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Cybertelecom
Federal Internet Law & Policy
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VoIP :: Interconnection Dont be a FOOL; The Law is Not DIY


Proceedings which raised on addressed telephony interconnection, begging questions about Internet interconnection but frequently confusing IP interconnection (layer 3/4) and telephony interconnection (application layer interconnection).

PSTN -> IP Transition

In the Broadband Plan, the Broadband Team recommended that the FCC examine and promote the transition of the PSTN to the Internet Protocol.  In the winter of 2012, AT&T filed a petition asking for permission to run a field experiment of a transition to a full IP transition, and the FCC placed this petition out for comment.  One issue raised (and confused) in this proceeding is IP interconnection.  Many commenters attempted to address legacy telephony interconnection and how that transitions to VoIP interconnection.  But in many of the presentations and comments, the stakeholders referred to “IP interconnection” (confusing Internet interconnection and application interconnection).

Universal Service Reform / Intercarrier Compensation

In order to reform universal service and intercarrier compensation (reciprocal compensation, access charges, settlement fees), and bring universal service into the broadband era, the FCC is striving to reform the entire system of settlements and payments between carriers. The old system was built in the era of a monopoly telephone network, and included the promise of universal service through, at that time, implicit subsidies, and involved the division between state and federal jurisdiction. As the network moves from the analog telephone network to an all IP network with VoIP applications, the FCC must reform the old PSTN interconnection rules as they will now apply in an IP environment. The problem, in the IP network environment, is how to distinguish and make rules for telephony interconnection as opposed to Internet interconnection (peering and transit).

42: IP-to-IP Interconnection. We recognize the importance of interconnection to competition and the associated consumer benefits. We anticipate that the reforms we adopt will further promote the deployment and use of IP networks, and seek comment in the accompanying FNPRM regarding the policy framework for IP-to-IP interconnection. We also make clear that even while our FNPRM is pending, we expect all carriers to negotiate in good faith in response to requests for IP-to-IP interconnection for the exchange of voice traffic

652: This Order also makes clear the prospective payment obligations for VoIP traffic and adopts a transitional intercarrier compensation framework for VoIP. In addition, we clarify certain aspects of CMRS-LEC compensation to reduce disputes and address existing ambiguity. We also make clear our expectation that carriers will negotiate in good faith in response to requests for IP-to-IP interconnection for the exchange of voice traffic.

653: Finally, in the Further Notice of Proposed Rulemaking (FNPRM), we seek comment on the transition and recovery mechanism for rate elements not reduced as part of this Order, including originating access and certain common and dedicated transport. We also seek comment on ways to implement our expectation of good faith negotiations for IP-to-IP interconnection for the exchange of voice traffic, ways to promote IP-to-IP interconnection, as well as other implementation issues for the bill-and-keep end state.

1011: In particular, even while our FNPRM is pending, we expect all carriers to negotiate in good faith in response to requests for IP-to-IP interconnection for the exchange of voice traffic. The duty to negotiate in good faith has been a longstanding element of interconnection requirements under the Communications Act and does not depend upon the network technology underlying the interconnection, whether TDM, IP, or otherwise. Moreover, we expect such good faith negotiations to result in interconnection arrangements between IP networks for the purpose of exchanging voice traffic. As we evaluate specific elements of the appropriate interconnection policy framework for voice IP-to-IP interconnection in our FNPRM, we will be monitoring marketplace developments, which will inform the Commissionís actions in response to the FNPRM.[1]

1341: Some commenters express concern that additional protections are needed to ensure IP-to-IP interconnection, however.[2] As discussed above, we expect all carriers to negotiate in good faith in response to requests for IP-to-IP interconnection for the exchange of voice traffic, and that such good faith negotiations will result in interconnection arrangements between IP networks,[3] and we seek comment below on which of the various possible statutory provisions as well as standards and enforcement mechanisms we should adopt to implement our expectation that carriers negotiate in good faith. We also seek comment on actions the Commission could take to, at a minimum, encourage the transition to IP-to-IP interconnection where efficient. In particular, we propose that if a carrier that has deployed an IP network receives a request to interconnect in IP, but instead requires TDM interconnection, the costs of the IP-to-TDM conversion would be borne by the carrier that elected TDM interconnection. We seek comment on this proposal. We also seek comment on other measures that Commission might adopt to encourage efficient IP-to-IP interconnection.

