Regulatory Alert: Rural Call Completion

Seal of the United States Federal Communicatio...

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

The FCC took action on October 28 to address a growing problem of calls that are not completed to rural areas. The Commission adopted new rules that are aimed to remedy a growing problem of calls that are not completed.

The FCC noted that the situation was “serious and unacceptable” and that every call that is placed should be terminated. The FCC note that “Whatever the reason, the consequences of failed calls can be life-threatening, costly, and frustrating. Rural businesses have reported losing customers who couldn’t call in orders, while families attempting to contact elderly relatives have worried when they hear a ring – but no one picks up on the other end because the call never actually went through.”

The FCC surmises several reasons for uncompleted calls:

  • They think that some providers are not routing to rural areas to avoid higher than average terminating access charge rates. The access rates in rural areas are still much higher than rates for major metropolitan areas, which reflects the higher cost of doing business in rural areas. Terminating rates can still be as much as two cents per minutes higher. However, the FCC has always said that it insists that every call must go through, and if they ever got evidence of a specific carrier boycotting an area due to high rates I suspect they would levy high fines.
  • They think that much of the problem is due to the fact that calls can be routed through multiple carriers. They note that the best industry practice is to limit to two the number of intermediate carriers involved in routing a call. I know there are a lot of new carriers in the market today, such as multiple new companies marketing voice services like IP Centrex who search for the lowest cost way to route calls. One has to suspect that the long distance carriers beneath some of these carriers have gotten very creative in terms of routing calls to save costs.
  • Some carriers have been sending a ring tone to the calling party before the call has actually been completed. One has to suspect that this is done so that the caller can’t hear all of the intermediate switching going on to get the call completed. The problem with doing this is that the caller will hang up after a few unanswered rings, often before the call has even been completed.

The FCC took several concrete steps to fix the problem. These new rules will be effective in a few weeks once the final rules are published. The new rules are:

  • False audible ringing is prohibited, meaning that a telephone provider cannot send a ringtone to the caller until the call has actually been answered.
  • Carriers with over 100,000 voice lines, and who are the carrier that determines how calls are routed must collect and retain calling data for a six month period.
  • Carriers who can certify that they follow best industry practices, such as not routing calls through more than two intermediate carriers, will be able to get a waiver for some or all of the storage and reporting requirements.
  • Carriers who can demonstrate that they have all of the mechanisms in place to complete rural calls can also ask for a waiver from the storage and reporting requirements.

Unified Communications

One of the most powerful feature sets available today is unified communications. Yet very few of my clients are selling it today. But if your customer base includes businesses or a lot of residential power users then you need to include unified communications in your product portfolio, and you need to sell it.

What is unified communications (UC)? UC is the integration of real-time communication services with non-real time services. Real time services include such things as voice telephony and VoIP, instant messaging, speech recognition, data sharing, collaboration and video conferencing. Non-real time communication services are often packaged under the name of unified messaging and include such features as voicemail, email, SMS and faxes.

There is no standard set of features that are included in a UC package and it seems that every company that offers it does it a little differently. So a carrier must typically build this product by tying together all of the components and features you already have available into a bundled product. Most carriers who own a softswitch and a voice mail server are capable of creating a basic unified communications product.

There are numerous value propositions that UC offers to end user customers:

  • Brings the ability to delivery any communications medium to any device, anywhere.
  • Extends the corporate network so that mobile customers can be productive from anywhere.
  • Gives the freedom to each individual UC user to tailor the product for the way they can best use it.
  • Can add telepresence technologies to let a UC user check the availability of other resources in his network. For instance a user can see if somebody is available to talk before they try to call them, eliminating the voicemail chain.
  • Can add collaboration and data sharing components which will make employees far more productive. Good collaboration software gives users the ability to share and work together on any document from any software platform simultaneously.

The value to a customer of UC is that it allows the customer to send a message on one medium and receive the same communication in another medium. This frees a customer from any restraints imposed by location or device and the perfect UC product will deliver any communications path to any device anywhere.

For example, a customer can receive an email on any device of his choice and also has the option to have the email content delivered as a standard email, or as a voicemail or text. Normally the customer can receive the medium, in this case an email, live in the medium for which it was intended, but can also opt to receive or store the email on a non-real time basis in any other medium.

The control for making the desired choices is given to the customer. To continue with this example, the customer can set up his UC to always receive emails in a certain format, for example, as a voice mail he listens to on his cellphone, or he can change his options on the fly during the day.

