Perhaps as a tribute to the memory of the Canadian Cable Telecommunications Association, the CRTC released a decision on Monday, coinciding with the annual conference of the Canadian Cable Systems Alliance – the association of smaller cable companies.
Decision 2006-58 relieves certain smaller competitive local exchange carriers (CLECs) of the requirement to provide equal access to competitive long distance providers. The CRTC has accepted yet another new term into the lexicon: small CLECs. These companies satisfy all three of:
- They are non-dominant Canadian carriers;
- They offer local VoIP services through a reseller; and
- They have fewer than 10,000 local exchange service telecommunications subscribers.
If these conditions are met, then a small CLEC does not have to provide equal access. The CRTC justifies the decision in part by saying “local VoIP service offerings, as currently marketed, do not generally have a discrete long distance component.”
Hmmmm. There must be different ads getting distributed in Hull. While many of the ads for VoIP I see have North America or European bundles, I think all of them have variable rates for the rest of the world. But the Commission has another rationale.
In trying to look at a technology justification,
The Commission notes that the equal access obligation is imposed on the originating carrier of the call and requires an examination of the dialled digits, either at the PSTN level or at the first softswitch of the VoIP provider, to determine whether the call is long distance or local.
What about the problem that all internet voice service providers have for access independent VoIP? Where should equal access interconnection take place for a Bell Digital Voice Lite subscriber, who lives and gets their bill in Montreal, but has a Toronto phone number calling England while sitting in a hotel room in Hong Kong?
The CRTC needed to do this tinkering of its VoIP Decision at the fringe to enable small cable companies to remarket pure reseller VoIP products as part of a bundle.
The problem with their tinkering is that it breaks the CRTC’s sacred principle of technological neutrality. If VoIP is the same as regular voice, what difference does it make that there are less than 10,000 lines? A regular CLEC of the same size, offering traditional voice, has to fulfill all of the obligations, including equal access. How is this technically neutral?
It would have been simpler and cleaner for the CRTC to just remove the equal access obligation for all access independent VoIP services, regardless of the size of the service provider. That approach would have acknowledged that nomadic voice is a lot more like mobile voice. That approach would have been consistent in preserving technological neutrality.
I’ll have my wife call the decorator.
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CRTC, CCTA, CCSA, VoIP, Mark Goldberg