Before the PUBLIC SERVICE COMMISSION OF WISCONSIN Madison Wisconsin

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "Before the PUBLIC SERVICE COMMISSION OF WISCONSIN Madison Wisconsin"

Transcription

1 Before the PUBLIC SERVICE COMMISSION OF WISCONSIN Madison Wisconsin Investigation of Voice over ) Case No. 5-TI-2071 Internet Protocol in Wisconsin ) Public Comments of Communications Workers of America Frank Mathews CWA Representative, Wisconsin and Illinois 106 S. Wynstone Park Drive, Suite 104 North Barrington, Illinois February 15, 2011

2 The Communications Workers of America (CWA) submits these public comments in the Commission Investigation of Voice over Internet Protocol in Wisconsin. 1 CWA represents more than 5,600 employees in Wisconsin who work at AT&T (wireline and wireless), Frontier, CenturyLink, and other telecommunications companies. CWA members have an interest in this proceeding as consumers as well as workers in the industry. The Commission seeks comment on the appropriate level of regulation that should apply to fixed, interconnected VoIP service. Fixed, interconnected VoIP service ( VoIP service ), such as A&T s U-Verse Voice offering or Time Warner s Digital Home Phone offering, is the practical equivalent of traditional telephone service. It is simply a means to transmit voice telephone calls from one end user to another via the telecommunications network, and as such, falls squarely within the Commission s definition of a telecommunications service. Federal law does not preempt state regulation of fixed, interconnected VoIP service. Since regulatory oversight to protect consumers should be based on the service offered, not on how it is delivered, the Commission should regulate VoIP service as a telecommunications service, subject to the same rules and consumer protections that apply to traditional telephone service. I. Interconnected, fixed VoIP service is a telecommunications service The Wisconsin statute (9m) defines a telecommunications service as the offering for sale of the conveyance of voice, data or other information at any frequency over any part of the electromagnetic spectrum, including the sale of service for collection, storage, forwarding, switching and delivery incidental to such communication and including the regulated sale of customer premises equipment. Wisconsin statute (10) defines a telecommunications 1 Public Service Commission of Wisconsin, Investigation of Voice over Internet Protocol (VoIP) in Wisconsin, Case No. 5-TI-2071, Notice of Proceeding and Prehearing Conference, Oct. 26, 2010; Second Amended Prehearing Conference Memorandum, Nov. 16, 2010; Third Amended Prehearing Conference Memorandum, Jan. 19,

3 utility as any organization that owns, operates, manages or controls any plant or equipment used to furnish telecommunications services within the state directly or indirectly to the public. Clearly, VoIP service meets the plain language definition of a telecommunications service. A VoIP service such as AT&T s U-Verse or Time Warner s Digital Home Phone offers for sale the conveyance of voice, data or other information at any frequency over any part of the electromagnetic spectrum. A VoIP service allows customers to make voice telephone calls to any other person or entity with an assigned telephone number. The statute is agnostic as to how such a call is transmitted or processed. The utilization by AT&T s U-Verse or Time Warner s Digital Home Phone of devices that permit the translation of analog voice signals into digitized signals with Internet Protocol (IP) codes that direct the data bits through the network is virtually identical, from a customer s perspective, to the service offered through traditional analog plain old telephone service. (POTS) The Federal Communications Commission (FCC) has had an open proceeding to determine, among other things, whether IP-enabled services such as VoIP should be categorized as either a telecommunications or information service, and what, if any, federal regulations should govern such services in the future. To date, the FCC has not issued a final order or administrative rule in this matter. 2 However, in a number of proceedings the FCC has indicated that it sees merit in the conclusion that VoIP service is a telecommunications and not an information service. In a 2009 letter, the Federal Communications Commission (FCC) Wireline Competition Bureau indicated that it would appear that Comcast s VoIP service is a telecommunications service subject to 2 See IP-Enabled Services Proceeding, 19 FCC Rcd

4 regulation under Title II of the Communications Act, as amended. 3 Further, in determining the eligibility of VoIP providers for federal E-Rate support, the Commission stated: We also adopt the USAC s proposal that interconnected VoIP be listed in both the telecommunications and Internet access categories of the ESL, despite the fact that the Commission has not yet determined the regulatory classification of interconnected VOIP. 4 Recently, the FCC issued a Declaratory Ruling in response to petitions from the Nebraska and Kansas commissions which authorized states to extend their universal service contribution requirements to nomadic interconnected VoIP services providers. 5 Universal service contributions are typically assessed on telecommunications carriers. The FCC in a series of other proceedings has ruled that VoIP providers are subject to a number of regulatory obligations, including contributions to the federal Universal Service Fund, 911 obligations, disability access, customer privacy, local number portability and numbering administration, discontinuance notifications, and public safety requirements. 6 3 Letter from Dana Shaffer, Chief, Wireline Competition Bureau and Matthew Berry, General Counsel, Federal Communications Bureau, to Kathryn A. Zachem, Vice President, Regulatory Affairs, Comcast Corporation, dated Jan. 18, Federal Communications Commission, Report and Order and Further Notice of Proposed Rulemaking, CC Docket No. 02-6, Dec. 2, 2009, para Federal Communications Commission, Declaratory Ruling, In the Matter of Universal Service Contribution Methodology, Petition of Nebraska Public Service Commission and Kansas Corporation Commission for Declaratory Ruling or, in the Alternative, Adoption of Rule Declaring that State Universal Service Funds May Assess Nomadic VoIP Intrastate Revenues, WC Docket No , Nov. 5, See, e.g., IP-Enabled Services; 911 Requirements for IP-Enabled Service Providers, WC Docket Nos , , First Report and Order and Notice of Proposed Rulemaking, 20 FCC Rcd (2005) (VoIP E911 Order) (E911), aff d, Nuvio Corp. v. FCC, 473 F.3d 302 (D.C. Cir. 2006); Communications Assistance for Law Enforcement Act and Broadband Access and Services, ET Docket No , First Report and Order and Notice of Proposed Rulemaking, 20 FCC Rcd (2005) (assistance for law enforcement); IP-Enabled Services, WC Docket No , Report and Order, 22 FCC Rcd (2007) (disability access); Implementation of the Telecommunications Act of 1996: Telecommunications Carriers Use of Customer Proprietary Network Information and Other Customer Information, CC Docket No , Report and Order and Further Notice of Proposed Rulemaking, 22 FCC Rcd 6927 (2007) (customer privacy); Telephone Number Requirements for IP-Enabled Services Providers, WC Docket No , Report and Order, Declaratory Ruling, Order on Remand, and Notice 4