UC is a very powerful product for customers who grasp it and use it. It can make a customer sticky to your network if you give them the freedom to have complete control over their communications.

How do you create a UC product for your network? The first step is to decide what you want to offer. Not every UC system tries to deliver every communications product to every device. Many UC products instead are crafted to satisfy specific customer applications. If you own a softswitch you probably already own many of the components needed to build a simple UC product. For example, there are various features built into the feature packages on a Metaswitch that can be combined to create a decent UC product. And if you only have a few business customers who will be interested in UC, this might be sufficient.

The other alternative is to buy a UC product from somebody else’s platform. Today there are numerous companies who have assembled UC products that function on their own platforms. As a carrier you can access these platforms on a wholesale basis and buy ready-made UC products for your customers rather than build your own UC products from scratch.

There has been a lot of industry activity in developing UC products in recent years. Since March 2008 there have been several open source UC projects based on Asterisk that has led to the creation of open source UC product lines. In May 2010, the Unified Communications Interoperability Forum (UCIF) was created to develop standards between technology companies for UC and to create interoperability profiles, implementation guidelines, and best UC practices. The original founding members were HP, Juniper Networks, Logitech, Microsoft and Polycom.

Because UC can be done in many different ways and can include numerous product components you can save a lot of time before trying to create a UC product by talking to CCG.

Should you Build a WiFi Network?

Free Wireless (WiFi) Minneapolis Hotspot in Su...

Free Wireless (WiFi) Minneapolis Hotspot in Sumner Field (Photo credit: Wikipedia)

For years I have had clients who have been building WiFi networks and then trying to figure out ways to make money with them. For the first time I think there is now enough opportunity to sufficiently monetize a WiFi network to make it look like a good investment. The following are some of the ways that other carriers are making money from WiFi. A good business plan will probably need to combine several of these together to make a viable business.

Cellular Data Upload. The biggest use of WiFi is becoming the uploading of cellular data to the network. Most cellular carriers sell data plans with low caps and they want and expect their customers to use WiFi to keep data traffic off the cellular networks. In most places the cellular networks are not nearly robust enough to handle all of the data they would need to carry if it wasn’t for WiFi. There are two different possible ways to monetize this.

If your service area has enough customers of one or more of the major cellular companies, the carriers might be interested in buying wholesale access into your WiFi network. This is something that is happening in big cities, and in many places the cellular carriers are deploying the WiFi directly. But there are now a number of markets where cellular carriers are buying bulk WiFi access from other carriers.

However, deals with cellular carriers are not yet something that has been commoditized, and the alternate plan is to sell data plans directly to cellular customers in your town for their smart phones. Many cellular customers already have WiFi in their homes, but with a city-wide WiFi network they could then get the WiFi benefits anywhere in town. Statistics say that 85% of cellular data is used in the home territory and you can sell data for less than the cellular carriers and make good money at it.

MVNO Wireless. Even better than selling cellular data to others is consider offering your own wireless plans using an MVNO. In this scenario you buy bulk cellular minutes, text messaging and cellular data and then package them your own cellular plans. If you have a city-wide WiFi network you have a big advantage because you can make sure that your cellular customers use your network for both voice and data when that is possible. This means that you can charge them cellular-level pricing for traffic that you are delivering at landline costs. The margins on MVNO wireless are already decent, but combining it with a robust WiFi network really enhances the bottom line.

Broadband Alternative. There are now a significant number of customers who don’t want traditional broadband delivered by wireline. In addition to smartphone users, there are many customers who now use pads and laptops instead of traditional PCs. So you can sell WiFi business plans as an alternative or as an adjunct to your existing data plans. WiFi-only plans can be priced similarly to traditional low-level landline plans and you might sell a ‘portability’ additive plan to your normal landline data customers. Finally, you can sell hourly, daily and weekly WiFi to visitors or occasional users.

VoIP / Local Only Phone. In every market there are customers who almost never leave town and with a WiFi network you can give them a much lower cost portable phone alternative than using a traditional cellphone carrier. This essentially is a cordless phone that will go anywhere in the town. You also can use WiFi to give local phones to kids and others for low prices, saving parents the cost of pricey cellular family plans.

