Interconnection in the IP Age

The issue of carrier interconnection rules related to managed IP networks for VoIP seems to be heating up.

The bottom line is that competitive carriers with IP-based networks want to be able to interconnect with ILECs via IP rather than having to convert traffic back to TDM. That’s because doing an IP-to-TDM conversion creates the need for more gateway infrastructure, can adversely affect the quality of voice and fax calls, and can stand in the way of a competitive service provider and its customers getting the most out of IP-capable networks. CLECs also want to ensure that ILECs continue to abide by interconnection rules already in place, even as they and the rest of the industry move to IP.

Dave Malfara, president and CEO of application network provider Remi Communications, tells me that Verizon Communications Inc. will not allow Remi to interconnect with it via IP, even where IP infrastructure is available. That works to the disadvantage of CLECs, he says.

That may be true of Verizon. But Hank Hultquist, vice president of federal regulatory at AT&T Inc., responds to Malfara’s claims by saying: “We’re very interested in looking into IP interconnection for our IP customers. What we’re not interested in doing is performing an IP-to-TDM conversion on behalf of other providers for our TDM customers.

“With respect to our IP customers, we’re quite interested in talking to people and figuring out what relationships could be formed for IP interconnection, and we’re really just starting to look at that,” Hultquist continues. “We might be interested from a commercial perspective in performing an IP-to-TDM conversion, but we don’t want to have any sort of compulsion where we would be required to perform the protocol conversion for interconnection with our TDM customers.”

Rick Cimerman, vice president of state government affairs at the National Cable & Telecommunications Association (NCTA), whose cableco members offer voice services and, therefore, need to interconnect with the ILECs as do the traditional CLECs, says the group is concerned that as ILECs migrate more to managed packet networks and IP, “they don’t forget the obligations that they have, under the law, to interconnect.”

While regulators are not working to remove any such obligations, the way at least one incumbent — Verizon — has been talking about interconnection for IP is raising some red flags at competitive carriers, says Cimerman.

He says he’s heard inklings of ILEC leanings on this issue through discussions at industry conferences. Cimerman says he also has seen evidence of it in Footnote 19 of Verizon’s response to a forbearance-related letter that NCTA submitted to the FCC, talking about how the association wants to see wholesale obligations in Section 251 upheld. In that footnote, Cimerman says, Verizon referred to upholding wholesale obligations in 251 as the network moves to IP as “a radical new approach for interconnection.”

But Cimerman and Malfara both point out that Sections 251 and 252 of the Telecom Act are not technology-specific in any way.

Cimerman adds that “The way in which ILEC networks were built, with guaranteed rate of return and the market power they exercise, that was all taken into account by Congress and policymakers when they established the interconnection rules in 251 and 252.”

Nonetheless, Cimerman continues, some incumbents seem to be pushing the idea that the industry should go to commercial negotiation. But that, Cimerman says, “fails to recognize that the existing system actually is commercial negotiation. The difference is that there’s a regulatory backstop if negotiations fail, as they almost inevitably do.”

Until next time,

Paula Bernier
Editor in Chief

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