency of 911 communications networks nationwide.Call CompletionNTCA, NECA Discuss Call Completion Data Requirements NTCA and NECA discussed the proposed rules for record keeping and reporting obligations to address rural call completion with FCC staff on October 22, 2013. They addressed the benefits of requiring originating providers who meet the minimum threshold to report both the Call Answer Rate and the Network Effectiveness Ratio. They said comparisons of this more granular data should greatly enhance the ability to identify poor originating provider performance and would help the Commission determine if originating or intermediate providers are engaged in false or misleading signaling practices. NTCA Discusses Call Completion Data Collection, Retention Rules NTCA spoke via telephone with acting Chairwoman Clyburn’s Legal Advisor on October 24, 2013, to discuss proposed rules for data collection obligations to help resolve rural call completion problems. NTCA reiterated that obtaining robust call completion reports from originating carriers and VoIP providers will help set incentives for proper management of underlying providers and thus better call completion rates. It said, however, an Order must ultimately be paired with swift and effective enforcement and efforts to inject greater transparency into the intermediate providers market. NTCA made clear its objection to any “safe harbors” that are not “earned,” and noted its limited concurrence with Verizon’s recent ex parte regarding requirements to submit aggregate data and retain data on the completion of individual calls to rural locations, but not to require such data retention for non-rural calls. Comcast Suggests Network Performance Metrics for Call Completion Order Comcast spoke with Wireline Competition Bureau staff on October 23, 2013, to discuss Comcast’s position on the call completion performance metrics. Comcast explained the Commission should employ metrics that are designed to properly measure the ability of networks to deliver calls to the terminating location and exclude calls that are not relevant to an assessment of a carrier’s call completion performance. Comcast asserted that the Network Effectiveness Ratio is a more accurate measure of network performance than the Answer Seizure Ratio and generally explained the advantages of using the NER metric. USTelecom Discusses Approaches to Address Call Completion Issues USTelecom spoke with acting Chairwoman Clyburn’s Legal Advisor and staff members of the Wireline Competition and Enforcement Bureaus on October 23, 2013, to discuss rural call completion problems. USTelecom expressed concern the proposed Order may not lead to behavioral changes in the near future that would reduce uncompleted calls to rural exchanges, noting that because of the lengthy Paperwork Reduction Act approval process, it would likely take a long time before the FCC could actually begin enforcement investigations. USTelecom said wide-spread adoption of industry best practices is more likely to have an impact on call completion over the next two years than the proposed data collection approach, and discussed those in the ATIS Call Termination Handbook. Indiana Commissioner Calls for Bold Enforcement Action on Rural Call Completion Problems Larry Landis, Commissioner of the Indiana URC, sent a letter to acting Chairwoman Clyburn and Commissioners Pai and Rosenworcel on October 24, 2013, to emphasize the need for an immediate and forceful response to call completion problems, noting they can have a direct impact on the livelihood of individual businesses and on the overall economic climate of rural areas in Indiana and across the country. He highlighted an email message sent to the FCC by Mr. Lee VonGunten, General Manager of Craigville Telephone Company, on September 26, pointing out the backdrop for this email was one large business customer that informed Mr. VonGunten it could no longer accept not being able to receive calls from its customers and planned to move its telecom services "back to a large national carrier." He encouraged the Commission to take bold, additional enforcement action now, with significant penalties for both past and future infractions of the rules, and to move aggressively in seeking broad additional comment where the record is insufficient to allow immediate resolution. AT&T Discusses Call Completion Data Retention, Safe Harbors AT&T met with acting Chairwoman Clyburn’s Legal Advisor, staff members of the Wireline Competition and Enforcement Bureaus, and separately with Commissioner Pai’s Legal Advisor and Commissioner Rosenworcel’s staff on October 22, 2013, to discuss rural call completion. AT&T urged the Commission to maintain a safe harbor for providers like AT&T that adopt industry-leading practices and discussed the significant costs associated with the data retention requirements. AT&T also discussed concerns that adding processing complexity to legacy long distance switches could actually increase instances of call failure. Frontier Urges FCC to Consider Cost Burden of Proposed Call Completion Rules Frontier filed a letter with the FCC on October 24, 2013, to express support for the Commission’s efforts to ensure rural call completion, but reiterated that the Commission’s proposed record retention rules would prove technologically difficult and costly to implement and maintain. It noted cost estimates supplied by CenturyLink and AT&T, and said these estimates provide reasonable proxies of compliance costs if proportionately scaled to the size of each carrier. Frontier noted the Commission has on the record numerous proposals that would allow the