Public Safety. Most towns and cities would be interested in using your network for public safety and public works. With a citywide WiFi network you can give all city employees access to data anywhere in town, making it easier for police and fire to operate using pads but also improving the productivity for inspectors and other city workers who are mobile in the town. You should be able to sell bulk access to the city and local utilities, particularly if you will arrange a QOS arrangement to give public safety a priority for the network when they need it.

Workforce Needs. And of course, a city-wide WiFi network will also increase your own productivity since your own installers and salespeople can always be connected to the network with a pad or smartphone. This is not a revenue opportunity but rather can save you money.

There certainly some issues to consider and it would make sense to pre-sell to the larger WiFi users before you build the network. But if you can sign up a cellular carrier or the City government as anchor tenants then you can build knowing that these other revenues will materialize if the network is built with good coverage.

Like any business there are operational issues to consider. For instance you will want to insure that only people who are paying for your service use the network so you will want a secure system to validate users and be prepared to boot off customers who give away passwords to others.

From a technical and cost perspective it has never been easier to get into the WiFi business. The price of equipment has dropped and it has become more science and less art to keep the network functioning well.

Regulatory Alert: FCC Reminds ACS Providers (Advanced Communications Services) of Filing for CVAA Compliance

Seal of the United States Federal Communicatio...

The FCC recently issued a public notice reminding Advanced Communications Providers (ACS) and equipment manufacturers that they need to provide evidence that they are complying with the Twenty First Century Communications and Video Accessibility Act (CVAA). The FCC is now implementing Section 255 of the Telecommunications Act of 1996 that requires telecom products and equipment be accessible by people with disabilities.

The FCC defines an ACS provider in Section 3(1) of the Act to mean a carrier that provides one of the following: (A) interconnected VoIP service; (B) non-interconnected VoIP service; (C) electronic messaging service; and (D) interoperable video conferencing service. The FCC also defines advanced communications services providers to include all entities that offer advanced communications services in or affecting interstate commerce, including resellers and aggregators. Such providers include entities that provide advanced communications services over their own networks, as well as providers of applications or services accessed (i.e., downloaded and run) by users over other service providers’ networks.

The CVAA law was enacted in 2010 and is aimed to ensure that people with disabilities have access to advanced communications services. This requirement by the FCC is somewhat unusual in that it applies to telecom providers who are otherwise largely unregulated.

And there are a lot of nuances to be in compliance:

  • There must be a filing done for each corporate entity that provides ACS services and you can’t just designate somebody at the parent company to cover all of your subsidiaries.
  • You must provide an affidavit of compliance by a company officer.
  • It must be filed electronically.

The original deadline for these filings was April 1, but we believe a lot of entities who should have filed did not. If you provide any form of VoIP you need to comply with these rules or face eventual fines.

The filing requires the following:

  • A description of the effort the company will undertake to discuss your services with customers with disabilities.
  • A description of the features and other ways that your products will be made accessible to customers with disabilities.
  • A description of how people with disabilities would most likely be able to use your products.

So, if you provide VoIP – even on a resale basis – you need to make this filing.

If you want to know more about the specific filing requirements, or if you want assistance in making this filing contact Terri Firestein at (301) 788-6889.

Customers – Make Them Part of Your ‘Club’

Today’s guest blogger is Mike Fox. He was one of the founders of CCG and we still work together on a number of projects. He is working today for Fox Management Advisors. Mike can be reached at (307) 431-6543.

MotorcyclesFor the past decade or so, the telecom industry has made great strides to become more competitive and focused on evolving customer needs and desires. However, we still have a long way to go. Our industry is changing and many products and services that were once ‘cash cows’ are now becoming almost ‘commodity’ services (although, in reality, treating any of your services like commodities is both dangerous and fundamentally wrong – I’ll address this in more detail in a future entry).

For example, long distance used to be a huge money-maker for telephone companies. Today, with unlimited (although, not ‘free’) calling throughout the US as part of most calling plans (landline or wireless), the world has changed. For those of us old enough to remember, it wasn’t that long ago that every long distance call was carefully scrutinized by our parents! Today, we don’t care who or where our kids call, just so long as they don’t go over the minutes in their plan.

So, how do we structure our sales culture to attract and keep more customers? What makes them sticky? Is it price? No, that’s commodity sales think. There will always be someone willing to offer lower prices. Sure, you have to be price competitive, but you should never sell on price.  Rather, sell on value and work to generate loyal customers. Many of the most loyal customer bases in the world are very willing to pay above market prices for the stuff they want. Think of Harley Davidson, Apple Computers and Starbucks. All provide products and services at prices above their competitors, but their customer base is extremely loyal and willing to pay such prices. And, it’s not just about quality. Sure their quality is good, but it’s more the subjective aspects that make these customers loyal – e.g., it’s fun to be part of the Harley club! Simply put, passionate, loyal and, ergo, sticky customers have an emotional attachment to the brand.

