AT&T Pushes Bill-and-Keep; Remote-Area Traffic Targeted; CLEC Hits 'Self Help'
AT&T pressed the FCC to "complete the move" to a default bill-and-keep regime of zero payments to eliminate incentives for intercarrier-compensation arbitrage. "Companies continue to game ... the system, creating irrational and inefficient economic incentives by artificially inflating switched access…
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charge revenues," filed the telco Thursday in docket 01-92. "Moving these remaining access charges to bill-and-keep would be consistent with the Commission’s overarching goal of discouraging arbitrage" and be aligned with a 2011 order finding "that, with respect to terminating traffic, the LEC’s end user is the cost causer and therefore the LEC should look first to its subscribers to recover the costs of its network." The cost causers in this case are access stimulators that "should bear sole responsibility for the expenses," AT&T said. It suggested the FCC could also state it violates the rules to be "intentionally locating high volume services in remote areas with the prevailing purpose of abusing the switched access regime" or routing "high-volume switched access traffic to remote areas to then re-route that traffic" via IP networks to the state in which the traffic is destined. Locating operations and targeting traffic in remote areas is arbitrage that "artificially" inflates traffic and increases terminating costs borne by interexchange carriers, filed USTelecom on meetings its members had with Wireline Bureau and Office of Economics and Analytics staffers, posted Friday in docket 18-155. It said "some arbitrageurs may be able to move around to increase their revenues" making it "difficult for terminating carriers to develop alternative network designs, like direct connections." Telcos also continue to "see revenue sharing agreements and traffic imbalances" consistent with access stimulation, it said. Calling ILEC rates a cap to its rates, CLEC Wide Voice said "carrier 'self-help' refusal to pay properly tariffed rates" is its single biggest problem," it filed on meetings CEO Andrew Nickerson had with aides to every commissioner and with Wireline Bureau and OEA staffers. It urged the FCC to "end the vilification of access stimulation" -- a "valid, compensable traffic category" created by the agency -- and penalize carriers engaging in "self-help non payment."