5 The Wisconsin statutory definition of telecommunications closely tracks the federal statute. Both the federal and Wisconsin statutes make clear that use of information processing for the management, control, or operations of a telecommunications network or the management of a telecommunications service (quoting the federal statute) does not transform a telecommunications service into an information service. 7 As the Wisconsin law makes clear, such information processing is incidental to the telecommunications service. Using Internet Protocol to transmit a voice telephone call does not magically transform the call from a telecommunications to a more lightly regulated information service. Recently, the Maine Public Utilities Commission (PUC), after a two-year investigation into the proper classification of fixed VoIP services, concluded that VoIP services meet the definition of telecommunications under federal law. The Maine PUC noted that in the absence of any action from the FCC, the Maine Commission made its own independent judgment that VoIP services met both the state and federal statutory definitions of of Proposed Rulemaking, 22 FCC Rcd (2007) (local number portability and numbering administration); IP- Enabled Services, WC Docket No , Report and Order, 24 FCC Rcd 6039 (2009) (discontinuance notifications); Universal Service Contribution Methodology; Federal-State Joint Board on Universal Service; 1998 Biennial Regulatory Review Streamlined Contributor Reporting Requirements Associated with Administration of Telecommunications Relay Service, North American Numbering Plan, Local Number Portability, and Universal Service Support Mechanisms; Telecommunications Services for Individuals with Hearing and Speech Disabilities, and the Americans with Disabilities Act of 1990; Administration of the North American Numbering Plan and North American Numbering Plan Cost Recovery Contribution Factor and Fund Size; Number Resource Optimization; Telephone Number Portability; Truth-in-Billing and Billing Format; IP-Enabled Services, WC Docket Nos , , CC Docket Nos , , , 96-45, , , , NSD File No. L-OO-72, Report and Order and Notice of Proposed Rulemaking, 21 FCC Rcd 7518, 7536, para. 34 (2006) (Interim Contribution Methodology Order), aff d in part and rev d in part, Vonage Holdings Corp. v. FCC, 489 F.3d 1232 (D.C. Cir. 2007). 7 The federal definition of telecommunications is the transmission, between or among points specified by the user, of information of the user s choosing, without change in the form or content of the information as sent and received. 47 U.S.C. 153(43). The term telecommunications service means the offering of telecommunications for a fee directly to the public, or to such classes or users as to be effectively available directly to the public, regardless of the facilities used. 47 U.S.C. 153(46). In contrast, the federal Communications Act, as amended, defines information service as the offering of a capability for generating, acquiring, storing, transforming, processing, retrieving, utilizing, or making available information via telecommunications, and includes electronic publishing, but does not include any use of any such capability for the management, control, or operations of a telecommunications network or the management of a telecommunications services. 47 U.S.C. 153(20). 5

6 telecommunications. 8 The Maine Commission stated that the correct way to construe the text of the (federal) statutory term telecommunications is to construe it literally, as Congress wrote it, and that a voice call is telecommunications 9 The Maine PUC identified three reasons to consider VoIP telecommunications. First, the user specifies the end points of the transmission by picking up the phone and dialing the number of the person he wishes to call; second, the user selects the form of the information to be transmitted by using his voice to speak into the phone and selects the content of the information by deciding what he wishes to say; and three, the form and content of what the user says into the phone is unchanged when it is heard by the recipient. The Maine PUC quotes extensively from the FCC s AT&T IP Telephony Order to support its conclusion that a conversion to IP packets is not a net protocol conversion when the form of the information, voice, is the same when sent and received. 10 The same reasoning applies in this instant proceeding. VoIP service such as AT&T s U-Verse or Time Warner s Digital Home Phone service are telecommunications services according to a plain reading of the Wisconsin and federal statutory definitions of the term. As such, they should be subject to the same regulatory framework as other telecommunications services. 8 Order, State of Maine Public Utilities Commission, Public Utilities Commission Investigation into Whether Providers of Time Warner Digital Phone Services and Comcast Digital Voice Service Must Obtain Certificate of Public Convenience and necessity to Offer Telephone Service, Docket No , Oct. 27, 2010, page Id., page Id., page See also Order, Petition for Declaratory Ruling that AT&T s Phone-to-Phone IP Telephony Services are Exempt from Access Charges, WC Docket No , FCC 04-97, April 14,

7 II. Federal statute and regulation do not preempt state regulation of interconnected, fixed VoIP as a telecommunications service As already noted, the Federal Communications Commission has not yet issued an order in the IP-Enabled Services Proceeding, and therefore has not ruled on whether fixed, interconnected VoIP service is an interstate service subject to federal regulatory preemption. It is important to differentiate between nomadic and fixed VoIP services. A nomadic VoIP service, such as Vonage, allows a customer to access the service from any device that has a broadband connection, regardless of the physical location. In contrast, a fixed VoIP service allows a customer to make a phone call from only a fixed location, such as a home or business. This instant proceeding deals with fixed VoIP service. The FCC, in its Vonage Order, ruled that nomadic VoIP service is an interstate service subject to federal preemption. But the FCC expressly declared, in argument before the Eighth Circuit Court of Appeals in a challenge to the Vonage Order that the FCC had not yet acted to preempt state regulation of fixed VoIP. The Eighth Circuit Court agreed, concluding that [the] contention that state regulation of fixed VoIP services should not be preempted remains an open issue. Minnesota 483 F.3d at The Wisconsin PUC should not refrain from subjecting fixed VoIP services to telecommunications regulation simply because the FCC may or may not, at some future date, issue an order that would have the effect of preempting state regulation of the service. To engage in preemptive preemption would be to abdicate this Commission s statutory responsibility to protect Wisconsin telecommunications consumers. 7

8 III. Interconnected, fixed VoIP services should be subject to the same regulations and consumer protections that apply to traditional telephone service The Wisconsin Commission has the obligation to treat providers of the same service the same. Imposing different regulatory treatment on similarly situated providers distorts the market, and provides competitive advantage based on regulatory arbitrage rather than superior service, innovation, or lower prices. There is simply no reason that a customer who purchases voice service transmitted with Internet protocol should be subject to fewer protections than a customer who purchases traditional voice telephony service. Telephone regulation is rooted in the fact that access to affordable, quality telephone service is essential to public safety, economic activity, and civic participation. In times of natural disaster, medical emergency, or criminal activity, a person simply must have access to telephone service. One cannot participate in economic or civic life without voice telephony. Because telephone service however delivered is an essential service, federal and state jurisdictions have long regulated voice telephony in the public interest. Recognizing that some regulatory requirements may no longer be necessary in a competitive environment, the Wisconsin legislature created a process by which the Commission can, upon petition and hearing, declare certain telecommunications services competitive and exempt from specific designated regulations. In making this determination, the legislature instructed the Commission to consider market conditions, including such factors as the availability of equivalent or substitutable service in the relevant market at comparable rates, the relevant market power of each telecommunications utility, and the existence of any significant barrier to entry or exit in the relevant market. 11 The statute does not consider provision of service by a different 11 Wis. Stat (2). 8