Do your customers feel passionate about your products and services? If not, that can be changed.  Find a way to make help your customers connect with your products and services in a personal way. While there are many ways to accomplish this, one important aspect is to nurture your personal relationships with your customers. Make them feel like they are part of your community and an important part of your community. When I lived back east, I became friends with a manager at an Acura car dealership. Over a period of 9 years, I bought several cars from him, even two used vehicles that were not Acuras. I love the Acura brand, but that isn’t what brought me back since there were several other Acura dealers in the area. Rather, every time I walked in that dealership (and I did many times when I wasn’t buying), they made me feel welcome and ‘part of the club’.  It was fun and whenever I was in the market for a new car, that’s who I went to first. Let’s figure out a way to make your customers think of you first when they think of ANYTHING related to telecommunications. Even if you don’t sell what they need at the time, encourage them to come in to the office and just talk. Who knows, it might result in a sale and it certainly will encourage them to come back the next time when you do have something they want.

Smart Upgrades

Every network faces periodic upgrades of electronics or key components. We have found that cutovers are the time when any network is the most vulnerable.

There are tried and true processes that can be used to minimize the chance or duration of network outages during upgrades. The following is a list of steps that we recommend for any network upgrade that puts customer service at risk. Following these steps is never a promise of 100% safety, but we have never seen a company that upgrades in this methodical and planned manner have major problems.

  1. Have a Project Manager for the Upgrade. It is vital to have one person in charge of the upgrade. They can get assistance in planning and doing the upgrade, but they need to be the one ready and authorized to react if things don’t go as planned.
  2. Develop a Checklist. You should develop a step-by-step checklist of everything to consider for the upgrade. Make sure that you understand every piece of equipment and software that will be affected by the upgrade. And then, most importantly, develop a step-by-step list of the steps required to perform the upgrade.
  3. Break the Upgrade into Manageable Steps.  If possible, the upgrade should be done in stages where progress can be measured and tested as each step progresses.
  4. Establish a Baseline / Establish a Go-Back Process. By this we mean that you need to completely understand the current network configuration, in detail. You need to know the exact settings of every piece of equipment. And once you understand the current network configuration develop a go-back process. This would be the steps needed to get the network back to the original configuration if something goes wrong during the upgrade. Ideally the go-back would be something really fast and we sometimes have seen this programmed such that it can be done in minutes.
  5. Understand the Traffic Flow (and then monitor during the cutover). During the upgrade process you might not get the same kind of alarms that you normally would expect. Also, changing traffic patterns due to the cutover can skew traditional measurements if you are rearranging the network. So it’s vital to understand your traffic flow before the upgrade. Then, have somebody monitor the traffic during the cutover since this might be the only way you will know that you have knocked customers out of service.
  6. Make Sure you have Vendor Support. For a major upgrade you should consider having a vendor representative on site. Otherwise, make sure ahead of time that somebody will be able to help you if you run into unexpected problems. I have seen clients schedule an upgrade over a holiday, not thinking that the needed expertise at the vendor is probably not going to be available.
  7. Pre-test Every Component before the Cut. Definitely test any new equipment before you introduce it into the network to make sure that it is operating properly. For complicated upgrades you ought to consider setting up a test lab where you can test the new equipment against components that will remain in the network for interoperability.
  8. Take Every Upgrade Seriously. I often see companies follow most of the above steps for major upgrades only to see them knock out their network for some simple upgrade like introducing new cards or something they thought was a simple upgrade. Any change that can knock down your network might knock down your network, so take every upgrade seriously.
  9. Define What Success Looks Like. You should establish the needed tests ahead of time that will let you check that every aspect of the network is working as planned. You don’t want to do an upgrade that is almost right only to find that you have created future problems. So establish a detailed test plan.

If you have questions about upgrades or want help developing an upgrade plan contact Derrel Duplechin of CCG at (337) 654-7490.

Will Telecom Investing Become Sexy Again?

Image representing Google as depicted in Crunc...

