AT&T Takes Aim at Google

Are Intercarrier Compensation Inequities the Cause?

When AT&T complained to the Federal Communications Commission last month that Google Voice was blocking calls to certain rural numbers which Common Carriers are required to complete, a number of different issues were at play: whether Google Voice is an "information service", exempt from regulation, or a regulated "telecommunications service"; whether telecommunications services should be less regulated; whether information services should be more regulated; and even net neutrality. But at the heart of the issue is really intercarrier compensation and its need for reform.

The issue started with "traffic pumping", a practice whereby rural local exchange carriers (LECs) recruit customers with extremely high inbound traffic (think call centers and chat lines). Each time a caller connects to those call centers or chat lines, the caller’s phone company must pay terminating access charges of as much as $0.05 per minute to the rural carrier. The rural LECs, in turn, were found to be sharing their windfall with the call center or chat line they had recruited, making a lucrative situation for both parties.

While traffic pumping is certainly an ethical violation, it is not illegal. But it does generate millions of dollars in access revenue. Service providers like AT&T and Verizon fought to be able to block calls to suspected traffic pumpers, but were denied that ability by the FCC. Instead, the FCC’s current recommendation to prevent or reduce traffic pumping is to ban service providers from sharing access charges with their customers, removing the incentive for companies with large amounts of lengthy inbound calls to sign-up with the rural LEC in the first place.

So when Google Voice admitted to blocking calls to certain rural numbers, AT&T cried foul, arguing that it is at a disadvantage if it continues to be required to abide by regulations that other service providers are not bound to obey. Google, on the other hand, argues that it is an application provider rather than a service provider, and therefore is exempt from the regulations written for telecommunications services. In fact, Google Voice requires another phone service (like landline, wireless, or VoIP) in order for it to work.

But if regulators reform the out-dated intercarrier compensation rules, this dispute, and many others, is solved. Without the inflated terminating access charges paid to the rural carriers, traffic pumping stops, and AT&T and Google Voice would no longer want to block those calls.

But overhauling intercarrier compensation is a daunting task, and with no solution having a clear ability to appease everyone, the FCC has been slow to act. There are, after all, hundreds of rural LECs that rely on high access rates to stay in business, and are not taking advantage of the regulations by engaging in activities like traffic pumping. But as technology continues to forge ahead, a regulatory framework devised 25 years ago falls further and further behind. Reforming the intercarrier compensation rules has the potential to resolve some of the industry’s most pressing issues if a comprehensive solution can be developed.

Planning Letter 398

As directed by the Canadian Radio-television and Telecommunications Commission (CRTC), relief for Ontario area code 705 will be provided through a distributed overlay of new area code 249, which is scheduled to begin 3/19/11.

Overlay Timeline:

• 9/19/10 – Central office codes within NPA 249 may be assigned to Telecommunications Service Providers (TSPs) – but may not be activated prior to the 3/19/11 relief date.
• 11/15/10 –
  ~ Start date for network testing (test numbers available through April/May ‘11).
  ~ Recommended date by which all international and domestic Telecommunications Service Providers should ensure the new 249 NPA is activated system wide.
• 1/15/11 – Calls dialed with 7-digits will receive an announcement advising the number dialed must be preceded by its area code and that their call will now proceed (will be connected).
• 3/5/11 - Mandatory 10-digit dialing begins. Calls dialed with 7-digits will connect to a similar announcement as above, however, the call will not be connected; instead, the caller will be instructed to redial using the area code. This announcement will remain until replaced by "a standard network announcement" phased in mid-June ’11.

Dialing Plan for Calls Originating in NPA 705 and 249:

• Local and Extended Area Service = 10-digits (NPA-NXX-XXXX)
• Toll and Alternatively Billed = 10-digits after the appropriate prefix digit(s).

A map showing geographic areas served, test numbers, as well as additional details are available at www.nanpa.com.

Planning Letter 397

An all services overlay has been approved by the Nebraska Public Service Commission (PSC), implementing the new 531 NPA as the relief method for the existing 402 NPA. The PSC has also outlined an implementation scheduled for open-ended permissive 10-digit local dialing for the 308 NPA “to be placed in service coincident with the start of permissive dialing in the 402 NPA.” The schedule, outlined below, may be extended by the PSC should it deem the extension “warranted and in the public interest.”

Relief Plan Implementation:

• 6/26/10 – Start of permissive 10-digit dialing.
• 9/26/10 – Earliest date central office codes in the new 531 NPA may be ordered through NANPA.
• 2/26/11 – End of permissive dialing and start of mandatory 10-digit dialing.
• 3/26/11 – Earliest new NPA central office code activation date; and effective date of the new 531 NPA.

While callers may use 7-digit or 10-digit dialing during the permissive period, the latter is encouraged in preparation for implementation of mandatory 10-digit dialing. Also to prepare for the end of the permissive dialing, carriers should ensure their switches are ready to begin sending 10 digits prior to the mandatory dialing conversion date.

402 and 531 NPA Dialing Plan (coincident with mandatory 10-digit dialing) -- Calls Terminating in Home NPA (HNPA) or Foreign NPA (FNPA) Dialing Plans by Call Type:
~ Local and EAS = 10-digits (NPA-NXX-XXX)
~ Toll = 1+10-digits (1+NPA-NXX-XXXX)
~ Operator services (credit card, collect or third party) =0+10-digits (0+NPA-NXX-XXXX)

308 NPA Open-Ended Dialing Plan (coincident with permissive 10-digit dialing) -- Calls Terminating in Home NPA (HNPA) or Foreign NPA (FNPA) Dialing Plans by Call Type:
~ Local and EAS = 7-digits (NXX-XXX) or 10-digits (NPA-NXX-XXX)
~ Toll = 1+10-digits (1+NPA-NXX-XXXX)
~ Operator services (credit card, collect or third party) =0+10-digits (0+NPA-NXX-XXXX)

Beginning 12/13/10, test numbers will be available and it is recommended that all international and domestic carriers use these to ensure the new 531 NPA has been activated throughout their systems prior to 3/26/11. For additional information, please visit www.nanpa.com.

Planning Letter 396

The Government of St. Maarten, Netherlands Antilles, had requested, and was granted, entry into the NANP. The new 721 NPA has been assigned to serve St. Maarten (previously under country code 599), with the introduction timeline as follows:
5/31/10 –
~ Start of permissive dialing (the new NPA or current 599 country code may be used for a dialed number terminating in St. Maarten).
~ The latest date for all international and domestic carriers to activate 721 NPA. A test number for verification of 721 activation will be provided at a later date.
11/30/10 –
~ End of permissive dialing and start of mandatory dialing of the new NPA.

Once the permissive dialing period ends, calls dialed with the 599 country code will receive a recorded message instructing callers to dial the correct country (1) and area code (721). The new 721 NPA will only be in effect for St. Maarten, the remainder of the Netherlands Antilles will continue to use country code 599. For more information, please visit www.nanpa.com.