On November 5, 2013, Level 3 Communications and its VoIP affiliate, Level 3 Enhanced Services (Level 3 ES), filed an ex parte with the FCC that largely mirrored the concerns previously raised by Vonage regarding CenturyLink's refusal to route traffic to telephone numbers assigned to the Level 3 ES OCN over existing Level 3 (the CLEC partner) interconnection trunks. (See November 6, 2013 post, VoIP Numbering Trial Off to a Slow Start). As a result, Level 3 has reported that it cannot initiate testing of call routing under the numbering trial in the Denver market. It also reports that this issue has created potential problems for other carriers who have requested telephone numbers in the A-block obtained by Level 3 ES in the Denver area, because it is unable to activate that block until it can successfully test routing for calls to telephone numbers in that block. Level 3 urged the FCC to "take action to clarify that carriers like CenturyLink may not refuse to route traffic under these circumstances."
In a subsequent ex parte filed on November 12, Level 3 recommended that as part of its investigation into this interconnection issue, the FCC should "not only consider whether CenturyLink's conduct is justified, but it should also seek information about the extent to which CenturyLink is enforcing its policies uniformly." As an example, it noted that CenturyLink routes traffic to Level 3's affiliate Broadwing over existing Level 3-CenturyLink interconnection trunks, but refuses to route traffic over comparable interconnection trunks to numbers assigned to the Level 3 ES OCN. Level 3 suggested that the FCC investigate CenturyLink's treatment of traffic associated with SBCIS, a non-carrier similarly situated to the VoIP trial participants, that has been permitted for years to obtain telephone numbers under its own OCN. Does CenturyLink demand that AT&T also obtain dedicated trunks for traffic destined for numbers assigned to the SBCIS OCN?
Another interesting comment from Level 3's November 5 ex parte is that it initially sought direct IP interconnection to support its VoIP trial traffic, but reported that "[i]n general, those efforts were unsuccessful." This experience may give the FCC valuable input as to whether giving interconnected VoIP providers direct access to numbers on a permanent basis will help accelerate the negotiation of IP interconnection agreements.
See previous articles regarding the FCC's VoIP Numbering Trial from Sharon Thomas: