Is Safe Harbor Safe Enough for Rural Call Completion?

Posted by Ken Babcock on Nov 15, 2017 1:04:48 PM
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The FCC is currently struggling mightily to arrive at a fair and equitable solution to the need to promote uniform quality of telecommunications for both large urban centers and very small rural areas of the United States.

The FCC fully recognizes that the existing Rural Call Completion reporting requirements are not capable of providing a reliable measurement of the “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. “

It is a recognized fact within the telecommunications industry that the quality of rural telecommunications has definitely improved over the last three (3) years.

However, the NTCA (The Rural Broadband Association) and the WTA (Western Telecommunications Alliance) which collectively represent roughly 1,575 small rural entities involved in providing rural telecommunications are deathly afraid that if the FCC does away with the data retention and record-keeping now in effect for measurement of rural call completion then the trend will be reversed 

This fear centers on the reality of the incentive for the larger ILECs to reduce costs of routing and terminating LD calls to customers located in rural parts of the United States.

From my perspective, if the FCC did revise its current stance on Rural Call Completion data retention, record-keeping and reporting there would still be an obvious need for the larger ILECs and wireless providers to do record retention and analysis.

Therefore, while the current cost to meet the FCC requirements would be reduced somewhat by the FCC, the remaining requirement to monitor intermediate provider’s performance as dictated in contractual terms sounds easier than it actually is.

Over the last two years the telecom industry has identified a series of actions to be followed by local exchange carriers that can be voluntarily exercised to monitor and control the affected call-completion functions. Chief among these are the following:

  • Reduce the rates to complete calls to geographically remote and sparsely populated rural areas.
  • Follow the ATIS (Alliance for Telecommunications Industry Solutions.) guidelines for call routing and termination which are extensive and if followed religiously would undoubtedly lead to excellent results.
  • Limit the number of “intermediate carriers” or least cost routers” involved in carry a single call from the call originator to the intended terminating party. Quite often these so-called intermediate providers may not be totally committed to prevent service degradation that can be more than just failure to complete calls. Service degradation issues such as significant delays, lack of ringing on called party phone numbers and manufactured false ringing and/or busy tones are all part of the overall problem.

In the following excerpts that I have taken from recent filings by and before the FCC by interested parties, I believe that you can see where we stand as an industry:

“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.

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, the most of the larger local exchange service and wireless service providers are adamant that the FCC should allow them to put a Safe Harbor methodology in place that would in turn allow them  to voluntarily implement whatever is required in their individual circumstances to achieve the stated goal of implementing and maintaining the highest grade of rural Long Distance call completion possible without preserving the need to do quarterly reporting to the FCC via the existing Form 480 process.

The point that I would like to make is that a safe harbor approach cannot be achieved without a significant ongoing investment in data capture, data enhancement, data storage and internal reporting of intermediate provider performance.

So while some of the sting of today’s FCC mandated data retention and reporting may be contemplated no one should be certain there is not much to do now and in the future.

Topics: Telecom Data Analytics, Regulatory, Rural Call Completion