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Intercarrier Compensation: A Rural Perspective. 2006 Annual Meeting August 8, 2006. Agenda. Key RLEC Issues for 2006 Universal Service Intercarrier Compensation Reform Overview of the NARUC ICC Task Force Process Review of the “Missoula Plan” Definitions of “Tracks” - PowerPoint PPT Presentation
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1 Intercarrier Compensation: A Rural Perspective 2006 Annual Meeting August 8, 2006
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Page 1: Intercarrier Compensation: A Rural Perspective

1

Intercarrier Compensation:

A Rural Perspective

2006 Annual MeetingAugust 8, 2006

Page 2: Intercarrier Compensation: A Rural Perspective

2

Agenda

1. Key RLEC Issues for 2006a. Universal Serviceb. Intercarrier Compensation Reform

2. Overview of the NARUC ICC Task Force Process

3. Review of the “Missoula Plan”a. Definitions of “Tracks” b. Rate transitions and revenue replacementc. Interconnection rules and compensation obligations

4. Conclusion5. Question and Answer Session

Page 3: Intercarrier Compensation: A Rural Perspective

3

2006 – A Critical Year• 2006 will be a critical year for the RLEC industry• Multiple events with significant impact

– FCC Intercarrier Compensation FNPRM– Post-RTF Universal Service Program– USF Collection Mechanism– 1996 Telecom Act Re-Write – Consolidation of the RBOCs and IXCs– Brand X Ramifications

• Policy ideas with negative implications for RLECs– Bill & Keep– USF mechanisms that are not based on costs– Unregulated IP Interconnection– Giving VoIP and IP-enabled services a free ride

• How much of your cash flow comes from USF and Intercarrier Compensation?– It will all be in play

Page 4: Intercarrier Compensation: A Rural Perspective

4

Rural Realities

• Policy Realities:– 1996 Act: Rural consumers shall have comparable

services and comparable prices to urban areas

• Economic Realities:– It is costly to serve remote, sparsely populated rural

areas– RLECs rely heavily on USF and ICC for cost recovery

Source Rural RBOCEnd User 27% 61%Access Charges 26% 10%USF 30% 0%Other 17% 29%

Source of Revenues

Page 5: Intercarrier Compensation: A Rural Perspective

5

Universal Service Issues

• Growth in the fund• Support for Competitive ETCs

– Reform of USF Distribution Mechanism

• USF Collection Mechanism• Post-RTF funding• Proxy Models• State Block Grants• Legislative Initiatives

Page 6: Intercarrier Compensation: A Rural Perspective

6

Intercarrier Compensation

Page 7: Intercarrier Compensation: A Rural Perspective

7

The Intercarrier Compensation Problem:

• Disparate charging mechanisms based on:– Jurisdiction (intrastate, interstate)– Nature of the call/technology (local, long distance,

Internet)– Type of carrier (LEC, IXC, CMRS, ISP, end-user)

• System is neither economically rational nor sustainable– Disparities leading to arbitrage and/or fraud– Phantom traffic– Inability to differentiate between interstate, intrastate

and local traffic

Page 8: Intercarrier Compensation: A Rural Perspective

8

AV

ER

AG

E R

AT

ES

(C

ents

per

MO

U)

High (¢/min): 1.5 8.9 9.9 34.9 6.8 35.9 0.3 0.1 8.9 0.3Low (¢/min): 0.5 0.3 0.4 0.7 0.2 0.4 0.0 0.0 0.2 0.0

0.0

1.0

2.0

3.0

4.0

5.0

6.0

Large ILECInterstate (0.6)

Small ILEC Interstate (1.8)

Large ILECIntrastate (2.5)

Small ILEC Intrastate ( 5.1)

CLEC Interstate ( 1.8)

CLEC Intrastate (3.0)

CMRS to ILEC (InterMTA 0.6)

CMRS to ILEC (IntraMTA 0.2)

Recip Comp (Voice 0.2)

Recip Comp (ISP 0.1)

LONG DISTANCE CALLS LOCAL CALLS WIRELESS CALLS

Current Intercarrier Compensation Rates

Page 9: Intercarrier Compensation: A Rural Perspective

9

ICC Reform Time Line

2001 2002 2003 2004 2005 2006

April 2001 – 1st FCC NPRM - Two FCC Staff papers promoting Bill & Keep (COBAK, BASICS)