1347. Alternatively, other comments seem to anticipate that IP interconnection policies could encompass IP traffic other than voice.2451 Would it be appropriate to encompass any non-voice IP traffic or services in such a framework, and how would they be defined? We note, for example, that the Commission historically has not regulated interconnection among Internet backbone providers. If a different interconnection policy framework were adopted in this context, how would it be distinguishable? To what extent would an IP-to-IP interconnection policy framework address interconnection rights for both voice and non-voice traffic, or to what extent would providers simply have the freedom to use otherwise-available interconnection arrangements to exchange particular IP traffic or services? [Universal Service Reform FCC No. 11-161 2011]

Time Warner Petitions

TW Telecom Petition Re Direct Ip-To-Ip Intercon Per Sec 251(C)(2) Of Comm Act WC Docket No. 11-119

Public Notice: "On June 30, 2011, TW Telecom inc. (TWTC) filed a petition for a declaratory ruling that TWTC has the right under section 251(c)(2) of the Communications Act , as amended, [1] to direct IP-to-IP interconnection with incumbent LECs for certain IP-based services. [2]   In particular, TWTC seeks direct IP-to-IP interconnection from incumbent LECs for the transmission and routing of TWTC's facilities-based Voice over Internet Protocol (VoIP) services and for voice services that originate and terminate in Time Division Multiplexing (TDM) format but are converted to IP format for transport (IP-in-the-middle voice services). [3]   As part of its request, TWTC asks the Commission to clarify that TWTC's facilities-based VoIP services are telecommunications services as well as telephone exchange services and/or exchange access. [4]  

Parties may file comments on either or both petitions on or before August 15, 2011 and reply comments on or before August 30, 2011 . All pleadings should reference WC Docket No. 11-119 .

. . . . . 

For further information regarding this proceeding, contact Melissa Droller Kirkel, Competition Policy Division, Wireline Competition Bureau, 7958, or Jean Ann Collins, Competition Policy Division, Wireline Competition Bureau, 2792.

Released:  07/15/2011.  COMMENT SOUGHT ON TW TELECOM INC. PETITION FOR DECLARATORY RULING REGARDING DIRECT IP-TO-IP INTERCONNECTION PURSUANT TO SECTION 251(C)(2) OF THE COMMUNICATIONS ACT. (DA No.  11-1198). (Dkt No 11-119 ). Comments Due:  08/15/2011. Reply Comments Due:  08/30/2011. WCB . PDF WORD TXT

Time Warner Petition Docket 06-55

Time Warner Cable Request for Declaratory Ruling that Competitive Local Exchange Carriers May Obtain Interconnection Under Section 251 of the Communications Act of 1934, as Amended, to Provide Wholesale Telecommunications Services to VoIP Providers, WC Docket No. 06-55, Memorandum Opinion and Order, 22 FCC Rcd 3513, 3519-20, para. 13 (Wireline Competition Bureau 2007) (permitting wholesale carriers to provide interconnection for VoIP provider customers facilitates the introduction of new technology and the availability of VoIP services).

Rural telecos sought to block interconnection with TW CLEC VoIP by having state PUC's rural that TW CLEC VoIP was not eligible for interconnection rights.

