[VoiceOps] Direct CLEC interconnect - taking the plunge
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.
-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
-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.
-MAKE FRIENDS WITH EVERYBODY, NO MATTER WHAT. No matter how wrong the
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.
Feel free to call me any time with questions as well,
19635 97th Ave
Mokena, IL 60448
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
> 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
> after adding up all the different recurring and start-up costs?
> Do you have the right geographical concentration for this to make
> (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
> 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
> Tandems, RC, and different LECs you may need to interconnect to? Is
> 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
> 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
> 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
> solution like Bandwidth/Dash/iNetwork and 911-enable), OSDA, CNAM and
> 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,
> -----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>
>> Backup Telecom would be my first choice. Mary Lou Carey. She's on
>> 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
>>> case with most, we started buying DIDs from wholesale carriers as
>>> 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
>>> 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
>>> are also welcome.
>>> Please feel free to respond on-list or off as you feel appropriate.
>>> VoiceOps mailing list
>>> VoiceOps at voiceops.org
>> VoiceOps mailing list
>> VoiceOps at voiceops.org
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19635 97th Ave
Mokena, IL 60448
Business Internet & Phone Services
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