January 2004 – “Group of 8” formed to work with ICF

June 2003 – Intercarrier Compensation Forum (ICF) formed - Goal to move ICC to Bill & Keep

July 2004 – NARUC ICC Task Force formed

Fall of 2004 – - ICF files Bill & Keep reform plan - ARIC and EPG file ICC reform plans

February 2005 -Rural Alliance (RA) Formed

March 2005 – 2nd FCC NPRM - Requests recommendations on ICC reform - RA, ICF and 101 other parties file comments

January 2006 – NARUC forms “Group of 11” to negotiate consensus ICC solution

March 7, 2006 – Compromise solution framework presented to NARUC

April 21, 2006 – Parties must indicate support for forwarding framework to the FCC

July 2006 – Missoula Plan sent to NARUC, NARUC files with FCC, FCC requests comments on Plan

Page 10: Intercarrier Compensation: A Rural Perspective

10

The Rural Alliance• Formed in February of 2005 to present a unified voice for

the RLEC industry on ICC reform• Over 350 RLECs, consultants, state and national RLEC

associations have supported the RA’s advocacy• Rural Alliance Steering Committee

– Six Members representing different RLEC market segments• Tom Conry, Farmers Mutual Cooperative Telephone

Company (IA)• Bob DeBroux, TDS Telecom (WI)• Wendy Fast, Consolidated Telephone Co. (NE)• Pat Morse, FairPoint Communications (KS)• Ken Pfister, Great Plains (NE)• Jack Rhyner, TelAlaska (AK)

– Four Advisory Members• National RLEC Associations (ITTA, NTCA, OPASTCO, WTA)

– Other Advisors• CHR Solutions, Fred Williamson & Assoc., GVNW, JSI,

McLean & Brown, NECA, Parrino Strategic Consulting, TELEC Consulting Resources

Page 11: Intercarrier Compensation: A Rural Perspective

11

NARUC ICC Task Force• The Task Force conducted twelve workshops between 7/04 and

1/06– Second meeting in Missoula, MT (thus the “Missoula Plan”)

• Most industry segments participated• Two Major Advocacy groups emerged

– Intercarrier Compensation Forum (AT&T, et. al.) and Rural Alliance (RA)

• In January of 2006, NARUC created two smaller groups to attempt to develop consensus plans– A “Group of 11” formed to create an overall solution framework

including three “Tracks” (Paul Cooper and Bob DeBroux represent RA)– An Interconnection Group to work out interconnection and transport

obligation details (Ken Pfister and Charlie Cooper represent RA)• On April 21, 2006 a sufficient number of Task Force participants

indicated support for moving the plan forward to the FCC• On July 24, 2006 NARUC forwarded the Plan to the FCC• On July 25, 2006 FCC requested comments on the Missoula Plan

Page 12: Intercarrier Compensation: A Rural Perspective

12

Why Was RA Involved?

– The ICF plan would have had a devastating impact on rural carriers and their customers

• Elimination of originating compensation• Mandatory Bill & Keep• Increased transport compensation obligations for RLECs

– NARUC created, and the FCC is supporting, a collaborative forum to develop workable solutions to ICC problems

– The RA became an essential player in the process and has made great progress in promoting RLEC issues

– We have achieved significant improvements over the ICF plan

– FCC Chairman Martin has indicated that he understands RLEC issues, but won’t give us all we might ask for

Page 13: Intercarrier Compensation: A Rural Perspective

13

What Were RA’s Key Objectives?

1. A “Multi-Track” Approach that recognizes RLEC differences

2. Cost-based ICC rates3. A sustainable and non-portable Intercarrier

Compensation Restructure Mechanism (RM) 4. Reasonable Interconnection Rules that limit

RLEC obligations to carry traffic beyond their networks

Page 14: Intercarrier Compensation: A Rural Perspective

14

What is the Missoula Plan?• A comprehensive multi-year plan for intercarrier compensation

reform• Establishes categories of carriers and three separate carrier Tracks• Transitions down to new intercarrier compensation rates within

each Track• Provides for revenue recovery associated with rate reductions

– Federal SLC cap increases– ‘Lifeline’ customers are exempt from SLC increases– Establishes a new Restructure Mechanism

• Establishes default rules for interconnection• Establishes “Early Adopter Fund”• Creates an incentive regulation option for qualifying rural ILECs• Provides interim and long-term solution to intercarrier

compensation related disputes within the industry- Phantom Traffic - Jurisdiction - Intra MTA Wireless Traffic - Virtual Foreign Exchange

Traffic- IP-PSTN

Page 15: Intercarrier Compensation: A Rural Perspective

15

Who Supports the Missoula Plan?

