WASHINGTON CALL TERMINATION ISSUES WORKSHOP Dale Merten C

WASHINGTON CALL TERMINATION ISSUES WORKSHOP Dale Merten, C. O. O. The Toledo Telephone Co. , Inc. Rick Vitzthum, Controller Kalama Telephone Company Tenino Telephone Company Betty Buckley, EVP Washington Independent Telecommunications Association August 8, 2011

Failure of Call Termination is a Major Issue l It affects customers l It affects companies

Customers’ Experiences l l Customers continue to suffer due to call incompletion Customer call completion issues – – – Ring tone with no answer – rings 10 -20 times – caller hangs up “Dead Air” One-way conversations (one party can hear the other, but the second cannot hear the first) Incorrect caller ID displayed to called party Caller receives incorrect or misleading message interceptions before call reaches tandem

Customers’ Experiences l Lack of call termination results in customer confusion and frustration – – – Customers around the country don’t understand or care about the reason why they cannot complete calls to WITA members Customers often blame WITA members’ customers switching to wireless competitors

Customers’ Experiences l Many calls don’t reach WITA members’ networks or the tandem that each WITA member sub-tends – Makes it difficult to trace calls and troubleshoot issues

Company Experiences l Coincident with major fluctuations in terminating minutes from various carriers – – Abnormally large decline in terminating access minutes Occurring statewide Involves both interstate and intrastate terminating access traffic Involves both originating wireline and wireless traffic

Analysis of Termination Issues l l Increase in non-completed calls are not due to inadequacies of WITA members’ networks Participants are explicitly altering SS 7 records –Originating call numbers are missing/altered in billing records l Large increase in unanswered calls across rural ILEC exchanges

“Least-Cost Routing” Could be a Cause of Call Termination Problems l Carriers are using LCR to reduce terminating costs – – – l Appears to sacrifice call quality Carriers may not complete calls to terminating customers Calls are “looping” between LCR subcontractors Direct violation of FCC Order – “Commission precedent provides that no carriers, including interexchange carriers, may block, choke, reduce or restrict traffic in any way. ” In the Matter of Call Blocking by Carriers, DA 072863, para. 6 (June 28, 2007).

“Least-Cost Routing” Could be a Cause of Call Termination Problems l Non-termination is in effect “call blocking” – – l Cost reduction/elimination for underlying carrier Forces end user to choose another carrier that does not block, choke or restrict traffic via LCR, or to cease making calls to that location. Results in customer isolation, disruption of interstate commerce, degradation of the PSTN, and conflicts with interconnection and universal service principles.

Actions WITA Members Are Taking To Address Call Termination Problems l l l Working with customers and originating callers of other carriers Performing traffic studies to compare SS 7 messages to billing records in attempt to find “missing calls” Conducting investigations which are expensive, timeconsuming and conducted with no specific obligation from suspected carrier(s) to cooperate – – Trouble reports have been submitted to carrier(s) that may be source of problem – with varied response Trouble Tickets

Where is the FCC? l l The commission is “committed to addressing arbitrage opportunities today” but will only address them as “part of comprehensive reform. ” The current model of USF and ICC does not account for changing customer preferences and continuing declines in access minutes. “You need reform to address these challenges. ” – l Carol Mattey, Deputy Chief, Wireline Competition Bureau, FCC Unfortunately, reform is many years away.

Fiction vs. Fact l Fiction: – – l Access minutes are on the decline Therefore the model must be broken Fact: – – WITA switches are busier than they have ever been We can’t bill for the call because the data has been stripped or altered

Test Procedures l l l Called and calling party agreed that records would be made public Calls were placed via multiple carriers, both TDM and Vo. IP Calls terminated on 864 -4700 POTS Intrastate, intra and inter-lata Interstate, intra and inter-lata Wireless

The Test Phone

Test Results l l l Calling number hears “Ring no Answer” Calling number hears 15 rings before answer Called number hears ring, then dead air – l l l Elderly think they are being stalked Call completes with one-way conversation Call completes with poor audio Call completes with spoofed calling number

Call from WA Land Line l l l Call was placed from Olympia First and second attempt = delay then fast busy Third and fourth attempts = call complete with incorrect calling number

Customer Complaints Dropping l l l Complaints peaked 6 months ago Initially, we thought they gave up on us Determined calls were now completing All from a single local number RLECs without soft switches cannot make this determination

Verified Users of LCR l l XO, Verizon, Sprint, Qwest, Magic Jack, Google Voice, Vonage, MCI, Comcast, Bresnan, Pae. Tec, Neutral Tandem, Level 3 Every provider tested resulted in LCR except AT&T – l However, they have a direct trunk to our switch Important to note that LCR itself isn’t the problem. The problem is misuse of LCR systems.

