[VoiceOps] FCC issues Declaratory Ruling on Call Termination

Charles Boening charlieb at cot.net
Tue Feb 14 23:30:02 EST 2012

Exactly.  As a rural carrier I can attest to that.  We have the capacity.  Send the dang call.

I'm going to step onto my soapbox for a couple paragraphs.

I'm sorry but I call the argument that there is a capacity issue BS.  :)  That will just end up being one more excuse by some carrier to try and get out of doing what they need to be doing which is completing calls.  If they don't have the capacity then they need to get the capacity.  I don't buy that capacity to rural landline carriers has suddenly run out.  Is there a run on landlines in rural communities across the US?

The thing is that these calls are being passed by carriers to least cost routers who, as  suggested, may not have the capacity to terminate calls to rural communities.  The carriers sending these calls to the least cost routers usually do have capacity but are trying to save a buck and knowingly passing the calls off to a 3rd party who may not have the capacity.  I even doubt that the least cost routers don't have capacity.  It's not like they are asked to have direct trunks to every single rural carrier.  That's part of what tandems are for.  All carriers in a LATA should to connect to a tandem.  What I suspect is going on is these guys are purchasing few "low cost" circuits (TDM or IP) and trying to route too many calls across those circuits or messing with the calls in ways that affect the completion of the call.  Plus, what's with spoofing the caller ID?  We have a rural customer who constantly gets calls from "New Jersey" when the remote office making the call is 100 miles away from the corporate office and they are both on the West Coast.

I've been on both ends of this as a rural carrier and as a CLEC in a larger area.  I know that as our rural ILEC, we have more than enough capacity to AT&T for call termination and origination in our area.  I'm pretty sure other carriers have enough capacity to AT&T to complete calls as well.  If there wasn't capacity then I would expect issues with terminating calls to metro areas as well.  We connect to an AT&T tandem in Redding, CA which is a good size area.  I know there is capacity there otherwise AT&T would be having issues terminating calls to every area served out of the tandem and they don't.  AT&T doesn't seem to have issues terminating calls to rural areas within its service area.  I'm guessing that's because they don't bill for those calls like rural carriers do.

We had a pretty nice example of this the other day.  A sister company has direct trunks to Sprint.  This sister company also has multiple exchanges in different rate centers and their own tandem for all their exchanges.  When a customer is calling rate center A calling rate center B, the ILEC sends the call out traditional Sprint trunks.  For those reading and asking why wouldn't the ILEC just tandem the call, the reason is because that would cut Sprint out of the loop and they would not be able to bill for the call.  We have to send the call to the customer's LD carrier even if it comes right back in to us.  Now that's a Sprint call so Sprint should send the call to the other rate center back via dedicated Sprint trunks but they don't.  They send the call off to a least cost router and the call never completes.  This was somewhat of a unique case since the trunks are dedicated as Sprint LD trunks and a single ILEC was on both ends of the call. After contacting Sprint the issue was resolved.  Sprint changed the routing to bypass the least cost routing service and route the call directly back as they should have in the first place.

Another issue we were able to resolve was through our Qwest IP LD connection.  We were seeing issues with CLEC customers calling into our ILEC service area.  We were able to open a ticket with Qwest who called their "upstream" carrier (they wouldn't share who it was)  who in turn fixed the issue (until it came back a few months later after a new LCR load).  What was interesting is that after contacting Qwest (ya, now Century Link) and getting the issue resolved, we saw not only our IP LD issue go away but the issue disappear across several LD carriers including Sprint, MCI and AT&T.  That tells me that there is a good chance they are all using the same least cost routing service or maybe perhaps Qwest was having issues routing the rural call to those carriers until the least cost routing issue was resolved.

This may be a simplistic view but the way I see it is this all comes back to LD carriers trying to save a buck and is not a capacity issue.  It's plain and simple.  They just need to suck it up and route the call to the rural community and either pass the cost on to the customer or eat it as part of the cost of doing business.  I'm just waiting for the day when some life or death call can't be completed and they get sued or criminal charges brought on them.

I'll get off my soapbox now.  :)


From: voiceops-bounces at voiceops.org [mailto:voiceops-bounces at voiceops.org] On Behalf Of Frank Bulk
Sent: Tuesday, February 14, 2012 7:23 PM
To: 'Mark R. Lindsey'; Scott Berkman
Cc: VoiceOps at voiceops.org
Subject: Re: [VoiceOps] FCC issues Declaratory Ruling on Call Termination

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> [mailto:voiceops-bounces at voiceops.org]<mailto:[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<mailto: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<mailto: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 back.

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<http://Bandwidth.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> [mailto:voiceops-bounces at voiceops.org]<mailto:[mailto:voiceops-bounces at voiceops.org]> On Behalf Of Carlos Alvarez
Sent: Tuesday, February 07, 2012 11:58 AM
To: VoiceOps at voiceops.org<mailto: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 "carrier?"

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<mailto: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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