Bill and Keep as the Efficient Interconnection Regime?: A Reply. Abstract

Similar documents
Patrick DeGraba Federal Trade Commission* Why Bill and Keep? Hotel Konigswinter, Germany 3 April 2006

IP Interconnection. Calvin S. Monson Vice President. Antigua September 2007

27 November 2009 TDC submission: ERG DRAFT Common Position on Next Generation Networks Future Charging Mechanisms/Long Term Termination Issues Draft

Mobile telephony in the UK

A MODEL FOR INTERCONNECTION IN IP-BASED NETWORKS

Organisation de Coopération et de Développement Économiques Organisation for Economic Co-operation and Development

WALKER WIRELESS LIMITED

Next Generation 911; Text-to-911; Next Generation 911 Applications. SUMMARY: In this document, the Federal Communications Commission (Commission)

NANC Future of Numbering Working Group

Response to Portfolio Committee on Communications. Measures to Reduce Interconnection Rates and High Costs of Telecommunications in South Africa

UNITED STATES INTERNATIONAL TRADE COMMISSION WASHINGTON, D.C. DEVICES AND RADIO FREQUENCY Docket No AND PROCESSING COMPONENTS THEREOF

The Effectiveness of Mobile Wireless Service as a Competitive Constraint on Landline Pricing: Was the DOJ Wrong?

Before the Federal Communications Commission Washington, D.C ) ) ) ) ) ) ) ) ) REPLY COMMENTS OF PCIA THE WIRELESS INFRASTRUCTURE ASSOCIATION

Implementation of Bill and Keep and Transitioning to it

Telecom Decision CRTC

Leased Line Charge Control

MERCATUS ON POLICY. Reforming the FCC s LowIncome Phone Subsidies. by Jerry Ellig. No. 105 February 2012

International Mobile Roaming -

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C In the Matter of ) ) Telephone Number Portability ) CC Docket No.

Telecom Order CRTC

Model Legislation As approved by the NCSL Executive Committee Task Force on State & Local Taxation of Communications and Electronic Commerce

SBC Long Distance Application - Personal Communications Industry Association Comments. Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C.

April 10, 2014 VIA ELECTRONIC FILING

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC ) ) ) ) ) ) ) ) COMMENTS OF T-MOBILE USA, INC.

POSTED September 3, 2009 QWEST CORPORATION S COMPARABLY EFFICIENT INTERCONNECTION PLAN FOR ENHANCED PROTOCOL PROCESSING SERVICES

September 25, Tom Wheeler, Chairman Federal Communications Commission 445 Twelfth Street, SW Washington, DC Number Portability

New Market Models for Traffic Exchange. Dennis Weller Chief Economist, Verizon WIK International Workshop Konigswinter 4 April 2006

Infrastructure Contributions Reform in Queensland

Current Intercarrier Compensation Issues Before the FCC and Potential Implications for Voice Peering K.C. Halm

Internet Interconnection An Internet Society Public Policy Briefing

ETNO Reflection Document in response to ECC/ CEPT consultation on Fixed-Mobile Convergence with Survey of Numbering Related Issues

Re: Protecting and Promoting the Open Internet, GN Docket No

Notice of Ex Parte Presentation, CC Docket No , Developing A Unified Intercarrier Compensation Regime.

Posted October 17, 2006 QWEST CORPORATION COMPARABLY EFFICIENT INTERCONNECTION PLAN FOR ENHANCED DIRECTORY ASSISTANCE

OTT Services Balancing Innovation, Investment and Competition

Response to public consultation on a proposal for an EC Regulation on mobile roaming charges in the Single Market. OnAir.

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C

SECTION 2-13: CARRIER PRESELECTION ACCESS SERVICE

PCS Poised to Capture Landline Revenues

The Waterbed Effect Explained in Relation to Roaming An Economics Perspective

Regulating and pricing network access

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

BCN Telecom, Inc. Customer Proprietary Network Information Certification Accompanying Statement

FN1. The Honorable James E. Gritzner, United States District Judge for the Southern District of Iowa.

