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To: Stephen B. Temple who wrote (3956)	5/31/1999 6:03:00 PM
From: Frank A. Coluccio	Read Replies (1) \| Respond to of 12823

Good article, Stephen. Thanks. I posted a similar article two days ago at: Message 9851033 Let's see. The ISPs who want to do long distance via VoIP are not actually common carriers, they are enhanced service providers, enjoying the waiver that was bestowed upon them in another era for another purpose. And their users are not making long distance calls, they are actually subscribing to an information processing service. CLECs are not providing long distance service when they terminate an end user's call into an ISP (when the call was actually originated on an ILEC switch), and they should not be paying access charges either when they themselves not only have their own structurally separated ISP service, but an ITSP service for LD telephony, to boot. Instead, they want reciprocating compensation for completing the ILEC's call into the ISP, in addition to the other fruits of regulatory forbearance, for lack of a more suitable word. Now, with this move, what do we have? As the article states: "ISPs can argue that they aren't like ordinary end users and are more like telecommunications carriers when they buy high-volume ADSL offerings. But will treating ISPs as wholesale customers of ADSL in order to protect discounted ADSL services from retail status threaten ISPs' end user status for access charge purposes?" Seems to me that the ISPs have a lot of arguments, not necessarily all consistent ones, but one for each instance when they are asked to pay the piper. Sooner or later the man in D.C. is going to get a pain in his back for bending backwards as far as he has. Two things occur to me here. One, the ILECs may be looking for some favorable treatment, as silly as that may sound, in order to get this service off the ground in the way of regulatory relief. I already said that it sounded silly, so no rebuffs on this point, please. In any event, they may argue that they are entitled to something along the lines that T, the largest LD company in the world, recently received on the cable venue, when the FCC voted hands off: Hands off. And two, the CLECs who have been enjoying reciprocal compensation treatment for completing dialup calls to ISPs may soon find themselves out of the money on this score. That is, if their ISP customers do a rapid uptake on DSL. Granted some of the Data CLECs are already entertaining this, and offering DSL to businesses, but to the greater extent these do not include residential users whose primary means of access is still dial. There are thousands of such ISPs out there, including the largest of them all... AOL, Mindspring, etc. Comments welcome. Regards, Frank Coluccio