”Significant gaps” exist in the rural call completion...

collection as a means of discovering further call completion problems will have “no practical utility” in addressing the root causes of the call completion issues, VCXC said in a filing in WC docket 13-39. “An industry wide ‘everyone presumed guilty’ data collection represents an extremely inefficient means of triggering enforcement actions,” VCXC said. “In the unlikely event problems arise with even 1 percent of total calls, 99 percent of the data collection burden represents a waste of resources the PRA approval process exists to prevent.” The FCC “failure to properly prepare” during the 40 months of investigations leading up to its rural call completion report “puts the application at risk and makes any outcome vulnerable to litigation and further delays,” VCXC said. A 90-day moratorium would let the FCC determine whether its PRA application can pass, and the agency might also convene industry meetings to discuss the issue, VCXC founder Daniel Berninger told us. The root cause of the call completion problems is the IP transition itself, Berninger said: “Chaos in the network” combined with “bad guys lurking out there, finding ways to collect money without delivering a service.” The problem is “a symptom of the chaos that ensues when you try to transition a network from TDM to all IP,” he said. Submitting the call completion data collection proposal to the Office of Management and Budget for PRA approval, only to have it be rejected, would be “a bigger setback than if we pause and assess the application before submitting it,” Berninger said. A data collection won’t fix anything, he said; it will just look for more problems. A better solution is for the FCC to “set up a process of anonymous whistleblowers” to find the bad actors, Berninger said.