On March 15, 2019 the FCC adopted its Fourth Report and Order (“Order”) establishing rural call completion service quality standards for intermediate providers.  While the Order remains largely unchanged from the draft circulated prior to the FCC’s March Open meeting (see our prior post) for more details on the draft Order), the FCC made one significant change that should interest intermediate providers handling calls destined for termination outside of the United States. The adopted Order clarifies that the new rules do not apply to non-U.S. intermediate providers on calls terminating outside of the United States. As a result, the Order eases compliance requirements for the final U.S. intermediate provider in a call path destined for foreign termination.

Continue Reading FCC Rural Call Completion Order Clarifies Applicability of Service Quality Standards

The FCC continues its efforts to improve rural call completion, teeing up a draft Fourth Report and Order (“Order”) that would adopt new service quality standards for intermediate providers (i.e. entities that carry, but do not originate or terminate calls) for consideration at its March 15, 2019 Open Meeting. The Order, which would further implement the Rural Call Quality and Reliability Act of 2017 (“RCC Act”), proposes intermediate provider service quality standards and related enforcement procedures, and sunsets existing call data recording and retention rules for covered providers. The Order also would deny two pending Petitions for Reconsideration of previous rural call completion orders. Although the proposed service quality standards would not take effect until the later of six months after the Order is released or 30 days after it is published in the Federal Register, intermediate providers will want to begin familiarizing themselves with the proposed new rules now in light of the significant potential enforcement penalties for noncompliance.

Continue Reading FCC Set to Adopt Rural Call Completion Service Quality Standards

Jameson Dempsey co-authored this post. 

With the new year upon us, the FCC will soon be receiving comment on one of the “big picture” issues facing telecom regulation: addressing the evolution of the Public Switched Telephone Network (“PSTN”) from “legacy” time-division multiplexing (“TDM”) systems toward an Internet protocol (“IP”) based network.  The transition from the traditional PSTN to IP has been a hot topic at the Commission and within the industry, as consumers increasingly “cut the cord” on landline copper networks and rely on mobile wireless or IP-enabled communications technologies running on broadband networks.  However, consumer groups and small carriers have warned that in recognizing the inevitable transition toward IP, the FCC should not abdicate—and in some cases must increase—regulatory authority over communications networks. Later this month, the FCC will receive comment on two divergent petitions proposing responses to the transition. These petitions provide the first opportunity for the FCC to frame the debate over IP-enabled communications in Obama’s second administration.


Continue Reading FCC Opens the Year with A New Look at the Transition from TDM to IP Networks