Commenters Suggest Changes to Proposed Call Completion Reporting Rules

The rules proposed in the NPRM “require clarification and refinement in order to assure the collection of meaningful data,” said the National Exchange Carrier Association, NTCA, the Western Telecommunications Alliance and the Eastern Rural Telecom Association (http://bit.ly/10FBPoc). Only facilities-based providers with control of the initial long-distance routing, should be subject to reporting requirements, as “they are best able to supply the necessary call performance data,” the rural associations said. They also questioned the proposed reporting threshold of 100 calls per month per operating carrier number, which “would fail to capture call completion failures at the smallest rural telephone companies.” With sufficient modifications, the proposed rules -- “paired with enforcement action” -- might eliminate the call completion problems “that currently plague rural America,” the group said.

The American Cable Association agreed that the responsibility for fixing call completion problems “should rest with the initial facilities-based” long distance provider (http://bit.ly/10Fz721). Non-facilities-based long distance providers, on the other hand, “do not control call routing nor do they directly have access to complete information to track a call to completion,” ACA said. “Imposing monitoring and reporting burdens” on them would be “inefficient,” it said. Time Warner Cable agreed, saying “the NPRM’s proposals sweep far too broadly” (http://bit.ly/YHuCqb). The cable company said it was “skeptical” about requiring interconnected VoIP providers or other originating providers to retain and report call completion data. “There is no evidence” these providers are responsible for the problems delivering calls to rural customers, Time Warner Cable said. “Rather, intermediate providers and long-distance carriers are the widely acknowledged cause of those issues.”

Comcast, however, said the commission’s approach to reporting and recordkeeping “appears to be sound,” and should apply to both originating and terminating service providers (http://bit.ly/10FxhOW). The company already collects the required information, and is fine with reporting it quarterly as long as call detail and sensitive information is stripped out before it’s publicly disclosed. Comcast questioned the commission’s use of a “call answer rate” metric that divides the number of call attempts by the total number of calls. Some types of calls should be excluded, Comcast said, such as call attempts that are handed back to the upstream provider; auto-dialer traffic; and calls to toll-free numbers, because “the originating service provider” there “has no way to implement remedial measures if problems are detected."

CompTel said it’s concerned that although the proposed reporting, record-keeping and data retention requirements “may confirm that a call completion problem exists in rural areas,” they won’t do much to “ensure that telephone service to rural customers is as reliable as service to the rest of the country” (http://bit.ly/10FBq5a). Cbeyond, EarthLink, Integra Telecom and tw telecom want the commission to “craft rules that account for the characteristics of the commercial arrangements used by carriers to provide long-distance service” (http://bit.ly/10FC82r). The FCC should do a better job defining which providers qualify as “facilities-based,” such as where a LEC resells long-distance service provided by another carrier, the CLECs said. Inter-carrier reporting and troubleshooting also deserve attention, they said, urging the commission to develop rules “mandating information exchange and problem resolution between carriers regarding call completion problems.” Such rules would “both accelerate resolution of these problems and assist the Commission in identifying those entities that are the source of call failures and degradation,” they said.

Although rural call completion offers a “particularly troublesome access arbitrage issue,” the proposed data collection -- comparing rural and urban call completion rates -- “introduces unnecessary variables into the data analysis,” USTelecom said (http://bit.ly/10FwA8e). “If the issue is truly related to access arbitrage, then call completion should be measured by the rate of call completion to carriers with various levels of terminating access rates, which do not necessarily correlate with the urban or rural status of an area.” The association also called for “uniform” data retention requirements across providers. Excluding any provider that’s terminating calls to rural customers where there’s a higher terminating access rate would “encourage further arbitrage, in that providers engaging in such arbitrage have a competitive advantage over those who complete calls and pay the appropriate access rates,” USTelecom said.

The record already contains “ample evidence” that calls to rural customers frequently end in failure, said NASUCA (http://bit.ly/10FC2YI). But while the FCC is focusing on interstate calls, the completion problem also occurs on intrastate calls, the association of state utility advocates said. “The FCC should -- at the very least -- encourage action by state commissions to address this serious and widespread problem.”