[VoiceOps] Direct CLEC interconnect - taking the plunge

Joe Fratantoni jfratantoni at cygnustel.com
Thu Oct 18 13:27:29 EDT 2012

Yet another recommendation here for Mary Lou, we have used her with 
much success since our transition into becoming a CLEC. I still call her 
regularly with questions; an infinite source of knowledge!

I think Scott really hit the nail on the head here. The ONLY real 
reasons to become a CLEC nowadays are access to customer loops, LEC 
duct, and right-of-ways. That's about it. The whole experience is, quite 
bluntly, a pain in the ass. When you aren't dealing with the usual 
regulatory upkeep; prepare for the LEC to fight you tooth and nail every 
step of the way.

If you are still committed to this, now is the time to address all of 
the things you won't want to deal with later.

If you're going to colocate in the CO, how are you going to bring 
connectivity to it? Is there dark fiber inner-office transport 
available? Are there other colocators there you can source this from? 
Are you going to be using remote entrance facilities? Is there duct 
available for you to utilize? (~$2/ft mrc) Is there a decent customer 
base you can service with DSL? What is the condition of the phone lines? 
Is it an old farm town with 100+ year old paper-insulated copper pairs 
that are going to cause your customers issues?

Time-wise, it is feasible for one person to manage all of your CLEC 
billing, ordering, numbers and portability, AOCN stuff, etc. BUT that 
WILL be that persons FULL TIME job. Don't trick yourself into thinking 
you can tackle all of these things and then your normal daily tasks. 
Hire someone full-time to deal with all of your ordering/support/carrier 
and lec responsibilities, and have Mary Lou train that person.

Specific Gotchas:

-Make sure the LEC does not require you to have E911 trunks to every 
area you have DID blocks in!!! Since you are a VOIP provider operating 
in a few areas, you likely will want to have DID blocks local to 
different areas. The LEC could force you to have circuits in every area 
with ambiguous ICA wording.

-Make sure your ICA has the verbage that dictates the 25% utilization 
limit of spare strands does not apply to instances where 6 or less 
strands exist.

-Obtain, in writing, with contact names and numbers the exact process 
in which you request a dark fiber inquiry/field survey. Hint hint: if 
they are saying you need to fill out an ASR; that not correct.

-Make sure you complete a pre-construction site visit request for COs 
you're interested in BEFORE you colo or even start the application 
process. Use this visit to make sure rooftop is available where you need 
it to be, and take a look at the collocation areas; write down the names 
and numbers (usually on the racks and cages) of the other colocators. 
These guys will be your best friends when it comes to getting IP in and 
out of that CO on the cheap. Get quotes and your network layout done 
BEFORE jumping into the colo. Do not count on LEC transport being 
available, feasible, or cheap.

-Separate everything, everything, everything into different 
corporations and BANs. When possible while peering/interconnecting with 
other colocators, have THEM order the cross-connect loops to have them 
on separate BANs. Make sure your billing dispute sections in your ICA do 
NOT require a deposit of payment in question before being able to 
dispute it, and that it does NOT allow the LEC to terminate your access 
trunks for non-payment, even on disputed amounts. Basically, you do not 
want the LEC to be able to extort money from you by killing your access 
trunks. You WILL have billing disputes, you WILL be asked to pay 
absolute incorrect nonsense. Incorrect nonsense that could get into 6 
figures. Do you really want to be forced into paying an erroneous 
$100,000+ amount to have your service restored? Have a good telcom 
attorney, and be ready to pay him or her lots of money.

-Figure out how your PUC handles complaints, disputes, and mediation. 
Look up previous CLEC-LEC issues with the PUC and inform yourself of 
some of the pitfalls they are currently experiencing. Now is your chance 
to slide language into your ICA that may prevent you from falling into 
the same issues and might actually give your CLEC buddies ground to 
stand on with their requests.

-Keep DETAILED CIRCUIT LOGS, with PONs, CFAs, etc. If you have the 
programming ability, design your own ordering system and apply for XML 
Gateway ordering. Store a copy of all orders.

-Apply for refund money from the LEC. AT&T has a program for CLECs in 
CA to be compensated when they miss order deadlines, turnups, etc. It is 
automatically calculated and paid if you are registered. Some fellow 
CLECs in the area are making thousands per month on this.

-Do NOT account for termination fees in your business model.

-Install and use an internal wiki religiously. Every contact you make, 
every scrap of information you gather. Names of engineers, technicians, 
CO managers, tricks for ordering/templates.

LEC is, no matter how much you think they are intentionally screwing you 
around, stay polite, friendly, always. No threats of legal action, no 
harsh words, do not cite ICA or reman text if you can help it, do not 
pass go, do not collect $200. Explain your requests in a friendly, 
personable manner, and only cite backup documentation or examples if you 
need it. Avoid debates on language. It doesn't matter what is written, 
you get things done by knowing who to ask and how to ask. Plain and 
simple. Create a budget for taking LEC personnel out, for sending them 
gift baskets, thank yous. Keep in touch with them (you are storing there 
contact information in your new wiki right?). Don't over-burden them, 
don't overwhelm them with requests. Try to avoid escalations if at all 
possible, they just make people less eager to help you. I certainly 
wouldn't like it if you demanded to speak to my 'boss' because you 
didn't like an answer I gave you on something I didn't feel you were 
entitled to; and I would be less inclined to help you with future 
requests. Remember, these people do not share your viewpoint or interest 
in getting things working for you. In their eyes, you are coming into 
their facilities, and using their network to steal their own customers.. 
So be nice.

-Expanding upon above: This industry is very very large, but very very 
tiny at the same time. You will run into all of the same people over and 
over again. Bear that in mind.