• AT&T• BellSouth• Cingular Wireless• Commonwealth Telephone Company• Consolidated Communications• Epic Touch • Global Crossing• Iowa Telecom• Level 3 Communications• Madison River Communications• Rural Alliance

Page 16: Intercarrier Compensation: A Rural Perspective

16

What happens next?

– The FCC has now put the plan out for public comment

– We know that several industry segments will oppose the Plan

• CTIA• Consumer Groups• Others?

– The Rural Alliance is developing an advocacy plan to leverage the strength of the RLEC industry

• State associations will play a key role• As much advocacy as possible will be done as the

“Missoula Group”

Page 17: Intercarrier Compensation: A Rural Perspective

17

Definition of the Tracks• Track 1

– All study areas affiliated with an RBOC– Price Cap non-rural, and RoR rural study areas not part of a CRTC*

– Price Cap rural study areas > 1 million loops– 92 Study Areas with 146.2 million loops

• Track 2– Price cap rural study areas < 1 million loops– Price cap non-rural study areas of CRTCs– RoR non-rural study areas not affiliated with an RBOC– RoR rural study areas > 10K loops that are part of a Holding Company

that also has Price Cap or non-rural study areas– 158 Study Areas with 12.5 million loops

• Track 3– RoR rural study areas < 10K loops that are part of a Holding Company

that also has Price Cap or non-rural study areas– All other RoR rural study areas– 1,185 Study Areas with 7.3 million loops

* Covered Rural Telephone Company – Generally similar to a “Rural” company or a “2% company” under the 1996 Act

Page 18: Intercarrier Compensation: A Rural Perspective

18

Rates

• Track 1: RBOCs & Large Price Cap– Uniform Structure and Uniform Rates– Low per minute termination rates ($0.0005 to $0.0007)

• Track 2: Mid-Size– Mid-size Price Cap– Target rate is +/- $0.01 (transport and termination)– Optional Incentive Regulation

• Track 3: Rural Rate-of Return (RoR)– Unified Interstate and State Access @ Interstate (≈

$0.018)– Rates vary by company with optional pooling and rate

banding

Page 19: Intercarrier Compensation: A Rural Perspective

19

Unifying Intercarrier Compensation Rates

Step 4: Intrastate access charges unify at interstate access rate levels.

Originating AccessTerminating AccessReciprocal Compensation

Step 4: Intrastate access charges unify at interstate access rate levels.

Step 1: Transport and Termination rates capped at interstate access levels. Existing EAS arrangements with other ILECs continue unchanged.

Track 3

Step 4: Charges unify as follows: $0.002 for end office switching and $0.0105 for

tandem switched transport in ROR study areas; $0.002 for end office switching and $0.0075 for

tandem switched transport in price cap or incentive regulation study areas;

Interstate direct trunk transport rate levels for dedicated switched transport.

Or, carriers may eliminate originating access.

Step 3: Termination charges for all traffic unify at $0.0005.Transport charges for tandem switched transport unify at: $0.0105 for ROR study areas; $0.0075 or $0.0097 (when originating is eliminated) for price

cap or incentive regulation study areas; Interstate direct trunk transport rate levels for dedicated

transport.

Track 2

Step 4: Charges unify as follows: $0.002 for end office switching; $0.0025 for tandem switched transport; Interstate direct trunk transport rate levels for

dedicated transport.Or, carriers may eliminate originating access.

Step 3: Termination charges for all traffic unify at $0.0007.Transport charges for dedicated transport unify at interstate direct trunk transport rate levels.

Step 4: Termination charge decreases to $0.0005.

Track 1

Origination ChargesTermination Charges

Step 4: Intrastate access charges unify at interstate access rate levels.

Originating AccessTerminating AccessReciprocal Compensation

Step 4: Intrastate access charges unify at interstate access rate levels.

Step 1: Transport and Termination rates capped at interstate access levels. Existing EAS arrangements with other ILECs continue unchanged.

