Agreed on Mary Lou, she knows her stuff and can help navigate the waters especially when it comes to ordering. Some questions you may want to ask yourself: Why make the step? Are there features or capabilities you are missing, or just a lack of control you want to address? Does this make business sense after adding up all the different recurring and start-up costs? Do you have the right geographical concentration for this to make sense (from the OP sounds like you might). Do you and/or your staff have SS7 knowledge and equipment that can handle it already? Neither of these are particularly cheap. Do you have an understanding of the local PUC's working rules and what it will take to get a CLEC license? Is this even possible in your specific situation (some PUCs are very tight on issuing new licenses)? Do you have a good telecom Attorney that can help you interpret and negotiate your ICA with the iLEC? Do you know who else is in the market to compare their ICA? Do you understand the local LEC infrastructure including how many LATAs, Tandems, RC, and different LECs you may need to interconnect to? Is there more than one iLEC covering the areas you wish to serve? Are you planning for Tandem trunking or do you have a reason to build out End-office trunks? What are your capacity needs? Do you have a staff to handle LNP, 911, and other "provisioning" tasks? How about systems to track it all? The FCC now has turnaround requirements on simple ports as low as one day you'll need to be able to meet. What are you not going to handle on your own? TF RESPORG is one good example that smaller CLECs don't jump right into. You'll still need other carriers for LD and International as well. Have you taken into account supplementary services like e911 (you'll need a listing provider like Intrado if you plan to have local trunks, or a nomadic solution like Bandwidth/Dash/iNetwork and 911-enable), OSDA, CNAM and LNP dipping? Some other items you'll want to research include the costs and processes for getting the other details setup, like switch CLLIs, point codes, OCNs, TN block assignments... Hope that helps, -Scott -----Original Message----- From: voiceops-bounces at voiceops.org [mailto:voiceops-bounces at voiceops.org] On Behalf Of Ryan Finnesey Sent: Wednesday, October 17, 2012 8:19 PM To: Anthony Orlando Cc: VoiceOps Subject: Re: [VoiceOps] Direct CLEC interconnect - taking the plunge Backup Telecom is great. Sent from my iPad On Oct 17, 2012, at 8:14 PM, "Anthony Orlando" <avorlando at yahoo.com> wrote:

Backup Telecom would be my first choice. Mary Lou Carey. She's on this board.

On Oct 17, 2012, at 18:39, Jay Hennigan <jay at west.net> wrote:

...

We are a regional hosted VoIP provider in California. We started as an ISP and moved into becoming a CLEC offering VOIP. As is probably the case with most, we started buying DIDs from wholesale carriers as SIP trunks. The majority of our customers are within a single LATA with a large minority in an adjoining one.

We are investigating the feasibility of direct interconnect with the RBOC/ILEC via SS7.

I'm interested in pointers/gotchas as well as recommendations of a consultant to help us navigate the maze, both from a political and technical standpoint. Suggestions as what not to do or who not to hire are also welcome.

Please feel free to respond on-list or off as you feel appropriate. -- _______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

