When a major carrier disputes your Switched Access bills, it can be intimidating. Not that these carriers intentionally come across that way — I’ve seen plenty of very polite correspondence on the subject from the large carriers. And to be fair, sometimes their skepticism about CLEC access rates is warranted. Not every CLEC has always made sure its access services are properly priced, tariffed, and billed.
But too often when a large carrier disputes an access bill, their opening remarks can sound a bit like “Let me tell you what’s going to happen here…”
Now, it’s understandable that a CLEC might feel powerless against the demands of the
large carriers. After all, these carriers have been in the game for a very long time, and they have teams of lawyers ensuring that they know all of the rates, rate caps, and associated rules, right? Well, while that may be true, I’ve run across quite a few instances where the assertions reflect more about what the carrier thinks should be the case than what is supported by
actual regulatory decisions.
The first issue I’ll touch on – since it is about to go dormant for a year — is the “PVU” factor
used to identify VoIP-PSTN traffic. One carrier in particular likes to impose its notion of what the CLEC’s PVU should look like. They recently told a CLEC that unless the CLEC reported its own PVU, the carrier would apply the “safe harbor” PVU on that CLEC (in addition to the carrier’s own PVU factor). Yes, the ICC Reform Order does mention a safe harbor PVU method, but it is a safe harbor a LEC can apply (via an intrastate access tariff) to the IXC – not the other way
around.
In another case, a large carrier insisted that the CLEC’s PVU should be 100% even though the
CLEC’s service was not VoIP according to the clear definition laid out in the Order. The carrier did not dispute what the Order said on the issue, but asserted the Order did not mean what it said.
Next, we’ll address 800 query rates…
Watch for the next installment in this series next week.
