Reactions to the submission of the ABC Plan and the announcement of the unprecedented joint framework for reform have been overwhelmingly positive. I think it’s fair to say that virtually everyone agrees with the premises that we must transform universal service into a program focused on broadband, not POTS (plain old telephone service), and we must, at the same time, reform intercarrier compensation in a measured way that addresses arbitrage and reduces reliance on implicit subsidies. The ABC Plan accomplishes both objectives.
Nonetheless, some parties have raised concerns about certain components of the plan. One issue that has drawn some criticism is the plan’s proposal for the treatment of traffic exchanged between telecom carriers that originates and/or terminates with a VoIP user. – The plan proposes that such traffic be treated like other traffic exchanged between telecom carriers, except that intrastate access charges would not be applied.
According to a joint filing by the Ad Hoc Telecommunications Users Committee, Google, Skype, Sprint, and Vonage this proposal would result in the “extension of the antiquated carrier access regime to VoIP applications.” Unfortunately, this is not exactly accurate. The fact is that these “antiquated” charges have long been routinely assessed on VoIP calls and not just by incumbent LECs. Indeed, VoIP providers as well as the LECs they employ have moved aggressively to assess access charges on VoIP calls. Just last year AT&T was forced to bring a formal complaint against a VoIP provider that tried to argue that the entire Internet was a virtual loop over which it provided switched access service. While the FCC saw through this bogus argument, many VoIP providers and/or the LECs they employ (including some of the parties to the joint filing) continue to assess access charges on VoIP calls.
In my opinion, from a VoIP perspective the most important objective should be to ensure that calls are treated symmetrically. That is, that the same intercarrier compensation rules apply regardless of whether a call originates with a VoIP user or terminates with a VoIP user. This is exactly what the ABC plan proposes. NCTA, which represents the largest VoIP providers in the country, filed a letter with the FCC in which it makes precisely this point. I have to say that, in this case at least, NCTA is actually the voice of reason.
Hank Hultquist is AT&T’s Vice President of Federal Regulatory