9 transmission protocol, such as IP, to be a relevant factor in considering whether to apply partial regulation to a particular service. Therefore, the Commission should subject VoIP service to the same regulatory obligations and consumer protections that are imposed on other similarly situated telecommunications services and telecommunications utilities. These include, but are not limited to, consumer protections and service standards (Wis. Admin. Code ch. PSC 165); universal service and educational telecommunications access program support (PSC 161 and PSC 162); relevant price regulation (PSC 163); filing and reporting requirements (PSC 164); and 911 emergency telecommunications services (PSC 173), among others. In summary, the Wisconsin Commission should protect consumers by adopting the same regulatory treatment for fixed VoIP services that it adopts for traditional telephone service to serve the public interest in quality, affordable telephone service. Telephone service is simply too vital to public health, safety, and economic life to leave to the whims of the marketplace. Moreover, equivalent treatment of VoIP services will preserve competitive neutrality, encouraging providers to compete based on service, innovation, and price rather than regulatory arbitrage. Finally, in the absence of federal preemption, the Wisconsin Commission has not only the authority but the obligation to regulate VoIP service to protect consumers. Respectfully submitted, Frank Mathews CWA Representative, Wisconsin and Illinois 106 S. Wynstone Park Drive, Suite 104 North Barrington, Illinois February 15,

Legal Alert: FCC Imposes Additional USF Contribution Obligations on Interconnected VoIP Providers, Increases Wireless Safe Harbor

Legal Alert: FCC Imposes Additional USF Contribution Obligations on Interconnected VoIP Providers, Increases Wireless Safe Harbor Legal Alert: FCC Imposes Additional USF Contribution Obligations on Interconnected VoIP Providers, Increases Wireless Safe Harbor July 7, 2006 On June 27, 2006, the Federal Communications Commission (

More information

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA Order Instituting Rulemaking on the Commission s Own Motion to Require Interconnected Voice Over Internet Protocol Service Providers to

More information

BEFORE THE FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20544

BEFORE THE FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20544 BEFORE THE FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20544 In the Matter of Petition of Nebraska Public Service Commission and Kansas Corporation Commission for Declaratory Ruling or, in the Alternative,

More information

Before the Federal Communications Commission Washington, D.C. 20554

Before the Federal Communications Commission Washington, D.C. 20554 Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Vermont Telephone Company Petition for Declaratory Ruling Whether Voice Over Internet Protocol Services Are Entitled

More information

Before the Federal Communications Commission Washington, D.C. 20554 COMMENTS OF JOHN STAURULAKIS, INC.

Before the Federal Communications Commission Washington, D.C. 20554 COMMENTS OF JOHN STAURULAKIS, INC. Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of High-Cost Universal Service Support Federal-State Joint Board on Universal Service WC Docket No. 05-337 CC Docket No.

More information

Before The FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554

Before The FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 Before The FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) Petition of Union Electric Company ) WC Docket No. 13-307 D/B/A Ameren Missouri for Declaratory ) Ruling Concerning

More information

THE STATE OF NEW HAMPSHIRE BEFORE THE PUBLIC UTILITIES COMMISSION

THE STATE OF NEW HAMPSHIRE BEFORE THE PUBLIC UTILITIES COMMISSION THE STATE OF NEW HAMPSHIRE BEFORE THE PUBLIC UTILITIES COMMISSION Application of Laws of 2012, Chapter 177 (Senate Bill 48 to VoIP and IP-Enabled Services Docket No. DT 12-308 BRIEF OF AT&T CORP. AND VERIZON

More information

STATE OF IOWA DEPARTMENT OF COMMERCE IOWA UTILITIES BOARD. ) ) ) ) ) Docket No. NOI-2013-0001 ) ) ) COMMENTS OF THE VOICE ON THE NET COALITION

STATE OF IOWA DEPARTMENT OF COMMERCE IOWA UTILITIES BOARD. ) ) ) ) ) Docket No. NOI-2013-0001 ) ) ) COMMENTS OF THE VOICE ON THE NET COALITION STATE OF IOWA DEPARTMENT OF COMMERCE IOWA UTILITIES BOARD IN RE: INQUIRY INTO THE APPROPRIATE SCOPE OF TELECOMMUNICATIONS REGULATION Docket No. NOI-2013-0001 COMMENTS OF THE VOICE ON THE NET COALITION

More information

Addendum StartPage: 0

Addendum StartPage: 0 Control Number : 39717 Item Number : 29 Addendum StartPage: 0 PROJECT NO. 39717 cz * s; ^^1^,jA lt RULEMAKING PROCEEDING PUBLIC UTILITY COMNIISj^; RELATED TO VOICE OVER INTERNET PROTOCOL (VoIP) OF TEXAS

More information

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of ) VONAGE HOLDINGS ) CORPORATION ) WC Docket No. 03-211 Petition for Declaratory Ruling ) Concerning an Order of the )

More information

Before the FEDERAL COMMUNICATIONS COMMISSION Washington D.C. 20544

Before the FEDERAL COMMUNICATIONS COMMISSION Washington D.C. 20544 Before the FEDERAL COMMUNICATIONS COMMISSION Washington D.C. 20544 Ameren Missouri Petition for Declaratory ) Ruling Pursuant to Section 1.2(a) of ) WC Docket No. 13-307 the Commission's Rules ) OPPOSITION

More information

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 ) In the Matter of ) ) VONAGE HOLDINGS ) CORPORATION ) ) Petition for Declaratory Ruling ) WC Docket No. 03-211 Concerning an Order of

More information

Before the Federal Communications Commission Washington, D.C. 20554 ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Before the Federal Communications Commission Washington, D.C. 20554 ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Telephone Number Requirements for IP-Enabled Services Providers Local Number Portability Porting Interval and Validation

More information

Before the. Federal Communications Commission Washington, D.C. 20554 AND. Charles Acquard, Executive Director NASUCA. 8380 Colesville Road, Suite 101

Before the. Federal Communications Commission Washington, D.C. 20554 AND. Charles Acquard, Executive Director NASUCA. 8380 Colesville Road, Suite 101 October 6, 2011 Stefanie A. Brand Director Division of Rate Counsel Deputy Public Advocate Newark, NJ 07101 Phone (973) 648-2690 Christopher J. White www.rpa.state.nj.us njratepayer@rpa.state.nj.us Fax

