Telling taies out of school let me say that I think alot of the discussion about GoogleVoice is way off track.
Here are some of the per minute rates for the same call based on the rules.
As a result of Apple and Google debate, the discussion of GoogleVoice got ATT in a strange position. That of being the only one in the battle the FCC had the ability to really petition about the issue.
That lead to ATT pointing out that GoogleVoice was in an interesting position, while neglecting to mention they were truly a secondary service and not a primary solution, we also ended up with interesting issues of when does an enhanced service start stop or apply.
But none of this is what is on ATT’s mind. They are focused on the right issue. Intercarrier compensation. They are pointing out the blocked calls not to point at Google, but to point at the craziness that the commission needs to address.
This does get complicated because entwined are the issues of high cost providers, phantom traffic and traffic pumping, but if Google can choose to avoid the cost for a free service, the question that should be asked is what is the harm?
The harm may be to the consumer behind the high cost carrier and therefore competitiion is the answer.
The time is right given the BTOP process to stare down the advocates of the status quo and make a decision.
Alistair Campbell the CTO of Truphone and Hank Hultquist of ATT were my guests on Squawkbox and I wanted to remind people about the discussion in light of the Intercarrier Compensation discussion.
Alistair does a nice job talking about the new era of communication over wireless Internet devices and Hank helps us see that regulatory reform is required.
The vote on Intercarrier Compensation has been delayed with the following two announcements.
STATEMENT OF FCC CHAIRMAN KEVIN J. MARTIN ON INTERCARRIER COMPENSATION AND UNIVERSAL SERVICE REFORM
November 3, 2008
The issues of Intercarrier Compensation and Universal Service reform have been in front of the Commission for years. Last summer I publicly indicated my intention to put forward concrete and comprehensive proposals to reform the inefficient and outmoded Intercarrier compensation and Universal Service programs. Those proposals have been with my colleagues for several weeks now. I am disappointed that we will miss the opportunity for comprehensive reform. Instead my colleagues have requested that we once again seek public comment on several proposals. As a result such a notice would make little progress and ask for comment again on the most basic and broad questions about reforming the two programs. For example, the Commission would again ask should broadband be supported by the Universal Service Fund and should we move to one uniform rate for all traffic or should that rate vary by the type of company?
I would like to be encouraged by my colleagues’ commitment that they will truly be ready to complete this much needed reform on December 18. The nature of the questions they would like to include makes me doubt they will have found their answers with an additional seven weeks. I believe the far more likely outcome is that, in December, the other Commissioners will merely want another Further Notice and another round of comment on the most difficult questions. I do not believe they will be prepared to address the most challenging issues and that the Commission will be negotiating over what further questions to ask in December.
Additionally, I have instructed the Bureau to draft a narrow order to address the Court’s remand. However, I remain skeptical that such an order which retains artificial and unsupported distinctions between types of Internet traffic will be seen any more favorably by the Court than the Commission’s two previous attempts.
I recognize that few other issues before the Commission are as technically complex and involved, with as many competing interests, as are reforming the Intercarrier Compensation and Universal Service programs. But neither of those two realities are an excuse for inaction. They will be true in one month, in one year or as we have now seen at the Commission, in ten years. I too remain committed to tackling the most difficult issues, providing answers to the toughest questions, fixing broken and outdated government programs and providing broadband to all Americans including those living in rural areas. I look forward to completing these long overdue and much needed reforms as soon as possible.
FOR IMMEDIATE RELEASE
November 3, 2008
JOINT STATEMENT OF COMMISSIONERS MICHAEL J. COPPS, JONATHAN S. ADELSTEIN, DEBORAH TAYLOR TATE AND ROBERT M. MCDOWELL
Below is a Joint Statement from the above-reference commissioners in response to the decision to remove the intercarrier compensation and universal service proposals from tomorrow’s agenda:
“Three weeks ago, Chairman Martin first shared with the Commission his proposals to fundamentally reform the intercarrier compensation and universal service systems. Four Commissioners provided the Chairman bi-partisan, constructive and substantive suggestions, and stated that notice and comment should be sought on the proposals, with an understanding that we would all be prepared to vote on December 18. We also have asked the Chairman to narrowly address the ISP-bound traffic remand and the Joint Board’s Recommendation. We therefore are disappointed that the Chairman has withdrawn the fundamental reform item from tomorrow’s agenda.
“We approached this proceeding with the common goal of modernizing our universal service and intercarrier compensation policies, and commend the desire to tackle some of the most important issues facing this Commission. It is equally important to ensure that any reform proposal receive the full benefit of public notice and comment – especially in light of the difficult economic circumstances currently facing our nation.
