Regulatory Alert: Annual Access Charge Reform Tariff Filings Coming Due

Seal of the United States Federal Communicatio...

Seal of the United States Federal Communications Commission. (Photo credit: Wikipedia)

The second year of access reform is here again and most LECs and CLECs will need to file revised access rates by July 1. However, you should be aware that many State Commissions have their own requirements and time frames that need to be addressed in advance of the FCC’s date. As an example, the Public Utilities Commission of Ohio is directing that all affected ILECs and CLECs file the appropriate intrastate tariff amendment application or letter of compliance on or before May 1, 2013. This alert is to warn that in many states you are not going to have the luxury of waiting until July 1 to file your rates.

These filings are due to FCC Report and Order (WC Docket No. 07-135) which adopted a transitional intercarrier compensation restructuring framework for both intrastate and interstate interexchange and reciprocal compensation telecommunications traffic. In its recent March 26, 2013 release (WC Docket No.13-76) the FCC established procedures for the 2013 filing of annual access charge tariffs and Tariff Review Plans (“TRP”) for price cap ILECs, rate-of-return ILECs and CLECs that benchmark rates to price cap or rate-of-return ILECs. The Order sets an effective date of July 2, 2013 for the July 2013 annual access charge tariff filing. The Order establishes May 17, 2013 as the date that price cap ILECs must file their short form TRP. Affected ILECs and CLECs may make their tariff filings on either a 15 or 7 day notice (prior to the effective date) therefore affected ILECs and CLECs filing on a 15 day notice must file on June 17, 2013 and those filing on a 7 day notice must file on June 25, 2013. All filings must be made using the FCC’s Electronic Tariff Filing System (“ETFS”).

You also need to be aware that as part of the annual access charge tariff filing carriers will need to include the universal service charge contribution factor for the third quarter which begins on July 1, 2013. Note that in accordance with 47 C.F.R. § 54.712 of the FCC’s rules “…if a contributor chooses to recover its federal universal service contribution costs through a line item on a customer’s bill the amount of the charge may not exceed the interstate telecommunications portion of that customer’s bill times the relevant contribution factor.”

If you need help with these filings let us know. CCG also offers a service we call Regulatory Compliance where we notify our clients each year of every regulatory filing they need to make. It’s affordable and a great way to make sure that you meet all of your regulatory filing requirements.  Call Terri Firestein at CCG if you need help or want more information. She is at (301) 788-6889.

Do You Know the Margins for Your Product Lines?

That sounds like a straightforward question and most businesses in the country can say yes to that question. But I find that a large percentage of telecom companies don’t know the margins on their products.

There are a number of reasons why it is important to know your margins.

  • You need to know if you are selling any product at a loss. It’s okay to consciously have a loss-leader product if selling it always also sells more profitable products. But it makes no sense to sell a product that loses money as a single product. If you have products that lose money you need to consider raising the price or stop selling the product.
  • You should be trying to sell what makes you the most bottom line. All too often I see telecom companies push products that get them a lot of revenue but not much margin.
  • Without knowing your margins you can’t understand where you need to cut costs. While raising rates is one way to increase margin, cutting costs can have the same effect.

Regulated telcos are very used to having separations studies performed that define their access costs. But these studies have no practical value to management and tell you nothing about your profit margins by product line. And many CLECs and cable companies have never done any kind of cost study.

There all kinds of studies that can be done to look at your margins. The most common are:

Fully allocated fully distributed costs. In these studies every cost in the company is distributed to products. Done properly these studies will define your gross margin (revenues minus direct costs of producing a product), your net margin (the margin after also allocating joint and common costs), and net income by product which will look at depreciation or a surrogate cost of the network layered onto your other costs.

Incremental costs. The large phone companies have historically produced TELRIC or other forms of incremental cost studies for state commissions. These studies do not calculate margins in the same way as a fully distributed cost study. Rather, they look at the incremental cost of producing one unit of the product. The main purpose of these studies is to prove that you aren’t selling products below cost, but otherwise they have very little practical value for management.

Luckily it is a very straightforward process to understand your margins. A fully allocated fully distributed cost study can be as simple as a spreadsheet that allocates every cost in your ledger to products using some logical allocator. The whole key to getting believable results is to develop the best allocators that you can find for the way your company operates.