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Yet another recommendation here for Mary Lou, we have used her with much success since our transition into becoming a CLEC. I still call her regularly with questions; an infinite source of knowledge! I think Scott really hit the nail on the head here. The ONLY real reasons to become a CLEC nowadays are access to customer loops, LEC duct, and right-of-ways. That's about it. The whole experience is, quite bluntly, a pain in the ass. When you aren't dealing with the usual regulatory upkeep; prepare for the LEC to fight you tooth and nail every step of the way. If you are still committed to this, now is the time to address all of the things you won't want to deal with later. If you're going to colocate in the CO, how are you going to bring connectivity to it? Is there dark fiber inner-office transport available? Are there other colocators there you can source this from? Are you going to be using remote entrance facilities? Is there duct available for you to utilize? (~$2/ft mrc) Is there a decent customer base you can service with DSL? What is the condition of the phone lines? Is it an old farm town with 100+ year old paper-insulated copper pairs that are going to cause your customers issues? Time-wise, it is feasible for one person to manage all of your CLEC billing, ordering, numbers and portability, AOCN stuff, etc. BUT that WILL be that persons FULL TIME job. Don't trick yourself into thinking you can tackle all of these things and then your normal daily tasks. Hire someone full-time to deal with all of your ordering/support/carrier and lec responsibilities, and have Mary Lou train that person. Specific Gotchas: -Make sure the LEC does not require you to have E911 trunks to every area you have DID blocks in!!! Since you are a VOIP provider operating in a few areas, you likely will want to have DID blocks local to different areas. The LEC could force you to have circuits in every area with ambiguous ICA wording. -Make sure your ICA has the verbage that dictates the 25% utilization limit of spare strands does not apply to instances where 6 or less strands exist. -Obtain, in writing, with contact names and numbers the exact process in which you request a dark fiber inquiry/field survey. Hint hint: if they are saying you need to fill out an ASR; that not correct. -Make sure you complete a pre-construction site visit request for COs you're interested in BEFORE you colo or even start the application process. Use this visit to make sure rooftop is available where you need it to be, and take a look at the collocation areas; write down the names and numbers (usually on the racks and cages) of the other colocators. These guys will be your best friends when it comes to getting IP in and out of that CO on the cheap. Get quotes and your network layout done BEFORE jumping into the colo. Do not count on LEC transport being available, feasible, or cheap. -Separate everything, everything, everything into different corporations and BANs. When possible while peering/interconnecting with other colocators, have THEM order the cross-connect loops to have them on separate BANs. Make sure your billing dispute sections in your ICA do NOT require a deposit of payment in question before being able to dispute it, and that it does NOT allow the LEC to terminate your access trunks for non-payment, even on disputed amounts. Basically, you do not want the LEC to be able to extort money from you by killing your access trunks. You WILL have billing disputes, you WILL be asked to pay absolute incorrect nonsense. Incorrect nonsense that could get into 6 figures. Do you really want to be forced into paying an erroneous $100,000+ amount to have your service restored? Have a good telcom attorney, and be ready to pay him or her lots of money. -Figure out how your PUC handles complaints, disputes, and mediation. Look up previous CLEC-LEC issues with the PUC and inform yourself of some of the pitfalls they are currently experiencing. Now is your chance to slide language into your ICA that may prevent you from falling into the same issues and might actually give your CLEC buddies ground to stand on with their requests. -Keep DETAILED CIRCUIT LOGS, with PONs, CFAs, etc. If you have the programming ability, design your own ordering system and apply for XML Gateway ordering. Store a copy of all orders. -Apply for refund money from the LEC. AT&T has a program for CLECs in CA to be compensated when they miss order deadlines, turnups, etc. It is automatically calculated and paid if you are registered. Some fellow CLECs in the area are making thousands per month on this. -Do NOT account for termination fees in your business model. -Install and use an internal wiki religiously. Every contact you make, every scrap of information you gather. Names of engineers, technicians, CO managers, tricks for ordering/templates. -MAKE FRIENDS WITH EVERYBODY, NO MATTER WHAT. No matter how wrong the LEC is, no matter how much you think they are intentionally screwing you around, stay polite, friendly, always. No threats of legal action, no harsh words, do not cite ICA or reman text if you can help it, do not pass go, do not collect $200. Explain your requests in a friendly, personable manner, and only cite backup documentation or examples if you need it. Avoid debates on language. It doesn't matter what is written, you get things done by knowing who to ask and how to ask. Plain and simple. Create a budget for taking LEC personnel out, for sending them gift baskets, thank yous. Keep in touch with them (you are storing there contact information in your new wiki right?). Don't over-burden them, don't overwhelm them with requests. Try to avoid escalations if at all possible, they just make people less eager to help you. I certainly wouldn't like it if you demanded to speak to my 'boss' because you didn't like an answer I gave you on something I didn't feel you were entitled to; and I would be less inclined to help you with future requests. Remember, these people do not share your viewpoint or interest in getting things working for you. In their eyes, you are coming into their facilities, and using their network to steal their own customers.. So be nice. -Expanding upon above: This industry is very very large, but very very tiny at the same time. You will run into all of the same people over and over again. Bear that in mind. -In regards to call completion.. going through the LEC is not as easy as dumping your calls to various sip carriers. When you have call completion issues (you will), you can't just pick up the phone an ask the LEC to fix it. They'll do an SS7 trap for you and ensure they are passing the call along proper (and it is difficult to get them to do that! Remember: it's who you know..) It is your responsible to work out all routing/translations issues with the other carriers. Start building your contact list now, and again, friendly. There are only a few individuals at every major carrier on this planet that deal with routing/translations. Make them like you. Your business will come to a grinding halt real fast if one day half or more of your customer base can't seem to dial Verizon or Sprint or whoevers numbers in a certain area for some reason, and you don't have a contact over there to help you with that. Don't think going through their support lines, whoelsale lines, or NOCs are going to get you anywhere either. -Create and enforce trading partner agreements!!! Now is your chance to get all of the contact information you ever wanted. When you receive a port-out request, force the porting carrier to first establish a 'trading partner agreement'. Send them a form to fill out, and detail your procedures (where they need to send there requests, to whom, what to include) but also force them to fill out call completion issue contact information, their own procedures for handling port outs, escalation lists, managers names and numbers. They WILL get it and give it to you. Verify it all before allowing a port. Good luck! Feel free to call me any time with questions as well, Joe Fratantoni Cygnus Communications 19635 97th Ave Mokena, IL 60448 815.680.5686 x206 Business Internet & Phone Services On 2012-10-17 21:19, Scott Berkman wrote:

