Global Crossing believes that the FCC's recent decision in the Free World Dialup docket compels it to treat all IP-enabled services as information services subject to exclusive federal jurisdiction.
In comments filed in response to the FCC's Notice of Proposed Rulemaking (NPRM) concerning the proper regulation of IP telephony, Global Crossing argues that "the FCC must establish simple, uniform rules and put an end to the constant gamesmanship that currently plagues the industry."
Key points of Global Crossing's "REFORM" agenda include:
- Rationalize inter-carrier compensation -- the FCC should establish a uniform inter-carrier compensation arrangement that not only recognizes that a "minute is a minute," but also that a "packet is a packet." All traffic exchanged between carriers, regardless of jurisdiction or type (voice, data or video) must be exchanged at a uniform rate to be negotiated between individual carriers without the distortion of past regulatory policies.
- Establish a swift and efficient dispute resolution forum -- this might include an arbitration procedure similar to that used in major league baseball whereby each party to a dispute puts forth its "best and final" offer.
- Formulate clear and simple rules and regulations.
- Overhaul universal service -- it must be sized so that it only supports universal service objectives and so that the fund is not used as an earnings support mechanism for certain carriers; consideration must also be given to alternative universal service funding mechanisms.
- Redefine public interest obligations -- the FCC needs to recognize that the greatest challenge for 911/E911 service is securing proper funding for the Public Safety Answering Points ("PSAPs").
- Maintain authority over "essential" bottleneck facilities.
