[VoiceOps] Direct CLEC interconnect - taking the plunge

Jay Hennigan jay at west.net
Thu Oct 18 14:02:50 EDT 2012

On 10/18/12 10:27 AM, Joe Fratantoni wrote:
> 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.

We are already a CLEC - for access to customer loops, duct, and

The reasons we are looking for direct interconnect:

* The majority of our customers are in one LATA.
* Shorter and consistent path back to the TDM world (fax, anyone?)
* More control over the porting process.
* Avoiding "Your intermittent issue is at an upstream carrier that we
can't name (Voldemort?) and we've asked them to fix it.  They report
that it's with an upstream carrier of theirs that they can't name..."

The last one is really aggravating when it happens, which seems to be
more and more frequently.

> 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?

Already in multiple local COs with DSLAMs, SHDSL, dark fiber.

> 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.

Good advice.  We already have a person dealing with much of this.
Ordering loops, CO co-location etc.  And we have people dealing with
number ports, e-911 location updates, etc with the other carriers.

And the below is gold - going in our wiki and being passed on.  Many thanks!

> 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

Jay Hennigan - CCIE #7880 - Network Engineering - jay at impulse.net
Impulse Internet Service  -  http://www.impulse.net/
Your local telephone and internet company - 805 884-6323 - WB6RDV

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