The FCC has released a 759-page Report and Order on Intercarrier Compensation and the Universal Service Fund. Much of which is a Further Notice of Proposed Rulemaking, meaning that close to half of the open issues are still not settled, so they're taking comments for maybe the seventh time or so. Overall, the R&O could have been a lot worse. It still reflects no real vision or understanding of the dynamics of either PSTN or Internet, and results in a system so complex that it's best explained by Benoit Mandelbrot's book "The Fractal Geometry of Nature". But I've seen much worse from the FCC in the past. At least they made a an attempt to balance mulitple interests.
But I found at least one "in your face" flagrant error, the kind you make because you want to flex your muscles openly and show you have the power to declare the value of pi to be 3.
The whole "phantom calling" thing requires carriers to populate and pass along Calling Party Number end to end, and to pass along Charge Number when different. Never mind that this is still not feasible with most SIP; that's SIP's fault and ... others have noted it. That's not the issue. And never mind that there are VoIP applications that are one-way without a CPN on the originating end, so the intermediate point (PSTN gateway) *is* the only CPN. They ignore that.
No, the flagrant one is that they are not requiring tandem owners to forward CIC and OCN to the terminating carrier, just CPN and CN. So you can use CPN or CN to determine the nominal rate center of the originator, to determine which rate to apply. But you don't know whom to bill! If it's an IXC call, the CIC identifies the carrier, and terminating carriers bill the IXC, not the originating carrier If it's intraLATA, the OCN identifies the carrier. (Phone number has no more meaning than DNS name; it's just a name, carrier-independent, looked up in the LNP database in order to terminate calls.) But tandem operators don't have to pass them. So terminating carriers have to purchase (yes, of course, there's money here) Daily Usage Files (DUFs) from the tandem owners for after-the-fact batch processing, in order to collect their intercarrier compensation from the right place. This is a big racket for Verizon and I suspect other ILECs.
The FCC's rationale? No legal authority. This is in the middle of an Order filled with broad claims of authority. It's like saying that Jack Johnson couldn't board the Titanic because the ship couldn't hanlde his weight.
No, you don't make up excuses like that unless you're making a VERY LOUD dogwhistle to the big tandem-owning LECs that you're giving them a big gift.
**-- Fred Goldstein k1io fgoldstein "at" ionary.com ionary Consulting ** **** **
Copied from Fred's post to the Cybertelecom-L mailing list, with his permission. I shortened the subject line, and any transcription errors are my fault.
Bill Horne Moderator