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A few months ago the FCC released order DA 18-710 specifying the network performance testing and reporting required for ISPs who receive support from the Connect America Fund (CAF). The order is nearly 40 pages, but in this post we will summarize the requirements and provide some options for how ISPs can comply.

Who Must Comply?

Recipients of CAF high-cost universal service support, including:

In February 2018, an up and coming VoIP service provider contacted us about performing a USF traffic analysis before their next quarterly filing. With the 'Safe Harbor' rate set at 64.9% and the quarterly contribution factor increasing to an all time high of 19.5%, D3 Unified Communications decided it was time to explore the option of performing a traffic study.

Within 1 week, we had a data sample from D3 and provided a free high level estimate of what their actual PIU would be if we completed the traffic study. Our quick analysis on the data estimated that their actual PIU would be less than half of the 'Safe Harbor' rate of 64.9%. The decision to perform the traffic study became an easy one to make as the savings were very evident.

The Improving Rural Call Quality and Reliability Act of 2017 (“RCC Act”) was signed into law by President Trump on February 26, 2018.

The primary thrust of the Act was designed to focus attention on the quality and reliability of communication services provided to rural areas of the United States by entities referred to as Intermediate Providers.

*** Ken Babcock will be hosting a free webinar on the new rules and impacts of the Rural Call Completion order on Wednesday, May 23, 2018 at 1 PM EST.  Click Here to sign up for the webinar ***

Changes are here for Rural Call Completion reporting and compliance.  The good news is that the FCC has ruled in FCC18-45 that, effective immediately, Covered Providers no longer must submit FCC 480 – Rural Call Completion Reports to the FCC on a quarterly basis. Thus, the report that was due May 15, 2018 covering the 1^st Quarter, 2018 does not have to be submitted.

However, there are new and increased FCC regulations as spelled out in the Second Rural Completion Order that was published in the Federal Register on May 10, 2018 and that goes into effect on June 11, 2018.  Covered Providers, as defined in the previous Rural Call Completion Report regime, must now implement an internal contract management and monitoring process that is far more stringent than anything experienced previously.

In my last blog, I made what I consider to be a clear statement of what can be done and what will happen if we do not do something.  We need to face reality and meet it head on.

The first thought that comes to my mind is that we will need one world-wide database that will be populated with unique Geographic User Building Blocs (GUBBS).  Initially, the thought is to make the concept work within the existing North American Numbering Plan Area (NANPA) and if successful expand the idea to the rest of the world.

Recently, there has been a growing public buzz about the impact of making it possible for any telephone number user to keep his/her same telephone number regardless of where he/she moves within the United States.

From a purely technical perspective, especially in this world of IP-to-IP connectivity and wireless, there is nothing from a network operations perspective that would prevent such an occurrence.

However, as we all know, the devil is in the details.

For the last fifty years of my telecom experience, a person’s telephone number had geographical significance that was critical to proper rating and classification of calls placed from a telephone number.

The telephone number could easily be translated to a/an:

• Exchange Name
• Exchange Carrier
• Rate Center having specific Vertical and Horizontal coordinates that identified the exact physical location within the North American Numbering Plan Area
• LATA Code
• State Code

This type of structure historically promoted distance-sensitive rating structures for individual calls that carried labels like Local, intrastate toll and interstate toll. The structure often dictated things like when you were billed for telephone usage during a month.

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. “

The proposed USF Contribution Factor for 4th Quarter 2017 is 18.8%.

The FCC recently announced that the proposed Federal Universal Service Fund ("USF") contribution factor for the 4Q of 2017 will be 18.8%. This is a significant increase from the 3Q rate of 17.1% and the highest contribution factor in the history of the USF.  

What Should You do?

When the Federal Communications Commission (FCC) first mandated Local Number Portability (LNP) on June 27, 1996 in the 100 largest Metropolitan Statistical Areas by October 1, 1997 and elsewhere by December 31, 1998 as a spur to open up competition for customers among local service providers, I doubt that it had any idea how pervasive their requirement would become.

At the time of the initial FCC ruling on LNP, the concept of allowing a user to transfer his/her fixed-line telephone service from one service provider to another without changing the service’s ten digit telephone number was viewed as the end-of-the-world by Regional Bell Operating Company (RBOC) and Independent Local Exchange Carrier (ILEC) personnel.