FCC and HD Tandem further discuss access stimulation
Representatives of HD Tandem, a provider of virtual tandem and termination services, met with several FCC Commissioners, their staff, and Chairman Pai on September 11–12, 2019 to discuss access stimulation. Here’s a recap.
In the ex parte filing recap of these meetings, HD Tandem representatives argued the following points:
- HD Tandem believes it is problematic for the FCC to involve itself in consumer pricing, especially since consumers prefer free voice applications (e.g., free conference calls) to pay voice applications.
- Both free and pay voice applications are subsidized with the intercarrier compensation regime.
- Banning the use of intercarrier compensation on free services would enable it to subside pay services only.
- The Draft Order would create disruption in both free and pay services.
- The order would impact a larger number of LECs than the FCC expects, as evidenced by an ex parte filing from the NTCA that identified 24 LECs would become newly-designated access stimulating, with another 9 on the bubble.
HD Tandem provided this explanation for the disruption they anticipate:
LECs in urban areas such as New York, Chicago, Los Angeles and Miami host the very same voice application services. However, these LECs would not trip the triggers in the Draft Order.
Because the Draft Order is not eliminating the use of intercarrier compensation system to subsidize voice application services, some of the billion voice application minutes at HD Tandem would migrate from LECs in peril of becoming designated access stimulating LECs and migrate to non-access stimulating LECs.
For this reason, HD Tandem believes that the Draft Order will simply steer traffic away from some LECs to others.
Instead of implementing a new, untested trigger, HD Tandem urged the Commission to focus on equalizing compensation. In particular, HD Tandem urged the Commission to:
- Revisit the issue of mileage elimination as a primary trigger in determining who is an access stimulating LEC.
- Eliminate the CEO mandated use policy.
- Move the industry toward bill-and-keep.