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:
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
“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:
“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:
“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:
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.