Agreed on Mary Lou, she knows her stuff and can help navigate the waters especially when it comes to ordering.

Some questions you may want to ask yourself:

Why make the step? Are there features or capabilities you are missing, or just a lack of control you want to address? Does this make business sense after adding up all the different recurring and start-up costs?

Do you have the right geographical concentration for this to make sense (from the OP sounds like you might).

Do you and/or your staff have SS7 knowledge and equipment that can handle it already? Neither of these are particularly cheap.

Do you have an understanding of the local PUC's working rules and what it will take to get a CLEC license? Is this even possible in your specific situation (some PUCs are very tight on issuing new licenses)?

Do you have a good telecom Attorney that can help you interpret and negotiate your ICA with the iLEC? Do you know who else is in the market to compare their ICA?

Do you understand the local LEC infrastructure including how many LATAs, Tandems, RC, and different LECs you may need to interconnect to? Is there more than one iLEC covering the areas you wish to serve?

Are you planning for Tandem trunking or do you have a reason to build out End-office trunks? What are your capacity needs?

Do you have a staff to handle LNP, 911, and other "provisioning" tasks? How about systems to track it all? The FCC now has turnaround requirements on simple ports as low as one day you'll need to be able to meet.

What are you not going to handle on your own? TF RESPORG is one good example that smaller CLECs don't jump right into. You'll still need other carriers for LD and International as well.

Have you taken into account supplementary services like e911 (you'll need a listing provider like Intrado if you plan to have local trunks, or a nomadic solution like Bandwidth/Dash/iNetwork and 911-enable), OSDA, CNAM and LNP dipping?

Some other items you'll want to research include the costs and processes for getting the other details setup, like switch CLLIs, point codes, OCNs, TN block assignments...

Hope that helps,

-Scott

-----Original Message----- From: voiceops-bounces at voiceops.org [mailto:voiceops-bounces at voiceops.org] On Behalf Of Ryan Finnesey Sent: Wednesday, October 17, 2012 8:19 PM To: Anthony Orlando Cc: VoiceOps Subject: Re: [VoiceOps] Direct CLEC interconnect - taking the plunge

Backup Telecom is great.

Sent from my iPad

On Oct 17, 2012, at 8:14 PM, "Anthony Orlando" <avorlando at yahoo.com> wrote:

...

Backup Telecom would be my first choice. Mary Lou Carey. She's on this board.

On Oct 17, 2012, at 18:39, Jay Hennigan <jay at west.net> wrote:

...

We are a regional hosted VoIP provider in California. We started as an ISP and moved into becoming a CLEC offering VOIP. As is probably the case with most, we started buying DIDs from wholesale carriers as SIP trunks. The majority of our customers are within a single LATA with a large minority in an adjoining one.

We are investigating the feasibility of direct interconnect with the RBOC/ILEC via SS7.

I'm interested in pointers/gotchas as well as recommendations of a consultant to help us navigate the maze, both from a political and technical standpoint. Suggestions as what not to do or who not to hire are also welcome.

