The issue of carrier interconnection rules related to managed IP networks for VoIP seems to be heating up.
The bottom line is that competitive carriers with IP-based networks want to be able to interconnect with ILECs via IP rather than having to convert traffic back to TDM. Thats because doing an IP-to-TDM conversion creates the need for more gateway infrastructure, can adversely affect the quality of voice and fax calls, and can stand in the way of a competitive service provider and its customers getting the most out of IP-capable networks. CLECs also want to ensure that ILECs continue to abide by interconnection rules already in place, even as they and the rest of the industry move to IP.
A panel today, called Next-Generation Interconnection The Challenges Ahead, aims to educate the COMPTEL audience on such interconnection issues and CLEC concerns around them.
Joe Gillan, a consultant with Gillan Associates, will moderate the panel, which consists of Rick Cimerman, vice president of state government affairs at the National Cable & Telecommunications Association (NCTA); Hank Hultquist, vice president of federal regulatory at AT&T Inc.; and Dave Malfara, president and CEO of application network provider Remi Communications.
Malfara said that today incumbent telcos will not allow CLECs to interconnect with them via IP, even where IP infrastructure is available. That works to the disadvantage of CLECs, he said.
We have local number portability and 800-number portability and Class-type local exchange services because of advancements in signaling brought about by SS7 and by Advanced Intelligent Network (AIN) technology, said Malfara. What were talking about now, in the new world of voice-over-packet technology, were talking about signaling capabilities [like SIP, H.323, etc.] that allow us to have further advancements over SS7. So the natural evolution of the PSTN for the past 100 years has been to accommodate those advancements in additional interconnection requirements. The overarching interconnection requirement in the Telecom Act, and in the ensuing rules, envisioned not only SS7 interconnection and signaling and transport interconnection available the time the Act was signed, but they say at any technically feasible point of interconnection. And these certainly are technically feasible. We do it all the time.
Cimerman of the NCTA, who notes that his associations cableco members are themselves CLECs given they offer voice to residential customers, added: We have concerns that as ILECs change out their own technology and put more of their own managed packet networks out there, or more IP out there, that they dont forget the obligations that they have, under the law, to interconnect.
While regulators are not working to remove any such obligations, the way at least one incumbent Verizon Communications Inc. has been talking about interconnection for IP is raising some red flags at competitive carriers, said Cimerman. He said hes heard inklings of ILEC leanings on this issue through discussions at industry conferences. Cimerman said he also has seen evidence of it in Footnote 19 of Verizons response to a forbearance-related letter that NCTA submitted to the FCC, talking about how the association wants to see wholesale obligations in Section 251 upheld.
In that footnote, Cimerman said, Verizon referred to upholding wholesale obligations in 251 as the network moves to IP as a radical new approach for interconnection.
But Cimerman and Malfara both point out that 251 and 252 are not technology-specific in any way.
I think there is some, maybe purposeful sometimes, confusion about what folks are talking about because I think that when or if we raise IP interconnection as an issue or a concern, what you get back [from RBOCs] is one of a couple of responses, added Cimerman.
Sometimes RBOCs will talk about the appeal of peering and put the focus on the public Internet, trying to create the impression that CLECs are pushing for Internet regulation. That Internet talk doesnt apply to this interconnection discussion, however, said Cimerman, because CLECs are referring to their own managed IP networks not the public Internet.
Incumbent voice providers also fail to note that peering typically involves networks of about the same size and with about the same amount of traffic flowing, because if that environment doesnt exist, network operators would have to pay one another, he said.
But apart from that, there is a distinction that is not being drawn, which is that interconnection for voice networks is a little bit different, always has been treated differently for historic reasons, added Cimerman. The way in which ILEC networks were built, with guaranteed rate of return and the market power they exercise, that was all taken into account by Congress and policymakers when they established the interconnection rules in 251 and 252.
Nonetheless, Cimerman continued, some incumbents seem to be pushing the idea that the industry should go to commercial negotiation.
But that, Cimerman said, fails to recognize that the existing system actually is commercial negotiation. The difference is that theres a regulatory backstop if negotiations fail, as they almost inevitably do.
Despite these CLEC concerns, the ILEC representative on the panel, AT&Ts Hultquist, said his company doesnt see any significant challenges around next-generation interconnection and does not draw distinctions between interconnection in the legacy world and the newer IP-based environment.
From AT&Ts standpoint, the main challenge is just seeing the market mature and how things are implemented, he said. We dont see any radical difference between what people call next-gen interconnection and what we traditionally viewed as IP peering and transit relationships. We dont actually see any huge challenges other than just the challenges that come up when you implement something new.
As for the idea that incumbent telcos only are allowing TDM interconnection with competitors, Hultquist replied: Were very interested in looking into IP interconnection for our IP customers. What were not interested in doing is performing an IP-to-TDM conversion on behalf of other providers for our TDM customers.
With respect to our IP customers, were quite interested in talking to people and figuring out what relationships could be formed for IP interconnection, and were really just starting to look at that, Hultquist continued. We might be interested from a commercial perspective in performing an IP-to-TDM conversion, but we dont want to have any sort of compulsion where we would be required to perform the protocol conversion for interconnection with our TDM customers.
But this story, although long, is just the tip of the iceberg on this issue. Please join us today for more detailed explanations and discussions of this issue.