As we reported just about a year ago, the FCC adopted a number of rules to address the problem of rural call completion or, more accurately, rural call non-completion. Many calls placed to numbers served by small rural telephone companies don’t seem to make it to their destination. And that seems to happen especially when the calls are routed through “least cost” intermediate service providers who don’t take kindly to the high per-minute termination access charges imposed by many small telcos. In keeping with its priority goal of universal connectivity, the FCC adopted rules mandating that calls not be blocked, that carriers file quarterly reports on call completion success rates, and that a ring tone not be delivered to the calling party until the call has actually been connected to its destination.
Five petitions for reconsideration were filed and the Commission has now denied all but one of them.
In response to the one successful petition, filed by USTelecom and ITTA, the FCC has decided to exempt from call quality reporting requirements intraLATA toll calls that are: (a) carried entirely over the covered provider’s network or (b) handed off by a covered provider directly to a the terminating carrier or a terminating tandem switch. Some carriers don’t keep detailed records of such calls now, so the cost of reporting on such calls would likely impose significant new cost burdens. Since the benefit of reports on such calls would be limited, the scale balanced in favor of an exemption. The exemption does not apply to interLATA toll calls, even if they are directly handed off to the terminating carrier or tandem; the FCC said that the majority of on-net traffic is interLATA and will still be covered.
Reconsideration petitioners taking aim at various other aspects of the rules didn’t fare so well. Of some interest in today’s environment of spectacular FCC enforcement actions, one petitioner expressed concern that its reports could be used to initiate enforcement actions and, in effect, end up constituting self-incrimination. The FCC said that, of course, it will allow carriers to provide exculpatory information (assuming they have any) before the axe falls. The FCC also: declined to expand the exemption for very small carriers by raising the threshold for eligibility (that exemption is available to carriers with no more than 100,000 subscriber lines); declined to adopt a general rule addressing the possible loss of an exemption because minority passive investors in one telco happen to own interests in other telcos; and rejected (on procedural grounds) a challenge to its authority to regulate when the ring tone is heard.
So the basic rules remain intact, at least unless and until there is a court appeal that succeeds. Several Commissioners waxed enthusiastic about finally nailing down a problem that vexes so many members of the public. Not so fast, though. The reporting requirements that are central to the call completion rules are “information collections” that must first be approved by the Office of Management and Budget, so it will be a while yet before the full rural call completion story is told. Check back here for updates on that front.