[VoiceOps] FCC issues Declaratory Ruling on Call Termination

Frank Bulk frnkblk at iname.com
Tue Feb 14 22:23:07 EST 2012

Members in this group keep focusing in on capacity as being the issue for
poor/degraded calls. but from NECA's report and all the other reports and
summaries I've seen, trunk capacity has not been listed as reason.  The
focus has always been on LCR practices and gateways that send back call
progress data even before it hits the termination switch.






From: voiceops-bounces at voiceops.org [mailto:voiceops-bounces at voiceops.org]
On Behalf Of Mark R. Lindsey
Sent: Tuesday, February 14, 2012 10:46 AM
To: Scott Berkman
Cc: VoiceOps at voiceops.org
Subject: Re: [VoiceOps] FCC issues Declaratory Ruling on Call Termination


As I read it, the FCC doesn't require anyone to build infinite capacity into
an area. The FCC just said that you can't intentionally degrade or block the
call based on the called destination if you have capacity available. 


Most carriers don't have a trunk group or route to rural, expensive areas
and separate trunk groups to cheaper metro areas. They just have TDM or SIP
trunks to the LD termination carriers that can support any type of call. The
FCC is saying that if you take a setup like that and intentionally make some
of the calls work poorly or fail more often than other calls, then YOU
PERSONALLY might have to pay $150k.


That implies (over the long term) that you must have a way to pass on your
costs to your customer so that you can actually afford to terminate the
calls that they send you, and even profit from doing so.


Who ever said it was reasonable to charge a single, competitive, fixed price
rate per minute for all Domestic US termination? But that's exactly what
everyone is expecting: $0.02/minute no matter where you call in the US.


I'm not a lawyer and this isn't legal advice.


-- Mark R Lindsey mark at ecg.co +1-229-316-0013  http://ecg.co/lindsey





On Feb 7, 2012, at 20:20 , Scott Berkman wrote:

+1 on Carlos' note about the free services that are the underlying cause for
this issue.  They put the services in these locations on purpose knowing
full well that the low costs they were paying for termination meant higher
costs on the other side.  As those services grew, there were obvious
consequences to the capacity the IXC's had into those areas.


As I was once told by someone at a major carrier that may or may not have
been mentioned by name in the OP, at some point when the call volumes to a
certain area are exponentially larger than what they should be based on the
actual population or even population growth expectations, it doesn't make
sense to build out the needed capacity to serve that growing volume of calls
if there are no paying end users to help cover the costs.


I find it "interesting" that not only did the FCC ignore the underlying
cause of these issues in the ruling, but it seems they have basically now
given the free conference and similar service providers the go ahead to keep
doing what they are doing without consequence, knowing the FCC has their


As far as GV, they are not a "carrier" in the traditional sense because they
don't operate as a CLEC or IXC in any way that I have seen yet.  For
inbound, all their TNs (at least the ones I have checked) are ported to
either Level 3 orBandwidth.com, which basically just makes them a big VoIP
customer of the big carriers.  Outbound is a little harder to trace, but in
all likelihood they mainly use the same carriers, perhaps some others as
well, so for their customers (or is it users for a free service?) to stop
having issues the IXC's they use will have to upgrade their trunking
capacities into the affected "rural" areas.




From: voiceops-bounces at voiceops.org [mailto:voiceops-bounces at voiceops.org]
On Behalf Of Carlos Alvarez
Sent: Tuesday, February 07, 2012 11:58 AM
To: VoiceOps at voiceops.org
Subject: Re: [VoiceOps] FCC issues Declaratory Ruling on Call Termination


I'm optimistic about this, though not knowledgeable enough to know the full
legal implications.  But it does seem like GV/L3/others will be forced to
change their ways.  Though maybe not GV, are they even considered a


I wonder what will happen to those "free" fax and conference call providers
who caused the problem to start with?  Can the locals refuse service to
them?  Will the FCC look at their practices independently?


On Mon, Feb 6, 2012 at 9:13 PM, Frank Bulk <frnkblk at iname.com> wrote:

The FCC issued a Declaratory Ruling today in regards to call termination.
The ruling prevents originating carriers from passing the buck to LCR, puts
responsibility on them if they are aware of degraded service, and attaches
some stiff fines.

It would seem to me that this would prevent Google Voice and others, such as
Level3, from not terminating to certain (more expensive) NPA/NXXes.


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Carlos Alvarez





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