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To: Frank A. Coluccio who wrote (1677)10/23/1998 9:55:00 AM
From: wonk  Read Replies (1) | Respond to of 3178
 
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



To: Frank A. Coluccio who wrote (1677)10/23/1998 10:18:00 AM
From: Stephen B. Temple  Read Replies (2) | Respond to of 3178
 
Frank: First of all, I really like the stance the FCC is taking on these matters. "Setback, listen, approach slowing, execute & deliver".

I think the "chain of command decisions" lets-run-in-reverse-order, on the new paradigm of rules and regulations as something the FCC saw this from the beginning.

One of the reasons why we are seeing "loop-holes" or "fence-post-riding" by the FCC is do to this very reason. Letting the reverse-cycle take affect from the grass-roots. IMO, the FCC tried has tried to comprehend every possible senerio & topic in regards to the TeleAct of 96, this is just another missing-link in determining the outcome.

I am a little stunned about ISPs getting recip-compensation, but directing my thoughts to the Government Regulators?, this is going to make it allot easier, and is setting a stage for the final act in regards to taxing/recip-comp/funding.

I think soon, everyone will pay a possible .05, or .00? across the board."

I look at it like a universal-traffic-tax for the whole industry, and your road-way will be tax by usage, or mileage. This recip-compensation" subject is at the heart of what I think could be a final closure to allot of bickering.

Again, my gut feeling is the FCC will let local and state levels figure out "every possibility", in local and regional disputs, then jump in with both feet for semi-final decisions.

In this article too, its the state PUCs that are making it easier for the FCC to approach those final links. I really like the idea that traveling-traffic should be equal compensation regardless of the carrier.

If you look at it with total-traffic-taxing, it emcompasses a broader scope Government Funding. Therefore, I would hope that the final results of a "universal funding" would be substancially less for everyone, therefore allowing the board to set "funding prices" annually based on prior results, whatever is needed for the next year.

As the PUCs and FCC members trade post'm notes> "when you do, we do" "when we do, you do". I see this as a slow and steady growth closing all forks in the road as we proceed.

Look at it this way, the ILECs are going to get their way. If ISPs are now going to get recip-comp", then they also will pay? Pay what?, of course.....pay back recip-comp" and of course in time, universal funding.

The ILECs have figured out, if you can't beat'm, make them join? Yes, I think so, this be the ol-back-door-trick!!! Could the ILECs have had a helping hand in making this possible? Ohhhhh myyyyy! Sounds like a possible "General Swartzchof" BEAR....sneak attack, back door play!

The more I think about it, the ILECs come out here better than anyone could have imagined "long term that is."

Me thinks the ISPs have stepped in their own dodoo? Maybe <gg>

Temp'

excuse the spelling please <g>