Image via CrunchBase

Will the fact that Google is investing in fiber make it sexy again to invest in telecom? The last time that there was a big boom in investing in new telecom ventures was the late 90’s. At that time there were dozens of start-up CLECs, a number of which were able to issue IPOs and go public. Every smart investor had some telecom stocks in their portfolio.

But the new CLECs and telecom firms of that time almost all went bust with only a few of them still around today. There are a number of reasons for the bust. The business plans of many telecom startups depended upon arbitrage – using the facilities of the incumbent rather than making infrastructure investments. And many of the telecom start-ups had bad business plans that expanded into too many markets too quickly to do it well. And somehow the telecoms got tied in with the dot.coms and when those went bust the telecoms followed them down the tubes. And investors lost a lot of money and got soured on telecom. The lasting effect of the bust was that it became unsexy to invest in telecom.

And almost nobody has invested in telecom since then. It’s hard to find anybody who doesn’t recognize that the US is falling behind the rest of the world in telecom infrastructure, namely fiber. Since the telecom bust the only ones investing in fiber to whole communities have been Verizon, some municipalities and some smaller independent telephone companies. Verizon’s decision to build fiber was a bold one, but it didn’t drag anybody else along. And Verizon’s fiber build dwarfs all of the rest of the builders collectively. The vast majority of the country does not have fiber but wants it badly.

But now Google comes along and is boldly investing in fiber in large communities – Kansas City and Austin. What they are telling the world is that there is profit in fiber, profit in infrastructure investing. Kansas City was touted as a trial, but by having announced Austin so quickly it is obvious that Google thinks that their experiment is working. And while Google has made an announcement for Provo, Utah, that is a one-off since they were able to pick up an existing fiber network and customers at a very good price.

I keep hearing that there is a lot of money today on the sidelines, meaning money waiting to get invested in good projects. And this is interesting to me since there is such an obvious need in this country today for new and upgraded infrastructure. In addition to a huge need for fiber networks there is a huge demand for clean energy generation plus the usual things like bridges and roads. Perhaps at least to some small degree the Google decision to boldly invest in infrastructure can be the first step towards unleashing the private equity in the country to invest in infrastructure again. Google thinks such investing can be profitable and obviously it is good for the country. Will others follow?

Regulatory Alert: FCC Acts on Numbering Issues

Seal of the United States Federal Communicatio...

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

At today’s FCC Open Meeting the FCC approved the release of a Notice of Proposed Rulemaking (NPRM) and Notice of Inquiry (NOI) on expanding direct access to telephone numbers for wholly VoIP providers like Vonage.  Vonage was also granted a waiver to conduct a limited 6 month trial involving 145,000 numbers.  The Wireline Competition Bureau is responsible for reporting back to the Commission at the conclusion of the trial.

Disassociating telephone numbers from geographic locations will also be part of this NPRM and NOI.

Check back as CCG will monitor this proceeding. We will be posting the NPRM and NOI when they are released.

Hosted IP Centrex Service

In a few other blogs I have referred to IP Centrex as a new service for businesses, so I thought I ought to explain the service. Hosted IP Centrex service uses data-centric phone sets to replaces key system, PBX system or existing Centrex service. The IP Centrex phones can be controlled by a softswitch or by connecting an IP PBX to a legacy switch.

A number of CCG’s clients are having success selling IP Centrex to business customers. The product includes the best features of a large PBX plus many additional “value added” services that are only available through IP based phone service. The product can be integrated with a subscriber’s computer systems to provide such features as dialing from Outlook, common databases for all employees, etc.

There is a wide range of phone sets available that include a screen that allows a caller to manage their calling. The product requires a customer to buy new IP handsets and many of my clients lease sets as part of the price.

This product has a large potential market since it can be tailored for the very small or very large business. It is easy for the carrier or the subscriber to customize features for each phone or for the whole system.

There are a number of benefits of this product to both the carrier and to subscribers. Some of the biggest advantages:

Benefits to the Carrier

  1. Can be sold to any business subscriber regardless of what service they had before. It’s a good replacement for B1’s, trunks or traditional Centrex.
  2. Subscribers become stickier to the extent you can get them hooked on custom features not available elsewhere.
  3. Allows a carrier to sell service outside your traditional footprint. You just need to find businesses that have a decent high-speed data connection. This also means you can sell voice services to all branches of a customer’s business and not just to those in your footprint.
  4. It promotes the Company’s data products and is easily bundled with data.
  5. The product has a lot of pricing flexibility and can be sold to compete with multiple B1’s or traditional Centrex. You should be able to profitably beat the price of any traditional phone product.