CCG has done these kind of margin studies many times and we don’t see them being offered by a lot of other consultants. There are a ton of companies that do separations studies or TELRIC studies, but not nearly so many who do straightforward cost accounting studies that management can use. Once you have a good margin study on hand then management can begin to understand how costs affect your profits. As an example, you can quickly see what will happen to your margins if you hire a new employee or if the cost of your Internet backbone goes down. That kind of basic information is vital if you want to maximize the bottom line. Knowing your margins lets you concentrate on those things that will have the best impact to the bottom line.

“Dumb Pipe” versus Full-Service Provider

Broadband and cable TV companies have been looking at their long-term strategy and they are going to have to decide if they are going to be what we at CCG call either a “dumb pipe” provider or a full-service provider.

A “dumb pipe” provider is a broadband company that sells a very fast Internet connection as its primary product and not much of anything else. A perfect example of this is what Google is doing in Kansas City. Google is selling a 1 Gbps Internet connection there for $70 per month. That is far more speed than is possible from the competition, but it is also more expensive. The only other product available from Google is one cable TV package that is bundled with the data for $120. Google only offers one other data package for low-income homes. Google doesn’t offer different size cable packages. They don’t offer voice. They don’t offer security, or cloud services or any of the panoply of new services that can be provided over fiber.

In my opinion Google has looked into the future and they believe that most of the other services that they could be selling will be available to customers over the very fast Internet connection that Google is selling them. One of the primary advantages to Google of the dumb pipe strategy is that they have a very simple product mix to sell. Fewer products means less staff needed to market, sell, provision and support customers.

The downside to the dumb pipe provider is that they will have a much lower average revenue per user (ARPU) than the full service provider. But both types of providers have a very similar cost of the network. And this is at the heart of the discussion that many of my clients are having about the long-term trends in the industry.

Most providers in the industry today are full-service providers. They support the full residential triple-play, have multiple options for cable TV, have multiple options for voice. They also sell a wide range of other products and their marketing strategy is aimed at getting the highest ARPU from customers they can.

But the full-service providers are worried when they look at some of the trends in the industry. They have already seen a lot of voice customers drop off the network. They are starting to see cable customers leave the network and they look ten years down the road and see a very different cable market. And so full-service providers are faced with figuring out how to go from where they are today to where they think they must be in the future.

I am starting to see evidence of the shift in the strategy of full-service providers. In the last year I have seen data prices being increased all over the country for the first time. And this is not because the cost of providing data is growing, because the margins on data have grown steadily each year over the last decade and are still growing. I think the service  providers have embarked on a long-term upward shift in data prices so that they will be getting more revenue from the one product that is likely to survive into the future.

The companies with the biggest dilemma are these just entering the market for the first time. Do they make the leap straight to being a dumb pipe provider, like Google, or do they become a full-service provider and enjoy the remaining years of high ARPU before voice and cable TV losses pull those numbers downward? It is a hard decision and a conversation I am now having with every new service provider.

What Business Customers Want

A significant percentage of CCG’s clients sell telecommunications services to businesses. When I ask them what they think businesses are now looking for from a telecommunications provider, I most often get the responses listed below.

Interestingly, saving money is not on this list. While most of my clients sell at competitive prices, they say that business customers value a reliable network much more than they do a lower price. Since phones and computers are often now tied together using IP, a network outage effectively can completely cripple a business if they lose both phone and the Internet.

Single service provider. Ideally, most small to medium businesses would like one service provider to take care of everything from data, phones, IT, computers, etc.

Reliable network. They want to be served by a reliable network, with reliability measured in terms of outages. This is often why a new network owner in a town will see slow sales to businesses for a few years until the local market perceives that their network as reliable.

Faster data speeds. While faster download speeds are always important, many businesses also covet fast upload speeds.

Employee mobility. Businesses want the ability for employees to be able to work from home or on the road.

Off-site data storage. Businesses want key data stored offsite to avoid catastrophic data losses. They feel safer if they know the company who is storing their data.

Fast provisioning and changes in services. Businesses want to be able to change things on the fly, be that moving an employee to a different office, changing the features on a given phone or computer, or increasing data speeds.

Physical security and surveillance. Businesses want next generation security systems with features like biometric access, motion detectors and hidden surveillance cameras.

Redundant connections. More and more businesses want physically redundant data connections since their businesses are more reliant on the Internet to be profitable.