Please feel free to respond on-list or off as you feel appropriate. -- _______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

-- Joe Fratantoni Cygnus Communications 19635 97th Ave Mokena, IL 60448 815.680.5686 x206 Business Internet & Phone Services

Porting control is what made us set up our own local interconnects. Way to many people in the middle causing porting issues. Carlos Alcantar Race Communications / Race Team Member 1325 Howard Ave. #604, Burlingame, CA. 94010 Phone: +1 415 376 3314 / carlos at race.com / http://www.race.com -----Original Message----- From: Jay Hennigan <jay at west.net> Date: Thursday, October 18, 2012 11:02 AM To: VoiceOps <voiceops at voiceops.org> Subject: Re: [VoiceOps] Direct CLEC interconnect - taking the plunge On 10/18/12 10:27 AM, Joe Fratantoni wrote:

Yet another recommendation here for Mary Lou, we have used her with much success since our transition into becoming a CLEC. I still call her regularly with questions; an infinite source of knowledge!

I think Scott really hit the nail on the head here. The ONLY real reasons to become a CLEC nowadays are access to customer loops, LEC duct, and right-of-ways. That's about it. The whole experience is, quite bluntly, a pain in the ass. When you aren't dealing with the usual regulatory upkeep; prepare for the LEC to fight you tooth and nail every step of the way.

We are already a CLEC - for access to customer loops, duct, and right-of-way. The reasons we are looking for direct interconnect: * The majority of our customers are in one LATA. * Shorter and consistent path back to the TDM world (fax, anyone?) * More control over the porting process. * Avoiding "Your intermittent issue is at an upstream carrier that we can't name (Voldemort?) and we've asked them to fix it. They report that it's with an upstream carrier of theirs that they can't name..." The last one is really aggravating when it happens, which seems to be more and more frequently.

If you are still committed to this, now is the time to address all of the things you won't want to deal with later.

If you're going to colocate in the CO, how are you going to bring connectivity to it? Is there dark fiber inner-office transport available? Are there other colocators there you can source this from? Are you going to be using remote entrance facilities? Is there duct available for you to utilize? (~$2/ft mrc) Is there a decent customer base you can service with DSL? What is the condition of the phone lines? Is it an old farm town with 100+ year old paper-insulated copper pairs that are going to cause your customers issues?

Already in multiple local COs with DSLAMs, SHDSL, dark fiber.

Time-wise, it is feasible for one person to manage all of your CLEC billing, ordering, numbers and portability, AOCN stuff, etc. BUT that WILL be that persons FULL TIME job. Don't trick yourself into thinking you can tackle all of these things and then your normal daily tasks. Hire someone full-time to deal with all of your ordering/support/carrier and lec responsibilities, and have Mary Lou train that person.

Good advice. We already have a person dealing with much of this. Ordering loops, CO co-location etc. And we have people dealing with number ports, e-911 location updates, etc with the other carriers. And the below is gold - going in our wiki and being passed on. Many thanks!

Specific Gotchas:

-Make sure the LEC does not require you to have E911 trunks to every area you have DID blocks in!!! Since you are a VOIP provider operating in a few areas, you likely will want to have DID blocks local to different areas. The LEC could force you to have circuits in every area with ambiguous ICA wording.

-Make sure your ICA has the verbage that dictates the 25% utilization limit of spare strands does not apply to instances where 6 or less strands exist.

-Obtain, in writing, with contact names and numbers the exact process in which you request a dark fiber inquiry/field survey. Hint hint: if they are saying you need to fill out an ASR; that not correct.

-Make sure you complete a pre-construction site visit request for COs you're interested in BEFORE you colo or even start the application process. Use this visit to make sure rooftop is available where you need it to be, and take a look at the collocation areas; write down the names and numbers (usually on the racks and cages) of the other colocators. These guys will be your best friends when it comes to getting IP in and out of that CO on the cheap. Get quotes and your network layout done BEFORE jumping into the colo. Do not count on LEC transport being available, feasible, or cheap.

