[VoiceOps] CALEA for the small fry operator

[Nathan Anderson]

For the purposes of USF and the 499 A/Q filing process, the FCC does not restrict "interconnected VoIP" carriers to those who have actual interconnection agreements with LECs and the facilities necessary to carry out those interconnections.  Otherwise, again, we could get away with never filing a 499A or Q again or paying into USF (right now we are still "de minimis" but I expect that will probably change within the next year or two).

We get our DIDs from a partner CLEC local to the area and they trunk calls to those numbers to us via IP/SIP over the public internet.  We currently terminate outbound calls via Flowroute.  For E911, we use 911ETC, which resells iNetwork's platform (f.k.a. "dash carrier services").

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Nathan Anderson
First Step Internet, LLC
nathana at fsr.com

-----Original Message-----
From: voiceops-bounces at voiceops.org [mailto:voiceops-bounces at voiceops.org] On Behalf Of Carlos Alvarez
Sent: Friday, January 18, 2013 3:24 PM
To: voiceops at voiceops.org
Subject: Re: [VoiceOps] CALEA for the small fry operator

On Fri, Jan 18, 2013 at 4:02 PM, Nathan Anderson <nathana at fsr.com> wrote:


	Furthermore, I don't think the section you quoted makes mention of LECs.  It says "Facilities-Based BROADBAND INTERNET ACCESS Providers".  So they aren't necessarily even talking about LECs here (although some LECs -- ones that have an ISP arm or division -- would be a subset of that group).  I don't think "facilities-based" is a term with a specific legal definition that means "telecom company with their own switch".  They are referencing "facilities-based" (that is, non-resellers/"white-labelers") ISPs (such as us), and "interconnected" VoIP providers (VoIP services that "interconnect" with the PSTN and use NANP TNs, such as Vonage, and now us).
	


The "interconnected" part could bear some refinement.  We no longer directly connect to any carriers using traditional telephony methods.  We only connect to other carriers via SIP.  Technically, we aren't "interconnected" as we ourselves don't facilitate connectivity between IP and the PSTN.  We facilitate connection between IP and IP.  That may or may not be too fine a point.

How do you connect to the PSTN?

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Carlos Alvarez
TelEvolve
602-889-3003