“We remain committed to fulfilling our obligation to tackle these difficult issues, and have set forth a reasonable path for completing comprehensive reform. We remain hopeful that the consensus process we have pursued regarding this issue will ultimately lead to a thoughtful, well-reasoned item that will inure to the benefit all Americans.”
Thank you for looking at what I sent you. I must apologize for not making things clear. I will ask you to revisit the Freedom2speak website.
The FCC has several petitions and actions going on simultaneously and it’s easy to lump them all together, but they deal with different aspects of what it means to provide service.
The Embarq petition has nothing to do with VoIP per se, but everything to do with Intercarrier compensation.
As you know the history of telecom was that long distance subsidized the cost of the local loop with termination charges to local terminating carriers.
Before VoIP came along the rates for these settlements were put in place. They had much more to do with regulatory objectives than real costs, both on the local loop side and on the interoffice, interLATA, International side.
The FCC had done excellent work, at one point, harmonizing the International settlements rates and many local rate plans benefitted as well. It is one of the key reasons bucket of minute pricing is available on all phones services.
The issue is that traffic rates for local and state termination have stayed stagnant since before the VoIP revolution. The termination charges with these local tariff rates are out of sync with the market realities today.
Whenever there is an anomaly like this the opportunity exists for arbitrage. The traffic that is terminating into these local carriers represent more than the volume that VoIP traffic represents and includes traffic from wireless and wireline services. However, often the traffic origination is not known since it is coming based on clearinghouse and competitive carrier relations and may be deliberately masked for competitive reasons.
The Embarq petition would want all traffic to be terminated at the rates that were set before the advantages of fiber, VoIP and competition came into being. And the rate has no relevance to cost. In fact, the cost of per minute billing systems is often considered not worth the hassle especially if bucket of minute pricing is applied.
The hope would be that a cohesive nationwide rate would apply based on real costs. Major carriers are advocating bill and keep and or a nationwide rate that is in keeping with the overall market and their experience of cost recovery.
If the Embarq petition is allowed to stand the implication is that competition may again be reduced by the cost prohibitive nature of compliance with per minute billing being applied to all carriers.
Of course the legacy carriers, have these systems so the status quo will get to stay that way. The more things change the more you get the same old POTS.
And that is the issue that Freedom2speak is all about. Like you, Regulators see the services that “quack like a duck” and want to apply the standard rules. The issue is that the revocation of the enhanced service provider exemption lumps everything that is displayed Freedom2speak.org as telecom. And given how many jurisdictions are looking for someone to tax, it is going to become burdensome. This is the point of reaching out.
Please reconsider and add your voice to show that VoIP is more than another duck.
Next week I will be guest hosting Alec Saunders’ Squawkbox.
Below is the agenda, but this is a reminder that it’s a conference call / interview. Open to a lot of people in a lot of ways. Your participation is welcome.
Agenda for the Week of 7 / 14 – 7/ 17.
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Monday July 14th. Guests: Jim Kohlenberger and Brita Strandberg
Title “Deployed Globally, Regulated Locally”
Jim Kohlenberger, Executive Director of the VON Coalition and VON Coalition International, takes a look at the world and the regulatory obstacles facing VoIP in various countries.
And then sets the stage for a discussion with Brita Strandberg of Harris Wiltshire. Regarding Web 2.0, (or other terms for the migration such as Telco 2.0, Communication As A Service [CAAS], etc.)
These issues have implications for everyone in our space. Your users and you may not consider the services you render as telecom and you consider yourselves good Netizens, but the way the laws are being written you may have to “quack like a duck” after all.
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Tuesday July 15th Guests Hank Hultquist of ATT and ???(Perhaps some one on the California issues as well? – Jim it may be you again)
Title “Following the Money”
After centuries of taxes and service fees based on the use of local switching by a phone company, the application of those rules to services on the Internet is burdensome. Can Intercarrier Compensation be placed into a model that is logical for all participants? While fighting for this vision on an international and national level, some municipalities are pushing us into even more complexity.
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Wednesday July 16th Guests Todd Daubert and Ron Del Sesto
Title: “Net Neutrality”
On “the Hill”, some issues take on lives of their own. The term Net Neutrality has been claimed by almost every contingent in the market. Ron Del Sesto of Bingham McCutchen, will provide context and talk about the way that the subject is being perceived by Congress. Todd Daubert of Kelley Drye will add to discussion with the concerns that face vendors and carriers alike in this debate.
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Thursday July 17th Guests Sam Shiffman, and a player to be determined.
Title: “Day in the life Regulatory Reality”
How does a carrier stay in compliance with regulation, when so many agencies claim jurisdiction? What resources are required and what issues are faced in coping with expanding services beyond a specific jurisdiction? Sam Shiffman and a fellow service provider will provide some insight as to the realities managing telecom regulation.
