The Problem with the Embarq Petition


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 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. Launched

Jim Kohlenberger has shared this information with me.  Included in this site which highlights the innovation of VoIP is the ability to petition to keep VoIP as an enhanced service.

With the FCC poised to vote November 4th on a key decision that will impact the future of Internet communication, today VoIP leaders are launching a new voice activated web site and online campaign to educate consumers and policymakers about the power and potential of VoIP:

An incredible transformation is making its way across the Internet — helping to bring voice to the net. These innovative Internet voice applications are changing the way we communicate, stay connected to our friends, family and colleagues. Together these technologies have the potential to deliver extraordinary new benefits.

We want to introduce you to some of the exciting new voice tools now just emerging. This new web site contains nearly 300 different cool tools — each unique — that are stretching the horizon of voice on the net.

But the future of some of these exciting technologies is not all assured. There are an unfortunate set of policy proposals by special interests that could limit your ability to speak and be heard on the Internet. And that’s why we’re asking you to get involved. Stand up — speak up — and fight for your freedom to speak on the Internet!

The web site:

1.    Highlights the amazing things that are happening when voice is integrated with the Internet.  Providing examples of nearly 300 innovative new voice enabled tools that are emerging on the Internet. These voice enabled Internet applications are giving voice to blogs, connecting friends together on MySpace and Facebook, empowering people on the campaign trail, transforming video games, integrating voice and video into instant messaging, allowing one telephone number to reach all your phones at once, ushering in a new era of voice recognition based information retrieval tools, integrating click to dial functionality into mapping and other web sites, and doing things never before possible.

2.    Demonstrates the extraordinary benefits that VoIP enabled tools can deliver.  The site includes a state by state map of benefits; highlights the broader benefits for consumers, the economy, the environment, homeland security, etc.; and provides examples of exciting and beneficial ways the technology is being put to use.  For example, at a time when families are struggling to pay their bills, VoIP enabled competition is poised to save consumers an astounding $110 billion over the next 5 years.

3.    Enables users to take specific actions to protect their freedom to speak on the net.  The FCC is poised to vote on November 4th on a key decision that will impact the future of these technologies.  The site describes key policy issues that could impact the growth of these technologies, and gives people the ability to take specific actions to protect their freedom to speak on the Internet.  With just a few clicks, the site allows users to file comments at the FCC or talk directly with policymakers.  Its critical because some proposals could subject voice enabled web sites to a patchwork of potentially conflicting state rules, or reverse key policies that would apply per minute fees to Internet commutations and voice enabled web sites.

4.    Using the medium as the message.  Voice enabled tools are incorporated throughout the site, including into voice blogs, a virtual VoIP debate between Obama and McCain, a tool to call members of Congress, and a voice broadcast tool tell their friends about the site.

VoIP is not another flavor of telephone service.  It’s a new frontier in communications for individuals and businesses alike, and it requires forward-thinking regulatory approaches.  If policymakers reflexively subject these new voice enabled Internet tools to yesterday’s telephone regulations without first understanding the variety of tools emerging, consumers and business users could miss out on the new services, increased choices and new ways to communicate that VoIP can deliver.

Jim Kohlenberger
Executive Director
The Voice on the Net Coalition

About the VON Coalition:
The Voice on the Net or VON Coalition consists of leading VoIP companies, on the cutting edge of developing and delivering voice innovations over Internet. The coalition, which includes AT&T, BT Americas, CallSmart, Cisco, CommPartners, Covad, EarthLink, Google, iBasis, i3 Voice and Data, Intel, Microsoft, New Global Telecom, PointOne,, Skype, T-Mobile USA, USA Datanet, and Yahoo!  works to advance regulatory policies that enable Americans to take advantage of the full promise and potential of VoIP. The Coalition believes that with the right public policies, Internet based voice advances can make talking more affordable, businesses more productive, jobs more plentiful, the Internet more valuable, and Americans more safe and secure. Since its inception, the VON Coalition has promoted pragmatic policy choices for unleashing VoIP’s potential.

Don’t be a POTS! Innovate!

If free is dead, in what plight can VoIP compete?

Next week in Chicago, I am going to present on the “Apps Gap.”  The sally of the presentation is that VoIP does not deserve its current fate.  Service providers are providing traditionary phone options that makes it as if they’re competing with common provide tied behind their back — how do you show presence on a POTS method?

Or they try to gain space adhering a $1000 computer that was not bought to replace a $10 handset. Worse hitherto, soft phones put a handset look and handle on the PC to really eliminate some trust the user sees innovation in advance of having one smaller set of buttons to punch.

Innovation is at a distance there, but you have to go looking on this account that it. The VON Coalition has found over 600 apps listed that they categorize as “Cool Tools” (the list is not yet public, but will be soon).  And the range of applications is extremely varying, from apps where presence rules, to Instant Messaging that includes voice, video and instant communication, as in a proper manner as multi-modal to PSTN connectors that connect your phone to the web – inbound and outbound.

Cool tools contain apps like the ingenuity to:

  • Voice enable your email or text your voice mail, or you can voice enable your blogs.
  • Social netting voice applications and tools for political activism.
  • Virtual assistants to reach you anywhere around the world.
  • Language transferrence applications to help you scheme others or learn their language.
  • Voice enabled widgets that let you think vaguely your message or avatars that purloin you.
  • Voice enabled games and animations and services that enable accessibility.
  • Mobile applications by reason of your cell phone and communications for your cameras.
  • Productivity tools for conferencing and collaboration and (of course)
  • Convergence for business on the PBX.

So talk up VoIP apps.

Use them to get humbler classes involved and thinking. Don’t let your family, your neighbor and especially your congressmen think that VoIP is blameless POTS through the Internet. Adopt one App today and tell me about it –

The reality is, we are in a dangerous period of regulatory concern. With economies in trouble, more taxes look like redemption to states through deficits, and VoIP that looks like POTS with a POTS requisition may spoil it for enhanced services from china to peru.

Regulators are looking to appoint taxes regardless of company revenues and may in addition require for VoIP services to be connected to emergency services or supplement the require to be paid of emergency services – unruffled admitting that the application is not a primary service. And these issues are not deserved in the US, they are worldwide.

Why is a VoIP tax this prominent? To gain market awareness, many applications developers have given their consequence away.  Some intend to stay free, others are being offered as exempt for a limited duration of one’s life. If the current regulatory mindset continues, it behest cost also a great deal of to move free apps.

Thursdays, I moderate a call on the Calliflower conferencing site with Jim Kohlenberger, Executive Director of the VON Coalition.  Please stop by and join us as we try to keep the Internet a voice-enabled environment.