More information

EDUCATIONAL ADVISORY

EDUCATIONAL ADVISORY EDUCATIONAL ADVISORY FORM 499 REVENUE REPORTING PRIMER SERIES Reporting Revenue from Interconnected VoIP Bundles and Corollary/Peripheral Services Sold in Conjunction With I-VoIP Issues, Options, Risks

More information

The Free State Foundation

The Free State Foundation A Free Market Think Tank For Maryland Because Ideas Matter Testimony of Randolph J. May President before the Senate Finance Committee and the House Economic Matters Committee of the Maryland General Assembly

More information

PUBLIC NOTICE Federal Communications Commission 445 12 th St., S.W. Washington, D.C. 20554

PUBLIC NOTICE Federal Communications Commission 445 12 th St., S.W. Washington, D.C. 20554 PUBLIC NOTICE Federal Communications Commission 445 12 th St., S.W. Washington, D.C. 20554 News Media Information 202 / 418-0500 Internet: http://www.fcc.gov TTY: 1-888-835-5322 DA 15-326 Released: March

More information

C-OTYiAVtC/yvCd. '"-.rcservicv. Oito' M30C131 PH2--30

C-OTYiAVtC/yvCd. '-.rcservicv. Oito' M30C131 PH2--30 Level (3) % COMMUNICATIONS C-OTYiAVtC/yvCd '"-.rcservicv. Oito' M30C131 PH2--30 Gregory L. Rogers Director, State Regulatory Affairs TEL: (720)888-2512 FAX: (720)888-5134 greg.rogers@level3.com [^ October

More information

KANSAS CORPORATION COMMISSION IP-to-IP Interconnection Report

KANSAS CORPORATION COMMISSION IP-to-IP Interconnection Report KANSAS CORPORATION COMMISSION IP-to-IP Interconnection Report 2014 REPORT ON IP- TO- IP INTERCONNECTION A Summary of Status of the FCC s Internet Protocol- to- Internet Protocol Interconnection Proceeding

More information

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) AT&T Petition for Declaratory ) WC Docket No. 02-361 Ruling that AT&T s Phone-to-Phone ) IP Telephony Services are

More information

Before the Federal Communications Commission Washington, D.C. 20554 ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) REPORT AND ORDER

Before the Federal Communications Commission Washington, D.C. 20554 ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) REPORT AND ORDER Before the Federal Communications Commission Washington, D.C. 20554 In the Matters of IP-Enabled Services Implementation of Sections 255 and 251(a)(2) of The Communications Act of 1934, as Enacted by The

More information

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 ) In the Matter of ) ) Request for Review by ) WC Docket No. 06-122 MeetingOne.com Corp. of Decision of ) Universal Service Administrator

More information

Before the Federal Communications Commission Washington, D.C. 20554 ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Before the Federal Communications Commission Washington, D.C. 20554 ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Universal Service Contribution Methodology Federal-State Joint Board on Universal Service 1998 Biennial Regulatory Review

More information

United States Court of Appeals

United States Court of Appeals United States Court of Appeals FOR THE EIGHTH CIRCUIT No. 08-1764 Vonage Holdings Corp.; Vonage Network, Inc., Plaintiffs - Appellees, v. Nebraska Public Service Commission; Rod Johnson, in his official

More information

Before the Federal Communications Commission Washington, D.C. 20554

Before the Federal Communications Commission Washington, D.C. 20554 Before the Federal Communications Commission Washington, D.C. 20554 ) In the Matter of ) ) Petition for Declaratory Ruling of ) American Electric Power Service ) Corporation et al. Regarding the ) Rate

More information

IP-Enabled Services. Frequently Asked Questions. Voice-Over-Internet Protocol

IP-Enabled Services. Frequently Asked Questions. Voice-Over-Internet Protocol 1 of 6 12/30/2011 10:58 AM Search RSS Updates E-Filing Initiatives Consumers Find People Voice-Over-Internet Protocol Search the FCC: FCC > Voice-Over-Internet Protocol site map Help Advanced Headlines

More information

12/29/2004 2:40:57 PM

12/29/2004 2:40:57 PM Recent Developments Voice Over Internet Protocol Joseph Gratz * FCC Chairman Michael Powell recently called Voice over Internet Protocol the killer app for legal policy change. 1 VoIP, as the technology

More information

Before the Federal Communications Commission Washington, DC 20554

Before the Federal Communications Commission Washington, DC 20554 Before the Federal Communications Commission Washington, DC 20554 In the Matter of AT&T Petition to Launch a Proceeding Concerning the TDM-to-IP Transition GN Docket No. 12-353 Petition of the National

More information

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 ) ) ) ) ) ) )

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 ) ) ) ) ) ) ) Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 Petition Of Nebraska Public Service Commission and Kansas Corporation Commission for Declaratory Ruling or, in the Alternative, Adoption

More information

F I L E D 03-08-11 04:59 PM

F I L E D 03-08-11 04:59 PM BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA F I L E D 03-08-11 04:59 PM Order Instituting Rulemaking on the Commission s Own Motion to Require Interconnected Voice Over Internet Protocol

More information

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) Universal Service Contribution Methodology ) WC Dkt. No. 06-122 ) ) COMMENTS OF THE OFFICE OF ADVOCACY, U.S. SMALL

More information

BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C. 20554 AMENDMENT

BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C. 20554 AMENDMENT BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C. 20554 In the Matter of ) ) SBC Communications Amendment to ) Ameritech s, Pacific Bell s, Nevada Bell s, and ) Southwestern Bell Telephone

More information

COMMENTS OF O1 COMMUNICATIONS, INC. & VAYA TELECOM, INC.

COMMENTS OF O1 COMMUNICATIONS, INC. & VAYA TELECOM, INC. Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Petition for Declaratory Ruling That tw telecom inc. Has The Right To Direct IP-to-IP Interconnection Pursuant To Section

More information

FCC Dives Headfirst Into Privacy

FCC Dives Headfirst Into Privacy Portfolio Media. Inc. 860 Broadway, 6th Floor New York, NY 10003 www.law360.com Phone: +1 646 783 7100 Fax: +1 646 783 7161 customerservice@law360.com FCC Dives Headfirst Into Privacy Law360, New York

More information

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 ) ) ) ) ) ) ) PETITION FOR RECONSIDERATION

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 ) ) ) ) ) ) ) PETITION FOR RECONSIDERATION Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of Reporting Requirements for U.S. Providers of International Telecommunications Services Amendment of Part 43 of the Commission

More information

One Hundred Tenth Congress of the United States of America

One Hundred Tenth Congress of the United States of America H. R. 3403 One Hundred Tenth Congress of the United States of America AT THE SECOND SESSION Begun and held at the City of Washington on Thursday, the third day of January, two thousand and eight An Act

More information

In the Matter of ) ) ) ) Consumer Information and Disclosure ) CG Docket No. 09-158. Truth-in-Billing and Billing Format ) CG Docket No.

