 Breaking Down the FCC Order: FCC Delays CMRS Bill-And-Keep
Posted by: on Jan 16, 2012
This blog is an update to an earlier blog titled FCC Order Released.
The FCC adopted an Order on Reconsideration on December 23, 2011. In the FCC USF/ICC Reform Order, effective December 29, 2011, Section XV. C. titled LEC-CMRS Non-Access Traffic says for LEC-CMRS intraMTA traffic subject to reciprocal compensation, the FCC is adopting a bill-and-keep methodology immediately. Since the transitional recovery mechanism does not begin until July 1, 2012, the Order on Reconsideration is now delaying the bill-and-keep methodology accordingly.
The Order on Reconsideration only affects existing, effective interconnection agreements governing the exchange of LEC-CMRS non-access (intraMTA) traffic and will enable carriers to continue to exchange traffic and receive compensation pursuant to these agreements until July 1, 2012.
The FCC strongly urges all parties with interconnection agreements to immediately begin preparations for the July 1 effective date of the transitional recovery mechanism, including by commencing discussions regarding change-of-law provisions, if applicable. In other words, they expect the parties to take the time between now and July 1 to renegotiate your interconnection agreements to adopt a bill-and-keep methodology meaning a $0.00 reciprocal compensation rate for intraMTA traffic.
The FCC is not abrogating existing commercial contracts or interconnection agreements but expects the bill-and-keep methodology to be requested when renegotiating these contracts or agreements. Each rural LEC should review their existing CMRS interconnection agreements looking specifically at the notification period for cancellation or renegotiation and the term of the interconnection agreement and the term for which it automatically renews. You will also want to review the change-of-law section in your interconnection agreement as that may be used to request renegotiation to the bill-and-keep methodology since the FCC included this wording in their Order on Reconsideration.
|