Moving to the cloud. Lately businesses have been asking about cloud services since they hear it is a way to eliminate or reduce their IT functions and let outside parties take care of updates, security, etc.

Unified communications.  Businesses want phone calls and data to get to them over multiple devices across multiple networks.

HD Voice

A spectrogram (0-5000 Hz) of the sentence &quo...

A spectrogram (0-5000 Hz) of the sentence “it’s all Greek to me” spoken by a female voice (Image:en-us-it’s_all_Greek_to_me.ogg). (Photo credit: Wikipedia)

HD voice (or wideband audio) is a technology that delivers the full frequency range of the human voice.  Traditional telephony has delivered a narrowband voice transmission and only transmitted sounds between 300 Hz and 3.4 kHz. However, the human voice extends between 80 Hz and 14 kHz, so traditional telephone has chopped off parts of every voice transmission.

The range of frequency was curtailed for traditional telephony based upon the limited bandwidth available for transmitting voice calls over a twisted copper pair. But voice that is sent over an IP path does not have those limitations and can send the full range of the human voice.

There has been an industry standard for wideband voice since 1987. However, until recently the only uses of the standard were in high-end video conferencing systems and for transmitting sports announcers back to the home station for rebroadcast.

But the industry is starting to use the HD voice protocol for calls made over VoIP. For example, Skype and some other PC-to-PC voice providers use the full HD voice bandwidth and the higher quality of the call can be experienced by a caller using a high-quality headset or handset. These same calls don’t sound better when listened to on a standard phone due to limitations in the speakers. There are also a number of vendors offering wideband telephones such as Avaya, Cisco, Grandstream, Gigaset, Polycom and others. These sets are capable of both sending and receiving a wideband voice signal, but the phones at both ends must be wideband capable to engage in an HD quality call.

So what are the business opportunities with HD Voice? Businesses are interested in having high-quality calls, particularly in conference rooms, noisy areas and other places where the quality can make a difference. The business opportunity is to make the phones available to businesses that are served with IP voice paths. HD Voice can then be sold as an add-on feature or as a more expensive voice line. A company that wants the higher quality calling is a great candidate for moving off of traditional TDM services onto VoIP, IP Centrex or other IP voice solution.

Should You Become an MVNO?

This article compares the price of US cell phone plans to those around the world. It shows that the basic packages from the large US providers are in some cases twice as expensive as in other countries.

The small oligopoly of nationwide carriers, being AT&T, Verizon, Sprint and T-Mobile, have no incentive to lower prices. The only thing that will get them to come down in price would be competition or some sort of regulatory action.

The large carriers have created an opportunity for some competition against their products by selling bulk minutes, data and messaging. Companies that buy these bulk minutes are known as MVNOs (Mobile Virtual Network Operators). There are scores of MVNO providers in the country with the largest ones listed here.

The three original MVNOs are TracPhone, Virgin and Boost and who still had over half of the pre-paid cellular phone business in 2012. However, note that Sprint recently bought Virgin and Boost, so perhaps part of their strategy is to create sub-markets and then gobble them up to make more profit.

MVNOs have various marketing strategies:

  • Republic relies on shunting a lot of traffic to WiFi which greatly lowers their costs.
  • Ting lets customers design their own rate plan.
  • Kajeet has plans for kids that are parent-controlled.
  • Solavei uses multi-level marketing similar to Amway.
  • Voyager Mobile competes on price and is selling very low-cost plans.

If your carrier business already has a loyal customer base you should consider becoming an MVNO. Your loyalty will bring you customers, and your existing customers will appreciate being able to save money on cell phones while buying from somebody they trust. As long as you do it smartly there are significant profits to be made in the MVNO business. All that is really needed is having good existing cell phone coverage in your area and the desire to expand your product line.

CCG can help you get into the MVNO business. We can assist you with finding a good deal on bulk minutes, help you design products and prices, help you create a business plan, and help you with technical strategies such as a handphone strategy, and using WiFi to lower costs.

Physics of the Future

I highly recommend anybody interested in Technology to read ‘Physics of the Future: How Science Will Shape Human Destiny and our Daily Lives by the Year 2100’ by Michio Kaku. The book is well written and is an easy and accessible read.

