20100927_3091.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KEMPTON
COMMISSIONER SMITH
CO MMISSI 0 NER RED FO RD
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:GRACE SEAMAN
DATE:SEPTEMBER 23, 2010
RE:POTLATCH TELEPH ONE CO MP ANY AD VI CE LETTER 10-03 TO ADD
AN EXCEPTION TO THE COMPANY'S INTRASTATE ACCESS
SERVICES AGREEMENT.
On September 1 , 2010, Potlatch Telephone Company (Potlatch) filed Tariff Advice
Letter 10-03 seeking approval to add an exception to the Company s Intrastate Access Services
Agreement. The exception will include jurisdictional report requirement provisions and will
include language to establish a 10% floor for terminating access minutes when originating
number information is lacking, but is necessary to determine the jurisdiction. Potlatch states that
the practice of setting a threshold for unidentified traffic is common in the industry and is the
result of a consistent problem with under-reporting originating information on the call detail
records. Potlatch further asserts that modifying the process for unidentified traffic that exceeds a
percentage threshold will help to reduce any financial incentive for inaccurate or inattentive
reporting of call detail. Carriers will be notified of this change in the Carrier Access Billing
System (CABS) bill. Potlatch requests an effective date of October 1 2010.
ST AFF DISCUSSION
Potlatch Telephone Company is a Title 61 company. Unidentified carrier traffic is a call
that is associated with a carrier, but does not provide the information that identifies the call as an
intra or inter state call. An unidentified call often defaults to the less expensive interstate traffic
rate which creates an economic disadvantage for the incumbent local exchange company (ILEC).
Unidentified traffic is a growing administrative and financial problem for ILECs. Staff discussed
DECISION MEMORANDUM - 1 -SEPTEMBER 23 2010
with Potlatch alternative methods of resolving this problem including the determination of the
carrier s ratio of inter versus intrastate minutes of use and the application of this ratio to the
unidentified traffic. The Company states that this method requires that the carrier provide
Potlatch with sufficient call record detail in order to apply the appropriate access rates. This is
difficult when some carriers have a significant amount of unidentified traffic (as much as 50%).
Another alternative looked at applying the carrier s declared percent of interstate usage
(PIU)l to the unidentified traffic. Potlatch asserts that it is not uncommon for the PIUs declared
by the carriers to have little resemblance to the actual ratio of inter versus intrastate for the
identifiable traffic. There is limited availability for validation or auditing of the carrier
submitted jurisdictional factors. The application of these declared unaudited factors to a high
proportion of the traffic can provide a financial incentive for the carriers and a disincentive for
ILECs.
ST AFF ANALYSIS
Staff has reviewed the filing and believes the proposed changes are reasonable and
recommends approval of this filing.
COMMISSION DECISION
Does the Commission agree?
Ih~u ~c~
Grace Seaman
UdmemoslPotAdvLtri 0-
IPIU refers to the amount of interstate traffic and thus subject to FCC authority.
DECISION MEMORANDUM - 2 -SEPTEMBER 23 2010