As more traffic migrates to VoIP, we will need a new approach to interconnection pricing. Any new approach to interconnection pricing should:
- Encourage efficient competition and the efficient use of, and investment in, telecommunications networks,
- Preserve the financial viability of universal service mechanisms. Thus any proposal that would result in significant reductions in intercarrier payments should include a proposal to address the shortfall,
- Treat technologies and competitors neutrally,
- Allow innovation,
- Minimize regulatory intervention and enforcement, consistent with the general trend toward less regulation wherever possible.
This implies treating VoIP providers that provide service over the PSTN in the same way as other telecommunications service providers, including with respect to:
- Interconnection charges: VoIP providers should face the same payment obligations as other service providers that use equivalent facilities and services. Similarly, VoIP providers should be entitled to the same reciprocal termination payments from PSTN operators,
- Regulatory fees: Technology neutrality suggests that all providers (including VoIP providers) whose service accesses the PSTN should be subject to the same regulatory fees, including universal service contributions,
- Other regulatory requirements: Where feasible, VoIP providers should have similar obligations to other service providers that offer a functionally equivalent service (for example with respect to emergency services, or obligations to support law enforcement call intercepts).
NGN Challenges to Regulators
NGNs will present both recurring and new challenges to regulators. Regulators will have to address whether and how to resolve issues relating to interconnection terms and conditions, but they may not have complete jurisdiction over all carriers. To the extend VoIP and other Internet-mediated services do not fit within a telecommunications services classification, regulators may not have lawful authority to mandate interconnection and to regulate rates. If VoIp and other Internet services fit within an enhanced, or information services category carriers may lawfully refuse to interconnect. Similarly national regulatory agencies may not have access to privately negotiated, voluntary interconnection arrangements.
VoIP Impact on Universal Service Funding
VoIP may have an adverse impact on universal service funding as consumers may have the ability to migrate from services that make contributions to ones that do not. If VoIP traffic can “leak” into the public switched telephone network without triggering access charge and universal service funding burdens, users of conventional services may have to bear a higher financial subsidy burden.
RELATED INFORMATION
A Comparison of Telecommunications and Internet Cost Recovery
Models for Internet Interconnection
Implications of VoIP for Interconnection Pricing
Pricing Mechanisms for VoIP Interconnection