Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC COMMENTS OF GENERAL COMMUNICATION, INC.

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Caren Lester
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1 Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC In the Matter of Rural Call Completion Video Relay Service Program WC Docket No COMMENTS OF GENERAL COMMUNICATION, INC. General Communication, Inc. ( GCI hereby submits these comments in response to the Federal Communication Commission s ( FCC or Commission Further Notice of Proposed Rulemaking ( FNPRM on rural call completion issues. 1 Specifically, GCI responds to the Commission s request for comment regarding whether additional guidance should be provided as to how existing or any new requirements in connection with rural call completion should apply to specific scenarios. 2 As explained below, to interconnect with some Alaska rural ILECs, because of those ILECs technology choices, GCI must use a signaling technology that does not provide the capabilities necessary to comply with the rules that require covered providers to record, retain, and report call completion data. Other than by waiver, the Commission s recording and retention requirement rules do not account for scenarios where compliance by a covered provider is not feasible for reasons beyond its control. Accordingly, the Commission should provide additional guidance for the specific scenario where providers must utilize signaling technologies that prevent compliance with the data requirements due to technological limitations of the originating or terminating ILEC. Specifically, GCI respectfully requests that the Commission s guidance exempt covered providers that must use MF signaling 1 2 Rural Call Completion, Report and Order and Further Notice of Proposed Rulemaking, FCC , WC Docket No (Released Nov. 8, 2013 ( Report and Order or FNPRM. FNPRM

2 to communicate with rural ILECs from these rules when the use of MF signaling is compelled by the rural ILEC s network. GCI provides services in Alaska, directly or through wholly-owned affiliates, as a rural incumbent local exchange carrier ( ILEC, competitive local exchange carrier ( CLEC, and long-distance telecommunications provider. In the Report and Order accompanying the FNPRM, the Commission adopted new rules (which are awaiting OMB approval that require covered providers to record, retain, and report call completion data. 3 Covered providers are providers of long-distance voice service that make the initial long-distance call path choice for more than 100,000 domestic retail subscriber lines. 4 The new rules were adopted to increase the Commission s ability to monitor and redress problems associated with the delivery of longdistance calls to rural areas. 5 These providers generally must collect call completion data, retain such data for six months, and file quarterly reports with the Commission. The Report and Order required covered providers to record and retain the following information for each long-distance call attempt: calling party number; called party number; date; time of day; whether the call is handed off to an intermediate provider, and if so, which intermediate provider; whether the call is going to a rural carrier, and, if so, which rural carrier, as identified by its operating company number ( OCN ; whether the call is interstate; and whether the call attempt was answered. 6 In addition, covered providers are required to record an indication whether the call attempt was completed to the incumbent local exchange carrier but signaled as busy, ring no answer, or unassigned number C.F.R , , and Report and Order Report and Order 19. Report and Order 42. Id. 2

3 GCI is a covered provider under the Report and Order s definition. But GCI has no capability to comply with the new rules when it must use multi-frequency (MF channel associated signaling. In fact, many of Alaska s rural ILECs use MF signaling; SS7 signaling technology is not universally deployed in Alaska. MF signaling uses a combination of tones for address (phone number and supervision signaling. The signaling is sent in-band over the same channel as the bearer channel for voice traffic. Using MF signaling, the originating telephone switching office sends a starting signal (off-hook to the terminating office indicating trunk seizure. After the initial seizure, the terminating office acknowledges a ready state by responding with a wink (short duration seizure and then goes back on-hook (wink start. The originating office responds by sending the customer ANI and called number to the terminating office. The terminating office responds with an acknowledgment wink and goes back on-hook. The chart below details the call attempt information returned (and thus recorded by the originating switch on a call with MF signaling: Actual Call Attempt Received by Originating Information Recorded Switch Call is answered Off-hook signal returned Billable call record Ring, no answer (caller No off-hook signal No answer eventually hangs up Busy signal No off-hook signal No answer (looks the same as ring no All circuits busy (caller hears reorder tone and hangs up No off-hook signal No answer (looks the same as ring no Invalid number (caller hears recording and hangs up Network congestion announcement (caller hears recording and hangs up No off-hook signal No off-hook signal No answer (looks the same as ring no No answer (looks the same as ring no 3

4 As shown in the chart, the off-hook signal is only generated when a call is answered. More importantly, on calls with MF signaling no other signal is generated if the call rings no answer, is busy, an invalid number, receives an announcement, or otherwise fails. Indeed, the transfer of additional signaling information is not possible in the case of MF signaling. This explains why providers who use MF have no capability to comply with the requirement to record an indication of whether a call attempt was signaled as busy, ring no answer, or unassigned number. MF and other in-band signaling systems differ from SS7 in that the routing digits are outpulsed in MF format in the same band channel used for voice. And the signaling message contains only the destination point code. The dialing user cannot detect these digits being outpulsed because the audio connection is not established all the way to the user s handset or device until after the connection is established with the terminating switch. Following a full connection, the same audio channel is connected to the user in order to communicate the voice or data across that same channel previously used for the in-band MF signaling. In contrast, SS7 messages are exchanged between network elements over bi-directional channels called signaling links. Signaling occurs out-of-band on dedicated channels rather than in-band on voice channels. Each signaling point in the SS7 network is uniquely identified by a numeric point codes. Point codes are carried in signaling messages exchanged between signaling points to identify the source and destination of each message. Each signaling point uses a routing table to select the appropriate signaling path for each message. Finally, if a GCI switch receives a call from a switch with SS7 signaling (for example, from the lower 48 states and hits an outgoing trunk with MF signaling, the release cause code of an unanswered call is always indicated as interworking, unspecified, which means the 4

terminating status of the call is unknown. In fact, any time a call leaves an ISDN network, the SS7 release cause is always indicated as interworking, unspecified.

5 terminating status of the call is unknown. In fact, any time a call leaves an ISDN network, the SS7 release cause is always indicated as interworking, unspecified. Because MF is not an ISDN system, the interworking, unspecified release cause indication will always be returned even when the call passes through multiple carriers. The new rules do not account for scenarios where the covered provider, for reasons outside of its control, must use a signaling system that leaves it with no capability to comply. In fact, the Report and Order plainly states that the call attempt indication would likely take the form of an SS7 signaling cause code or SIP signaling message associated with each call attempt. 8 GCI therefore respectfully requests that the Commission exempt covered providers that must use MF signaling to communicate with rural ILECs from the rules that require them to record, retain, and report call completion data. Exclusion of these providers should not compromise the Commission s ability to monitor rural call completion problems more effectively. Respectfully submitted, January 16, 2014 John T. Nakahata Jennifer P. Bagg Randall W. Sifers WILTSHIRE &GRANNIS LLP 1200 Eighteenth Street, NW 12 th Floor Washington, DC T: ( jnakahata@wiltshiregrannis.com Counsel to General Communication, Inc. 8 Id. 5

October 4, Ex Parte. Ms. Marlene H. Dortch Secretary Federal Communications Commission th Street, SW Washington, DC 20554

October 4, Ex Parte. Ms. Marlene H. Dortch Secretary Federal Communications Commission th Street, SW Washington, DC 20554 Ex Parte Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12 th Street, SW Washington, DC 20554 Re: Connect America Fund, WC Docket No. 10-90; A National Broadband Plan for Our Future,