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FCC Finally Gets the Message about Rural Call Termination Problems  

After Months of Pleading by Rural Industry, FCC Announces Workshop and Task Force

On September 26, 2011, the FCC announced plans to hold a workshop on October 18 and launch a Rural Call Completion Task Force “to investigate and address the spreading problem of calls to rural areas that are being delayed or fail to connect.” The FCC’s announcement comes after months of letters, filings, and state efforts to catch the FCC’s attention on this growing problem. NTCA, OPASTCO, WTA and NECA have all been persistent about informing the FCC of call termination problems, and it looks like the FCC has finally gotten the message loud and clear—unlike many rural consumers who are not getting their calls and faxes.

In the September 26 press release, the FCC acknowledged that there has been a reported 2000% increase in call termination complaints between April 2010 and March 2011, and “Failed or degraded calls not only undermine the integrity of the nation’s telephone networks and frustrate customers, but they also pose a serious risk to public safety and harm the rural economy.”

A September 20 “Request for Public Workshop and Policy Statement on Call Routing and Termination Problems in Rural America” by NTCA ceo Shirley Bloomfield may have been the kick that the FCC needed. Bloomfield’s letter to FCC Chairman Julius Genachowski urges the FCC to “issue a clear and unequivocal policy statement” and conduct a public workshop. Bloomfield argues, “Consumers in rural communities deserve at least the same level of network reliability as urban consumers, and failures to deliver calls to rural America are just as worthy of examination in a public forum.” Bloomfield is referring to a recent FCC workshop on network reliability which resulted from network reliability issues being thrust in the spotlight after the recent East Coast earthquake and Hurricane Irene.

Bloomfield also explained that RLECs cannot handle the myriad call termination problems alone, and “Consideration and resolution of these issues can no longer be left to linger in endless debate, or in one-on-one operational discussions, or in behind the scenes industry workgroups, or in sporadic policy deliberations in small conference rooms” because these issues create “substantial risk for public tragedy and financial distress.”

In preparation for the October 18 Workshop, I thought it would be interesting to research recent association, carrier and state efforts to battle this pervasive, nationwide problem. I turned up a considerable amount of interesting information, summarized in the following timeline:

March 11, 2011 Rural Representatives meet with FCC: In this ex parte meeting, the Rural Representatives presented an overview of the rapidly increasing call termination problems experienced in a variety of states. 80% of respondents to an NTCA survey reported experiencing call termination problems. The Rural Representatives described the consequences of call termination problems for RLECs, businesses, consumers and public safety. Apparently, one business “invoiced its rural LEC for more than $50,000, citing lost sales from potential customers” when customers were repeatedly unable to reach the business by telephone.

April 4, 2011- Letter to Genachowski from Representative Robert Latta (R-OH): Rep. Latta explained that he represents the largest agricultural district in Ohio, which is served by 18 RLECs. Latta writes, “I am asking that you investigate the problem of incoming calls being terminated in rural areas and if unjust and unreasonable discrimination is occurring, if there is a violation of common carrier requirements, or if calls are being blocked.” Latta expresses concern that blocked or incomplete calls result in missed opportunities for small businesses. On August 2, FCC Chairman Genachowski responded saying that the FCC needs specific information, and “it is not clear if these calls are being dropped intentionally, or if there is a technical issue that prevents their completion.”

June 13, 2011- Rural Representatives send letter to FCC: This letter described in detail the call termination problems experienced by rural consumers, and hinted that magicJack and other Least Cost Routing (LCR) carriers may be at fault for some of the problems. The Rural Representatives described how difficult it is to identify the source of call termination problems, and that RLECs are often blamed even if they are not at fault (The ILEC Advisor: RLECs to FCC: Please Investigate Call Termination Problems, June 20, 2011).  

