Jan 15, 2018 10:00:00 AM
That’s right, just when you thought the FCC’s terminating switched access reforms to a bill-and -keep regime would make your life simpler, it turns out things are much more complex – and error prone – than ever. For example, in one New York state Local Access and Transport Area (LATA) terminating switched access cost per minute (CPM) can range from $0.00070000 to $0.00883148, that’s over twelve times higher! We’ll share the gory details later in the blog, but first some background.
The July 1, 2017 access filings added a brand-new twist to terminating access rate management, the notion of “affiliation”. Simply put, if the access tandem (AT) and the terminating end office (EO) are owned by the same incumbent local exchange carrier (ILEC) , i.e. affiliated and are price cap regulated - one set of rate elements apply; if the access tandem and the terminating end office are owned by two different ILECs, i.e. non-affiliated, another set of rate element apply.
Jan 12, 2018 10:00:00 AM
Several diverse companies have banded together to complain to the FCC that despite the transition of terminating switched access rates to bill-and-keep, national wireless carriers are engaging in traffic aggregation schemes at the terminating end of calls. In a December 4, 2017 ex parte presentation in Docket 10-90, the Klein Law Group representing Consolidated Communications, Peerless Network and West Telecom Services noted that:
By refusing direct interconnection (and in some cases terminating existing connections altogether) for all terminating traffic or certain types of terminating traffic (e.g., interMTA and/or wholesale traffic), these wireless carriers are forcing such terminating traffic to be routed through their “intermediate carrier partners” or “affiliates” and as a result, originating carriers no longer can terminate such traffic to these wireless carriers on a bill-and-keep basis. (Klein Law Group, ex parte, at p. 3).