Bill and Keep
The Voice on the Net Coalition (VON Coalition), of which Broadvox is a member, response to the Notice For Proposed Rulemaking and the Further Notice For Proposed Rulemaking and although reasonably short at nine pages, it is still surprisingly longer than needed. The net of the response is that the VON Coalition wants the FCC to do three things:
- Maintain the current definition of IP services as Information Services as defined in the Telecommunications Act of 1996. This would prevent any change in how IP services are regulated by the FCC.
- Adopt the “Bill and Keep” option for billing IP service providers. Under a bill and keep option IP carriers would be treated in a similar fashion as wireless carriers. There would be no charges for originating or terminating traffic as each carrier would recover their network costs by billing their customers/end users.
- Make the changes immediate and avoid having an interim period where reform is done in steps. This would allow for carriers and investors to have confidence in making decisions to expand, improve or otherwise invest in their businesses.
The VON Coalition accurately points out that the FCC will impose unnecessary costs and rules complexity if the IP carriers have to differentiate voice traffic from other information services. In the case of Unified Communications users have the ability to intermingle voice with information applications. Users are able to do this dynamically. Therefore, it would be very difficult to identify and label VoIP traffic differently from the underlying and supporting applications and services.
The need for reform is accepted by all parties. We need to be both patient and perhaps a little bit anxious regarding the result.