Frank:
...And as an ISP, they are also enjoying exempt status, if I'm not mistaken, on the access side wrt universal service and originating and terminating charges where their IP services are involved... or does this extend beyond simple dial up access, into their VoIP services as well?
We had a brief discussion here, but rereading it we may, in part, have been talking past each other. (g)
#reply-5620471
#reply-5626916
Perhaps I can clarify my thoughts.
These PUC rulings are "strict construction" rulings. I think of it this way:
"Generic" ISP purchases circuits and phone numbers from CLEC. "Generic" ISP cutsomer, who is an ILEC subscriber, dials the ISP. Therefore, call is routed to the CLEC which effectively terminates the call (final PSTN destination).
ISP Customer (ILEC subscriber) ==> ILEC ==> CLEC ==> ISP
My point in the earlier message about call centers was that if one removes the phrase ISP and substitutes, for example, a phone bank at a local TV station for a telethon or a fund raising drive, would there be confusion here? The CLEC, in this example, providing circuits and phone numbers to the station, is the terminating carrier for an ILEC orginating call. Hence, entitled to compensation since their facilities are being used and they are the terminating carrier.
Residential subscriber ==> ILEC ==> CLEC ==> CLEC customer (e.g., tv station)
Back on point, in my mind once the ISP enlarges its status to an ITSP, then the whole issue of reciprocal compensation changes. The ITSP takes on a carrier status being both a destination for PSTN traffic and an originator of traffic ultimately terminated on the PSTN. The CLEC then becomes, in effect a pass through (receiving compensation from the ILEC but paying to the ITSP, a wash transaction.
Since NETCOM is a "wholly-owned" subsidiary of ICG, the ILEC is focusing on NETCOM not being entitled to compensation (true) but ignoring their contractual relationship with ICG (separate legal entity). IMO, the PUCs are saying "sorry, ICG is a carrier, NETCOM (legally) is not, honor your contract)." If and when Netcom becomes a carrier, providing VoIP services I think it all changes.
Perhaps I'm still confused.
ww |
