More on the Notice of Proposed Rulemaking and Further Notice of Proposed Rulemaking

David Byrd : Byrd's Eye View
David Byrd
Chief Marketing Officer for ANPI

More on the Notice of Proposed Rulemaking and Further Notice of Proposed Rulemaking

In general, I have been too busy or disinterested to ever read a Notice of Proposed Rulemaking (NPRM). I can now say, “That was a mistake.” It is well worth the effort to read relevant parts of the NPRM just to understand the way of thinking by the current makeup of the FCC. Now, I am not referring to the five commissioners who I doubt have read the document or even understand the more technical nuanced sections of the document. I am instead thinking of the guys that actually wrote the document. I am thinking of the next layer of bureaucrats with whom the Tier 1 carriers and ILECs meet on a consistent basis. I am thinking of the lobbyists that helped to frame the questions and soon will assist in defining the answers.

I completed reading of the section on VoIP and InterCarrier Compensation (ICC) with little understanding of the proposed rules for charging ITSPs like Broadvox. The section is mostly a series of questions related as to whether the FCC has the regulatory power to change the rules regarding access charges and how much, if any, the carriers providing VoIP services should pay. The current opinion of the FCC was not expressed. Rather the opinion of certain carriers was included in the NPRM to provoke industry participants and interested parties responses. While the NPRM reads as though an objective approach will be taken to resolve access and termination charges as they relate to VoIP, most providers of VoIP service expect the ILECs to establish the baseline for the payment structure during their lobbying efforts. VoIP service providers are not optimistic. However, I was somewhat pleased to see that the FCC does not believe any change to the payment structure should be immediate. They are properly concerned as to the impact any change would have on further innovation, investments and cost to the public.

The second concern regarding VoIP was with regard to identifying the origin of IP traffic. Here the NPRM is clear. It does propose that there be new rules to ensure traffic is properly identified. Although, the NPRM also expresses the clear statement that such rules should not drive the generation of any new standards that hamper the growth of IP communications. Any changes to the standards or network signaling needed to improve identifying where traffic originates should be “forward” looking and not “backward” looking. Indeed the NPRM properly identifies the roles of SS7 and SIP in their current support of caller identification and routing. To support better identification of traffic to support the ICC reforms will require changes to standards, equipment, and business support systems. This will take both time and money. It will materially impact all members of the IP ecosystem. Therefore, such changes must be well thought and not defined by the more powerful ILECs and their lobbyists.

Broadvox and other like minded supporters of keeping VoIP free from regulation belong to a group called the VON Coalition.  The VON Coalition has filed a Response on the behalf of its members to the NPRM regarding Universal Service Fund (USF) and ICC reform. I did find it interesting that the response was only nine doubled spaced pages. That in response to a nearly 300 page document that was single spaced. Interesting. There was no time to read it for today’s blog, but I will.

See you on Monday with another new recipe. I am thinking perhaps French.

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