Commission to take meaningful steps to ensure rural call completion without the significant cost impact of its proposed rules. Frontier encouraged the Commission to fully consider the cost burdens associated with its proposed rural call completion rules. Vonage Requests Time Be Granted in Call Completion Order to Change Network Call Tones Vonage had separate conference calls with Commissioner Pai’s Legal Advisor and the Wireline Competition Bureau’s Attorney Advisor on October 23, 2013, to discuss the pending call completion Order. Vonage emphasized that any new rules regarding the presentation of a “comfort ring” to calling parties should become effective no sooner than 90 days following the publication of the Order in the Federal Register. Vonage explained that while it presents callers with a “comfort ring” infrequently on domestic calls, any change in the call logic on a large scale must be done methodically and tested prior to deployment.USF/ICC Transformation OrderCongressional Members Express Concern With QRA Caps Congressional Members representing Wisconsin sent a letter to acting Chairwoman Clyburn on October 24, 2013, to express concern the Transformation Order is undermining the ability of small RoR Wisconsin carriers to provide rural consumers with the broadband service they need to compete in today’s global economy. They said one of the main causes of uncertainty and decline in investment is the FCC’s QRA approach to providing high-cost support for small carriers. They noted a recent study by former FCC Chief Economist Simon Wilkie shows the QRA cap fails to provide incentives for broadband deployment and actually generates the regulatory uncertainty that is discouraging investment. Adak Eagle, Windy City File Information in Connection With Requests for Review/ Reconsideration of USF Caps Adak Eagle Enterprises and Windy City Cellular filed a letter on October 23, 2013, to provide supplemental information in response to Wireline Competition Bureau staff questions in connection with their pending Petition for Reconsideration and Application for Review of the Order denying their Petitions for Waiver of the $250 per-line per-month cap on high-cost USF support. AEE and WCC said the waiver process has left them underfunded, understaffed, and on the brink of collapse, and said they do not have the resources to continue the costly cycle of providing more and more supplemental information when they already have provided exhaustive amounts of detailed information demonstrating they satisfy the waiver standard. They believe this supplemental information provides more than ample information for the Bureaus to reverse their denial. NECA Files Average Schedule to Cost Company Conversion Dates NECA filed a letter on October 24, 2013, at the FCC’s request, providing average schedule company to cost company conversion dates NECA has on record from the year 2000 and forward. NECA noted this file does not include data for companies that converted from rate of return to price cap.Intercarrier CompensationNorthern Valley Discusses AT&T Access Charge Dispute With FCC Northern Valley Communications met with staff members of the Wireline Competition Bureau on October 23, 2013, to discuss issues raised in AT&T’s September 2013 ex parte, including what NVC says is AT&T’s self-help withholding of payment and false allegations it engaged in a “mileage pumping” scheme. NVC claims the South Dakota Network differs markedly from the service the FCC considered in AT&T v. Alpine, and claims AT&T withheld from NVC all access charges for several months in its efforts to force Northern Valley to charge it below-tariffed rates for transport. NVC asserted while AT&T is now at least paying a modest amount of the access charges, it continues to withhold millions of dollars due to Northern Valley.BroadbandUSDA Announces Awards for Broadband Projects in Unserved Rural Areas The USDA issued a News Release on October 24, 2013, announcing 14 awards for projects to bring broadband to unserved rural communities. USDA is providing $20.3 million in grants through the Community Connect Grant program. USDA said these are the first awards made under the Community Connect program's new guidelines that now allow applicants to fund broadband infrastructure for more than one community and raise the minimum required speed to 5 Mbps.NumberingVonage Files Third Report on VoIP Numbering Trial Vonage filed a Third Report on its VoIP numbering trial on October 24, 2013, pursuant to the April 18, 2013 Order. Vonage provided information for the Atlanta and Boston markets, and noted for the Phoenix market it has not yet been able to reach agreement with CenturyLink, the relevant RBOC, to ensure routing of PSTN traffic to telephone numbers directly held by Vonage will work properly.Relay ServicesPurple Communications Replies to Comments on its Clarification Request of IP CTS Rules Purple Communications filed a Reply on October 23, 2013, to comments on its Petition seeking clarification of the statement in the June 10, 2013 Order that “calls that are completed using a technology that does not provide both inbound and outbound functionality are not compensable from the TRS Fund” does not apply when users access IP CTS through web and wireless services. Purple said the FCC should either clarify footnote 122 was not intended to apply to inbound web and wireless IP CTS calls, or if the FCC decides that footnote 122 does apply to such calls, clarify whether the inbound and outbound calls can operate on more than one technology.Editor: Teresa Evert | Assistant Editor: Shawn O'Brien |
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