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November 23, 2009

COUNT YOUR COWS

A cell on wheels, usually referred to as a COW, is a mobile cell site that consists of a cellular antenna tower and electronic radio transceiver equipment on a truck or trailer, designed to be part of cellular network. These sites are used to provide expanded cellular coverage or capacity at major sporting events, conventions or in disaster areas where cellular coverage either was never present or was compromised by the disaster.

Cost management tip: It is a good idea to do a periodical inventory review of leased circuits associated with the COW sites. While some COWs are being used for an extended period of time, others are just a one time deal, a temporary solution. Disconnect leased facilities where COW is no longer needed.

So count your COWs. Maybe some of them already left your pastures.


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November 19, 2009

Advantages to an email repository for disputes

An email repository is a location where email messages can be sent and stored, and access is shared among several employees. There are several advantages to keeping an email repository for filing billing disputes. First, you have an easy tracking method of when disputes were filed with the vendor and any important correspondence. Second, the repository can be set up so more than one individual can view the repository. If someone on the team is out of the office, another team member can easily step in and help with the absent coworker’s disputes until he or she returns. When the individual returns to the office, they know what other team members did on their work. Third, if issues come up in the future regarding disputes, resolutions, etc., then the email repository can support your position.


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November 05, 2009

CLEC Access Reform: Rural Exemption Enables Traffic Pumping

The phenomenon known as traffic pumping has, at its core, a requirement for high switched access rates. Given the benchmarking requirements set forth by the FCC in its CLEC Access Reform rulings (often referred to as the Seventh and Eight Reports and Orders) there is limited opportunity for competitive local exchange carriers to charge rates high enough to rationalize traffic pumping and the associated relationships with free calling service companies. The small minority of carriers that do characterize themselves as rural exempt.

So, what does this mean?

As part of the rulings, a CLEC is required to “mirror” the rates of the dominant incumbent local exchange carrier (ILEC) for interstate switched access. Most often, this is one of the regional bell operating companies (RBOCs). The FCC carved out a set of criteria by which a CLEC could exceed the ILEC rate. Specifically, if the CLEC competed with a non-rural ILEC and served only customers from areas with a population less than 50,000, then it was afforded the ability to charge the highest banded rate from NECA FCC No. 5. The next logical step in the progression here, then, is traffic pumping migrated to CLECs whose service area illustrated they served only rural geographic areas. Thus, these CLECs could theoretically gain the benefit of the higher switched access rates and the high volumes of traffic associated with traffic pumping.


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November 04, 2009

Google Voice Victimized by Traffic Pumpers

Its not just the traditional fixed line operators that are falling victim to traffic pumping. These days traffic pumpers are branching out and taking advantage of new communications technologies, as well as the companies bringing them to market. Just this past weekend The New York Times ran an article explaining that Google's' Voice service had been victimized by traffic pumpers located in and around rural America. (See: Why Google Doesn't like Its Phone Bill - www.nytimes.com/2009/11/01/business/01digi.html)

Under the Common Carrier laws, long-distance companies must provide universal terminations. They can not block calls to other carriers. And, in rural areas long distance carriers are required to compensate local telephone companies for calls originating and terminating to and from those networks. When long-distance carriers connect to those local networks, they may be charged excessively high rates to connect. And, as a result of this loop-hole, local carries in rural areas can take advantage of the inter-carrier compensation system. They do it by partnering with and sharing revenue generated from services that "pump" lots of calls onto their networks. Services that generate lots of in-bound calls include such things as adult pornographic chat lines, free conference calling services, and party lines.

When Google discovered what was happening last August they began blocking outbound Google Voice calls to a small number of these rural numbers. This, in-turn, prompted AT&T's complaint to the FCC that Google Voice should be treated the same as other traditional phone services. The ensuing battle ultimately led to the Google Voice application being rejected from the iPhone App Store. Google's claim was that since they are providing a free, Web-based software application, and are not technically a phone company, they should not be held to the same common carrier laws that other long-distance carriers must adhere to. Regardless of whether Google should be called a long-distance provider, or not, one thing it does have in common with the rest of the industry is that our current carrier compensation system is broken, outdated, and in need of help from the FCC to fix it.

At this point it is unclear when the FCC will take up this matter and issue a formal decision. But, one thing is clear -- as communications technologies continue to converge, we will see more companies like Google fall victim to traffic pumpers. As long as the current loop-holes in our carrier compensation system remain, traffic pumpers will continue exploiting them at the expense of more victims.


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