Track 3

Step 4: Charges unify as follows: $0.002 for end office switching and $0.0105 for

tandem switched transport in ROR study areas; $0.002 for end office switching and $0.0075 for

tandem switched transport in price cap or incentive regulation study areas;

Interstate direct trunk transport rate levels for dedicated switched transport.

Or, carriers may eliminate originating access.

Step 3: Termination charges for all traffic unify at $0.0005.Transport charges for tandem switched transport unify at: $0.0105 for ROR study areas; $0.0075 or $0.0097 (when originating is eliminated) for price

cap or incentive regulation study areas; Interstate direct trunk transport rate levels for dedicated

transport.

Track 2

Step 4: Charges unify as follows: $0.002 for end office switching; $0.0025 for tandem switched transport; Interstate direct trunk transport rate levels for

dedicated transport.Or, carriers may eliminate originating access.

Step 3: Termination charges for all traffic unify at $0.0007.Transport charges for dedicated transport unify at interstate direct trunk transport rate levels.

Step 4: Termination charge decreases to $0.0005.

Track 1

Origination ChargesTermination Charges

Page 20: Intercarrier Compensation: A Rural Perspective

20

AV

ER

AG

E R

AT

ES

(C

ents

per

MO

U)

High (¢/min): 1.5 8.9 9.9 34.9 6.8 35.9 0.3 0.1 8.9 0.3Low (¢/min): 0.5 0.3 0.4 0.7 0.2 0.4 0.0 0.0 0.2 0.0

0.0

1.0

2.0

3.0

4.0

5.0

6.0

Large ILECInterstate (0.6)

Small ILEC Interstate (1.8)

Large ILECIntrastate (2.5)

Small ILEC Intrastate ( 5.1)

CLEC Interstate ( 1.8)

CLEC Intrastate (3.0)

CMRS to ILEC (InterMTA 0.6)

CMRS to ILEC (IntraMTA 0.2)

Recip Comp (Voice 0.2)

Recip Comp (ISP 0.1)

LONG DISTANCE CALLS LOCAL CALLS WIRELESS CALLS

Current Intercarrier Compensation Rates

Page 21: Intercarrier Compensation: A Rural Perspective

21

ICC Rates After ReformA

VE

RA

GE

RA

TE

S (

Cen

ts p

er M

OU

)

* Compensation for EAS traffic remains under existing arrangements

** Compensation for IntraMTA traffic @ local rates & compensation for InterMTA traffic @ interstate access rates

Track 1 ILECs (0.0023) Track 2 ILECs (0.0080) Track 3 ILECs (0.0171)

0.0000

0.0100

0.0200

0.0300

0.0400

0.0500

0.0600

LD Interstate

Local

Wireless

LD Intrastate

LD Intrastate

LDIntrastate

LD Interstate Local

Wireless

LDInterstate

Local *

Wireless **

Page 22: Intercarrier Compensation: A Rural Perspective

22

SLC Increases

• Track 1– Residential SLC Caps increase $3.50 over 4 years– Average residential SLC may increase by no more than

$0.75 in steps 1 and 2, and $1.00 in steps 3 and 4– No residential SLC may increase by more than $0.95 in

steps 1 and 2, and $1.20 in steps 3 and 4

• Track 2– Residential SLC Caps increase $2.25 over 3 years– MLB SLC Cap increase to $10.00

• Track 3– Residential SLC Caps increase $2.25 over 3 years– No MLB increase

Page 23: Intercarrier Compensation: A Rural Perspective

23

Restructure Mechanism

• To the extent revenues associated with rate reductions are not recovered through restructured intercarrier charges or increases to the SLC, the Plan permits additional recovery through a new Restructure Mechanism (RM).

• The RM will be available to non-ILEC competitive carriers. (The precise formulas for determination of RM amounts for competitive carriers has yet to be finalized.)

