Tuesday, August 23, 2011

COMPTEL Lobbies for Amendment to ILECs' Intercarrier Compensation Plan

COMPTEL, which is an industry association representing competitive communications service providers and their supplier partners, filed comments with the FCC regarding universal service and intercarrier compensation (ICC) reform. Specifically, COMPTEL is proposing a Competitive Amendment to the ILECs' ABC Plan released in July. The amendment seeks to:




  • Remove Uncertainty Regarding IP-to-IP Interconnection – Since the circuit-switched architecture of today's PSTN will ultimately be replaced with an IP architecture, it is vital that nondiscriminatory, cost-based IP interconnection agreements must replace the circuit-switched interconnection agreements that underlie today's PSTN so that the transition to an IP-based PSTN will be seamless. Modifications to the intercarrier compensation regime to facilitate an IP environment should also make clear that the basic legal framework for seamless interconnection – i.e., the competitive protections of Sections 251/252 – applies in a technology neutral manner. Addressing compensation without enforcing the appropriate legal framework will do nothing to promote a ubiquitous competitive broadband environment.


  • Ensure Cost-Based Rates for All Transport as well as Termination – The COMPTEL Competitive Amendment would ensure reforms comply with the statutory mandate that all transport and termination rates for traffic under section 251(b)(5) be cost-based. Irrespective of their previous labels as interstate access, intrastate access, local, VoIP or any other categorization, all calls should be considered under the provisions of Section 255(b)(5) and the associated pricing regulations under 252(d)(2) should be applied with equal force to all transport and termination.


"The ILECs' proposal [also known as the ABC Plan] does nothing to promote deployment of next-generation IP networks because it further entrenches the greatest obstacle to such deployment: The refusal by most ILECs to negotiate interconnection agreements that comply with the critical competitive protections of Section 251 and 252 of the Act," COMPTEL's comments noted. "The ABC plan is designed to perpetuate and protect ILEC revenues, while dramatically reducing competitors' revenues and denying competitors access to cost-based transport as required by law. In contrast, the Competitive Amendment provides a framework that addresses the needs of the industry as a whole." http://www.comptel.com

  • A coalition of six of the leading carriers in the U.S., submitted a proposal to the FCC for reforming the Universal Service Fund (USF) and the Intercarrier Compensation (ICC) system. Members of the group include AT&T, CenturyLink, FairPoint, Frontier, Verizon and Windstream -- which collectively serve the vast majority of U.S. wireline customers, including those residing in high-cost rural areas, which are the primary focus of USF support.


  • The big telcos said the key aim of their proposal is to speed broadband deployment to more than 4 million Americans living in rural areas. They also announced an agreement with three organizations that represent small carriers on a framework for complementary reform. Joining the companies in support of reform are the National Telecommunications Cooperative Association, the Organization for the Promotion and Advancement of Small Telecommunications Companies and Western Telecommunications Alliance.

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