On 1/18/13 6:30 PM, Nathan Anderson wrote:
For the purposes of USF and the 499 A/Q filing process, the FCC does not restrict "interconnected VoIP" carriers to those who have actual interconnection agreements with LECs and the facilities necessary to carry out those interconnections. Otherwise, again, we could get away with never filing a 499A or Q again or paying into USF (right now we are still "de minimis" but I expect that will probably change within the next year or two).
To quote http://transition.fcc.gov/cgb/consumerfacts/voip911.pdf, which has been brought up in this thread already: To ensure that a consumer's choice of Voice over Internet Protocol (VoIP) for telephone service does not adversely affect that consumer's ability to access emergency services, the Federal Communications Commission (FCC) has taken steps to require that providers of ?interconnected? VoIP services (VoIP services that use the Public Switched Telephone Network (PSTN), including wireless networks, to originate and terminate calls) meet Enhanced 911 (E911) obligations. Or, as I read that, if you can place calls to or from the PSTN you're "interconnected." If you've got some weird system for hooking up intercoms in your 5 factories that has no access to/from the PSTN, they don't care about your "phone system." So just because you're using SIP trunks, instead of PRIs, interconnections to a LEC, or what-have-you, has no bearing at all so far as I know. --Jon Radel jradel at vantage.com 267-756-1014