-In regards to call completion.. going through the LEC is not as easy 
as dumping your calls to various sip carriers. When you have call 
completion issues (you will), you can't just pick up the phone an ask 
the LEC to fix it. They'll do an SS7 trap for you and ensure they are 
passing the call along proper (and it is difficult to get them to do 
that! Remember: it's who you know..) It is your responsible to work out 
all routing/translations issues with the other carriers. Start building 
your contact list now, and again, friendly. There are only a few 
individuals at every major carrier on this planet that deal with 
routing/translations. Make them like you. Your business will come to a 
grinding halt real fast if one day half or more of your customer base 
can't seem to dial Verizon or Sprint or whoevers numbers in a certain 
area for some reason, and you don't have a contact over there to help 
you with that. Don't think going through their support lines, whoelsale 
lines, or NOCs are going to get you anywhere either.

-Create and enforce trading partner agreements!!! Now is your chance to 
get all of the contact information you ever wanted. When you receive a 
port-out request, force the porting carrier to first establish a 
'trading partner agreement'. Send them a form to fill out, and detail 
your procedures (where they need to send there requests, to whom, what 
to include) but also force them to fill out call completion issue 
contact information, their own procedures for handling port outs, 
escalation lists, managers names and numbers. They WILL get it and give 
it to you. Verify it all before allowing a port.

Good luck!

Feel free to call me any time with questions as well,

Joe Fratantoni
Cygnus Communications
19635 97th Ave
Mokena, IL 60448
815.680.5686 x206
Business Internet & Phone Services

On 2012-10-17 21:19, Scott Berkman wrote:
> Agreed on Mary Lou, she knows her stuff and can help navigate the 
> waters
> especially when it comes to ordering.
> Some questions you may want to ask yourself:
> Why make the step?  Are there features or capabilities you are 
> missing, or
> just a lack of control you want to address?  Does this make business 
> sense
> after adding up all the different recurring and start-up costs?
> Do you have the right geographical concentration for this to make 
> sense
> (from the OP sounds like you might).
> Do you and/or your staff have SS7 knowledge and equipment that can 
> handle it
> already?  Neither of these are particularly cheap.
> Do you have an understanding of the local PUC's working rules and 
> what it
> will take to get a CLEC license?  Is this even possible in your 
> specific
> situation (some PUCs are very tight on issuing new licenses)?
> Do you have a good telecom Attorney that can help you interpret and
> negotiate your ICA with the iLEC?  Do you know who else is in the 
> market to
> compare their ICA?
> Do you understand the local LEC infrastructure including how many 
> LATAs,
> Tandems, RC, and different LECs you may need to interconnect to?  Is 
> there
> more than one iLEC covering the areas you wish to serve?
> Are you planning for Tandem trunking or do you have a reason to build 
> out
> End-office trunks?  What are your capacity needs?
> Do you have a staff to handle LNP, 911, and other "provisioning" 
> tasks?  How
> about systems to track it all?  The FCC now has turnaround 
> requirements on
> simple ports as low as one day you'll need to be able to meet.
> What are you not going to handle on your own?  TF RESPORG is one good
> example that smaller CLECs don't jump right into.  You'll still need 
> other
> carriers for LD and International as well.
> Have you taken into account supplementary services like e911 (you'll 
> need a
> listing provider like Intrado if you plan to have local trunks, or a 
> nomadic
> solution like Bandwidth/Dash/iNetwork and 911-enable), OSDA, CNAM and 
> dipping?
> Some other items you'll want to research include the costs and 
> processes for
> getting the other details setup, like switch CLLIs, point codes, 
> OCNs, TN
> block assignments...
> Hope that helps,
> -Scott
> -----Original Message-----
> From: voiceops-bounces at voiceops.org 
> [mailto:voiceops-bounces at voiceops.org]
> On Behalf Of Ryan Finnesey
> Sent: Wednesday, October 17, 2012 8:19 PM
> To: Anthony Orlando
> Cc: VoiceOps
> Subject: Re: [VoiceOps] Direct CLEC interconnect - taking the plunge
> Backup Telecom is great.
> Sent from my iPad
> On Oct 17, 2012, at 8:14 PM, "Anthony Orlando" <avorlando at yahoo.com> 
> wrote:
>> Backup Telecom would be my first choice. Mary Lou Carey. She's on 
>> this
> board.
>> On Oct 17, 2012, at 18:39, Jay Hennigan <jay at west.net> wrote:
>>> We are a regional hosted VoIP provider in California.  We started 
>>> as an
>>> ISP and moved into becoming a CLEC offering VOIP.  As is probably 
>>> the
>>> case with most, we started buying DIDs from wholesale carriers as 
>>> SIP
>>> trunks.  The majority of our customers are within a single LATA 
>>> with a
>>> large minority in an adjoining one.
>>> We are investigating the feasibility of direct interconnect with 
>>> the
>>> RBOC/ILEC via SS7.
>>> I'm interested in pointers/gotchas as well as recommendations of a
>>> consultant to help us navigate the maze, both from a political and
>>> technical standpoint.  Suggestions as what not to do or who not to 
>>> hire
>>> are also welcome.
>>> Please feel free to respond on-list or off as you feel appropriate.
>>> --
>>> _______________________________________________
>>> VoiceOps mailing list
>>> VoiceOps at voiceops.org
>>> https://puck.nether.net/mailman/listinfo/voiceops
>> _______________________________________________
>> VoiceOps mailing list
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Joe Fratantoni
Cygnus Communications
19635 97th Ave
Mokena, IL 60448
815.680.5686 x206
Business Internet & Phone Services

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