• “Early Adopter Fund” of at least $200M or percentage of state recovery mechanism as determined by the Commission is created for states that have previously or established state recovery mechanisms to reduce intrastate access rates. State Commissions insure RM is utilized for appropriate purposes

Page 24: Intercarrier Compensation: A Rural Perspective

24

Estimated Restructure Mechanism Size

Restructure Mechanism.…………… $ 1,500M

Universal Service Mechanisms

High Cost Fund Modifications…… $ 300M

Lifeline Support……………………… $ 225M

Early Adopter Fund .....……….……….. $ 200M

Total……………………………………… $ 2,225M

Page 25: Intercarrier Compensation: A Rural Perspective

25

Track 3: RM Calculation

Base Year Intrastate Switched Access Revenue

Base Year Reciprocal Compensation (Net)

Current Year Interstate Switched Access Revenue Requirement

Current Year Traffic Sensitive SLC Revenue

Current Year Intrastate & Interstate Switched Access and Recip. Comp. Revenues, net of Payments to Other Carriers for Recip. Comp. and Transiting/Transport

Current Year LSS Revenue

LESS

Page 26: Intercarrier Compensation: A Rural Perspective

26

Summary

$2,225 Sub-Total : RM Plus Additional Items*

$300 High Cost Fund/USF Mechanism Adjustments

$225 Lifeline Increases

$200 Early Adopter Fund

Additional Items: Transition

$1,500 Restructure Mechanism

3. Transition: Restructure Mechanisms ($ Millions)

$ 2.25 $ 2.25 $ 3.50 Interstate SLC Cap Increases

2. Transition: Rebalanced Enduser Rates ($/ Month/ Line)

$ 0.0171 $ 0.0095 $ 0.0045 Origination Rates

$ 0.0171 $ 0.0080 $ 0.0005 Termination Rates

1. Transition: Target Intercarrier Rates ($/Access Minute)

TRACK 3TRACK 2TRACK 1

$2,225 Sub-Total : RM Plus Additional Items*

$300 High Cost Fund/USF Mechanism Adjustments

$225 Lifeline Increases

$200 Early Adopter Fund

Additional Items: Transition

$1,500 Restructure Mechanism

3. Transition: Restructure Mechanisms ($ Millions)

$ 2.25 $ 2.25 $ 3.50 Interstate SLC Cap Increases

2. Transition: Rebalanced Enduser Rates ($/ Month/ Line)

$ 0.0171 $ 0.0095 $ 0.0045 Origination Rates

$ 0.0171 $ 0.0080 $ 0.0005 Termination Rates

1. Transition: Target Intercarrier Rates ($/Access Minute)

TRACK 3TRACK 2TRACK 1

* Illustratively, if covered on telephone numbers and connections basis, then it would be a charge of $0.30 per unit per month

Page 27: Intercarrier Compensation: A Rural Perspective

27

• The interconnection obligations and intercarrier compensation framework of the Missoula Plan operate on an Edge architecture An Edge is a location on a carrier’s network where it receives

traffic to perform the termination function.• General interconnection obligation: A carrier must permit

other carriers with the financial obligation for interconnection to physically interconnect, directly or through a transit carrier, at its Edge

• The Plan specifies duties interconnecting carriers must satisfy to obtain interconnection

• The Plan establishes rules for procurement and provision of Tandem Transit Service Carrier with the financial obligation for transport chooses the

transit carrier. Indirectly interconnected carriers and the Tandem Transit

Provider must exchange call detail records at no additional charge.

Interconnection Framework

Page 28: Intercarrier Compensation: A Rural Perspective

28

Intercarrier Compensation Framework

• Each carrier has a financial obligation to transport its originating non-access traffic to the terminating carrier’s Edge Transport is the transmission facilities a carrier requires

to physically connect its network with the terminating carrier’s edge.

Transport exceptions exist for out of balance traffic. Interconnection between Track 1 carriers and CRTCs is

governed by a specific transport framework.• Each carrier has a financial obligation for the

termination of its traffic by the terminating carrier Termination is the acceptance of traffic by a terminating

carrier at its Edge and the delivery of the traffic to the called party.

Termination charges cover any transport and end office switching a terminating carrier uses to deliver traffic from its Edge to the called party.

Page 29: Intercarrier Compensation: A Rural Perspective

29

TerminatingEnd User

LEC BE.O.

OriginatingEnd User

LEC AE.O.

Transport and Termination of Non-Access Traffic

EDGE

Transport Termination

• When a carrier uses the terminating carrier’s network to fulfill its obligation to transport non-access traffic, transport and termination charges will apply.• Termination is the acceptance of traffic at its designated Edge for delivery to the called party.

General Intercarrier Compensation Framework

Access Traffic Remains as it is Today

Page 30: Intercarrier Compensation: A Rural Perspective

30

TerminatingEnd User

LEC BE.O.

OriginatingEnd User

LEC AE.O.

Indirect Interconnection

A carrier may fulfill its duty to transport non-access traffic via direct or indirect interconnection.

