VoIP Numbering Trials

In our last episode of the VoIP Numbering Trial saga (November 13, 2013 post, Level 3 Reports Same Obstacles as Vonage in Numbering Trial), I reported that Level 3’s VoIP affiliate, Level 3 ES, was unable to test call routing in the Denver market due to CenturyLink’s refusal to allow its traffic to be routed via the existing Level 3 CLEC interconnection trunks. This was the same issue that Vonage raised with respect to its numbering trial in the Phoenix market, where CenturyLink is also the incumbent LEC  (November 6, 2013 post, VoIP Numbering Trial Off to a Slow Start).

CenturyLink jumped into the fray with an ex parte filing on November 15, 2013, responding to the criticisms from Vonage and Level 3. CenturyLink asserted that it “supports the VoIP Numbering Trial,” but that in order to assess the impact of giving VoIP providers direct access to numbers, “it is important to be able to track and measure traffic from trial participants.”  It said that “it has seen increased instances of robo-calling and the telecom equivalent of denial of service (TDOS) attacks associated with traffic from VoIP end points.” According to CenturyLink, its insistence that traffic to VoIP providers in the trial be routed over separate trunk groups is “an industry standard approach to tracking and measuring traffic.” It also asserted that it “does not cost much to establish separate trunks…and CenturyLink is more than willing to waive any charges for the trial period.”

Level 3 responded with its own ex parte on November 20, 2013. Level 3 was apparently less than impressed with CenturyLink’s offer to waive any charges for the separate trunk group during the trial stating:  “Even setting aside the question of whether such facilities could be set up before the trial period ends on December 17, CenturyLink’s proposal would require Level 3 to purchase unnecessary facilities to establish inefficient routing a month from now rather than today, which does not address Level 3’s concerns with CenturyLink’s refusal to route traffic to it in connection with the trial.”

Not to be left out of the discussion, on November 27, 2013, SmartEdgeNet dba Edge Communications (“SEN”), filed an ex parte in which it described itself as “one of the victims of CenturyLink’s [separate trunk] requirement.”  SEN disputed CenturyLink’s claim that it needs to track and measure traffic, which it argued was “irrelevant to the purpose of the trial.” It also rebutted CenturyLink’s “industry standard” argument, stating that “the requirement for separate trunks may be an industry standard approach for TDM carriers, but it is not an industry standard approach for interconnected VoIP providers. Instead, it defeats one of the benefits of interconnected VoIP services by adding additional, unnecessary costs.”

SEN labeled CenturyLink’s alleged support of the numbering trial as “gratuitous” and concluded its letter with scathing remarks about CenturyLink’s intent, stating “It should be obvious what CenturyLink is about in this instance. Although it has stated to SEN that its separate trunk requirement is a matter of CenturyLink ‘policy,’ it has implied to SEN that it will not let SEN into its markets without a fight…The Commission has been here before when the Bell System attempted to erect barriers to entry. It wasn’t tolerated then and it should not be tolerated now.”

Stay tuned for the next episode…. VoIP Numbering Trials



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