June 24, 2011- Oregon Public Utilities Commission Call Termination Workshop: This workshop included presentations by the Oregon Telephone Association RLEC members. Canby Telephone vp of network operations Brandon Zupancic presented a very interesting analysis of least cost routing. He argued, “Least cost routing, if implemented right, would benefit everyone. However, there are many unintended consequences of LCR!” Zupancic explains, “Some originating carriers route calls to LCR providers and those contracts stipulate that they will not complete calls to certain NPA-NXXs (due to costs to terminate in those areas)—but the originating carrier may not know that and keeps sending calls to that LCR provider destined for that terminating location.”

Zupancic also explains that rural customers and businesses are seeing significant problems with receiving faxes; and Canby has tested lines, tested inside wiring, verified filters, sent faxes to the afflicted customers from local lines, and even replaced customer fax machines with the company’s own devices only to see continued delivery failure. According to Zupancic, VoIP compression “creates excessive packet loss that fax machines cannot correct, so fax transmissions consistently fail at a high rate whenever they originate, transit, or terminate a VoIP/SIP network.”  To learn more about LCR, Zupancic's presentation is definitely worth a read (available here). The Oregon Public Utilities Commission announced a formal investigation into call termination problems on July 5, 2011. 

July 21, 2011- New Mexico Exchange Carriers Group presentation to NM Science Technology & Telecommunications Committee: Jeremy Graves, coo of Valley Telephone Cooperative, presented information about LCR and rural call termination problems in response to a request from the NM Science Technology & Telecommunications Committee. He stressed that RLECs cannot help customers resolve many of these problems, and the livelihood of rural residents and businesses is at stake. He explains that businesses, “in most cases, are solely dependent on their ability to receive calls. Calls to these businesses, when not completed, give the impression that they are closed and revenue is lost.” Graves presented the following chart which illustrates the nature of LCR:

September 7, 2011- Montana Telecommunications Association letter to FCC: MTA general manager Geoffrey Feiss writes, “It seems to me that a virus that has been afflicting telecommunications traffic nationwide for more than a year, which the FCC has been made aware of repeatedly, warrants at least as much attention as the also-important issue of intermittent loss of signal during natural disasters,” also referring to the recent East Coast earthquake and hurricane. Feiss includes letters from customers that highlight increasing problems in call quality, missed business opportunities, and concern about family members who cannot be reached by telephone.

September 20, 2011- Oklahoma Corporation Commission, “Making a Connection:” OCC announced that it sent a letter to the FCC supporting a July 20 National Association of Regulatory Utility Commissioners (NARUC) resolution to investigate call termination problems. NARUC determined that call termination problems “create negative public interest,” and “are antithetical to the public interest by creating confusion, isolation and frustration on the part of called parties and calling parties.” OCC is also conducting an inquiry.

These examples clearly illustrate that call termination problems are serious, substantial, and persistent. They are not a result of a technological defect in the RLECs’ networks, they are a result of regulatory loopholes and access charge avoidance schemes. Even though the FCC intends to reform the Intercarrier Compensation system soon, RLECs cannot afford any more delay on resolving call termination problems.

The failure to complete calls to rural customers on such a large scale weakens America’s entire telecommunications industry and creates inexcusable public safety risks in addition to lost business opportunities. The problems prevent family and friends from communicating with each other, and reflect poorly on an RLEC’s reputation. It is not only difficult for RLECs to troubleshoot these problems, but it is difficult to even explain to consumers what is happening when they cannot be reached by telephone or fax. How many everyday consumers would actually assume that a call isn’t completed because of least cost routing, much less understand it? More importantly, how many failed calls are not reported every day?

I, for one, am happy that the “call” to the FCC to address these problems went through. What do you think is the best course of resolution for rural call termination problems? Is ICC reform the solution, or should the FCC do more?

Reader Comments (1)

I have been having these problems on a regular basis. Bell Canada is supposedly a well reputable company, but due to their cost saving measures, they have leased long distance lines that do not complete calls in the U.S. on a regular basis. I hope this addresses these issues once and for all and uncompleted calls will be a thing of the past.

September 30, 2011 | Unregistered CommenterJoshua Bulk

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