In the Matter of ) ) ) ) Consumer Information and Disclosure ) CG Docket No. 09-158. Truth-in-Billing and Billing Format ) CG Docket No. Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of Empowering Consumers to Prevent and Detect Billing for Unauthorized Charges ( Cramming CG Docket No. 11-116 Consumer Information

More information

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554. GN Docket No. 11-117. PS Docket No. 07-114. WC Docket No.

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554. GN Docket No. 11-117. PS Docket No. 07-114. WC Docket No. Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of Amending the Definition of Interconnected VoIP Service in Section 9.3 of the Commission s Rules Wireless E911 Location

More information

Minnesota Public Utilities Commission Staff Briefing Papers

Minnesota Public Utilities Commission Staff Briefing Papers Minnesota Public Utilities Commission Staff Briefing Papers Meeting Date: Wednesday, August 13, 2003... Agenda Item # **1 Company: Docket No. Vonage Holdings Corporation P-6214/C-03-108 In the Matter of

More information

March 13, 2012. Enclosed for filing in the above-referenced matter, please find Reply Comments of the Michigan Cable Telecommunications Association.

March 13, 2012. Enclosed for filing in the above-referenced matter, please find Reply Comments of the Michigan Cable Telecommunications Association. 124 West Allegan Street, Suite 1000 Lansing, Michigan 48933 T (517) 482-5800 F (517) 482-0887 www.fraserlawfirm.com Michael S. Ashton MAshton@fraserlawfirm.com (517) 377-0875 March 13, 2012 Ms. Mary Jo

More information

Before the Federal Communications Commission Washington, D.C. 20554 ) ) ) ) ) ) ORDER. Adopted: June 27, 2008 Released: June 30, 2008

Before the Federal Communications Commission Washington, D.C. 20554 ) ) ) ) ) ) ORDER. Adopted: June 27, 2008 Released: June 30, 2008 Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Request for Review by InterCall, Inc. of Decision of Universal Service Administrator CC Docket No. 96-45 ORDER Adopted:

More information

Regulatory,Taxand BusinessImplicationsof. RelatedtoEnhanced Communications

Regulatory,Taxand BusinessImplicationsof. RelatedtoEnhanced Communications Regulatory,Taxand BusinessImplicationsof RecentFCCDecisions RelatedtoEnhanced Communications Regulatory, Tax and Business Implications of Recent FCC Decisions Related to Enhanced Communications Jonathan

More information

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 COMMENTS OF VONAGE HOLDINGS CORPORATION

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 COMMENTS OF VONAGE HOLDINGS CORPORATION Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 Comments Public Safety and Homeland Security Bureau Seeks Comment on Whether the Commission s Rules Concerning Disruptions to communications

More information

MEMORANDUM THE FCC S 2015 OPEN INTERNET ORDER AND IMPLICATIONS FOR BROADBAND INTERNET ACCESS SERVICE PROVIDERS SAMPLE

MEMORANDUM THE FCC S 2015 OPEN INTERNET ORDER AND IMPLICATIONS FOR BROADBAND INTERNET ACCESS SERVICE PROVIDERS SAMPLE MEMORANDUM THE FCC S 2015 OPEN INTERNET ORDER AND IMPLICATIONS FOR BROADBAND INTERNET ACCESS SERVICE PROVIDERS Introduction On March 12, 2015, the Federal Communications Commission ( FCC or Commission

More information

Before the Federal Communications Commission Washington, D.C. 20554 ) ) ) ) ) ) ) ) ) ORDER. Adopted: February 20, 2013 Released: February 20, 2013

Before the Federal Communications Commission Washington, D.C. 20554 ) ) ) ) ) ) ) ) ) ORDER. Adopted: February 20, 2013 Released: February 20, 2013 Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Rules and Policies Regarding Calling Number Identification Service Caller ID Petition of Chevrah Hatzalah Volunteer

More information

THE STATE CORPORATION COMMISSION OF THE STATE OF KANSAS. Thomas E. Wright, Chairman Michael C. Moffet Joseph F. Harkins

THE STATE CORPORATION COMMISSION OF THE STATE OF KANSAS. Thomas E. Wright, Chairman Michael C. Moffet Joseph F. Harkins THE STATE CORPORATION COMMISSION OF THE STATE OF KANSAS Before Commissioners: Thomas E. Wright, Chairman Michael C. Moffet Joseph F. Harkins In the Matter of the Investigation to Address Obligations of

More information

PUBLIC NOTICE Federal Communications Commission 445 12 th St., S.W. Washington, D.C. 20554

PUBLIC NOTICE Federal Communications Commission 445 12 th St., S.W. Washington, D.C. 20554 PUBLIC NOTICE Federal Communications Commission 445 12 th St., S.W. Washington, D.C. 20554 News Media Information 202 / 418-0500 Internet: http://www.fcc.gov TTY: 1-888-835-5322 DA 15-1330 Released: November

More information

the Interconnection Agreements filed with the Idaho Public Utilities Commission (the

the Interconnection Agreements filed with the Idaho Public Utilities Commission (the - ' '..:,- ':)CeC \ir i \;- ; L!LED IDAHO pub~i~~:i~~~e OMMISgWi'fEB -6 1"- ~;i'i 9: 58 In the Matter of the Petition for Approval of an Amendment to an Interconnection Agreement Between Verizon Northwest

More information

VoIP. VoIP. Panel Discussion. 2005 SEATA Conference July 12, 2005. Overview. Overview of VoIP Technology Explore State and Local Tax Issues

VoIP. VoIP. Panel Discussion. 2005 SEATA Conference July 12, 2005. Overview. Overview of VoIP Technology Explore State and Local Tax Issues VoIP Panel Discussion 2005 SEATA Conference July 12, 2005 Deborah Bierbaum AT&T Director External Tax Policy Meredith Garwood Time Warner Cable Vice President Tax Overview Overview of VoIP Technology Explore

More information

January 23, 2015. Re: Protecting and Promoting the Open Internet, GN Docket No. 14-28; Framework for Broadband Internet Service, GN Docket No.

