Tiki Gaugler. XO Communications Sunrise Valley Drive Herndon, VA (703) September 27, 2011.

Transcription

1 Tiki Gaugler XO Communications Sunrise Valley Drive Herndon, VA (703) September 27, 2011 Ex parte VIA ECFS Marlene H. Dortch Secretary Federal Communications Commission th Street, SW Washington, DC Re: Connect America Fund, WC Docket No ; A National Broadband Plan for Our Future, GN Docket No ; Establishing Just and Reasonable Rates for Local Exchange Carriers, WC Docket No ; High-Cost Universal Service Support, WC Docket No ; Developing an Unified Intercarrier Compensation Regime, CC Docket No ; Federal-State Joint Board on Universal Service, CC Docket No ; Lifeline and Link-Up, WC Docket No On September 26, Lisa Youngers, Kevin Joseph and I, on behalf of XO Communications, LLC ( XO ) met with Zac Katz, Legal Advisor to Chairman Genachowski for Wireline Communications, International and Internet Issues, and Rebekah Goodheart of the Wireline Competition Bureau, to discuss intercarrier compensation reform. XO urged the Commission to include IP interconnection policies in conjunction with reduced TDM-based rates in order to provide a balanced industry approach to reform. At a minimum, the Commission should confirm in this proceeding that telecommunications carriers must negotiate arrangements for IP-based interconnection with other carriers. The discussion in the meetings was consistent with XO s filings in the above-captioned proceedings and followed the attached presentation, which was distributed at the meeting. Respectfully Submitted, /s/ Tiki Gaugler Federal Regulatory Counsel Attachment cc: Zac Katz Rebekah Goodheart

2 Intercarrier Compensation and IP Interconnection

3 ABC and RLEC proposals Cannot be considered consensus Do not include CLEC input despite significant impact on competitive providers Do not address CLEC concerns about IP interconnection Improperly apply higher access rates on VoIP services 2

4 VoIP and IP-enabled services VoIP and other IP-PSTN services are jurisdictionally mixed and should be regulated at interstate level Classification of VoIP services is not necessary at this time FCC determination of proper intercarrier compensation scheme for IP-PSTN services should apply prospectively: IP-PSTN traffic should not be subject to access charges under 251(g) Termination rates for IP-PSTN traffic should be regulated under sections 251(b)(5) and 201 and immediately set at reciprocal compensation levels IP-PSTN traffic must be designated upfront as IP-enabled to avoid future billing disputes Subjecting VoIP to access rates and also requiring TDM conversion subjects VoIP services to higher costs, whereas immediately applying lower rates would encourage IP deployment 3

5 Promote IP Interconnection Policies Focus of intercarrier compensation policies must shift from circuit-switched (TDM) to IP networks to reflect market developments (regardless of technology used to serve end users) Eliminate LATA and other jurisdictional traffic boundaries Current intercarrier compensation and TDM network interconnection arrangements are inefficient Carriers are rapidly deploying innovative IP-enabled services to end users, thus TDM interconnection arrangements are quickly becoming outdated Even where end users are served via TDM technology, IP interconnection and transport provides lower cost and more efficient exchange of traffic Adoption of strong IP interconnection policies within intercarrier compensation regime will create proper 4 incentives to spur additional broadband deployment

6 Section 251 IP Interconnection Commission should adopt specific rules to create proper financial incentives to invest in IP-based networks Section 251(a) requires all telecommunications carriers to interconnect with other carriers The Act is technology neutral so this includes interconnection with IP-based networks Section 251(c)(2) requires ILECs to provide interconnection, at any technically feasible point within the carrier s network Includes interconnection to ILEC s IP network for exchange of traffic in IP format regardless of technology used to serve end users Format of carrier-to-end user exchange determined by serving carrier 5

7 TDM-Based Services All intercarrier compensation rates should be regulated within a federal framework under section 251(b)(5) Need swift transition to lower intercarrier compensation rates uniformly applicable to all carriers Disparate rates lead to arbitrage opportunities Additional subsidies should be explicitly addressed by universal service 6

8 Universal Service Focus CAF on support for broadband services Cap high cost fund at current level Ensure competitively and technologically neutral distributions and recovery mechanisms Quickly address USF contribution issues 7