The Problem is Gigantic l l l A random sample of our call data 07/08/11 shows 8813 call terminations 4155 all from a single local EAS number 8714 calls show no CIC (0000 or blank) 98% of traffic terminates for free 47% of traffic terminates from one local number

Revenue Loss For Everyone l WITA company customers – l WITA companies – l Lose business due to unreliable phone service Lose revenue due to records altered to avoid charges State of Washington – Lose tax revenue on toll charges

Kalama Telephone Company & Tenino Telephone Company l Our test results and customer complaints matches Toledo’s experience – – – Calling number hears “Ring no Answer” Calling number hears 15 rings before answer Called number hears ring, then dead air Call completes with one-way conversation Call completes with poor audio Call completes with spoofed calling number

Magic. Jack Testing l Magic. Jack Phone Number = 253 -719 -7115 (Tacoma) – Calls from Washington DC to 360 -264 -3155 l – Calls placed from Tenino to 360 -264 -3155 l – TGMU Record showed the from number and billing number as 360918 -XXXX delivered on common toll trunk. 360 -918 is an Olympia EAS exchange Calls from Tenino to 360 -673 -3155 (Kalama) l TGMU Record showed the from number and billing number as 360232 -XXXX delivered on common toll trunk. 360 -232 is a Longview EAS exchange

Kalama Telephone Company Trunk Group Measurement Utility (TGMU) - Terminating Traffic

Tenino Telephone Company Trunk Group Measurement Utility (TGMU) - Terminating Traffic

Terminating Call Record

Terminating Call Record

Terminating Call Record

KALAMA TELEPHONE COMPANY Common Toll Trunk Terminating Traffic

TENINO TELEPHONE COMPANY Common Toll Trunk Terminating Traffic

Beyond the data and dollars Steve Appelo, Associate Executive Officer Wahkiakum West Telephone Greg Morasch, General Manager St. John Telephone Company

State Statutes Involved l RCW 80. 36. 140 This statute allows the Commission to address “unjust, unreasonable, unjustly discriminatory or unduly preferential” practices of telecommunications carriers and “inadequate, inefficient, improper or insufficient” telecommunications services.

State Statutes Involved l RCW 80. 36. 160 Allows the WUTC to prescribe “connections” for toll service and to “prescribe the routing of toll message and conversations over such connections and the practices and regulations to be followed with respect to such routing. ”

State Statutes Involved l RCW 80. 36. 200 Every telecommunications company operating in this state shall receive, transmit and deliver, without discrimination or delay, the messages of any other telecommunications company.

State Statutes Involved l RCW 80. 36. 220 Telecommunications companies shall receive, exchange and transmit each other's messages without delay or discrimination, and all telecommunications companies shall receive and transmit messages for any person.

State Statutes Involved l RCW 80. 36. 260 Whenever the commission shall find…that repairs or improvements to, or changes in, any telecommunications line ought reasonably be made…in order to secure adequate service or facilities for telecommunications, the commission shall make and serve an order directing that such repairs, improvements, changes, additions or extensions be made in the manner to be specified therein.

POSSIBLE WUTC ACTION l l l Reaffirm that all traffic, IP and circuit-switched, is required to pay proper jurisdictional compensation for originating and terminating access. Declare non-payment of tariffed ICC charges to be unlawful Declare that engaging in practices to avoid proper call termination to be unlawful Declare intention to impose significant fines on carriers found to knowingly refuse to complete calls or provide accurate billing information Investigate routing practices of wholesale carriers, including Vo. IP transport providers

Thank you! WITA and our members look forward to working with the WUTC to quickly resolve least cost routing abuses and phantom traffic. Betty Buckley 360. 352. 5453