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Nationwide Competitive
Local Exchange Carrier


KFR Updates

January 2015

FCC Moves Forward on Reporting Requirements of Rural Call Completion Order   

More than a year after the release of the FCC's Rural Call Completion order, the reporting rules have taken a big step toward implementation.  On November 4, 2014, the Commission adopted an Order on Reconsideration that grants only one petitioner's request.

The Commission granted the petition filed by USTelecom and ITTA, and therefore modified the rules adopted in the order so that the record keeping, retention, and reporting requirements do not apply to intraLATA calls that are handed off by the covered provider directly to the terminating local exchange carrier or to the tandem that the terminating LEC's end office subtends.

As you may recall, the order requires providers of long-distance service that make the initial long-distance call path choice for more than 100,000 domestic retail subscriber lines to record and retain specific information about each call attempt to a rural operation company.  The information for the previous six calendar months must be readily retrievable, and providers covered by the order must submit a report to the Commission quarterly that provides data on call attempts by month.
FCC Chairman Tom Wheeler said the rules on data collection "allow both the Commission and service providers to pinpoint areas where call completion rates are unacceptably low," although many service providers disagree, arguing that the rules are burdensome and that the data collected will be of little value in solving the problem of poor service to rural communities.

The next step toward implementation is for the federal Office of Management and Budget, which must review the rules to ensure they are not overly burdensome per the Paperwork Reduction Act process, to approve the rules, at which time they will be published, with an effective date, in the Federal Register.

As announced when the order was first released in late 2013, KFR stands ready to help you implement these reporting rules. Please contact Kim Russo at krusso@kfrservices.com or 843.879.5030 for assistance.

For previous coverage of this issue in our newsletter, please see our October 2014, April 2014, and January 2014 issues.


IXCs, LECs Battle on Access Charges for IntraMTA Calls

Industry associations representing local exchange carriers met with the FCC's Wireline Competition Bureau on December 17, 2014, to discuss disputes arising between LECs and Interexchange Carriers (IXCs) over intraMTA wireless traffic. 

The disputes stem from the IXCs recent interpretation of the nearly 20-year-old "intraMTA Rule".  The IntraMTA Rule makes calls exchanged between local exchange carriers and wireless carriers, that originated and terminating the same MTA, subject to reciprocal compensation.  Citing a section of the 2011 Intercarrier Compensation Reform ruling which states "...all traffic routed to or from a CMRS provider that, at the beginning of a call, originates and terminates within the same MTA, is subject to reciprocal compensation, without exception," the IXCs claim they should not have to pay access charges on intraMTA traffic delivered  to LECs on behalf of wireless carriers.  They are not only disputing current bills, but are requesting refunds of ten of millions of dollars in access charge payments made in the nearly 20 years since the intraMTA rule took effect, arguing that the rule has been wrongly interpreted from the start. In fact, Sprint had filed at least 34 lawsuits against 360 LEC defendants, and Verizon has filed at least 33 lawsuits against 514 LEC defendants. 

A group of LECs petitioned the FCC for a declaratory ruling in November 2014, asking the Commission to confirm that the intraMTA rule does not apply to LEC charges billed to an IXC when the IXC terminates traffic to or receives traffic from a LEC via switched access services.

In the petition, the LECs point to the IXCs' 18 years of voluntary payment of switch access charges for these services as evidence that they are required to pay the fees.  Further, the LECs say they had no way of knowing that the traffic being handed off by the IXCs had been originated by a wireless carrier. 

The IXCs, conversely, argue that the Commission has already decided that intraMTA calls are subject to reciprocal compensation in all cases.

Absent action by the FCC, the many lawsuits filed on this issue will continue to work their way through the court system, causing what the LECs say are substantial costs, unanticipated risks, and a threat to their near-term investment plans.

KFR Releases Remote Call Forwarding Rate Data 

KFR has completed development of a database Remote Call Forwarding rates for major incumbent local exchange carriers in each state. 

The data is available as a one-time delivery, or with quarterly updates.

The Remote Call Forwarding rates were added to our existing Call Features rate database, which is primarily used by non facilities-based local service providers to verify rates from the underlying local exchange carrier and to bill their subscribers more accurately.

For more details, contact Kim Russo via email or call her at 843.879.5030.

Q1 Contribution Factor 

The proposed Universal Service Fund contribution factor for the first quarter of 2015 is 16.8%, up from 16.1% the previous quarter.

KFR News