NTCA is the latest organization to petition for a rulemaking...

regulation” that retains parts of the existing regulatory framework that protect consumers, while jettisoning regulations that have limited applicability in an IP world. The commission should develop a list of existing regulations that may have limited applicability in an IP world, and seek comment on which of those regulations should be eliminated, retained or modified, NTCA said. Regulations to be eliminated could include legacy discontinuance requirements and equal access dialing parity rules, said Michael Romano, senior vice president-policy. The association said this proposal would lead to a “comprehensive, but granular ‘refreshing'” of the regulatory framework that would promote regulatory certainty and provide peace of mind to lenders and investors. While its review is under way, the commission should implement an incentive-based mechanism that lets carriers recover costs for the exchange of communications traffic where they agree to make available IP-based interconnection, NTCA said. Incentivized IP-to-IP interconnection would promote investment in IP networks, Romano told us. NTCA asked the commission to confirm that “all interconnection for the exchange of traffic subject to sections 251 and 252 is governed by the [Telecom] Act, regardless of the technology that might happen to be used to achieve such interconnection.” Romano acknowledged a “big debate” as to whether traffic exchanged on an IP basis between carriers is subject to the interconnection duties. After the FCC said last year that VoIP and other telecom traffic is subject to the intercarrier compensation requirements of Sections 251 and 252 -- and used that rationale to take jurisdiction to change ICC rates on those systems -- then “it must follow” that interconnection for the exchange of such traffic is also subject to the Act, Romano said.