Kaku is a theoretical physicist who researched for this book by talking to leading scientists in many fields of science and asked them where current research is taking their fields by the end of the century. Many scientists see practical and disruptive innovations coming from their own fields of study. But when taken all together, the changes that the scientists see coming look amazingly like Star Trek minus the transporters and the warp speed travel and the Vulcans.

At the turn of the 20th century the world was completely disrupted by inventions like the automobile, electric lights, airplanes, etc. At the end of the last century we saw the world changed drastically by the computer.

Some of the many changes that scientists see coming during this next century include:

  • Cheap fusion power, meaning almost unlimited, pollution-free power for everybody.
  • The ability to locally make things (like the Star Trek replicator) which we are already starting to see with the 3D printer industry.
  • Computer chips so cheap that they are built into everything.
  • A high likelihood of computer sentience.
  • Nanotechnology being used to constantly monitor your health from within and that will intercede to keep you healthy. Cancer won’t be cured so much as it will never be allowed to get started.
  • Space tourism will be routine and not just for the very rich.
  • Driverless cars wiping out gridlock in even the biggest cities.

This book is a fascinating read. The next century is going to see massive technology disruptions that will completely transform almost every industry. In the process many of our largest corporations will go the way of the buggy whip manufacturers.

The book made me think about the telecom industry. One thing that is obvious is that there is going to be massive amounts of data produced everywhere and for this data to be made sense of we will need fiber networks. The idea of gigabit networks will be a quaint idea of the past and we will be having discussions about whether terabit networks are fast enough.

One thing the book doesn’t postulate about is the human element. Certainly there will be a lot of people eager to take advantage of these new technologies. But one has to wonder what is going to happen if parts of society turn their back on such revolutionary breakthroughs and what that might mean for the future of the planet. One also has to wonder if these breakthroughs will be made available to everybody or just to the rich. I haven’t read a book in a long time that has given me more to think and dream about.

Launching a New Product

At CCG we often introduce clients to new products. Historically our clients had the leisure to introduce products slowly since they were not operating in highly competitive markets. However, today we see speed to market being a major factor in being successful. Since there are many steps needed to launch a new product and because it will touch every part of your organization, it is mandatory that you are organized and have a plan to develop and launch a complex product on time and do it well. Lack of organization will inevitably lead to delays, or worse, to a product that is half-baked and full of problems.

At CCG we are experts at the process of launching new products and many of our clients now include CCG as part of the new product development and launch team. We can provide the needed discipline and the extra manpower and expertise needed to insure that a product is launched on time and is customer-ready.

The following (using the example of launching IP Centrex) is  a list of the basic steps required to launch a new product. This list is abbreviated but demonstrates how launching a new product will touch every part of your organization. Without a clear plan it is easy to get bogged down and delayed.

Steps needed to launch IP Centrex

Define the Product. Define the specific market for the product. In the case of IP Centrex, should you have different packages to reach different parts of the market? (For instance there might be a version for typical small business, a more complex product for more businesses like doctor’s offices, and a product for businesses with a centralized receptionist). Define the equipment and software needed to launch the product. What kind of handsets / functionality do you want to offer? Will you let subscribers use their own devices like smart phones and tablets? Will you support integration of phones and computer systems (Outlook, etc,)? Will you be supporting 911 portability (supporting 911 when the customer moves the phone off-premises)?

Determine Technical Readiness. Is your switch ready to support the product or do you need an upgrade? Will your OSS/BSS support the new product’s billing and operational requirements? If you are going to launch using something other than a softswitch, take the steps needed to choose the right gear and/or partner. Find a 911 mobility vendor to support remote 911 if you go this route. How are you willing to distribute the product – over your own network, over leased facilities, or over the open internet. Anticipate and address any IP addressing issues. Analyze the customer premise network requirements –  premise wiring alternatives, customer demarcation points, VoIP quality assurance capabilities, etc.

Product Pricing. Create a name and branding for the product. Determine the market prices of competing products (trunks for existing PBXs, B1s, traditional Centrex, other VoIP providers, etc.). Determine your pricing strategy (one price fits all vs. pricing based upon what the subscriber is using today). Determine your pricing elements (individual service elements like stations, talk paths, features and calling plans or a more all-inclusive element). Determine if you are going to sell and/or lease handsets as part of the product. Will this be bundled with other products like data or long distance?

