THE REGULATORY MIX AND BLOG ARTICLES

AT&T, Bandwidth.com, Inc. and Vonage Holdings, Corp. each submitted comments last week in response to the FCC Wireline Competition Bureau's (WCB) January 31 report regarding the results of the VoIP numbering trials. (See TMI previous Blog Postings Update on VoIP Numbering Trial: War of Words Continues; and The Regulatory Mix – Tuesday, February 4, 2014). The WCB report found that the trials demonstrated the technical feasibility for interconnected VoIP providers to obtain telephone numbers directly from the numbering administrators and did not identify technical problems regarding number exhaust, number porting, VoIP interconnection, or intercarrier compensation. However, the report noted that some carrier disputes arose regarding interconnection and porting that caused some issues during the trials.

The Federal Communications Commission has issued its 2014 Enforcement Advisory reminding telecommunications carriers and interconnected VoIP providers that they must file their annual CPNI certifications by March 1st. The Advisory notes that in prior years many companies failed to file or filed certificates that violated the FCC’s rules in material respects. Accordingly, providers are reminded that failure to comply with the CPNI rules, including the annual certification requirement, may subject them to enforcement action, including monetary forfeitures of up to $160,000 for each violation or each day of a continuing violation, up to a maximum of $1,575,000. Additionally, false statements or misrepresentations to the Commission may be punishable by fine or imprisonment under Title 18 of the U.S. Code.

The Regulatory Mix, TMI’s daily blog of regulatory activities, is a snapshot of PUC, FCC, legislative, and occasionally court, issues that our regulatory monitoring team uncovers each day. Depending on their significance, some items may be the subject of a TMI Regulatory Bulletin.

The Regulatory Mix, TMI’s daily blog of regulatory activities, is a snapshot of PUC, FCC, legislative, and occasionally court, issues that our regulatory monitoring team uncovers each day. Depending on their significance, some items may be the subject of a TMI Regulatory Bulletin.

The Regulatory Mix, TMI’s daily blog of regulatory activities, is a snapshot of PUC, FCC, legislative, and occasionally court, issues that our regulatory monitoring team uncovers each day. Depending on their significance, some items may be the subject of a TMI Regulatory Bulletin.

In our last episode of the VoIP Numbering Trial saga (November 13, 2013 post, Level 3 Reports Same Obstacles as Vonage in Numbering Trial), I reported that Level 3's VoIP affiliate, Level 3 ES, was unable to test call routing in the Denver market due to CenturyLink's refusal to allow its traffic to be routed via the existing Level 3 CLEC interconnection trunks. This was the same issue that Vonage raised with respect to its numbering trial in the Phoenix market, where CenturyLink is also the incumbent LEC  (November 6, 2013 post, VoIP Numbering Trial Off to a Slow Start).

On November 5, 2013, Level 3 Communications and its VoIP affiliate, Level 3 Enhanced Services (Level 3 ES), filed an ex parte with the FCC that largely mirrored the concerns previously raised by Vonage regarding CenturyLink's refusal to route traffic to telephone numbers assigned to the Level 3 ES OCN over existing Level 3 (the CLEC partner) interconnection trunks. (See November 6, 2013 post, VoIP Numbering Trial Off to a Slow Start). As a result, Level 3 has reported that it cannot initiate testing of call routing under the numbering trial in the Denver market. It also reports that this issue has created potential problems for other carriers who have requested telephone numbers in the A-block obtained by Level 3 ES in the Denver area, because it is unable to activate that block until it can successfully test routing for calls to telephone numbers in that block. Level 3 urged the FCC to "take action to clarify that carriers like CenturyLink may not refuse to route traffic under these circumstances."

In last week's post (VoIP Numbering Trial Off to a Slow Start, posted November 6, 2013), I referenced an October 29 ex parte filing by Vonage, in which it reported that AT&T and Verizon had negotiated interconnection agreement amendments with Vonage's CLEC partner in the Atlanta and Boston markets, respectively, while CenturyLink had refused to negotiate a similar amendment in the Phoenix market. The agreements with AT&T and Verizon allow the CLEC partner to deliver PSTN-originated traffic to Vonage's OCN over existing interconnection trunks.

The Regulatory Mix, TMI’s daily blog of regulatory activities, is a snapshot of PUC, FCC, legislative, and occasionally court, issues that our regulatory monitoring team uncovers each day. Depending on their significance, some items may be the subject of a TMI Regulatory Bulletin.

Beginning in June 2013, the FCC authorized what is supposed to be a six-month trial during which five VoIP service providers are allowed direct access to telephone number resources. The five providers - Vonage, SmartEdgeNet (d/b/a Edge Communications), Wiltel Communications (an affiliate of Level 3), Millicorp, and IntelePeer - have begun filing the status reports required by the FCC. Initial reports were to be filed 60 days after each company requested direct access to numbers with monthly reports filed thereafter. So far, all five providers have filed at least their initial reports, but only Vonage has reported any ported - or new numbers in service - the other four carriers are still in the testing stages.