3/1/07 Time Warner Cable Request for Declaratory Ruling that Competitive Local Exchange Carriers May Obtain Interconnection Under Section 251 of the Communications Act of 1934, as Amended, to Provide Wholesale Telecommunications Services to VoIP Providers. Order: Word | Acrobat Martin Press Statement: Word | Acrobat

In this Order, the Wireline Competition Bureau (Bureau) grants a petition for declaratory ruling filed by Time Warner Cable (TWC) asking the Commission to declare that wholesale telecommunications carriers are entitled to interconnect and exchange traffic with incumbent local exchange carriers (LECs) when providing services to other service providers, including voice over Internet Protocol (VoIP) service providers pursuant to sections 251(a) and (b) of the Communications Act of 1934, as amended (the Act).  As explained below, we reaffirm that wholesale providers of telecommunications services are telecommunications carriers for the purposes of sections 251(a) and (b) of the Act, and are entitled to the rights of telecommunications carriers under that provision.  We conclude that state commission decisions denying wholesale telecommunications service providers the right to interconnect with incumbent LECs pursuant to sections 251(a) and (b) of the Act are inconsistent with the Act and Commission precedent and would frustrate the development of competition and broadband deployment.

On March 1, 2006, TWC filed a petition for declaratory ruling requesting that the Commission affirm that “requesting wholesale telecommunications carriers are entitled to obtain interconnection with incumbent LECs to provide wholesale telecommunications services to other service providers” (including VoIP-based providers).

In its Petition, TWC states that in 2003 it began to deploy a facilities-based competitive telephone service using VoIP technology, which enables it to offer a combined package of video, high-speed data, and voice services. TWC purchases wholesale telecommunications services from certain telecommunications carriers, including MCI WorldCom Network Services Inc. (MCI) and Sprint Communications Company, L.P. (Sprint), to connect TWC’s VoIP service customers with the public switched telephone network (PSTN). MCI and Sprint provide transport for the origination and termination on the PSTN through their interconnection agreements with incumbent LECs.  In addition, MCI and Sprint provide TWC with connectivity to the incumbent’s E911 network and other necessary components as a wholesale service.

TWC claims that MCI has been unable to provide wholesale telecommunications services to TWC in certain areas in South Carolina and that Sprint has been unable to provide wholesale telecommunications services to TWC in certain areas in Nebraska because, unlike certain other state commissions, the South Carolina Public Service Commission (South Carolina Commission) and the Nebraska Public Service Commission (Nebraska Commission) have determined that rural incumbent LECs are not obligated to enter into interconnection agreements with competitive service providers (like MCI and Sprint) to the extent that such competitors operate as wholesale service providers.

TWC argues that the South Carolina and Nebraska Commissions misinterpreted the statute when they decided, among other things, that competitive LECs providing wholesale telecommunications services to other service providers, in this case VoIP-based providers, are not “telecommunications carriers” for the purposes of section 251 of the Act, and, therefore, are not entitled to interconnect with incumbent LECs.

TWC asks the Commission to grant a declaratory ruling reaffirming that telecommunications carriers are entitled to obtain interconnection with incumbent LECs to provide wholesale telecommunications services to other service providers.  The Petition also requests that the Commission clarify that interconnection rights under section 251 of the Act are not based on the identity of the wholesale carrier’s customer.

PLEADING CYCLE ESTABLISHED FOR COMMENTS ON TIME WARNER CABLE'S PETITION FOR DECLARATORY RULING THAT COMPETITIVE LOCAL EXCHANGE CARRIERS MAY OBTAIN INTERCONNECTION TO PROVIDE WHOLESALE TELECOMMUNICATIONS SERVICE TO VOIP PROVIDERS.,

On March 1, 2006, Time Warner Cable (TWC) filed a petition for declaratory ruling requesting that the Commission affirm that competitive local exchange carriers (LECs) are entitled to interconnect with incumbent LECs pursuant to Section 251 of the Communications Act of 1934 (the Act), as amended, for the purpose of exchanging traffic on behalf of VoIP-based providers. TWC asserts that the public service commissions of South Carolina and Nebraska misinterpreted the statute when issuing decisions finding, among other things, that competitive LECs providing wholesale telecommunications services to other service providers are not “telecommunications carriers” for the purposes of Section 251 of the Act, and, therefore, are not entitled to interconnect with incumbent LECs. Specifically, TWC argues that competitive LECs selling telecommunications services on a wholesale basis are telecommunications carriers and are entitled to interconnection under Section 251.

See also

Interconnects - SBC Tutorial from Catharine24