AT&T Billing Glossary

ARCT. co consumer ISSUE. ES committe EACO GUIDELINES G SERVISES (DRAFT)

Telecommunications Regulation. TAIWAN Tsar & Tsai Law Firm

December 21, 1998 BY ELECTRONIC MAIL AND HAND DELIVERY

Before the Federal Communications Commission Washington, D.C

The Economics of Mobile Interconnection Rates in South Africa

BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C ) ) ) ) ) REPLY COMMENTS OF THE USTELECOM ASSOCIATION

Comments of GVNW Consulting, Inc.

Before the FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C ) ) ) ) ) ) ) ) ) ) ) COMMENTS OF THE TELECOMMUNICATIONS INDUSTRY ASSOCIATION

The Evolution of Internet Interconnection from Hierarchy to Mesh : Implications for Government Regulation. May 5, 2014

African Union (AU) International Mobile Roaming Guidelines September

REPUBLIC OF IRAQ COMMUNICATIONS AND MEDIA COMMISSION

ver1 on If you have questions, please contact me either at (888) or October 26, 2015

NECA Debate Intercarrier Compensation, Universal Service & Telecom Legislation. John T. Nakahata Harris, Wiltshire & Grannis, LLP September 19, 2005

OUTLINE. I Overview: the Challenge of NGNs for regulation. Outline

Geo-blocking and its impact on consumers

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C COMPARABLY EFFICIENT INTERCONNECTION PLAN

Innovation, Resource Constraints, and Mergers in Network Industries

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C

Regulatory Guide of Local Access Charge

July 23, 2015 VIA ELECTRONIC FILING. Marlene H. Dortch, Secretary Federal Communications Commission th Street, SW Washington, DC 20554

1.1 What is Microeconomics?

The Mixed Blessing of a Deregulatory Endpoint for the Public Switched Telephone Network

1717 Pennsylvania Avenue, N.W. 12 th Floor Washington, D.C November 6, 2014

Migrating to IPv6 The Role of Basic Coordination

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C COMMENTS OF VONAGE HOLDINGS CORP.

BNetzA therefore requests a BEREC Opinion on the above measures until June 1.

Frontier Telephone Companies TARIFF FCC NO. 3 1st Revised Page 3-1 Cancels Original Page 3-1 ACCESS SERVICE

Re: Connect America Fund, WC Docket No Developing a Unified Intercarrier Compensation Regime, CC Docket No

Lex Mundi Telecommunications Regulation Multi-Jurisdictional Survey

THE CODE COMPLIANCE PANEL OF PHONEPAYPLUS TRIBUNAL DECISION

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C

U.S. Regulatory Framework for ILEC Unbundling Obligations in the Context of Fiber Loop Deployments

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C

Michael Pierce Public Utilities Regulatory Analyst, Communications Division

VERIZON MARYLAND LLC 1. Performance Assurance Plan. Maryland

Advances in Regulatory Pricing and Costing in the Digital Economy: VoLTE Interconnection Issues

VERIZON HAWAII INTERNATIONAL INC. Federal Rate Schedule 1 Original Title Page INTERNATIONAL PACKET SWITCHING SERVICE TITLE PAGE

Wholesale Very high bit-rate Digital Subscriber Line (VDSL) Service

Interconnection Policies and Rates Setting

The Impact of the Call Termination Rate Reduction on Consumer Surplus in South Africa

RATES AS OF OCTOBER 1, 2015

MOBILE TARIFFS ANALYSIS 1 APRIL TO 30 SEPTEMBER 2018

Telecom Decision CRTC

Service Any or all services by the Company provided pursuant to this Business Service Guide.

