From: Justin Hannah
[justin@carrierone.net] Sent: Tuesday, December 02, 2003 1:39
AM To: voipforum Subject: VoIP Forum comments - Why not just
regulate recip compensation? I don't see the purpose of addressing
residential VoIP applications such as Vonage for a variety of reasons, but the
bells have enough to worry about with CLECs, Wireless number portability, and so
forth. Sure, there needs to be a way to do E911 reliably, and USF if
anything will go by the wayside if telecom was allowed to become cheaper.
As far as accessability for the deaf and blind... This is the internet- they
have EMAIL, and theres plenty of gateways from the internet to phones utilizing
web sites. It isn't the telecom service providers fault if a company
installs non-compliant hardware at their facility. Thats a completely moot
issue for regulatory consideration as a whole.
The real bottom line here
is that carriers are using VoIP to carry long distance traffic (especially
intrastate in many cases) and dumping them off as local calls so that they can
avoid higher termination/origination rates solely because of recip compensation,
unfortunately in the process making the government lose millions in revenue from
taxes and contributions. If you want to fix the source of this problem
at the heart, simply flatten the rate of or get rid of the recip compensation to
begin with and disallow ITCs and CLECs from charging astronomical rates and the
whole problem will go away. Then there will be no real advantage of
using VoIP for them and it will make competition even better for wholesale and
retail long distance. They are all doing it because otherwise they would
have to charge $.03-$.05/min to their wholesale customers which are going to LCR
that call somewhere else instead, when RBOC costs half a cent or
less.
Now with wireless number portability it couldn't be any more vital
for this to happen. If long distance carriers are routing calls by NPA/NXX
instead of OCN, they will be filing bankruptcy left and right for numbers that
got ported out from landline to wireless telephones. If you flatten
compensation across the board it will solve that problem too. Querying LIDB to
find out what the terminating LEC is costs you per query which would make the
cost of long distance completion go up.