January 23, 2015. Re: Protecting and Promoting the Open Internet, GN Docket No. 14-28; Framework for Broadband Internet Service, GN Docket No. VIA ECFS Ms. Marlene Dortch Secretary Federal Communications Commission 445 12 th Street, SW Washington, D.C. 20554 Re: Protecting and Promoting the Open Internet, GN Docket No. 14-28; Framework for Broadband

More information

BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON D.C. 20554

BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON D.C. 20554 BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON D.C. 20554 In the Matter of: ) ) Petition for Declaratory Ruling that AT&T s ) Phone-to-Phone IP Telephony Services Are ) WC Docket No. 02-361 Exempt

More information

TITLE I 911 SERVICES AND IP ENABLED VOICE SERVICE PROVIDERS

TITLE I 911 SERVICES AND IP ENABLED VOICE SERVICE PROVIDERS 122 STAT. 2620 PUBLIC LAW 110 283 JULY 23, 2008 July 23, 2008 [H.R. 3403] New and Emerging Technologies 911 Improvement Act of 2008. 47 USC 609 note. Public Law 110 283 110th Congress An Act To promote

More information

l Iu:blkJl:er&ke C1t:otmttissiott

l Iu:blkJl:er&ke C1t:otmttissiott " State of Florida 11 JUl28 AM 10: ~2 l Iu:blkJl:er&ke C1t:otmttissiott Cot1HISSlON CAPITAL CIRCLE OFFICE CENTER. 2540 SHUMARD OAK BOULEVARD TALLAHASSEE, FLORIDA 32399-0850 -~-~-~-(}-It-j\-~-J)-lJ-~- ClERK

More information

Before the Federal Communications Commission Washington, DC 20554 ) ) ) ) ) REPLY COMMENTS OF THE TELECOMMUNICATIONS INDUSTRY ASSOCIATION

Before the Federal Communications Commission Washington, DC 20554 ) ) ) ) ) REPLY COMMENTS OF THE TELECOMMUNICATIONS INDUSTRY ASSOCIATION Before the Federal Communications Commission Washington, DC 20554 In the Matter of Request for Review By InterCall, Inc. of Decision of Universal Service Administrator CC Docket No. 96-45 To: The Commission

More information

DEVELOPMENTS IN VOIP AND BROADBAND REGULATION

DEVELOPMENTS IN VOIP AND BROADBAND REGULATION DEVELOPMENTS IN VOIP AND BROADBAND REGULATION John Nakahata Brita Strandberg Bruce Gottlieb Harris, Wiltshire & Grannis Copyright 2005 All Rights Reserved i TABLE OF CONTENTS Page I. Introduction...1 A.

More information

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 ) ) ) ) COMMENTS OF THE UNITED STATES TELECOM ASSOCIATION

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 ) ) ) ) COMMENTS OF THE UNITED STATES TELECOM ASSOCIATION Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of Protecting and Promoting the Open Internet ) ) ) ) GN Docket No. 14-28 COMMENTS OF THE UNITED STATES TELECOM ASSOCIATION

More information

) ) ) ) SYNOPSIS. Request for Agency Action filed by Carbon/Emery Telecom, Inc. ( Carbon/Emery ) on July 18,

) ) ) ) SYNOPSIS. Request for Agency Action filed by Carbon/Emery Telecom, Inc. ( Carbon/Emery ) on July 18, - BEFORE THE PUBLIC SERVICE COMMISSION OF UTAH - --------------------------------------------------------------------------------------------- ) In the Matter of the Request for Agency Action of Carbon/Emery

More information

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 COMMENTS OF THE NEW JERSEY DIVISION OF THE RATEPAYER ADVOCATE

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 COMMENTS OF THE NEW JERSEY DIVISION OF THE RATEPAYER ADVOCATE Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) Telecommunications Relay Services and ) Speech-to-Speech Services for ) CG Docket No. 03-123 Individuals with Hearing

More information

Before the Federal Communications Commission Washington, D.C. 20554 ) ) ) ) ) ) ) ORDER. Adopted: October 22, 2013 Released: October 22, 2013

Before the Federal Communications Commission Washington, D.C. 20554 ) ) ) ) ) ) ) ORDER. Adopted: October 22, 2013 Released: October 22, 2013 Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Schools and Libraries Universal Service Support Mechanism A National Broadband Plan for Our Future ORDER CC Docket No.

More information

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 ) ) ) ) ) ) ) ) ) REPLY COMMENTS OF CTIA THE WIRELESS ASSOCIATION

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 ) ) ) ) ) ) ) ) ) REPLY COMMENTS OF CTIA THE WIRELESS ASSOCIATION Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of High-Cost Universal Service Support Federal-State Joint Board on Universal Service Request for Review of Decision of Universal

More information

A STUDY OF VOICE OVER INTERNET PROTOCOL IN MISSOURI

A STUDY OF VOICE OVER INTERNET PROTOCOL IN MISSOURI A STUDY OF VOICE OVER INTERNET PROTOCOL IN MISSOURI VoIP INDUSTRY TASK FORCE REPORT MARCH 30, 2004 CASE NO. TW-2004-0324 TABLE OF CONTENTS Introduction... 1 PART I VoIP TECHNOLOGY... 5 Phone-To-Phone VoIP...

More information

VOICE OVER INTERNET PROTOCOL

VOICE OVER INTERNET PROTOCOL 3/9/05 U.S. SENATE S.2281 7.22.04 VoIP Bill circulating in Senate Commerce Committee proposes federal preemption of VoIP services; exempts VOIP services from access-charges, but allows federal intercarrier

More information

Before the Federal Communications Commission Washington, DC 20554

Before the Federal Communications Commission Washington, DC 20554 Before the Federal Communications Commission Washington, DC 20554 In the Matter of Technologies Transitions Policy Task Force GN Docket No. 13-5 COMMENTS OF THE AMERICAN CABLE ASSOCIATION ON PUBLIC NOTICE

More information

Federal Communications Commission FCC 04-267. Before the Federal Communications Commission Washington, D.C. 20554 ) ) ) ) ) )

Federal Communications Commission FCC 04-267. Before the Federal Communications Commission Washington, D.C. 20554 ) ) ) ) ) ) Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Vonage Holdings Corporation Petition for Declaratory Ruling Concerning an Order of the Minnesota Public Utilities Commission

More information

Before the Federal Communications Commission Washington, D.C. 20554

Before the Federal Communications Commission Washington, D.C. 20554 Before the Federal Communications Commission Washington, D.C. 20554 In the Matters of ) ) Federal-State Joint Board ) CC Docket No. 96-45 On Universal Service ) ) Access Charge Reform ) CC Docket No. 96-262