Before the. Federal Communications Commission. Washington, D.C ) ) ) ) COMMENTS OF PUBLIC KNOWLEDGE AND THE NEW AMERICA FOUNDATION

12 Approval of a New PRESTO Agreement Between York Region and Metrolinx

OPUC Transmission Workshop 2 FERC Pro Forma Transmission

BT Assure Cloud Identity Annex to the General Service Schedule

IXP Policy Considerations

CENTURYLINK OPERATING COMPANIES TARIFF F.C.C. NO. 11 2ND REVISED INDEX PAGE 8-0 CANCELS 1ST REVISED INDEX PAGE 8-0 ACCESS SERVICE

Consistent Measurement of Broadband Availability

OECD Experts Meeting on Telecommunications Services

SUBJECT: PRESTO operating agreement renewal update. Committee of the Whole. Transit Department. Recommendation: Purpose: Page 1 of Report TR-01-17

ITU SURVEY ON TARIFF POLICIES 2014

Transcription:

Bill and Keep as the Efficient Interconnection Regime?: A Reply PATRICK DEGRABA * Charles River Associates Abstract In a critique of my paper outlining the Central Office Bill and Keep (COBAK) proposal, Wright (2001) offers two sets of conditions under which a COBAK interconnection regime would not lead to optimal utilization. While there could be conditions under which some interconnection regime other than COBAK would lead to higher social surplus measures in very simple models of telecommunications, the critique provides no evidence that these conditions would be empirically significant. This, along with the other considerations explained in the proposal and not considered in the analysis, continue to suggest that COBAK is an appropriate policy recommendation. 1 Introduction The Telecommunications Act of 1996 was designed to reduce regulatory intervention in the provision of telecommunications services in the United States, and afford the marketplace a greater role in providing and pricing telecommunications services. The transition from monopoly to competition necessitated the development of, among other things, a consistent set of rules governing inter-network calls. The purpose of my COBAK proposal 1 was to present an implementable set of rules that could be applied consistently across all forms of interconnection. 2 A major goal of the COBAK proposal is to show that efficient pricing could be attained under an interconnection regime that acknowledges communication is a shared service from which both the calling and the called party benefit, and accordingly requires the parties to share the cost of calls. 3 It also identifies a number of practical areas in which COBAK would improve upon the existing interconnection regime independent of any externalities that exist between the calling and called party, including eliminating many existing regulatory arbitrage opportunities, reducing the need for regulators to monitor and determine the * Mailing address: 1201 F St NW, Suite 700, Washington DC 20004, U.S. E-mail address: PDeGraba@crai.com Nothing in this paper necessarily represents the views of Charles River Associates, nor any of its clients. 1 DeGraba (2000b), henceforth COBAK paper. 2 The FCC recently issued an NPRM seeking comment on the implementability of bill-and-keep interconnection regimes as proposed in the COBAK paper and in another FCC working paper, Atkinson and Barnekov (2000). 3 The bulk of prior analysis has assumed that the caller derives all of the benefits from a call and, therefore, properly assumes the entire cost of interconnection. 61

incremental cost of individual networks for the purpose of setting cost-based interconnection rates for each network, and reducing the need to update such findings as the technologies of these networks evolve. COBAK will also eliminate the expense networks currently incur in determining how many minutes pass from one network to another. Thus, COBAK offers an interconnection regime that can both generate efficient prices and solve many of the practical problems facing the industry. 2 Response to the criticisms The critique by Wright (2001) focuses on the results of COBAK that depend on how the benefits of telecommunications are divided between calling and called party. Such a critique of policy recommendations can both advance the pure theory by focusing in greater detail on specific aspects of the proposal, and may result in additional policy recommendations. To begin, I disagree with Wright s claim that the COBAK paper argues that COBAK is efficient per se. Paragraph 4 of my paper states that COBAK is appropriate when a number of assumptions hold, one of which is that both the calling and called parties typically share in the benefits of a call. 4 More generally, determining appropriate interconnection rates is an empirical matter. The interconnection regime will affect a vast number of decisions, including usage levels by customers, subscription levels of customers, choices by carriers of which technologies to adopt, attempts by carriers to engage in regulatory arbitrage, and decisions made by regulators. An appropriate policy must balance the costs and benefits among all of these decisions. At a more specific level, Wright states that Two fundamental problems with the COBAK approach that are not addressed by DeGraba are its failure to internalize network externalities between the calling and the called party and its failure to apply Ramsey principles to the recovery of joint costs (see section 4 of his critique). 2.1 Accounting for the call externality I address these in reverse order. To illustrate his second point, Wright argues that there are some calls for which the calling party receives most of the benefit. He then argues that a bill-and-keep interconnection regime would under-allocate the cost of the call to the calling party. He states, In fact the assumption that the called party has no willingness to pay may be closer to reality in many situations than DeGraba s implicit assumption that the willingness to pay of the calling and the called parties is always equal. This problem can be viewed as a Lindahl problem, in which the cost of a public good (a minute of calling) is divided between consuming parties (called and calling parties). In the Lindahl problem, parties should contribute to the cost of a public good in proportion to the incremental benefit they derive. If the benefits of all minutes of callings are shared equally, then users should share the costs equally. 4 See also footnote 53 of the COBAK paper. 62