Testing. Buy test handsets/stations. Activate and then test each switch feature with the handsets. Create a common or custom profile configuration for supported and chosen handset types. Make sure that you have an easy way to load the profile configurations into handsets/stations. Make sure the chosen features will work with each other (a common problem when combining multiple complex features). Test OSS and billing system.

Regulatory. Are tariff updates needed? If you are going into new markets will you need to open new 911 PSAPs? If sold as a regulated product, how does SLC charge apply? Are there any CALEA issues?

Sales and Marketing Readiness. Define the value proposition for the subscriber. Develop marketing literature. Update website. Develop order form that will capture the complexities of the product.

Internal Training. Train salespeople and CSRs on how to use the product. Train help-desk staff. Train anybody who will install or train on the product. Should your own company be the first test customer?

Customer Training. Develop customer training material/manuals.  Consider a web tool andor video tool. Develop training plan. Will you train every employee or train the trainers? How much will you charge for training? How do future subscriber employees get trained?

Implementation. Develop installation plan/checklist. Order IP stations. Perform any customer premise network changes required. Install and verify data connection(s). Install stations and any managed network equipment required. Develop plan to verify that every station is updated and provisioned correctly. Conduct subscriber training sessions. Ask for subscriber feedback on the quality of the implementation. Render and verify first bill.

NOC/Customer Support/Troubleshooting. How will you handle customer support? Will the first level of trouble shooting be done at the CSR level or by specially trained individuals? Who will have access to the tools and training required to assist subscribers?  Will billing issues and technical issues be handled by different employees or by the same employees?

Ongoing Product Maintenance. How do you stay abreast of new features, services and apps that may benefit your subscribers?  How and when do you introduce updates to subscribers?

Faster Fiber

Exceeding the Speed of Light

Exceeding the Speed of Light (Photo credit: IntelGuy)

Researchers at the University of Southhampton have demonstrated a new fiber technology that allows light to traverse fiber at 99.7 % of the speed of light. This is a vast improvement over current fiber technologies that pass light at about 70% the speed of light.

It has long been understood that the glass in a fiber optics cable slows the light signal and that light can travel much faster through air. The new technology creates hollow fiber-optic cable to create a trapped air-pocket for the transmission media.

An abstract of the research can be viewed in Nature Photonics.

As can be expected, it will be a few years before the faster fiber hits the street. But the market is going to want faster fiber since the primary benefit of the new technology will be the reduction of latency on long-haul fiber routes. Researchers also postulate that the first use for the fiber might be as wiring for supercomputers since electricity ‘crawls’ through wiring at about 2/3 the speed of light.

Kansas Deregulation

On March 27 a bill passed (HB 2201) the Kansas Senate that largely deregulated telephone companies in Kansas from being the carrier of last resort. The bill passed the Senate by 36 – 4 and passed in the House by 118 – 1. In the past telephone companies were required to provide telephone service to most customers who wanted service, with some limitations that applied to extremely rural customers. But the new bill provides a host of ways that can excuse a phone company from providing service.

The bill applies to all regulated telephone companies, but also to a lot of other companies that provide telephone service like cable companies and CLECs.

“I think we’re at the point where we can take one of our largest carriers (AT&T) and treat them as if they’re a wireless carrier or cable carrier,” said Sen. Pat Apple, the chairman of the Senate Utilities Committee.

House Bill No. 2201 (click to open .pdf) is the Senate-approved version of the bill. Since the Senate made changes it will have to return to the House for final approval or else go to a House-Senate conference committee if the House doesn’t accept the Senate’s changes.

It’s unclear how the bill might have changed the role of the Kansas Corporation Commission (KCC) who currently regulates telephone companies. Currently the KCC has the authority to ‘prevent fraud’ but the bill changes that authority to ‘investigate fraud’. It’s not clear if the KCC will have any authority to affect the behavior of a badly performing telecom provider, as is already the case with cellular companies today.

The bill also shrinks the Kansas Universal Fund, which is a pool of money collected from telephone customers in the state and that is used to support rural telephony.

The bill was originally authored by AT&T but was presented to the legislation with a united front by most of the carriers in the state. AT&T has lobbied for similar legislation in many other states. While Kansas is now the first state to effectively remove carrier-of-last-resort obligations, one would expect this to happen in other states. Telephone subscribers have been steadily dropping everywhere as consumers have shifted to cell phones and to VoIP carriers for their telephone usage.