-Separate everything, everything, everything into different corporations and BANs. When possible while peering/interconnecting with other colocators, have THEM order the cross-connect loops to have them on separate BANs. Make sure your billing dispute sections in your ICA do NOT require a deposit of payment in question before being able to dispute it, and that it does NOT allow the LEC to terminate your access trunks for non-payment, even on disputed amounts. Basically, you do not want the LEC to be able to extort money from you by killing your access trunks. You WILL have billing disputes, you WILL be asked to pay absolute incorrect nonsense. Incorrect nonsense that could get into 6 figures. Do you really want to be forced into paying an erroneous $100,000+ amount to have your service restored? Have a good telcom attorney, and be ready to pay him or her lots of money.

-Figure out how your PUC handles complaints, disputes, and mediation. Look up previous CLEC-LEC issues with the PUC and inform yourself of some of the pitfalls they are currently experiencing. Now is your chance to slide language into your ICA that may prevent you from falling into the same issues and might actually give your CLEC buddies ground to stand on with their requests.

-Keep DETAILED CIRCUIT LOGS, with PONs, CFAs, etc. If you have the programming ability, design your own ordering system and apply for XML Gateway ordering. Store a copy of all orders.

-Apply for refund money from the LEC. AT&T has a program for CLECs in CA to be compensated when they miss order deadlines, turnups, etc. It is automatically calculated and paid if you are registered. Some fellow CLECs in the area are making thousands per month on this.

-Do NOT account for termination fees in your business model.

-Install and use an internal wiki religiously. Every contact you make, every scrap of information you gather. Names of engineers, technicians, CO managers, tricks for ordering/templates.

-MAKE FRIENDS WITH EVERYBODY, NO MATTER WHAT. No matter how wrong the LEC is, no matter how much you think they are intentionally screwing you around, stay polite, friendly, always. No threats of legal action, no harsh words, do not cite ICA or reman text if you can help it, do not pass go, do not collect $200. Explain your requests in a friendly, personable manner, and only cite backup documentation or examples if you need it. Avoid debates on language. It doesn't matter what is written, you get things done by knowing who to ask and how to ask. Plain and simple. Create a budget for taking LEC personnel out, for sending them gift baskets, thank yous. Keep in touch with them (you are storing there contact information in your new wiki right?). Don't over-burden them, don't overwhelm them with requests. Try to avoid escalations if at all possible, they just make people less eager to help you. I certainly wouldn't like it if you demanded to speak to my 'boss' because you didn't like an answer I gave you on something I didn't feel you were entitled to; and I would be less inclined to help you with future requests. Remember, these people do not share your viewpoint or interest in getting things working for you. In their eyes, you are coming into their facilities, and using their network to steal their own customers.. So be nice.

-Expanding upon above: This industry is very very large, but very very tiny at the same time. You will run into all of the same people over and over again. Bear that in mind.

-In regards to call completion.. going through the LEC is not as easy as dumping your calls to various sip carriers. When you have call completion issues (you will), you can't just pick up the phone an ask the LEC to fix it. They'll do an SS7 trap for you and ensure they are passing the call along proper (and it is difficult to get them to do that! Remember: it's who you know..) It is your responsible to work out all routing/translations issues with the other carriers. Start building your contact list now, and again, friendly. There are only a few individuals at every major carrier on this planet that deal with routing/translations. Make them like you. Your business will come to a grinding halt real fast if one day half or more of your customer base can't seem to dial Verizon or Sprint or whoevers numbers in a certain area for some reason, and you don't have a contact over there to help you with that. Don't think going through their support lines, whoelsale lines, or NOCs are going to get you anywhere either.

-Create and enforce trading partner agreements!!! Now is your chance to get all of the contact information you ever wanted. When you receive a port-out request, force the porting carrier to first establish a 'trading partner agreement'. Send them a form to fill out, and detail your procedures (where they need to send there requests, to whom, what to include) but also force them to fill out call completion issue contact information, their own procedures for handling port outs, escalation lists, managers names and numbers. They WILL get it and give it to you. Verify it all before allowing a port.

Good luck!

Feel free to call me any time with questions as well,

Joe Fratantoni Cygnus Communications 19635 97th Ave Mokena, IL 60448 815.680.5686 x206 Business Internet & Phone Services

-- Jay Hennigan - CCIE #7880 - Network Engineering - jay at impulse.net Impulse Internet Service - http://www.impulse.net/ Your local telephone and internet company - 805 884-6323 - WB6RDV _______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops