Whippany, NJ - May 28, 2004  -The National Exchange Carrier Association (NECA) has submitted its comments to the Federal Communications Commission in response to the Notice of Proposed Rulemaking on IP-Enabled Services. In its submission NECA argues that IP service providers using the public switched telephone network to originate or terminate their telephone calls must compensate LECs for such use and contribute to the Universal Service Fund as all other providers offering similar services do.

In recent years a number of entities have gone to the FCC in an effort to avoid paying access charges and contributing to the Universal Service Fund simply by stamping themselves with an “Internet” label. These carriers attempt to gain a free ride from intercarrier compensation and universal service contribution obligations by “conjuring up the mystery, excitement and difference that the Internet label connotes, as well as to elicit sympathy from those who believe that regulators must, at all costs, ‘keep hands off’ the Internet,” according to the comments.

But the fact that these services use Internet Protocol during some portions of a call simply makes no difference from the consumer’s perspective, and shouldn’t make any difference from a regulatory perspective.  There is nothing special about Internet protocol, compared to other protocols, when it is being used to provide basic telephone service over the Public Switched Telephone Network. Without the PSTN these providers would have no customers for their long distance VoIP service according to NECA’s comments.

Granting one class of carriers an exemption from access charges based simply on the technology they employ would severely undermine a key revenue source for LECs. As a result, many NECA members could become unable to continue to provide basic service, let alone advanced services. Without these networks in place, the IP-Enabled services that the Commission wishes to promote will be available only to urban and suburban end users with access to low-cost communications networks, and the country will become literally and figuratively disconnected from its rural areas.  

 In addition to its comments on the regulation of VoIP services, NECA argues for the FCC not to limit the ability of carriers to continue to tariff basic DSL services. Tariffing and pooling are options that must be made available to rural carriers to promote the deployment of advanced services in rural areas.