EDGE

TRANSITTANDEM

LEC A’s financial duty to transport trafficCarrier that pays chooses interconnection method

Direct Interconnection

General Interconnection Framework

Page 31: Intercarrier Compensation: A Rural Perspective

31

Rural Transport Obligation

The Plan provides Track 2 and 3 ILECs an exception from the general duty to transport non-access traffic originating on its network to the terminating carrier’s Edge. This is referred to as the “Rural Transport Rule.”

OriginatingEnd User

CRTCE.O.

Meet PointNon-

CRTCE.O.

EDGE

Rural Transport RuleShifts some or all of the transport cost between the meet point and the

non-CRTC’s edge to the terminating carrier.

TerminatingEnd User

CRTC Interconnection Framework

Page 32: Intercarrier Compensation: A Rural Perspective

32

Rural Transport Rule for CRTCs

Tandem InterconnectionThe non-CRTC bears all of the transport cost

Direct Interconnection

Track 3 ILECs will pay the non-CRTC 50% of the dedicated transport, not to exceed 10 miles.

The non-CRTC will bear the balance of the cost.

CRTC Interconnection Framework

OriginatingEnd User

CRTCE.O.

Meet PointNon-

CRTCE.O.

TerminatingEnd UserEDGE

Page 33: Intercarrier Compensation: A Rural Perspective

33

Intercarrier Compensation Framework• As a general rule, calling and called telephone numbers will be

used to determine when traffic should be subject to switched access charges or reciprocal compensation charges Resolves wireless intraMTA intercarrier compensation disputes. Helps to resolve virtual FX and VoIP-to-PSTN intercarrier

compensation disputes.• The Plan provides a mechanism governing how all carriers may

obtain both interim and formal interconnection agreements – and companion reciprocal compensation arrangements – for the exchange of non-access traffic An interim interconnection arrangement with the originating carrier

by sending a notification letter to the originating carrier Both carriers to begin billing one another their applicable interim

reciprocal compensation charges (i.e., interstate access rates) beginning 15 days after the date of the notification letter

Any carrier may request a formal agreement by invoking the negotiation and arbitration procedures set forth in Section 252 of the Act

Page 34: Intercarrier Compensation: A Rural Perspective

34

Comprehensive Solution for Phantom Traffic

• Establishes call signaling rules that apply to all communications service providers and traffic identification obligations to help expeditiously resolve disputes With certain exceptions, every originating communications service

provider must transmit telephone number of the calling party to intermediate and terminating carriers.

With certain exceptions, every intermediate communications service provider must transmit without alteration the telephone number information it receives from another provider.

When a provider’s switch is equipped with SS7, it shall utilize SS7 when interconnecting directly with another provider’s switch that is equipped with SS7.

• Proposes an industry-driven uniform framework for the generation and exchange of call detail records

• Implements rules to govern procurement and provision of Tandem Transit Service

• Recommends an interim order, pending adoption of comprehensive intercarrier compensation reform, that will: Implement the call signaling rules. Establish an interim process and, in certain circumstances, charges for

the creation and exchange of call detail information.

Page 35: Intercarrier Compensation: A Rural Perspective

35

Other Features of the Missoula Plan

• Creates a federal Early Adopter Fund for States that have rebalanced intrastate access through explicit state funds Minimum of $200M provided for the Early Adopter Fund. Missoula Plan supporters commit resources to work with State Commissioners

to help size this Fund and determine how it should work when States have rebalanced intrastate access through state funds or local rate increases.

• Provides additional universal service support Provides approximately $300M for several rural and non-rural high cost loop

fund modifications. Provides approximately $225M in additional Lifeline support to insulate low

income consumers from SLC increases. • ROR CRTCs will have an annual option to move to an incentive regulation

program on a study area-by-study area basis Study areas for which incentive regulation is chosen will be treated as Track 2. Existing ROR rules for switched services will be replaced by rules that regulate

prices. Interstate special access prices will be reinitialized to 11.25% ROR and subject

to a price cap plan.

Page 36: Intercarrier Compensation: A Rural Perspective

36

How does the plan deal with VNXX?

• Does not constrain the association of rate centers and telephone numbers

• Does limit exposure by:– Constraining the traffic classified as local by employing

the telephone numbers principle– Reassigning the financial obligation for transport to the

terminating non-CRTC

Page 37: Intercarrier Compensation: A Rural Perspective

37

What does proposal mean for traffic terminating from ISP to

PSTN?

