Telecom Law Monitor : Washington D.C. Telecom Lawyer & Attorney : Kelley Drye & Warren Law Firm : New York, Chicago, Connecticut, New Jersey, Brussels

In a move that surprised almost no one, the FCC extended its discontinuance of service rules to providers of interconnected VoIP services.  When this latest action becomes effective, interconnected VoIP providers will be required to give customers advance notice of plans to discontinue service and will have to file for FCC approval of such actions.  FCC approval is automatic 30 days after the Commission issues public notice, unless it issues an order denying the discontinuance within that time.  Curiously, although the Vonage order preempts state regulation of interconnected VoIP entry or exit, the discontinuance rules require interconnected VoIP providers to notify the relevant state commissions in addition to the FCC.  

More broadly, as it has before, the FCC refused to classify interconnected VoIP service as either a telecommunications service or an information service.  So, while we still don't know what it is, exactly, interconnected VoIP has yet another of the obligations traditionally associated with POTS service.  

Kelley Drye Client Advisory - FCC Releases Order Extending Discontinuance of Service
Requirements to Providers of Interconnected VoIP Service 

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Late last night, the FCC announced its agenda for its May 13 Open Meeting. Highlighting the agenda are items relating to VoIP provider discontinuance obligations and LNP deadlines.

VoIP

The FCC announced that it plans to “consider a Report and Order concerning the requirements of interconnected VoIP providers when discontinuing service.”  This is sort of a stealth item on the agenda, as there has been virtually no discussion in the docket on this issue in the most recent months.

We hear that the FCC is likely to impose notice requirements similar to those that apply for traditional telecommunications carriers. This will continue a trend for interconnected VoIP where the FCC has imposed, one-by-one, obligations traditionally held by telecommunications carriers while steadfastly refusing to classify interconnected VoIP services. In today’s state of affairs, interconnected VoIP has nearly all of the burdens of regulation but few of the benefits. The most significant outstanding issue continues to be the application of access charges to interconnected VoIP. This topic has been a subject of litigation for some time.

Number Porting

The FCC will address porting intervals and related standards for the transfer of telephone numbers between carriers when a customer switches service providers. Cable providers in particular are pushing for a maximum interval of one-day for simple wireline to wireline and intermodal porting requests. The Order could also further address the information that carriers may require in order to implement a porting request, response intervals for customer service requests (CSRs) and other concerns raised regarding fair competition among providers.
 

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