The COBAK analysis does not require that for every minute of calling the called and calling parties share the benefits equally. 5 It is consistent with the weaker assumption that there is some distribution over the division of the benefits across calls, and that the distribution is centered on a roughly even division of the benefits. DeGraba (2000a) does show that when customers share equally in the benefit of each call and competing carriers have access to the same technology, a bill-and-keep regime that equally divides the costs results in first best utilization. 6 DeGraba (2000a) also shows that, with a symmetric distribution over the division of benefits between the calling and called parties, a bill-andkeep interconnection regime represents the most efficient cost allocation system. For distributions that are weighted towards the calling party receiving more of the benefit, the calling party should pay more than half the cost of the call. COBAK actually imposes more of the cost of the call on the calling party, since the calling party pays for originating switching and all transport, while the called party pays only for terminating switching. 7 2.2 Accounting for the subscription externality I found Wright s first example more interesting. He argues that there should be a positive termination charge paid by wireline networks to wireless networks when wireline customers call wireless customers. The reason is that customers on the wireline network receive a benefit when more customers join the wireless network. When such a termination charge exists (and no termination charge is paid by calling parties on the wireless network to other parties on the wireline network), the wireless carrier will lower its subscription rates, which will increase the number of customers subscribing to the wireless network. Wright then argues that the additional subscription resulting from the lower prices benefits society. Since all wireless customers presumably also subscribe to the wireline network, the benefit comes in the form of increased accessibility provided by mobile phones. The analysis assumes an asymmetry between wireline and wireless subscription. That is, raising the price of service to wireline customers causes little reduction in wireline network subscription and usage, but decreasing the rate to wireless customers causes a significant increase in new wireless subscriptions. If the interconnection charge is viewed as a tax, then his analysis can be viewed as saying that taxing an inelastically demanded service (which in this case is assumed to be subscription to the wireline network) to subsidize a service that is both elastically demanded and under-demanded by the market (wireless subscription) can be welfare-improving. Thus, for example, making the extreme assumptions that customers inelastically subscribe to the wireline network and that all local service is flat-rated, implies that an increase in termination charges imposed on the wireline network would result in an 5 Even if such an assumption were made, the statement that there are some calls for which the calling party receives no benefit by itself is not a valid criticism of COBAK or any other interconnection regime. Clearly, if different calls have different distributions of benefit, then there is no single interconnection rate that will ensure a first best allocation for each call. Thus, by Wright s logic, the fact that there are some calls for which both the calling and the called parties share the benefits equally, would imply that a calling party pays interconnection regime would not be efficient. 6 On the other hand, it is relatively simple to show that if the calling party receives the entire benefit of every call, then a calling party pays interconnection will lead to efficient utilization. 7 This of course applies to interconnecting networks with similar technology and therefore costs. 63