• Telephone numbers rule defines classification • Calling and called numbers for the purpose of

applying the telephone numbers rule cannot be intermediate numbers

• Phantom traffic issues must be resolved to solve problems

Page 38: Intercarrier Compensation: A Rural Perspective

38

What did we Get and What did we have to Give

Up? The Consensus • The consensus process requires give and take and no party

walked away with everything they wanted• So what did we get?

– Cost based intercarrier compensation charges rather than bill and keep

– Originating access charges– Smaller SLC increases than the large companies – Financial transport responsibility limited to exchange boundaries– Clarity regarding interconnection responsibility – Solution to the phantom traffic problems– Make whole for lost revenues in the Restructure Mechanism– Other items

• And what did we have to give up and why?– Local rate benchmarking – difficulty in getting local rate increases– 10 miles – to make it more attractive for wireless to sign on– Other issues…

• Although rural companies had to compromise on some issues we were able to obtain our key objectives

Page 39: Intercarrier Compensation: A Rural Perspective

39

Next Steps

• The FCC has now put the Missoula Plan out for public comment– Comments September 25– Replies November 9

• The framework will come under attack on multiple fronts– Wireless Carriers – still want bill and keep– Consumer Groups – SLC increases– Verizon and Qwest have not signed on– Others - ???

• The Rural Alliance will need to fight to retain the important items we won during the NARUC process

Page 40: Intercarrier Compensation: A Rural Perspective

40

Join the Rural Alliance!!

• We are at the beginning of a long fight for our financial future

• We have demonstrated what we can do when we plan and act as a united rural industry

• To be successful we will need to engage the best legal and regulatory talent in our industry

• Over 350 RLECs participated in our advocacy efforts• We need to get everyone on board now!

– Suggested Contribution:• 0 – 499 Access Lines $500• 500 – 999 Access Lines $1,000• 1,000 – 9,999 Access Lines $2,000• Over 10,000 Access Lines $3,000

Page 41: Intercarrier Compensation: A Rural Perspective

41

In Summary

• The RLEC industry has made great progress over the past 18 months through the Rural Alliance and the NARUC process

• The proposed framework offers significant benefits:– Cost-based originating and terminating rates– A non-portable RM to assure revenue stability– Interconnection rules and compensation obligations

that limit RLEC transport obligations– Stability and certainty going forward

• The RLEC industry is united as never before to fight for the fair intercarrier compensation reform that our customers need and deserve

Page 42: Intercarrier Compensation: A Rural Perspective

42

For more information on the Rural Alliance please visit our

web site at www.rural-alliance.org

Page 43: Intercarrier Compensation: A Rural Perspective

43

Growth in the USF

$0

$1,000

$2,000

$3,000

$4,000

$5,000

$6,000

$7,000

$8,000

1986

1987

1988

1999

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

An

nu

al S

up

po

rt $

M

Page 44: Intercarrier Compensation: A Rural Perspective

44

$0

$1,000

$2,000

$3,000

$4,000

$5,000

$6,000

$7,000

$8,000

1998 1999 2000 2001 2002 2003 2004 2005 2006

An

nu

al S

up

po

rt $

M

Competitive ETC

Access Reform

Rural Health Care

Schools & Libraries

Low Income

ILEC High Cost

Sources of Growth

Note: LTS included in ILEC High Cost 3Q04 – 4Q06

Page 45: Intercarrier Compensation: A Rural Perspective

45

$0

$200

$400

$600

$800

$1,000

$1,200

4Q01

1Q02

2Q02

3Q02

4Q02

1Q03

2Q03

3Q03

4Q03

1Q04

2Q04

3Q04

4Q04

1Q05

2Q05

3Q05

4Q05

1Q06

2Q06

An

nu

aliz

ed F

un

din

g (

$M

illi

on

s)

Pending

Approved

CETC Support

Page 46: Intercarrier Compensation: A Rural Perspective

46

USF Collection Mechanism

0%

2%

4%

6%

8%

10%

12%

2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 1 2 3 4 1 2

2000 2001 2002 2003 2004 2005 2006

Co

ntr

ibu

tio

n F

acto

r

$0

$5

$10

$15

$20

$25

Fu

nd

ing

Bas

e $B


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