BEFORE THE FEDERAL COMMUNICATIONS COMMISSION Washington, D ...

BEFORE THE
FEDERAL COMMUNICATIONS COMMISSION

Washington, D.C. 20554

In the Matter of )
Rural Call Completion ) WC Docket No. 13-39
)

REPLY COMMENTS OF THE PUBLIC SERVICE COMMISSION OF WISCONSIN

The Public Service Commission of Wisconsin (PSCW) filed comments1 in this docket2

on May 9, 2013. As in those initial comments, the PSCW encourages the FCC to take up this

call completion matter in a timely manner, to take steps to identify call completion problems

though the appropriate tracking of calls and the dissemination of provider call completion

statistics, and to consider certain specific approaches to some of the Commission’s proposals.

The PSCW has reviewed other filed comments and offers a few brief observations

thereon:

• The PSC commends the recommendations of the NARUC3 (as subsequently endorsed by
14 other state commissions4) as appropriate responses to the chronic and real issues of

call termination problems experienced in many states. The NARUC suggestions for

enforcement, and not just data collection, should be carefully evaluated in determining

the spread and depth of the provider obligations imposed in this investigation. As

1 Comments of the Public Service Commission of Wisconsin, dated May 9, 2013, (PSCW) in WC Docket 13-39.
2 See, In the matter of Rural Call Completion, WC Docket 13-39 (rel. Feb.7, 2013), Public Notice, DA-13-780
(rel. Apr. 18, 2013) (NPRM).
3 Comments of the National Association of Regulatory Utility Commissioners (NARUC), dated May 8, 2013, in
WC Docket 13-39.
4 Joint State Commission Comments. These joint comments were from state commissions in California, Idaho,
Indiana, Iowa, Michigan, Minnesota, Montana, Nebraska, New York, Ohio, Pennsylvania, South Dakota, Vermont,
and West Virginia.

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suggested by NARUC, the Commission should consider all efforts that can help “ensure
call failure causes are timely identified and either resolved or enforced in a meaningful
way.”
• NARUC, at page 15 of its comments, asks the Commission to “require strict compliance
with ATIS-0300106 Intercarrier Completion/Call Termination Handbook.5” In
comments from Cbeyond, Earthlink, Integra, and TW Telecom,6 those providers also
endorse the ATIS handbook, specifically, the framework of Section 6.1 as “the departure
point for developing rules mandating information exchange and problem resolution
between carriers.” As the PSCW has noted, information sharing is a critical piece of the
solution to these issues. Efforts of ATIS (a cooperative industry organization) to get
providers conversing and collaborating on problem identification and corrective actions
can be an effective means of gaining more immediate and real-time troubleshooting of
ongoing call concerns. As the PSCW noted earlier, “Many are suffering real harm, both
fiscal and non-fiscal, by being subject to calls that cannot be completed, or that have such
low quality that communication is impossible.7” This problem has lingered too long; any
approaches that can lead to short-term calling resolutions or ultimate long-term solutions
must be entertained. Adding emphasis to and an increased use of already-existing
industry methods to track down and remedy call completion difficulties should be
pursued.

5 Alliance for Telecommunications Industry Solutions, ATIS Standard on Intercarrier Call Completion/Call
Termination Handbook, ATIS-0300106 (rel. Aug. 2012).
6 Comments of Cbeyond, Earthlink, Integra and TW Telecom, dated May 13, 2013, in WC Docket 13-39.
7 PSCW at page 1.

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• CenturyLink suggests that “Any reporting, record keeping and retention requirements
should be limited to interstate calls.8” The PSCW disagrees. Both intrastate and
interstate calls are failing to complete; customer experience is the same regardless of the
call jurisdiction. Given the widespread inability of some consumers to get calls, to make
calls, or to communicate effectively on those calls, imposing jurisdictional limits on
remedies will not serve the ultimate consumers in the rural areas of the country.
Especially in the circumstances where there are increasing moves to deregulate at the
state level, to limit state authority on some telecommunications activities, or where
jurisdiction is, at best, subject to litigious debate, attempts to restrict the possibility of
remedy should not be withheld. The PSCW suggests that the FCC must craft appropriate
remedies to this problem that will allow successful calling attempts no matter where
those calls begin or end.

The PSCW again commends the Commission for moving forward on this issue and
encourages that further definitive action, sooner rather than later, is needed for the benefit of
quality telecommunications to and from all parts of the United States.

Dated at Madison, Wisconsin, this 22nd day of May, 2013.
By the Commission:

Sandra J. Paske
Secretary to the Commission

DL: 00728213

8 Comments of CenturyLink dated May 13, 2013, in WC Docket 13-39, at page 9.

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