[VoiceOps] FCC 499A and traffic studies

[Nathan Anderson]

'lo,

Not sure if this is the right forum to talk about this (regulatory policy/rules, and U.S. centric ones to boot); if not, feel free to ignore.

We're doing interconnected VoIP, and for past 499A filings we have just elected to use the statutory "safe harbor" inter/intrastate traffic ratio of 64.9%/35.1% for providers like us.  This time around, we are trying our hands at some traffic studies, but it's unclear to me exactly what traffic we are supposed to be capturing in these.  Do they want all traffic captured, or just traffic that could be conceivably billed to the customer (regardless of whether it actually is or not; we don't do postpaid minutes billing) and thus is potentially revenue-generating?

That is to say, should a comprehensive traffic study capture all minutes, or just call termination minutes?  And should call termination minutes that are the result of a customer of ours dialing a toll-free number be counted, since the callee would be picking up the tab on those?  (Seems to me that revenues for interstate toll-free and collect calls should be reported by the callee's phone company, and revenues for interstate toll calls reported by the caller's phone company.  Thus why I wonder whether our traffic study should ignore outbound toll-free minutes and also ignore all inbound minutes UNLESS the inbound call is to a toll-free DID.)

Also, what technically constitutes an interstate call?  Can that be determined solely based on the area code of the caller and callee, or can (or should) the actual call path be the deciding factor?  How do nomadic (e.g., mobile/wireless) providers handle this?  If someone with a mobile that has a New York number is physically in Seattle with that phone, and the phone is connected to a cell in Seattle, and (s)he calls a Seattle landline, is that an interstate call or an intrastate call?

Thanks,

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