In November of 2011, the Federal Communications Commission (FCC) announced sweeping changes that would dramatically alter the landscape of telecommunications in the United States. The Commission made the decision to take on several major issues head-on by reforming the nature of Intercarrier Compensation and banning certain practices that led to the development of cost-avoidance loopholes, which significantly impaired call quality in favor of higher voice margins.
For most organizations, it has taken an army of regulatory attorneys [wearing very thick glasses] to figure out the phase-in requirements of the FCC’s vision as outlined in the 750+ page report. Many operators that built their business around exploiting these loopholes suddenly found that their viable and profitable businesses had a shelf life, with a fast approaching expiration date.
Fast forward 2 years to the present day and the Commission is once again throwing the industry into a tailspin with the announcement of the Order for Rural Call Completion. If you’ve read through the first paragraph of this document and are still interested enough to be reading this blog, you are undoubtedly aware of the Rural Call Completion Order and have some stake in the outcome or the reporting requirements. From a personal perspective, I can’t help but marvel at the present Order. The pragmatist in me questions the incredibly poor timing. With the phase-in of the ICC and the ultimate goal of embracing a bill and keep interconnect framework, this Order seems rather pointless.
Everyone who understands the changes that are already being phased-in each July knows that the cost avoidance practices that led to poor call completion rates for rural LECs will have become moot within the next 24 months – with or without the Order. Let’s face it, no one out there is paying nine cents per minute for termination to high cost OCNs anymore, and they haven’t for a while. Inter and Intra State rates were leveled in July 2013. July of 2014 will see access tariffs effectively reduced by about 1/3, on their way to intermediate rates of .005/minute for Rate of Return LECs and .0007 for Price Cap LECs. Even though these rate structures aren’t ‘bill and keep’, the low interconnect rate functions as an effective enough deterrent to prevent the shady cost-management practices that resulted in poor service to customers of Rural LECs. Put another way, there simply won’t be a reason to play LCR hot-potato with calls to Rural LECs anymore.
Which brings me to my point. If the financial issues that led to poor Rural LEC service are about to evaporate, why is the Commission launching onerous reporting and retention requirements now? Well, I don’t have an answer, other than my usual speculation and conspiracy theories. But what I do know is that most of the organizations we’re speaking with, even today, have no viable plans that will allow them to fulfill the requirements of the Order. With compliance deadlines fast approaching, and few viable candidates that provide this type of service, operators will find themselves grappling between internally hacking together a reporting solution [and taking some chances as to the accuracy of something that is rushed through the development cycle] or finding a software partner to help.
We’ve anticipated this issue at WeDo Technologies, and are working with service providers to help them comply with the new requirements. We think complying with the Commission’s requirements shouldn’t be scary or break the budget. In fact, with the FCC providing very little insight into how long this new report will be required, WeDo Technologies believes service providers should be cautious about investing too many internal resources into developing a solution to support it. Find out more about how we’re supporting the industry on R CC by contacting us.