increase in the flat local rate. This does not effect wireline network subscription or usage. The increase in termination revenue in the wireless network causes wireless carriers to lower subscription rates, thus increasing the number of subscribers, and therefore welfare. However, if the termination rates are passed through to wireline customers in the form of per-minute usage charges, usage from wireline customers to wireless customers would fall, which lowers welfare. This welfare reduction would have to be weighed against the welfare increase from additional wireless subscription. The welfare increase does not necessarily outweigh the welfare reduction. In addition if there were some price sensitivity in wireline subscription, then increasing the usage rate would presumably cause some marginal customers to drop off the wireline network, which would further reduce welfare. Thus, it is possible that (wireline to wireless) termination charges can increase welfare, but, as a matter of theory this is not always the case. This analysis by Wright does however provide a useful insight that helps to illuminate a specific aspect of the theory of markets for network goods. This assertion that there may be a welfare gain from imposing a positive termination charge from wireline to wireless networks is not by itself enough to imply that regulators should impose such a charge. If local rates were flat-rated, one would first want to be assured that the elasticity of subscription for wireline service was significantly lower than the elasticity for wireless service. For example, the demand for second lines is likely to be more price-sensitive than the demand for first lines. Thus, an interconnection charge imposed on wireline calling in a market that has flat-rated local service will raise the price of second lines (as well as for first lines), which will reduce the quantity of second lines demanded, thus reducing the accessibility of customers over the wireline network while increasing their accessibility over the wireless network. A second complicating factor is that customers may view wireless and wireline subscriptions as substitutes (i.e., they may cancel their wireline subscription in favor of relying on wireless service to handle both calls at home and mobile calls). A subsidy from wireline to wireless networks would increase the rate of customers substitution from wireline to wireless. To the extent that wireless mobile technology is more expensive than wireline technology, such a substitution would move many calls off the less expensive wireline network and onto the more expensive wireless network, thus reducing welfare. Even if it were determined that such a subsidy could increase overall welfare, a series of problems (outlined in the COBAK analysis) would be encountered that might make implementation expensive enough or imprecise enough to negate much or all of the potential benefit. Briefly these include (i) the fact that it would be difficult for regulators to obtain the necessary cost and demand elasticity data to set appropriate rates, 8 (ii) differential termination rates create incentives for carriers to engage in regulatory arbitrage, 9 and (iii) the termination rate may lead to carriers choosing an inefficient technology. Finally, while COBAK prevents one network from demanding termination payments from another network that delivers a call to the called party s central office, it 8 There is a sizeable literature dedicated to discussing those mechanisms regulators can use to persuade firms to reveal their true costs. 9 For example if there were no termination charges between wireless carriers a wireline carrier that also owned a wireless carrier could launder calls originating on its wireline network through its wireless network and avoid termination charges. 64

does not prevent carriers from charging customers on other networks directly. 10 Thus, in the United States for instance, COBAK does not prevent the use of 800 or 900 services. Such retail solutions could yield different equilibria than those arising from government mandated interconnection regimes. One difference between allowing a carrier to bill calling parties directly and allowing termination charges is that customers must agree to purchase the service where the carrier charges the calling party directly. Thus, rather than imposing termination charges on all customers, allowing for a market solution allows each individual customer a choice of whether or not to charge people who call him or her. 3 Conclusions The COBAK proposal presents an interconnection regime in which there need be no termination charges for calls that cross networks. The FCC has recently initiated a proceeding to seek comments on implementing such a regime. Julian Wright has presented a number of empirical conditions under which COBAK might not lead to efficient utilization of the network. The FCC proceeding will present an opportunity to determine if these or other criticisms of COBAK are enough to prevent the U.S. telecommunications industry from adopting some form of bill and keep interconnection. 4 References Atkinson, J. and C. Barnekov (2000) A competitively neutral approach to network interconnection, Federal Communications Commission, OPP Working Paper #34. DeGraba, P., (2000a) Efficient interconnection for competing networks, Working Paper. DeGraba, P. (2000b) Bill and keep at the central office as the efficient interconnection regime, Federal Communications Commission, OPP Working Paper #33 (2000b). Wright, J. (2002) Bill and keep as the efficient interconnection regime?, Review of Network Economics, 1, 54-60. 10 Note that the carrier would not need to physically render a bill to such a party, but rather pay the party s carrier to bill the customer with that customer s local phone bill, much as wireline carriers currently provide billing services for long distance carriers in the U.S. 65