Is There a Life After Rural Call Completion Reports?

Over the last two years, the FCC has been in the process of determining whether it still makes sense to have telecom service providers collect and report on call answer and completion rates on long distance domestic calls that were handed-off to Interexchange Carriers who provided routing, transport and completion functions for the calls made to customers of a NECA-provided list of small ILECs as well as to the much larger non-rural local exchange service providers in aggregate.

The intent was to provide the FCC with a clear measurement of how answer and call completion rates differed for various small non-rural carriers compared to the overall rate provided to larger non-rural carriers in total.

The purpose of the FCC Form 480 (Rural Call Completion Reporting) was to provide a tool for the FCC to spur the overall improvement of interLATA long distance toll completion rates to far-flung telephone users who had been complaining long and hard that they were being abused in comparison to their non-rural cousins.

The requirements to collect summarize, report and retain underlying data on the FCC Form 480 has been in effect since the 1^st Quarter, 2016.

During the life of the reporting process, local exchange carriers having 100,000 or more fixed business fixed residence and mobile lines have had to spend considerable expense and effort to comply with the FCC order.

Overall, the reported rates have not improved greatly and the FCC has found it difficult if not impossible to rely on the quarterly FCC Form 480 reports because of the uneven quality and perceived integrity issues of the reports themselves. A large issue has been the inability of service providers to distinguish “autodialer” and wholesale traffic in their reports.

Nevertheless, the larger local exchange carriers strongly believe that they have improved their levels of service and that the continued expense caused by the reporting process is not warranted.

In fact, the FCC notes in the Second FNPRM that rural call completion complaints have decreased by 57% from 2015-2016.

As a result, the FCC on June 22, 2017 issued the Second FNPRM in which it proposes and/or seeks comment on:

Adopting new rules that would, consistent with industry best practices, require covered providers to

1. Monitor the rural call performance of their intermediate providers
2. Hold those intermediate providers accountable for their performance.
3. Eliminating the FCC’s existing rural call completion data collection and reporting rules, which may be rendered unnecessary by the adoption of new rules intended to more directly and proactively address rural call completion problems. “

This line of attack has triggered a most prolific and intriguing set of recommendations by the industry as a whole to solve the issue permanently.

Basically, all interested parties with the exception of the WTA(Western Telecommunications Alliance ) and NCTA(National Cable and Television Association) and a few other representatives of the small rural telecom companies are in agreement that the current quarterly reporting process should be stopped immediately and a shift be made toward voluntary actions designed to focus on intermediate providers as a means for boosting call completion rates.

The suggestions for change that have been offered run the gamut as follows:

• Eliminate terminating local interconnection charges and transition tandem and transit charges totally to a bill & keep regime.
• Prohibit the use of more than two (2) intermediate providers in RCC paths.
• Establishing a waiver process for carriers that have a legitimate need to use more than two intermediate carriers in RCC paths
• Implement a public registry at the FCC for all intermediate carriers serving RCC paths.
• Requiring carriers to ensure that the average utilization of trunk groups used to complete rural calls never exceeds 80%.
• Establish the provision of safe-harbor and non safe-harbor levels of service to rural local exchange carriers in this cases where a call originator is willing to sacrifice call completion quality for cost reasons.
• Support implementation of the ATIS an Intercarrier Call Completion/Call Termination Handbook that includes recommended industry best practices to mitigate call completion issues
• Mandate the use of test lines, where available, in resolving call completion issues reported by the called party. Such lines can expedite trouble resolution, avoid Customer Propriety Network Information-(CPNI) related issues and exclude problems that may be specific to the called party’s access and customer premises equipment arrangements.

Comcast in its first set of reply comments in August, 2017 went so far as to propose the following set of guidelines for effectively monitoring intermediate long distance toll providers:

• Require intermediate providers to undergo technical tests that confirm network reliability before receiving traffic.
• Establish performance metrics for assessing intermediate provider performance;
• Monitors whether each intermediate provider meets these metrics at
• least once per month
• Directly address any failure to meet these metrics with the intermediate provider
• Remove an intermediate provider from a route if the intermediate provider either fails to provide the covered provider with a description of the remedial actions undertaken to improve its performance or the intermediate provider’s performance does not improve after a reasonable period of time.

In addition it appears that Congress is on the cusp of passing legislation that appropriately places the focus of regulation on third-party intermediate providers who are the source of most call completion issues.

The practices that are identified for elimination are as follows:

1. Prohibiting “call looping,” a practice in which the intermediate provider hands off a call for completion to a provider that has previously handed off the call).
2. Requiring intermediate providers to “crank back” or release a call back to the originating carrier, rather than simply dropping the call, upon failure to find a route
3. Prohibiting intermediate providers from processing calls so as to “terminate and re-originate” them (e.g., fraudulently using “SIM boxes” or unlimited VoIP plans to re-originate large amounts of traffic in an attempt to shift the cost of terminating these calls from the originating provider to the wireless or wireline provider).

In general, most of the larger local exchange service providers are adamant that the FCC should voluntarily allow competitive market forces and industry collaboration and cooperation as seen in industry best practices to work their magic rather than take the stand that the Form 480 requirements must stay in place for ever.