In a subsequent ex parte filed on November 12, Level 3 recommended that as part of its investigation into this interconnection issue, the FCC should "not only consider whether CenturyLink's conduct is justified, but it should also seek information about the extent to which CenturyLink is enforcing its policies uniformly." As an example, it noted that CenturyLink routes traffic to Level 3's affiliate Broadwing over existing Level 3-CenturyLink interconnection trunks, but refuses to route traffic over comparable interconnection trunks to numbers assigned to the Level 3 ES OCN. Level 3 suggested that the FCC investigate CenturyLink's treatment of traffic associated with SBCIS, a non-carrier similarly situated to the VoIP trial participants, that has been permitted for years to obtain telephone numbers under its own OCN. Does CenturyLink demand that AT&T also obtain dedicated trunks for traffic destined for numbers assigned to the SBCIS OCN?
Another interesting comment from Level 3's November 5 ex parte is that it initially sought direct IP interconnection to support its VoIP trial traffic, but reported that "[i]n general, those efforts were unsuccessful." This experience may give the FCC valuable input as to whether giving interconnected VoIP providers direct access to numbers on a permanent basis will help accelerate the negotiation of IP interconnection agreements.
VoIP Numbering Trial Off to a Slow Start
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