More information

FCC Adopts Controversial Net Neutrality Rules Governing Broadband Internet Access Services

FCC Adopts Controversial Net Neutrality Rules Governing Broadband Internet Access Services January 2011 FCC Adopts Controversial Net Neutrality Rules Governing Broadband Internet Access Services BY CARL W. NORTHROP, MICHAEL LAZARUS & DAVID DARWIN The Federal Communications Commission (the FCC

More information

Before the Federal Communications Commission Washington, D.C. 20554 ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) REPORT AND ORDER

Before the Federal Communications Commission Washington, D.C. 20554 ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) REPORT AND ORDER Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Numbering Policies for Modern Communications IP-Enabled Services Telephone Number Requirements for IP-Enabled Services

More information

BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON D.C

BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON D.C BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON D.C. 20554 In the Matter of: ) ) SBC IP Communications, Inc. ) Petition for Limited Waiver of ) CC Docket No. 99-200 Section 52.15(g)(2)(i) of the

More information

PUBLIC NOTICE Federal Communications Commission 445 12 th Street, S.W. Washington, D.C. 20554

PUBLIC NOTICE Federal Communications Commission 445 12 th Street, S.W. Washington, D.C. 20554 PUBLIC NOTICE Federal Communications Commission 445 12 th Street, S.W. Washington, D.C. 20554 News Media Information 202 / 418-0500 Internet: http://www.fcc.gov TTY: 1-888-835-5322 DA 15-274 Released:

More information

BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, DC 20554

BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, DC 20554 BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, DC 20554 ) Protecting and Promoting the Open Internet ) GN Docket No. 14-28 ) Notice of Information Collection ) OMB Control No. 306-1158 ) COMMENTS

More information

Regulatory Reclassification of Broadband Internet Access Service is the Unsurprising Result of ISPs Inexplicable Challenges to FCC Authority

Regulatory Reclassification of Broadband Internet Access Service is the Unsurprising Result of ISPs Inexplicable Challenges to FCC Authority Regulatory Reclassification of Broadband Internet Access Service is the Unsurprising Result of ISPs Inexplicable Challenges to FCC Authority An Open Internet has long been a bipartisan goal in the United

More information

VoIP Service Provider Regulatory Compliance Guide:

VoIP Service Provider Regulatory Compliance Guide: VoIP Service Provider Regulatory Compliance Guide: Your Comprehensive Guide for Ensuring Compliance with Federal Communications Commission (FCC) and State Regulations Applicable to Interconnected VoIP

More information

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) Time Warner Cable s Petition for ) WC Docket No. 06-55 Declaratory Ruling that Competitive ) Local Exchange Carriers

More information

Before the Federal Communications Commission Washington, D.C. 20554

Before the Federal Communications Commission Washington, D.C. 20554 Before the Federal Communications Commission Washington, D.C. 20554 ) In the Matter of ) ) Preserving the Open Internet ) ) Broadband Industry Practices ) ) REPLY COMMENTS I. Introduction. The American

More information

Geographic Routing of Toll Free Services

Geographic Routing of Toll Free Services Introduction Routing calls based on the caller s location is an important aspect of many toll free services, whether a call originates from a wireline, wireless, or VOIP caller. For example, a toll free

More information

Before the Federal Communications Commission Washington, D.C. 20554

Before the Federal Communications Commission Washington, D.C. 20554 Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of: ) ) ) Inflexion Communications ) ) WC Docket No. 04-52 Petition for Declaratory Ruling that ) Inflexion Communications

More information

BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C. 20554

BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C. 20554 BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C. 20554 In the Matter of ) ) IP-Enabled Services ) WC Docket No. 04-36 ) E911 Requirements for IP-Enabled ) WC Docket No. 05-196 Service Providers

More information

BEFORE THE FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 COMMENTS OF VONAGE HOLDINGS CORPORATION

BEFORE THE FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 COMMENTS OF VONAGE HOLDINGS CORPORATION BEFORE THE FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of Ensuring Customer Premises Equipment PS Docket No. 14-174 Backup Power for Continuity of Communications Technology Transitions

More information

Voice over Internet Protocol (VoIP) Core-Edge Working Group Meeting, September 28-29, 2004 Chintan Vaishnav Research Assistant, MIT CFP

Voice over Internet Protocol (VoIP) Core-Edge Working Group Meeting, September 28-29, 2004 Chintan Vaishnav Research Assistant, MIT CFP Voice over Internet Protocol (VoIP) Core-Edge Working Group Meeting, September 28-29, 2004 Chintan Vaishnav Research Assistant, MIT CFP chintanv@mit.edu 1 Outline Part I Regulatory Issues Part II The Core-Edge

More information

RE: ARB 165(1) and ARB 422(1) Comments of Verizon Northwest Inc.

RE: ARB 165(1) and ARB 422(1) Comments of Verizon Northwest Inc. March 18, 2004 Ms. Cheryl Walker Administrative Hearings Division Oregon Public Utility Commission 550 Capitol Street N.E., Suite 215 Salem, OR 97310 RE: ARB 165(1) and ARB 422(1) Comments of Verizon Northwest

More information

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) Jurisdictional Separations Reform ) and Referral to the Federal-State ) CC Docket No. 80-286 Joint Board ) ) Communications

More information

CHAPTER 15 - TELECOMMUNICATIONS ARTICLE 1 - GENERAL PROVISIONS. 37-15-101. Short title; sunset.

CHAPTER 15 - TELECOMMUNICATIONS ARTICLE 1 - GENERAL PROVISIONS. 37-15-101. Short title; sunset. CHAPTER 15 - TELECOMMUNICATIONS ARTICLE 1 - GENERAL PROVISIONS 37-15-101. Short title; sunset. (a) This chapter shall be known as the "Wyoming Telecommunications Act." (b) This chapter is repealed effective

More information

CALEA Monitoring Report for Broadband Access and VOIP Services

CALEA Monitoring Report for Broadband Access and VOIP Services FEDERAL COMMUNICATIONS COMMISSION CALEA Monitoring Report for Broadband Access and VOIP Services Notice to Individuals Required by the Privacy Act of 1974 and the Paperwork Reduction Act of 1995 Public

More information

Phone Company or Phony Company? Part 2 by Dean K. Wilson, P.E.