Benefits to Business Subscribers

  1. The Subscribers get a telephone system that equals the features of a high-end PBX.
  2. The Subscriber no longer needs to buy or maintain a PBX. The customer can buy the IP phones or lease them from you.
  3. Subscribers can portray a unified professional image to the public. Employees at remote locations can be integrated into the telephone system. And small companies can act like bigger companies by the use of the various features. Remote employees can be made to feel like a part of the Company.
  4. Subscribers can tailor the phone system and each phone to meet their needs. There are hundreds of features available including many that were not available on analog systems.
  5. Subscribers can easily manage the features available on each set using the Subscriber portal that allows for easy and immediate changes to the features on any or all phones.
  6. Phones are portable and an employee can quickly move their phone from desk to desk or office to office and keep the same extension, voice mail and features.
  7. Phones can be programmed to be nomadic (portable, but not mobile). This means that an employee can take the phone out of the office and work at home or in a hotel as if they were in the office.  All features and functions of the phone remain unchanged.

Who is Going to Pay for the IP Network?

Peninsular Telephone Company

Peninsular Telephone Company (Photo credit: Nick Suan)

Small telcos and most CLECs are waiting to see what will come from the changes due to converting to an all IP network for telephony. Today the telephony voice network utilizes TDM (time division multiplexing) technology that was originally developed for copper but that has been upgraded to use fiber. But the FCC has said that this old network is going to have to be upgraded to all-IP, meaning that voice will be carried by Ethernet similar to the way that data is transmitted.

I don’t think anybody is arguing that this kind of shift makes sense. IP trunking is far more efficient in terms of carrying more calls in the same amount of bandwidth. And a lot of companies have already implemented some IP trunking.

The important issue for small telcos and CLECs is how this transition is going to change their costs. In order to understand the possible change, let’s look at how voice traffic gets to and from small telcos and CLECs today.

  • Independent telephone companies connect with larger companies and neighboring companies by physical interconnection at mutual meetpoints. Historically, most of the meetpoints are located at the physical border between two neighboring telephone companies with each company owning the fiber and electronics in their own territory. And each telco is responsible for the costs of their portion of the network. Historically local calls have been exchanged for free in both directions and there are access charges in place for all telcos to get paid by the long distance carriers for using their network and facilities for long distance calls.
  • The rules governing CLECs were established by the Telecommunications Act of 1996. This Act laid forth the basic rule that a CLEC can interconnect with a telco network at any technically feasible point. This idea was fought hard by the large telcos who wanted CLECs to bring traffic to their tandems (regional hub offices). Once a CLEC has established a meetpoint, then it works pretty much the same as normal telco interconnection in that both parties are responsible for costs on their side of the interconnection. Sometimes local calls are interchanged for a fee and sometimes they are free (called bill and keep) and this is negotiated. The CLECs also bill access charges for carrying long distance calls.

There are a number of ways that IP trunking could be implemented, and each of them has financial consequences for small telcos and CLECs:

  • The IP network could be built to mimic the current PSTN. The routes would be roughly the same but the rules of interconnection would stay the same. But with IP trunking the network would be more efficient.
  • The large telcos could establish regional hubs and expect everybody else to somehow get their traffic to those locations. This would be a radical change for small telcos who would have to build or lease fiber from their rural location to the nearest regional hub. For CLECs this would completely undo the rules established by the Telecommunications Act of 1996 and would put all of the cost to get to the hubs onto them.
  • In the most extreme IP network there would be only a few large hubs to cover the whole US. This would be the most efficient in terms of the hubs, but it would require all telcos and CLECs to spend a lot of money to get their voice traffic to and from the hub.

Since I have been working in the industry the RBOCs (now AT&T and Verizon) have tried several times to put the burden and the cost of transporting calls onto the small telcos. But regulators have always stepped in to stop this because they realize that it would greatly jack up the cost of doing business in rural areas. I certainly hope that as we move to a more efficient network that we don’t end up breaking a system that is working well.

The downside to any plan that shifts cost to small telcos is that the cost of providing local and long distance service will increase in rural areas. The consequence of changing the CLEC rules will be less competition. The current interconnection and compensation rules have served the country well. Every caller benefits by having affordable rates to call to and from rural areas. And there is no doubt that higher communications cost would be a major hindrance to creating and keeping jobs in rural areas.