Phone Company or Phony Company? Part 2 by Dean K. Wilson, P.E. Fire Alarm Notebook by Dean K. Wilson. P.E. Page 1 question: Phone Company or Phony Company? Part 2 by Dean K. Wilson, P.E. In the March/April 2008 edition of, I attempted to answer the following Question:

More information

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC GN Docket No. 14-28 In the Matter of Protecting and Promoting the Open Internet The Telecom Act of 1996 Requires the FCC to Classify Commercial

More information

Before the Federal Communications Commission Washington, D.C. 20554

Before the Federal Communications Commission Washington, D.C. 20554 Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of ) ) Contributions to the Telecommunications ) CG Docket No. 11-47 Relay Services Fund ) ) COMMENTS OF THE INFORMATION

More information

Michael 3. Wid Director Public Affiin. Policy, and Communications 100 Communications Drive P.O. Box 49 Sun Prairie, WI 535950049

Michael 3. Wid Director Public Affiin. Policy, and Communications 100 Communications Drive P.O. Box 49 Sun Prairie, WI 535950049 Michael 3. Wid Director Public Affiin. Policy, and Communications 100 Communications Drive P.O. Box 49 Sun Prairie, WI 535950049 January 13,2009 Phone: 608-837-1732 FAX: 608-837-1 128 E-mail: mike.wirl@verizon.com

More information

MAINE PUBLIC UTILITIES COMMISSION

MAINE PUBLIC UTILITIES COMMISSION MAINE PUBLIC UTILITIES COMMISSION Report to the Legislature Pursuant to An Act to Reform Telecommunications Regulation, Public Law 2011, Chapter 623, Section D-7, Regarding Assessments Paid By Voice Service

More information

Before the Federal Communications Commission Washington, D.C. 20554 ) ) ) ) ) ) REPLY COMMENTS OF LEVEL 3 COMMUNICATIONS, LLC

Before the Federal Communications Commission Washington, D.C. 20554 ) ) ) ) ) ) REPLY COMMENTS OF LEVEL 3 COMMUNICATIONS, LLC Before the Federal Communications Commission Washington, D.C. 20554 In the Matters of Local Number Portability Porting Interval and Validation Requirements Telephone Number Portability WC Docket No. 07-244

More information

Privacy Year in Review: Privacy and VoIP Technology

Privacy Year in Review: Privacy and VoIP Technology Privacy Year in Review: Privacy and VoIP Technology JOHN B. MORRIS, JR. ABSTRACT Voice over internet protocol ( VoIP ) technology is increasingly being used throughout the nation. VoIP technology provides

More information

COMMENTS OF THE ELECTRONIC PRIVACY INFORMATION CENTER THE FEDERAL COMMUNICATIONS COMMISSION

COMMENTS OF THE ELECTRONIC PRIVACY INFORMATION CENTER THE FEDERAL COMMUNICATIONS COMMISSION COMMENTS OF THE ELECTRONIC PRIVACY INFORMATION CENTER To THE FEDERAL COMMUNICATIONS COMMISSION In the Matter of "Rules and Regulations Implementing the Truth in Caller ID Act of 2009" WC Docket No. 11-39

More information

Taxing Telecommunications

Taxing Telecommunications Taxing Telecommunications October 11, 2005 Deborah R. Bierbaum, Director External Tax Policy Document/Ref erence Number 2004 AT&T, All Rights Reserv ed. Overview Review issues and factors challenging current

More information

Before the Federal Communications Commission Washington, D.C. 20554 ) ) ) ) ) ) REPLY COMMENTS OF THE NEW JERSEY DIVISION OF RATE COUNSEL

Before the Federal Communications Commission Washington, D.C. 20554 ) ) ) ) ) ) REPLY COMMENTS OF THE NEW JERSEY DIVISION OF RATE COUNSEL Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Petition for Declaratory Ruling Whether Voice over Internet Protocol Services Are Entitled to the Interconnection Rights

More information

BEFORE THE FEDERAL COMMUNICATIONS COMMISSION. Washington, D.C. 20554

BEFORE THE FEDERAL COMMUNICATIONS COMMISSION. Washington, D.C. 20554 BEFORE THE FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of THE PROVISION OF TELECOMMUNICATIONS SERVICE VIA "CABLE INTERNET" UNITED STATES INTERNET INDUSTRY ASSOCIATION ("USIIA"),

More information

S T A T E O F M I C H I G A N BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * * *

S T A T E O F M I C H I G A N BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * * * S T A T E O F M I C H I G A N BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * * * In the matter, on the Commission s own motion, ) to commence an investigation into voice over ) Case No. internet protocol

More information

TESTIMONY OF THE VOICE ON THE NET COALITION BEFORE THE SENATE JOBS, AGRICULTURE AND RURAL DEVELOPMENT COMMITTEE. HEARING ON S.F. No.

TESTIMONY OF THE VOICE ON THE NET COALITION BEFORE THE SENATE JOBS, AGRICULTURE AND RURAL DEVELOPMENT COMMITTEE. HEARING ON S.F. No. TESTIMONY OF THE VOICE ON THE NET COALITION BEFORE THE SENATE JOBS, AGRICULTURE AND RURAL DEVELOPMENT COMMITTEE HEARING ON S.F. No. 895 FEBRUARY 25, 2015 Good afternoon Chairman Sparks, Vice Chair Schmit

More information

DRAFT Second Circulation for Comments

DRAFT Second Circulation for Comments 1 DRAFT Second Circulation for Comments Barbados (VoIP) Voice Over Internet Protocol Policy Policy in accordance with sections 4 (2)(b) and 4 (2)(f) of the Telecommunications Act 2001-36. This policy describes

More information

Classifying Broadband Services as Telecommunications Services: A Tidal Wave of Change to USF Contribution Rules or a Slow Road to Somewhere?

Classifying Broadband Services as Telecommunications Services: A Tidal Wave of Change to USF Contribution Rules or a Slow Road to Somewhere? Classifying Broadband Services as Telecommunications Services: A Tidal Wave of Change to USF Contribution Rules or a Slow Road to Somewhere? Orlando, FL Friday, May 15, 2015 10:15AM-11:00AM C. Douglas

More information

Before the Federal Communications Commission Washington, D.C. 20554 ) ) ) ) ) ) ) REPLY COMMENTS

Before the Federal Communications Commission Washington, D.C. 20554 ) ) ) ) ) ) ) REPLY COMMENTS Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of: Service Quality, Customer Satisfaction, Infrastructure and Operating Data Gathering REPLY COMMENTS Matthew M. Polka

More information

INTERCONNECTED VOIP REGULATORY COMPLIANCE MANUAL

INTERCONNECTED VOIP REGULATORY COMPLIANCE MANUAL INTERCONNECTED VOIP REGULATORY COMPLIANCE MANUAL Prepared and maintained by: The CommLaw Group www.commlawgroup.com 1420 Spring Hill Road, Suite 205 McLean, VA 22102 Regulatory Compliance Guide for Telecommunications

More information